[Federal Register Volume 88, Number 170 (Tuesday, September 5, 2023)]
[Proposed Rules]
[Pages 60746-60865]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-17583]
[[Page 60745]]
Vol. 88
Tuesday,
No. 170
September 5, 2023
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for Walk-In
Coolers and Freezers; Proposed Rule
Federal Register / Vol. 88, No. 170 / Tuesday, September 5, 2023 /
Proposed Rules
[[Page 60746]]
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DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2017-BT-STD-0009]
RIN 1905-AD79
Energy Conservation Program: Energy Conservation Standards for
Walk-In Coolers and Freezers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and announcement of public
meeting.
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SUMMARY: The Energy Policy and Conservation Act, as amended (``EPCA''),
prescribes energy conservation standards for various consumer products
and certain commercial and industrial equipment, including walk-in
coolers and freezers (``walk-ins'' or ``WICFs''). EPCA also requires
the U.S. Department of Energy (``DOE'') to periodically determine
whether more-stringent, standards would be technologically feasible and
economically justified, and would result in significant energy savings.
In this notice of proposed rulemaking (``NOPR''), DOE proposes amended
energy conservation standards for walk-ins, and also announces a public
meeting to receive comment on these proposed standards and associated
analyses and results.
DATES:
Comments: DOE will accept comments, data, and information regarding
this NOPR no later than November 6, 2023.
Meeting: DOE will hold a public meeting via webinar on Wednesday,
September 27, 2023, from 1:00 p.m. to 4:00 p.m. See section VII,
``Public Participation,'' for webinar registration information,
participant instructions and information about the capabilities
available to webinar participants.
Comments regarding the likely competitive impact of the proposed
standard should be sent to the Department of Justice contact listed in
the ADDRESSES section on or before October 5, 2023.
Interested persons are encouraged to submit comments using the
Federal eRulemaking Portal at www.regulations.gov under docket number
EERE-2017-BT-STD-0009. Follow the instructions for submitting comments.
Alternatively, interested persons may submit comments, identified by
docket number EERE-2017-BT-STD-0009, by any of the following methods:
(1) Email: [email protected]. Include the docket number
EERE-2017-BT-STD-0009 in the subject line of the message.
(2) Non-electronic submissions: Please contact (202) 287-1445 for
instructions if an electronic copy cannot be submitted.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section VII of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting documents/materials,
is available for review at www.regulations.gov. All documents in the
docket are listed in the www.regulations.gov index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
The docket web page can be found at www.regulations.gov/docket/EERE-2017-BT-STD-0009. The docket web page contains instructions on how
to access all documents, including public comments, in the docket. See
section VII of this document for information on how to submit comments
through www.regulations.gov.
EPCA requires the Attorney General to provide DOE a written
determination of whether the proposed standard is likely to lessen
competition. The U.S. Department of Justice Antitrust Division invites
input from market participants and other interested persons with views
on the likely competitive impact of the proposed standard. Interested
persons may contact the Division at [email protected] on or
before the date specified in the DATES section. Please indicate in the
``Subject'' line of your email the title and Docket Number of this
proposed rulemaking.
FOR FURTHER INFORMATION CONTACT:
Mr. Troy Watson, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Email:
[email protected].
Mr. Matthew Schneider, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (240) 597-6265. Email:
[email protected].
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact the Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Walk-Ins
C. Deviation From Process Rule
1. Public Comment Period
III. General Discussion
A. General Comments
B. Scope of Coverage
C. Test Procedure
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared To Increase in Price (LCC
and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Equipment
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Equipment Classes
a. Doors
b. Panels
c. Refrigeration Systems
2. Technology Options
a. Fully Assembled Walk-Ins
b. Doors and Panels
c. Refrigeration Systems
B. Screening Analysis
1. Screened Out Technologies
a. Fully Assembled Walk-Ins
b. Doors and Panels
c. Refrigeration Systems
2. Remaining Technologies
a. Doors and Panels
b. Refrigeration Systems
C. Engineering Analysis
1. Efficiency Analysis
a. Display Doors
b. Non-Display Doors
c. Panels
d. Dedicated Condensing Units and Single-Packaged Dedicated
Systems
e. Unit Coolers
2. Cost Analysis
a. Teardown Analysis
b. Cost Estimation Method
c. Manufacturing Production Costs
d. Manufacturer Markup and Shipping Costs
[[Page 60747]]
3. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
1. Trial Standard Levels
2. Energy Use of Envelope Components
3. Energy Use of Refrigeration Systems
a. Fan Power
b. Nominal Daily Run Hours
4. Estimated Annual Energy Consumption
F. Life-Cycle Cost and Payback Period Analysis
1. Equipment Cost
2. Consumer Sample
3. Installation Cost
4. Annual Energy Consumption
5. Energy Prices
a. Future Electricity Prices
6. Maintenance and Repair Costs
7. Equipment Lifetimes
8. Discount Rates
9. Energy Efficiency Distribution in the No-New-Standards Case
10. Payback Period Analysis
G. Shipments Analysis
1. Price Elasticity
2. Shipments Results
H. National Impact Analysis
1. Product Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
1. High Warm Air-Infiltration Applications
2. Small Businesses
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Capital and Product Conversion Costs
d. Manufacturer Markup Scenarios
3. Manufacturer Interviews
a. Increasing Insulation Thickness
b. Reduced Anti-Sweat Heat
c. Refrigerant Regulation
4. Discussion of MIA Comments
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous Oxide
2. Monetization of Other Emissions Impacts
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Walk-Ins
Standards
a. Doors
b. Panels
c. Refrigeration Systems
2. Annualized Benefits and Costs of the Proposed Standards
D. Reporting, Certification, and Sampling Plan
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866, 13563, and 14094
B. Review Under the Regulatory Flexibility Act
1. Description of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, Rule
3. Description on Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements Including
Differences in Cost, if Any, for Different Groups of Small Entities
a. Doors
b. Panels
c. Refrigeration Systems
5. Duplication, Overlap, and Conflict With Other Rules and
Regulations
6. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Webinar
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
The Energy Policy and Conservation Act, Public Law 94-163, as
amended (``EPCA''),\1\ authorizes DOE to regulate the energy efficiency
of a number of consumer products and certain industrial equipment. (42
U.S.C. 6291-6317) Title III, Part C of EPCA,\2\ established the Energy
Conservation Program for Certain Industrial Equipment. (42 U.S.C. 6311-
6317) Such equipment includes walk-ins,\3\ the subject of this
rulemaking.
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\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020), which reflect the last statutory amendments that impact
Parts A and A-1 of EPCA.
\2\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
\3\ Walk-in coolers and walk-in freezers are defined as an
enclosed storage space, including but not limited to panels, doors,
and refrigeration systems, refrigerated to temperatures,
respectively, above, and at or below 32 degrees Fahrenheit that can
be walked into, and has a total chilled storage area of less than
3,000 square feet; however, the terms do not include products
designed and marketed exclusively for medical, scientific, or
research purposes. 10 CFR 431.302.
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Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that DOE determines is technologically feasible and
economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A))
Furthermore, the new or amended standard must result in a significant
conservation of energy. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(B))
EPCA also provides that not later than 6 years after issuance of any
final rule establishing or amending a standard, DOE must publish either
a notice of determination that standards for the product do not need to
be amended, or a notice of proposed rulemaking including new proposed
energy conservation standards (proceeding to a final rule, as
appropriate). (42 U.S.C. 6316(a); 42 U.S.C. 6295(m))
In accordance with these and other statutory provisions discussed
in this document, DOE analyzed the benefits and burdens of three trial
standard levels (``TSLs'') for walk-ins. The TSLs and their associated
benefits and burdens are discussed in detail in sections V.A through
V.C of this document. As discussed in section V.C of this document, DOE
has tentatively determined that TSL 2 represents the maximum
improvement in energy efficiency that is technologically feasible and
economically justified. The proposed standards for walk-in non-display
doors, which are expressed in maximum daily energy consumption in
kilowatt-hours per day (``kWh/day''), are shown in Table I.1. These
proposed standards, if adopted, would apply to all non-display doors of
walk-ins listed in Table I.1 manufactured in, or imported into, the
United States starting on the date 3 years after the publication of the
final rule for this proposed rulemaking.
[[Page 60748]]
Table I.1--Proposed Energy Conservation Standards for Walk-In Non-Display Doors
[TSL 2]
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Equipment class
--------------------------------------------------------------------------------------- Maximum daily energy
Display/non-display Opening mechanism Temperature consumption (kWh/day) *
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Non-Display......................... Manual................. Medium................. 0.01 x And + 0.25
Low.................... 0.06 x And + 1.32
Manual................. Medium................. 0.01 x And + 0.39
Low.................... 0.05 x And + 1.56
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* And is the representative value of surface area of the non-display door as determined in accordance with the
DOE test procedure at 10 CFR part 431, subpart R, appendix A and applicable sampling plans.
The proposed standards for walk-in refrigeration systems, which are
expressed as annual walk-in energy factor 2 (``AWEF2'') in British
thermal units per Watt-hour (``Btu/W-h''), are shown in Table I.2.
These proposed standards, if adopted, would apply to all walk-in
refrigeration systems listed in Table I.2 manufactured in, or imported
into, the United States starting on the date 3 years after the
publication of the final rule for this proposed rulemaking.
Table I.2--Proposed Energy Conservation Standards for Walk-In
Refrigeration Systems
[TSL 2]
------------------------------------------------------------------------
Equipment class Minimum AWEF2 (Btu/W-h) *
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Dedicated Condensing System--
High, Indoor, Non-Ducted with a
Net Capacity (qnet) of:
<7,000 Btu/h................. 7.80E-04 x qnet + 2.20
>=7,000 Btu/h................ 7.66
Dedicated Condensing system--
High, Outdoor, Non-Ducted with a
Net Capacity (qnet) of:
<7,000 Btu/h................. 1.02E-03 x qnet + 2.47
>=7,000 Btu/h................ 9.62
Dedicated Condensing system--
High, Indoor, Ducted with a Net
Capacity (qnet) of:
<7,000 Btu/h................. 2.46E-04 x qnet + 1.55
>=7,000 Btu/h................ 3.27
Dedicated Condensing system--
High, Outdoor, Ducted with a Net
Capacity (qnet) of:
<7,000 Btu/h................. 3.76E-04 x qnet + 1.78
>=7,000 Btu/h................ 4.41
Dedicated Condensing unit and
Matched Refrigeration System--
Medium, Indoor with a Net
Capacity (qnet) of:
<8,000 Btu/h................. 5.58
>=8,000 Btu/h and <25,000 Btu/ 3.00E-05 x qnet + 5.34
h.
>=25,000 Btu/h............... 6.09
Dedicated Condensing unit and
Matched Refrigeration System--
Medium, Outdoor with a Net
Capacity (qnet) of:
<25,000 Btu/h................ 2.13E-05 x qnet + 7.15
>=25,000 Btu/h............... 7.68
Dedicated Condensing unit and
Matched Refrigeration System--
Low, Indoor with a Net Capacity
(qnet) of:
<25,000 Btu/h................ 2.50E-05 x qnet + 2.36
>=25,000 Btu/h and <54,000 1.72E-06 x qnet + 2.94
Btu/h.
>=54,000 Btu/h............... 3.03
Dedicated Condensing unit and
Matched Refrigeration System--
Low, Outdoor with a Net Capacity
(qnet) of:
<9,000 Btu/h................. 9.83E-05 x qnet + 2.63
>=9,000 Btu/h and <25,000 Btu/ 3.06E-05 x qnet + 3.23
h.
>=25,000 Btu/h and <75,000 4.96E-06 x qnet + 3.88
Btu/h.
>=75,000 Btu/h............... 4.25
Single-Packaged Dedicated
Condensing system--Medium,
Indoor with a Net Capacity
(qnet) of:
<9,000 Btu/h................. 9.86E-05 x qnet + 4.91
>=9,000 Btu/h................ 5.8
Single-Packaged Dedicated
Condensing system--Medium,
Outdoor with a Net Capacity
(qnet) of:
<9,000 Btu/h................. 2.47E-04 x qnet + 4.89
>=9,000 Btu/h................ 7.11
Single-Packaged Dedicated
Condensing system--Low, Indoor
with a Net Capacity (qnet) of:
<6,000 Btu/h................. 8.00E-05 x qnet + 1.8
>=6,000 Btu/h................ 2.28
Single-Packaged Dedicated
Condensing system--Low, Outdoor
with a Net Capacity (qnet) of:
<6,000 Btu/h................. 1.63E-04 x qnet + 1.8
>=6,000 Btu/h................ 2.77
Unit Cooler--High Non-Ducted with
a Net Capacity (qnet) of:
<9,000 Btu/h................. 10.34
>=9,000 Btu/h and <25,000 Btu/ 3.83E-04 x qnet + 6.9
h.
>=25,000 Btu/h............... 16.46
Unit Cooler--High Ducted with a
Net Capacity (qnet) of:
<9,000 Btu/h................. 6.93
>=9,000 Btu/h and <25,000 Btu/ 3.64E-04 x qnet + 3.66
h.
>=25,000 Btu/h............... 12.76
Unit Cooler--Medium.......... 9.65
[[Page 60749]]
Unit Cooler--Low............. 4.57
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* qnet is the representative value of net capacity in Btu/h as
determined in accordance with the DOE test procedure at 10 CFR part
431, subpart R, appendix C1 and applicable sampling plans.
A. Benefits and Costs to Consumers
Table I.3 through Table I.5 present DOE's evaluation of the
economic impacts of the proposed standards on consumers of walk-ins, as
measured by the average life-cycle cost (``LCC'') savings and the
simple payback period (``PBP'').\4\ The average LCC savings are
positive for all equipment classes, and the PBP is less than the
average lifetime of walk-ins, which is estimated to be between 8 and 20
years (see section IV.F.10 of this document).
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\4\ The average LCC savings refer to consumers that are affected
by a standard and are measured relative to the efficiency
distribution in the no-new-standards case, which depicts the market
in the compliance year in the absence of new or amended standards
(see section IV.F.9 of this document). The simple PBP, which is
designed to compare specific efficiency levels, is measured relative
to the baseline product (see section IV.F of this document).
\5\ All monetary values in this document are expressed in 2022
dollars.
Table I.3--Impacts of Proposed Energy Conservation Standards on Consumers of Walk-In Display and Non-Display
Doors
[TSL 2] \5\
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Average LCC
Display/non-display Opening mechanism Temperature savings Simple payback
(2022$) period (years)
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Display........................... Manual............... Low.................. .............. ..............
Medium............... .............. ..............
Non-Display....................... Manual............... Low.................. 723 1.3
Medium............... 86 3.2
Motorized............ Low.................. 1,192 1.0
Medium............... 113 2.4
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Table I.4--Impacts of Proposed Energy Conservation Standards on Consumers of Walk-In Panels
[TSL 2]
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Average LCC
Equipment Temperature savings Simple payback
(2022$) period (years)
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Structural.................................... Low............................. .............. ..............
Medium.......................... .............. ..............
Floor......................................... Low............................. .............. ..............
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Table I.5--Impacts of Proposed Energy Conservation Standards on Consumers of Walk-in Refrigeration Systems
[TSL 2]
----------------------------------------------------------------------------------------------------------------
Average LCC
System Temperature Location savings Simple payback
(2022$) period (years)
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Dedicated Condensing Unit and Low.................. Indoor............... 163 4.0
Matched Refrigeration System. Outdoor.............. 172 3.6
Medium............... Indoor............... 567 3.4
Outdoor.............. 136 2.6
Unit Cooler....................... Low.................. N/A.................. 1,306 1.2
Medium............... 212 2.0
High................. .............. ..............
High, Ducted......... 237 0.7
Matched Refrigeration Systems and High, Non-Ducted..... Indoor............... 124 1.3
Single-Packaged Dedicated Systems. Outdoor.............. 126 2.9
High, Ducted......... Indoor............... 296 1.7
Outdoor.............. 305 3.4
[[Page 60750]]
Single-Packaged Dedicated Systems. Low.................. Indoor............... 180 3.8
Outdoor.............. .............. ..............
Medium............... Indoor............... 103 3.5
Outdoor.............. 177 1.2
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DOE's analysis of the impacts of the proposed standards on
consumers is described in section IV.F of this document.
B. Impact on Manufacturers 6
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\6\ All monetary values in this document are expressed in 2022
dollars unless otherwise noted.
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The industry net present value (``INPV'') is the sum of the
discounted cash flows to the industry from the base year through the
end of the analysis period (2023-2056). Using a real discount rate of
9.4 percent for doors, 10.5 percent for panels, and 10.2 percent for
refrigeration systems, DOE estimates that the INPV for manufacturers of
walk-in display doors, non-display doors, panels, and refrigeration
systems in the case without amended standards is $278.0 million, $536.7
million, $875.2 million, and $490.1 million, respectively. Under the
proposed standards, all walk-in display door equipment classes remain
at the baseline efficiency level. As a result, there are no changes to
INPV and no conversion costs for display door manufacturers. Under the
proposed standards, the change in INPV for non-display door
manufacturers is estimated to range from -4.8 percent to -2.6 percent,
which is approximately -$25.5 million to -$14.2 million. Under the
proposed standards, all walk-in panel equipment classes remain at the
baseline efficiency level. As a result, there are no changes to INPV
and no conversion costs for panel manufacturers. Under the proposed
standards, the change in INPV for refrigeration system manufacturers is
estimated to range from -9.8 percent to -7.7 percent, which is
approximately -$47.8 million to -$37.9 million. In order to bring
equipment into compliance with amended standards, it is estimated that
the walk-in non-display door and refrigeration system industries would
incur total conversion costs of $28.9 million and $60.1 million,
respectively.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this document. The
analytic results of the manufacturer impact analysis (``MIA'') are
presented in section V.B.2 of this document.
C. National Benefits and Costs
DOE's analyses indicate that the proposed energy conservation
standards for walk-ins would save a significant amount of energy.
Relative to the case without amended standards, the lifetime energy
savings for walk-ins purchased in the 30-year period that begins in the
anticipated year of compliance with the amended standards (2027-2056)
amount to 1.51 quadrillion British thermal units (``Btu''), or
quads.\7\ This represents a savings of 6 percent relative to the energy
use of these products in the case without amended standards (referred
to as the ``no-new-standards case'').
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\7\ The quantity refers to full-fuel-cycle (``FFC'') energy
savings. FFC energy savings includes the energy consumed in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and, thus, presents a more complete
picture of the impacts of energy efficiency standards. For more
information on the FFC metric, see section IV.H.2 of this document.
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The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for walk-ins ranges from $1.45
billion (at a 7-percent discount rate) to $3.66 billion (at a 3-percent
discount rate). This NPV expresses the estimated total value of future
operating-cost savings minus the estimated increased product costs and
installation costs for walk-ins purchased in 2027-2056.
In addition, the proposed standards for walk-ins are projected to
yield significant environmental benefits. DOE estimates that the
proposed standards would result in cumulative emission reductions (over
the same period as for energy savings) of 28.5 million metric tons
(``Mt'') \8\ of carbon dioxide (``CO2''), 8.8 thousand tons
of sulfur dioxide (``SO2''), 52.9 thousand tons of nitrogen
oxides (``NOX''), 237.4 thousand tons of methane
(``CH4''), 0.3 thousand tons of nitrous oxide
(``N2O''), and 0.1 tons of mercury (``Hg'').\9\
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\8\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\9\ DOE calculated emissions reductions relative to the no-new-
standards-case, which reflects key assumptions in the Annual Energy
Outlook 2023 (``AEO2023''). AEO2023 reflects, to the extent
possible, laws and regulations adopted through mid-November 2022,
including the Inflation Reduction Act. See section IV.K of this
document for further discussion of AEO2023 assumptions that effect
air pollutant emissions.
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DOE estimates the value of climate benefits from a reduction in
greenhouse gases (GHG) using four different estimates of the social
cost of CO2 (``SC-CO2''), the social cost of
methane (``SC-CH4''), and the social cost of nitrous oxide
(``SC-N2O''). Together these represent the social cost of
GHG (``SC-GHG''). DOE used interim SC-GHG values (in terms of benefit
per ton of GHG avoided) developed by an Interagency Working Group on
the Social Cost of Greenhouse Gases (``IWG'').\10\ The derivation of
these values is discussed in section IV.L of this document. For
presentational purposes, the climate benefits associated with the
average SC-GHG at a 3-percent discount rate are estimated to be $1.6
billion. DOE does not have a single central SC-GHG point estimate and
it emphasizes the importance and value of considering the benefits
calculated using all four sets of SC-GHG estimates.
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\10\ To monetize the benefits of reducing GHG emissions this
analysis uses the interim estimates presented in the Technical
Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990 published in February
2021 by the IWG. (``February 2021 SC-GHG TSD''). www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.
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DOE estimated the monetary health benefits of SO2 and
NOX emissions reductions using benefit-per-ton estimates
from the Environmental Protection Agency,\11\ as discussed in
[[Page 60751]]
section IV.L of this document. DOE estimated the present value of the
health benefits would be $1.3 billion using a 7-percent discount rate,
and $3.2 billion using a 3-percent discount rate.\12\ DOE is currently
only monetizing health benefits from changes in ambient fine
particulate matter (PM2.5) concentrations from two
precursors (SO2 and NOX), and from changes in
ambient ozone from one precursor (for NOX), but will
continue to assess the ability to monetize other effects such as health
benefits from reductions in direct PM2.5 emissions.
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\11\ U.S. EPA. Estimating the Benefit per Ton of Reducing
Directly Emitted PM2.5, PM2.5 Precursors and
Ozone Precursors from 21 Sectors. Available at www.epa.gov/benmap/estimating-benefit-ton-reducing-pm25-precursors-21-sectors.
\12\ DOE estimates the economic value of these emissions
reductions resulting from the considered TSLs for the purpose of
complying with the requirements of Executive Order 12866.
---------------------------------------------------------------------------
Table I.6 summarizes the monetized benefits and costs expected to
result from the proposed standards for walk-ins. There are other
important unquantified effects, including certain unquantified climate
benefits, unquantified public health benefits from the reduction of
toxic air pollutants and other emissions, unquantified energy security
benefits, and distributional effects, among others.
Table I.6--Summary of Monetized Benefits and Costs of Proposed Energy
Conservation Standards for Walk-Ins
[TSL 2]
------------------------------------------------------------------------
Billion 2022$
------------------------------------------------------------------------
3% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings...................... 4.7
Climate Benefits *................................... 1.6
Health Benefits **................................... 3.2
------------------
Total Benefits [dagger].......................... 9.5
------------------------------------------------------------------------
Consumer Incremental Product Costs [Dagger].......... 1.3
Net Benefits......................................... 8.2
Change in Producer Cashflow (INPV [Dagger][Dagger]).. (0.07) - (0.05)
------------------------------------------------------------------------
7% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings...................... 2.2
Climate Benefits * (3% discount rate)................ 1.6
Health Benefits **................................... 1.3
Total Benefits [dagger].............................. 5.1
Consumer Incremental Product Costs [Dagger].......... 0.7
Net Benefits......................................... 4.4
Change in Producer Cashflow (INPV [Dagger][Dagger]).. (0.07) - (0.05)
------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-in
coolers and freezers shipped in 2027-2056. These results include
consumer, climate, and health benefits that accrue after 2056 from the
walk-in coolers and freezers shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the
social cost of carbon (SC-CO2), methane (SC-CH4), and nitrous oxide
(SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent
discount rates; 95th percentile at 3 percent discount rate) (see
section IV.L of this document). Together these represent the global SC-
GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3 percent discount rate are
shown; however, DOE emphasizes the importance and value of considering
the benefits calculated using all four sets of SC-GHG estimates. To
monetize the benefits of reducing GHG emissions, this analysis uses
the interim estimates presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX
and SO2. DOE is currently only monetizing (for SO2 and NOX) PM2.5
precursor health benefits and (for NOX) ozone precursor health
benefits, but will continue to assess the ability to monetize other
effects such as health benefits from reductions in direct PM2.5
emissions. See section IV.L of this document for more details.
[dagger] Total and net benefits include those consumer, climate, and
health benefits that can be quantified and monetized. For presentation
purposes, total and net benefits for both the 3-percent and 7-percent
cases are presented using the average SC-GHG with 3-percent discount
rate.
[Dagger] Costs include incremental equipment costs as well as
installation costs.
[Dagger][Dagger] Operating Cost Savings are calculated based on the life
cycle costs analysis and national impact analysis as discussed in
detail. See sections IV.F and IV.H of this document. DOE's NIA
includes all impacts (both costs and benefits) along the distribution
chain beginning with the increased costs to the manufacturer to
manufacture the equipment and ending with the increase in price
experienced by the consumer. DOE also separately conducts a detailed
analysis on the impacts on manufacturers (the MIA). See section IV.J
of this document. In the detailed MIA, DOE models manufacturers'
pricing decisions based on assumptions regarding investments,
conversion costs, cashflow, and margins. The MIA produces a range of
impacts, which is the rule's expected impact on the INPV. The change
in INPV is the present value of all changes in industry cash flow,
including changes in production costs, capital expenditures, and
manufacturer profit margins. Change in INPV is calculated using the
industry weighted average cost of capital values of 9.4 percent for
walk-in non-display doors and 10.2 percent for walk-in refrigeration
systems that are estimated in the MIA (see chapter 12 of the NOPR TSD
for a complete description of the industry weighted average cost of
capital). For walk-ins, those values are -$73 million to -$52 million.
DOE accounts for that range of likely impacts in analyzing whether a
TSL is economically justified. See section V.C of this document. DOE
is presenting the range of impacts to the INPV under two markup
scenarios: the Preservation of Gross Margin scenario, which is the
manufacturer markup scenario used in the calculation of Consumer
Operating Cost Savings in this table, and the Preservation of
Operating Profit Markup scenario, where DOE assumed manufacturers
would not be able to increase per-unit operating profit in proportion
to increases in manufacturer production costs. DOE includes the range
of estimated INPV in the above table, drawing on the MIA explained
further in section IV.J of this document, to provide additional
context for assessing the estimated impacts of this proposal to
society, including potential changes in production and consumption,
which is consistent with OMB's Circular A-4 and E.O. 12866. If DOE
were to include the INPV into the net benefit calculation for this
proposed rule, the net benefits would range from $8.13 billion to
$8.15 billion at 3-percent discount rate and would range from $4.33
billion to $4.35 billion at 7-percent discount rate. Parentheses ( )
indicate negative values. DOE seeks comment on this approach.
[[Page 60752]]
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The monetary values for the
total annualized net benefits are (1) the reduced consumer operating
costs, minus (2) the increase in product purchase prices and
installation costs, plus (3) the value of climate and health benefits
of emission reductions, all annualized.\13\
---------------------------------------------------------------------------
\13\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2023, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2030), and then discounted the present value from each year
to 2023. Using the present value, DOE then calculated the fixed
annual payment over a 30-year period, starting in the compliance
year, that yields the same present value.
---------------------------------------------------------------------------
The national operating cost savings are domestic private U.S.
consumer monetary savings that occur as a result of purchasing the
covered products and are measured for the lifetime of walk-ins shipped
in 2027-2056. The benefits associated with reduced emissions achieved
as a result of the proposed standards are also calculated based on the
lifetime of walk-ins shipped in 2027-2056. Total benefits for both the
3-percent and 7-percent cases are presented using the average GHG
social costs with 3-percent discount rate. Estimates of SC-GHG values
are presented for all four discount rates in section IV.L of this
document.
Table I.7 presents the total estimated monetized benefits and costs
associated with the proposed standard, expressed in terms of annualized
values. The results under the primary estimate are as follows.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced NOx and SO2 emissions, and the
3-percent discount rate case for climate benefits from reduced GHG
emissions, the estimated cost of the standards proposed in this rule is
$70.7 million per year in increased equipment costs, while the
estimated annual benefits are $214.1 million in reduced equipment
operating costs, $90.4 million in climate benefits, and $132.2 million
in health benefits. In this case the net benefit would amount to $366.0
million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $72.4 million per year in
increased equipment costs, while the estimated annual benefits are
$260.0 million in reduced operating costs, $90.4 million in climate
benefits, and $177.7 million in health benefits. In this case, the net
benefit would amount to $455.7 million per year.
Table I.7--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Walk-ins
[TSL 2]
----------------------------------------------------------------------------------------------------------------
Million 2022$/year
-----------------------------------------------
Low-net- High-net-
Primary benefits benefits
estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
3% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 260.0 265.3 264.9
Climate Benefits *.............................................. 90.4 92.6 90.0
Health Benefits **.............................................. 177.7 182.1 177.0
-----------------------------------------------
Total Monetized Benefits [dagger]........................... 528.1 540.0 531.9
----------------------------------------------------------------------------------------------------------------
Consumer Incremental Product Costs [Dagger]..................... 72.4 102.6 64.7
Monetized Net Benefits.......................................... 455.7 437.4 467.2
Change in Producer Cashflow (INPV[Dagger][Dagger]).............. (7.6) - (5.4) (7.6) - (5.4) (7.6) - (5.4)
----------------------------------------------------------------------------------------------------------------
7% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 214.1 218.8 218.3
Climate Benefits * (3% discount rate)........................... 90.4 92.6 90.0
Health Benefits **.............................................. 132.2 135.3 131.7
-----------------------------------------------
Total Monetized Benefits [dagger]........................... 436.7 446.7 440.0
Consumer Incremental Product Costs [Dagger]..................... 70.7 95.4 64.1
Monetized Net Benefits.......................................... 366.0 351.2 376.0
Change in Producer Cashflow (INPV [Dagger][Dagger])............. (7.6) - (5.4) (7.6) - (5.4) (7.6) - (5.4)
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-ins shipped in 2027-2056. These results
include consumer, climate, and health benefits that accrue after 2056 from the products shipped in 2027-2056.
The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the
AEO2023 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition,
incremental equipment costs reflect a medium decline rate in the Primary Estimate, a low decline rate in the
Low Net Benefits Estimate, and a high decline rate in the High Net Benefits Estimate. The methods used to
derive projected price trends are explained in sections IV.F.1 and IV.H.3 of this document. Note that the
Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this
document). For presentational purposes of this table, the climate benefits associated with the average SC-GHG
at a 3 percent discount rate are shown; however, DOE emphasizes the importance and value of considering the
benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG
emissions, this analysis uses the interim estimates presented in the Technical Support Document: Social Cost
of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 published in February 2021
by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for SO2 and NOX) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. See section IV.L of this document for more details.
[dagger] Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-
percent discount rate.
[Dagger] Costs include incremental equipment costs as well as installation costs.
[[Page 60753]]
[Dagger][Dagger] Operating Cost Savings are calculated based on the life cycle costs analysis and national
impact analysis as discussed in detail below. See sections IV.F and IV.H of this document. DOE's NIA includes
all impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
manufacturer to manufacture the product and ending with the increase in price experienced by the consumer. DOE
also separately conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J of
this document. In the detailed MIA, DOE models manufacturers' pricing decisions based on assumptions regarding
investments, conversion costs, cashflow, and margins. The MIA produces a range of impacts, which is the rule's
expected impact on the INPV. The change in INPV is the present value of all changes in industry cash flow,
including changes in production costs, capital expenditures, and manufacturer profit margins. The annualized
change in INPV is calculated using the industry weighted average cost of capital values of 9.4 percent for
walk-in non-display doors and 10.2 percent for walk-in refrigeration systems that are estimated in the MIA
(see chapter 12 of the NOPR TSD for a complete description of the industry weighted average cost of capital).
For walk-ins, those values are -$7.6 million to -$5.4 million. DOE accounts for that range of likely impacts
in analyzing whether a TSL is economically justified. See section V.C of this document. DOE is presenting the
range of impacts to the INPV under two markup scenarios: the Preservation of Gross Margin scenario, which is
the manufacturer markup scenario used in the calculation of Consumer Operating Cost Savings in this table, and
the Preservation of Operating Profit Markup scenario, where DOE assumed manufacturers would not be able to
increase per-unit operating profit in proportion to increases in manufacturer production costs. DOE includes
the range of estimated annualized change in INPV in the above table, drawing on the MIA explained further in
section IV.J of this document, to provide additional context for assessing the estimated impacts of this
proposal to society, including potential changes in production and consumption, which is consistent with OMB's
Circular A-4 and E.O. 12866. If DOE were to include the INPV into the annualized net benefit calculation for
this proposed rule, the annualized net benefits would range from $448.1 million to $450.3 million at 3-percent
discount rate and would range from $358.4 million to $360.6 million at 7-percent discount rate. Parentheses (
) indicate negative values. DOE seeks comment on this approach.
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this document.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. Specifically, with regards to
technological feasibility, equipment achieving these standard levels
are already commercially available for all equipment classes covered by
this proposal. As for economic justification, DOE's analysis shows that
the benefits of the proposed standard exceed, to a great extent, the
burdens of the proposed standards.
Using a 7-percent discount rate for consumer benefits and costs and
NOx and SO2 reduction benefits, and a 3-percent discount
rate case for GHG social costs, the estimated cost of the proposed
standards for walk-ins is $70.7 million per year in increased equipment
costs, while the estimated annual benefits are $214.1 million in
reduced equipment operating costs, $90.4 million in climate benefits
and $132.2 million in health benefits. The net benefit amounts to
$366.0 million per year.
The significance of the savings offered by a new or amended energy
conservation standard cannot be determined without knowledge of the
specific circumstances surrounding a given rulemaking.\14\ For example,
some covered products and equipment have substantial energy consumption
occur during periods of peak energy demand. The impacts of these
products on the energy infrastructure can be more pronounced than
products with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis.
---------------------------------------------------------------------------
\14\ Procedures, Interpretations, and Policies for Consideration
in New or Revised Energy Conservation Standards and Test Procedures
for Consumer Products and Commercial/Industrial Equipment, 86 FR
70892, 70901 (Dec. 13, 2021).
---------------------------------------------------------------------------
As previously mentioned, the standards are projected to result in
estimated national energy savings of 1.55 quad FFC for walk-in doors,
panels and refrigeration systems shipped between 2027 and 2056, the
equivalent of the primary annual energy use of 42.7 million homes, or
1.4 million homes per year of the analysis. In addition, they are
projected to reduce CO2 emissions by 28.5 Mt for walk-in
doors, panels and refrigeration systems shipped between 2027 and
2056.\15\ Based on these findings, DOE has initially determined the
energy savings from the proposed standard levels are ``significant''
within the meaning of 42 U.S.C. 6295(o)(3)(B). A more detailed
discussion of the basis for these tentative conclusions is contained in
the remainder of this document and the accompanying technical support
document (``TSD'').
---------------------------------------------------------------------------
\15\ These results include benefits to consumers which accrue
after 2056 from the equipment shipped in 2027-2056.
---------------------------------------------------------------------------
DOE also considered more-stringent energy efficiency levels as
potential standards, and is still considering them in this rulemaking.
However, DOE has tentatively concluded that the potential burdens of
the more-stringent energy efficiency levels would outweigh the
projected benefits.
Based on consideration of the public comments DOE receives in
response to this document and related information collected and
analyzed during the course of this rulemaking effort, DOE may adopt
energy efficiency levels presented in this document that are either
higher or lower than the proposed standards, or some combination of
level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed rule, as well as some of the relevant
historical background related to the establishment of standards for
walk-ins.
A. Authority
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment.
Title III, Part C of EPCA, added by Public Law 95-619, Title IV,
section 441(a) (42 U.S.C. 6311-6317, as codified), established the
Energy Conservation Program for Certain Industrial Equipment, which
sets forth a variety of provisions designed to improve energy
efficiency. This equipment includes walk-ins, the subject of this
document. (42 U.S.C. 6311(1)(G)) EPCA prescribed initial standards for
these products. (42 U.S.C. 6313(f)) EPCA specifically prescribed that
no later than January 1, 2020, the Secretary shall publish a final rule
to determine if the standards should be amended. (42 U.S.C. 6313(f)(5))
EPCA further provides that, not later than 6 years after the issuance
of any final rule establishing or amending a standard, DOE must publish
either a notice of determination that standards for the product do not
need to be amended, or a NOPR including new proposed energy
conservation standards (proceeding to a final rule, as appropriate).
(42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1)).
The energy conservation program under EPCA consists essentially of
four parts: (1) testing, (2) labeling, (3) the establishment of Federal
energy conservation standards, and (4) certification and enforcement
procedures. Relevant provisions of EPCA include definitions (42 U.S.C.
6311), test procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C.
6315), energy conservation standards (42
[[Page 60754]]
U.S.C. 6313), and the authority to require information and reports from
manufacturers (42 U.S.C. 6316; 42 U.S.C. 6296).
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6316(a) and (b); 42 U.S.C. 6297) DOE may, however, grant waivers
of Federal preemption for particular State laws or regulations, in
accordance with the procedures and other provisions set forth under
EPCA. (See 42 U.S.C. 6316(a) (applying the preemption waiver provisions
of 42 U.S.C. 6297))
Subject to certain criteria and conditions, DOE is required to
develop test procedures to measure the energy efficiency, energy use,
or estimated annual operating cost of each covered equipment during a
representative average use cycle and that are not unduly burdensome to
conduct. (42 U.S.C. 6314(a)(2)) Manufacturers of covered equipment must
use the Federal test procedures as the basis for: (1) certifying to DOE
that their equipment complies with the applicable energy conservation
standards adopted pursuant to EPCA (42 U.S.C. 6316(a); 42 U.S.C.
6295(s)), and (2) making representations about the efficiency of that
equipment (42 U.S.C. 6314(d)). Similarly, DOE must use these test
procedures to determine whether the equipment complies with relevant
standards promulgated under EPCA. (42 U.S.C. 6316(a); 42 U.S.C.
6295(s)) The DOE test procedures for walk-ins appear at title 10 of the
Code of Federal Regulations (``CFR'') part 431, subpart R, appendices
A, B, C, and C1.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered equipment, including walk-ins. Any new or
amended standard for a covered product must be designed to achieve the
maximum improvement in energy efficiency that the Secretary of Energy
determines is technologically feasible and economically justified. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A)) Furthermore, DOE may not adopt
any standard that would not result in the significant conservation of
energy. (42 U.S.C. 6295(o)(3))
Moreover, DOE may not prescribe a standard: (1) for certain
products, including walk-ins, if no test procedure has been established
for the product, or (2) if DOE determines by rule that the standard is
not technologically feasible or economically justified. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed
standard is economically justified, DOE must determine whether the
benefits of the standard exceed its burdens. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after
receiving comments on the proposed standard, and by considering, to the
greatest extent practicable, the following seven statutory factors:
(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 the covered 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 standard;
(3) The total projected amount of energy (or as applicable, water)
savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered
products likely to result from 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
standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (``Secretary'') considers
relevant.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA establishes a rebuttable presumption that a standard
is economically justified if the Secretary finds that the additional
cost to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an ``anti-backsliding''
provision, which prevents the Secretary from prescribing any amended
standard that either increases the maximum allowable energy use or
decreases the minimum required energy efficiency of a covered product.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(1)) Also, 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. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for a covered product that has two or more
subcategories. DOE must specify a different standard level for a type
or class of product that has the same function or intended use, if DOE
determines that 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. (42 U.S.C.
6316(a); 42 U.S.C. 6295(q)(1)) In determining whether a performance-
related feature justifies a different standard for a group of products,
DOE must consider such factors as the utility to the consumer of the
feature and other factors DOE deems appropriate. Id. Any rule
prescribing such a standard must include an explanation of the basis on
which such higher or lower level was established. (42 U.S.C. 6316(a);
42 U.S.C. 6295(q)(2))
B. Background
1. Current Standards
The current energy conservation standards for walk-ins are set
forth in DOE's regulations at 10 CFR 431.306. The current energy
conservation standards for walk-in doors are in terms of maximum daily
energy consumption, which is measured in kWh/day (see Table II.1). The
current energy conservation standards for walk-in panels are in terms
of R-value, which is measured in h-ft\2\-[deg]F/Btu (see Table II.2).
The current energy conservation standards for refrigeration systems are
in terms of AWEF, which is measured in Btu/W-h (see Table II.3).
Table II.1--Federal Energy Conservation Standards for Walk-in Coolers
and Walk-In Freezer Doors
------------------------------------------------------------------------
Equations for maximum daily
Equipment class energy consumption (kWh/
day)
------------------------------------------------------------------------
Display door, medium-temperature.......... 0.04 x Add + 0.41.
Display door, low-temperature............. 0.15 x Add + 0.29.
Passage door, medium-temperature.......... 0.05 x And + 1.7.
Passage door, low-temperature............. 0.14 x And + 4.8.
[[Page 60755]]
Freight door, medium-temperature.......... 0.04 x And + 1.9.
Freight door, low-temperature............. 0.12 x And + 5.6.
------------------------------------------------------------------------
Add or And = surface area of the display door or non-display door,
respectively, expressed in ft\2\, as determined in appendix A to
subpart R of 10 CFR part 431.
Table II.2--Federal Energy Conservation Standards for Walk-In Coolers
and Walk-In Freezer Panels
------------------------------------------------------------------------
Minimum R-
value (h-
Equipment class ft\2\-[deg]F/
Btu)
------------------------------------------------------------------------
Wall or ceiling panels, medium-temperature.............. 25
Wall or ceiling panels, low-temperature................. 32
Floor panels, low-temperature........................... 28
------------------------------------------------------------------------
Table II.3--Federal Energy Conservation Standards for Walk-In Coolers
and Walk-In Freezer Refrigeration Systems
------------------------------------------------------------------------
Equipment class Minimum AWEF (Btu/W-h)
------------------------------------------------------------------------
Dedicated condensing system, medium- 5.61.
temperature, indoor.
Dedicated condensing system, medium- 7.60.
temperature, outdoor.
Dedicated condensing system, low- 9.091 x 105 x qnet + 1.81.
temperature, indoor with a net capacity
(qnet) of <6,500 British thermal units
per hour (``Btu/h'').
Dedicated condensing system, low- 2.40.
temperature, indoor with a net capacity
(qnet) of >=6,500 Btu/h.
Dedicated condensing system, low- 6.522 x 10-5 x qnet + 2.73.
temperature, outdoor with a net capacity
(qnet) of <6,500 Btu/h.
Dedicated condensing system, low- 3.15.
temperature, outdoor with a net capacity
(qnet) of >=6,500 Btu/h.
Unit cooler, medium-temperature........... 9.00.
Unit cooler, low-temperature, indoor with 1.575 x 10-5 x qnet + 3.91.
a net capacity (qnet) of <15,500 Btu/h.
Unit cooler, low-temperature, indoor with 4.15.
a net capacity (qnet) of >=15,500 Btu/h.
Where qnet is net capacity as determined
in accordance with 10 CFR 431.304 and
certified in accordance with 10 CFR part
429.
------------------------------------------------------------------------
2. History of Standards Rulemaking for Walk-Ins
In a final rule published on June 3, 2014 (``June 2014 Final
Rule''), DOE prescribed the energy conservation standards for walk-in
doors, panels, and refrigeration systems manufactured on and after June
5, 2017. 79 FR 32050. After publication of the June 2014 Final Rule,
the Air-Conditioning, Heating and Refrigeration Institute (``AHRI'')
and Lennox International, Inc. (``Lennox''), a manufacturer of walk-in
refrigeration systems, filed petitions for review of DOE's final rule
and DOE's subsequent denial of a petition for reconsideration of the
rule (79 FR 59090 (October 1, 2014)) with the United States Court of
Appeals for the Fifth Circuit. Lennox Int'l v. Dep't of Energy, Case
No. 14-60535 (5th Cir.). A settlement agreement was reached among the
parties under which the Fifth Circuit vacated energy conservation
standards for six of the refrigeration system equipment classes--the
two standards applicable to multiplex condensing refrigeration systems
(subsequently re-named as ``unit coolers'') operating at medium and
low-temperatures and the four standards applicable to dedicated
condensing refrigeration systems operating at low-temperatures.\16\
After the Fifth Circuit issued its order, DOE established a Working
Group to negotiate energy conservation standards to replace the six
vacated standards. 80 FR 46521 (August 5, 2015). The Working Group
assembled its recommendations into a Term Sheet (see Docket EERE-2015-
BT-STD-0016-0056) that was presented to, and approved by, the Appliance
Standards and Rulemaking Federal Advisory Committee on December 18,
2015. (EERE-2015-BT-STD-0016-0055 at p. 11)
---------------------------------------------------------------------------
\16\ The 13 other standards established in the June 2014 Final
Rule (i.e., the four standards applicable to dedicated condensing
refrigeration systems operating at medium temperatures; the three
standards applicable to panels; and the six standards applicable to
doors) were not vacated. The compliance date for the remaining
standards was on or after June 5, 2017.
---------------------------------------------------------------------------
In a final rule published on July 10, 2017 (``July 2017 Final
Rule''), DOE adopted energy conservation standards for the six classes
of walk-in refrigeration systems were vacated--specifically, unit
coolers and low-temperature dedicated condensing systems. 82 FR 31808.
The rule required compliance with the six new standards on and after
July 10, 2020.
To evaluate whether to propose amendments to the energy
conservation standards for walk-ins, DOE issued a request for
information (``RFI'') in the Federal Register on July 16, 2021 (``July
2021 RFI''). 86 FR 37687. In the July 2021 RFI, DOE sought data,
information, and comment pertaining to walk-ins. 86 FR 37687, 37689.
DOE subsequently announced the availability of the preliminary
analysis it had conducted for the purpose of evaluating the need for
amending the current energy conservation standards for walk-ins in the
Federal Register on June 30, 2022, (``June 2022 Preliminary
Analysis''). The analysis was set forth in the Department's
accompanying preliminary TSD. DOE held a public meeting via webinar to
discuss and receive comment on the June 2022 Preliminary Analysis on
July 22, 2022. The meeting covered the analytical framework, models,
and tools that DOE
[[Page 60756]]
used to evaluate potential standards; the results of the preliminary
analyses performed by DOE; the potential energy conservation standard
levels derived from those analyses; and other relevant issues.
In response to the publication of the July 2021 RFI, DOE received
comments from interested parties. The July 2021 RFI comments were
addressed in chapter 2 of the June 2022 Preliminary Analysis TSD.
DOE received comments in response to the June 2022 Preliminary
Analysis from the interested parties listed in Table II.4 of this
document.
---------------------------------------------------------------------------
\17\ AHRI submitted two comment documents to the docket. The
first document in the docket includes AHRI's comments for
traditional walk-in manufacturers (i.e., medium- and low-temperature
walk-in components). The associated file name in the docket is: AHRI
Comments WICF NOPR EERE-2017-BT-STD-0009. These comments are
referenced in this document as ``AHRI'' comments.
\18\ AHRI submitted two comment documents to the docket. The
second document in the docket includes AHRI's comments supporting
wine cellar manufacturers (i.e., high-temperature walk-in
refrigeration systems). The associated file name in the docket is:
Comments WICF NOPR EERE-2017-BT-STD-0009 Wine. These comments are
referenced in this document as ``AHRI-Wine'' comments.
Table II.4--June 2022 Preliminary Analysis Written Comments
----------------------------------------------------------------------------------------------------------------
Comment No. in
Commenter(s) Abbreviation the docket Commenter type
----------------------------------------------------------------------------------------------------------------
Air-Conditioning, Heating, and AHRI \17\................. 39 Trade Association.
Refrigeration Institute.
Air-Conditioning, Heating, and AHRI-Wine \18\............ 39 Trade Association.
Refrigeration Institute.
Appliance Standards Awareness Project, Efficiency Advocates...... 37 Efficiency Organizations.
American Council for an Energy-
Efficient Economy, Natural Resources
Defense Council, Northwest Energy
Efficiency Alliance.
Heat Transfer Products Group, LLC....... HTPG...................... 35 Manufacturer.
Hussmann Corporation.................... Hussmann--Door............ 33 Manufacturer.
Hussmann Corporation.................... Hussmann--Refrigeration... 38 Manufacturer.
KeepRite Refrigeration, Inc............. KeepRite.................. 41 Manufacturer.
Lennox International Inc................ Lennox.................... 36 Manufacturer.
North American Association of Food NAFEM..................... 42 Trade Association.
Equipment.
Rob Brooks.............................. Brooks.................... 34 Individual.
----------------------------------------------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\19\
To the extent that interested parties have provided written comments
that are substantively consistent with any oral comments provided
during the July 22, 2022, public meeting, DOE cites the written
comments throughout this document. Any oral comments provided during
the webinar that are not substantively addressed by written comments
are summarized and cited separately throughout this document.
---------------------------------------------------------------------------
\19\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for walk-ins. (Docket NO. EERE-2017-
BT-STD-0009, which is maintained at www.regulations.gov). The
references are arranged as follows: (commenter name, comment docket
ID number, page of that document).
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C. Deviation From Process Rule
In accordance with section 3(a) of 10 CFR part 430, subpart C,
appendix A (``Process Rule''), DOE notes that it is deviating from the
provision in the Process Rule regarding the pre-NOPR and NOPR stages
for an energy conservation standard rulemaking by not publishing a
framework document and providing a public comment period less than 75
days. Framework Document
Section 6(a)(2) of the Process Rule states that if DOE determines
it is appropriate to proceed with a rulemaking, the preliminary stages
of a rulemaking to issue or amend an energy conservation standard that
DOE will undertake will be a framework document and preliminary
analysis, or an advance notice of proposed rulemaking. While DOE
published a preliminary analysis for this rulemaking (see 87 FR 39008),
DOE did not publish a framework document in conjunction with the
preliminary analysis. DOE notes, however, that chapter 2 of the
preliminary TSD that accompanied the preliminary analysis--entitled
Analytical Framework, Comments from Interested Parties, and DOE
Responses--describes the general analytical framework that DOE uses in
evaluating and developing potential amended energy conservation
standards.\20\ As such, publication of a separate framework document
would be largely redundant of previously published documents.
---------------------------------------------------------------------------
\20\ The preliminary technical support document is available at
www.regulations.gov/document/EERE-2017-BT-STD-0009-0024.
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1. Public Comment Period
Section 6(f)(2) of the Process Rule specifies that the length of
the public comment period for a NOPR will be not less than 75 calendar
days. For this NOPR, DOE is instead providing a 60-day comment period,
consistent with EPCA requirements. 42 U.S.C. 6316(a); 42 U.S.C.
6295(p). DOE is opting to deviate from the 75-day comment period
because stakeholders have already been afforded multiple opportunities
to provide comments on this proposed rulemaking.
As noted previously, DOE requested comment in the July 2021 RFI on
the analysis conducted in support of the last energy conservation
standard rulemaking for walk-ins and provided a 30-day comment period.
In its June 2022 Preliminary Analysis and TSD, DOE's analysis remained
largely the same as the analysis conducted in support of the previous
energy conservation standards rulemaking for walk-ins. DOE requested
comment in the June 2022 Preliminary Analysis TSD on the analysis
conducted in support of this current rulemaking. Given that this
analysis remained largely the same as the June 2022 Preliminary
Analysis, and in light of the 60-day comment period DOE has already
provided with its June 2022 Preliminary Analysis, DOE has determined
that a 60-day comment period is appropriate for this NOPR and that it
will provide interested parties with a meaningful opportunity to
comment on the proposed rule.
III. General Discussion
DOE developed this proposal after considering oral and written
comments, data, and information from interested parties that represent
a variety of interests. The following discussion addresses issues
raised by these commenters.
[[Page 60757]]
A. General Comments
This section summarizes general comments received from interested
parties regarding rulemaking timing and process.
The Efficiency Advocates commented that they encourage DOE to
consider evaluating potential standards for refrigeration shipping
containers. (Efficiency Advocates, No. 37 at pp. 5-6) As discussed in
the test procedure final rule that was published on May 4, 2023 (``May
2023 TP Final Rule''), DOE has not evaluated refrigerated shipping
containers to determine if current walk-in test procedures would
produce test results that reflect energy efficiency, energy use, or
estimated operating costs during a representative average use cycle,
without being unduly burdensome to conduct. 88 FR 28780, 28787.
Therefore, DOE has determined that refrigerated shipping containers are
not currently subject to the DOE test procedure or energy conservation
standards for WICFs. DOE may consider whether test procedures and
energy conservation standards should be applied to refrigerated
shipping containers in a future rulemaking.
AHRI-Wine commented that wine cellar manufacturers seek
clarification on whether the June 2022 Preliminary Analysis would
change AWEF standards for high-temperature walk-in refrigeration
systems. (AHRI-Wine, No. 39 at p. 5) DOE notes that there are currently
no standards for high-temperature units. DOE did analyze high-
temperature units in the June 2022 Preliminary Analysis. In this NOPR,
DOE is proposing an energy conservation standard for high-temperature
units in section I.
AHRI-Wine urged DOE to increase in future analysis the box load
multiplier of 0.5 that was proposed in the April 2022 test procedure
because many wine cellar applications are high-end homes with little
traffic into and out of the cellar. (AHRI-Wine, No. 39 at p. 3) DOE
notes that the box load multiplier is part of the walk-in test
procedure and not the energy conservation standards. The May 2023 TP
Final Rule adopted the box load multiplier of 0.5 and therefore, the
NOPR engineering analysis for high-temperature units used this value.
AHRI-Wine recommended that DOE conduct interviews with more wine
cellar manufacturers to get a better representation of the wine cellar
market. (AHRI, No. 39 at p. 5) DOE notes that it invited several wine
cellar manufacturers to participate in interviews, which informed this
rulemaking. DOE further notes that it welcomes comments, data, and
information regarding this proposed rule from all interested parties.
The Efficiency Advocates suggested that DOE consider setting
standards for refrigeration systems as a function of capacity since
larger capacity units are generally able to reach higher efficiency
levels. (Efficiency Advocates, No. 37 at pp. 2-3) Furthermore, the
Efficiency Advocates cited the disparity in the LCC to support setting
standards as a function of capacity. Id. DOE evaluated the economics of
each efficiency level for each representative unit. This analysis
indicated that more stringent standards were generally economically
justified for larger units and, therefore, DOE proposed standards that
reflected this. As seen in section I, DOE is proposing standards as a
function of capacity for most refrigeration system equipment classes.
Lennox commented that several items were non-functional in the June
2022 preliminary engineering analysis worksheet. (Lennox, No. 36 at p.
9) DOE notes that a new engineering spreadsheet has been updated to
reflect the updated analysis for this NOPR and the items identified by
Lennox have been resolved in this version of the engineering sheet.\21\
Additionally, DOE has reviewed the non-functional items identified in
Lennox's comment and found that none impacted the results of the
engineering analysis.
---------------------------------------------------------------------------
\21\ The new refrigeration systems engineering sheet can be
found at www.regulations.gov/docket/EERE-2017-BT-STD-0009.
---------------------------------------------------------------------------
NAFEM stated that it endorses and reiterates all comments made by
AHRI. (NAFEM, No. 42 at p. 2) DOE notes that throughout this document,
reference to comments made by AHRI are therefore understood to be
representative of the viewpoints of NAFEM as well. NAFEM also commented
that it hopes DOE will follow the Process Rule. Id. In section II.C of
this document, DOE discusses certain minor deviations from the Process
Rule as well as the justification for such deviations. Aside from these
minor deviations, DOE has developed this NOPR in accordance with the
Process Rule.
B. Scope of Coverage
This NOPR covers ``walk-in coolers and walk-in freezers'' defined
as an enclosed storage space, including but not limited to panels,
doors, and refrigeration systems, refrigerated to temperatures,
respectively, above, and at or below 32 degrees Fahrenheit that can be
walked into, and has a total chilled storage area of less than 3,000
square feet; however, the terms do not include products designed and
marketed exclusively for medical, scientific, or research purposes. 10
CFR 431.302. Rather than establishing standards for complete walk-in
systems, DOE has established standards for the principal components
that make up a walk-in (i.e., doors, panels, and refrigeration
systems).
A ``door'' means an assembly installed in an opening on an interior
or exterior wall that is used to allow access or close off the opening
and that is movable in a sliding, pivoting, hinged, or revolving manner
of movement. For walk-in coolers and walk-in freezers, a door includes
the frame (including mullions), the door leaf or multiple leaves
(including glass) within the frame, and any other elements that form
the assembly or part of its connection to the wall. Id.
A ``panel'' means a construction component that is not a door and
is used to construct the envelope of the walk-in, (i.e., elements that
separate the interior refrigerated environment of the walk-in from the
exterior). Id.
A ``refrigeration system'' means the mechanism (including all
controls and other components integral to the system's operation) used
to create the refrigerated environment in the interior of a walk-in
cooler or walk-in freezer, consisting of:
(1) A dedicated condensing refrigeration system (as defined in 10
CFR 431.302); or
(2) A unit cooler.
The scope of coverage and equipment classes for this NOPR are
discussed in further detail in section IV.A.1 of this document.
C. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6314(a))
Manufacturers of covered equipment must use these test procedures to
certify to DOE that their equipment complies with energy conservation
standards and to quantify the efficiency of their equipment. DOE's
current energy conservation standards for walk-in doors are expressed
in terms of maximum daily energy consumption, DOE's current energy
conservation standards for walk-in panels are expressed in terms of R-
value, and DOE's current energy conservation standards for walk-in
refrigeration systems are expressed in terms of AWEF. (See 10 CFR part
431, subpart R, appendices A, B, C, and C1.)
On April 21, 2022, DOE published a test procedure NOPR (``April
2022 TP NOPR'') and on May 4, 2023, DOE published the May 2023 TP Final
Rule.
[[Page 60758]]
87 FR 23920; 88 FR 28780 In the June 2022 Preliminary Analysis, DOE
used the test procedure proposed in the April 2022 TP NOPR to evaluate
the efficiency of walk-in components. In this NOPR analysis, DOE used
the test procedure adopted in the May 2023 TP Final Rule to evaluate
the efficiency of walk-in components. From this point forward the May
2023 TP Final Rule will be the ``current test procedure''.
In the May 2023 TP Final Rule, DOE established a new appendix,
appendix C1 to subpart R (``appendix C1''), and a new energy metric,
AWEF2, for refrigeration systems. (See 10 CFR part 431, subpart R,
appendix C1.) The engineering analysis results and the proposed energy
conservation standards for refrigeration systems are presented as AWEF2
values. Manufacturers would be required to begin using appendix C1 as
of the compliance date of an energy conservation standards promulgated
as a result of this rulemaking.
D. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the equipment that are the subject of the rulemaking. As
the first step in such an analysis, DOE develops a list of technology
options for consideration in consultation with manufacturers, design
engineers, and other interested parties. DOE then determines which of
those means for improving efficiency are technologically feasible. DOE
considers technologies incorporated in commercially available equipment
or in working prototypes to be technologically feasible. 10 CFR 431.4;
10 CFR part 430, subpart C, appendix A, sections 6(b)(3)(i) and 7(b)(1)
of the Process Rule.
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
practicability to manufacture, install, and service; (2) adverse
impacts on equipment utility or availability; (3) adverse impacts on
health or safety, and (4) unique-pathway proprietary technologies. 10
CFR 431.4; Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of the Process
Rule. Section IV.B of this document discusses the results of the
screening analysis for walk-in doors, panels, and refrigeration
systems, particularly the designs DOE considered, those it screened
out, and those that are the basis for the standards considered in this
rulemaking. For further details on the screening analysis for this
rulemaking, see chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a new or amended standard for a type or
class of covered product, it must determine the maximum improvement in
energy efficiency or maximum reduction in energy use that is
technologically feasible for such equipment. (42 U.S.C. 6316(a); 42
U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE
determined the maximum technologically feasible (``max-tech'')
improvements in energy efficiency for walk-in doors, panels, and
refrigeration systems, using the design parameters for the most
efficient equipment available on the market or in working prototypes.
The max-tech levels that DOE determined for this rulemaking are
described in section IV.C.1 of this proposed rule and in chapter 5 of
the NOPR TSD.
E. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to walk-in doors, panels, and
refrigeration systems purchased in the 30-year period that begins in
the year of compliance with the proposed standards (2027-2056).\22\ The
savings are measured over the entire lifetime of walk-in doors, panels,
and refrigeration systems purchased in the previous 30-year period. DOE
quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
no-new-standards case. The no-new-standards case represents a
projection of energy consumption that reflects how the market for the
equipment would likely evolve in the absence of amended energy
conservation standards.
---------------------------------------------------------------------------
\22\ Each TSL is composed of specific efficiency levels for each
equipment class. The TSLs considered for this NOPR are described in
section V.A of this document. DOE conducted a sensitivity analysis
that considers impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (``NIA'') spreadsheet model
to estimate national energy savings (``NES'') from potential amended or
new standards for walk-in doors, panels, and refrigeration systems. The
NIA spreadsheet model (described in section IV.H of this document)
calculates energy savings in terms of site energy, which is the energy
directly consumed by products at the locations where they are used. For
electricity, DOE reports national energy savings in terms of primary
energy savings, which is the savings in the energy that is used to
generate and transmit the site electricity. DOE also calculates NES in
terms of FFC energy savings. The FFC metric includes the energy
consumed in extracting, processing, and transporting primary fuels
(i.e., coal, natural gas, petroleum fuels), and thus presents a more
complete picture of the impacts of energy conservation standards.\23\
DOE's approach is based on the calculation of an FFC multiplier for
each of the energy types used by covered products or equipment. For
more information on FFC energy savings, see section IV.H.2 of this
document.
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\23\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as
amended at 77 FR 49701 (Aug. 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended standards for covered equipment, DOE
must determine that such action would result in significant energy
savings. (42 U.S.C. 6295(o)(3)(B))
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\24\ For
example, some covered equipment have most of their energy consumption
occur during periods of peak energy demand. The impacts of this
equipment on the energy infrastructure can be more pronounced than
equipment with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis, taking into
account the significance of cumulative FFC national energy savings, the
cumulative FFC emissions reductions, and the need to confront the
global climate crisis, among other factors. DOE has initially
determined the energy savings from the proposed standard levels are
``significant'' within the meaning of 42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(3)(B).
---------------------------------------------------------------------------
\24\ The numeric threshold for determining the significance of
energy savings established in a final rule published on February 14,
2020 (85 FR 8626, 8670), was subsequently eliminated in a final rule
published on December 13, 2021 (86 FR 70892).
---------------------------------------------------------------------------
As stated, the standard levels proposed in this document are
projected to result in national energy savings of 1.55 quads, the
equivalent of the primary annual energy use of 42.7 million homes.
Based on the amount of FFC savings, the corresponding reduction in
emissions, and the need to confront the global climate crisis, DOE
[[Page 60759]]
has initially determined the energy savings from the proposed standard
levels are ``significant'' within the meaning of 42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(3)(B).
F. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides seven factors to be evaluated in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has
addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential new or amended standard
on manufacturers, DOE conducts an MIA, as discussed in section IV.J of
this document. DOE first uses an annual cash flow approach to determine
the quantitative impacts. This step includes both a short-term
assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period. The industry-wide impacts analyzed include (1) INPV, which
values the industry on the basis of expected future cash flows, (2)
cash flows by year, (3) changes in revenue and income, and (4) other
measures of impact, as appropriate. Second, DOE analyzes and reports
the impacts on different types of manufacturers, including impacts on
small manufacturers. Third, DOE considers the impact of standards on
domestic manufacturer employment and manufacturing capacity, as well as
the potential for standards to result in plant closures and loss of
capital investment. Finally, DOE takes into account cumulative impacts
of various DOE regulations and other regulatory requirements on
manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and PBP associated with new or amended standards. These
measures are discussed further in the following section. For consumers
in the aggregate, DOE also calculates the national net present value of
the consumer costs and benefits expected to result from particular
standards. DOE also evaluates the impacts of potential standards on
identifiable subgroups of consumers that may be affected
disproportionately by a standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered equipment in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered equipment
that are likely to result from a standard. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC
and PBP analysis.
The LCC is the sum of the purchase price of equipment (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the equipment. The LCC analysis requires a variety of inputs, such as
equipment prices, equipment energy consumption, energy prices,
maintenance and repair costs, equipment lifetime, and discount rates
appropriate for consumers. To account for uncertainty and variability
in specific inputs, such as equipment lifetime and discount rate, DOE
uses a distribution of values, with probabilities attached to each
value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of more-efficient equipment through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered equipment in the first year of compliance with new
or amended standards. The LCC savings for the considered efficiency
levels are calculated relative to the case that reflects projected
market trends in the absence of new or amended standards. DOE's LCC and
PBP analysis is discussed in further detail in section IV.F of this
document.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(III)) As discussed in section III.E of this document,
DOE uses its NIA model to project national energy savings.
d. Lessening of Utility or Performance of Equipment
In establishing equipment classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered equipment. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards
proposed in this document would not reduce the utility or performance
of the equipment under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from a proposed standard. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to
determine the impact, if any, of any lessening of competition likely to
result from a proposed standard and to transmit such determination to
the Secretary within 60 days of the publication of a proposed rule,
together with an analysis of the nature and extent of the impact. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy
of this proposed rule to the Attorney General with a request that the
Department of Justice (``DOJ'') provide its determination on this
issue. DOE will publish and respond to the Attorney General's
determination in the final rule. DOE invites comment from the public
regarding the competitive impacts that are likely to result from this
proposed rule. In addition, stakeholders may also provide comments
separately to DOJ regarding these potential impacts. See the ADDRESSES
section for information to send comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water
conservation in determining whether a new or amended standard is
economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VI)) The energy savings from the proposed standards
are likely to provide improvements to the security and reliability of
the Nation's energy system. Reductions in the demand for electricity
also may result in reduced costs for maintaining the reliability of the
Nation's electricity system. DOE conducts a utility impact analysis to
estimate how standards may affect the Nation's needed power generation
[[Page 60760]]
capacity, as discussed in section IV.M of this document.
DOE maintains that environmental and public health benefits
associated with the more efficient use of energy are important to take
into account when considering the need for national energy
conservation. The proposed standards are likely to result in
environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases (``GHGs'') associated with energy
production and use. DOE conducts an emissions analysis to estimate how
potential standards may affect these emissions, as discussed in section
IV.K of this document; the estimated emissions impacts are reported in
section V.B.6 of this document. DOE also estimates the economic value
of emissions reductions resulting from the considered TSLs, as
discussed in section V.C.1 of this document.
g. Other Factors
In determining whether an energy conservation standard is
economically justified, DOE may consider any other factors that the
Secretary deems to be relevant (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VII)) To the extent DOE identifies any relevant
information regarding economic justification that does not fit into the
other categories described previously, DOE could consider such
information under ``other factors.''
2. Rebuttable Presumption
EPCA creates a rebuttable presumption that an energy conservation
standard is economically justified if the additional cost to the
equipment that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. (42 U.S.C. 6316(a);
42 U.S.C. 6295(o)(2)(B)(iii)) DOE's LCC and PBP analyses generate
values used to calculate the effects that proposed energy conservation
standards would have on the payback period for consumers. These
analyses include, but are not limited to, the 3-year payback period
contemplated under the rebuttable-presumption test. In addition, DOE
routinely conducts an economic analysis that considers the full range
of impacts to consumers, manufacturers, the Nation, and the
environment, as required under 42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i). The results of this analysis serve as the basis for
DOE's evaluation of the economic justification for a potential standard
level (thereby supporting or rebutting the results of any preliminary
determination of economic justification). The rebuttable presumption
payback calculation is discussed in section V.B.1.c of this proposed
rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
rulemaking with regard to walk-ins. Separate subsections address each
component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential amended or new
energy conservation standards. The national impacts analysis uses a
second spreadsheet set that provides shipments projections and
calculates national energy savings and net present value of total
consumer costs and savings expected to result from potential energy
conservation standards. DOE uses the third spreadsheet tool, the
Government Regulatory Impact Model (``GRIM''), to assess manufacturer
impacts of potential standards. These three spreadsheet tools are
available on the DOE website for this proposed rulemaking:
www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=56&action=viewlive. Additionally, DOE used
output from the latest version of the Energy Information
Administration's (``EIA's'') Annual Energy Outlook (``AEO''), a widely
known energy projection for the United States, for the emissions and
utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the equipment
concerned, including the purpose of the equipment, the industry
structure, manufacturers, market characteristics, and technologies used
in the equipment. This activity includes both quantitative and
qualitative assessments, based primarily on publicly available
information. The subjects addressed in the market and technology
assessment for this rulemaking include (1) a determination of the scope
of the rulemaking and equipment classes, (2) manufacturers and industry
structure, (3) existing efficiency programs, (4) shipments information,
(5) market and industry trends; and (6) technologies or design options
that could improve the energy efficiency of walk-ins. The key findings
of DOE's market assessment are summarized in the following sections.
See chapter 3 of the NOPR TSD for further discussion of the market and
technology assessment.
1. Equipment Classes
When evaluating and establishing energy conservation standards, DOE
may establish separate standards for a group of covered equipment
(i.e., establish a separate equipment class) if DOE determines that
separate standards are justified based on the type of energy used, or
if DOE determines that equipment capacity or other performance-related
feature justifies a different standard. (42 U.S.C. 6316(a); 42 U.S.C.
6295(q)) In making a determination whether a performance-related
feature justifies a different standard, DOE must consider such factors
as the utility of the feature to the consumer and other factors DOE
determines are appropriate. (Id.)
Rather than establishing standards for complete walk-in systems,
DOE has established standards for each of the principal components that
make up a walk-in (i.e., doors, panels, and refrigeration systems).
a. Doors
DOE's existing standards for walk-in doors are based on six
equipment classes, differentiated by temperature and whether they are
display doors or non-display doors. DOE defines a display door as a
door that is designed for product display or has 75 percent or more of
its surface area composed of glass or another transparent material. 10
CFR 431.302. Non-display doors are all doors not considered display
doors and are mainly used to allow people and products to be moved into
and out of the walk-in. Non-display doors are further divided by
whether they are passage or freight doors. DOE defines a freight door
as a door that is not a display door and is equal to or larger than 4
feet wide and 8 feet tall. DOE defines passage doors as any doors that
are not display doors or freights doors. Id. Display, passage, and
freight doors are further divided based on walk-in temperature (i.e.,
cooler or freezer). DOE currently defines separate energy conservation
standards for the following walk-in door classes (10 CFR 431.306(c) and
(d)):
Display Door, Medium-temperature,
Display Door, Low-temperature,
Passage Door, Medium-temperature,
Passage Door, Low-temperature,
Freight Door, Medium-temperature, and
Freight Door, Low-temperature.
In the June 2022 Preliminary Analysis, DOE combined passage and
freight non-display door classes and
[[Page 60761]]
instead differentiated non-display doors by whether or not they have
motorized door openers. DOE's initial research and analysis indicated
that distinguishing non-display door classes by the presence or absence
of a motorized door opener could be a more appropriate distinction of
equipment classes rather than door size. As with its prior analysis,
DOE also evaluated the motorized and non-motorized non-display door
classes by temperature conditions: medium-temperature (i.e., cooler)
and low-temperature (i.e., freezer).
In the June 2022 Preliminary Analysis, DOE also distinguished
display door classes by the presence or absence of a motorized door
opener. DOE analyzed medium- and low-temperature display doors without
motorized door openers and medium-temperature display doors with
motorized door openers. DOE has not identified any motorized display
doors for low-temperature applications and therefore did not analyze
such equipment in the June 2022 Preliminary Analysis. See section
3.1.2.1 of chapter 3 of the June 2022 preliminary analysis TSD.
DOE sought feedback on the equipment classes analyzed for walk-in
doors in section ES.4.1 of the June 2022 Preliminary Analysis TSD.
Hussmann-Doors commented that their request to have their Heavy Duty
Door (``HDD'') and ABC Beer Cave (``ABC'') products classified as
passage doors was not approved in 2017 and stated that there would be a
cost benefit if their HDD and ABC product were to be classified as
passage doors rather than display doors. Hussmann-Doors further
elaborated that if these products were recognized as passage doors,
they would not need to use expensive vacuum-insulated glass packs and
could consider a more economical glass pack. (Hussmann-Doors, No. 33 at
p. 2) In response, DOE notes that the display door definition
references the physical characteristics of the door (i.e., the
percentage of surface area composed of glass or another transparent
material) and is not contingent on door application. It is DOE's
understanding that both Hussmann's HDD and ABC products are composed of
at least 75 percent glass or another transparent material. Any door(s)
that meets this criteria is considered a display door, even those not
necessarily designed for product display.
The Efficiency Advocates agreed that non-display doors should be
differentiated by manual or motorized opening mechanism (Efficiency
Advocates, No. 37 at pp. 1-2).
Consistent with stakeholder feedback, DOE has tentatively concluded
that it is more appropriate to distinguish non-display doors by whether
or not they have a motorized door opener, rather than by size.
Additionally, DOE has tentatively concluded that it is appropriate to
distinguish display doors by whether or not they have a motorized door
opener. DOE is proposing to establish the equipment classes listed in
Table IV.1 for walk-in doors.
Table IV.1--Proposed Equipment Classes for Walk-In Doors
----------------------------------------------------------------------------------------------------------------
Display/non-display Opening mechanism Temperature Class code
----------------------------------------------------------------------------------------------------------------
Display.............................. Manual................. Medium................. DW.M.
Low.................... DW.L.
Motorized.............. Medium................. DS.M.
Non-display.......................... Manual................. Medium................. NM.M.
Low.................... NM.L.
Motorized.............. Medium................. NO.M.
Low.................... NO.L.
----------------------------------------------------------------------------------------------------------------
DOE discusses representative units, baseline assumptions for
representative unit efficiency, and design options analyzed at higher
efficiency levels for walk-in display and non-display doors in sections
IV.C.1.a and IV.C.1.b of this document, respectively. DOE notes that,
consistent with its June 2022 Preliminary Analysis, it did not consider
more efficient levels for the motorized display door class beyond the
current maximum energy consumption (i.e., baseline efficiency level) in
this NOPR. In its review of the motorized display door market, DOE
found that manufacturers are already implementing maximum technology
design options, such as vacuum- insulated glass, to achieve the current
maximum energy consumption standard since the motor consumes additional
energy. DOE has not identified any energy-saving technology options for
motorized display doors that were retained during the screening
analysis, as discussed in sections IV.A.2.b and IV.B of this document.
DOE received comments in response to the June 2022 Preliminary Analysis
regarding efficiency of motorized (i.e., sliding) display doors. These
comments are addressed in section IV.C.1.a of this document.
b. Panels
DOE's existing standards for walk-in panels apply to three
equipment classes that are differentiated by whether they are
structural (also referred to as ``wall or ceiling panels'') or floor
panels. Structural panels are further separated by temperature
condition (i.e., cooler or freezer). DOE's analysis for the June 2014
Final Rule determined that, unlike walk-in freezers, the majority of
walk-in coolers have concrete floors and no insulated floor panels.
Thus, DOE did not adopt insulation R-value standards for walk-in cooler
floors. 79 FR 32050, 32067. DOE's re-evaluation of the market for this
rulemaking suggests that the walk-in cooler floor panel market has not
changed substantially since the June 2014 Final Rule. Therefore, DOE
has excluded walk-in cooler floor panels from this proposed rulemaking.
DOE currently defines separate energy conservation standards for
the following walk-in panel classes (10 CFR 431.306(a)):
Structural Panel, Medium-Temperature,
Structural Panel, Low-Temperature, and
Floor Panel, Low-Temperature.
DOE has not established standards for display panels because they
make up a small percentage of the panel market; therefore, standards
would not result in significant energy savings without incurring
disproportionate costs. 79 FR 32050, 32067. In the June 2022
Preliminary Analysis, DOE maintained the current panel equipment
classes. See section 3.1.2.2 of chapter 3 of the June 2022 preliminary
analysis TSD. In section ES.4.1 of the June 2022 Preliminary Analysis
TSD, DOE requested comment on the equipment classes used in this
analysis. DOE received no comment regarding panel equipment classes in
response to the June 2022 Preliminary Analysis. As such, DOE is
proposing to maintain its
[[Page 60762]]
current equipment classes for walk-in panels. Table IV.2 summarizes the
equipment classes for walk-in panels.
Table IV.2--Equipment Classes for Walk-In Panels
------------------------------------------------------------------------
Component Temperature Class code
------------------------------------------------------------------------
Structural Panel................ Medium............ PS.M.
Low............... PS.L.
Floor Panel..................... Low............... PF.L.
------------------------------------------------------------------------
c. Refrigeration Systems
DOE's existing standards for walk-in refrigeration systems apply to
nine equipment classes, differentiated by whether they are unit coolers
or dedicated condensing systems and by temperature (i.e., whether they
are a cooler or freezer). A ``dedicated condensing system'' means a
dedicated condensing unit, a single-packaged dedicated system, or a
matched refrigeration system. (See 10 CFR 431.302.) Dedicated
condensing systems are further differentiated by their installation
location (i.e., indoor or outdoor). Low-temperature dedicated
condensing systems and unit cooler equipment classes are further
differentiated by net capacity. DOE currently defines separate energy
conservation standards for the following walk-in refrigeration system
classes (10 CFR 431.306(e)):
Dedicated Condensing System, Medium-Temperature, Indoor,
Dedicated Condensing System, Medium-Temperature, Outdoor,
Dedicated Condensing System, Low-Temperature, Indoor, Net
Capacity of less than 6,500 Btu/h,
Dedicated Condensing System, Low-Temperature, Indoor, Net
Capacity of greater than or equal to 6,500 Btu/h,
Dedicated Condensing System, Low-Temperature, Outdoor, Net
Capacity of less than 6,500 Btu/h,
Dedicated Condensing System, Low-Temperature, Outdoor, Net
Capacity of greater than or equal to 6,500 Btu/h,
Unit Cooler, Medium-Temperature,
Unit Cooler, Low-Temperature, Net Capacity of less than
15,500 Btu/h, and
Unit Cooler, Low-Temperature, Net Capacity of greater than
or equal to 15,500 Btu/h.
In the June 2022 Preliminary Analysis TSD, DOE noted that single-
packaged dedicated systems, which are dedicated condensing systems with
a combined condensing unit and unit cooler, were not evaluated
separately from dedicated condensing units and matched refrigeration
systems in the previous rulemaking. New test procedure provisions in
appendix C1 require specific test methods for single-packaged dedicated
systems that measure the inherent thermal losses of such systems. These
thermal losses reduce the capacity and therefore the efficiency of
single-packaged dedicated systems. For this reason, in the June
Preliminary Analysis, DOE evaluated single-packaged dedicated systems
separately from split dedicated condensing systems.\25\ See section
3.1.2.3 of chapter 3 of the June 2022 preliminary analysis TSD.
---------------------------------------------------------------------------
\25\ Split dedicated condensing systems or split systems refer
to any dedicated condensing system that is made up of a unit cooler
and a remote dedicated condensing unit. The systems are split
because the unit cooler and dedicated condensing unit are not in the
same package.
---------------------------------------------------------------------------
In the May 2023 TP Final Rule, DOE defined a high-temperature
refrigeration system as a walk-in refrigeration system that is not
designed to operate below 45 [deg]F. 88 FR 28780, 28789. High-
temperature units are generally smaller capacity than medium-
temperature units and therefore contain small-capacity compressors,
which DOE has found to be less efficient. Additionally, some high-
temperature units are sold in ducted configurations. Ducting adds
flexibility to installation location and removes refrigeration
equipment from the refrigerated storage space. Ducts also increase
energy consumption due to the higher external static pressure imposed
on the system's fans. In the June 2022 Preliminary Analysis, DOE
evaluated high-temperature units and ducted units as separate equipment
classes. The equipment classes that DOE analyzed in the June 2022
Preliminary Analysis are summarized in Table IV.3.
Table IV.3--Walk-In Refrigeration System Equipment Classes Analyzed in the June 2022 Preliminary Analysis
----------------------------------------------------------------------------------------------------------------
System Temperature Location Class code
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing Unit............ Medium-Temperature..... Outdoor................ DC.M.O.
Indoor................. DC.M.I.
Low-Temperature........ Outdoor................ DC.L.O.
Indoor................. DC.L.I.
Unit Cooler.......................... High-Temperature....... N/A.................... UC.H.
Medium-Temperature..... UC.M.
Low-Temperature........ UC.L.
Single-Packaged Dedicated System..... High-Temperature (Non- Outdoor................ SPU.H.O.
ducted). Indoor................. SPU.H.I.
High-Temperature Outdoor................ SPU.H.O.D.
(Ducted). Indoor................. SPU.H.I.D.
Medium-Temperature..... Outdoor................ SPU.M.O.
Indoor................. SPU.M.I.
Low-Temperature........ Outdoor................ SPU.L.O.
Indoor................. SPU.L.I.
----------------------------------------------------------------------------------------------------------------
[[Page 60763]]
DOE requested comment on the equipment classes in section ES.4.1 of
the Executive Summary of the June 2022 Preliminary Analysis TSD,
repeated in Table IV.3. AHRI requested further clarification on DOE's
reasoning for separating single-packaged dedicated systems and
dedicated condensing systems. (AHRI, No. 39 at pp. 1-2) Hussmann-
Refrigeration stated that it agrees with AHRI's inquiry. (Hussmann-
Refrigeration, No. 38 at p. 2) HTPG commented that it disagrees with
DOE separating single-packaged dedicated systems and dedicated
condensing systems because a single-packaged dedicated system is
essentially a matched pair and matched pairs have the same efficiency
requirements as dedicated condensing systems. (HTPG, No. 35 at p. 3)
Additionally, HTPG stated that if single-packaged dedicated systems are
held to a lower standard than dedicated condensing systems and matched
pairs, then consumers could purchase lower cost single-packaged
dedicated systems at a lower efficiency level than dedicated condensing
units and matched pairs. Id. The Efficiency Advocates encouraged DOE to
ensure that efficiency standard levels for single-packaged dedicated
systems are as stringent (e.g., incorporate similar assumed design
options) as efficiency standard levels for dedicated condensing units
to prevent a shift in the market away from dedicated condensing units
and towards single-packaged dedicated systems. (Efficiency Advocates,
No. 37 at p. 5)
DOE clarifies that in Table IV.3, the dedicated condensing unit
equipment class refers to all split systems. In general, DOE has
separated packaged equipment from split systems as packaged equipment
provides consumers with more options for space-constrained
applications. But packaged refrigeration systems are inherently less
efficient because manufacturers cannot employ the same technologies
such as increased heat exchanger sizes without impacting the overall
dimensions of the packaged system. In addition, packaged systems are
constrained by their overall weight limitations of the equipment, which
affects the technologies options that can be applied to the system.
Packaged systems typically contain smaller heat exchangers and those
heat exchangers have less faces for airflow to pass over impacting the
overall heat transfer of the system. In addition, packaged systems have
both the cold and hot sides connected within the packaged framework and
the cold side is exposed to the outside, which increases the losses
associated with the thermal loads. Overall, DOE has tentatively decided
that packaged system and split system WICF refrigeration systems cannot
be combined into the same product class because packaged systems
provide consumers with more options for space-constrained applications
and inherent differences in system design between packaged systems and
split systems limit the efficiency of the former.
AHRI-Wine commented that it seeks clarification on where matched
split systems are represented in Table 5.3.4 of the June 2022
Preliminary Analysis TSD, which lists the representative units chosen
for the refrigeration system analysis. (AHRI-Wine, No. 39 at p. 2)
Also, AHRI-Wine recommended adding high-temperature dedicated
condensing [units] since leaving these out of the scope would be a
competitive disadvantage for manufacturers that sell single-packaged
dedicated systems and matched split systems. Id. Furthermore, AHRI-Wine
commented that wine cellar manufacturers seek clarification on the
classes that constitute matched split, ducted and non-ducted, and
indoor and outdoor systems. (AHRI-Wine, No. 39 at p. 5)
DOE notes that it did not establish a test procedure for high-
temperature dedicated condensing units tested alone in the May 2023 TP
Final Rule; however, it did establish a test procedure for high-
temperature matched refrigeration systems and single-packaged dedicated
condensing systems. This decision is discussed in detail in the May
2023 TP Final Rule. 88 FR 28780, 28816-28817. As such, DOE did not
analyze high-temperature dedicated condensing units in this NOPR
analysis and therefore is not proposing to establish an equipment class
for high-temperature dedicated condensing units. DOE is, however,
proposing to establish an equipment class for both high-temperature
matched refrigeration systems and high-temperature single-packaged
dedicated condensing systems. For this NOPR, DOE evaluated high-
temperature matched refrigeration systems and high-temperature single-
packaged dedicated systems as a single equipment class since both are
sold with a condenser and an evaporator that are matched for optimal
performance. Furthermore, the temperature difference between the
refrigerated and ambient spaces for high-temperature refrigeration
systems is less than the temperature difference for medium- and low-
temperature systems. Therefore, thermal losses have less impact for
high-temperature systems. This means that the difference in performance
between high-temperature matched refrigeration systems and high-
temperature single-packaged dedicated systems is much less than the
performance difference expected between medium- or low-temperature
matched refrigeration systems and medium- or low-temperature single-
packaged dedicated systems. Because of the expected similarity in
performance, DOE has tentatively determined that a single class of
equipment encompassing high-temperature matched refrigeration systems
and single-packaged dedicated systems is appropriate. In its analysis
of high-temperature refrigeration units, DOE focused on single-packaged
dedicated systems since this is where most of the shipments are
concentrated for the high-temperature market.
DOE is proposing to establish the following equipment classes for
refrigeration systems, as presented in Table IV.4.
Table IV.4--Proposed Equipment Classes for Walk-In Refrigeration Systems
----------------------------------------------------------------------------------------------------------------
System Temperature Location Class code
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing Units and Medium-Temperature..... Outdoor................ DC.M.O.
Matched Refrigeration Systems. Indoor................. DC.M.I.
Low-Temperature........ Outdoor................ DC.L.O.
Indoor................. DC.L.I.
Unit Cooler.......................... High-Temperature (Non- N/A.................... UC.H.
Ducted).
High-Temperature UC.H.D.
(Ducted).
Medium-Temperature..... UC.M.
Low-Temperature........ UC.L.
Matched Refrigeration Systems and High-Temperature (Non- Outdoor................ SPU.H.O.
Single-Packaged Dedicated Systems. ducted). Indoor................. SPU.H.I.
[[Page 60764]]
High-Temperature Outdoor................ SPU.H.O.D.
(Ducted). Indoor................. SPU.H.I.D.
Single-Packaged Dedicated Systems.... Medium-Temperature..... Outdoor................ SPU.M.O.
Indoor................. SPU.M.I.
Low-Temperature........ Outdoor................ SPU.L.O.
Indoor................. SPU.L.I.
----------------------------------------------------------------------------------------------------------------
As discussed previously, the current DOE standards for walk-in
refrigeration systems differentiate low-temperature dedicated
condensing systems and unit coolers by net capacity. DOE understands
that for split systems and single-packaged dedicated systems, lower
capacity systems may have greater difficulty attaining higher
efficiency levels than higher capacity systems since compressors for
small-sized equipment are generally less efficient. Additionally, DOE
has found through testing that lower capacity unit coolers tend to have
reduced efficiency compared to higher capacity unit coolers. As
discussed in section III.A of this document, DOE received comments on
the June 2022 Preliminary Analysis suggesting that walk-in
refrigeration system efficiency standards should vary with net capacity
for walk-in refrigeration system equipment classes. In this NOPR, DOE
evaluated multiple capacities in each equipment class to better
ascertain the relationship between efficiency and net capacity. This is
discussed in more detail in the Representative Units subsection of
section IV.C.1.d of this document. In section I, DOE discusses the
proposed standards for walk-in refrigeration systems.
2. Technology Options
DOE considered separate technology options for whole walk-ins,
doors, and panels, and refrigeration systems.
a. Fully Assembled Walk-Ins
In the market analysis and technology assessment presented in
Chapter 3 of the June 2022 preliminary analysis TSD, DOE identified
seven technology options that would be expected to improve the
efficiency of a fully assembled walk-in (i.e., wall, ceiling and floor
panels, door(s), and refrigeration system(s)) but would not apply
specifically to any of the components analyzed in this rulemaking:
Energy storage systems,
Refrigeration system override,
Automatic evaporator fan shut-off,
Non-penetrative internal racks and shelving,
Humidity sensors,
Fiber optic natural lighting, and
Heat reclaim valve.
DOE requested comment on the technology options in section ES.4.2
of the June 2022 Preliminary Analysis TSD. DOE received no comments on
the technology options that might improve the efficiency of whole walk-
ins. Therefore, DOE identified the same technology options for the NOPR
analysis. DOE further discusses these technology options in chapter 3
of the NOPR TSD.
b. Doors and Panels
In the preliminary market analysis and technology assessment, DOE
identified 15 technology options that would be expected to improve the
efficiency of doors and/or panels, as measured by the DOE test
procedure. These technology options are listed in Table IV.5.
Table IV.5--Summary of Door and Panel-Related Technology Options
Analyzed in the June 2022 Preliminary Analysis
------------------------------------------------------------------------
Technology options Applicable component
------------------------------------------------------------------------
Door gaskets.............................. Doors.
Anti-sweat heater/freezer wire controls...
Display and window glass system insulation
performance.
Non-electric, reduced, or no anti-sweat
systems.
Improved frame systems....................
Automatic door opening and closing systems
Occupancy sensors.........................
High-efficiency lighting..................
Automatic insulation deployment systems... Display Doors.
Infiltration-reducing devices or systems Non-display Doors.
(e.g., air curtains, strip curtains,
vestibule entryways, revolving doors).
Insulation thickness and material......... Non-display doors and
panels.
Framing materials.........................
Damage-sensing systems (e.g., air and
water infiltration sensors, heat flux
sensors).
Panel interface systems................... Panels.
------------------------------------------------------------------------
In response to the June 2022 Preliminary Analysis, Hussmann-Doors
stated that its sliding doors are designed to utilize insulation from
the box/cooler wall to minimize door anti-sweat heat power. (Hussmann-
Doors, No. 33 at p. 3) Per Hussmann-Doors' recommendation, DOE is
considering this as a technology option for walk-in doors. The
screening of this technology option is discussed further in section
IV.B.1.a.
DOE is considering the same technology options for doors and panels
in this NOPR that it considered in the June 2022 Preliminary Analysis,
as well as the sliding doors referenced the comment from Hussmann-
Doors.
c. Refrigeration Systems
In the preliminary market analysis and technology assessment, DOE
identified 16 technology options that would be expected to improve the
efficiency of refrigeration systems:
Improved evaporator and condenser fan blades,
Improved evaporator and condenser coils,
Evaporator fan control,
Ambient sub-cooling,
Higher-efficiency fan motors,
Higher-efficiency compressors,
Variable-speed compressors,
Liquid suction heat exchanger,
Adaptive defrost,
Hot gas defrost,
Floating head pressure,
Condenser fan control,
Economizer cooling,
Crank case heater controls,
Single-package thermal insulation, and
Oil management systems.
DOE requested comment on the technology options in section ES.4.2
of
[[Page 60765]]
the June 2022 Preliminary Analysis TSD. AHRI commented that there are
many technology options on the market that may individually provide
energy savings for refrigeration systems, however, these technologies
would require significant modification to implement with current
systems and once implemented, they may no longer provide significant
energy savings, as they are contingent on other aspects of the system.
(AHRI, No. 39 at p. 2)
DOE notes that it applies screening criteria to all potential
technology options which is designed to eliminate technologies that are
not suitable for further analysis as discussed in section IV.B and in
Ch. 4 of the TSD. This includes analysis of the technological
feasibility and practicability. DOE then conducts a full engineering
analysis to weigh the costs and energy savings of each design option
that remains after the screening analysis. The engineering analysis is
discussed in section IV.C. This engineering analysis evaluates
potential changes to other aspects of the system necessary to implement
the option.
HTPG agreed that DOE has considered all the technology options
available on the market for walk-in refrigeration systems that it is
aware of. (HTPG, No. 35 at p. 4) AHRI-Wine commented that wine cellar
manufacturers agree with the technologies that DOE has considered in
its analysis. (AHRI-Wine, No. 39 at p. 2)
Based on comments received from stakeholders, DOE is considering
the same technology options for walk-in refrigeration systems in this
NOPR as were considered in the June 2022 Preliminary Analysis.
B. Screening Analysis
DOE uses the following five screening criteria to determine which
technology options are suitable for further consideration in an energy
conservation standards rulemaking:
1. Technological feasibility. Technologies that are not
incorporated in commercial equipment or in commercially viable,
existing prototypes will not be considered further.
2. Practicability to manufacture, install, and service. If it is
determined that mass production of a technology in commercial equipment
and reliable installation and servicing of the technology could not be
achieved on the scale necessary to serve the relevant market at the
time of the projected compliance date of the standard, then that
technology will not be considered further.
3. Impacts on product utility. If a technology is determined to
have a significant adverse impact on the utility of the equipment to
subgroups of consumers or result in the unavailability of any covered
equipment type with performance characteristics (including
reliability), features, sizes, capacities, and volumes that are
substantially the same as equipment generally available in the United
States at the time, it will not be considered further.
4. Safety of technologies. If it is determined that a technology
would have significant adverse impacts on health or safety, it will not
be considered further.
5. Unique-pathway proprietary technologies. If a technology has
proprietary protection and represents a unique pathway to achieving a
given efficiency level, it will not be considered further, due to the
potential for monopolistic concerns. 10 CFR 431.4; 10 CFR part 430,
subpart C, appendix A, sections 6(c)(3) and 7(b).
In summary, if DOE determines that a technology, or a combination
of technologies, fails to meet one or more of the listed five criteria,
it will be excluded from further consideration in the engineering
analysis. The reasons for eliminating any technology are discussed in
the following sections.
The subsequent sections include comments from interested parties
pertinent to the screening criteria, DOE's evaluation of each
technology option against the screening analysis criteria, and whether
DOE determined that a technology option should be excluded (``screened
out'') based on the screening criteria.
1. Screened Out Technologies
a. Fully Assembled Walk-Ins
In the June 2022 Preliminary Analysis, DOE screened out the
following technology options under the tentative assumption that they
would not affect rated energy consumption of the walk-in components as
measured by the DOE test procedure. While these technologies may
improve the energy efficiency of a fully assembled walk-in installed in
the field, DOE's current walk-in test procedures are component-specific
(i.e., DOE does not have a test procedure for determining energy use of
a fully assembled walk-in):
Energy storage systems,
Refrigeration system override,
Automatic evaporator fan shut-off,
Non-penetrative internal racks and shelving,
Humidity sensors, and
Heat reclaim valves.
See section 4.2.1 of the June 2022 Preliminary Analysis TSD.
Furthermore, in the June 2022 Preliminary Analysis, DOE screened
out fiber optic natural lighting since it is not technologically
feasible. DOE is not aware of any such systems currently manufactured
and sold for walk-in operations.
DOE requested comment on the technologies that it had screened out
in section ES.4.3 of the June 2022 Preliminary Analysis TSD. HTPG
commented that it agrees that energy storage systems, refrigeration
systems override, automatic evaporator fan shut-off, humidity sensors,
and heat reclaim valves do not affect the rated energy consumption as
measured under the walk-in test procedures. (HTPG, No. 359 at p. 4)
Lennox supported DOE's conclusions and rationale for the screened out
technologies. (Lennox, No. 36 at p. 3) AHRI-Wine stated that wine
cellar manufacturers agree with the technologies screened in and out of
the analysis. (AHRI-Wine, No. 39 at p. 2)
In its NOPR analysis, DOE has screened out all technology options
for whole walk-ins for the same rationales as it did for the June 2022
Preliminary Analysis.
b. Doors and Panels
In the June 2022 Preliminary Analysis, DOE screened out the
following technology options because any reduction in energy use would
not be captured by the test procedure in appendix A to subpart R of 10
CFR part 431 (``appendix A'') and any increase in R-value would not be
captured by the test procedure in appendix B to subpart R of 10 CFR
part 431 (``appendix B''):
Infiltration-reducing devices,
Air and water infiltration sensors,
Heat flux sensors, and
Structural materials for panels.
Infiltration-reducing technologies could include door gaskets,
automatic door opening and closing systems, air curtains, strip
curtains, vestibule entryways, revolving doors, and panel interface
systems. In the June 2022 Preliminary Analysis, DOE had tentatively
determined that any potential energy savings from infiltration-reducing
devices would not be captured because air infiltration is a
characteristic of a fully assembled walk-in. The walk-in test
procedures do not evaluate the energy use of the assembled walk-in box
and instead evaluate the energy use of a single component (i.e., door
or panel); therefore, technologies that may improve energy efficiency
of the full walk-in box were screened out.
Additionally, DOE preliminarily concluded that any potential energy
savings from air and water infiltration sensors, heat flux sensors, and
structural materials for panels would not be captured by either the
appendix A or
[[Page 60766]]
appendix B test procedures. Air and water infiltration sensors and heat
flux sensors are technology options that would most benefit the end
user for monitoring the continuing performance of walk-in components;
however, the potential degradation captured by these sensors over the
lifetime of a walk-in are not reflected in the current test procedure.
Additionally, changes to panel structural materials are not captured in
the test procedure since the current walk-in panels test procedure
provides a method for determining the R-value of the panel insulation
only. In other words, the overall R-value of the panel, including
structural materials, is not captured by the current test procedure.
Therefore, such technologies were screened out.
Furthermore, in the June 2022 Preliminary Analysis, DOE screened
out the following technologies due to technological infeasibility since
DOE was not able to find these technologies incorporated into either
prototypes or commercially available walk-in doors or panels:
Non-electric anti-sweat systems,
Higher efficiency LEDs, and
Automatic insulation deployment systems.
In the June 2022 Preliminary Analysis, DOE screened out panel and
door insulation thicker than six inches because DOE received feedback
during manufacturer interviews that it is not practicable to
manufacture and install and it has adverse impacts on consumer utility.
See section 4.3.2.4 of chapter 4 of the June 2022 Preliminary Analysis
TSD. DOE preliminarily concluded that insulation thicker than six
inches would be heavy, unwieldy, and would take up space that the
consumer would otherwise use. Additionally, panels and non-display
doors greater than six inches that use foam-in-place insulation would
take an excessive amount of time to cure, impacting the practicability
to manufacture, install, and service.
In section ES.4.1 of the June 2022 Preliminary Analysis, DOE
requested comment on the technology options it had screened out for
doors and panels. DOE received no comment on the screened out
technologies for doors and panels. In this analysis, DOE is screening
out the same technologies that it screened out in the June 2022
Preliminary Analysis, in addition to the eliminated anti-sweat heater
system technology option.
Walk-in doors typically use anti-sweat heater wires to prevent (1)
condensation from collecting on the glass, frame, or any other portion
of the door, which can puddle and be hazardous to consumers, (2) glass
from fogging, and (3) condensation that may lead to low-temperature
doors freezing shut. The amount and rate of condensation on walk-in
doors is dependent on the relative humidity surrounding the walk-in and
the surface temperature of the door. To ensure the temperature of the
door surface stays above the dew point of its surroundings, electric
resistive heater wire is installed around the frame of the door. DOE
recognizes that anti-sweat systems on doors may be necessary in high-
humidity environments and DOE does not have sufficient evidence to
demonstrate that anti-sweat heat can be removed from doors installed in
all climate zones of the U.S. without having a potential negative
impact on the safety and utility of the walk-in. Therefore, DOE is
screening out eliminated anti-sweat heater systems in this NOPR on the
basis of safety of technology.
Furthermore, DOE is screening out the technology option to utilize
insulation from the box/cooler wall to minimize door anti-sweat heat
power recommended by Hussmann-Doors in its comment and discussed in
section IV.A.2.b of this document. DOE recognizes that an ideally
designed walk-in box ensures that panel design could reduce door
sweating; however, DOE notes that since its walk-in test procedures
evaluate the performance of walk-in components separately, these design
pairings are not captured by the test procedure and therefore cannot be
used to analyze higher efficiency levels.
c. Refrigeration Systems
In the June 2022 Preliminary Analysis, DOE tentatively determined
that adaptive defrost, hot gas defrost, oil management systems, and
economizer cooling would not affect the measured AWEF2 value of walk-in
refrigeration systems based on appendix C1. DOE requested comment on
the screened out technologies in section ES.4.3 of the June 2022
Preliminary Analysis TSD.
HTPG commented that it agrees that oil management systems, adaptive
defrost, hot gas defrost, and economizer cooling do not affect rated
energy consumption as measured under the test procedures for
refrigeration systems. (HTPG, No. 35 at p. 4)
DOE has tentatively determined that oil management systems,
adaptive defrost, hot gas defrost, and economizer cooling would not
affect the measured AWEF2 value of walk-in refrigeration systems when
measured using appendix C1.
In the June 2022 Preliminary Analysis, DOE also screened out three-
phase motors as a design option. In general, three-phase motors can
save energy compared to single-phase motors, however, use of three-
phase motors requires three-phase power. Not all businesses that use
walk-ins are equipped with three-phase power, and therefore must use
single-phase equipment. DOE therefore screened out this design option
on the grounds of utility.
HTPG commented that it agrees with screening out three-phase motors
as a technology option. Id. In this NOPR analysis, DOE is screening out
three-phase motors based on utility.
In response to the June 2022 Preliminary Analysis, AHRI-Wine
recommended that DOE consider how a 50-percent increase in condenser
face area would increase the footprint of a single-packaged wine cooler
system and how this increase in footprint would affect the market.
(AHRI-Wine, No. 39 at p. 2) DOE received similar feedback during
manufacturer interviews. DOE notes that high-temperature walk-ins are
often installed in residential applications that have standard stud
spacing in walls and standard joist spacing in floors and ceilings;
therefore, these units may be designed to fit between these structural
members for construction and aesthetic reasons. DOE has tentatively
determined that consumers would lose the compact feature of high-
temperature refrigeration systems if the evaporator or condenser heat
exchangers underwent a considerable increase in size. Therefore, DOE is
proposing to screen out improved evaporator and condenser coils for
high-temperature refrigeration systems on the grounds of customer
utility due to the additional heat exchanger size needed for this
technology option.
The screened out technologies for fully assembled walk-ins and each
component of walk-ins are discussed in more detail in chapter 4 of the
accompanying TSD.
2. Remaining Technologies
Through a review of each technology, DOE tentatively concludes that
none of the identified technologies for whole walk-ins, listed in
section IV.A.2.a, met all five screening criteria to be examined
further as design options in DOE's NOPR analysis.
a. Doors and Panels
Through a review of each technology, DOE tentatively concludes that
all of the other identified technologies for doors and panels, listed
in section IV.A.2.b of this document met all five screening criteria to
be examined further as design options in DOE's NOPR analysis. In
[[Page 60767]]
summary, DOE did not screen out the following technology options:
Glass system insulation performance for display doors,
Occupancy sensors (lighting controls) for doors,
Anti-sweat heater controls for doors,
Improved frame systems and materials for non-display
doors,
Reduced anti-sweat heater systems for doors, and
Increased insulation thicknesses up to 6 inches for non-
display doors and panels.
In section ES.4.3 of the June 2022 Preliminary Analysis TSD, DOE
requested comment on the screened in technologies. Hussmann-Doors
stated that increased insulation thicknesses up to 6 inches for non-
display doors and panels would help reduce insulation requirements on
framing materials for door products and that increased wall thickness
would offer additional insulation. (Hussmann-Doors, No. 33 at p. 3) DOE
understands this comment to support increased insulation thicknesses up
to 6 inches as a technology option for non-display doors and panels.
Additionally, Hussmann-Doors stated that the cost of applying
controllers (e.g., to control the on time of electrical components like
lighting and anti-sweat heat) to door products is not economically
justified by the resulting energy savings. However, Hussmann-Doors
commented that it does use controllers on its products to be compliant
with regulations. (Hussmann-Doors, No. 33 at p. 2) Hussmann-Doors also
commented that it does not see a need for a change to the standard for
doors based on the technology option of occupancy sensors. Id. DOE
understands Hussmann-Doors comment to mean that it believes the energy
consumption standard for doors should not change to reflect that
occupancy sensors can reduce energy consumption. In response to these
comments, DOE notes that it in addition to the screening analysis
discussed above, it conducts a full engineering analysis to weigh the
costs and energy savings of each potential design option. While DOE
evaluates specific design options for the purposes of developing a
representative cost-efficiency curve, manufacturers are not bound to
implement the design options that DOE analyzes to meet a performance-
based energy conservation standard. Manufacturers may employ any design
option, whether DOE has evaluated it or not, so long as it meets the
energy consumption standard based on the Federal test procedure. The
engineering analysis is discussed further in section IV.C of this
document.
DOE has initially determined that these technology options are
technologically feasible because they are being used or have previously
been used in commercially available equipment or working prototypes.
DOE also finds that all of the remaining technology options meet the
other screening criteria (i.e., practicable to manufacture, install,
and service and do not result in adverse impacts on consumer utility,
product availability, health, or safety, unique-pathway proprietary
technologies). For additional details, see chapter 4 of the NOPR TSD.
b. Refrigeration Systems
Through a review of each technology, DOE tentatively concludes that
all the other identified technologies listed in section IV.A.2.c of
this document met all five screening criteria to be examined further as
design options in DOE's NOPR analysis. In summary, DOE did not screen
out the following technology options for walk-in refrigeration systems:
Hydrocarbon refrigerants,
Higher efficiency compressors,
Improved evaporator and condenser coil,
Higher efficiency condenser fan motors,
Improved condenser and evaporator fan blades,
Ambient sub-cooling,
Off-cycle evaporator fan control,
Head pressure control,
Variable-speed condenser fan control,
Crankcase heater controls,
Improved thermal insulation for single-packaged dedicated
systems,
Higher efficiency evaporator fan motors,
On-cycle evaporator fan control, and
Liquid suction heat exchanger.
In section ES.4.3 of the June 2022 Preliminary Analysis TSD, DOE
requested comment on the screened in technologies. DOE received no
comment on the screened in technologies for refrigeration systems.
DOE has initially determined that these technology options are
technologically feasible because they are being used or have previously
been used in commercially available products or working prototypes. DOE
also finds that all the remaining technology options meet the other
screening criteria (i.e., practicable to manufacture, install, and
service and do not result in adverse impacts on consumer utility,
product availability, health, or safety, unique-pathway proprietary
technologies). For additional details, see chapter 4 of the NOPR TSD
C. Engineering Analysis
The purpose of the engineering analysis is to establish the
relationship between the efficiency and cost of each component of walk-
ins (e.g., doors, panels, and refrigeration systems). There are two
elements to consider in the engineering analysis; the selection of
efficiency levels to analyze (i.e., the ``efficiency analysis'') and
the determination of product cost at each efficiency level (i.e., the
``cost analysis''). In determining the performance of higher-efficiency
walk-ins, DOE considers technologies and design option combinations not
eliminated by the screening analysis. For each walk-in component
equipment class, DOE estimates the baseline cost, as well as the
incremental cost for the walk-in component at efficiency levels above
the baseline. The output of the engineering analysis is a set of cost-
efficiency ``curves'' that are used in downstream analyses (i.e., the
LCC and PBP analyses and the NIA).
1. Efficiency Analysis
DOE typically uses one of two approaches to develop energy
efficiency levels for the engineering analysis: (1) relying on observed
efficiency levels in the market (i.e., the efficiency-level approach),
or (2) determining the incremental efficiency improvements associated
with incorporating specific design options to a baseline model (i.e.,
the design-option approach). Using the efficiency-level approach, the
efficiency levels established for the analysis are determined based on
the market distribution of existing products (in other words, based on
the range of efficiencies and efficiency level ``clusters'' that
already exist on the market). Using the design option approach, the
efficiency levels established for the analysis are determined through
detailed engineering calculations and/or computer simulations of the
efficiency improvements from implementing specific design options that
have been identified in the technology assessment. DOE may also rely on
a combination of these two approaches. For example, the efficiency-
level approach (based on actual products on the market) may be extended
using the design option approach to ``gap fill'' levels (to bridge
large gaps between other identified efficiency levels) and/or to
extrapolate to the max-tech level (particularly in cases where the max-
tech level exceeds the maximum efficiency level currently available on
the market).
[[Page 60768]]
In this rulemaking, DOE relies on a design-option approach for
doors, panels, dedicated condensing units, and single-packaged
dedicated systems. DOE relies on both a design-option and an
efficiency-level approach for unit coolers, depending on the equipment
class. These approaches are discussed in the following sections.
a. Display Doors
Representative Units
As previously mentioned in section IV.A.1.a of this document, DOE
evaluated equipment classes for display doors in the June 2022
Preliminary Analysis based on the presence or absence of a motor. In
the June 2022 Preliminary Analysis, DOE analyzed three representative
door sizes for manually opening display doors and two representative
door sizes for motorized display doors. The representative units were
based on the number of door openings within a common frame.
Additionally, DOE based its representative door sizes on typical height
and width of doors found in equipment product literature. See section
5.3.1 of chapter 5 of the June 2022 Preliminary Analysis TSD. DOE
sought comment on the representative units selected in section ES.4.5
of the June 2022 Preliminary Analysis TSD.
In response, Hussmann-Doors commented that the representative door
sizes used in the analysis are appropriate; however, Hussmann-Doors
stated that it sells a sliding door that is larger than the
representative units. (Hussmann-Doors, No. 33 at p. 3) DOE notes that
the representative units it selects for analysis are intended to be
representative of the display door industry as a whole and cannot
capture every door available on the market. Additionally, DOE
ultimately did not define representative units for motorized display
doors in this NOPR since, as discussed in section IV.A.1.a of this
document, DOE did not evaluate higher efficiency levels for these doors
in its analysis. However, DOE may consider evaluating higher efficiency
levels for motorized display doors in a future rulemaking, at which
time it would determine representative units based on the market at
that time.
DOE received no comments on the manually opening display door
representative units; therefore, in this NOPR, DOE maintained the same
manually opening display door representative units that were evaluated
in the June 2022 Preliminary Analysis. Table IV.6 lists the display
door classes and sizes that DOE analyzed in its engineering analysis
for this NOPR, where the dimensions listed are consistent with the
surface area that is used to determine the maximum daily energy
consumption.
Table IV.6--Representative Units Analyzed for Display Doors
----------------------------------------------------------------------------------------------------------------
Number of door Dimensions height
Opening mechanism Temperature Class code openings x length, ft
----------------------------------------------------------------------------------------------------------------
Manual........................... Medium-temperature.. DW.M................ 1 6.25 x 2.5
3 6.25 x 7.5
5 6.25 x 12.5
Low-temperature..... DW.L................ 1 6.25 x 2.5
3 6.25 x 7.5
5 6.25 x 12.5
----------------------------------------------------------------------------------------------------------------
Baseline Efficiency, Design Options, and Higher Efficiency Levels
To determine the baseline efficiency of manually opening display
doors in the June 2022 Preliminary Analysis, DOE relied on the current
energy conservation standards and minimum prescriptive requirements for
the glass pack of transparent reach-in doors at 10 CFR 431.306(b)(1)-
(2). DOE's analysis suggested that manufacturers already implement
high-efficiency frame designs to minimize thermal transmission;
therefore, DOE included high-efficiency frame designs as a baseline
design option for manually opening display doors in the June 2022
Preliminary Analysis.
In the June 2022 Preliminary Analysis, DOE evaluated the design
options listed in Table IV.7 for manually opening display doors. As
noted, design option DR1 includes baseline design options; additional
design options are evaluated in DR2 (efficiency level 1) and DR3
(efficiency level 2).
Table IV.7--Design Options Evaluated in the June 2022 Preliminary Analysis and This NOPR Analysis for Display
Doors
----------------------------------------------------------------------------------------------------------------
Description
-------------------------------------------------
Efficiency level Design option code Medium-temperature, Low-temperature, manual
manual display doors display doors
----------------------------------------------------------------------------------------------------------------
0 (Baseline)......................... DR1.................... 2-pane glass with argon 3-pane glass with argon
gas fill. gas fill.
1.................................... DR2.................... 3-pane glass with argon 3-pane glass with
gas fill. krypton gas fill.
2.................................... DR3.................... 2-pane vacuum-insulated 2-pane vacuum-insulated
glass. glass.
----------------------------------------------------------------------------------------------------------------
In response to the June 2022 Preliminary Analysis, Hussmann-Doors
commented that vacuum-insulated glass on a sliding door affects the U-
factor. DOE interprets this comment to suggest that vacuum-insulated
glass could be used to reach higher efficiency levels for all display
doors, including manually opening display doors. DOE notes that vacuum-
insulated glass is the maximum technology option for manually opening
display doors.
DOE received no other comments on the design options or efficiency
levels for manually opening display doors. In this NOPR analysis, DOE
maintained the same baseline efficiency level, design options, and
higher efficiency levels that it evaluated in the June 2022 Preliminary
Analysis.
[[Page 60769]]
b. Non-Display Doors
Representative Units
As previously mentioned in section IV.A.1.a of this document, DOE
evaluated equipment classes for non-display doors based on the presence
or absence of a motorized door opener in the June 2022 Preliminary
Analysis. DOE analyzed three representative sizes for each class of
non-display doors based on the representative sizes analyzed for both
passage and freight doors in the June 2014 Final Rule and based on
typical height and width of doors found in current equipment product
literature. See section 5.3.1 of chapter 5 of the preliminary analysis
TSD. DOE sought comment on the representative units selected in section
ES.4.5 of the preliminary analysis TSD. DOE did not receive any
stakeholder comments with respect to non-display door representative
units.
In this NOPR analysis, DOE modified the non-display door
representative sizes that it evaluated based on further review of
product literature and interviews with manufacturers. Table IV.8 lists
the non-display door classes and sizes that DOE analyzed in the
engineering analysis for this NOPR.
Table IV.8--Representative Units Analyzed for Non-Display Doors
----------------------------------------------------------------------------------------------------------------
Dimensions,
Opening mechanism Temperature Class code Size height x length,
in
----------------------------------------------------------------------------------------------------------------
Manual.......................... Medium-temperature. NM.M.............. Small............. 84 x 38
Medium............ 90 x 40
Large............. 96 x 56
Low-temperature.... NM.L.............. Small............. 84 x 38
Medium............ 90 x 40
Large............. 96 x 56
Motorized....................... Medium-temperature. NO.M.............. Small............. 100 x 66
Medium............ 118 x 90
Large............. 154 x 90
Low-temperature.... NO.L.............. Small............. 100 x 66
Medium............ 118 x 90
Large............. 154 x 90
----------------------------------------------------------------------------------------------------------------
Baseline Efficiency, Design Options, and Higher Efficiency Levels
To determine non-display door baseline efficiency, DOE relied on
the current energy conservation standards. For the June 2022
Preliminary Analysis, based on certifications in the private
certification and compliance management system (``CCMS'') database and
product literature, DOE assumed that baseline non-display doors had
3.5-inch-thick insulation for coolers and 4-inch-thick insulation for
freezers, wood framing materials, anti-sweat heat with no controls, and
lighting with no controls.
For the June 2022 Preliminary Analysis, DOE evaluated the design
options listed in Table IV.9 for non-display doors. While DOE largely
maintained these design options in its analysis for this NOPR, there
were a few changes specific to their implementation, discussed in more
detail below.
Table IV.9--Design Options Evaluated in the June 2022 Preliminary
Analysis for Non-Display Doors
------------------------------------------------------------------------
Design option code Description
------------------------------------------------------------------------
Occupancy sensors (lighting
controls).
LNC.............................. No lighting controls.
LCTRL............................ Lighting controls.
Anti-sweat heater wire controls.
ASHNC............................ No anti-sweat heater controls.
ASCTRL........................... Anti-sweat heater controls.
Improved frame systems and lower
conductivity framing materials.
FR1.............................. Baseline non-display door frame made
of wood.
FR2.............................. Improved non-display door frame made
of insulation.
Decreased anti-sweat heater power.
ASH1............................. Baseline anti-sweat heater power.
ASH2............................. Reduced or eliminated anti-sweat
heater power.
Increased Insulation Thickness.
TCK1............................. Baseline insulation thickness.
TCK2............................. Increased insulation thickness 1.
TCK3............................. Increased insulation thickness 2.
TCK4............................. Increased insulation thickness 3.
------------------------------------------------------------------------
In the June 2022 Preliminary Analysis, DOE included lighting in
baseline manually opening non-display doors. DOE's research at the time
indicated that non-display doors sometimes include lighting and
switches to operate that lighting. Therefore, DOE was able to use
lighting controllers as a design option for the representative units it
modeled. However, upon further review of the market, DOE found that
lighting may or may not be included with non-display doors. Therefore,
DOE removed lighting from its baseline representative units of manually
opening non-display doors in this NOPR, thus removing the use of the
lighting controller as a design option in its analysis of non-display
doors.
In the June 2022 Preliminary Analysis, DOE combined improved non-
display door framing systems and materials with reduced or eliminated
anti-sweat heater power. In section ES.4.6 of the June 2022 Preliminary
Analysis TSD, DOE requested comment on its assumptions that anti-sweat
heater power can be reduced or eliminated by use of improved framing
systems and materials. If anti-sweat heater power can be reduced
through other means of design or technology options for doors, DOE
sought specific data on the achievable reduction in anti-sweat heater
power and the cost to implement. DOE received no comment on whether
improving framing systems and materials could reduce anti-sweat heater
or by how much anti-sweat heater power could potentially be reduced.
In this NOPR analysis, DOE decoupled improved frame systems and
materials from the reduction in anti-sweat heater power and implemented
these as separate design options. Additionally, in this NOPR analysis,
rather than present a fixed value of anti-
[[Page 60770]]
sweat heater wire power in watts, DOE is presenting the amount of anti-
sweat heater power in terms of rated power per linear foot, which can
be converted into the total anti-sweat heater power per representative
unit using door leaf dimensions. DOE recognizes that the total value of
anti-sweat heater power will vary based on the size of the door leaf
but that manufacturers generally use wire with the same rating of power
per linear foot across doors of different sizes. DOE is presenting
anti-sweat heat in terms of a rated power per linear foot and is
soliciting feedback on the values used in this analysis.
In the June 2022 Preliminary Analysis, DOE had considered
eliminated anti-sweat heater power as a design option for medium-
temperature non-display doors, however, as discussed in section
IV.B.1.b of this document, DOE is no longer considering elimination of
anti-sweat heater systems as a design option since DOE does not have
sufficient evidence to demonstrate that doors without anti-sweat heat
could be installed in all climates or installation locations. Instead,
DOE has tentatively concluded in this NOPR that cooler doors could
reduce anti-sweat heater power. Based on certified information in DOE's
private CCMS database, approximately 93 percent of models reported a
rated anti-sweat heater power of less than or equal to 2 W/ft;
therefore, DOE evaluated the energy savings and cost associated with
reducing rated anti-sweat heater power from baseline levels to 2 W/ft.
For low-temperature non-display doors, in the June 2022 Preliminary
Analysis, DOE determined reduced anti-sweat heater power values based
on a line of best fit of anti-sweat heater power versus door area from
the lower third of non-zero anti-sweat heater power values certified in
DOE's private CCMS database. See section 5.7.1.4 of chapter 5 of the
June 2022 Preliminary Analysis TSD. In this NOPR analysis, based on a
combination of certified values in CCMS, rated anti-sweat heater power
per linear foot of wire based on product literature, and information
received during confidential interviews with manufacturers, DOE has
tentatively concluded that freezer doors may be able to implement a
reduced rated anti-sweat heater system power of 5 W/ft.
Table IV.10 shows the baseline and reduced anti-sweat heater wire
power evaluated in this NOPR for each equipment class. The design
options that DOE evaluated for non-display doors for the NOPR analysis
are shown in Table IV.11.
Table IV.10--Anti-Sweat Heater Wire Power per Linear Foot Used in NOPR
Analysis
------------------------------------------------------------------------
Baseline anti- Reduced anti-
sweat heater wire sweat heater wire
Equipment class power rating (W/ power rating (W/
ft) ft)
------------------------------------------------------------------------
Medium-Temperature, Manually- 4 2
Opening Non-Display Doors........
Low-Temperature, Manually-Opening 10 5
Non-Display Doors................
Medium-Temperature, Motorized Non- 4 2
Display Doors....................
Low-Temperature, Motorized Non- 9.5 5
Display Doors....................
------------------------------------------------------------------------
Table IV.11--Design Options Evaluated in This NOPR Analysis for Non-
Display Doors
------------------------------------------------------------------------
Design option code Description
------------------------------------------------------------------------
Anti-sweat heater wire controls.
ASHNC............................ No anti-sweat heater controls.
ASCTRL........................... Anti-sweat heater controls.
Improved frame systems and lower
conductivity framing materials.
FR1.............................. Baseline non-display door framing
made of wood.
FR2.............................. Improved non-display door framing
made of insulation.
Decreased anti-sweat heater power.
ASH1............................. Baseline anti-sweat heater power.
ASH2............................. Reduced anti-sweat heater power.
Increased Insulation Thickness.
TCK1............................. Baseline insulation thickness.
TCK2............................. Increased insulation thickness 1.
TCK3............................. Increased insulation thickness 2.
TCK4............................. Increased insulation thickness 3.
------------------------------------------------------------------------
DOE seeks comment on the baseline and assumed reduction in anti-
sweat heater wire power listed in Table IV.10. DOE specifically seeks
feedback on whether the reduced anti-sweat heater wire power is
acceptable for use in walk-in doors at all climates and installations
throughout the U.S.
c. Panels
Representative Units
In the June 2022 Preliminary Analysis, DOE evaluated the same
representative units for each panel equipment class that it evaluated
for the June 2014 Final Rule. See section 5.3.2 of chapter 5 of the
June 2022 Preliminary Analysis TSD. DOE requested comment on these
panel representative units in section ES.4.5 of the June 2022
Preliminary Analysis TSD. DOE did not receive any comments regarding
the representative units analyzed for panels. Therefore, DOE maintained
the same representative units it evaluated in the June 2022 Preliminary
Analysis for this NOPR analysis. Table IV.12 summarizes the
representative units evaluated for walk-in panel equipment classes.
Table IV.12--Representative Units Analyzed for Panels in This NOPR
----------------------------------------------------------------------------------------------------------------
Dimensions
Equipment Temperature Equipment class code height x
length, ft
----------------------------------------------------------------------------------------------------------------
Structural.............................. Medium.................... PS.M...................... 8 x 1.5
8 x 4
9 x 5.5
Structural.............................. Low....................... PS.L...................... 8 x 1.5
8 x 4
[[Page 60771]]
9 x 5.5
Floor................................... .......................... PF.L...................... 8 x 2
8 x 4
9 x 6
----------------------------------------------------------------------------------------------------------------
Baseline Efficiency, Design Options and Efficiency Levels
For panels, DOE evaluated increasing insulation thickness to obtain
higher insulation R-values as calculated pursuant to appendix B of
subpart R to 10 CFR 431. The thermal resistance of insulating materials
increases approximately linearly with material thickness.
For determining the baseline efficiency level, DOE relied on the
current R-value standards. Based on DOE's analysis of the market, 3.5
inches of foam insulation is generally used for baseline medium-
temperature panels and low-temperature floor panels, while 4 inches of
foam insulation is used in baseline low-temperature structural panels
to meet the minimum R-value requirements specified in 10 CFR
431.306(a)(3)-(4).
In addition, DOE found that many panel manufacturers offer
insulation in thicknesses of 4, 5, and 6 inches. DOE also observed that
the majority (approximately 75 percent) of the market uses polyurethane
insulation, with the remainder using extruded polystyrene (``XPS''),
expanded polystyrene, and polyisocyanurate insulation in its walk-in
panels. Therefore, DOE assessed the incremental increase in R-value for
polyurethane insulation at 4, 5, and 6 inches as design options, with 6
inches being the max-tech design option.
d. Dedicated Condensing Units and Single-Packaged Dedicated Systems
Refrigerants Analyzed
In the June 2022 Preliminary Analysis, DOE assumed R-448A as a
refrigerant for medium- and low-temperature dedicated condensing units
and single-packaged dedicated systems. Based on the available
compressor performance coefficients, and an examination of the
refrigerant compositions, DOE tentatively concluded that R-448A and R-
449A have nearly identical performance characteristics for walk-in
applications and that AWEF2 standards would not be meaningfully changed
if analysis was conducted using R-449A instead of R-448A. R-448A/R-449A
was chosen because the walk-in industry is shifting to lower global
warming potential (``GWP'') refrigerants. R-448A/R-449A have much lower
GWP compared to R-404A--additionally R-448A/R-449A has a higher glide,
which will tend to disadvantage dedicated condensing units when they
are tested alone according to the DOE test procedure. In other words,
R-448A/R-449A are the most conservative, lower GWP, widely available
refrigeration options. For the June 2022 Preliminary Analysis, DOE used
R-134A in its evaluation of high-temperature single-packaged dedicated
units since this is the only refrigerant option currently offered for
this equipment.
DOE requested comment on whether the refrigerants used are
representative of the current and future walk-in market in section
ES.4.8 of the June 2022 Preliminary Analysis TSD. In response to the
June 2022 Preliminary Analysis, DOE received several comments on the
refrigerants used in the analysis and on the need to consider lower GWP
refrigerants.
HTPG agreed with DOE using R-448A and R-449A in its analysis of
medium- and low-temperature dedicated condensing units, specifically
the compressor coefficients and the reduction in mass flow rate. (HTPG,
No. 35 at pp. 3, 6) AHRI agreed with DOE using R-448A and R-449A in its
analysis, however, it recommended that A2L \26\ or other refrigerants
(i.e., R-454A, R-454C, R-455A, R-744A) be considered in a future
analysis. (AHRI, No. 39 at p. 3) Hussmann-Refrigeration stated that due
to the Environmental Protection Agency (``EPA'') regulations,\27\
changes to refrigerants are expected and further analysis of system
performance may be required to determine the efficiency impact of the
new refrigerants. (Hussmann-Refrigeration, No. 38 at p. 2) Hussmann-
Refrigeration additionally commented that it agrees with the views of
other AHRI members on the matter of the transition to A2L refrigerants
and stated that R-448A and R-449A will not be available for future
markets and are currently not available for new applications at a
charge level greater than 50 pounds in California. (Hussmann-
Refrigeration, No. 38 at p. 4) Lennox commented that R-448A and R-449A
are not representative of the future market, which would likely consist
of R-454A, R-454C, R-455A, and R-744. (Lennox, No. 36 at p. 5) Lennox
also stated that R-744 (i.e., CO2) could pose a significant
challenge if it is required for transcritical operation.\28\ Id. Lennox
recommended that DOE consider the technological feasibility,
performance, and cost impacts of the transition to lower GWP
refrigerants, specifically A2L and CO2 refrigerants, when
proposing energy conservation standards. (Lennox, No. 36 at pp. 1-3).
HTPG also recommended that DOE consider the transition to low-GWP
refrigerants in its analysis. (HTPG, No. 35 at p. 6)
---------------------------------------------------------------------------
\26\ A2L is a refrigerant classification from the American
Society of Heating, Refrigeration, and Air-Conditioning Engineers
(``ASHRAE'') Standard 34: ``Designation and Safety Classification of
Refrigerants''. The A2L class defines refrigerants that are
nontoxic, but mildly flammable. Refrigerants in this classification
include R-454A, R-454C, and R-455A.
\27\ See ``Phasedown of Hydrofluorocarbons: Allowance Allocation
Methodology for 2024 and Later Years'', 87 FR 66372.
\28\ CO2 refrigeration systems are transcritical
because the high-temperature refrigerant that is cooled by ambient
air is in a supercritical state, above the 87.8 [deg]F critical
point temperature, above which the refrigerant cannot exist as
separate vapor and liquid phases.
---------------------------------------------------------------------------
EPA published a NOPR, ``Phasedown of Hydrofluorocarbons:
Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection
(i) the American Innovation and Manufacturing Act of 2020'', on
December 15, 2022, as a part of the American Innovation and
Manufacturing (``AIM'') Act (``December 2022 AIM NOPR'') which outlined
new refrigerant regulations regarding acceptable GWP limits for various
air conditioning and refrigeration systems. 87 FR 76738. One proposal
in the December 2022 AIM NOPR is to limit the GWP of refrigerants in
remote condensing units used in retail food refrigeration or cold
storage warehouse systems to 300 GWP or less if the system's
refrigerant charge is less than 200 pounds. As proposed, this limit
[[Page 60772]]
would take effect on January 1, 2025. DOE has tentatively determined
that walk-in refrigeration systems within the scope of this energy
conservation standards rulemaking, designed to cool a chilled storage
area less than 3,000 square feet, would not exceed 200 pounds of
refrigerant charge and would therefore be subject to the GWP
limitations proposed in the December 2022 AIM NOPR. R-448A and R-449A
have GWPs of just under 1,400, well over the proposed 300 GWP limit.
Therefore, DOE acknowledges that by the compliance date of any
potential standards promulgated by this rulemaking, R-448A and R-449A
may no longer be permitted for use in walk-in refrigeration systems if
the proposals in the December 2022 AIM NOPR are finalized.
For this NOPR, to estimate potential performance penalties
associated with transitioning from R-448A and R-449A to a lower GWP
refrigerant, DOE modeled the performance of three potential replacement
A2L refrigerants: R-454A, R-454C, and R-455A. At the DOE test
conditions prescribed for dedicated condensing units tested alone, R-
407A, R-448A and R-454A have condenser glides of less than 9 [deg]F,
R454C has a glide of roughly 12 [deg]F, and R455A has a glide or
roughly 17 [deg]F. When analyzed with available compressor
coefficients, DOE found that R-454A had a coefficient of performance
higher than R-407A and R-448A, while R455A and R-454C had coefficients
of performance that were lower than R-407A and R-448A. Of the three
refrigerants with GWPs less than 300, R-454A has the lowest glide and
highest coefficient of performance. Based on these results, DOE has
tentatively determined that R-454A would be the most likely replacement
for R-407A, R-448A, and R-449A in walk-in applications if the proposals
in the December 2022 AIM NOPR are adopted. DOE further analyzed the
compression efficiency of R-454A compared to R-448A and has tentatively
determined that walk-in dedicated condensing systems would not suffer a
performance penalty when switching from R-407A, R-448A, or R-449A to R-
454A.
DOE attempted to corroborate these modeling results with data from
testing. During interviews, DOE asked if manufacturers had tested any
A2L refrigerants such as R-454A, R-454C, and R-455A. At the time,
manufacturers indicated that they were not able to obtain a sufficient
quantity of these refrigerants for testing. Manufacturers stated that
chemical companies that manufacturer these refrigerants were still in
the process of formulating these refrigerant blends. Additionally,
manufacturers emphasized that there was not yet industry consensus on
the best refrigerant to move forward with given the information they
have about refrigerants and regulations at this time. As such, DOE was
not able to compare its modeling results to real-world tests prior to
the publication of this NOPR.
In response to the December 2022 AIM NOPR the Chemours Company FC,
LLC (``Chemours'') submitted a comment in which they presented results
from an analysis comparing the performance of various refrigerants.
(Chemours, EPA-HQ-OAR-2021-0643 No. 141 at p. 12) That analysis showed
that R-454A has similar, if not better, performance to refrigerants
used in walk-in coolers today. Id. Chemours generally supported R-454A
as a replacement for higher GWP refrigerants. Id.
DOE has tentatively determined that any standards set based on an
analysis of dedicated condensing units operating with R-448A or R-449A
would be appropriate for units operating with R-454A. DOE has therefore
continued to use R-448A as the baseline refrigerant for all medium- and
low-temperature dedicated condensing units and single-packaged
dedicated systems in this NOPR analysis.
DOE requests test results or performance data for walk-in
refrigeration systems using R-454A, R-454C, and/or R-455A.
Additionally, DOE requests comment on its tentative determination that
R-454A is the most likely replacement for R-448A and R-449A with a GWP
of less than 300 and that walk-in dedicated condensing systems would
not suffer a performance penalty when switching from R-448A or R-449A
to R-454A.
DOE did not consider R-744 (CO2) as a potential
refrigerant for this NOPR analysis. During interviews, manufacturers
stated that while CO2 may be a viable option for larger
grocery store rack condenser installations, CO2 is unlikely
to be commonly adopted for walk-in dedicated condensing systems in
response to a low-GWP transition. Based on this feedback, DOE has
tentatively determined that analyzing CO2 dedicated
condensing systems would not be representative of the industry as a
whole and would not provide insight into the performance of walk-in
dedicated condensing systems after the low-GWP transition.
DOE also did not analyze R-290 (propane) as a potential refrigerant
in the June 2022 Preliminary Analysis because DOE lacked R-290
performance data for walk-in systems. See the June 2022 Preliminary
Analysis TSD, chapter 2, section 2.4.3.2 for details. In response to
this, AHRI stated that some companies have transitioned smaller charge
walk-in refrigeration system products to propane. (AHRI, no. 39 at p.
5) DOE is aware that there are single-packaged dedicated systems
currently on the market that use R-290 as a refrigerant for use in
walk-in systems. In this NOPR analysis, DOE collected additional
performance data for R-290 compressors and has included R-290 in its
analysis of medium- and low-temperature single-packaged dedicated
systems. The current charge limits for A3 (flammable) refrigerants are
limited to 150 grams.\29\ DOE has determined that all split system
walk-in refrigeration systems would exceed this limit, so DOE did not
analyze R-290 as a refrigerant for dedicated condensing units.
Additionally, DOE was unable to identify compressors for high-
temperature applications designed for use with R-290. As such, DOE did
not analyze high-temperature refrigeration systems using R-290.
---------------------------------------------------------------------------
\29\ EPA published a final rule pertaining to hydrocarbon
refrigerants on December 20, 2011. FR 76 78832. This rule limits the
acceptable charge of propane in a refrigeration circuit to 150 grams
for refrigeration systems with end-uses in the retail food industry.
FR 76 78832, 78836.
---------------------------------------------------------------------------
AHRI commented that when transitioning from non-flammable
refrigerants to R-290, other components must be upgraded to comply with
UL60335-2-89 \30\ requirements. (AHRI, No. 39 at p. 6) Furthermore,
AHRI stated that few state and local building codes are updated to
handle charging refrigeration equipment that use A3 refrigerants and
storing the necessary quantities of flammable refrigerants to supply
end-user needs. Id. AHRI also commented that charge sizes may need to
be increased; however, this may only be possible when doors are not
present on equipment. (AHRI, No. 39 at p. 6) In this NOPR, DOE assumed
that refrigerant system component costs would increase to comply with
safety standards when switching from non-flammable refrigerants to R-
290. These cost increases are associated with ensuring all components
are spark proof. Details of DOE's cost analysis are discussed in more
detail in chapter 5 of the accompanying TSD. Additionally, DOE limited
each refrigeration circuit using R-290 to 150 grams of charge in its
analysis to comply with current regulations. DOE is aware of commercial
refrigeration systems and walk-in
[[Page 60773]]
refrigeration systems currently on the market that use propane as a
refrigerant. As such, DOE has tentatively determined that building
codes and local regulations are in-place for refrigeration systems
charged with A3 refrigerants.
---------------------------------------------------------------------------
\30\ UL standard ``Household and Similar Electrical Appliances--
Safety--Part 2-89: Particular Requirements for Commercial
Refrigerating Appliances and Ice-Makers with an Incorporated or
Remote Refrigerant Unit or Motor-Compressor''
---------------------------------------------------------------------------
In the June 2022 Preliminary Analysis, DOE analyzed high-
temperature refrigeration systems using R-134A. In response to this
analysis, AHRI-Wine commented that wine cellar manufacturers agree with
DOE using R-134A and stated that adopting other refrigerants may not be
viable for high-temperature units. (AHRI-Wine, No. 39 at p. 5) Feedback
from manufacturer interviews indicates that manufacturers are not
currently aware of a reasonable replacement for R-134A. Based on
manufacturer feedback and manufacturer product catalogs, DOE has
tentatively determined that high-temperature refrigeration systems
currently on the market are only available with R-134A. Therefore, DOE
only evaluated R-134A for high-temperature units in this NOPR analysis.
DOE notes that if the proposals in the December 2022 AIM NOPR are
finalized, R-134A would be banned for use in walk-in coolers and a low-
GWP substitute would be required. If a low-GWP replacement becomes
available for R-134A and DOE determines that the performance of this
hypothetical refrigerant is sufficiently different than R-134A, DOE may
analyze that refrigerant for high-temperature systems as a part of this
rulemaking or a future rulemaking.
DOE requests comment on any potential low-GWP replacements for
high-temperature systems. Additionally, DOE requests high-temperature
performance data or test results for any potential low-GWP alternatives
to R-134A.
Representative Units
In the June 2022 Preliminary Analysis, DOE chose representative
units to span the range of capacities sold for each equipment class.
See section 5.3.3 of chapter 5 of the June 2022 Preliminary Analysis
TSD. Table IV.13 summarizes the representative dedicated condensing
units and single-packaged dedicated system units evaluated in the June
2022 Preliminary Analysis. DOE requested comment on these
representative units in section ES.4.5 of the June 2022 Preliminary
Analysis TSD.
Table IV.13--June 2022 Preliminary Analysis Representative Units for Dedicated Condensing Units and Single-
Packaged Dedicated Systems
----------------------------------------------------------------------------------------------------------------
Capacities
System Temperature Location Equipment class analyzed (Btu/
code h)
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing Unit........ Medium............. Outdoor............ DC.M.O............. 9,000
25,000
54,000
Indoor............. DC.M.I............. 9,000
25,000
54,000
Low................ Outdoor............ DC.L.O............. 3,000
9,000
25,000
54,000
Indoor............. DC.L.I............. 3,000
9,000
25,000
54,000
Single-Packaged Dedicated Systems High (Non-ducted).. Outdoor............ SPU.H.O............ 2,000
9,000
Indoor............. SPU.H.I............ 2,000
9,000
High (Ducted)...... Outdoor............ SPU.H.O.D.......... 9,000
Indoor............. SPU.H.I.D.......... 9,000
Medium............. Outdoor............ SPU.M.O............ 2,000
9,000
Indoor............. SPU.M.I............ 2,000
9,000
Low................ Outdoor............ SPU.L.O............ 2,000
9,000
Indoor............. SPU.L.I............ 2,000
9,000
----------------------------------------------------------------------------------------------------------------
In response, the Efficiency Advocates and HTPG commented that DOE
should consider analyzing additional representative units to provide a
broader range of capacities to help set standards as a function of
capacity. (Efficiency Advocates, No. 37 at p. 4; HTPG, No. 35 at p. 5)
Specifically, HTPG suggested analyzing the following representative
units for dedicated condensing units:
Medium-temperature, indoor, hermetic, 3,000 Btu/h,
Medium-temperature, indoor, scroll, 6,000 Btu/h,
Medium-temperature, outdoor, hermetic, 3,000 Btu/h,
Medium-temperature, outdoor, scroll, 6,000 Btu/h,
Medium-temperature, outdoor, semi-hermetic, 175,000 Btu/h,
Low-temperature, indoor, hermetic, 4,000 Btu/h,
Low-temperature, indoor, scroll, 3,000 Btu/h,
Low-temperature, outdoor, hermetic, 4,000 Btu/h,
Low-temperature, outdoor, scroll, 3,000 Btu/h, and
Low-temperature, outdoor, semi-hermetic, 120,000 Btu/h.
(HTPG, No. 35 at p. 5)
As discussed in section IV.A.1.c, lower-capacity compressors are
less
[[Page 60774]]
efficient than higher capacity compressors. While the standards for
low-temperature dedicated condensing systems take this into account,
current standards for the medium-temperature dedicated condensing
systems do not. Based on testing and its analysis of the compliance
certification database (``CCD'') and manufacturer literature, DOE has
tentatively determined that medium-temperature dedicated condensing
units below around 4,000 Btu/h would have to be equipped with all
available design options to meet the current standards. As such, DOE
did not evaluate higher efficiency levels for lower capacity medium-
temperature dedicated condensing units in this NOPR; instead, DOE is
proposing to maintain the current standard level for this equipment.
Standards proposed for these units in this NOPR were converted from the
current AWEF metric to the AWEF2 metric based on the appendix C1 test
procedure.
Lennox commented that it generally agrees with the capacities
chosen but suggested that the analysis could be improved by including
larger capacity products. (Lennox, No. 36 at p. 2) AHRI suggested that
DOE refer to its capacity suggestion in its response to the WICF TP
NOPR,\31\ which included a recommendation to analyze larger capacity
representative units such as 96,000 Btu/h. (AHRI, No. 39 at pp. 2-3)
Hussmann-Refrigeration and Lennox stated that they agree with AHRI's
recommendation that DOE evaluate a larger capacity unit of 96,000 Btu/h
as a representative unit for dedicated condensing units. (Hussmann-
Refrigeration, No. 38 at p. 3; Lennox, No. 36 at pp. 3-4) Lennox added
that the recommendation to include a high-capacity representative unit
is based on the number of basic models in the CCD. (Lennox, No. 36 at
pp. 3-4)
---------------------------------------------------------------------------
\31\ See Docket No. EERE-2017-BT-TP-0010-0022 at
www.regulations.gov.
---------------------------------------------------------------------------
Based on stakeholder feedback and the number of certified basic
models in the CCD, DOE has included additional lower and higher
capacity representative units in its NOPR analysis. Specifically, DOE
has included 75,000 Btu/h medium-temperature outdoor and indoor
dedicated condensing units, a 124,000 Btu/h medium-temperature outdoor
dedicated condensing unit, and a 75,000 Btu/h low-temperature outdoor
dedicated condensing unit. Additionally, DOE analyzed 2,000 Btu/h and
9,000 Btu/h medium-temperature, indoor and outdoor single-packaged
dedicated systems and 2,000 Btu/h and 6,000 Btu/h low-temperature,
indoor and outdoor single-packaged dedicated systems. As discussed in
section IV.A.1.c of this document, DOE did not analyze smaller medium-
temperature dedicated condensing units as it has tentatively determined
that the units on the market are already at the maximum technology
level.
AHRI-Wine recommended that DOE consider using representative units
specific to the high-temperature and wine cellar cooling industry, with
a range of capacities from 1,000 Btu/h to 18,000 Btu/h. (AHRI-Wine, No.
39 at p. 3) AHRI-Wine also recommended including indoor and outdoor
high-temperature dedicated condensing systems with capacities of 2,000
Btu/h, 9,000 Btu/h, and 25,000 Btu/h. (AHRI, No. 39 at p. 3)
Furthermore, AHRI-Wine suggested that DOE analyze 2,000 Btu/h and 9,000
Btu/h high-temperature ducted and non-ducted, indoor and outdoor
single-packaged dedicated systems. (Id.)
DOE interprets AHRI-Wine's recommendation to evaluate additional
dedicated condensing system representative units to refer to dedicated
condensing units and matched refrigeration systems. As discussed in
section IV.A.1.c of this document, DOE only analyzed high-temperature
single-packaged dedicated systems in this NOPR analysis and is
proposing a single high-temperature equipment class for matched
refrigeration systems and single-packaged dedicated systems. Based on
manufacturer feedback and a review of high-temperature product
literature, DOE analyzed 2,000 Btu/h and 7,000 Btu/h, indoor and
outdoor, ducted and non-ducted high-temperature single-packaged
dedicated systems for this NOPR analysis. DOE did not encounter single-
packaged high-temperature units with a capacity of over 7,000 Btu/h. As
discussed in section IV.A.1.c of this document, DOE did not analyze
high-temperature matched refrigeration systems separately from single-
packaged dedicated systems since DOE has tentatively concluded that
single-packaged dedicated systems are representative of the majority of
the high-temperature market. Therefore, DOE did not analyze any
representative units for high-temperature single-packaged dedicated
systems larger than 7,000 Btu/h for this NOPR analysis.
AHRI-Wine requested that DOE clarify how capacity factors into
DOE's high-temperature analysis and observed that if the lowest
capacity for high-temperature systems is 9,000 Btu/h with a rotary
compressor, then any unit with a capacity below 9,000 Btu/h with a
hermetic compressor may be at a disadvantage. Id.
In this NOPR analysis, the capacity of a representative unit
determines its characteristics, components, and design. For example,
DOE analyzed 7,000 Btu/h high-temperature representative units with a
rotary compressor and analyzed 2,000 Btu/h high-temperature
representative units with a hermetic compressor based on DOE's review
of the market. DOE is proposing standards for high-temperature
refrigeration systems in this rulemaking that vary with capacity.
Table IV.14 lists the representative capacities evaluated in this
NOPR for walk-in dedicated condensing units and single-packaged
dedicated systems. More details on the representative units DOE
selected for dedicated condensing units and single-packaged dedicated
systems are in chapter 5 of the accompanying TSD.
Table IV.14--Representative Units Analyzed for Dedicated Condensing Units and Single-Packaged Dedicated Systems
----------------------------------------------------------------------------------------------------------------
Capacity (Btu/
System Temperature Location Class code h)
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing Units....... Medium............. Outdoor............ DC.M.O............. 9,000
25,000
54,000
75,000
124,000
[[Page 60775]]
Indoor............. DC.M.I............. 9,000
25,000
54,000
75,000
Low................ Outdoor............ DC.L.O............. 3,000
9,000
25,000
54,000
75,000
Indoor............. DC.L.I............. 9,000
25,000
54,000
Single-Packaged Dedicated Systems High (Non-ducted).. Outdoor............ SPU.H.O............ 2,000
7,000
Indoor............. SPU.H.I............ 2,000
7,000
High (Ducted)...... Outdoor............ SPU.H.O.D.......... 2,000
7,000
Indoor............. SPU.H.I.D.......... 2,000
7,000
Medium............. Outdoor............ SPU.M.O............ 2,000
9,000
Indoor............. SPU.M.I............ 2,000
9,000
Low................ Outdoor............ SPU.L.O............ 2,000
6,000
Indoor............. SPU.L.I............ 2,000
6,000
----------------------------------------------------------------------------------------------------------------
Design Options
In the June 2022 Preliminary Analysis, DOE used a design option
approach to evaluate potential efficiency improvements for walk-in
dedicated condensing units and single-packaged dedicated systems. DOE
considered the technologies listed in Table IV.15 as design options for
dedicated condensing units and single-packaged dedicated systems.
Table IV.15--June 2022 Preliminary Analysis Refrigeration System Design
Options
------------------------------------------------------------------------
Dedicated condensing Single-packaged
units dedicated systems
------------------------------------------------------------------------
All Units................... Improved Improved
condenser coil. condenser coil.
Higher Higher
efficiency efficiency
condenser fan condenser fan
motors. motors.
Improved Off-cycle
fan blades. evaporator fan
control.
Improved
thermal insulation.
Improved
fan blades.
Outdoor Only................ Crankcase Crankcase
heater controls. heater controls.
Variable- Variable-
speed condenser fan speed condenser fan
control. control.
Ambient sub- Ambient sub-
cooling. cooling.
Head Head
pressure control. pressure control.
High-temperature............ .................... Higher
efficiency
compressors.
------------------------------------------------------------------------
Some design options passed the screening analysis but were not
evaluated in the June 2022 Preliminary Analysis. DOE did not analyze
higher efficiency evaporator fan motors in the June 2022 Preliminary
Analysis since EPCA prescribes use of either electronically commutated
motors (``ECMs'') or 3-phase motors (42 U.S.C. 6213(f)(1)(E)). DOE did
not have sufficient data for the June 2022 Preliminary Analysis to
evaluate variable-capacity compressors, hydrocarbon refrigerants,
improved evaporator coils, and liquid suction heat exchangers. Finally,
DOE did not analyze on-cycle evaporator fan control since variable-
capacity compressors are a prerequisite for this design option to be
effective.
As discussed in the Refrigerants Analyzed subsection of section
IV.C.1.d of this document, DOE included hydrocarbon refrigerants in
this NOPR analysis. Stakeholder comments pertaining to hydrocarbon
refrigerants are addressed in the Refrigerants Analyzed subsection.
In section ES.4.6 of the June 2022 Preliminary Analysis TSD, DOE
specifically requested data and feedback on improved evaporator coils
for single-packaged dedicated systems and liquid suction heat
exchangers for refrigeration systems.
DOE received no comments regarding improved evaporator coils as a
design option; however, during interviews, manufacturers indicated that
larger evaporator coils were an effective design option to increase the
efficiency of single-packaged dedicated systems. DOE gathered
additional data on evaporator performance from the CCD and modeled
improved evaporator coils as a design
[[Page 60776]]
option for single-packaged dedicated systems. Details of DOE's analysis
for this design option are discussed in chapter 5 of the accompanying
TSD.
DOE also received no comments regarding improved evaporator motors.
As stated previously, DOE's interpretation of the language in EPCA is
that it prescribes the use of either ECMs or 3-phase motors (42 U.S.C.
6213(f)(1)(E)). As such, DOE did not evaluate improved evaporator
motors in this NOPR analysis.
In response to the request for comment about liquid suction heat
exchangers, AHRI, HTPG, Hussmann-Refrigeration, and Lennox suggested
that DOE exclude liquid suction heat exchangers as a design option,
since this technology does not always improve efficiency. (AHRI, No. 39
at p. 3; HTPG, No. 35 at p. 6; Hussmann-Refrigeration, No. 38 at p. 3;
Lennox, No. 36 at p. 4) AHRI also commented that liquid suction heat
exchangers are difficult to implement on units with higher AWEF. (AHRI,
No. 39 at p. 3). AHRI-Wine recommended that heat exchangers should only
be used for split systems when there may be liquid subcooling losses
and low return gas temperatures. (AHRI-Wine, No. 39 at p. 4) DOE
understands AHRI-Wine's comment to be in reference to liquid suction
heat exchangers. As stated in the June 2022 Preliminary Analysis TSD,
DOE does not have sufficient data on how liquid suction heat exchangers
may impact performance or component lifetimes of walk-in refrigeration
systems. See section 5.7.2.9 of chapter 5 of the June 2022 Preliminary
Analysis TSD. Since DOE did not receive additional data from
stakeholders in response to the June 2022 Preliminary Analysis, DOE did
not analyze liquid suction heat exchangers as a design option in this
NOPR analysis.
The Efficiency Advocates encouraged DOE to evaluate multiple-
capacity and/or variable-speed compressors as design options.\32\
(Energy Advocates, No. 37 at p. 2) However, KeepRite stated that using
variable-capacity compressors does not automatically increase the
efficiency and that the system must be designed to exploit the
advantages provided by the variable-speed components. (KeepRite, No. 41
at p. 1) Additionally, KeepRite commented that compressor efficiency
should be regulated at the compressor manufacturer level. (KeepRite,
No. 41 at p. 2) In this NOPR analysis, DOE analyzed variable-capacity
compressors for low- and medium-temperature refrigeration systems and
assumed that the system was redesigned to take advantage of the
variable-speed compressor. Specifically, DOE assumed that unit coolers
paired with dedicated condensing units under analysis, and unit coolers
contained within single-packaged dedicated systems under analysis, had
on-cycle two-speed capabilities. However, DOE did not analyze on-cycle
variable-speed evaporator fan controls as an independent design option
because not all unit coolers would be paired with condensing systems
that could vary the cooling load to take advantage of on-cycle
variable-speed evaporator fans. Details of the variable-capacity
compressor design option implementation in this NOPR analysis can be
found in chapter 5 of the accompanying TSD.
---------------------------------------------------------------------------
\32\ Multiple-capacity compressors have three or more distinct
capacities at which they can operate. Variable-capacity or variable-
speed compressors have a range of capacities in which they can
operate at any given speed.
---------------------------------------------------------------------------
HTPG commented that it disagrees with DOE's statement that the air-
side heat transfer characteristics of coils could be improved by
decreasing the spacing between the fins because there could be
potential negative impacts, such as increased fouling, clogging of the
coil on condensers, frost accumulation, and blockage on evaporator
coils. (HTPG, No. 35 at p. 2) DOE acknowledges that decreased fin
spacing can increase coil fouling or result in frost accumulation on
low-temperature evaporator units that would negatively affect unit
operation. As such, when DOE evaluated improved condenser and
evaporator coils in this NOPR, it maintained a constant fins per inch
between baseline and improved coils.
KeepRite commented that efficiency gains from higher efficiency
condenser fan motors are limited because motors are already regulated
for efficiency. (KeepRite, No. 41 at p. 2) Through market research and
manufacturer feedback, DOE has tentatively determined that most
baseline condenser fan motors are permanent split capacity-type motors;
however, DOE has found some dedicated condensing unit fans models that
utilize more efficient ECMs. Therefore, DOE has tentatively determined
that higher efficiency condenser fan motors are a feasible design
option.
AHRI requested clarification on whether two-speed fans are
considered in DOE's analysis and whether they fall under the same
requirements as variable-speed fans. (AHRI, No. 39 at p. 2) Hussmann-
Refrigeration reiterated AHRI's comment seeking clarification on
variable- and multiple-speed fans. (Hussmann-Refrigeration, No. 38 at
p. 2) Lennox commented that it considers the scope of technologies DOE
has evaluated to be appropriate; however, it suggested that DOE
consider variable-speed condenser fan control. (Lennox, No. 36 at p. 2)
Furthermore, Lennox stated that two- or multiple-speed condenser fans
could be considered as a potential subset of full variable-speed
condenser fans. Id. DOE is interpreting AHRI and Hussmann-
Refrigeration's comments to be asking for clarification about the
variable-speed condenser fan design option. In the June 2022
Preliminary Analysis, DOE considered only fully variable-speed, not
two-speed, condenser fan motors as a design option. Through
manufacturer interviews and its own analysis, DOE has tentatively
determined that fully variable-speed fans are more effective at
increasing a unit's efficiency than two-speed fans. Furthermore, based
on an analysis of ECM prices, DOE has tentatively determined that the
cost for variable- and two-speed ECMs are similar. Therefore, DOE did
not include two-speed condenser fans as an intermediate design option
in its NOPR analysis. DOE notes that it has chosen what it considers to
be the most realistic design path in its NOPR analysis, however, the
design options evaluated by DOE should not be interpreted as
prescriptive requirements but rather possible steps along a potential
efficiency improvement path.
KeepRite stated that efficiency gains from implementing a variable-
speed condenser fan are limited by the lowered head pressure setting
that many units already implement to reach baseline and that many units
already use this type of fan. (KeepRite, No. 41 at p. 2) DOE notes that
it received multiple comments suggesting that dedicated condensing
units already use the lowest reliable head pressure setting to meet
baseline efficiency levels. These comments are addressed in the
baseline efficiency subsection of section IV.C.1.d. DOE acknowledges
that there is limited potential for variable-speed condenser fans to
save energy when a unit's head pressure has already been lowered and
DOE considers the relationship between variable-speed condenser fans
and a unit's head pressure setting in its analysis. Based on
manufacturer interview feedback, DOE has tentatively determined that
very few or no baseline walk-in refrigeration systems use variable-
speed condenser fans. Rather, variable-speed condenser fans are an
optional extra for additional control or efficiency that consumers can
specify at an additional cost.
KeepRite also commented that no real energy savings would occur
from
[[Page 60777]]
ambient subcooling because it is already realized in the liquid line of
a typical installation, and because ambient subcooling decreases the
overall condensing area of the unit resulting in an increase in energy
consumption. (KeepRite, No. 41 at p. 2) In this NOPR analysis, DOE
implemented the ambient subcooling design option by assuming that
condenser face area is added to a coil to make an ambient subcooling
circuit, rather than re-circuiting a portion of the existing heat
exchanger condensing area to ambient subcooling. Based on its analysis,
DOE has tentatively determined that increased liquid line subcooling
does increase system efficiency. As such DOE, is analyzing ambient
subcooling as a design option for walk-in refrigeration systems.
AHRI-Wine stated that smaller-sized high-temperature units can
maximize liquid subcooling entering the expansion valve without having
a dedicated liquid subcooling section in the condenser coil. (AHRI-
Wine, No. 39 at p. 6) Additionally, AHRI-Wine commented that it seeks
clarification on if the ambient subcooling design option is defined by
a specific subcooling target. Id. DOE understands that smaller-sized
high-temperature units can maximize subcooling without having a
dedicated liquid subcooling section, however, based on its analyses,
DOE has found that an additional subcooling circuit does result in
efficiency increases for all walk-in refrigeration systems. DOE is
therefore maintaining ambient subcooling as a design option for all
outdoor dedicated condensing units and outdoor single-packaged
dedicated systems. Furthermore, DOE clarifies that in this NOPR
analysis, the subcooling achieved through the addition of an ambient
subcooling circuit is based on a specified subcooling target determined
consistent with manufacturer interview feedback. The details of the
ambient subcooling design option are further discussed in chapter 5 of
the accompanying TSD.
AHRI-Wine commented that wine cellar manufacturers seek further
clarification on the head pressure design options: (1) If fixed head
pressure is regulated by adding a head pressure control valve to the
system for hot gas bypass; (2) if floating head pressure means a
condenser that drops head pressure as a function of the ambient
[temperature] with no external controls; and (3) if fan speed
regulation is categorized as fan speed reduction or fan cycling based
on head pressure. (AHRI-Wine, No. 39 at p. 6) DOE assumes that in a
system without floating head pressure controls (``fixed head
pressure''), there would be no head pressure controls. This includes
passive or active controls that would allow head pressure reductions at
lower ambient temperatures. For systems with floating head pressure,
DOE assumes the system would be equipped with a valve or a set of
valves that would enable refrigerant gas to bypass the condenser coil
and allow the system head pressure to float down at lower ambient
temperatures. In this NOPR, DOE implemented two condenser fan control
options: cycling fans and variable-speed fans. DOE assumed cycling
condenser fans would cycle on and off at low ambient temperature to
reduce fan power. DOE assumed that variable-speed fan controls were
combined with appropriate motors and would reduce the fan's speed at
lower ambient temperature to reduce fan power. The details of DOE's
implementation of floating head pressure controls and condenser fan
controls can be found in chapter 5 of the accompanying TSD.
KeepRite commented that crankcase heaters use a small fraction of
the energy used for compressors and fans and stated that controlling
the crankcase heaters would only save a portion of that small fraction
of energy. (KeepRite, No. 41 at p. 2) KeepRite added that some
crankcase heater controls can reduce efficiency due to the current test
procedure calculations. Id. DOE has tentatively determined that
although crankcase heaters use less energy than other system
components, crankcase heater controls can still reduce energy use of
walk-in refrigeration units when tested according to the current test
procedure in accordance with appendix C1.
AHRI-Wine recommended that DOE consider 0.5-inch, R-2 insulation or
equivalent for baseline thermal insulation and 1.5-inch, R-6
insulation, or equivalent, for the increased thermal insulation design
options. (AHRI-Wine, No. 39 at p. 6) DOE considered this recommendation
and data collected through high-temperature unit teardowns and has
reduced the thermal insulation thickness for high-temperature units to
be consistent with AHRI-Wine's recommendation. This is consistent with
DOE's acknowledgment of the size-sensitive nature of the high-
temperature walk-in market, as thermal insulation thicker than 1.5
inches would not be practical in many high-temperature applications.
During manufacturer interviews conducted prior to this NOPR
analysis, some manufacturers indicated that improvements to condenser
fan blades did not effectively increase walk-in refrigeration system
efficiency. DOE analyzed evaporator fan data as a proxy for condenser
fan data and found no correlation between evaporator fan designs and
evaporator efficiency. Based on the manufacturer interview feedback and
the fan data analysis, DOE has tentatively determined that improving
fan blade designs has no measurable effect on AWEF2 values. As such,
DOE is not including improved condenser fan blades as a design option
in this NOPR analysis.
In summary, the dedicated condensing unit and single-packaged
dedicated systems design options analyzed in this NOPR, and the
equipment classes that they apply to, are listed in Table IV.16.
Table IV.16--NOPR Analysis Refrigeration System Design Options
------------------------------------------------------------------------
Dedicated Single-packaged
condensing units dedicated systems
------------------------------------------------------------------------
All Units....................... Higher Higher
efficiency efficiency
compressors. compressors.
Improved Higher
condenser coil. efficiency
Higher condenser fan
efficiency motors.
condenser fan Off-cycle
motors. evaporator fan
control.
improved
thermal
insulation.
Outdoor Units Only.............. Crankcase Crankcase
heater controls. heater controls.
Variable- Variable-
speed condenser speed condenser
fan control. fan control.
Ambient Ambient
subcooling. sub-cooling.
Head Head
pressure controls. pressure
controls.
Medium- and Low-Temperature .................. Improved
Units Only. evaporator and
condenser coil.
Hydrocarbon
refrigerants.
------------------------------------------------------------------------
[[Page 60778]]
Baseline Efficiency
For each equipment class, DOE generally selects a baseline model as
a reference point for each class, and measures changes resulting from
potential energy conservation standards against the baseline. The
baseline model in each equipment class represents the characteristics
of an equipment typical of that class (e.g., capacity, physical size).
Generally, a baseline model is one that just meets current energy
conservation standards, or, if no standards are in place, the baseline
is typically the most common or least efficient unit on the market.
In the June 2022 Preliminary Analysis, DOE set baseline efficiency
levels for currently covered dedicated condensing units using the
applicable minimum energy conservation standard. See 10 CFR 431.306.
For equipment classes that were not analyzed in previous walk-in
rulemakings (e.g., single-packaged dedicated systems, high-temperature
single-packaged dedicated systems), DOE used product catalogs, feedback
from manufacturer interviews, and testing to set the baseline at the
lowest efficiency level commonly seen on the market today.
The Efficiency Advocates requested clarification on the discrepancy
between the baseline AWEF ratings in the engineering analysis and the
current standards, stating that some dedicated condensing units in the
June 2022 Preliminary Analysis have baseline efficiency levels both
below and above the current standard levels. (Efficiency Advocates, No.
37 at pp. 4-5) HTPG commented that no representative unit of single-
packaged dedicated systems meets the minimum AWEF of 7.6 for dedicated
condensing systems after all design options are applied. (HTPG, No. 35
at p. 3)
In the June 2022 Preliminary Analysis, DOE set baseline efficiency
levels for dedicated condensing units with energy conservation
standards at the current minimum standard level using the appendix C
test procedure (see appendix C to Subpart R to 10 CFR 431). For
example, for a medium-temperature, outdoor dedicated condensing unit,
DOE determined which technology options would just meet the current
AWEF standard of 7.6 Btu/W-h using the appendix C test procedure. Once
units had their baseline design options set, DOE conducted the rest of
the efficiency analysis using the appendix C1 test procedure to
determine AWEF2 values for each efficiency level, including baseline.
DOE notes that in the June 2022 Preliminary Analysis, efficiency value
was labeled as ``AWEF,'' however, all efficiency values calculated in
accordance with the appendix C1 test procedure were AWEF2 values, as
defined in the appendix C1.
Among other updates, appendix C1 includes additional off-cycle
power measurements and accounts for single-packaged dedicated system
thermal losses that are not included in appendix C. Therefore, the
AWEF2 of a given representative unit tends to be lower than the AWEF
for the same unit, which explains why AWEF2 for some baseline units was
below current AWEF standards in the June 2022 Preliminary Analysis.
Single-packaged dedicated system AWEF2 values are generally more
affected by the test procedure changes since appendix C1 accounts for
thermal loss. As observed by HTPG, this could mean that even with all
design options added, many single-packaged dedicated unit AWEF2 values
do not meet current AWEF standards. DOE notes that the tested AWEF
values for these units would meet the current AWEF standards. In
contrast, some baseline dedicated condensing units did not require any
additional design options to meet the current standard level. Using the
appendix C1 test procedure, these baseline dedicated condensing units
exceed the current standards.
In this NOPR analysis, DOE maintained the June 2022 Preliminary
Analysis baseline approach and set baseline efficiency levels for
dedicated condensing systems analyzed in previous rulemakings by
determining the combination of design options using the appendix C test
procedure necessary to meet the current applicable minimum energy
conservation standards for AWEF.
AHRI-Wine suggested that DOE consider hermetic compressors for all
wine cellar units with a capacity less than 9,000 Btu/h. (AHRI-Wine,
No. 39 at p. 5) Based on feedback from high-temperature refrigeration
manufacturers and a review of compressor catalogs, DOE has tentatively
determined that high-temperature rotary compressors are readily
available and are commonly used in high-temperature refrigeration
systems above 5,000 Btu/h. DOE therefore assumed that the 7,000 Btu/h
representative units would use a rotary compressor at baseline for this
NOPR analysis. Consistent with AHRI-Wine's recommendation and DOE's
review of product catalogs, DOE assumed hermetic compressors are used
in 2,000 Btu/h high-temperature single-packaged dedicated systems at
baseline.
In response to the June 2022 Preliminary Analysis baseline
discussion, HTPG commented that baseline for dedicated condensing units
should include floating head pressure since many condensing units on
the market utilize this design option to meet the current minimum AWEF.
(HTPG, No. 35 at p. 5) AHRI commented that in the June 2022 Preliminary
Analysis, DOE assumed a higher head pressure than what is typically
seen on the market. (AHRI, No. 39 at p. 2). KeepRite stated that most
units include a lower head pressure setting and any further reduction
could have adverse effects and reduce operating efficiency. (KeepRite,
No. 41 at pp. 1-2) Furthermore, KeepRite commented that flashing would
occur from routing a liquid line through a warm area of a building
unless the line is well insulated. Id. DOE found that manufacturers
generally agreed with these statements during manufacturer interviews.
Based on stakeholder feedback, DOE has adjusted the baseline head
pressure control design option to allow head pressure to float down to
150 pounds per square inch. Additionally, DOE assumed that liquid lines
would be well insulated if routed through warm areas of a building.
Details of DOE's procedure for determining baseline for each
representative unit and modeling of head pressure controls are
discussed in chapter 5 of the accompanying TSD.
Higher Efficiency Levels
Consistent with the analysis for previous walk-in refrigeration
system rulemakings (i.e., The June 2014 Final Rule and the July 2017
Final Rule), in the June 2022 Preliminary Analysis, DOE added the
remaining applicable design options to each representative unit to
determine efficiency levels above baseline. As discussed in the design
option section, the increase in AWEF2 from each design option for each
representative unit is calculated using appendix C1 and is calibrated
using test data, stakeholder comments, and manufacturer interview
feedback.
In section ES.4.4 of the June 2022 Preliminary Analysis TSD, DOE
requested comment on the efficiency levels that it evaluated.
Hussmann-Refrigeration commented that efficiency levels beyond the
baseline may not be attainable because many of the technology options
that DOE considered in the June 2022 Preliminary Analysis are already
being implemented to achieve the current minimum AWEF. (Hussmann-
Refrigeration, No. 38 at p. 2) Based on its analysis, DOE notes that
while most or all available design options are necessary to meet the
baseline efficiency
[[Page 60779]]
level for some representative units, other representative units can
achieve efficiencies higher than baseline with the application of the
evaluated design options. DOE has validated its results through its own
walk-in refrigeration system testing. Additionally, DOE's performance
modeling of each design option in this analysis was developed with
manufacturer feedback through manufacturer interviews. DOE has
tentatively determined that the results of this analysis are
representative of the units and technology currently available on the
market and has therefore adopted the June 2022 Preliminary Analysis
efficiency level approach in this NOPR.
The Efficiency Advocates questioned why no meaningful energy
savings occur for efficiency levels (corresponding to the variable-
speed condensing fan, ambient subcooling, and self-regulated crankcase
heater control design options) above the baseline for the smallest
representative unit for medium-temperature, outdoor, dedicated
condensing units. (Efficiency Advocates, No. 37 at p. 2) The June 2022
Preliminary Analysis showed that the variable-speed condensing fan and
ambient subcooling design options were less effective at improving the
energy efficiency of smaller capacity units. Additionally, the self-
regulated crankcase heater control design option reduced energy
consumption and improved efficiency by only a small amount for all
equipment classes. As such, these design options did not meaningfully
improve the AWEF2 or reduce the energy consumption of the 9,000 Btu/h
medium-temperature outdoor dedicated condensing representative unit. In
this NOPR analysis DOE has revised its assumptions for these three
design options based on manufacturer feedback received during
interviews. With these modifications, these design options become more
effective than what DOE presented in the June 2022 Preliminary
Analysis. Details of DOE's revised assumptions for these design options
are discussed in chapter 5 of the accompanying TSD.
AHRI-Wine commented that wine cellar manufacturers already optimize
their units for efficiency, including heat exchanger coils with high
density corrugated fins, rifled tubing, and circuiting optimized for
specific operating points for wine cellar applications. (AHRI-Wine, No.
39 at p. 4) AHRI-Wine also stated that it may be difficult for wine
cellar manufacturers to reach higher efficiency levels because fewer
technology options are available for smaller capacity units. (AHRI-
Wine, No. 39 at p. 3) Based on its analysis for this NOPR, DOE has
tentatively concluded that there are design options that can be applied
to baseline high-temperature units to improve their efficiency, such as
electronically commutated condenser fan motors and crankcase heater
controls. DOE also notes that several design options considered for
medium- and low-temperature dedicated condensing units and single-
packaged dedicated systems are not being considered for high-
temperature systems in this analysis, such as improved condenser and
evaporator coils. Table IV.16 in the Design Options subsection of
section IV.C.1.d shows the design options that apply to all units,
including high-temperature units, and to medium- and low-temperature
units only.
For the June 2022 Preliminary Analysis, DOE developed correlations
between fan power and the nominal capacity for units with different
temperature and ducting configurations. See section 5.5.5.4 of chapter
5 of the June 2022 preliminary TSD. In response to this analysis, AHRI
requested clarification on DOE's approach for using fan watts as a
function of nominal capacity and external static pressure. (AHRI, No.
39 at p. 2) In this NOPR analysis, DOE built fan power models similar
to those presented in the June 2022 Preliminary Analysis. These models
are based on either unit capacity (from product catalogs and testing)
or the ratio of condenser load to condenser temperature difference
(from testing) and external static pressure for ducted units (from
manufacturer's requests for waivers submitted to DOE).\33\ These models
and the data they are based on are discussed in more detail in chapter
5 of the accompanying TSD.
---------------------------------------------------------------------------
\33\ CellarPro Decision and Order, 86 FR 23702 (May 4, 2021);
Air Innovations Decision and Order, 86 FR 26504 (May 14, 2021);
Vinotemp Decision and Order, 86 FR 36732 (July 13, 2021); LRC Coil
Interim Waiver 86 FR 47631 (Aug. 26, 2021).
---------------------------------------------------------------------------
AHRI commented that reliability issues with maximum technology
options could prove the maximum technology options to be unfeasible.
(AHRI, No. 39 at p. 2) As previously discussed, the purpose of DOE's
screening analysis is to remove technology options that may have a
negative impact on equipment utility; therefore, DOE has tentatively
determined that application of any design option, including all maximum
technology design options, would not have a negative impact on
equipment utility. The Efficiency Advocates commented that DOE should
ensure that the maximum technology efficiency levels are at least
equivalent to the most efficient products on the market and pointed to
certified models with AWEFs that exceed the maximum technology level in
the June 2022 preliminary TSD for multiple walk-in refrigeration
equipment classes. (Efficiency Advocates, No. 37 at p. 5) DOE notes
that the engineering analysis is based on design options that DOE has
identified as available on the market and has shown, through analysis
and/or testing, to increase dedicated condensing unit and/or single-
packaged dedicated system efficiency. DOE has tentatively concluded
that some of the higher AWEF values reported in CCD are either not
feasible or are not representative of the maximum technology options
attainable for the entire market. This means that maximum technology
AWEF2 values in this analysis may not reach the maximum AWEF levels in
the CCD for some refrigeration equipment classes. The CCD efficiency
distribution is discussed in detail in chapter 3 of the accompanying
TSD.
The specifics of modeling each design option are discussed in
chapter 5 of the accompanying TSD.
e. Unit Coolers
Refrigerants Analyzed
In the June 2022 Preliminary Analysis, DOE assumed R-404A in its
analysis of medium- and low-temperature unit coolers and assumed R-134A
in its analysis of high-temperature unit coolers. See section 2.4.3.2
of chapter 2 of the June 2022 Preliminary Analysis TSD. DOE requested
comment on whether the refrigerants it used in its analysis are
representative of the current and future walk-in market in section
ES.4.8 of the preliminary analysis TSD.
In response, HTPG commented that it agrees with DOE using R-404A in
its analysis of medium- and low-temperature unit coolers. (HTPG, No. 35
at p. 6) AHRI-Wine commented that wine cellar manufacturers agree with
DOE using R-134A for high-temperature unit coolers in the June 2022
Preliminary Analysis. (AHRI-Wine, No. 39 at p. 5)
As discussed in section IV.C.1.d, there is an upcoming December
2022 AIM NOPR that, if adopted as proposed, would require the use of
lower GWP refrigerants for walk-in coolers and freezers. DOE notes that
the primary concern about the transition to lower GWP refrigerants
relative to the performance of refrigeration systems is the potential
for higher refrigerant glide. As discussed in section IV.C.1.d of this
document, glide has a differential impact for walk-in refrigeration
systems since dedicated condensing units and
[[Page 60780]]
unit coolers are tested and rated separately. Increased refrigerant
glide can decrease condensing unit performance, however, increased
refrigerant glide does not decrease unit cooler performance. As such,
there is limited concern that unit coolers would not be able to meet a
proposed standard should the proposals in the December 2022 AIM NOPR be
finalized. DOE is therefore basing its unit cooler NOPR analysis on the
same refrigerants that it analyzed in the June 2022 Preliminary
Analysis--R-404A for medium- and low-temperature unit coolers and R-
134A for high-temperature unit coolers.
Representative Units
As discussed in section 5.3.3 of the June 2022 Preliminary Analysis
TSD, DOE analyzed the representative units listed in Table IV.17.
Table IV.17--Representative Units Analyzed for Unit Coolers in the June
2022 Preliminary Analysis
------------------------------------------------------------------------
Temperature Class code Capacity
------------------------------------------------------------------------
High................................. UC.H.................. 9,000
25,000
Medium............................... UC.M.................. 9,000
25,000
Low.................................. UC.L.................. 9,000
25,000
------------------------------------------------------------------------
DOE requested comment on the representative units analyzed in
section ES.4.5 of the June 2022 Preliminary Analysis TSD. HTPG
commented that DOE should consider analyzing additional representative
units to provide a broader range of capacities to help set standards as
a function of capacity. (HTPG, No. 35 at p. 5) Specifically, HTPG
recommended analyzing medium- and low-temperature unit coolers at
75,000 and 175,000 Btu/h. (Id.) AHRI also requested that DOE consider
larger capacity representative units (also recommended in their comment
to the WICF TP NOPR \34\), such as 72,000 Btu/h for unit coolers.
(AHRI, No. 39 at pp. 2-3) Hussmann-Refrigeration and Lennox stated that
they agree with AHRI's request for a larger capacity representative
unit at 72,000 Btu/h for unit coolers. (Hussmann-Refrigeration, No. 38
at p. 3; Lennox, No. 36 at pp. 3-4) AHRI also recommended that DOE
analyze ducted and non-ducted high-temperature unit coolers with
capacities of 2,000 Btu/h, 9,000 Btu/h, and 25,000 Btu/h. (AHRI, No. 39
at p. 2)
---------------------------------------------------------------------------
\34\ See Docket No. EERE-2017-BT-TP-0010-0022.
---------------------------------------------------------------------------
For this NOPR analysis, DOE identified additional representative
units for the medium- and low-temperature equipment classes based on
stakeholder comments combined with the common units certified in the
CCD. Specifically, DOE has added 3,000 Btu/h, 54,000 Btu/h, and 75,000
Btu/h representative capacities for medium- and low-temperature unit
coolers. DOE has tentatively concluded that for walk-in applications
(total chilled storage area of less than 3,000 square feet), unit
cooler capacities would not exceed 75,000 Btu/h and therefore did not
include a representative unit above 75,000 Btu/h. Similarly, DOE
identified representative units for the high-temperature equipment
classes based on stakeholder comments and a review of manufacturer
literature. Ultimately, DOE has included ducted high-temperature unit
coolers at 9,000 Btu/h and 25,000 Btu/h in this NOPR analysis.
The unit cooler representative units analyzed in this NOPR analysis
are listed in Table IV.18.
Table IV.18--Representative Units Analyzed for Unit Coolers
------------------------------------------------------------------------
Capacity
Temperature Class code (Btu/h)
------------------------------------------------------------------------
High (Non-Ducted).................... UC.H.................. 9,000
25,000
High (Ducted)........................ UC.H.D................ 9,000
25,000
Medium............................... UC.M.................. 3,000
9,000
25,000
54,000
75,000
Low.................................. UC.L.................. 3,000
9,000
25,000
54,000
75,000
------------------------------------------------------------------------
Efficiency Levels
In the June 2022 Preliminary Analysis, DOE defined efficiency
levels using the design option approach. See section 5.2 of chapter 5
of the June 2022 Preliminary Analysis TSD.
In response to DOE's design options analysis, Lennox commented that
it believes the potential for efficiency increases based on design
options for evaporator coils and heat exchangers are relatively small
and that improvements in evaporator coils should be cost-justified
because they are capital intensive. (Lennox, No. 36 at p. 4) DOE notes
that in the engineering analysis, it considers both the efficiency and
cost increases for each design option. These costs and efficiency gains
are further analyzed in the downstream analyses where manufacturer
capital expenditure is evaluated relative to potential standard levels.
For more details on this analysis, see section IV.J of this document.
Additionally, DOE received comments from stakeholders pertaining to
the improved evaporator fan blade design option considered in section
5.7.2.4 of chapter 5 of the June 2022 Preliminary Analysis. Lennox
commented that, based on its own experience, changing the evaporator
fan blade does not increase a unit's efficiency. (Lennox, No. 36 at p.
3) AHRI commented that it believes changing fan blades would result in
only minimal energy gains. (AHRI, No. 39 at p. 2) In the manufacturer
interviews that DOE conducted, most manufacturers agreed that improving
evaporator fan blades has no measurable effect on unit cooler
efficiency. Based on this feedback, DOE assumed that fans with improved
blades were not an effective design option for improving the efficiency
of walk-in refrigeration systems in this NOPR analysis.
KeepRite commented that applying variable-speed evaporator fans can
save energy during low load operation; however, since the system will
run at a lower efficiency, the system must be designed to modulate the
cooling capacity. (KeepRite, No. 41 at p.1) DOE notes that in the June
2022 Preliminary Analysis, variable-speed evaporator fans were only
analyzed as a design option for reducing off-cycle unit cooler fan
power. DOE did not consider variable-speed fan controls that adjust the
evaporator fan speed during the compressor on-cycle since on-cycle
variable-speed evaporator fan control requires pairing to a condensing
system that can modulate the cooling load sent to the evaporator to
effectively save energy, and there is no guarantee that unit coolers
will be paired with such condensing systems in the field. See section
5.7.2.7 of chapter 5 of the June 2022 Preliminary Analysis TSD. In this
NOPR analysis, DOE is not considering variable-speed evaporator fans as
a design option to improve efficiency.
The Efficiency Advocates requested clarification on why no
meaningful energy savings occur when implementing a variable-speed
evaporator fan and improved fan blades for low-temperature unit
coolers. (Efficiency Advocates, No. 37 at p. 2) DOE notes that both the
calculated AWEF and estimated energy consumption of low-temperature
unit coolers include evaporator fan power, defrost power, estimated
system power, and any ancillary power. Evaporator fan power makes up a
limited proportion of the total energy a unit cooler consumes.
[[Page 60781]]
As such, design options that provide relatively small energy
improvements relative to the overall energy use of a unit cooler (like
improved evaporator fan blades and variable-speed evaporator fan
controls) will have minimal impact on overall energy savings and
reduction in AWEF.
HTPG stated that it disagrees with DOE's design option analysis
approach, since DOE did not recognize that most baseline units already
include improved evaporator fan blades and variable-speed evaporator
fans. (HTPG, No. 35 at pp. 2-5) Furthermore, HTPG commented that it
does not believe unit cooler efficiency levels should be increased
because the remaining technology options, excluding improved fan blades
and variable-speed fans, would result in no efficiency increases. (Id.)
DOE notes that in the June 2022 Preliminary Analysis, there were
some unit cooler representative units that just met baseline with all
design options, including improved fan blades and variable-speed fans,
applied; however, DOE found that some units in the CCD at each
representative capacity for medium- and low-temperature unit coolers
are rated at a higher efficiency than baseline. Therefore, DOE has
tentatively determined that the efficiency level of unit coolers could
be increased beyond the current energy conservation standards.
Based on additional market research and stakeholder comments, DOE
switched to an efficiency level approach for medium- and low-
temperature unit coolers in this NOPR analysis. DOE has tentatively
determined that this approach results in more accurate cost-efficiency
curves, which are directly informed by the unit cooler market. To
conduct this analysis, DOE constructed a database of medium- and low-
temperature unit coolers by combining CCD data and manufacturer product
literature. Throughout this notice, this database is referenced as
``the unit cooler performance database.'' The efficiency levels
evaluated in this NOPR analysis for medium- and low-temperature units
are not defined using design options but are based on the unit cooler
performance database.
In the June 2022 Preliminary Analysis, DOE observed that in the
unit cooler performance database there was a group of low- and medium-
temperature unit coolers with ratings at what appears to be a constant
offset above the current standards. See section 3.2.4.4 in chapter 3 of
the preliminary TSD. In response to DOE's finding, HTPG commented that
DOE should be able to determine the constant offset that low- and
medium-temperature unit coolers are rated above the current standards
from product literature because disclosure of efficiency information in
marketing materials is required by title 10 Code of Federal Regulations
Part 431.305 Walk-in cooler and walk-in freezer labeling requirements.
(HTPG, no. 35 at p. 2) DOE was not able to find product literature or
marketing materials for the units in question and therefore was not
able to confirm the AWEF ratings for this group of unit coolers
certified in the CCD and did not consider them in its analysis. The
most recent CCD efficiency distribution is discussed in more detail in
chapter 3 of the accompanying TSD.
Not including the group of unit coolers with ratings at what appear
to be a constant offset above the current standards, the current CCD
includes few unit coolers rated above baseline. However, after
evaluating certified unit cooler capacities, DOE has tentatively
determined that there are unit coolers on the market at efficiencies
higher than baseline. As such, instead of modeling efficiency based on
certified AWEF values, DOE calculated unit cooler AWEF in accordance
with appendix C to subpart R using certified capacity, catalog fan
power, and default defrost power calculations. Using the unit cooler
performance database, DOE found that the primary design option in unit
coolers on the market today to improve efficiency is an improved
evaporator coil. Specifically, DOE found that adding tube rows to unit
cooler evaporators increases capacity while keeping fan power constant,
resulting in more efficient units.
DOE was unable to construct a performance database for high-
temperature unit coolers since there are no high-temperature units
certified in the CCD; therefore, DOE conducted a design option approach
for high-temperature unit coolers. As discussed in section IV.B.2.b of
this document, the design options remaining for unit coolers after
screening are improved evaporator coil, improved evaporator fan blades,
off-cycle evaporator fan control, and on-cycle evaporator fan control.
As discussed previously in this section, DOE has tentatively determined
that improved evaporator fan blades do not effectively improve unit
cooler efficiency, and therefore DOE did not analyze improved
evaporator fan blades as a design option for high-temperature unit
coolers. Additionally, on-cycle evaporator fan control requires a
condensing system that varies cooling load to the unit cooler and DOE
is aware that not all high-temperature condensing systems are capable
of this type of operation. As a result, DOE did not analyze on-cycle
evaporator fan control as a design option for high-temperature unit
coolers. The remaining design options for high-temperature unit coolers
are improved evaporator coils and off-cycle evaporator fan controls.
Details on DOE's methods for defining baseline efficiency and
efficiency levels above baseline are discussed in the following
sections and in more detail in Ch. 5 of the accompanying TSD.
Baseline Efficiency
For each equipment class, DOE generally selects a baseline model as
a reference point for each class, and measures changes resulting from
potential energy conservation standards against the baseline. The
baseline model in each equipment class represents the characteristics
of equipment typical of that class (e.g., capacity, physical size).
Generally, a baseline model is one that just meets current energy
conservation standards, or, if no standards are in place, the baseline
is typically the most common or least efficient unit on the market.
As discussed in section 5.6.3 of the June 2022 Preliminary Analysis
TSD, DOE assumed that a baseline medium- or low-temperature unit would
just meet the current energy conservation standards (see 10 CFR
431.306). The analysis in the June 2022 Preliminary Analysis evaluated
which design option combinations would be needed to achieve the current
standards.
In response to this baselining approach, AHRI commented that DOE
did not consider in its analysis that many manufacturers are already
using variable-speed technology in their unit coolers. (AHRI, No. 39 at
p. 2). KeepRite commented that most unit coolers include off-cycle fan
control to meet the current standards. (KeepRite, No. 41 at p. 2) HTPG
stated that it believes baseline unit coolers should include improved
evaporator fan blades and variable-speed evaporator fans. (HTPG, No. 35
at p.5) KeepRite stated that enhanced tubing and fin surfaces are
already found in most evaporator and condenser coils. (KeepRite, No. 41
at p. 2)
DOE acknowledges that many baseline medium- and low-temperature
unit coolers use variable-speed fans, improvements to fan blades, and
optimized heat exchanger coils. While constructing the unit cooler
performance database for this NOPR analysis, DOE found that all units
included in the database used two-speed ECMs. DOE made no assumptions
about baseline unit cooler technologies while constructing this
database since
[[Page 60782]]
the performance benefits of different technologies should be apparent
from the fan power and capacities of the unit. DOE found that baseline
medium- and low-temperature unit coolers with a capacity less than
25,000 Btu/h typically had two evaporator rows and baseline units with
a capacity greater than 25,000 Btu/h typically had three evaporator
tube rows. Table IV.19 lists representative units and the number of
baseline evaporator tubes DOE used in its analysis.
Table IV.19--Baseline Medium- and Low-Temperature Unit Cooler Evaporator
Tube Rows
------------------------------------------------------------------------
Baseline
Temperature Capacity evaporator
(Btu/h) tube rows
------------------------------------------------------------------------
Medium.......................................... 3,000 2
9,000 2
25,000 2
54,000 3
75,000 3
Low............................................. 3,000 2
9,000 2
25,000 2
54,000 3
75,000 3
------------------------------------------------------------------------
There are currently no energy conservation standards for high-
temperature unit coolers; therefore, DOE could not use a current
standard as the baseline for the high-temperature equipment classes.
Instead, DOE used manufacturer literature to select baseline units that
DOE has tentatively determined are representative of the baseline
efficiency currently on the market. DOE determined potential design
options applied to these units based on a review of manufacturer
literature and feedback from high-temperature refrigeration system
manufacturers. DOE validated the AWEF values used to define the high-
temperature baseline efficiency level through investigative testing.
Maximum Technology Levels
In the June 2022 Preliminary Analysis, DOE defined the maximum
technology unit cooler as a unit cooler that includes all analyzed
design options. See chapter 5 of the June 2022 Preliminary Analysis
TSD. As discussed in the Efficiency Levels subsection of section
IV.C.1.e of this document, the baseline and maximum technology
efficiency levels are the same for some unit coolers. However, DOE's
reevaluation using the unit cooler performance database indicates that
unit coolers at efficiencies higher than baseline are currently
available in the market.
To set the maximum technology level for medium- and low-temperature
unit coolers in its NOPR analysis, DOE selected the highest efficiency
unit cooler available for each representative capacity from the unit
cooler performance database. As discussed previously, the highest
efficiency unit coolers at each representative capacity corresponded to
an increase in two evaporator tube rows. Table IV.20 lists the unit
cooler representative units evaluated in the NOPR and the number of
tubes used to reach the highest efficiency level.
Table IV.20--Maximum Technology Medium- and Low-Temperature Unit Cooler
Evaporator Tube Rows
------------------------------------------------------------------------
Maximum
Capacity technology
Temperature (Btu/h) evaporator
tube rows
------------------------------------------------------------------------
Medium.......................................... 3,000 4
9,000 4
25,000 4
54,000 5
75,000 5
Low............................................. 3,000 4
9,000 4
25,000 4
54,000 5
75,000 5
------------------------------------------------------------------------
For the high-temperature unit cooler analysis, DOE maintained the
approach it used in the June 2022 Preliminary Analysis. Specifically,
it defined the maximum technology level as a representative unit with
all the design options applied. As discussed in the unit cooler
Efficiency Levels subsection of section IV.C.1.e of this document, the
design options analyzed for high-temperature unit coolers were off-
cycle evaporator fan controls and improved evaporator coils. In this
NOPR, a maximum technology high-temperature unit cooler includes both
design options.
Defining maximum technology levels for unit coolers is discussed in
more detail in chapter 5 of the accompanying TSD.
Intermediate Efficiency Levels
All medium- and low-temperature unit cooler representative
capacities had baseline and maximum technology efficiency levels that
differed by more than one tube row. DOE defined an efficiency level for
each of these representative units at the number of tube rows between
their baseline and maximum technology levels. For example, if the
baseline has three tube rows and the maximum technology had five tube
rows, DOE defined an intermediate efficiency level at four tube rows.
DOE's analysis of the market suggested that manufacturers only use full
tube rows and therefore, DOE only used whole number tube rows for the
analysis. DOE determined the efficiency of these intermediate
efficiency levels using data from the unit cooler performance database.
DOE did not define intermediate efficiency levels for high-temperature
unit coolers.
Defining and determining the efficiency of intermediate efficiency
levels is discussed in more detail in chapter 5 of the accompanying
TSD.
2. Cost Analysis
The cost analysis portion of the engineering analysis is conducted
using one or a combination of cost approaches. The selection of cost
approach depends on a suite of factors, including the availability and
reliability of public information, characteristics of the regulated
product, and the availability and timeliness of purchasing the
equipment on the market. The cost approaches are summarized as follows:
Physical teardowns: Under this approach, DOE physically
dismantles a commercially available product, component-by-component, to
develop a detailed bill of materials for the product.
Virtual teardowns: In lieu of physically deconstructing a
product, DOE identifies each component using parts diagrams and spec
sheets (available from manufacturer websites or appliance repair
websites, for example) to develop the bill of materials for the
product.
Price surveys: If neither a physical nor catalog teardown
is feasible (for example, for tightly integrated products such as
fluorescent lamps, which are infeasible to disassemble and for which
parts diagrams are unavailable) or cost-prohibitive and otherwise
impractical (e.g., large commercial boilers), DOE conducts price
surveys using publicly available pricing data published on major online
retailer websites and/or by soliciting prices from distributors and
other commercial channels.
In the present case, DOE conducted the analysis using physical
teardowns supplemented with virtual teardowns.
As discussed in section IV.C.1 of this document, DOE identified the
energy efficiency levels associated with walk-in components using
testing, market data, and manufacturer interviews. Next, DOE selected
equipment for the physical teardown analysis having characteristics of
typical equipment on the market at the representative capacity. DOE
gathered information from performing a
[[Page 60783]]
physical teardown analysis to create detailed bill of materials
(``BOMs''), which included all components and processes used to
manufacture the equipment. DOE used the BOMs from the teardowns as
inputs to calculate the manufacturer production cost (``MPC'') for
equipment at various efficiency levels spanning the full range of
efficiencies from the baseline to the maximum technology available.
During the development of the analysis for this NOPR, DOE held
confidential interviews with manufacturers to gain insight into the
walk-in industry and to request feedback on the engineering analysis.
DOE used the information gathered from these interviews, along with the
information obtained through the teardown analysis and public comments,
to refine its MPC estimates for this rulemaking. Next, DOE derived
manufacturer markups using data obtained for past walk-in rulemakings
in conjunction with manufacturer feedback. The markups were used to
convert MPCs into manufacturer sales prices (``MSPs''). Further
information on comments received and the analytical methodology is
presented in the following subsections. For additional detail, see
chapter 5 of the NOPR TSD.
a. Teardown Analysis
To assemble BOMs and to calculate the manufacturing costs for the
different parts of walk-in components, DOE disassembled multiple
envelope and refrigeration system units into their base parts and
estimated the materials, processes, and labor required for the
manufacture of each individual part, a process referred to as a
``physical teardown.'' Using the data gathered from the physical
teardowns, DOE characterized each part according to its weight,
dimensions, material, quantity, and the manufacturing processes used to
fabricate and assemble it.
DOE also used a supplementary method, called a ``virtual
teardown,'' which examines published manufacturer catalogs and
supplementary component data to estimate the major physical differences
between equipment that was physically disassembled and similar
equipment that was not. For supplementary virtual teardowns, DOE
gathered equipment data such as dimensions, weight, and design features
from publicly available information, such as manufacturer catalogs.
For parts fabricated in-house, the prices of the underlying ``raw''
metals (e.g., tube, sheet metal) are estimated on the basis of 5-year
averages to smooth out spikes in demand. Other ``raw'' materials such
as plastic resins, insulation materials, etc. are estimated on a
current-market basis. The costs of raw materials are based on
manufacturer interviews, quotes from suppliers, and secondary research.
Past results are updated periodically and/or inflated to present-day
prices using indices from resources such as MEPS Intl.,\35\
PolymerUpdate,\36\ the U.S. geologic survey (``USGS''),\37\ and the
Bureau of Labor Statistics (``BLS'').\38\
---------------------------------------------------------------------------
\35\ For more information on MEPS Intl, please visit:
www.meps.co.uk/.
\36\ For more information on PolymerUpdate, please visit:
www.polymerupdate.com.
\37\ For more information on the USGS metal price statistics,
please visit www.usgs.gov/centers/nmic/commodity-statistics-and-information.
\38\ For more information on the BLS producer price indices,
please visit: www.bls.gov/ppi/.
---------------------------------------------------------------------------
More information regarding details on the teardown analysis can be
found in chapter 5 of the NOPR TSD.
b. Cost Estimation Method
The costs of models are estimated using the content of the BOMs
(i.e., materials, fabrication, labor, and all other aspects that make
up a production facility) to generate the MPCs. For example, these MPCs
consider cost contributions from overhead and depreciation. DOE
collected information on labor rates, tooling costs, raw material
prices, and other factors as inputs into the cost estimates. For
purchased parts, DOE estimated the purchase price based on volume-
variable price quotations and detailed discussions with manufacturers
and component suppliers. For fabricated parts, the prices of raw metal
materials \39\ (i.e., tube, sheet metal) are estimated using the
average of the most recent 5-year period. The cost of transforming the
intermediate materials into finished parts was estimated based on
current industry pricing at the time of analysis.\40\
---------------------------------------------------------------------------
\39\ Fastmarkets, available at www.fastmarkets.com/amm-is-part-of-fastmarkets.
\40\ U.S. Department of Labor, Bureau of Labor Statistics,
Producer Price Indices, available at www.bls.gov/ppi/.
---------------------------------------------------------------------------
c. Manufacturing Production Costs
DOE estimated the MPC at each efficiency level considered for each
representative unit, from the baseline through the maximum technology
and then calculated the percentages attributable to each cost category
(i.e., materials, labor, depreciation, and overhead). These percentages
are used to validate the assumptions by comparing them to
manufacturers' actual financial data published in annual reports, along
with feedback obtained from manufacturers during interviews. DOE uses
these production cost percentages in the MIA (see section IV.J).
In response to the June 2022 Preliminary Analysis, Hussmann-Doors
commented that the manufacturer production costs used in the June 2022
Preliminary Analysis are about 30 percent lower for display, swinging,
medium-temperature doors and 50 percent lower for display, swinging,
low-temperature doors compared to its current door products. (Hussmann-
Doors, No. 33 at p. 4) Hussmann-Doors also commented specifically on
its display door frames, stating that its structures use a new material
that was developed to meet the DOE energy requirements that were set in
2017 and that the material costs 1.5 times the cost of conventional
materials on a per pound basis. (Hussmann-Doors, No. 33 at p. 4) Lennox
commented that the MPC estimates are below current values. (Lennox, No.
36 at p. 4)
AHRI commented that it believes many assumptions for labor and time
that contribute to MPCs are too low. (AHRI, No. 39 at p. 3) Hussmann-
Refrigeration commented that it agrees with AHRI that the assumptions
that contribute to MPCs are too low. (Hussmann-Refrigeration, No. 38 at
p. 3) AHRI-Wine commented that it disagrees with the MPCs and MSPs due
to the volatility of the market, supply chain issues, the dates that
the efficiency standards will be implemented, and the volume of the
wine cellar market. (AHRI-Wine, No. 39 at p. 4)
Based on stakeholder feedback, in preparing this NOPR DOE updated
the labor costs that contribute to the MPC by increasing the hourly
wages. Additionally, for refrigeration systems, DOE lowered the
employee to supervisor ratio. DOE also sought feedback on costs during
the most recent round of manufacturer interviews. DOE has incorporated
the feedback received during these interviews and from stakeholder
comments into its cost analysis for this NOPR. DOE has tentatively
determined that the MPCs presented in this NOPR are representative of
the current walk-in market.
d. Manufacturer Markup and Shipping Costs
To account for manufacturer non-production costs and profit margin,
DOE applies a multiplier (the manufacturer markup) to the MPC. The
resulting MSP is the price at which the manufacturer distributes a unit
into commerce. DOE developed an average manufacturer markup by
examining the annual Securities and Exchange Commission
[[Page 60784]]
10-K reports filed by publicly traded manufacturers whose combined
product range includes walk-ins. DOE also relied on data published in
the June 2014 Final Rule and information gathered from manufacturer
interviews to develop the initial manufacturer markup estimates. See
chapter 12 of the NOPR TSD or section IV.J.2.d of this document for
additional detail on the manufacturer markup.
In response to the MSPs, KeepRite commented that larger coils would
result in higher installation and shipping costs. (KeepRite, No. 41 at
p. 2)
DOE acknowledges that shipping costs account for additional non-
production cost for manufacturers to distribute their equipment to the
first buyer in the distribution chain. In this NOPR analysis, DOE
estimated a per-unit shipping cost for each representative unit at each
efficiency level based on the size and weight of the given unit. Design
options such as larger condenser coils resulted in larger per unit
shipping costs due to the increased size and weight associated with the
design option. These shipping costs were incorporated into consumer
prices. Installation costs are discussed in section IV.F.3 of this
document.
3. Cost-Efficiency Results
The results of the engineering analysis are reported as cost-
efficiency curves in the form of maximum daily energy consumption (in
kWh/day) versus MSP (in dollars) for doors, R-value (in h-ft\2\-[deg]F/
Btu) versus MSP (in dollars) for panels, and AWEF2 (in Btu/h) versus
MSP (in dollars). The methodology for developing the curves started
with determining the energy consumption for baseline equipment and MPCs
for this equipment. For the equipment classes that used the design
option approach, DOE implemented design options above baseline using
the ratio of cost to savings and implemented only one design option at
each efficiency level. Design options were implemented until all
available technologies were employed (i.e., at a max-tech level). For
the equipment classes that used the efficiency level approach, DOE
increased the efficiency level using the ratio of cost to savings above
baseline until the maximum efficiency level was reached. See chapter 5
of the NOPR TSD for additional detail on the engineering analysis and
appendix 5B of the NOPR TSD for complete cost-efficiency results.
In response to the June 2022 Preliminary Analysis, AHRI requested
further clarification on the cost-efficiency data in Tables 5A.5.22,
5A.5.25, 5A.5.34, and 5A.5.35, particularly on how the AWEF values were
determined and the cost differences between efficiency levels. (AHRI,
No. 39 at p. 3). The cost-efficiency curves were determined using the
cost and efficiency analyses. These are discussed in detail in chapter
5 of the June 2022 Preliminary Analysis TSD. The cost and efficiency
analyses for this NOPR are described in sections IV.C.1 and IV.C.2 of
this document, and in more detail in chapter 5 of the accompanying TSD.
D. Markups Analysis
The markups analysis develops appropriate markups (e.g., retailer
markups, distributor markups, contractor markups) in the distribution
chain and sales taxes to convert the MSP and shipping cost estimates
derived in the engineering analysis to consumer prices, which are then
used in the LCC and PBP analysis. At each step in the distribution
channel, companies mark up the price of the product to cover business
costs and profit margin.
Regarding its markup analysis in the June 2022 Preliminary
Analysis, DOE received comments from AHRI and Lennox. AHRI responded
that single-packaged dedicated systems are sold through the original
equipment manufacturer (``OEM'') distribution channel more so than
other walk-in refrigeration systems, where 75 percent of shipments are
through OEMs, 15 percent are through refrigeration wholesalers, and the
remaining 10 percent are spread across general contractor and equipment
distributor. (AHRI, No. 16 at p. 15) Lennox responded that its analysis
of e-commerce channels for dedicated condensing equipment, unit coolers
and single-packaged dedicated systems indicates these channels are
primarily used to source used refurbished equipment. (Lennox, No. 36 at
p. 5) Lennox stated that it believes single-packaged dedicated systems
could have quicker adoption via e-commerce because of the nature of the
equipment and its simpler application use, and that while e-commerce
may be a factor in the future, dedicated condensing unit and unit
cooler application require knowledgeable personnel to select and
balance the equipment. Lennox further commented that with EPA's plans
to reduce hydrofluorocarbon (``HFC'') emissions per the AIM Act, low-
GWP refrigerants including A2Ls and CO2 are expected to come
into the market, which will increase the complexity of selecting walk-
in refrigeration equipment for customers, affecting the rate of e-
commerce adoption. (Id.)
In response to AHRI, DOE notes that the distribution channels that
were used in its June 2022 Preliminary Analysis are consistent with the
values provided by AHRI and DOE has maintained these values in its NOPR
analysis. DOE tentatively agrees with Lennox's position that the e-
commerce distribution channel is primarily used for refurbished/used
equipment and that e-commerce may become a viable means of distribution
of dedicated condensing and unit cooler equipment in the future.
However, DOE notes that refurbished/used equipment are outside the
scope of this rulemaking and are therefore not considered in this
analysis and that future distribution through e-commerce is uncertain.
Because of these uncertainties, DOE has not included the e-commerce
distribution channel in this analysis and has maintained the approach
used in the June 2022 Preliminary Analysis. However, DOE may consider
including walk-ins e-commerce distribution channels in its analysis in
a future rulemaking.
DOE seeks comment on e-commerce distribution channels, including
which types of walk-in equipment use this channel and the size of this
channel.
DOE developed baseline and incremental markups for each agent in
the distribution chain. Baseline markups are applied to the price of
equipment with baseline efficiency, while incremental markups are
applied to the difference in price between baseline and higher-
efficiency models (the incremental cost increase). The incremental
markup is typically less than the baseline markup and is designed to
maintain similar per-unit operating profit before and after new or
amended standards.\41\ In the context of this analysis, OEMs are mostly
manufacturers of envelope insulation panels who may also sell entire
walk-in units. Manufacturers of entire walk-in units assemble a
combination of purchased and manufactured components at either the
manufacturer's plant or at the customer site. Table IV.21 shows the
distribution channels DOE defined for this analysis. Table IV.22
summarizes the baseline markups and incremental markups developed for
walk-in equipment. The markups shown in this table reflect national
average values for the given markup. In the
[[Page 60785]]
subsequent LCC analysis, regional markup multipliers were developed and
were used to capture regional variation in mechanical contractor
markups as well as state-to-state differences in sales taxes. Also, in
the LCC analysis, the relative shipments to new construction and to the
replacement market vary by equipment class resulting in some slight
differences between sales-weighted average baseline and average
incremental markups by equipment class.
---------------------------------------------------------------------------
\41\ Because the projected price of standards-compliant
equipment is typically higher than the price of baseline equipment,
using the same markup for the incremental cost and the baseline cost
would result in higher per-unit operating profit. While such an
outcome is possible, DOE maintains that in markets that are
reasonably competitive it is unlikely that standards would lead to a
sustainable increase in profitability in the long run.
Table IV.21--Distribution Channel Weights
----------------------------------------------------------------------------------------------------------------
Dedicated Single-
condensing Panels and non- packaged Unit coolers
Distribution channel units and unit Display doors display doors dedicated for multiplex
coolers systems *
----------------------------------------------------------------------------------------------------------------
Direct (National Account)....... 0.03 0.30 0.45 .............. 0.45
Contractors..................... 0.03 0.14 0.11 0.5 0.01
Distributors.................... 0.34 0.56 0.44 0.5 0.05
OEM............................. 0.18 .............. .............. 0.75 0.05
Wholesale....................... 0.42 .............. .............. 0.15 0.45
Grand Total..................... 1.00 1.00 1.00 1.00 1.00
----------------------------------------------------------------------------------------------------------------
* Unit coolers are sold into applications where they are connected to both dedicated, and multiplex condensing
systems. While multiplex condensing systems are not currently with scope unit coolers connected to them are.
Table IV.22--Distribution Channel Shares and Markups
----------------------------------------------------------------------------------------------------------------
Baseline Incremental
Equipment class code Equipment family markup markup
----------------------------------------------------------------------------------------------------------------
DC.L.O........................................ DC.............................. 2.03 1.37
DC.L.I........................................ DC.............................. 2.03 1.37
DC.M.O........................................ DC.............................. 2.03 1.37
DC.M.I........................................ DC.............................. 2.03 1.37
UC.L.......................................... UC.............................. 2.03 1.37
UC.M.......................................... UC.............................. 2.03 1.37
UC.L--Multiplex............................... UC.............................. 1.98 1.46
UC.M--Multiplex............................... UC.............................. 1.98 1.46
FP.L.......................................... P and NDD....................... 1.32 1.19
PS.L.......................................... P and NDD....................... 1.32 1.19
PS.M.......................................... P and NDD....................... 1.32 1.19
NM.L.......................................... P and NDD....................... 1.32 1.19
NM.M.......................................... P and NDD....................... 1.32 1.19
NO.L.......................................... P and NDD....................... 1.32 1.19
NO.M.......................................... P and NDD....................... 1.32 1.19
DW.L.......................................... DD.............................. 1.71 1.29
DW.M.......................................... DD.............................. 1.71 1.29
SP.M.I........................................ SP.............................. 1.53 1.18
SP.M.O........................................ SP.............................. 1.53 1.18
SP.L.I........................................ SP.............................. 1.53 1.18
SP.L.O........................................ SP.............................. 1.53 1.18
SP.H.I........................................ SP.............................. 1.53 1.18
SP.H.O........................................ SP.............................. 1.53 1.18
SP.H.ID....................................... SP.............................. 1.53 1.18
SP.H.OD....................................... SP.............................. 1.53 1.18
----------------------------------------------------------------------------------------------------------------
Key: DC = dedicated condensing unit; UC = unit cooler; P = panel, NDD = non-display door; DW = display door, SP
= single-packaged dedicated system.
After identifying the six distribution channels listed in Table
IV.21, DOE relied on economic data from the U.S. Census Bureau \42\ and
other sources \43\ to determine how prices are marked up as equipment
is passed from the manufacturer to the customer.
---------------------------------------------------------------------------
\42\ U.S. Census Bureau. Electrical, Hardware, Plumbing, and
Heating Equipment and Supplies: 2020. 2020. Washington, DC Report
No. EC-02-421-17
\43\ Heating, Air conditioning & Refrigeration Distributors
International. 2012 Profit Report (2011 Data). 2012. Columbus, OH.
---------------------------------------------------------------------------
Chapter 6 of the NOPR TSD provides details on DOE's development of
markups for walk-in coolers and freezers.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of walk-in coolers and freezers at different
efficiencies in representative U.S. commercial buildings, and to assess
the energy savings potential of increased walk-in efficiency. The
energy use analysis estimates the range of energy use for walk-ins in
the field (i.e., as they are actually used by consumers) stated as
annual energy consumption (``AEC''). The energy use analysis provides
the basis for other analyses DOE performed, particularly assessments of
the energy savings and the savings in consumer operating costs that
could result from adoption of amended or new standards.
1. Trial Standard Levels
DOE analyzed the benefits and burdens of three trial standard
levels (``TSLs'') for the considered walk-in doors, panels, and
refrigeration systems. These TSLs were developed by combining specific
efficiency levels for each of the equipment classes analyzed by DOE in
the engineering analysis, as
[[Page 60786]]
discussed in section IV.A.1 of this document. DOE presents the results
for the TSLs in this document by equipment type rather than by
equipment class for brevity, while the results for all efficiency
levels for each representative unit and equipment class that DOE
analyzed are available in chapters 5, 8, and 10 of the NOPR TSD.
To estimate the impacts of improved efficiency on walk-in envelope
components (e.g., panels, doors), DOE must first establish the
efficiencies and energy use of the connected refrigeration equipment;
therefore, DOE is presenting the TSLs in this section of the document.
By determining the TSL in the energy use analysis, DOE can estimate the
impacts of specific, consistent policy scenarios across both walk-in
refrigeration systems and envelope components. For this analysis DOE is
examining three TSLs.
TSL 3 is the efficiency levels that use the combination of design
options for each representative unit at the maximum feasible
technologically level.
Table IV.23--Envelope Components Efficiency Level by Representative Unit
Mapping for TSL 3
------------------------------------------------------------------------
Equipment class TSL 3
------------------------------------------------------------------------
Display Doors
------------------------------------------------------------------------
DW.L.................................................... 2
DW.M.................................................... 2
------------------------------------------------------------------------
Non-display Doors
------------------------------------------------------------------------
NM.L.................................................... 5
NM.M.................................................... 6
NO.L.................................................... 5
NO.M.................................................... 6
------------------------------------------------------------------------
Panels
------------------------------------------------------------------------
PF.L.................................................... 3
PS.L.................................................... 2
PS.M.................................................... 3
------------------------------------------------------------------------
Table IV.24--Refrigeration Systems Efficiency Level by Representative Unit Mapping for TSL 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Capacity (kBtu/hr)
Equipment class --------------------------------------------------------------------------------------------------
2 3 6 7 9 25 54 75 124
--------------------------------------------------------------------------------------------------------------------------------------------------------
Dedicated Condensing Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I............................................... ......... 2 ......... ......... 1 3 2 ......... .........
DC.L.O............................................... ......... 3 ......... ......... 5 8 5 5 .........
DC.M.I............................................... ......... ......... ......... ......... 1 2 3 3 .........
DC.M.O............................................... ......... ......... ......... ......... 7 8 7 8 8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Single-packaged Dedicated Condensing Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
SP.H.I............................................... 2 ......... ......... 2 ......... ......... ......... ......... .........
SP.H.ID.............................................. 2 ......... ......... 2 ......... ......... ......... ......... .........
SP.H.O............................................... 6 ......... ......... 6 ......... ......... ......... ......... .........
SP.H.OD.............................................. 6 ......... ......... 6 ......... ......... ......... ......... .........
SP.L.I............................................... 7 ......... 3 ......... ......... ......... ......... ......... .........
SP.L.O............................................... 4 ......... 4 ......... ......... ......... ......... ......... .........
SP.M.I............................................... 5 ......... ......... ......... 3 ......... ......... ......... .........
SP.M.O............................................... 9 ......... ......... ......... 5 ......... ......... ......... .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Unit Coolers
--------------------------------------------------------------------------------------------------------------------------------------------------------
UC.H................................................. ......... ......... ......... ......... 1 1 ......... ......... .........
UC.H.ID.............................................. ......... ......... ......... ......... 1 1 ......... ......... .........
UC.L................................................. ......... 2 ......... ......... 2 2 2 2 .........
UC.M................................................. ......... 2 ......... ......... 2 2 2 2 .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
TSL 2 is the combination of efficiency levels of all representative
units where FFC is maximized while constrained to a positive NPV at a
7-percent discount rate. For display doors (DW.L and DW.M) and for
panels (PF.L, PS.L, and PS.M) there are no efficiency improvements that
results in consumer benefits; therefore, the mapped ELs for this TSL
remain at baseline (EL 0). In this proposed rule, the efficiency levels
for non-display doors and structural panels at TSL 2 are constrained
such that improvements to insulation are harmonized across non-display
doors and structural panels to avoid a circumstance where DOE would
propose a standard where one component would require increased
insulation thickness, but not the other. Thus, the efficiency levels at
TSL 2 are aligned to reflect design options where the insulation
thickness is harmonized and results in positive NPV for both non-
display doors and structural panels. Aligning the insulation thickness
of non-display doors and panels avoids a potential unintended
consequence where the installation of replacement non-display doors
could trigger the replacement of some, or all, of the attached walk-in
enclosure panels because the thickness of the components do not match.
DOE seeks comment on its assumptions and rationale for harmonizing
panel and non-display door thicknesses at a given TSL.
DOE notes that for refrigeration systems there are no such
constraints and TSL 2 is evaluated by the strict criteria of maximum
FFC with positive consumer NPV at a 7 percent discount rate. This
results in a situation where the combination of ELs for TSL 2 for some
equipment are at max-tech levels where others are not.
Table IV.25--Envelope Components Efficiency Level by Representative Unit
Mapping for TSL 2
------------------------------------------------------------------------
Equipment class TSL 2
------------------------------------------------------------------------
Display Doors
------------------------------------------------------------------------
DW.L........................................................... 0
DW.M........................................................... 0
------------------------------------------------------------------------
Non-display Doors
------------------------------------------------------------------------
NM.L........................................................... 3
NM.M........................................................... 3
[[Page 60787]]
NO.L........................................................... 3
NO.M........................................................... 3
------------------------------------------------------------------------
Panels
------------------------------------------------------------------------
PF.L........................................................... 0
PS.L........................................................... 0
PS.M........................................................... 0
------------------------------------------------------------------------
Table IV.26--Refrigeration Systems Efficiency Level by Representative Unit Mapping for TSL 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Capacity (kBtu/hr)
Equipment class --------------------------------------------------------------------------------------------------
2 3 6 7 9 25 54 75 124
--------------------------------------------------------------------------------------------------------------------------------------------------------
Dedicated Condensing Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I............................................... ......... 1 ......... ......... 0 2 1 ......... .........
DC.L.O............................................... ......... 2 ......... ......... 3 7 4 3 .........
DC.M.I............................................... ......... ......... ......... ......... 0 1 2 2 .........
DC.M.O............................................... ......... ......... ......... ......... 2 3 3 3 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Single-packaged Dedicated Condensing Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
SP.H.I............................................... 1 ......... ......... 2 ......... ......... ......... ......... .........
SP.H.ID.............................................. 2 ......... ......... 2 ......... ......... ......... ......... .........
SP.H.O............................................... 5 ......... ......... 5 ......... ......... ......... ......... .........
SP.H.OD.............................................. 5 ......... ......... 6 ......... ......... ......... ......... .........
SP.L.I............................................... 4 ......... 2 ......... ......... ......... ......... ......... .........
SP.L.O............................................... 0 ......... 0 ......... ......... ......... ......... ......... .........
SP.M.I............................................... 3 ......... ......... ......... 1 ......... ......... ......... .........
SP.M.O............................................... 7 ......... ......... ......... 3 ......... ......... ......... .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Unit Coolers
--------------------------------------------------------------------------------------------------------------------------------------------------------
UC.H.I............................................... ......... ......... ......... ......... 0 0 ......... ......... .........
UC.H.ID.............................................. ......... ......... ......... ......... 1 1 ......... ......... .........
UC.L................................................. ......... 2 ......... ......... 2 2 2 2 .........
UC.M................................................. ......... 2 ......... ......... 2 2 2 2 .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
TSL 1 is the combination of efficiency levels where NPV at a 7-
percent discount rate is maximized. Panels and non-display doors are
subject to the same constraint as in TSL 2 that the design options for
insulation thickness must result in positive NPV.
Table IV.27--Envelope Components Efficiency Level by Representative Unit
Mapping for TSL 1
------------------------------------------------------------------------
Equipment class TSL 1
------------------------------------------------------------------------
Display Doors
------------------------------------------------------------------------
DW.L........................................................... 0
DW.M........................................................... 0
------------------------------------------------------------------------
Non-display Doors
------------------------------------------------------------------------
NM.L........................................................... 3
NM.M........................................................... 1
NO.L........................................................... 3
NO.M........................................................... 1
------------------------------------------------------------------------
Panels
------------------------------------------------------------------------
PF.L........................................................... 0
PS.L........................................................... 0
PS.M........................................................... 0
------------------------------------------------------------------------
Table IV.28--Refrigeration Systems Efficiency Level by Representative Unit Mapping for TSL 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Capacity (kBtu/hr)
Equipment class --------------------------------------------------------------------------------------------------
2 3 6 7 9 25 54 75 124
--------------------------------------------------------------------------------------------------------------------------------------------------------
Dedicated Condensing Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I............................................... ......... 1 ......... ......... 0 2 1 ......... .........
DC.L.O............................................... ......... 2 ......... ......... 3 5 3 3 .........
DC.M.I............................................... ......... ......... ......... ......... 0 1 2 2 .........
DC.M.O............................................... ......... ......... ......... ......... 1 2 3 3 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Single-packaged Dedicated Condensing Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
SP.H.I............................................... 1 ......... ......... 2 ......... ......... ......... ......... .........
SP.H.ID.............................................. 2 ......... ......... 2 ......... ......... ......... ......... .........
SP.H.O............................................... 4 ......... ......... 3 ......... ......... ......... ......... .........
[[Page 60788]]
SP.H.OD.............................................. 4 ......... ......... 3 ......... ......... ......... ......... .........
SP.L.I............................................... 4 ......... 2 ......... ......... ......... ......... ......... .........
SP.L.O............................................... 0 ......... 0 ......... ......... ......... ......... ......... .........
SP.M.I............................................... 2 ......... ......... ......... 1 ......... ......... ......... .........
SP.M.O............................................... 5 ......... ......... ......... 3 ......... ......... ......... .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Unit Coolers
--------------------------------------------------------------------------------------------------------------------------------------------------------
UC.H.I............................................... ......... ......... ......... ......... 0 0 ......... ......... .........
UC.H.ID.............................................. ......... ......... ......... ......... 1 1 ......... ......... .........
UC.L................................................. ......... 1 ......... ......... 2 1 2 1 .........
UC.M................................................. ......... 2 ......... ......... 1 2 1 2 .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
2. Energy Use of Envelope Components
DOE used the results of the engineering analysis to determine the
annual electrical energy consumption of each walk-in envelope component
(i.e., panels, non-display doors, and display doors). For panels, the
AEC is calculated as the energy consumption per unit area of the panel
for heat infiltration through the panel or door. For doors that use
electricity directly from electricity-consuming components (i.e.,
lighting and/or anti-sweat heaters), DOE calculated the associated
increased refrigeration load from the electricity-consuming components
and added it to the total to obtain the daily refrigeration load. This
refrigeration load was divided by the annual energy efficiency ratio
(``AEER'') of the shipment-weighted average of refrigeration system
equipment classes grouped by temperature rating to estimate the
associated energy use. DOE multiplied the daily electrical energy
consumption by the number of days per year to obtain the AEC. DOE then
determined the total electrical energy consumption associated with each
envelope component by (1) calculating the refrigeration energy
consumption required to compensate for heat infiltration through the
envelope based on the assumed connected refrigeration system, and (2)
adding any direct electrical energy consumed by component. The
refrigeration load was calculated by multiplying the U-factor for the
component by the reference temperature difference between the exterior
and the interior, as specified in the DOE test procedure.
DOE notes that the energy savings from improved insulation or
reduced heat infiltration would be realized as reduced load on the
attached refrigeration systems; however, for the purpose of reporting
savings to determine any potential amended standard, these energy
savings are attributed to the individual envelope component in
question.
DOE did not receive any comments regarding its energy use analysis
pertaining to envelope components and has therefore maintained its
approach from the June 2022 Preliminary Analysis.
Table IV.29--Applied AEERs by Equipment Class
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class Baseline -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
DC.L.I.......................................... 2.79 2.84 2.84 2.84
DC.L.O.......................................... 4.10 4.16 4.18 4.82
DC.M.I.......................................... 5.81 6.09 6.09 6.09
DC.M.O.......................................... 8.02 8.74 8.74 10.81
SP.L.I.......................................... 2.11 2.38 2.38 2.47
SP.L.O.......................................... 3.30 3.30 3.30 3.98
SP.M.I.......................................... 5.68 6.02 6.05 6.12
SP.M.O.......................................... 7.80 8.23 8.25 9.65
----------------------------------------------------------------------------------------------------------------
3. Energy Use of Refrigeration Systems
DOE calculated the AEC of the refrigeration system assuming it is
matched to a walk-in envelope with the appropriate refrigeration load.
Further, DOE assumes that this refrigeration load is fixed in both the
no-new standards and amended standards cases.
The engineering analysis uses a design-option approach that, for
each design-option combination, adds a feature that increases
efficiency. Hence, equipment class can be represented by a group of
efficiency level indicators matching the engineering design option.
For each equipment class, the engineering analysis evaluates the
performance of the dedicated condensing unit, unit cooler, or single-
packaged dedicated system, and for each representative capacity the
performance data are passed to the energy use calculation. The data and
equations used to calculate the annual energy use depend on the type of
equipment and are available in chapters 7, 8, and associated appendixes
of the NOPR TSD. The unit coolers that are not attached to dedicated
condensing units are assumed to be paired with a compressor rack with
constant net capacity; these are referred to as multiplex applications.
Low-temperature unit coolers include the impact of energy consumption
during the defrost cycle. For refrigeration systems, the net capacity
is affected by the design options added, so at each efficiency level
the run hours are adjusted to ensure that the amount of heat removed is
constant across all efficiency levels. For outdoor systems, the
compressor and condenser performance are also affected by ambient
temperature, and this effect is
[[Page 60789]]
incorporated into the energy use calculation. Detailed equations and
input data are presented for each equipment type in chapter 7 of the
NOPR TSD.
a. Fan Power
In response to the June 2022 Preliminary Analysis, AHRI commented
that refrigeration system fans would need to continuously operate when
using A2L refrigerants to reduce the concentration of flammable
refrigerants, which might result in the need for evaporator redesign.
(AHRI, No. 39 at p. 5) DOE is not aware of a safety standard that
requires continuous fan operation for systems using flammable
refrigerants. As such, in this NOPR, DOE assumed the same fan operation
for refrigeration systems using R-448A or R-449A and refrigeration
systems using A2L refrigerants.
b. Nominal Daily Run Hours
The daily run hours for baseline units are assumed to be 16 hours
for medium- and high-temperature systems and 18 hours for low-
temperature systems based on guidelines typically used in sizing
refrigeration systems. DOE assumed that systems were sized at design
temperatures of 95 [deg]F for outdoor units and 90 [deg]F for indoor
units. DOE also assumed an oversize factor of 20 percent is included,
which has the effect of reducing the daily run hours by a factor of \1/
1.2\. These assumptions are unchanged from the June 2014 Final Rule and
the July 2017 Final Rule. 79 FR 32083, 82 FR 31842. During the rest of
the time, the system is in off-mode, so the only energy consumption is
from the controls and evaporator fan.
In section ES.4.13 of the Executive Summary of the June 2022
Preliminary Analysis TSD, DOE requested comment on its approach for
determining the energy use of walk-in refrigeration systems. DOE
received comments from several stakeholder regarding daily run hours.
Lennox stated that DOE's application of 16 hours per day run time
is significantly low. (Lennox No. 36 at p. 6) Lennox also stated that
WICF refrigeration systems must be properly sized with extended run
times to ensure consistent temperature control to preserve the products
within. Lennox additionally commented that Heatcraft engineering manual
guidelines exist for a range of applications and that Heatcraft
guidelines for high-temperature rooms and unit coolers are based on
prep room applications where there is a higher level of outside air-
infiltration that increases the box loads. Lennox stated that Heatcraft
Run Time Guidelines are as follows:
35 [deg]F room with no timer: 16 hours,
35 [deg]F room with timer: 18 hours,
Blast coolers/freezers with positive defrost: 18 hours,
Storage freezer 20 hours,
25 to 34 [deg]F coolers with hot gas or electric defrost
20-22 hours, and
50 [deg]F rooms and higher with coil temperatures above 32
[deg]F: 20-22 hours.
(Id.)
Additionally, AHRI commented that some of its members stated that
some high-temperature unit coolers and high-temperature single-packaged
equipment would estimate the run time closer to 20 hours and requested
clarification on how the 16-hour per day nominal run time was
determined. (AHRI No. 39 at p. 4), Hussmann-Refrigeration agreed with
AHRI and stated that 20 hours is the appropriate nominal run time hours
for high-temperature single-packaged equipment. (Hussmann-
Refrigeration, No. 38 at p. 4)
In response to Lennox, DOE notes that the run time guidelines they
provided are specifically for determining the box cooling load for
prep-room applications. DOE further notes that these guidelines
encompass equipment not currently covered by the standard. In the June
2022 Preliminary Analysis, DOE adopted the run time hours from previous
analyses and stakeholder negotiations, in which they have been a
central non-contentious modeling assumption. 79 FR 32083, 81 FR 63008,
82 FR 31846. The benefit of using these single point values is that
they simplify an already complicated analysis. DOE notes that using a
single point assumption for all equipment types may not capture the
wide range of ways walk-ins are used in the field. DOE has the
technical capability to include a distribution of run time values
weighted by different walk-in applications; however, DOE does not have
either data or information with enough detail from which to construct
such a distribution.
In response to AHRI and Hussmann-Refrigeration and their request
for background on why DOE applied 16 hours as the nominal run time
hours for high-temperature single-packaged condensing systems and unit
coolers, DOE presented this number in the June 2022 Preliminary
Analysis as a modeling assumption because the intended cooling
temperature of high-temperature equipment is similar to that of medium-
temperature systems at 35 [deg]F.
Additionally, AHRI commented that it agreed with the 16-hour per
day run time for single-packaged equipment. (AHRI, No. 39 at p. 4) HTPG
agreed with the daily nominal run time hours per day for low and
medium-temperature single-packaged equipment. (HTPG, No. 35 at p. 6)
NAFEM also confirmed that the run times used in the previous rulemaking
are still representative. (NAFEM, No. 13 at p. 2)
For this NOPR, DOE is maintaining its modeling assumption of 16
hours per day of nominal daily run hours for high-temperature equipment
and maintaining its modeling assumptions from the June 2022 Preliminary
Analysis for all other classes. However, in its subgroup analysis, DOE
will examine high-temperature equipment where the nominal run time is
20 hours per day to approximate consumers with walk-ins with high warm
air-infiltration (e.g., prep-rooms) as a separate consumer subgroup
analysis. See section IV.I. DOE's applied run time hours are shown in
Table IV.30.
Table IV.30--Applied Nominal Daily Run Hours
------------------------------------------------------------------------
Temperature Hrs/day
------------------------------------------------------------------------
Low.......................................................... 18
High......................................................... 16
Medium....................................................... 16
------------------------------------------------------------------------
DOE seeks information and data from which to create representative
distributions of run time hours for different walk-in refrigeration
equipment and temperature classes.
4. Estimated Annual Energy Consumption
Table IV.31--Annual Energy Consumption Estimates for Panels
[kWh/year per ft\2\]
----------------------------------------------------------------------------------------------------------------
Equipment class Baseline TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
PF.L............................................ 5.8 5.8 5.7 4.0
PS.L............................................ 9.5 9.4 9.4 5.2
PS.M............................................ 2.3 2.2 2.2 1.1
----------------------------------------------------------------------------------------------------------------
[[Page 60790]]
Table IV.32--Annual Energy Consumption Estimates for Doors
[kWh/year]
----------------------------------------------------------------------------------------------------------------
Equipment class Baseline TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
DW.L............................................ 2,698 2,668 2,663 2,120
DW.M............................................ 775 765 762 523
NM.L............................................ 3,796 1,318 1,316 1,118
NM.M............................................ 1,239 554 281 212
NO.L............................................ 5,320 2,049 2,045 1,678
NO.M............................................ 1,738 835 462 339
----------------------------------------------------------------------------------------------------------------
Table IV.33--Annual Energy Consumption Estimates for Refrigeration Systems
[kWh/year]
----------------------------------------------------------------------------------------------------------------
Equipment class Baseline TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
DC.L.I.......................................... 26,420 25,917 25,917 25,887
DC.L.O.......................................... 40,791 40,254 40,090 34,729
DC.M.I.......................................... 12,178 11,621 11,621 11,615
DC.M.O.......................................... 17,720 17,478 17,303 13,147
SP.H.I.......................................... 2,275 2,035 2,035 1,999
SP.H.ID......................................... 3,897 3,258 3,258 3,258
SP.H.O.......................................... 3,184 2,935 2,795 2,746
SP.H.OD......................................... 5,264 4,607 4,139 4,127
SP.L.I.......................................... 6,624 5,880 5,880 5,653
SP.L.O.......................................... 8,535 8,535 8,535 7,077
SP.M.I.......................................... 6,360 6,006 5,983 5,907
SP.M.O.......................................... 5,963 5,645 5,636 4,816
UC.H............................................ 4,666 4,666 4,666 4,613
UC.H.ID......................................... 6,948 6,519 6,519 6,519
UC.L............................................ 45,993 43,845 43,190 43,190
UC.M............................................ 17,333 16,895 16,785 16,785
----------------------------------------------------------------------------------------------------------------
Chapter 7 of the NOPR TSD provides further details on DOE's energy
use analysis for walk-ins.
F. Life-Cycle Cost and Payback Period Analysis
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual consumers of potential energy conservation standards for
walk-ins. The effect of new or amended energy conservation standards on
individual consumers usually involves a reduction in operating cost and
an increase in purchase cost. DOE used the following two metrics to
measure consumer impacts:
The LCC is the total consumer expense of an appliance or
product over the life of that product, consisting of total installed
cost (manufacturer selling price, distribution chain markups, sales
tax, and installation costs) plus operating costs (expenses for energy
use, maintenance, and repair). To compute the operating costs, DOE
discounts future operating costs to the time of purchase and sums them
over the lifetime of the product.
The PBP is the estimated amount of time (in years) it
takes consumers to recover the increased purchase cost (including
installation) of a more-efficient product through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
at higher efficiency levels by the change in annual operating cost for
the year that amended or new standards are assumed to take effect.
For any given efficiency level, DOE measures the change in LCC
relative to the LCC in the no-new-standards case, which reflects the
estimated efficiency distribution of walk-ins in the absence of new or
amended energy conservation standards. In contrast, the PBP for a given
efficiency level is measured relative to the baseline product.
For each considered efficiency level in each equipment class, DOE
calculated the LCC and PBP for a nationally representative set of
commercial consumers. As stated previously, DOE developed household
samples from the 2018 Commercial Buildings Energy Consumption Survey
(``CBECS 2018'').\44\ For each sample, DOE determined the energy
consumption for the walk-ins and the appropriate energy price. By
developing a representative sample of commercial consumers, the
analysis captured the variability in energy consumption and energy
prices associated with the use of walk-ins.
---------------------------------------------------------------------------
\44\ U.S. Energy Information Administration. Commercial
Buildings Energy Consumption Survey 2018, 2022.
---------------------------------------------------------------------------
Inputs to the calculation of total installed cost include the cost
of the product--which includes MPCs, manufacturer markups, retailer and
distributor markups, and sales taxes--and installation costs. Inputs to
the calculation of operating expenses include annual energy
consumption, energy prices and price projections, repair and
maintenance costs, product lifetimes, and discount rates. DOE created
distributions of values for product lifetime, discount rates, and sales
taxes, with probabilities attached to each value, to account for their
uncertainty and variability.
The computer model DOE uses to calculate the LCC relies on a Monte
Carlo simulation to incorporate uncertainty and variability into the
analysis. The Monte Carlo simulations randomly sample input values from
the probability distributions and walk-ins user samples. The model
calculated the LCC for products at each efficiency level per simulation
run. The analytical results include a distribution of 30,000 data
points for refrigeration systems and 10,000 data points for envelope
components, showing the range of LCC savings for a given efficiency
level relative to the no-new-standards case efficiency distribution. In
performing an iteration of the Monte Carlo simulation
[[Page 60791]]
for a given consumer, product efficiency is chosen based on its
probability. If the chosen product efficiency is greater than or equal
to the efficiency of the standard level under consideration, the LCC
calculation reveals that a consumer is not impacted by the standard
level. By accounting for consumers who already purchase more-efficient
products, DOE avoids overstating the potential benefits from increasing
product efficiency.
DOE calculated the LCC and PBP for consumers of walk-ins as if each
were to purchase a new product in the expected year of required
compliance with new or amended standards. Amended standards would apply
to walk-ins manufactured three years after the date on which any new or
amended standard is published. (42 U.S.C. 6313(f)(5)(B)(i)) At this
time, DOE estimates publication of a final rule in 2024; therefore, for
purposes of its analysis, DOE used 2027 as the first year of compliance
with any amended standards for walk-ins.
Table IV.34 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations. The subsections that follow
provide further discussion. Details of the spreadsheet model, and of
all the inputs to the LCC and PBP analyses, are contained in chapter 8
of the NOPR TSD and its appendices.
Table IV.34--Summary of Inputs and Methods for the LCC and PBP Analysis
*
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Product Cost................. Derived by multiplying MPCs by
manufacturer and retailer markups and
sales tax, as appropriate. Used
historical data to derive a price
scaling index to project product costs.
Installation Costs........... Baseline installation cost determined
with data from RS Means. Assumed no
change with efficiency level.
Annual Energy Use............ The total annual energy use multiplied by
the buildings containing WICF.
Variability: Based on the CBECS 2018.
Energy Prices................ Electricity: Based on EIA's Form 861 data
for 2021.
Variability: Regional energy prices
determined for 9 divisions.
Energy Price Trends.......... Based on AEO2023 price projections.
Repair and Maintenance Costs. Assumed no change with efficiency level.
Product Lifetime............. Average: between 9 and 12 years.
Discount Rates............... Approach involves identifying all
possible debt or asset classes that
might be used to purchase the considered
appliances, or might be affected
indirectly. Primary data source was the
Federal Reserve Board's Survey of
Consumer Finances.
Compliance Date.............. 2027.
------------------------------------------------------------------------
* Not used for PBP calculation. References for the data sources
mentioned in this table are provided in the sections following the
table or in chapter 8 of the NOPR TSD.
1. Equipment Cost
To calculate consumer product costs, DOE multiplied the MSPs
developed in the engineering analysis by the markups described
previously (along with sales taxes). DOE used different markups for
baseline products and higher-efficiency equipment because DOE applies
an incremental markup to the increase in MSP associated with higher-
efficiency products.
DOE examined historical producer price index (``PPI'') data for
commercial refrigerators and related equipment manufacturing available
between 1978 and 2021 from the BLS.\45\ Even though this PPI series may
also contain prices of refrigeration equipment other than walk-ins,
this is the most disaggregated price series that are representative of
walk-ins. DOE assumes that this PPI is a close proxy to historical
price trends for walk-ins. The PPI data reflect nominal prices,
adjusted for product quality changes. The inflation-adjusted (deflated)
price index for commercial refrigerators and related equipment
manufacturing was calculated by dividing the PPI series by the Gross
Domestic Product Chained Price Index.
---------------------------------------------------------------------------
\45\ Product series ID: PCU3334153334153. Available at:
www.bls.gov/ppi/.
---------------------------------------------------------------------------
DOE has observed a spike in the trend of annual real prices between
2021 and 2022. However, when the PPI is examined at a month-by-month
level, the nominal PPI from 2022 through 2023 appears to be leveling
off. Specifically, the monthly PPI data in Table IV.35 shows the
Observation Value increasing from a value of 339 in January 2022 to a
value of 375 through July 2022; thereafter the Observed Value increases
slightly to 378 in February 2023 (emphasis added). As of the
publication of this NOPR, the Gross Domestic Product Chained Price
Index was not available for 2023; therefore, DOE was unable to include
data for the year 2023 in this NOPR. These data will be monitored by
DOE. If a trend in the data appears prior to publication of the final
rule, DOE will apply it. Additionally, the engineering analysis was
conducted in 2022 and captures this increase in terms of walk-in
equipment prices. DOE notes that it has captured the impact of this
spike, if it were realized, as a constant increase in real prices in
the low economic price scenario results shown in section V.C.
Table IV.35--Excerpt From PPI Industry Data for Air-Conditioning, Refrigeration, and Forced Air Heating
Equipment Mfg-Refrigeration Condensing Units, All Refrigerants, Except Ammonia (Complete), Not Seasonally
Adjusted
[ID PCU3334153334155]
----------------------------------------------------------------------------------------------------------------
Observation
Year Period Label value
----------------------------------------------------------------------------------------------------------------
2022.......................................... M01 2022 Jan........................ 339
2022.......................................... M02 2022 Feb........................ 339
2022.......................................... M03 2022 Mar........................ 348
[[Page 60792]]
2022.......................................... M04 2022 Apr........................ 356
2022.......................................... M05 2022 May........................ 356
2022.......................................... M06 2022 Jun........................ 366
2022.......................................... M07 2022 Jul........................ 375
2022.......................................... M08 2022 Aug........................ 375
2022.......................................... M09 2022 Sep........................ 376
2022.......................................... M10 2022 Oct........................ 375
2022.......................................... M11 2022 Nov........................ 376
2022.......................................... M12 2022 Dec........................ 376
2023.......................................... M01 2023 Jan........................ 377
2023.......................................... M02 2023 Feb........................ 378
----------------------------------------------------------------------------------------------------------------
DOE received no comments on its future price trend methodology in
the June 2022 Preliminary Analysis. For this analysis, DOE maintained
the same approach for determining future equipment prices as in the
June 2022 Preliminary Analysis and assumed that equipment prices would
be constant over time in terms of real dollars, i.e., constant 2022
prices.
2. Consumer Sample
DOE conducts its analysis in support of a potential new minimum
efficiency standard at the National level. This means that DOE must
distribute its sample of consumers of walk-in equipment throughout the
Nation to capture variability of key inputs of walk-ins operation.
Specifically, for the annual energy use estimate, DOE is concerned
about distributing the population of walk-in installations across
different regions to capture variability in equipment installation
saturations and electricity prices, which will impact the operating
cost of the equipment. This distribution of installations is referred
to as the ``consumer sample.'' For this analysis DOE used data supplied
by AHRI and CBECS to estimate the number of walk-in installations by
sector and Census Division. The weights of each representative unit by
sector are shown in Table IV.36 through Table IV.38.\46\ These weights
show that dedicated condensing systems are evenly spread across all
sectors, with small business sectors limited to smaller capacity
equipment, additionally, single-packaged dedicated condensing systems
are limited to the small business sectors and concentrated in the food
service sector.
---------------------------------------------------------------------------
\46\ A full breakdown of the consumer sample showing the
distribution of equipment by Census Division can be found in
appendix 8E of the Technical Support Document.
---------------------------------------------------------------------------
In response to the June 2022 Preliminary Analysis, Lennox requested
more detail on the ``Large Other'' sector distribution versus other
sectors, especially when compared to the food service sector, which has
a much lower sector distribution in the TSD.
The other categories, both small and large, are used by CBECS as a
catchall for buildings with primary building activities that are not
defined within specific categories. In this analysis, DOE defines a
small business as one of less than 3000 ft\2\ of floorspace, and a
large business as one greater than 3000 ft\2\ floorspace. When
examining CBECS for buildings containing walk-in coolers and freezers
(RFGWIN6), DOE found the count of walk-in installations in the other
category to be substantial, leading DOE to conclude that these are
installed in grocery sections of ``big box'' retail properties, which
do not have a category in CBECS.
HTPG disagreed with DOE's selection of unit capacity values for the
respective equipment classes in Table 8.2.1 and Table 8.2.2 of the June
2022 Preliminary Analysis TSD, stating that the range of values is too
narrow and does not provide a valid representation of the distribution
of WICF into the various sectors. (HTPG, No. 35 at p. 7) HTPG also
disagreed with DOE's weighting values reflected in the table for large
and small food sales, food service and other sectors for the range of
unit capacities selected, commenting that the smaller capacity units
would dominate the small sectors with a very low weighting in the large
sectors; however, HTPG stated that DOE's data reflects just the
opposite distribution. HTPG commented that properly understanding the
distribution requires viewing the entire product line with a set of
broader capacity ranges in the various sectors. (Id.)
As discussed above, and shown in Table IV.36 through Table IV.38,
DOE has estimated the installation of walk-in coolers and freezers
across several business categories and sizes, and has tried to
concentrate the installation of smaller capacity walk-ins into small-
sized business. The large weight of walk-ins attributed to large other
is a result of the large quantity of walk-in installations found in
CBECS. Further, for this NOPR, DOE has increased the number of
representative capacities within each equipment class to better reflect
the size of the equipment distributed in commerce. See section IV.C.1
for a more detailed discussion regarding the selection of analyzed
equipment.
Lennox commented that in section 8.2.1.1, bullet 2a of the June
2022 Preliminary Analysis TSD, DOE explains how the proportion of walk-
in boxes across medium- and low-temperature applications was
determined. Lennox commented that, based on stakeholder input, DOE
assumed that the relative proportion of coolers to freezers is \2/3\ to
\1/3\. (Lennox, No. 36 at pp. 6-7) Lennox further commented, however,
that DOE displays two equations in that section to conclude its number
of coolers and freezes by building type using the same ratio ``\2/3\,''
instead of ``\2/3\'' on one and ``\1/3\'' on the other, which can be
assumed to be the split to achieve 100 percent; Lennox stated that this
looks like a clerical oversight, which DOE should address. (Id.)
Further, the CA IOUs noted that most indoor walk-in dedicated
condensing units are part of single-packaged dedicated systems, and for
the low-temperature, indoor category (778), a total of 1,631 indoor
models, or 11 percent of the 15,008 dedicated
[[Page 60793]]
condensing system listings, exist in CCMS. The CA IOUs stated that, for
comparison, in food service, generally about one third of walk-ins are
freezers while two-thirds of walk-ins are coolers. (CA IOUs, No. 17 at
p. 8)
To clarify, in the June 2022 Preliminary Analysis, DOE used the
ratios of \2/3\ medium-temperature and \1/3\ low-temperature to split
the market of coolers and freezers in its economic analysis. DOE has
maintained this ratio in the NOPR analysis.
Table IV.36--Consumer Sample and Weights--Dedicated Condensing Units
[%]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Sector Capacity (kBtu/hr)
Equipment class ---------------------------------------------------------------------------------------------------------------
Cat. Size 3 9 25 54 75 124
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I.................................. Other...................... Large...................... 23 18 4 10 ....... .......
Small...................... 1 1 0 0 ....... .......
Sales...................... Large...................... 4 3 1 2 ....... .......
Small...................... 3 3 1 0 ....... .......
Service.................... Large...................... 5 4 1 2 ....... .......
Small...................... 7 6 1 0 ....... .......
DC.L.O.................................. Other...................... Large...................... 7 25 7 5 14 .......
Small...................... 0 2 0 0 0 .......
Sales...................... Large...................... 1 4 1 1 2 .......
Small...................... 1 4 1 0 0 .......
Service.................... Large...................... 1 6 1 1 3 .......
Small...................... 2 8 2 0 0 .......
DC.M.I.................................. Other...................... Large...................... * 12 30 7 4 0 .......
Small...................... * 1 2 0 0 0 .......
Sales...................... Large...................... * 2 5 1 1 0 .......
Small...................... * 2 4 1 0 0 .......
Service.................... Large...................... * 3 6 1 1 0 .......
Small...................... * 4 9 2 0 0 .......
DC.M.O.................................. Other...................... Large...................... * 3 30 9 2 6 6
Small...................... * 0 2 1 0 0 0
Sales...................... Large...................... * 1 5 2 0 1 1
Small...................... * 0 4 1 0 0 0
Service.................... Large...................... * 1 7 2 0 1 1
Small...................... * 1 9 3 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
* For this NOPR DOE is not considering the impacts of representative units DC.M.I and DC.M.O at the 3 kBtu/hr capacity (see the Representative Units
subsection of section IV.C.1.d). However, these capacities persist within the consumer sample as they are still distributed in commerce, and the
impacts for the fraction of these equipment must be accounted for when determining overall costs and benefits for DC.M.I and DC.M.O as equipment
classes even if efficiency improvements are not being considered for these specific capacities.
Table IV.37--Consumer Sample and Weights--Single-Packaged Dedicated Systems
[%]
----------------------------------------------------------------------------------------------------------------
Sector Capacity (kBtu/hr)
Equipment class ------------------------------------------------------------------------------
Cat. Size 2 6 7 9
----------------------------------------------------------------------------------------------------------------
SP.H.I........................... Other............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Sales............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Service............. Large.............. 0 ....... 0 .......
Small.............. 74 ....... 26 .......
SP.H.ID.......................... Other............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Sales............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Service............. Large.............. 0 ....... 0 .......
Small.............. 74 ....... 26 .......
SP.H.O........................... Other............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Sales............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Service............. Large.............. 0 ....... 0 .......
Small.............. 22 ....... 78 .......
SP.H.OD.......................... Other............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Sales............... Large.............. 0 ....... 0 .......
Small.............. 0 ....... 0 .......
Service............. Large.............. 0 ....... 0 .......
Small.............. 22 ....... 78 .......
SP.L.I........................... Other............... Large.............. 0 0 ....... .......
Small.............. 9 4 ....... .......
Sales............... Large.............. 0 0 ....... .......
Small.............. 19 9 ....... .......
Service............. Large.............. 0 0 ....... .......
Small.............. 41 18 ....... .......
SP.L.O........................... Other............... Large.............. 0 0 ....... .......
Small.............. 3 9 ....... .......
Sales............... Large.............. 0 0 ....... .......
Small.............. 7 21 ....... .......
Service............. Large.............. 0 0 ....... .......
[[Page 60794]]
Small.............. 15 45 ....... .......
SP.M.I........................... Other............... Large.............. 0 ....... ....... 0
Small.............. 3 ....... ....... 10
Sales............... Large.............. 0 ....... ....... 0
Small.............. 6 ....... ....... 22
Service............. Large.............. 0 ....... ....... 0
Small.............. 14 ....... ....... 46
SP.M.O........................... Other............... Large.............. 0 ....... ....... 0
Small.............. 1 ....... ....... 12
Sales............... Large.............. 0 ....... ....... 0
Small.............. 2 ....... ....... 26
Service............. Large.............. 0 ....... ....... 0
Small.............. 3 ....... ....... 56
----------------------------------------------------------------------------------------------------------------
Table IV.38--Consumer Sample and Weights--Unit Coolers
[%]
----------------------------------------------------------------------------------------------------------------
Sector Capacity (kBtu/hr)
Equipment class ---------------------------------------------------------------------------------
Cat. Size 3 9 25 54 75
----------------------------------------------------------------------------------------------------------------
UC.H.I *...................... Other............ Large........... ....... 0 0 ....... .......
Small........... ....... 0 0 ....... .......
Sales............ Large........... ....... 0 0 ....... .......
Small........... ....... 0 0 ....... .......
Service.......... Large........... ....... 30 11 ....... .......
Small........... ....... 43 16 ....... .......
UC.H.ID....................... Other............ Large........... ....... 0 0 ....... .......
Small........... ....... 0 0 ....... .......
Sales............ Large........... ....... 0 0 ....... .......
Small........... ....... 0 0 ....... .......
Service.......... Large........... ....... 30 11 ....... .......
Small........... ....... 43 16 ....... .......
UC.L.I........................ Other............ Large........... 18 16 4 14 0
Small........... 1 1 0 1 0
Sales............ Large........... 3 3 1 3 0
Small........... 3 2 1 2 0
Service.......... Large........... 4 3 1 3 0
Small........... 6 5 1 5 0
UC.L.M........................ Other............ Large........... 2 21 28 8 8
Small........... 0 0 0 0 0
Sales............ Large........... 0 4 5 1 1
Small........... 0 0 0 1 1
Service.......... Large........... 0 5 6 2 2
Small........... 1 0 0 2 2
UC.L.O........................ Other............ Large........... 6 22 7 7 10
Small........... 0 1 0 0 1
Sales............ Large........... 1 4 1 1 2
Small........... 1 3 1 1 2
Service.......... Large........... 1 5 2 2 2
Small........... 2 7 2 2 3
UC.M.I........................ Other............ Large........... 10 27 8 7 0
Small........... 1 2 1 0 0
Sales............ Large........... 2 5 1 1 0
Small........... 1 4 1 1 0
Service.......... Large........... 2 6 2 1 0
Small........... 3 9 2 2 0
UC.M.M........................ Other............ Large........... 2 29 19 8 8
Small........... 0 0 0 0 0
Sales............ Large........... 0 5 3 1 1
Small........... 0 0 0 1 1
Service.......... Large........... 0 6 4 2 2
Small........... 1 0 0 2 2
----------------------------------------------------------------------------------------------------------------
* For unit coolers, the index I, O, and M indicate that the unit cooler is connected to an Indoor, Outdoor, or
Multiplex condensing system.
AHRI commented that it maintains that a small fraction of panels
are installed outdoors (AHRI, No. 16 at p. 17) For this analysis, DOE
maintained the approach it used in the June 2022 Preliminary Analysis
and did not consider panels and doors installed outdoors in this NOPR
analysis.
3. Installation Cost
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the product. DOE used data from
RSMeans 2023 \47\ (``RSMeans'') to estimate the baseline installation
cost for walk-in coolers and freezers. The information from RSMeans did
not indicate that installation costs would be impacted
[[Page 60795]]
with increased efficiency levels over the baseline for all the designs
options considered in the engineering analysis (see section IV.C.1). As
such, installation costs were not included in the June 2022 Preliminary
Analysis.
---------------------------------------------------------------------------
\47\ Reed Construction Data, RSMeans Facilities Maintenance &
Repair 2013 Cost Data Book, 2023.
---------------------------------------------------------------------------
AHRI, HTPG, Lennox, and Hussmann-Refrigeration disagreed with DOE's
assumption that installation costs are not a function of efficiency and
stated that characteristics necessary for efficiency gains, like
additional sensors, control systems and technologies, will affect
installation and manufacturing cost of units. (AHRI, No. 39 at p. 4;
HTPG, No. 35 at p. 8; Lennox, No. 36 at p. 8; Hussmann-Refrigeration,
No. 38 at p. 5)
DOE tentatively agrees with concerns from AHRI, HTPG, Lennox, and
Hussmann-Refrigeration that the inclusion of sensors and controls at
increased efficiency levels would increase the cost of equipment
installation (and commissioning) over the baseline. Therefore, in the
standards case, for this analysis DOE is asserting that the cost of
installing will not change with equipment efficiency with the exception
of improvements to controls. As this rulemaking covers walk-in
equipment where each type of equipment is considered a package unto
itself, and any control or sensor improvement would be part of said
package; therefore, there would be no additional costs for control
installation, but there would be additional costs for control
configuration prior to equipment commissioning. For this analysis, DOE
examined RSMeans for the cost of control configuration and added the
following installation costs where equipment has the following design
option (see section IV.C.1 of this document). RSMeans shows that the
amount of time to configure most controls is half-hour of labor, while
for variable-capacity HVAC drives--used as a proxy for variable-
capacity refrigeration compressors--the amount of labor is two hours.
DOE assumed the average nonunion shop rate to be $154 (2022$) per
hour.\48\ In instances where multiple improvements were applied to a
single equipment sub-system, (e.g., crank case heating controls: CCHC1
and CCHC2), DOE only included a single control configuration cost. DOE
did not find any evidence that control configuration scales with
equipment capacity and did not include any additional control
configuration costs related to equipment costs.
---------------------------------------------------------------------------
\48\ See: series: 230953103620 and 230953103680.
Table IV.39--Example Installation Costs by Design Option for Low-Temperature Dedicated Condensing Systems
----------------------------------------------------------------------------------------------------------------
Additional Total
Equipment class kBtu/hr EL Design option installation installed cost
cost ($) ($)
----------------------------------------------------------------------------------------------------------------
DC.L.I.............................. 3 0 Baseline.............. 0 0
1 EC.................... 77 77
2 CMPVS................. 308 385
9 0 Baseline.............. 0 0
1 CMPVS................. 308 308
25 0 Baseline.............. 0 0
1 CD2................... 0 0
2 EC.................... 77 77
3 CMPVS................. 308 385
54 0 Baseline.............. 0 0
1 CD2................... 0 0
2 CMPVS................. 308 308
DC.L.O.............................. 3 0 Baseline.............. 0 0
1 CCHC1................. 77 77
2 CCHC2................. 0 77
3 CMPVS................. 308 385
9 0 Baseline.............. 0 0
1 CCHC1................. 77 77
2 CCHC2................. 0 77
3 VSCF.................. 77 154
4 ASC................... 0 154
5 CMPVS................. 308 462
25 0 Baseline.............. 0 0
1 CCHC1................. 77 77
2 CCHC2................. 0 77
3 CCF................... 0 77
4 EC.................... 77 154
5 VSCF.................. 0 154
6 CD2................... 0 154
7 ASC................... 0 154
8 CMPVS................. 308 462
54 0 Baseline.............. 0 0
1 CCHC1................. 77 77
2 CCHC2................. 0 77
3 VSCF.................. 77 154
4 ASC................... 0 154
5 CMPVS................. 308 462
75 0 Baseline.............. 0 0
1 CCHC1................. 77 77
2 CCHC2................. 0 77
3 VSCF.................. 77 154
[[Page 60796]]
4 ASC................... 0 154
5 CMPVS................. 308 462
----------------------------------------------------------------------------------------------------------------
Additionally, HTPG commented that structures may be required to
mount products, and increased piping sizes to reduce pressure drop and
additional control wiring may be necessary for higher efficiency
products, which will increase cost. (HTPG, No. 35 at p. 8) Lennox
commented that increase in the product physical size is due to larger
heat exchangers and larger equipment could require more costly building
structure support as well as increased rigging costs. (Lennox, No. 36
at p. 8)
Neither HTPG nor Lennox provided data or information on the rate at
which installation would require new structures or showing that more
efficient equipment would require more costly building structures or
rigging costs, or any other details to support their claims. In this
analysis, DOE is not considering a purchasing shift to larger
capacities (see section IV.G of this document) but is considering like-
for-like capacity installations between the no-new standards and
standards cases. As such, DOE did not include any further installation
costs for refrigeration systems.
Brooks stated that per 2021ICC (IBC) section 2603.4.1.2 and
2603.4.1.3, cooler and freezer walls--if up to a maximum of 10 inches
thick--must have a covering of steel (0.4 mm) or aluminum (0.8mm) and
be protected by an automatic sprinkler system.\49\ (Brooks, No. 34 at
p. 2) Brooks further stated that for installations less than 4 inches
thick and WICF less than 400 ft\2\ in non-sprinklered buildings, the
foam must have a metal facing of aluminum (0.81mm) or non-corrosive
steel (0.41mm). (Id.)
---------------------------------------------------------------------------
\49\ International Codes Council, International Building Codes,
2018, codes.iccsafe.org/content/IBC2018P6/chapter-26-plastic#IBC2018P6_Ch26_Sec2603.4.1.2 (Last accessed: March 6, 2023).
---------------------------------------------------------------------------
DOE recognizes the fire code requirements indicated by Brooks and
has added $0.50 per ft\2\ of installation cost for panels with greater
than 4 inches of insulation thickness to cover the cost of facing the
panel with non-corrosive steel.
4. Annual Energy Consumption
For each consumer from the consumer sample (see section IV.F.2 of
this document), DOE determined the energy consumption for walk-ins of
the different efficiency levels determined in the engineering analysis
(see section IV.C.1 of this document) for each TSL (see section IV.E.1
of this document) using the approach described previously in section
IV.E of this document.
5. Energy Prices
Because marginal electricity price more accurately captures the
incremental savings associated with a change in energy use from higher
efficiency, it provides a better representation of incremental change
in consumer costs than average electricity prices. Therefore, DOE
applied average electricity prices for the energy use of the product
purchased in the no-new-standards case, and marginal electricity prices
for the incremental change in energy use associated with the other
efficiency levels considered.
DOE derived electricity prices in 2022 using data from Edison
Electric Institute's Typical Bills and Average Rates
reports.50 51 Based upon comprehensive, industry-wide
surveys, this semi-annual report presents typical monthly electric
bills and average kilowatt-hour costs to the customer as charged by
investor-owned utilities. For the commercial sector, DOE calculated
electricity prices using the methodology described in Coughlin and
Beraki (2019).\52\
---------------------------------------------------------------------------
\50\ Edison Electric Institute, Typical Bills and Average
Rates--Summer 2022, December 2022, ISBN: 978-1-938066-04-7.
\51\ Edison Electric Institute, Typical Bills and Average
Rates--Winter 2022, June 2022, ISBN: 978-0-931032-88-2.
\52\ Coughlin, K. and B. Beraki. 2019. Non-residential
Electricity Prices: A Review of Data Sources and Estimation Methods.
Lawrence Berkeley National Lab. Berkeley, CA. Report No. LBNL-
2001203. ees.lbl.gov/publications/non-residential-electricity-prices.
---------------------------------------------------------------------------
For this NOPR DOE maintained the methodology it used in the July
2021 Preliminary Analysis where electricity prices to vary by sector
and region. In the analysis, variability in electricity prices is
chosen to be consistent with the way the consumer economic and energy
use characteristics are defined in the LCC analysis for walk-ins. DOE
derived average and marginal annual non-residential (commercial and
industrial) electricity prices using data from EIA's Form EIA-861
database (based on ``Annual Electric Power Industry Report''),\53\
Edison Electric Institute's Typical Bills and Average Rates Reports,
and information from utility tariffs. Electricity tariffs for non-
residential consumers can be very complex, with the principal
difference from residential rates being the incorporation of demand
charges. The presence of demand charges means that two consumers with
the same monthly electricity consumption may have very different bills,
depending on their peak demand. For this analysis, DOE used marginal
electricity prices to estimate the impact of demand charges for
consumers of walk-ins and EIA's Annual Energy Outlook 2023
(``AEO2023'') to estimate future energy prices (see section IV.F.5.a of
this document). DOE developed discount rates from estimates of the
finance cost for consumers and commercial businesses that purchase
walk-ins. More detail on the methodology of use to calculate the
marginal electricity rates can be found in appendix 8B of the NOPR TSD.
---------------------------------------------------------------------------
\53\ Available at: www.eia.doe.gov/cneaf/electricity/page/eia861.html.
[[Page 60797]]
Table IV.40--Marginal and Average Electricity Prices by Census Division and Sector Size
[2022$/kWh]
----------------------------------------------------------------------------------------------------------------
Marginal
Sector Region Average electricity
electricity price
----------------------------------------------------------------------------------------------------------------
Large Food Sales................................................ 1 0.155 0.128
Large Food Service.............................................. 1 0.155 0.128
Large Other..................................................... 1 0.155 0.128
Small Food Sales................................................ 1 0.175 0.156
Small Food Service.............................................. 1 0.175 0.156
Small Other..................................................... 1 0.175 0.156
Large Food Sales................................................ 2 0.091 0.072
Large Food Service.............................................. 2 0.091 0.072
Large Other..................................................... 2 0.091 0.072
Small Food Sales................................................ 2 0.119 0.116
Small Food Service.............................................. 2 0.119 0.116
Small Other..................................................... 2 0.119 0.116
Large Food Sales................................................ 3 0.104 0.084
Large Food Service.............................................. 3 0.104 0.084
Large Other..................................................... 3 0.104 0.084
Small Food Sales................................................ 3 0.129 0.116
Small Food Service.............................................. 3 0.129 0.116
Small Other..................................................... 3 0.129 0.116
Large Food Sales................................................ 4 0.123 0.101
Large Food Service.............................................. 4 0.123 0.101
Large Other..................................................... 4 0.123 0.101
Small Food Sales................................................ 4 0.151 0.140
Small Food Service.............................................. 4 0.151 0.140
Small Other..................................................... 4 0.151 0.140
----------------------------------------------------------------------------------------------------------------
a. Future Electricity Prices
To estimate energy prices in future years in the June 2022
Preliminary Analysis, DOE multiplied the 2021 energy prices by the
projection of annual average price changes for each of the nine census
divisions from the Reference case in AEO 2022, which has an end year of
2050.\54\ To estimate price trends after 2050, DOE assumed constant
real prices at the 2050 rate. In section ES.4.17 of the Executive
Summary of the June 2022 Preliminary Analysis TSD, DOE requested
comment on its assumed average and marginal electricity costs.
---------------------------------------------------------------------------
\54\ EIA. Annual Energy Outlook 2022 with Projections to 2050.
Available at www.eia.gov/forecasts/aeo/ (last accessed February 13,
2023).
---------------------------------------------------------------------------
AHRI disagreed with the analysis that real electricity price will
decrease to 2050 but agrees that average and marginal electricity
prices will increase to 2050. (AHRI, No. 39 at p. 4) Hussmann-
Refrigeration agrees with the views of the other AHRI members on the
matter of electricity costs. (Hussmann-Refrigeration, No. 38 at pp. 4-
5)
HTPG agreed with the costs in Table ES.3.18 of the June 2022
Preliminary Analysis TSD. (HTPG, No. 35 at p. 7) HTPG stated that the
costs seem in line with the electrical cost of $0.1063/kWh stated in
ASHRAE 90.1, but that the trend illustrated in Electricity Price Factor
Projections (Figure 8.3.2), with the cost going down year over year,
does not seem reasonable. HTPG stated that according to the U.S. Energy
Information Administration (EIA), electricity prices have increased 1.8
percent per year in the United States for the past 25 years. HTPG
commented that with the phase out of fossil fuels and the process of
replacing technologies that use fossil fuels (coal, oil, and natural
gas) with technologies that use electricity as a source of energy, the
demand for electricity should go up year over year driving prices up
even further, not down. (Id.)
Lennox stated that DOE's estimate of average and marginal
electricity costs up to year 2050 (using as reference the AEO 2022
projection) appears logical. (Lennox, No. 36 at p. 8)
In response to commenters on DOE's future electricity price trend
from the June 2022 Preliminary Analysis, DOE notes that it uses the
most current price trends developed by EIA for its AEO. For the 2022
publication, future commercial electricity prices were shown to have a
slight decrease, in terms of real dollars, over the time period of 2027
through 2050.\55\ For this NOPR analysis DOE has applied the most
recent AEO (AEO2023) which shows a similar, slight downward trend as in
the 2022 publication.
---------------------------------------------------------------------------
\55\ EIA. Annual Energy Outlook 2023. Available at www.eia.gov/outlooks/aeo/ (last accessed April 17, 2023).
---------------------------------------------------------------------------
6. Maintenance and Repair Costs
Repair costs are associated with repairing or replacing product
components that have failed in an appliance; maintenance costs are
associated with maintaining the operation of the product. Typically,
small incremental increases in product efficiency entail no, or only
minor, changes in repair and maintenance costs compared to baseline
efficiency products.
AHRI, HTPG, Hussmann-Refrigeration, Lennox, and KeepRite disagreed
with DOE's assumption that repair and maintenance costs are not a
function of efficiency and stated that the various technologies to make
the unit more efficient will affect these costs. (AHRI, No. 39 at p. 4;
HTPG, No. 35 at p. 7; Hussmann-Refrigeration, No. 38 at p. 4; KeepRite,
No. 41 at p. 3)
For this analysis, DOE has revised its maintenance and repair cost
assumptions. DOE notes that the quantity of walk-in refrigeration
equipment sold above the current standard is very small. This has
resulted in an absence of repair or maintenance data from which DOE can
determine an informed methodology. In the absence of such data, DOE has
made the simple modeling assumption consumers would pay an additional
10 percent per year of equipment MSP in the standards and no-new-
standards cases for each maintenance and repair.
[[Page 60798]]
Lennox stated that hot gas defrost requires additional piping,
which will also increase maintenance and repair costs. Lennox stated
that it understands DOE has screened out this technology from this
analysis but these costs must be considered if hot gas is considered.
(Lennox, No. 36 at p. 6) DOE is not considering the cost or benefits of
adaptive defrost technologies, such as hot gas defrost, in this
analysis.
DOE requests any comment, data, and sources of information for the
maintenance and repair costs of walk-in coolers and freezers with the
technologies described in IV.C.
7. Equipment Lifetimes
For walk-ins, DOE used lifetime estimates from the June 2022
Preliminary Analysis.
Because the basis for the lifetime estimates in the literature for
walk-in equipment is uncertain, DOE used distributions to estimate the
lifetimes of walk-in systems and envelope components in the field. The
resulting survival function, which DOE assumed has the form of a
cumulative Weibull distribution, provides an average and median
appliance lifetime. DOE used different Weibull distributions to
estimate the lifetimes for similar equipment types. In the July 2021
RFI, DOE presented the following list of the average of the lifetime
distributions of WICF equipment used in this analysis, shown in Table
IV.41. 86 FR 37687, 37702.
Additionally, DOE maintained its modeling assumption of a minimum
service lifetime of 2 years for all equipment classes. This reflects
the fact that many units are purchased with a warranty that effectively
guarantees that the unit will remain in operation during the warranty
period.
Table IV.41 shows the average and maximum lifetimes for walk-in
envelope components and refrigeration systems.
Table IV.41--Lifetimes for Walk-In Equipment
[Years]
----------------------------------------------------------------------------------------------------------------
WICF equipment lifetimes (years)
-------------------------------------------------
Equipment category Panels and Non-display Refrigeration
display doors doors equipment
----------------------------------------------------------------------------------------------------------------
Average Lifetime.............................................. 12 8.5 10.5
Maximum Lifetime.............................................. 25 12 20
----------------------------------------------------------------------------------------------------------------
For this analysis, DOE maintained the lifetimes from the June 2022
Preliminary Analysis.
8. Discount Rates
The discount rate is the rate at which future expenditures are
discounted to estimate their present value. DOE employs a two-step
approach in calculating discount rates for analyzing customer economic
impacts (e.g., LCC). The first step is to assume that the actual cost
of capital approximates the appropriate customer discount rate. The
second step is to use the capital asset pricing model (``CAPM'') to
calculate the equity capital component of the customer discount rate.
For this NOPR, DOE estimated a statistical distribution of commercial
customer discount rates of walk-in consumers, by calculating the cost
of capital for the different types of walk-in owners.
DOE's method views the purchase of a higher efficiency appliance as
an investment that yields a stream of energy cost savings. DOE derived
the discount rates for the LCC analysis by estimating the cost of
capital for companies that purchase walk-ins. For private firms, the
weighted average cost of capital (``WACC'') is commonly used to
estimate the present value of cash flows to be derived from a typical
company project or investment. Most companies use both debt and equity
capital to fund investments, so their cost of capital is the weighted
average of the cost to the firm of equity and debt financing, as
estimated from financial data for publicly traded firms in the sectors
that purchase distribution transformers.\56\ As discount rates can
differ across industries, DOE estimates separate discount rate
distributions for a number of aggregate sectors with which elements of
the LCC building sample can be associated.
---------------------------------------------------------------------------
\56\ Previously, Damodaran Online provided firm-level data, but
now only industry-level data is available, as compiled from
individual firm data, for the period of 1998-2018. The data sets
note the number of firms included in the industry average for each
year.
---------------------------------------------------------------------------
DOE received no comments on its discount rate methodology and
analysis and maintained its approach for this NOPR. See chapter 8 of
the NOPR TSD for further details on the development of consumer
discount rates.
9. Energy Efficiency Distribution in the No-New-Standards Case
To estimate the share of consumers that would be affected by a
potential energy conservation standard at a particular efficiency
level, DOE's LCC analysis considered the projected distribution (market
shares) of product efficiencies under the no-new-standards case (i.e.,
the case without amended or new energy conservation standards).
To estimate the energy efficiency distribution of walk-ins for
2027, DOE used information provided from stakeholder in response to the
June 2022 Preliminary Analysis and records from DOE's CCMS database.
The estimated market shares for the no-new-standards case for walk-in
coolers and freezers panels and doors are shown in Table IV.42. See
chapter 8 of the NOPR TSD for further information on the derivation of
the efficiency distributions.
Lennox stated that it has yet to observe customer demand for higher
efficiency walk-in equipment (dedicated condensing systems, unit
coolers, and single-packaged units) versus equipment meeting the base
walk-ins standard. While there is potential for higher efficiency
product demand, consumers are buying the base walk-in equipment that
meets the minimum standard levels. (Lennox, No. 36 at p. 7)
Regarding refrigeration systems, for this analysis, DOE tentatively
agrees with the statement from Lennox stating that while more efficient
equipment designs are possible to manufacture, there is little market
for them. For refrigeration systems, DOE has made the modeling
assumption that all walk-in coolers and freezers refrigeration systems
would be at baseline in the no-new-standards case. However, for non-
display doors and panels, DOE did apply the rates of more efficient
designs found in DOE's CCMS database.\57\ DOE related the fraction of
designs in the
[[Page 60799]]
CCMS database to the different panel and non-display doors efficiency
levels based on the percentage reduction in daily energy consumption
(kWh/day). (see sections IV.C.1.b and IV.C.1.c of this document).
---------------------------------------------------------------------------
\57\ U. S. Department of Energy. Compliance Certification
Database. 2023. https://www.regulations.doe.gov/certification-data/
(Last accessed: February 1, 2023).
---------------------------------------------------------------------------
DOE acknowledges that its application of the equipment information
available in CCMS is not consistent over the different equipment types
covered in this analysis; however, DOE has found that the resulting
distribution of efficiencies for envelope components and refrigeration
systems is a close reflection of the overall sales of efficient
equipment disclosed to DOE during confidential manufacturer interviews.
Table IV.42--Distribution of Efficiencies in the No-New Standards Case for Panel and Non-Display Doors by
Efficiency Level
----------------------------------------------------------------------------------------------------------------
Equipment class
Efficiency level ----------------------------------------------------------------------------
NM.L NM.M NO.L NO.M PF.L PS.L PS.M
----------------------------------------------------------------------------------------------------------------
0.................................. 0.48 0.20 0.85 0.12 0.34 0.64 0.49
1.................................. 0.14 0.18 0.07 0.08 0.48 0.25 0.30
2.................................. 0.17 0.53 0.08 0.71 0.13 0.11 0.21
3.................................. 0.17 0.09 0.00 0.09 0.06 0.00 0.00
4.................................. 0.04 0.00 0.00 0.00 ......... ......... .........
5.................................. 0.00 0.00 0.00 0.00 ......... ......... .........
6.................................. 0.00 0.00 0.00 0.00 ......... ......... .........
----------------------------------------------------------------------------------------------------------------
The LCC Monte Carlo simulations draw from the efficiency
distributions and randomly assign an efficiency to the walk-in coolers
and freezers purchased by each sample consumer in the no-new-standards
case. The resulting percent shares within the sample match the market
shares in the efficiency distributions.
10. Payback Period Analysis
The payback period (``PBP'') is the amount of time (expressed in
years) it takes the consumer to recover the additional installed cost
of more-efficient products, compared to baseline products, through
energy cost savings. PBPs that exceed the life of the product mean that
the increased total installed cost is not recovered in reduced
operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the product and the change in the
first-year annual operating expenditures relative to the baseline. DOE
refers to this as a ``simple PBP'' because it does not consider changes
over time in operating cost savings. The PBP calculation uses the same
inputs as the LCC analysis when deriving first-year operating costs.
As noted previously, EPCA establishes a rebuttable presumption that
a standard is economically justified if the Secretary finds that the
additional cost to the consumer will be less than three times the value
of the first year's energy savings resulting from the standard, as
calculated under the applicable test procedure, when purchasing a
product in compliance with an energy conservation standard level. (42
U.S.C. 6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determined the value of the first year's energy savings by calculating
the energy savings in accordance with the applicable DOE test procedure
and multiplying those savings by the average energy price projection
for the year in which compliance with the amended standards would be
required.
G. Shipments Analysis
DOE uses projections of annual product shipments to calculate the
national impacts of potential amended or new energy conservation
standards on energy use, NPV, and future manufacturer cash flows.\58\
The shipments model takes an accounting approach, tracking market
shares of each equipment class and the vintage of units in the stock.
Stock accounting uses product shipments as inputs to estimate the age
distribution of in-service product stocks for all years. The age
distribution of in-service product stocks is a key input to
calculations of both the NES and NPV, because operating costs for any
year depend on the age distribution of the stock.
---------------------------------------------------------------------------
\58\ DOE uses data on manufacturer shipments as a proxy for
national sales, as aggregate data on sales are lacking. In general,
one would expect a close correspondence between shipments and sales.
---------------------------------------------------------------------------
To calculate projected shipments of each equipment type, DOE uses a
two-step approach. In the first step, the annual shipments of completed
walk-in installations (hereafter referred to as ``boxes'') of all types
are calculated using a stock model, whose principal inputs are
commercial floor space projections and the average lifetime of a walk-
in box. In the second step, the various types of refrigeration systems
and envelopes are partitioned over the shipments of the entire market
for boxes.
DOE modeled the shipments of walk-in boxes to three commercial
building sectors: food sales, food service and other. Projections of
the growth in floor space for each of these sectors are taken from the
Annual Energy Outlook 2023 (AEO2023) \59\ Reference case. To estimate
the lifetime of walk-in boxes, DOE used the distribution from the LCC
(see chapter 8 of the June 2022 Preliminary Analysis TSD).
---------------------------------------------------------------------------
\59\ U.S. Energy Information Administration. Annual Energy
Outlook 2023.
---------------------------------------------------------------------------
Shipments of walk-in coolers and freezers are driven by new
purchases and stock replacements due to failures. In each year, the
model calculates total stock by vintage and then estimates the number
of units that will fail. The number of units that fail determines the
replacement shipments in that year. Shipments to new installations are
determined by the market saturation (number of boxes per square foot)
multiplied by the new floor space constructed in that year. As walk-in
boxes have been in use for several decades, DOE assumed that market
saturations are constant.
AHRI commented that it has seen a shift in volume estimates towards
larger equipment for WICFs but cannot provide justification as to why
and need more time to review. (AHRI, No. 39 at p. 4) Hussmann-
Refrigeration commented that it supports AHRI's comment (Hussmann-
Refrigeration, No. 38 at p. 4)
DOE notes that the comments from AHRI and Hussmann-Refrigeration
regarding a growth trend in the overall capacity of walk-in
refrigeration equipment is of interest and could be incorporated into
its shipments and downstream analysis, provided that specific details
can be determined. DOE would need to know if this shift in capacity
toward larger equipment affects
[[Page 60800]]
all refrigeration systems (i.e., dedicated condensing systems, unit
coolers, or single-packaged condensing systems) and all applications
and temperature classes (i.e., indoor/outdoor or low-, medium- or high-
temperature equipment). Additionally, DOE would need information as to
whether this trend toward higher capacity equipment will come at the
expense of small capacity equipment and, if so, which capacities
specifically. If DOE were to apply a capacity growth trend to its
existing analysis with the information provided by AHRI, without
further details, it could result in an overstatement of benefits as
larger capacity equipment are showing greater potential benefits.
For this analysis, DOE continued to maintain the constant market
shares for refrigeration equipment as presented in the June 2022
Preliminary Analysis.
DOE requests information or data to characterize a shift toward
larger capacity equipment in its analysis. DOE seeks information about
the represented units, customer types (food service, food sales,
other), and business sizes effected.
Additionally, AHRI, Hussmann-Refrigeration, and HTPG commented that
DOE's initial shipments estimates were overstated. (Hussmann-
Refrigeration, No. 38 at p. 5; HTPG, No. 35 at p. 8; AHRI, No. 39 at p.
5)
AHRI, Hussmann-Refrigeration, and HTPG did not specify which
shipment they found to be overstated. However, DOE notes that in the
July 2022 public meeting (EERE-2017-BT-STD-0009-0026), it had
mislabeled the metric of shipments for refrigeration systems on slide
number 35 as the number of physical units shipped, and that in fact it
should have been labeled capacity shipped in kBtu/hr; DOE notes this
may be the cause of the appearance of inflated shipments. DOE's initial
shipment estimates are shown in section IV.G.2 of this document.
1. Price Elasticity
Economic theory suggests that changes in the price of walk-in
components resulting from this standard could potentially affect the
number of shipments due to the price elasticity of demand. This might
take the form of either a decrease in shipments in cases where purchase
costs increase or an increase in shipments in cases where life-cycle
costs decrease. But this general economic theory applies differently in
different contexts and, based on the information available to DOE,
indicates that shipments will not be meaningfully affected by the
proposed rule.
Lennox commented on DOE's assumption that a decrease in shipments
would be unlikely in the walk-in market due to potential new standards.
(Lennox, No. 36 at p. 8) Lennox supported DOE's modeling assumption
that future shipments would either not be affected, or would only be
marginally affected, by new standards as long as the standards were
``reasonable'' and cost-justified by consumers. (Id.) However, DOE
notes that Lennox did not specifically quantify what a ``reasonable''
and cost-justified level would be. The levels proposed in this analysis
show positive economic benefits for consumers (see section V.B.1.a for
LCC results) and the Nation as whole.
For this analysis, DOE continues to use the assumption in the June
2022 Preliminary Analysis that a decrease in shipments is unlikely in
the walk-in market. In addition, DOE observes that changes in
purchasing behavior are unlikely due to the essential nature of the
equipment and the lack of available substitutes. Moreover, the
substantial savings to consumers over the lifetime of the equipment is
expected to positively affect consumer purchasing incentives. Based on
these considerations, and the lack of contradictory information, DOE
continues to assume that the shipments do not change between the base
case and standards case.
2. Shipments Results
Table IV.43--Projected Shipments of WICF Boxes for Select Years
[2027-2056]
----------------------------------------------------------------------------------------------------------------
Year Food sales Food service Other Total
----------------------------------------------------------------------------------------------------------------
2027............................................ 24,488 34,423 91,740 150,652
2031............................................ 24,867 35,339 94,367 154,573
2035............................................ 25,865 37,502 99,254 162,621
2039............................................ 26,528 39,052 103,269 168,850
2043............................................ 27,402 41,017 108,051 176,470
2047............................................ 28,071 42,559 112,600 183,229
2051............................................ 28,749 44,072 116,556 189,378
2056............................................ 28,881 44,367 117,358 190,605
----------------------------------------------------------------------------------------------------------------
H. National Impact Analysis
The NIA assesses the NES and the NPV from a national perspective of
total consumer costs and savings that would be expected to result from
new or amended standards at specific efficiency levels.\60\
(``Consumer'' in this context refers to consumers of the product being
regulated.) DOE calculates the NES and NPV for the potential standard
levels considered based on projections of annual product shipments,
along with the annual energy consumption and total installed cost data
from the energy use and LCC analyses. For the present analysis, DOE
projected the energy savings, operating cost savings, product costs,
and NPV of consumer benefits over the lifetime of walk-ins sold from
2027 through 2056.
---------------------------------------------------------------------------
\60\ The NIA accounts for impacts in the 50 states and U.S.
territories.
---------------------------------------------------------------------------
DOE evaluates the impacts of new or amended standards by comparing
a case without such standards with standards-case projections. The no-
new-standards case characterizes energy use and consumer costs for each
equipment class in the absence of new or amended energy conservation
standards. For this projection, DOE considers historical trends in
efficiency and various forces that are likely to affect the mix of
efficiencies over time. DOE compares the no-new-standards case with
projections characterizing the market for each equipment class if DOE
adopted new or amended standards at specific energy efficiency levels
(i.e., the TSLs or standards cases) for that class. For the standards
cases, DOE considers how a given standard would likely affect the
market shares of products with efficiencies greater than the standard.
DOE uses a model to calculate the energy savings and the national
consumer costs and savings from each TSL. The NIA spreadsheet model
uses typical values (as opposed to probability distributions) as
inputs.
[[Page 60801]]
Table IV.44 summarizes the inputs and methods DOE used for the NIA
analysis for the NOPR. Discussion of these inputs and methods follows
the table. See chapter 10 of the NOPR TSD for further details.
Table IV.44--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments.................... Annual shipments from shipments model.
Compliance Date of Standard.. 2027.
Efficiency Trends............ Constant.
Annual Energy Consumption per Annual weighted-average values are a
Unit. function of energy use at each TSL.
Total Installed Cost per Unit Annual weighted-average values are a
function of cost at each TSL.
Incorporates projection of future
product prices based on historical data.
Annual Energy Cost per Unit.. Annual weighted-average values as a
function of the annual energy
consumption per unit and energy prices.
Repair and Maintenance Cost Annual values do not change with
per Unit. efficiency level.
Energy Price Trends.......... AEO2023 projections (to 2050) and
constant thereafter.
Energy Site-to-Primary and A time-series conversion factor based on
FFC Conversion. AEO2023.
Discount Rate................ 3 percent and 7 percent.
Present Year................. 2023.
------------------------------------------------------------------------
1. Product Efficiency Trends
A key component of the NIA is the trend in energy efficiency
projected for the no-new-standards case and each of the standards
cases. Section IV.F.9 of this document describes how DOE developed an
energy efficiency distribution for the no-new-standards case (which
yields a shipment-weighted average efficiency) for each of the
considered equipment classes for the year of anticipated compliance
with an amended or new standard. To project the trend in efficiency
absent amended standards for walk-in coolers and freezers over the
entire shipment's projection period, DOE maintained constant
efficiencies.
DOE used the shipments-weighted energy efficiency distribution for
2027 (the assumed date of compliance with a new standard) as a starting
point. To represent the distribution of walk-in energy efficiencies in
2027, DOE used the same market shares as used in the no-new-standards
case for the life-cycle cost analysis (see section IV.C.1.a). The
approach is further described in chapter 10 of the NOPR TSD.
For the standards cases, DOE used a ``roll-up'' scenario to
establish the shipment-weighted efficiency for the year that standards
are assumed to become effective (2027). In this scenario, the market
shares of products in the no-new-standards case that do not meet the
standard under consideration would ``roll up'' to meet the new standard
level, and the market share of products above the standard would remain
unchanged.
To develop standards case efficiency trends after 2027, DOE assumed
that efficiency would remain constant.
2. National Energy Savings
The NES analysis involves a comparison of national energy
consumption of the considered products between each potential standards
case (``TSL'') and the case with no new or amended energy conservation
standards. DOE calculated the national energy consumption by
multiplying the number of units (stock) of each product (by vintage or
age) by the unit energy consumption (also by vintage). DOE calculated
annual NES based on the difference in national energy consumption for
the no-new-standards case and for each higher efficiency standard case.
DOE estimated energy consumption and savings based on site energy and
converted the electricity consumption and savings to primary energy
(i.e., the energy consumed by power plants to generate site
electricity) using annual conversion factors derived from AEO2023.
Cumulative energy savings are the sum of the NES for each year over the
timeframe of the analysis.
Use of higher-efficiency products is sometimes associated with a
direct rebound effect, which refers to an increase in utilization of
the equipment due to the increase in efficiency. DOE did not find any
data on the rebound effect specific to walk-ins. Further, due to the
nature of the walk-ins used in commercial applications, those using the
equipment would not likely have knowledge of the equipment's efficiency
and would not likely alter their usage behavior based on the
equipment's efficiency. Because of this, DOE has not applied a rebound
effect for this analysis.
In a statement of policy published on August 18, 2011 (``August
2011 Statement of Policy''), in response to the recommendations of a
committee on ``Point-of-Use and Full-Fuel-Cycle Measurement Approaches
to Energy Efficiency Standards'' appointed by the National Academy of
Sciences, DOE announced its intention to use FFC measures of energy use
and greenhouse gas and other emissions in the national impact analyses
and emissions analyses included in future energy conservation standards
rulemakings. 76 FR 51281. After evaluating the approaches discussed in
the August 2011 Statement of Policy, DOE published a statement of
amended policy on August 17, 2012 in which it explained its
determination that EIA's National Energy Modeling System (``NEMS'') is
the most appropriate tool for its FFC analysis and its intention to use
NEMS for that purpose. 77 FR 49701. NEMS is a public domain, multi-
sector, partial equilibrium model of the U.S. energy sector \61\ that
EIA uses to prepare its Annual Energy Outlook. The FFC factors
incorporate losses in production and delivery in the case of natural
gas (including fugitive emissions) and additional energy used to
produce and deliver the various fuels used by power plants. The
approach used for deriving FFC measures of energy use and emissions is
described in appendix 10A of the NOPR TSD.
---------------------------------------------------------------------------
\61\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2009, DOE/EIA-0581(2009), October 2009.
Available at www.eia.gov/forecasts/aeo/index.cfm (last accessed
April 17, 2023).
---------------------------------------------------------------------------
3. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by consumers are (1) total annual installed cost, (2) total
annual operating costs (i.e., energy costs and repair and maintenance
costs), and (3) a discount factor to calculate the present value of
costs and savings. DOE calculates net savings each year as the
difference between the no-new-standards case and each standards case in
terms of total savings in operating costs versus total increases in
installed
[[Page 60802]]
costs. DOE calculates operating cost savings over the lifetime of each
product shipped during the projection period.
As discussed in section IV.F.1 of this document, DOE developed
walk-in price trends based on historical PPI data. DOE applied the same
trends to project prices for each equipment class at each considered
TSL. DOE did not receive comments on its future price trend methodology
as presented in the June 2022 Preliminary Analysis; as such, DOE
maintained constant real prices throughout this analysis. DOE's
projection of product prices is described in appendix 10C of the NOPR
TSD.
To evaluate the effect of uncertainty regarding the price trend
estimates, DOE investigated the impact of different product price
projections on the consumer NPV for the considered TSLs for walk-ins in
addition to the default price trend. DOE considered two product price
sensitivity cases: (1) a high price decline case based on the period
between 2005 and 2021 showing a price increase of 1.29 percent a year,
and (2) a low price decline case based on the period between 1978 and
2004 showing a price decline of 0.56 percent per year. The derivation
of these price trends and the results of these sensitivity cases are
described in appendix 10C of the NOPR TSD.
The energy cost savings are calculated using the estimated energy
savings in each year and the projected price of the appropriate form of
energy. To estimate energy prices in future years, DOE multiplied the
average National energy prices by the projection of annual National-
average commercial energy price changes in the Reference case from
AEO2023, which has an end year of 2050. To estimate price trends after
2050, DOE used constant real prices at 2050 levels. As part of the NIA,
DOE also analyzed scenarios that used inputs from variants of the
AEO2023 Reference case that have lower and higher economic growth.
Those cases have lower and higher energy price trends compared to the
Reference case. NIA results based on these cases are presented in
appendix 10C of the NOPR TSD.
In considering the consumer welfare gained due to the direct
rebound effect, DOE accounted for change in consumer surplus attributed
to additional cooling from the purchase of a more efficient unit.
Overall consumer welfare is generally understood to be enhanced from
rebound. The net consumer impact of the rebound effect is included in
the calculation of operating cost savings in the consumer NPV results.
For walk-ins, DOE found no evidence that a rebound effect occurs and
did not apply a rebound effect for this analysis.
DOE requests comments on its assumption that there is no rebound
effect for walk-in coolers and freezers.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPR, DOE estimated the NPV of consumer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (``OMB'') to Federal agencies on the development of regulatory
analysis.\62\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
---------------------------------------------------------------------------
\62\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis. September 17, 2003. Section E. Available at
www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf. (last accessed February 9, 2023).
---------------------------------------------------------------------------
I. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended energy
conservation standards on consumers, DOE evaluates the impact on
identifiable subgroups of consumers that may be disproportionately
affected by a new or amended national standard. The purpose of a
subgroup analysis is to determine the extent of any such
disproportional impacts. DOE evaluates impacts on particular subgroups
of consumers by analyzing the LCC impacts and PBP for those particular
consumers from alternative standard levels. For this NOPR, DOE analyzed
the impacts of the considered standard levels on the following two
subgroups:
1. High Warm Air-Infiltration Applications
In response to comments discussed in section IV.E.3.b of this
document, DOE is including a subgroup to approximate the impacts for
business where walk-ins are operated in environments with higher warm
air-infiltration. This would have the effect of putting a greater
cooling load on the refrigeration equipment, thus increasing run hours.
For this subgroup DOE has assumed 20 daily run hours for all
refrigeration system equipment.
The results of this analysis can be found in Table V.51, Table
V.52, and Table V.53, which show increased benefits for, in terms of
LCC savings, for all equipment. This is a direct result of the
increased hours of operation.
2. Small Businesses
This analysis used subsets of the CBECS 2018 sample composed of
businesses that are small business in the consumer sample (see section:
IV.F.2 of this document). DOE used the LCC and PBP model to estimate
the impacts of the considered efficiency levels on these subgroups. DOE
used adjusted electricity costs and discount rates to better reflect
these costs experienced by small businesses.
Table IV.45--Electricity Costs for Small Businesses
[2022$/kWh]
----------------------------------------------------------------------------------------------------------------
Sector Region Average Marginal
----------------------------------------------------------------------------------------------------------------
Small Food Sales................................................ 1 0.175 0.156
Small Food Service.............................................. 1 0.175 0.156
Small Other..................................................... 1 0.175 0.156
Small Food Sales................................................ 2 0.119 0.116
Small Food Service.............................................. 2 0.119 0.116
Small Other..................................................... 2 0.119 0.116
Small Food Sales................................................ 3 0.129 0.116
Small Food Service.............................................. 3 0.129 0.116
Small Other..................................................... 3 0.129 0.116
Small Food Sales................................................ 4 0.151 0.14
[[Page 60803]]
Small Food Service.............................................. 4 0.151 0.14
Small Other..................................................... 4 0.151 0.14
----------------------------------------------------------------------------------------------------------------
Table IV.46--Distribution of Discount Rates for Small Businesses
------------------------------------------------------------------------
Discount rate
Sector (%) Weight
------------------------------------------------------------------------
Small Food Sales........................ 0.0649 0.1201
Small Food Sales........................ 0.0743 0.4700
Small Food Sales........................ 0.0838 0.2598
Small Food Sales........................ 0.0933 0.0358
Small Food Sales........................ 0.1067 0.0393
Small Food Sales........................ 0.1176 0.0370
Small Food Sales........................ 0.1205 0.0208
Small Food Sales........................ 0.1425 0.0173
Small Food Service...................... 0.0798 0.0516
Small Food Service...................... 0.0850 0.3690
Small Food Service...................... 0.0944 0.4114
Small Food Service...................... 0.1009 0.0810
Small Food Service...................... 0.1138 0.0440
Small Food Service...................... 0.1215 0.0429
Small Other............................. 0.0433 0.0859
Small Other............................. 0.0567 0.0493
Small Other............................. 0.0637 0.1416
Small Other............................. 0.0714 0.0518
Small Other............................. 0.0854 0.2307
Small Other............................. 0.0945 0.2325
Small Other............................. 0.1048 0.1053
Small Other............................. 0.1154 0.0590
Small Other............................. 0.1237 0.0355
Small Other............................. 0.1311 0.0083
------------------------------------------------------------------------
The results of the small businesses subgroup analysis are shows
increased consumer benefit across most equipment, as shown in Table
V.51, Table V.52, and Table V.53. The increase in benefits is driven by
the higher electricity prices attributed to small businesses customers.
Chapter 11 in the NOPR TSD describes the consumer subgroup
analysis.
DOE requests comments on its subgroups analysis.
J. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate the financial impacts of amended
energy conservation standards on manufacturers of walk-ins and to
estimate the potential impacts of such standards on direct employment
and manufacturing capacity. The MIA has both quantitative and
qualitative aspects and includes analyses of projected industry cash
flows, the INPV, investments in research and development (``R&D'') and
manufacturing capital, and domestic manufacturing employment.
Additionally, the MIA seeks to determine how amended energy
conservation standards might affect manufacturing employment, capacity,
and competition, as well as how standards contribute to overall
regulatory burden. Finally, the MIA serves to identify any
disproportionate impacts on manufacturer subgroups, including small
business manufacturers.
The quantitative part of the MIA primarily relies on the Government
Regulatory Impact Model (``GRIM''), an industry cash flow model with
inputs specific to this rulemaking. The key GRIM inputs include data on
the industry cost structure, unit production costs, product shipments,
manufacturer markups, and investments in R&D and manufacturing capital
required to produce compliant products. The key GRIM outputs are the
INPV, which is the sum of industry annual cash flows over the analysis
period, discounted using the industry-weighted average cost of capital,
and the impact to domestic manufacturing employment. The model uses
standard accounting principles to estimate the impacts of more-
stringent energy conservation standards on a given industry by
comparing changes in INPV and domestic manufacturing employment between
a no-new-standards case and the various standards cases. To capture the
uncertainty relating to manufacturer pricing strategies following
amended standards, the GRIM estimates a range of possible impacts under
different manufacturer markup scenarios.
The qualitative part of the MIA addresses manufacturer
characteristics and market trends. Specifically, the MIA considers such
factors as a potential standard's impact on manufacturing capacity,
competition within the industry, the cumulative impact of other DOE and
non-DOE regulations, and impacts on manufacturer subgroups. The
complete MIA is outlined in chapter 12 of the NOPR TSD.
DOE conducted the MIA for this rulemaking in three phases. In Phase
1 of the MIA, DOE prepared a profile of the walk-in manufacturing
industry based on the market and technology assessment, preliminary
manufacturer interviews, and publicly-available information. This
included a top-down analysis of walk-in door, panel, and refrigeration
system manufacturers that DOE used to derive preliminary financial
inputs for the GRIM (e.g.,
[[Page 60804]]
revenues; materials, labor, overhead, and depreciation expenses;
selling, general, and administrative expenses (``SG&A''); and R&D
expenses). DOE also used public sources of information to further
calibrate its initial characterization of the walk-in manufacturing
industry, including company filings of form 10-K from the SEC,\63\
corporate annual reports, the U.S. Census Bureau's Annual Survey of
Manufactures (ASM),\64\ and reports from Dun & Bradstreet.\65\
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\63\ U.S. Securities and Exchange Commission, Electronic Data
Gathering, Analysis, and Retrieval (EDGAR) system. Available at
www.sec.gov/edgar/search/ (last accessed February 14, 2023).
\64\ U.S. Census Bureau, Annual Survey of Manufactures.
``Summary Statistics for Industry Groups and Industries in the U.S
(2021).'' Available at: www.census.gov/data/tables/time-series/econ/asm/2018-2021-asm.html (Last accessed February 14, 2023).
\65\ The Dun & Bradstreet Hoovers login is available at:
app.dnbhoovers.com (Last accessed February 17, 2023).
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In Phase 2 of the MIA, DOE prepared a framework industry cash flow
analysis to quantify the potential impacts of amended energy
conservation standards. The GRIM uses several factors to determine a
series of annual cash flows starting with the announcement of the
standard and extending over a 30-year period following the compliance
date of the standard. These factors include annual expected revenues,
costs of sales, SG&A and R&D expenses, taxes, and capital expenditures.
In general, energy conservation standards can affect manufacturer cash
flow in three distinct ways: (1) creating a need for increased
investment, (2) raising production costs per unit, and (3) altering
revenue due to higher per-unit prices and changes in sales volumes.
In addition, during Phase 2, DOE developed interview guides to
distribute to manufacturers of walk-ins in order to develop other key
GRIM inputs, including product and capital conversion costs, and to
gather additional information on the anticipated effects of energy
conservation standards on revenues, direct employment, capital assets,
industry competitiveness, and subgroup impacts.
In Phase 3 of the MIA, DOE conducted structured, detailed
interviews with representative manufacturers. During these interviews,
DOE discussed engineering, manufacturing, procurement, and financial
topics to validate assumptions used in the GRIM and to identify key
issues or concerns. See section IV.J.3 of this document for a
description of the key issues raised by manufacturers during the
interviews. As part of Phase 3, DOE also evaluated subgroups of
manufacturers that may be disproportionately impacted by amended
standards or that may not be accurately represented by the average cost
assumptions used to develop the industry cash flow analysis. Such
manufacturer subgroups may include small business manufacturers, low-
volume manufacturers, niche players, and/or manufacturers exhibiting a
cost structure that largely differs from the industry average. DOE
identified one subgroup for a separate impact analysis: small business
manufacturers. The small business subgroup is discussed in section VI.B
of this document, ``Review under the Regulatory Flexibility Act'' and
in chapter 12 of the NOPR TSD.
2. Government Regulatory Impact Model and Key Inputs
DOE uses the GRIM to quantify the changes in cash flow due to new
or amended standards that result in a higher or lower industry value.
The GRIM uses a standard, annual discounted cash flow analysis that
incorporates manufacturer costs, markups, shipments, and industry
financial information as inputs. The GRIM models changes in costs,
distribution of shipments, investments, and manufacturer margins that
could result from an amended energy conservation standard. The GRIM
spreadsheet uses the inputs to arrive at a series of annual cash flows,
beginning in 2023 (the base year of the analysis) and continuing to
2056. DOE calculated INPVs by summing the stream of annual discounted
cash flows during this period. For walk-in door, panel, and
refrigeration system manufacturers, DOE used a real discount rate of
9.4 percent, 10.5 percent, and 10.2 percent, respectively, which was
derived from industry financials and then modified according to
feedback received during manufacturer interviews.
The GRIM calculates cash flows using standard accounting principles
and compares changes in INPV between the no-new-standards case and each
standards case. The difference in INPV between the no-new-standards
case and a standards case represents the financial impact of the new or
amended energy conservation standard on manufacturers. As discussed
previously, DOE developed critical GRIM inputs using a number of
sources, including publicly available data, results of the engineering
analysis, results of the shipments analysis, and information gathered
from industry stakeholders during the course of manufacturer
interviews. The GRIM results are presented in section V.B.2 of this
document. Additional details about the GRIM, the discount rate, and
other financial parameters can be found in chapter 12 of the NOPR TSD.
a. Manufacturer Production Costs
Manufacturing more efficient equipment is typically more expensive
than manufacturing baseline equipment due to the use of more complex
components, which are typically more costly than baseline components.
The changes in the MPCs of covered equipment can affect the revenues,
gross margins, and cash flow of the industry. In this rulemaking, DOE
relies on a design-option approach for doors, panels, dedicated
condensing units, and single-packaged dedicated systems. DOE relies on
both a design-option and an efficiency-level approach for unit coolers,
depending on the equipment class. For a complete description of the
MPCs, see chapter 5 of the NOPR TSD or section IV.C of this document.
b. Shipments Projections
The GRIM estimates manufacturer revenues based on total unit
shipment projections and the distribution of those shipments by
efficiency level. Changes in sales volumes and efficiency mix over time
can significantly affect manufacturer finances. For this analysis, the
GRIM uses the NIA's annual shipment projections derived from the
shipments analysis from 2023 (the base year) to 2056 (the end year of
the analysis period). The shipments model takes an accounting approach,
tracking market shares of each equipment class and the vintage of units
in the stock. Stock accounting uses equipment shipments as inputs to
estimate the age distribution of in-service equipment stocks for all
years.
To calculate projected shipments of each equipment type, DOE uses a
two-step approach. In the first step, the annual shipments of completed
WICF installations (also referred to as ``boxes'') installations of all
types are calculated using a stock model, whose principal inputs are
commercial floor space projections and the average lifetime of a WICF
box. In the second step, the various types of refrigeration systems and
envelopes are partitioned over the shipments of the entire market for
boxes. See chapter 9 of the NOPR TSD for additional details or section
IV.G of this document.
c. Capital and Product Conversion Costs
New or amended energy conservation standards could cause
manufacturers to incur conversion costs to bring their production
facilities and equipment
[[Page 60805]]
designs into compliance. DOE evaluated the level of conversion-related
expenditures that would be needed to comply with each considered
efficiency level in each equipment class. For the MIA, DOE classified
these conversion costs into two major groups: (1) capital conversion
costs; and (2) product conversion costs. Capital conversion costs are
investments in property, plant, and equipment necessary to adapt or
change existing production facilities such that new compliant equipment
designs can be fabricated and assembled. Product conversion costs are
investments in research, development, testing, marketing, and other
non-capitalized costs necessary to make equipment designs comply with
new or amended energy conservation standards.
DOE relied on information derived from manufacturer interviews,
equipment teardown analysis, and the engineering models, as well as
data collected in support of the June 2014 Final Rule, to evaluate the
level of capital and product conversion costs manufacturers would
likely incur at the considered standard levels. In interviews, DOE
asked manufacturers to estimate the capital conversion costs (e.g.,
changes in production processes, equipment, and tooling) to implement
the various design options. The data generated from the equipment
teardown and engineering analyses were used to estimate the capital
investment in equipment, tooling, and conveyor required of OEMs at each
efficiency level, considering such factors as product design, raw
materials, purchased components, and fabrication method. Changes in
equipment, tooling, and conveyer, supplemented by feedback from
confidential manufacturer interviews, were then used to estimate
capital conversion costs. In interviews, DOE also asked manufacturers
to estimate the redesign effort and engineering resources required at
various efficiency levels to quantify the product conversion costs.
Manufacturer data was aggregated to protect confidential information.
For manufacturers of refrigeration systems, DOE also included the
costs associated with appendix C1, as finalized in the May 2023 TP
Final Rule. 88 FR 28780. Using individual model counts from the CCD and
the efficiency distribution assumptions in the shipments analysis, DOE
estimated the industry costs associated with re-rating compliant models
in accordance with appendix C1.
In general, DOE assumes all conversion-related investments occur
between the year of publication of the final rule and the year by which
manufacturers must comply with the new standard. The conversion cost
figures used in the GRIM can be found in section V.B.2 of this
document. For additional information on the estimated capital and
product conversion costs, see chapter 12 of the NOPR TSD.
d. Manufacturer Markup Scenarios
MSPs include direct manufacturing production costs (i.e., labor,
materials, and overhead estimated in DOE's MPCs) and all non-production
costs (i.e., SG&A, R&D, and interest), along with profit. To calculate
the MSPs in the GRIM, DOE applied manufacturer markups to the MPCs
estimated in the engineering analysis for each equipment class and
efficiency level. Modifying these manufacturer markups in the standards
case yields different sets of impacts on manufacturers. For the MIA,
DOE modeled two standards-case scenarios to represent uncertainty
regarding the potential impacts on prices and profitability for
manufacturers following the implementation of amended energy
conservation standards: (1) a preservation of gross margin percentage
scenario; and (2) a preservation of operating profit scenario. These
scenarios lead to different manufacturer markup values that, when
applied to the MPCs, result in varying revenue and cash flow impacts.
Under the preservation of gross margin percentage scenario, DOE
applied an uniform ``gross margin percentage'' markup across all
efficiency levels, which assumes that manufacturers would be able to
maintain the same amount of profit as a percentage of revenues at all
efficiency levels within an equipment class. If manufacturer production
costs increase with efficiency, this scenario implies that the per-unit
dollar profit will increase. DOE assumed a gross margin percentage of
31 percent for display doors, 33 percent for non-display doors, 24
percent for panels, and 26 percent for refrigeration systems.\66\
Manufacturers tend to believe it is optimistic to assume that they
would be able to maintain the same gross margin percentage if their
production costs increase, particularly for minimally efficient
products.
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\66\ The gross margin percentages of 31 percent, 33 percent, 24
percent, and 26 percent are based on manufacturer markups of 1.45,
1.50, 1.32, and 1.35, respectively.
---------------------------------------------------------------------------
In the preservation of operating profit scenario, if the cost of
production goes up under a standards case, manufacturers are generally
required to reduce their manufacturer markups to a level that maintains
base-case operating profit. DOE implemented this scenario in the GRIM
by adjusting the manufacturer markups at each TSL to yield
approximately the same earnings before interest and taxes in the
standards case as in the no-new-standards case in the year after the
expected compliance date of the amended standards. The implicit
assumption behind this scenario is that the industry can only maintain
its operating profit in absolute dollars after the standard takes
effect. Therefore, operating profit in percentage terms is typically
reduced between the no-new-standard case and the standards cases.
A comparison of industry financial impacts under the two markup
scenarios is presented in section V.B.2.a of this document.
3. Manufacturer Interviews
DOE interviewed seven door manufacturers, including OEMs of display
and non-display doors, three panel manufacturers, and four
refrigeration system manufacturers. Some manufacturers interviewed
produced more than one walk-in component. Participants included both
small businesses and large manufacturers with a range of equipment
offerings and market shares.
In interviews, DOE asked manufacturers to describe their major
concerns regarding the potential for more stringent energy conservation
standards for walk-ins. The following section highlights manufacturer
concerns that helped inform the projected potential impacts of an
amended standard on the industry. Manufacturer interviews are conducted
under nondisclosure agreements (``NDAs''), so DOE does not document
these discussions in the same way that it does public comments in the
comment summaries and DOE's responses throughout the rest of this
document.
a. Increasing Insulation Thickness
Manufacturers of non-display doors and panels expressed concern
about the impact of increased insulation thickness on processing time,
capital investment, equipment cost, and company profitability. In
interviews, manufacturers stated that much of the existing production
equipment is designed to produce non-display doors and panels 3.5
inches to 5 inches thick. Panels that are 6 inches thick are less
common in the industry. Manufacturers stated that increasing insulation
thickness to 5 inches or 6 inches would notably extend curing and
processing times, potentially reducing
[[Page 60806]]
manufacturing capacity. To maintain current production levels, some
manufacturers stated that they would need to buy additional fixtures
and presses to offset the added processing time. A standard that
requires 6-inch-thick panels would involve significant additional
investment by most manufacturers. Furthermore, some manufacturers
asserted that the walk-in market is price sensitive and increasing
insulation thickness would add product costs with minimal benefit to
the consumer. Alternatively, absorbing these costs would significantly
reduce profit margins.
b. Reduced Anti-Sweat Heat
In interviews, some door manufacturers expressed concern that more
stringent standards would necessitate reduced anti-sweat heat power,
which could lead to safety hazards in some settings. These
manufacturers stated that doors are typically designed for a range of
ambient conditions because store operating conditions deviate from
humidity levels assumed in standard test conditions. These
manufacturers asserted that lowering the energy use requirements would
increase the risk of condensation, particularly in stores without
adequate climate control or stores located in humid regions.
Manufacturers stated that excessive condensation could lead to water
pooling on the floor, which is a slip hazard.
c. Refrigerant Regulation
Nearly all refrigeration system manufacturers expressed concerns
about their ability to meet more stringent energy conservation
standards and comply with refrigerant regulation limiting the use of
HFC and high-GWP refrigerants. First, manufacturers expressed concern
about the regulatory uncertainty surrounding the transition to low-GWP
refrigerants. Second, manufacturers shared that there is technical
uncertainty about the performance of A2L refrigerants and their impact
on system efficiency. Third, manufacturers stated that transitioning
walk-in refrigeration systems to make use of A2L or A3 refrigerants
requires a significant amount of engineering resources, laboratory
testing time, and capital investment. Some manufacturers also
manufacture other equipment, such as commercial refrigerators,
refrigerator-freezers, and freezers, which are subject to both EPA and
DOE regulations and would potentially require redesign during a similar
timeframe as walk-ins. Nearly all manufacturers expressed concern that
they would have neither the time nor the resources to complete the dual
development necessary to comply with both more stringent DOE energy
conservation standards and EPA regulations over a short duration.
Specifically, manufacturers stated that there could be staffing and
testing bandwidth constraints in the years leading up to EPA and DOE
compliance deadlines. Some manufacturers said they are already
struggling to find more laboratory capacity for evaluation and
analysis, which would be further exacerbated should DOE adopt more
stringent energy conservation standards.
4. Discussion of MIA Comments
In response to the June 2022 Preliminary Analysis, AHRI suggested
that DOE consider the refrigerant transition and other relevant
rulemakings in the regulatory burden evaluation, including the
requirement to change chemicals in articles containing phenol,
isopropylated phosphate (``PIP'') (3:1) and others. (AHRI, No. 39 at p.
6) Additionally, AHRI stated that to make the transition to flammable
refrigerants, manufacturers report capital expenditure estimates of
$0.5 to $1.0 million for small facilities and $2.0 to $4.0 million for
medium and larger facilities and equipment for spark-proof and
explosion-proof equipment and design. (AHRI, No. 39 at p. 5)
DOE analyzes cumulative regulatory burden pursuant to section 13(g)
of appendix A. Pursuant to section 13(g) of appendix A, the Department
will analyze and consider the impact on manufacturers of multiple
product/equipment-specific Federal regulatory actions. Regarding
potential refrigerant regulation, DOE understands that manufacturers of
walk-in refrigeration systems will likely need to transition to
alternative, low-GWP refrigerants to comply with anticipated
refrigeration regulations, such as the December 2022 AIM NOPR, prior to
the expected 2027 compliance date of potential energy conservation
standards. 87 FR 76738. While DOE did not consider the refrigerant
transition costs to be conversion costs, as the change in refrigerant
is independent of DOE actions related to any amended energy
conservation standards, DOE did incorporate the estimated costs
associated with redesigning walk-in refrigeration systems to make use
of flammable refrigerants and upgrading production facilities to
accommodate flammable refrigerants in the GRIM. DOE relied on
manufacturer feedback in confidential interviews, a report prepared for
EPA,\67\ and AHRI's written comments to estimate the industry
refrigerant transition costs. See subsection ``Refrigerants Analyzed''
of section IV.C.1.d of this document for additional discussion on the
analyzed refrigerants in this NOPR and chapter 12 of the NOPR TSD for
additional discussion on cumulative regulatory burden. Regarding
chemical regulations, such as EPA's final rule prohibiting the
processing and distribution of PIP (3:1) and PIP (3:1)-containing
products, DOE did not consider these regulations in its NOPR cumulative
regulatory burden analysis as EPA's final rule is not a walk-in-
specific Federal regulatory action. 86 FR 894.
---------------------------------------------------------------------------
\67\ See pp. 5-113 of the ``Global Non-CO2 Greenhouse
Gas Emission Projections & Marginal Abatement Cost Analysis:
Methodology Documentation'' (2019). www.epa.gov/sites/default/files/2019-09/documents/nonco2_methodology_report.pdf.
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In response to the June 2022 Preliminary Analysis, AHRI commented
that DOE should be aware that many independent custom cellar and
cabinet builders could be impacted by amended energy conservation
standards for WICFs. (AHRI-Wine, No. 39 at p. 5)
DOE notes that similar comments were made by a high-temperature
refrigeration system manufacturer during confidential interviews. As
discussed in section IV.B, DOE understands that design options that
necessitate a significant change in system size could impact custom
wine cellar designs since high-temperature walk-ins may be space-
constrained. DOE has tentatively determined that consumers would lose
the utility of compact high-temperature refrigeration systems if the
evaporator or condenser heat exchangers underwent a considerable
increase in size. Therefore, DOE is proposing to screen out improved
evaporator and condenser coils for high-temperature refrigeration
systems on the grounds of customer utility due to the additional heat
exchanger size needed for this technology option. See IV.B of this
document or chapter 4 of the NOPR TSD for additional details on the
screening analysis.
K. Emissions Analysis
The emissions analysis consists of two components. The first
component estimates the effect of potential energy conservation
standards on power sector and site (where applicable) combustion
emissions of CO2, NOX, SO2, and Hg.
The second component estimates the impacts of potential standards on
emissions of two additional greenhouse gases, CH4 and
N2O, as well as the
[[Page 60807]]
reductions to emissions of other gases due to ``upstream'' activities
in the fuel production chain. These upstream activities comprise
extraction, processing, and transporting fuels to the site of
combustion.
The analysis of electric power sector emissions of CO2,
NOX, SO2, and Hg uses emissions factors intended
to represent the marginal impacts of the change in electricity
consumption associated with amended or new standards. The methodology
is based on results published for the AEO, including a set of side
cases that implement a variety of efficiency-related policies. The
methodology is described in appendix 13A in the NOPR TSD. The analysis
presented in this notice uses projections from AEO2023. Power sector
emissions of CH4 and N2O from fuel combustion are
estimated using Emission Factors for Greenhouse Gas Inventories
published by the EPA.\68\
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\68\ Available at www.epa.gov/sites/production/files/2021-04/documents/emission-factors_apr2021.pdf (last accessed April 17,
2023).
---------------------------------------------------------------------------
FFC upstream emissions, which include emissions from fuel
combustion during extraction, processing, and transportation of fuels,
and ``fugitive'' emissions (direct leakage to the atmosphere) of
CH4 and CO2, are estimated based on the
methodology described in chapter 15 of the NOPR TSD.
The emissions intensity factors are expressed in terms of physical
units per MWh or MMBtu of site energy savings. For power sector
emissions, specific emissions intensity factors are calculated by
sector and end use. Total emissions reductions are estimated using the
energy savings calculated in the NIA.
1. Air Quality Regulations Incorporated in DOE's Analysis
DOE's no-new-standards case for the electric power sector reflects
the AEO, which incorporates the projected impacts of existing air
quality regulations on emissions. AEO2023 reflects, to the extent
possible, laws and regulations adopted through mid-November 2022,
including the emissions control programs discussed in the following
paragraphs the emissions control programs discussed in the following
paragraphs, and the Inflation Reduction Act.\69\ SO2
emissions from affected electric generating units (``EGUs'') are
subject to nationwide and regional emissions cap-and-trade programs.
Title IV of the Clean Air Act sets an annual emissions cap on
SO2 for affected EGUs in the 48 contiguous States and the
District of Columbia (DC). (42 U.S.C. 7651 et seq.) SO2
emissions from numerous States in the eastern half of the United States
are also limited under the Cross-State Air Pollution Rule (``CSAPR'').
76 FR 48208 (Aug. 8, 2011). CSAPR requires these States to reduce
certain emissions, including annual SO2 emissions, and went
into effect as of January 1, 2015.\70\ AEO2023 incorporates
implementation of CSAPR, including the update to the CSAPR ozone season
program emission budgets and target dates issued in 2016. 81 FR 74504
(Oct. 26, 2016). Compliance with CSAPR is flexible among EGUs and is
enforced through the use of tradable emissions allowances. Under
existing EPA regulations, any excess SO2 emissions
allowances resulting from the lower electricity demand caused by the
adoption of an efficiency standard could be used to permit offsetting
increases in SO2 emissions by another regulated EGU.
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\69\ For further information, see the Assumptions to AEO2023
report that sets forth the major assumptions used to generate the
projections in the Annual Energy Outlook. Available at www.eia.gov/outlooks/aeo/assumptions/ (last accessed April 17, 2023).
\70\ CSAPR requires states to address annual emissions of
SO2 and NOX, precursors to the formation of
fine particulate matter (PM2.5) pollution, in order to
address the interstate transport of pollution with respect to the
1997 and 2006 PM2.5 National Ambient Air Quality
Standards (``NAAQS''). CSAPR also requires certain states to address
the ozone season (May-September) emissions of NOX, a
precursor to the formation of ozone pollution, in order to address
the interstate transport of ozone pollution with respect to the 1997
ozone NAAQS. 76 FR 48208 (Aug. 8, 2011). EPA subsequently issued a
supplemental rule that included an additional five states in the
CSAPR ozone season program; 76 FR 80760 (Dec. 27, 2011)
(Supplemental Rule).
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However, beginning in 2016, SO2 emissions began to fall
as a result of the Mercury and Air Toxics Standards (``MATS'') for
power plants.\71\ 77 FR 9304 (Feb. 16, 2012). In the MATS final rule,
EPA established a standard for hydrogen chloride as a surrogate for
acid gas hazardous air pollutants (``HAP''), and also established a
standard for SO2 (a non-HAP acid gas) as an alternative
equivalent surrogate standard for acid gas HAP. The same controls are
used to reduce HAP and non-HAP acid gas; thus, SO2 emissions
are being reduced as a result of the control technologies installed on
coal-fired power plants to comply with the MATS requirements for acid
gas. Because of the emissions reductions under the MATS, it is unlikely
that excess SO2 emissions allowances resulting from the
lower electricity demand would be needed or used to permit offsetting
increases in SO2 emissions by another regulated EGU.
Therefore, energy conservation standards that decrease electricity
generation would generally reduce SO2 emissions. DOE
estimated SO2 emissions reduction using emissions factors
based on AEO2023.
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\71\ In order to continue operating, coal power plants must have
either flue gas desulfurization or dry sorbent injection systems
installed. Both technologies, which are used to reduce acid gas
emissions, also reduce SO2 emissions.
---------------------------------------------------------------------------
CSAPR also established limits on NOX emissions for
numerous States in the eastern half of the United States. Energy
conservation standards would have little effect on NOX
emissions in those States covered by CSAPR emissions limits if excess
NOX emissions allowances resulting from the lower
electricity demand could be used to permit offsetting increases in
NOX emissions from other EGUs. In such case, NOX
emissions would remain near the limit even if electricity generation
goes down. A different case could possibly result, depending on the
configuration of the power sector in the different regions and the need
for allowances, such that NOX emissions might not remain at
the limit in the case of lower electricity demand. In this case, energy
conservation standards might reduce NOX emissions in covered
States. Despite this possibility, DOE has chosen to be conservative in
its analysis and has maintained the assumption that standards will not
reduce NOX emissions in States covered by CSAPR. Energy
conservation standards would be expected to reduce NOX
emissions in the States not covered by CSAPR. DOE used AEO2023 data to
derive NOX emissions factors for the group of States not
covered by CSAPR.
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would be expected to slightly reduce Hg emissions. DOE
estimated mercury emissions reduction using emissions factors based on
AEO2023, which incorporates the MATS.
L. Monetizing Emissions Impacts
As part of the development of this proposed rule, for the purpose
of complying with the requirements of Executive Order 12866, DOE
considered the estimated monetary benefits from the reduced emissions
of CO2, CH4, N2O, NOX, and
SO2 that are expected to result from each of the TSLs
considered. In order to make this calculation analogous to the
calculation of the NPV of consumer benefit, DOE considered the reduced
emissions expected to result over the lifetime of products shipped in
the projection period for each TSL. This section summarizes the basis
for the values used for monetizing
[[Page 60808]]
the emissions benefits and presents the values considered in this NOPR.
To monetize the benefits of reducing GHG emissions, this analysis
uses the interim estimates presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published in February 2021 by the IWG.
1. Monetization of Greenhouse Gas Emissions
DOE estimates the monetized benefits of the reductions in emissions
of CO2, CH4, and N2O by using a
measure of the SC of each pollutant (e.g., SC-CO2). These
estimates represent the monetary value of the net harm to society
associated with a marginal increase in emissions of these pollutants in
a given year, or the benefit of avoiding that increase. These estimates
are intended to include (but are not limited to) climate-change-related
changes in net agricultural productivity, human health, property
damages from increased flood risk, disruption of energy systems, risk
of conflict, environmental migration, and the value of ecosystem
services.
DOE exercises its own judgment in presenting monetized climate
benefits as recommended by applicable Executive orders, and DOE would
reach the same conclusion presented in this proposed rulemaking in the
absence of the social cost of greenhouse gases. That is, the social
costs of greenhouse gases, whether measured using the February 2021
interim estimates presented by the Interagency Working Group on the
Social Cost of Greenhouse Gases or by another means, did not affect the
rule ultimately proposed by DOE.
DOE estimated the global social benefits of CO2,
CH4, and N2O reductions using SC-GHG values that
were based on the interim values presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim
Estimates under Executive Order 13990, published in February 2021 by
the IWG (``February 2021 SC-GHG TSD''). The SC-GHGs is the monetary
value of the net harm to society associated with a marginal increase in
emissions in a given year, or the benefit of avoiding that increase. In
principle, SC-GHGs includes the value of all climate change impacts,
including (but not limited to) changes in net agricultural
productivity, human health effects, property damage from increased
flood risk and natural disasters, disruption of energy systems, risk of
conflict, environmental migration, and the value of ecosystem services.
The SC-GHGs therefore, reflects the societal value of reducing
emissions of the gas in question by one metric ton. The SC-GHGs is the
theoretically appropriate value to use in conducting benefit-cost
analyses of policies that affect CO2, N2O and
CH4 emissions. As a member of the IWG involved in the
development of the February 2021 SC-GHG TSD, DOE agrees that the
interim SC-GHG estimates represent the most appropriate estimate of the
SC-GHG until revised estimates have been developed reflecting the
latest, peer-reviewed science.
The SC-GHGs estimates presented here were developed over many
years, using transparent process, peer-reviewed methodologies, the best
science available at the time of that process, and with input from the
public. Specifically, in 2009, the IWG, that included the DOE and other
executive branch agencies and offices was established to ensure that
agencies were using the best available science and to promote
consistency in the social cost of carbon (``SC-CO2'') values
used across agencies. The IWG published SC-CO2 estimates in
2010 that were developed from an ensemble of three widely cited
integrated assessment models (``IAMs'') that estimate global climate
damages using highly aggregated representations of climate processes
and the global economy combined into a single modeling framework. The
three IAMs were run using a common set of input assumptions in each
model for future population, economic, and CO2 emissions
growth, as well as equilibrium climate sensitivity--a measure of the
globally averaged temperature response to increased atmospheric
CO2 concentrations. These estimates were updated in 2013
based on new versions of each IAM. In August 2016 the IWG published
estimates of the social cost of methane (``SC-CH4'') and
nitrous oxide (``SC-N2O'') using methodologies that are
consistent with the methodology underlying the SC-CO2
estimates. The modeling approach that extends the IWG SC-CO2
methodology to non-CO2 GHGs has undergone multiple stages of
peer review. The SC-CH4 and SC-N2O estimates were
developed by Marten et al.\72\ and underwent a standard double-blind
peer review process prior to journal publication. In 2015, as part of
the response to public comments received to a 2013 solicitation for
comments on the SC-CO2 estimates, the IWG announced a
National Academies of Sciences, Engineering, and Medicine review of the
SC-CO2 estimates to offer advice on how to approach future
updates to ensure that the estimates continue to reflect the best
available science and methodologies. In January 2017, the National
Academies released their final report, Valuing Climate Damages:
Updating Estimation of the Social Cost of Carbon Dioxide, and
recommended specific criteria for future updates to the SC-
CO2 estimates, a modeling framework to satisfy the specified
criteria, and both near-term updates and longer-term research needs
pertaining to various components of the estimation process.\73\ Shortly
thereafter, in March 2017, President Trump issued Executive Order
13783, which disbanded the IWG, withdrew the previous TSDs, and
directed agencies to ensure SC-CO2 estimates used in
regulatory analyses are consistent with the guidance contained in OMB's
Circular A-4, ``including with respect to the consideration of domestic
versus international impacts and the consideration of appropriate
discount rates'' (Executive Order (``E.O.'') 13783, Section 5(c)).
Benefit-cost analyses following E.O. 13783 used SC-GHG estimates that
attempted to focus on the U.S.-specific share of climate change damages
as estimated by the models and were calculated using two discount rates
recommended by Circular A-4, 3 percent and 7 percent. All other
methodological decisions and model versions used in SC-GHG calculations
remained the same as those used by the IWG in 2010 and 2013,
respectively.
---------------------------------------------------------------------------
\72\ Marten, A. L., E. A. Kopits, C. W. Griffiths, S. C.
Newbold, and A. Wolverton. Incremental CH4 and
N2O mitigation benefits consistent with the U.S.
Government's SC-CO2 estimates. Climate Policy. 2015.
15(2): pp. 272-298.
\73\ National Academies of Sciences, Engineering, and Medicine.
Valuing Climate Damages: Updating Estimation of the Social Cost of
Carbon Dioxide. 2017. The National Academies Press: Washington, DC.
nap.nationalacademies.org/catalog/24651/valuing-climate-damages-updating-estimation-of-the-social-cost-of.
---------------------------------------------------------------------------
On January 20, 2021, President Biden issued E.O. 13990, which re-
established the IWG and directed it to ensure that the U.S.
Government's estimates of the social cost of carbon and other
greenhouse gases reflect the best available science and the
recommendations in the national Academies 2017 report. The IWG was
tasked with first reviewing the SC-GHG estimates currently used in
Federal analyses and publishing interim estimates within 30 days of the
E.O. that reflect the full impact of GHG emissions, including by taking
global damages into account. The interim SC-GHG estimates published in
February 2021 are used here to estimate the climate benefits for this
proposed rulemaking. The E.O. instructs the IWG
[[Page 60809]]
to undertake a fuller update of the SC-GHG estimates that takes into
consideration the advice in the National Academies 2017 report and
other recent scientific literature. The February 2021 SC-GHG TSD
provides a complete discussion of the IWG's initial review conducted
under E.O.13990. In particular, the IWG found that the SC-GHG estimates
used under E.O. 13783 fail to reflect the full impact of GHG emissions
in multiple ways.
First, the IWG found that the SC-GHG estimates used under E.O.
13783 fail to fully capture many climate impacts that affect the
welfare of U.S. citizens and residents, and those impacts are better
reflected by global measures of the SC-GHG. Examples of omitted effects
from the E.O. 13783 estimates include direct effects on U.S. citizens,
assets, and investments located abroad, supply chains, U.S. military
assets and interests abroad, and tourism, and spillover pathways such
as economic and political destabilization and global migration that can
lead to adverse impacts on U.S. national security, public health, and
humanitarian concerns. In addition, assessing the benefits of U.S. GHG
mitigation activities requires consideration of how those actions may
affect mitigation activities by other countries, as those international
mitigation actions will provide a benefit to U.S. citizens and
residents by mitigating climate impacts that affect U.S. citizens and
residents. A wide range of scientific and economic experts have
emphasized the issue of reciprocity as support for considering global
damages of GHG emissions. If the United States does not consider
impacts on other countries, it is difficult to convince other countries
to consider the impacts of their emissions on the United States. The
only way to achieve an efficient allocation of resources for emissions
reduction on a global basis--and so benefit the U.S. and its citizens--
is for all countries to base their policies on global estimates of
damages. As a member of the IWG involved in the development of the
February 2021 SC-GHG TSD, DOE agrees with this assessment and,
therefore, in this proposed rule DOE centers attention on a global
measure of SC-GHG. This approach is the same as that taken in DOE
regulatory analyses from 2012 through 2016. A robust estimate of
climate damages that accrue only to U.S. citizens and residents does
not currently exist in the literature. As explained in the February
2021 TSD, existing estimates are both incomplete and an underestimate
of total damages that accrue to the citizens and residents of the U.S.
because they do not fully capture the regional interactions and
spillovers discussed above, nor do they include all of the important
physical, ecological, and economic impacts of climate change recognized
in the climate change literature. As noted in the February 2021 SC-GHG
TSD, the IWG will continue to review developments in the literature,
including more robust methodologies for estimating a U.S.-specific SC-
GHG value, and explore ways to better inform the public of the full
range of carbon impacts. As a member of the IWG, DOE will continue to
follow developments in the literature pertaining to this issue.
Second, the IWG found that the use of the social rate of return on
capital (7 percent under current OMB Circular A-4 guidance) to discount
the future benefits of reducing GHG emissions inappropriately
underestimates the impacts of climate change for the purposes of
estimating the SC-GHG. Consistent with the findings of the National
Academies and the economic literature, the IWG continued to conclude
that the consumption rate of interest is the theoretically appropriate
discount rate in an intergenerational context,\74\ and recommended that
discount rate uncertainty and relevant aspects of intergenerational
ethical considerations be accounted for in selecting future discount
rates.
---------------------------------------------------------------------------
\74\ Interagency Working Group on Social Cost of Carbon. Social
Cost of Carbon for Regulatory Impact Analysis under Executive Order
12866. 2010. United States Government. (Last accessed April 17,
2023.) www.epa.gov/sites/default/files/2016-12/documents/scc_tsd_2010.pdf; Interagency Working Group on Social Cost of
Carbon. Technical Update of the Social Cost of Carbon for Regulatory
Impact Analysis Under Executive Order 12866. 2013. (Last accessed
April 17, 2023.) www.federalregister.gov/documents/2013/11/26/2013-28242/technical-support-document-technical-update-of-the-social-cost-of-carbon-for-regulatory-impact; Interagency Working Group on
Social Cost of Greenhouse Gases, United States Government. Technical
Support Document: Technical Update on the Social Cost of Carbon for
Regulatory Impact Analysis-Under Executive Order 12866. August 2016.
(Last accessed April 17, 2023.) www.epa.gov/sites/default/files/2016-12/documents/sc_co2_tsd_august_2016.pdf; Interagency Working
Group on Social Cost of Greenhouse Gases, United States Government.
Addendum to Technical Support Document on Social Cost of Carbon for
Regulatory Impact Analysis under Executive Order 12866: Application
of the Methodology to Estimate the Social Cost of Methane and the
Social Cost of Nitrous Oxide. August 2016. (Last accessed April 17,
2023.) www.epa.gov/sites/default/files/2016-12/documents/addendum_to_sc-ghg_tsd_august_2016.pdf.
---------------------------------------------------------------------------
Furthermore, the damage estimates developed for use in the SC-GHG
are estimated in consumption-equivalent terms, and so an application of
OMB Circular A-4's guidance for regulatory analysis would then use the
consumption discount rate to calculate the SC-GHG. DOE agrees with this
assessment and will continue to follow developments in the literature
pertaining to this issue. DOE also notes that while OMB Circular A-4,
as published in 2003, recommends using 3% and 7% discount rates as
``default'' values, Circular A-4 also reminds agencies that ``different
regulations may call for different emphases in the analysis, depending
on the nature and complexity of the regulatory issues and the
sensitivity of the benefit and cost estimates to the key assumptions.''
On discounting, Circular A-4 recognizes that ``special ethical
considerations arise when comparing benefits and costs across
generations,'' and Circular A-4 acknowledges that analyses may
appropriately ``discount future costs and consumption benefits . . . at
a lower rate than for intragenerational analysis.'' In the 2015
Response to Comments on the Social Cost of Carbon for Regulatory Impact
Analysis, OMB, DOE, and the other IWG members recognized that
``Circular A-4 is a living document'' and ``the use of 7 percent is not
considered appropriate for intergenerational discounting. There is wide
support for this view in the academic literature, and it is recognized
in Circular A-4 itself.'' Thus, DOE concludes that a 7% discount rate
is not appropriate to apply to value the social cost of greenhouse
gases in the analysis presented in this analysis.
To calculate the present and annualized values of climate benefits,
DOE uses the same discount rate as the rate used to discount the value
of damages from future GHG emissions, for internal consistency. That
approach to discounting follows the same approach that the February
2021 TSD recommends ``to ensure internal consistency--i.e., future
damages from climate change using the SC-GHG at 2.5 percent should be
discounted to the base year of the analysis using the same 2.5 percent
rate.'' DOE has also consulted the National Academies' 2017
recommendations on how SC-GHG estimates can ``be combined in RIAs with
other cost and benefits estimates that may use different discount
rates.'' The National Academies reviewed several options, including
``presenting all discount rate combinations of other costs and benefits
with [SC-GHG] estimates.''
As a member of the IWG involved in the development of the February
2021 SC-GHG TSD, DOE agrees with the above assessment and will continue
to follow developments in the literature pertaining to this issue.
While the IWG works to assess how best to incorporate the latest, peer-
reviewed science to
[[Page 60810]]
develop an updated set of SC-GHG estimates, it set the interim
estimates to be the most recent estimates developed by the IWG prior to
the group being disbanded in 2017. The estimates rely on the same
models and harmonized inputs and are calculated using a range of
discount rates. As explained in the February 2021 SC-GHG TSD, the IWG
has recommended that agencies revert to the same set of four values
drawn from the SC-GHG distributions based on three discount rates as
were used in regulatory analyses between 2010 and 2016 and were subject
to public comment. For each discount rate, the IWG combined the
distributions across models and socioeconomic emissions scenarios
(applying equal weight to each) and then selected a set of four values
recommended for use in benefit-cost analyses: an average value
resulting from the model runs for each of three discount rates (2.5
percent, 3 percent, and 5 percent), plus a fourth value, selected as
the 95th percentile of estimates based on a 3 percent discount rate.
The fourth value was included to provide information on potentially
higher-than-expected economic impacts from climate change. As explained
in the February 2021 SC-GHG TSD, and DOE agrees, this update reflects
the immediate need to have an operational SC-GHG for use in regulatory
benefit-cost analyses and other applications that was developed using a
transparent process, peer-reviewed methodologies, and the science
available at the time of that process. Those estimates were subject to
public comment in the context of dozens of proposed rulemakings as well
as in a dedicated public comment period in 2013.
There are a number of limitations and uncertainties associated with
the SC-GHG estimates. First, the current scientific and economic
understanding of discounting approaches suggests discount rates
appropriate for intergenerational analysis in the context of climate
change are likely to be less than 3 percent, near 2 percent or
lower.\75\ Second, the IAMs used to produce these interim estimates do
not include all of the important physical, ecological, and economic
impacts of climate change recognized in the climate change literature
and the science underlying their ``damage functions''--i.e., the core
parts of the IAMs that map global mean temperature changes and other
physical impacts of climate change into economic (both market and
nonmarket) damages--lags behind the most recent research. For example,
limitations include the incomplete treatment of catastrophic and non-
catastrophic impacts in the IAMs, their incomplete treatment of
adaptation and technological change, the incomplete way in which inter-
regional and intersectoral linkages are modeled, uncertainty in the
extrapolation of damages to high-temperatures, and inadequate
representation of the relationship between the discount rate and
uncertainty in economic growth over long time horizons. Likewise, the
socioeconomic and emissions scenarios used as inputs to the models do
not reflect new information from the last decade of scenario generation
or the full range of projections. The modeling limitations do not all
work in the same direction in terms of their influence on the SC-
CO2 estimates. However, as discussed in the February 2021
TSD, the IWG has recommended that, taken together, the limitations
suggest that the interim SC-GHG estimates used in this proposed rule
likely underestimate the damages from GHG emissions. DOE concurs with
this assessment.
---------------------------------------------------------------------------
\75\ Interagency Working Group on Social Cost of Greenhouse
Gases (IWG). 2021. Technical Support Document: Social Cost of
Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive
Order 13990. February. United States Government. Available at:
www.whitehouse.gov/briefing-room/blog/2021/02/26/a-return-to-science-evidence-based-estimates-of-the-benefits-of-reducing-climate-pollution/.
---------------------------------------------------------------------------
DOE's derivations of the SC-CO2, SC-N2O, and
SC-CH4 values used for this NOPR are discussed in the
following sections, and the results of DOE's analyses estimating the
benefits of the reductions in emissions of these GHGs are presented in
section IV.L.2 of this document.
a. Social Cost of Carbon
The SC-CO2 values used for this NOPR were based on the
values developed for the IWG's February 2021 TSD, which are shown in
Table IV.47 in five-year increments from 2020 to 2050. The set of
annual values that DOE used, which was adapted from estimates published
by EPA,\76\ is presented in Appendix 14A of the final rule TSD. These
estimates are based on methods, assumptions, and parameters identical
to the estimates published by the IWG (which were based on EPA
modeling), and include values for 2051 to 2070. DOE expects additional
climate benefits to accrue for products still operating after 2070, but
a lack of available SC-CO2 estimates for emissions years
beyond 2070 prevents DOE from monetizing these potential benefits in
this analysis.
---------------------------------------------------------------------------
\76\ See EPA, Revised 2023 and Later Model Year Light-Duty
Vehicle GHG Emissions Standards: Regulatory Impact Analysis,
Washington, DC, December 2021. Available at nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1013ORN.pdf (last accessed February 21, 2023).
Table IV.47--Annual SC-CO2 Values From 2021 Interagency Update, 2020-2050
[2020$ Per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount Rate and Statistic
-----------------------------------------------------------------
Year 3% 95th
5% Average 3% Average 2.5% Average percentile
----------------------------------------------------------------------------------------------------------------
2020.......................................... 14 51 76 152
2025.......................................... 17 56 83 169
2030.......................................... 19 62 89 187
2035.......................................... 22 67 96 206
2040.......................................... 25 73 103 225
2045.......................................... 28 79 110 242
2050.......................................... 32 85 116 260
----------------------------------------------------------------------------------------------------------------
DOE multiplied the CO2 emissions reduction estimated for
each year by the SC-CO2 value for that year in each of the
four cases. DOE adjusted the values to 2022$ using the implicit price
deflator for gross domestic product (``GDP'') from the Bureau of
Economic Analysis. To calculate a present value of the stream of
monetary values, DOE
[[Page 60811]]
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SC-CO2 values
in each case.
b. Social Cost of Methane and Nitrous Oxide
The SC-CH4 and SC-N2O values used for this
NOPR were based on the values developed for the February 2021 TSD.
Table IV.48 shows the updated sets of SC-CH4 and SC-
N2O estimates from the latest interagency update in 5-year
increments from 2020 to 2050. The full set of annual values used is
presented in Appendix 14-A of the NOPR TSD. To capture the
uncertainties involved in regulatory impact analysis, DOE has
determined it is appropriate to include all four sets of SC-
CH4 and SC-N2O values, as recommended by the IWG.
DOE derived values after 2050 using the approach described above for
the SC-CO2.
Table IV.48--Annual SC-CH4 and SC-N2O Values From 2021 Interagency Update, 2020-2050
[2020$ Per metric ton]
--------------------------------------------------------------------------------------------------------------------------------------------------------
SC-CH4 SC-N2O
-------------------------------------------------------------------------------------------------
Discount rate and statistic Discount rate and statistic
Year -------------------------------------------------------------------------------------------------
5% 3% 2.5% 3% 95th 5% 3% 2.5% 3% 95th
Average Average Average percentile Average Average Average percentile
--------------------------------------------------------------------------------------------------------------------------------------------------------
2020.................................................. 670 1500 2000 3900 5800 18000 27000 48000
2025.................................................. 800 1700 2200 4500 6800 21000 30000 54000
2030.................................................. 940 2000 2500 5200 7800 23000 33000 60000
2035.................................................. 1100 2200 2800 6000 9000 25000 36000 67000
2040.................................................. 1300 2500 3100 6700 10000 28000 39000 74000
2045.................................................. 1500 2800 3500 7500 12000 30000 42000 81000
2050.................................................. 1700 3100 3800 8200 13000 33000 45000 88000
--------------------------------------------------------------------------------------------------------------------------------------------------------
DOE multiplied the CH4 and N2O emissions
reduction estimated for each year by the SC-CH4 and SC-
N2O estimates for that year in each of the cases. DOE
adjusted the values to 2022$ using the implicit price deflator for
gross domestic product (``GDP'') from the Bureau of Economic Analysis.
To calculate a present value of the stream of monetary values, DOE
discounted the values in each of the cases using the specific discount
rate that had been used to obtain the SC-CH4 and SC-
N2O estimates in each case.
2. Monetization of Other Emissions Impacts
For the NOPR, DOE estimated the monetized value of NOX
and SO2 emissions reductions from electricity generation
using the latest benefit-per-ton estimates for that sector from the
EPA's Benefits Mapping and Analysis Program.\77\ DOE used EPA's values
for PM2.5-related benefits associated with NOX
and SO2 and for ozone-related benefits associated with
NOX for 2025 2030, and 2040, calculated with discount rates
of 3 percent and 7 percent. DOE used linear interpolation to define
values for the years not given in the 2025 to 2040 period; for years
beyond 2040 the values are held constant. DOE combined the EPA regional
benefit-per-ton estimates with regional information on electricity
consumption and emissions from AEO2023 to define weighted-average
national values for NOX and SO2 (see appendix 14B
of the NOPR TSD).
---------------------------------------------------------------------------
\77\ U.S. Environmental Protection Agency. Estimating the
Benefit per Ton of Reducing Directly-Emitted PM2.5,
PM2.5 Precursors and Ozone precursors from 21 Sectors.
www.epa.gov/benmap/estimating-benefit-ton-reducing-directly-emitted-pm25-pm25-precursors-and-ozone-precursors.
---------------------------------------------------------------------------
DOE also estimated the monetized value of NOX and
SO2 emissions reductions from site use of natural gas in
walk-in coolers and freezers using benefit-per-ton estimates from the
EPA's Benefits Mapping and Analysis Program. Although none of the
sectors covered by EPA refers specifically to residential and
commercial buildings, the sector called ``area sources'' would be a
reasonable proxy for residential and commercial buildings.\78\ The EPA
document provides high and low estimates for 2025 and 2030 at 3- and 7-
percent discount rates.\79\ DOE used the same linear interpolation and
extrapolation as it did with the values for electricity generation.
---------------------------------------------------------------------------
\78\ ``Area sources'' represents all emission sources for which
states do not have exact (point) locations in their emissions
inventories. Because exact locations would tend to be associated
with larger sources, ``area sources'' would be fairly representative
of small dispersed sources like homes and businesses.
\79\ ``Area sources'' are a category in the 2018 document from
EPA, but are not used in the 2021 document cited above. See:
www.epa.gov/sites/default/files/2018-02/documents/sourceapportionmentbpttsd_2018.pdf.
---------------------------------------------------------------------------
DOE multiplied the site emissions reduction (in tons) in each year
by the associated $/ton values, and then discounted each series using
discount rates of 3 percent and 7 percent as appropriate.
M. Utility Impact Analysis
The utility impact analysis estimates the changes in installed
electrical capacity and generation projected to result for each
considered TSL. The analysis is based on published output from the NEMS
associated with AEO2023. NEMS produces the AEO Reference case, as well
as a number of side cases that estimate the economy-wide impacts of
changes to energy supply and demand. For the current analysis, impacts
are quantified by comparing the levels of electricity sector
generation, installed capacity, fuel consumption and emissions in the
AEO2023 Reference case and various side cases. Details of the
methodology are provided in the appendices to chapters 13 and 15 of the
NOPR TSD.
The output of this analysis is a set of time-dependent coefficients
that capture the change in electricity generation, primary fuel
consumption, installed capacity and power sector emissions due to a
unit reduction in demand for a given end use. These coefficients are
multiplied by the stream of electricity savings calculated in the NIA
to provide estimates of selected utility impacts of potential new or
amended energy conservation standards.
N. Employment Impact Analysis
DOE considers employment impacts in the domestic economy as one
factor in selecting a proposed standard. Employment impacts from new or
amended energy conservation standards include both direct and indirect
impacts. Direct employment impacts are any changes in the number of
employees of manufacturers of the equipment subject to standards. The
MIA addresses those impacts. Indirect employment impacts are changes in
national employment that occur due to
[[Page 60812]]
the shift in expenditures and capital investment caused by the purchase
and operation of more-efficient appliances. Indirect employment impacts
from standards consist of the net jobs created or eliminated in the
national economy, other than in the manufacturing sector being
regulated, caused by (1) reduced spending by consumers on energy, (2)
reduced spending on new energy supply by the utility industry, (3)
increased consumer spending on the products to which the new standards
apply and other goods and services, and (4) the effects of those three
factors throughout the economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (``BLS''). BLS regularly publishes its estimates of
the number of jobs per million dollars of economic activity in
different sectors of the economy, as well as the jobs created elsewhere
in the economy by this same economic activity. Data from BLS indicate
that expenditures in the utility sector generally create fewer jobs
(both directly and indirectly) than expenditures in other sectors of
the economy.\80\ There are many reasons for these differences,
including wage differences and the fact that the utility sector is more
capital-intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive sector (i.e., the utility sector) to more labor-
intensive sectors (e.g., the retail and service sectors). Thus, the BLS
data suggest that net national employment may increase due to shifts in
economic activity resulting from energy conservation standards.
---------------------------------------------------------------------------
\80\ See U.S. Department of Commerce-Bureau of Economic
Analysis. Regional Multipliers: A User Handbook for the Regional
Input-Output Modeling System (RIMS II). 1997. U.S. Government
Printing Office: Washington, DC. Available at https://apps.bea.gov/scb/pdf/regional/perinc/meth/rims2.pdf (last accessed April 27,
2023).
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this NOPR using an input/output model of the U.S.
economy called Impact of Sector Energy Technologies version 4
(``ImSET'').\81\ ImSET is a special-purpose version of the ``U.S.
Benchmark National Input-Output'' (``I-O'') model, which was designed
to estimate the national employment and income effects of energy-saving
technologies. The ImSET software includes a computer-based I-O model
having structural coefficients that characterize economic flows among
187 sectors most relevant to industrial, commercial, and residential
building energy use.
---------------------------------------------------------------------------
\81\ Livingston, O.V., S.R. Bender, M.J. Scott, and R.W.
Schultz. ImSET 4.0: Impact of Sector Energy Technologies Model
Description and User Guide. 2015. Pacific Northwest National
Laboratory: Richland, WA. PNNL-24563.
---------------------------------------------------------------------------
DOE notes that ImSET is not a general equilibrium forecasting
model, and that the uncertainties involved in projecting employment
impacts, especially changes in the later years of the analysis. Because
ImSET does not incorporate price changes, the employment effects
predicted by ImSET may over-estimate actual job impacts over the long
run for this rule. Therefore, DOE used ImSET only to generate results
for near-term timeframes (2027-2036), where these uncertainties are
reduced. For more details on the employment impact analysis, see
chapter 16 of the NOPR TSD.
V. Analytical Results and Conclusions
The following section addresses the results from DOE's analyses
with respect to the considered energy conservation standards for walk-
in coolers and freezers. It addresses the TSLs examined by DOE, the
projected impacts of each of these levels if adopted as energy
conservation standards for walk-in coolers and freezers, and the
standards levels that DOE is proposing to adopt in this NOPR.
Additional details regarding DOE's analyses are contained in the NOPR
TSD supporting this document.
A. Trial Standard Levels
In general, DOE typically evaluates potential new or amended
standards for products and equipment by grouping individual efficiency
levels for each class into TSLs. Use of TSLs allows DOE to identify and
consider manufacturer cost interactions between the equipment classes,
to the extent that there are such interactions, and price elasticity of
consumer purchasing decisions that may change when different standard
levels are set.
In the analysis conducted for this NOPR, DOE analyzed the benefits
and burdens of three TSLs for walk-ins. DOE developed TSLs that combine
efficiency levels for each analyzed equipment class, these TSL are
discussed in section IV.E.1 of this document.
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on walk-in coolers and freezers
consumers by looking at the effects that potential amended standards at
each TSL would have on the LCC and PBP. DOE also examined the impacts
of potential standards on selected consumer subgroups. These analyses
are discussed in the following sections.
a. Life-Cycle Cost and Payback Period
In general, higher-efficiency products affect consumers in two
ways: (1) purchase price increases and (2) annual operating costs
decrease. Inputs used for calculating the LCC and PBP include total
installed costs (i.e., product price plus installation costs), and
operating costs (i.e., annual energy use, energy prices, energy price
trends, repair costs, and maintenance costs). The LCC calculation also
uses product lifetime and a discount rate. Chapter 8 of the NOPR TSD
provides detailed information on the LCC and PBP analyses.
Table V.1 through Table V.56 show the LCC and PBP results for the
TSLs considered for each equipment class. In the first of each pair of
tables, the simple payback is measured relative to the baseline
product. In the second table, impacts are measured relative to the
efficiency distribution in the no-new-standards case in the compliance
year (see section III.E of this document). Because some consumers
purchase equipment with higher efficiency in the no-new-standards case,
the average savings are less than the difference between the average
LCC of the baseline product and the average LCC at each TSL. The
savings refer only to consumers who are affected by a standard at a
given TSL. Those who already purchase a product with efficiency at or
above a given TSL are not affected. Consumers for whom the LCC
increases at a given TSL experience a net cost.
Doors
[[Page 60813]]
Table V.1--Average LCC and PBP Results for Equipment Class: DW.L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 3,101 260 2,160 5,261 .............. 12.1
1....................................................... 3,101 257 2,136 5,237 .............. 12.1
2....................................................... 3,101 256 2,132 5,233 .............. 12.1
3....................................................... 4,463 210 1,747 6,210 44.0 12.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.2--LCC Savings Relative to the Base Case Efficiency Distribution
for Equipment Class: DW.L
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 .................
2................................. 0 .................
3................................. 100 -1,106
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.3--Average LCC and PBP Results for Equipment Class: DW.M
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,888 75 615 3,504 .............. 12.0
1....................................................... 2,888 74 607 3,495 .............. 12.0
2....................................................... 2,888 73 605 3,493 .............. 12.0
3....................................................... 4,248 53 436 4,684 99.1 12.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.4--LCC Savings Relative to the Base Case Efficiency Distribution
for Equipment Class: DW.M
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 .................
2................................. 0 .................
3................................. 100 -1,247
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.5--Average LCC and PBP Results for Equipment Class: NM.L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,574 368 2,219 4,793 .............. 8.0
1....................................................... 2,833 164 992 3,825 1.3 8.0
2....................................................... 2,833 164 991 3,824 1.3 8.0
3....................................................... 3,136 145 878 4,014 2.8 8.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
[[Page 60814]]
Table V.6--Lcc Savings Relative to the Base Case Efficiency Distribution
for Equipment Class: NM.L
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 2 724
2................................. 2 723
3................................. 37 307
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.7--Average LCC and PBP Results for Equipment Class: NM.M
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,605 120 727 3,332 .............. 8.0
1....................................................... 2,736 64 387 3,123 2.4 8.0
2....................................................... 2,850 41 251 3,101 3.2 8.0
3....................................................... 3,229 34 209 3,438 8.2 8.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.8--LCC Savings Relative to the Base Case Efficiency Distribution
for Equipment Class: NM.M
------------------------------------------------------------------------
Average savings--
impacted
TSL % Consumers with consumers
net cost (2022$)
------------------------------------------------------------------------
1................................. 2 203
2................................. 11 86
3................................. 96 -291
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.9--Average LCC and PBP Results for Equipment Class: NO.L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 7,102 516 3,089 10,191 .............. 7.9
1....................................................... 7,363 247 1,480 8,844 1.0 7.9
2....................................................... 7,363 246 1,478 8,841 1.0 7.9
3....................................................... 7,688 212 1,276 8,964 2.1 7.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.10--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: NO.L
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 1 1,194
2................................. 2 1,192
3................................. 9 932
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
[[Page 60815]]
Table V.11--Average LCC and PBP Results for Equipment Class: NO.M
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 7,059 168 1,014 8,073 .............. 8.0
1....................................................... 7,190 94 568 7,758 1.8 8.0
2....................................................... 7,307 63 383 7,690 2.4 8.0
3....................................................... 7,704 51 311 8,015 6.3 8.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.12--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: NO.M
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 306
2................................. 3 113
3................................. 95 -266
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Panels
Table V.13--Average LCC and PBP Results for Equipment Class: PF.L per ft\2\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 13.27 0.57 4.41 17.68 .............. 11.5
1....................................................... 13.27 0.56 4.35 17.62 .............. 11.5
2....................................................... 13.27 0.56 4.34 17.61 .............. 11.5
3....................................................... 16.10 0.40 3.15 19.25 26.1 11.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.14--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: PF.L per ft\2\
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 .................
2................................. 0 .................
3................................. 95 -1.61
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.15--Average LCC and PBP Results for Equipment Class: PS.L per ft\2\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 13.31 0.93 7.23 20.54 .............. 11.6
1....................................................... 13.31 0.91 7.12 20.43 .............. 11.6
2....................................................... 13.31 0.91 7.11 20.41 .............. 11.6
[[Page 60816]]
3....................................................... 16.18 0.55 4.33 20.51 10.1 11.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.16--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: PS.L per ft\2\
------------------------------------------------------------------------
Average savings--
% Consumers with impacted
TSL net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 .................
2................................. 0 .................
3................................. 64 -0.50
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.17--Average LCC and PBP Results for Equipment Class: PS.M per ft\2\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 12.82 0.22 1.72 14.54 .............. 11.6
1....................................................... 12.82 0.22 1.69 14.50 .............. 11.6
2....................................................... 12.82 0.21 1.67 14.49 .............. 11.6
3....................................................... 16.13 0.12 0.94 17.07 54.0 11.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.18--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: PS.M per ft\2\
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 .................
2................................. 0 .................
3................................. 100 -2.33
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Refrigeration Systems
Table V.19--Average LCC and PBP Results for Equipment Class: DC.L.I
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 7,644 2,476 22,075 29,719 .............. 10.6
1....................................................... 7,764 2,436 21,849 29,614 4.0 10.6
2....................................................... 7,764 2,436 21,849 29,614 4.0 10.6
[[Page 60817]]
3....................................................... 11,192 2,434 23,745 34,937 -16.2 10.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.20--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: DC.L.I
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 11 163
2................................. 11 163
3................................. 100 -5,218
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.21--Average LCC and PBP Results for Equipment Class: DC.L.O
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 26,565 3,788 39,834 66,399 .............. 10.5
1....................................................... 26,618 3,745 39,544 66,162 1.4 10.5
2....................................................... 26,720 3,732 39,507 66,227 3.6 10.5
3....................................................... 38,663 3,323 43,528 82,191 -25.0 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.22--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: DC.L.O
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 237
2................................. 8 172
3................................. 100 -15,792
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.23--Average LCC and PBP Results for Equipment Class: DC.M.I
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 3,801 1,157 10,327 14,128 .............. 10.5
1....................................................... 3,916 1,113 10,065 13,982 3.4 10.5
2....................................................... 3,916 1,113 10,065 13,982 3.4 10.5
3....................................................... 5,401 1,113 10,775 16,175 -26.7 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
[[Page 60818]]
Table V.24--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: DC.M.I
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 1 567
2................................. 1 567
3................................. 100 -2,047
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.25--Average LCC and PBP Results for Equipment Class: DC.M.O
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 5,803 1,651 15,078 20,881 .............. 10.6
1....................................................... 5,829 1,632 14,951 20,780 1.6 10.6
2....................................................... 5,872 1,618 14,873 20,745 2.6 10.6
3....................................................... 8,771 1,300 14,006 22,777 21.6 10.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.26--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: DC.M.O
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 101
2................................. 1 136
3................................. 96 -1,896
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.27--Average LCC and PBP Results for Equipment Class: SP.H.I
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple Payback Average
TSL First year's Lifetime Period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 1,978 255 2,709 4,688 .............. 10.5
1....................................................... 2,006 230 2,557 4,563 1.3 10.5
2....................................................... 2,006 230 2,557 4,563 1.3 10.5
3....................................................... 2,035 226 2,550 4,585 2.5 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.28--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.H.I
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 2 124
2................................. 2 124
3................................. 3 103
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
[[Page 60819]]
Table V.29--Average LCC and PBP Results for Equipment Class: SP.H.ID
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,051 436 3,977 6,027 .............. 10.5
1....................................................... 2,145 370 3,586 5,731 1.7 10.5
2....................................................... 2,145 370 3,586 5,731 1.7 10.5
3....................................................... 2,145 370 3,586 5,731 1.7 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.30--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.H.ID
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 296
2................................. 0 296
3................................. 0 296
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.31--Average LCC and PBP Results for Equipment Class: SP.H.O
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,857 357 3,829 6,686 .............. 10.5
1....................................................... 2,867 331 3,659 6,526 0.4 10.5
2....................................................... 2,948 317 3,612 6,560 2.9 10.5
3....................................................... 3,079 312 3,660 6,738 9.0 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.32--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.H.O
------------------------------------------------------------------------
Average savings--
TSL % Consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 159
2................................. 3 126
3................................. 81 -53
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.33--Average LCC and PBP Results for Equipment Class: SP.H.OD
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,820 590 5,401 8,221 .............. 10.5
1....................................................... 2,836 522 4,948 7,784 0.2 10.5
2....................................................... 3,119 474 4,797 7,916 3.4 10.5
3....................................................... 3,146 472 4,806 7,951 3.8 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
[[Page 60820]]
Table V.34--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.H.OD
------------------------------------------------------------------------
Average
savings--
TSL % Consumers impacted
with net cost consumers
(2022$)
------------------------------------------------------------------------
1....................................... 0 437
2....................................... 4 305
3....................................... 13 270
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.35--Average LCC and PBP Results for Equipment Class: SP.L.I
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 3,722 743 7,026 10,748 .............. 10.5
1....................................................... 3,939 666 6,630 10,568 3.8 10.5
2....................................................... 3,939 666 6,630 10,568 3.8 10.5
3....................................................... 5,223 643 7,100 12,323 inf 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.36--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.L.I
------------------------------------------------------------------------
Average savings--
TSL % consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 7 180
2................................. 7 180
3................................. 100 -1,575
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.37--Average LCC and PBP Results for Equipment Class: SP.L.O
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 4,951 956 9,129 14,079 .............. 10.6
1....................................................... 4,951 956 9,129 14,079 .............. 10.6
2....................................................... 4,951 956 9,129 14,079 .............. 10.6
3....................................................... 6,514 806 8,843 15,357 39.0 10.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.38--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.L.O
------------------------------------------------------------------------
Average savings--
TSL % consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. ................. .................
2................................. ................. .................
3................................. 100.0 -1,278
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
[[Page 60821]]
Table V.39--Average LCC and PBP Results for Equipment Class: SP.M.I
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 4,002 713 6,961 10,963 .............. 10.5
1....................................................... 4,087 677 6,762 10,849 3.0 10.5
2....................................................... 4,104 674 6,756 10,860 3.5 10.5
3....................................................... 5,277 666 7,263 12,540 inf 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.40--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.M.I
------------------------------------------------------------------------
Average savings--
TSL % consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 4 114
2................................. 5 103
3................................. 100 -1,577
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.41--Average LCC and PBP Results for Equipment Class: SP.M.O
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 4,795 668 7,032 11,826 .............. 10.5
1....................................................... 4,821 635 6,820 11,641 0.9 10.5
2....................................................... 4,830 634 6,819 11,649 1.2 10.5
3....................................................... 6,093 549 6,848 12,942 50.8 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.42--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: SP.M.O
------------------------------------------------------------------------
Average savings--
TSL % consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0 186
2................................. 0 177
3................................. 100 -1,116
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.43--Average LCC and PBP Results for Equipment Class: UC.H
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 3,083 483 4,626 7,709 .............. 10.5
1....................................................... 3,083 483 4,626 7,709 .............. 10.5
2....................................................... 3,083 483 4,626 7,709 .............. 10.5
3....................................................... 3,201 478 4,660 7,861 inf 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
[[Page 60822]]
Table V.44--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: UC.H
------------------------------------------------------------------------
Average savings--
TSL % consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. ................. .................
2................................. ................. .................
3................................. 61 -152
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.45--Average LCC and PBP Results for Equipment Class: UC.H.ID
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 3,161 719 6,377 9,538 .............. 10.5
1....................................................... 3,188 679 6,113 9,301 0.7 10.5
2....................................................... 3,188 679 6,113 9,301 0.7 10.5
3....................................................... 3,188 679 6,113 9,301 0.7 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.46--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: UC.H.ID
------------------------------------------------------------------------
Average savings--
TSL % consumers with impacted
net cost consumers (2022$)
------------------------------------------------------------------------
1................................. 0.0 237
2................................. 0.0 237
3................................. 0.0 237
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
Table V.47--Average LCC and PBP Results for Equipment Class: UC.L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,658 4,413 34,322 36,980 .............. 10.5
1....................................................... 2,801 4,239 33,099 35,900 0.9 10.5
2....................................................... 2,908 4,186 32,766 35,674 1.2 10.5
3....................................................... 2,908 4,186 32,766 35,674 1.2 10.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.48--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: UC.L
------------------------------------------------------------------------
Average savings--
TSL % Consumers with net impacted consumers
cost (2022$)
------------------------------------------------------------------------
1........................... 3 1,080
2........................... 8 1,306
3........................... 8 1,306
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
[[Page 60823]]
Table V.49--Average LCC and PBP Results for Equipment Class: UC.M
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2022$)
---------------------------------------------------------------- Simple payback Average
TSL First year's Lifetime period (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2,468 1,675 13,649 16,118 .............. 10.6
1....................................................... 2,530 1,640 13,418 15,948 2.0 10.6
2....................................................... 2,546 1,631 13,360 15,906 2.0 10.6
3....................................................... 2,546 1,631 13,360 15,906 2.0 10.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.50--LCC Savings Relative to the Base Case Efficiency
Distribution for Equipment Class: UC.M
------------------------------------------------------------------------
Average savings--
TSL % Consumers with net impacted consumers
cost (2022$)
------------------------------------------------------------------------
1........................... 9 170
2........................... 10 212
3........................... 10 212
------------------------------------------------------------------------
Note: The savings represent the average LCC for affected consumers.
b. Consumer Subgroup Analysis
In the consumer subgroup analysis, DOE estimated the impact of the
considered TSLs on high warm air-infiltration applications, and small
businesses. Table V.51 through Table V.53 compare the average LCC
savings and PBP at each efficiency level for the consumer subgroups
with similar metrics for the reduced consumer sample for all equipment
classes and representative units. In most cases, the average LCC
savings and PBP for small business and applications with high amount of
warm-air infiltration at the considered trial standard levels are not
substantially different from the average for all consumers. In those
cases where the results differ, the selected subgroups tend to have
greater benefits due to in the case of the small business subgroup:
higher electricity costs; and; in the case of the warm-air infiltration
subgroup: increased hours of operation.
Chapter 11 of the NOPR TSD presents the complete LCC and PBP
results for the subgroups.
Table V.51--Comparison of LCC Savings and PBP for Consumer Subgroups for Walk-In Doors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Reference Small business
Equipment class -----------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2022$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
DW.L.................................................... .............. .............. -1,106 .............. .............. -1,004
DW.M.................................................... .............. .............. -1,247 .............. .............. -1,206
NM.L.................................................... 724 723 307 1,287 1,287 1,072
NM.M.................................................... 203 86 -291 289 345 -5
NO.L.................................................... 1,194 1,192 932 1,761 1,761 1,610
NO.M.................................................... 306 113 -266 419 534 192
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
DW.L.................................................... .............. .............. 44.0 .............. .............. 29.1
DW.M.................................................... .............. .............. 99.1 .............. .............. 67.0
NM.L.................................................... 1.3 1.3 2.8 1.0 1.0 2.0
NM.M.................................................... 2.4 3.2 8.2 1.8 2.4 5.7
NO.L.................................................... 1.0 1.0 2.1 0.7 0.7 1.5
NO.M.................................................... 1.8 2.4 6.3 1.4 1.8 4.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost
--------------------------------------------------------------------------------------------------------------------------------------------------------
DW.L.................................................... .............. .............. 100 .............. .............. 100
DW.M.................................................... .............. .............. 100 .............. .............. 100
NM.L.................................................... 2 2 37 2 2 6
NM.M.................................................... 2 11 96 6 7 51
NO.L.................................................... 1 2 9 0 0 3
NO.M.................................................... 0 3 95 2 5 28
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 60824]]
Table V.52--Comparison of LCC Savings and PBP for Consumer Subgroups for Walk-In Panels
--------------------------------------------------------------------------------------------------------------------------------------------------------
Reference Small business
Equipment class -----------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings per ft\2\ (2022$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
PF.L.................................................... .............. .............. -1.61 .............. .............. -1.66
PS.L.................................................... .............. .............. -0.50 .............. .............. 0.17
PS.M.................................................... .............. .............. -2.33 .............. .............. -2.61
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
PF.L.................................................... .............. .............. 26.1 .............. .............. 17.4
PS.L.................................................... .............. .............. 10.1 .............. .............. 6.8
PS.M.................................................... .............. .............. 54.0 .............. .............. 33.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
PS.M.................................................... .............. .............. 95 .............. .............. 100
PS.L.................................................... .............. .............. 64 .............. .............. 41
PS.M.................................................... .............. .............. 100 .............. .............. 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.53--Comparison of LCC Savings and PBP for Consumer Subgroups for Walk-In Refrigeration Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
Reference Small businesses Warm air
Equipment class --------------------------------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2022$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I............................. 163 163 -5,218 256 256 -2,851 266 266 -5,138
DC.L.O............................. 237 172 -15,792 243 191 -2,603 271 226 -15,238
DC.M.I............................. 567 567 -2,047 763 763 -1,851 1,004 1,004 -1,932
DC.M.O............................. 101 136 -1,896 -8 34 -1,331 -136 -41 -1,055
SP.H.I............................. 124 124 103 124 124 103 180 180 167
SP.H.ID............................ 296 296 296 297 297 297 446 446 446
SP.H.O............................. 159 126 -53 159 125 -53 165 164 -3
SP.H.OD............................ 437 305 270 439 307 272 540 518 485
SP.L.I............................. 180 180 -1,575 180 180 -1,578 265 265 -1,461
SP.L.O............................. ........... ........... -1,278 ........... ........... -1,279 ........... ........... -1,121
SP.M.I............................. 114 103 -1,577 114 92 -1,576 198 183 -1,467
SP.M.O............................. 186 177 -1,116 186 177 -1,116 208 202 -898
UC.H............................... ........... ........... -152 ........... ........... -145 ........... ........... -141
UC.H.ID............................ 237 237 237 263 263 263 320 320 320
UC.L............................... 1,080 1,306 1,306 1,638 2,025 2,025 1,289 1,568 1,568
UC.M............................... 170 212 212 273 341 341 235 293 293
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I............................. 4.0 4.0 inf 2.0 2.0 inf 3.1 3.1 inf
DC.L.O............................. 1.4 3.6 inf 1.2 3.3 45.3 1.2 3.1 inf
DC.M.I............................. 3.4 3.4 inf 2.1 2.1 inf 2.4 2.4 inf
DC.M.O............................. 1.6 2.6 21.6 inf 3.0 22.2 inf 19.2 12.0
SP.H.I............................. 1.3 1.3 2.5 1.3 1.3 2.4 0.9 0.9 1.7
SP.H.ID............................ 1.7 1.7 1.7 1.7 1.7 1.7 1.2 1.2 1.2
SP.H.O............................. 0.4 2.9 9.0 0.4 2.9 9.1 0.4 2.5 7.0
SP.H.OD............................ 0.2 3.4 3.8 0.2 3.4 3.8 0.2 2.5 2.8
SP.L.I............................. 3.8 3.8 inf 3.8 3.8 inf 3.2 3.2 291.4
SP.L.O............................. ........... ........... 39.0 ........... ........... 39.1 ........... ........... 24.9
SP.M.I............................. 3.0 3.5 inf 3.0 3.7 inf 2.1 2.5 inf
SP.M.O............................. 0.9 1.2 50.8 0.9 1.1 50.7 0.8 1.0 22.9
UC.H............................... ........... ........... inf ........... ........... inf ........... ........... inf
UC.H.ID............................ 0.7 0.7 0.7 0.7 0.7 0.7 0.6 0.6 0.6
UC.L............................... 0.9 1.2 1.2 0.5 0.7 0.7 0.7 1.0 1.0
UC.M............................... 2.0 2.0 2.0 1.2 1.2 1.2 1.6 1.6 1.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.I............................. 11 11 100 2 2 100 5 5 100
DC.L.O............................. 0 8 100 0 4 100 0 5 100
DC.M.I............................. 1 1 100 0 0 100 0 0 100
DC.M.O............................. 0 1 96 23 23 95 38 29 85
SP.H.I............................. 2 2 3 2 2 3 0 0 1
SP.H.ID............................ 0 0 0 0 0 0 0 0 0
SP.H.O............................. 0 3 81 0 3 81 0 2 56
SP.H.OD............................ 0 4 13 0 4 13 0 2 5
SP.L.I............................. 7 7 100 7 7 100 4 4 100
SP.L.O............................. 0 0 100 0 0 100 0 0 100
SP.M.I............................. 4 5 100 4 5 100 1 2 100
[[Page 60825]]
SP.M.O............................. 0 0 100 0 0 100 0 0 100
UC.H............................... 0 0 61 0 0 47 0 0 41
UC.H.ID............................ 0 0 0 0 0 0 0 0 0
UC.L............................... 3 8 8 0 1 1 2 5 5
UC.M............................... 9 10 10 0 1 1 7 7 7
--------------------------------------------------------------------------------------------------------------------------------------------------------
c. Rebuttable Presumption Payback
As discussed in section IV.G of this document, EPCA establishes a
rebuttable presumption that an energy conservation standard is
economically justified if the increased purchase cost for a product
that meets the standard is less than three times the value of the
first-year energy savings resulting from the standard. In calculating a
rebuttable presumption payback period for each of the considered TSLs,
DOE used discrete values, and as required by EPCA, based the energy use
calculation on the DOE test procedure for walk-in coolers and freezers.
In contrast, the PBPs presented in section V.B.1.a of this document
were calculated using distributions that reflect the range of energy
use in the field.
Table V.54 presents the rebuttable-presumption payback periods for
the considered TSLs for walk-in coolers and freezers. While DOE
examined the rebuttable-presumption criterion, it considered whether
the standard levels considered for the NOPR are economically justified
through a more detailed analysis of the economic impacts of those
levels, pursuant to 42 U.S.C. 6295(o)(2)(B)(i), that considers the full
range of impacts to the consumer, manufacturer, Nation, and
environment. The results of that 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.
Table V.54--Rebuttable-Presumption Payback Periods for Walk-In Doors
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
DW.L............................................................ .............. .............. 65.7
DW.M............................................................ .............. .............. 109.1
NM.L............................................................ 1.6 1.6 3.3
NM.M............................................................ 2.6 3.7 9.1
NO.L............................................................ 1.2 1.2 2.6
NO.M............................................................ 2.0 2.8 7.0
----------------------------------------------------------------------------------------------------------------
Table V.55--Rebuttable-Presumption Payback Periods for Walk-In Panels
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
PF.L............................................................ .............. .............. 0.7
PS.L............................................................ .............. .............. 0.6
PS.M............................................................ .............. .............. 2.2
----------------------------------------------------------------------------------------------------------------
Table V.56--Rebuttable-Presumption Payback Periods for Refrigeration Systems
----------------------------------------------------------------------------------------------------------------
TSL
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
DC.L.I.......................................................... * Inf inf inf
DC.L.O.......................................................... 1.5 6.1 inf
DC.M.I.......................................................... inf inf inf
DC.M.O.......................................................... 1.5 3.4 inf
SP.H.I.......................................................... 15.0 15.0 18.8
SP.H.ID......................................................... 4.2 4.2 4.2
SP.H.O.......................................................... 0.3 3.5 12.2
SP.H.OD......................................................... 0.2 3.5 3.9
SP.L.I.......................................................... 12.7 12.7 inf
SP.L.O.......................................................... .............. .............. inf
SP.M.I.......................................................... 6.1 10.9 inf
SP.M.O.......................................................... 1.0 1.4 inf
UC.H............................................................ .............. .............. inf
UC.H.ID......................................................... 0.8 0.8 0.8
UC.L............................................................ 0.8 1.1 1.1
[[Page 60826]]
UC.M............................................................ 2.4 2.5 2.5
----------------------------------------------------------------------------------------------------------------
* Indicates that the estimated payback results are negative. This is the results of projected negative operating
cost savings at the proposed TSL, resulting in overall negative payback periods.
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of amended energy
conservation standards on manufacturers of walk-ins. The following
section describes the expected impacts on manufacturers at each
considered TSL. Chapter 12 of the NOPR TSD explains the analysis in
further detail.
a. Industry Cash Flow Analysis Results
In this section, DOE provides GRIM results from the analysis, which
examines changes in the industry that would result from a standard. The
following tables summarize the estimated financial impacts (represented
by changes in INPV) of potential amended energy conservation standards
on manufacturers of walk-ins, as well as the conversion costs that DOE
estimates manufacturers of walk-ins would incur at each TSL.
The impact of potential amended energy conservation standards were
analyzed under two scenarios: (1) the preservation of gross margin
percentage; and (2) the preservation of operating profit, as discussed
in section IV.J.2.d of this document. The preservation of gross margin
percentages applies a ``gross margin percentage'' of 31 percent for
display doors, 33 percent for non-display doors, 24 percent for panels,
and 26 percent for refrigeration systems, across all efficiency
levels.\82\ This scenario assumes that a manufacturer's per-unit dollar
profit would increase as MPCs increase in the standards cases and often
represents the upper-bound to industry profitability under potential
amended energy conservation standards.
---------------------------------------------------------------------------
\82\ The gross margin percentages of 31 percent, 33 percent, 24
percent, and 26 percent are based on manufacturer markups of 1.45,
1.50, 1.32, and 1.35, respectively.
---------------------------------------------------------------------------
The preservation of operating profit scenario reflects
manufacturers' concerns about their inability to maintain margins as
MPCs increase to reach more-stringent efficiency levels. In this
scenario, while manufacturers make the necessary investments required
to convert their facilities to produce compliant equipment, operating
profit does not change in absolute dollars and decreases as a
percentage of revenue. The preservation of operating profit scenario
typically results in the lower (or more severe) bound to impacts of
potential amended standards on industry.
Each of the modeled scenarios results in a unique set of cash flows
and corresponding INPV for each TSL. INPV is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2023-2056). The ``change in INPV'' results refer to
the difference in industry value between the no-new-standards case and
standards case at each TSL. To provide perspective on the short-run
cash flow impact, DOE includes a comparison of free cash flow between
the no-new-standards case and the standards case at each TSL in the
year before amended standards would take effect. This figure provides
an understanding of the magnitude of the required conversion costs
relative to the cash flow generated by the industry in the no-new-
standards case.
Conversion costs are one-time investments for manufacturers to
bring their manufacturing facilities and product designs into
compliance with potential amended standards. As described in section
IV.J.2.c of this document, conversion cost investments occur between
the year of publication of the final rule and the year by which
manufacturers must comply with the new standard. The conversion costs
can have a significant impact on the short-term cash flow on the
industry and generally result in lower free cash flow in the period
between the publication of the final rule and the compliance date of
potential amended standards. Conversion costs are independent of the
manufacturer markup scenarios and are not presented as a range in this
analysis.
Table V.57, Table V.58, Table V.59, and Table V.60 show the MIA
results for each TSL for walk-in display door, non-display door, panel,
and refrigeration system industries, respectively.
Doors
Display Doors
Table V.57--Manufacturer Impact Analysis Results for Walk-In Display Doors
----------------------------------------------------------------------------------------------------------------
No-new-
Unit standards TSL 1 TSL 2 TSL 3
case
----------------------------------------------------------------------------------------------------------------
INPV........................... 2022$ Million.... 278.0 278.0 278.0 215.5 to 355.6.
Change in INPV *............... %................ .......... .......... .......... (22.5) to 27.9.
Free Cash Flow * (2026)........ 2022$ Million.... 21.7 21.7 21.7 12.8.
Change in Free Cash Flow * %................ .......... .......... .......... (41.0).
(2026).
Product Conversion Costs....... 2022$ Million.... .......... .......... .......... 24.0
Capital Conversion Costs....... 2022$ Million.... .......... .......... .......... 1.5.
Total Conversion Costs......... 2022$ Million.... .......... .......... .......... 25.5.
----------------------------------------------------------------------------------------------------------------
* Parentheses (-) negative values.
At TSL 1 and TSL 2, the standard for all walk-in display door
equipment classes (DW.L, DW.M) are set to the baseline efficiency level
(EL 0). As a result, there are no changes to INPV, no changes in
industry free cash flow, and no conversion costs.
[[Page 60827]]
At TSL 3, the standard represents the max-tech energy efficiency
for all equipment classes. The change in INPV is expected to range from
-22.5 to 27.9 percent. At this level, free cash flow is estimated to
decrease by 41.0 percent compared to the no-new-standards case value of
$21.7 million in the year 2026, the year before the standards year. DOE
estimates that no display door shipments currently meet the max-tech
efficiency levels.
DOE expects display doors would require the use of vacuum-insulated
glass as a substitute for the prescriptive minimum design of double-
pane or triple-pane insulated glass packs for medium-temperature doors
(DW.M) and low-temperature doors (DW.L), respectively. For the 10 OEMs
that manufacture walk-in display doors, implementing vacuum-insulated
glass would require significant engineering resources and testing time
to ensure adequate durability of their doors in all commercial
settings. In interviews, manufacturers emphasized that there are
currently a very limited number of suppliers of vacuum-insulated glass.
Door manufacturers expressed concerns that the 3-year conversion period
between the publication of the final rule and the compliance date of
the amended energy conservation standard might be insufficient to
design and test a full portfolio of vacuum-insulated doors that meet
the max-tech efficiencies and maintain their internal metrics over the
door lifetime. Of the 10 OEMs that manufacture walk-in display doors,
four are small, domestic businesses. DOE estimates capital conversion
costs of $1.5 million and product conversion costs of $24.0 million.
Conversion costs total $25.5 million.
At TSL 3, the shipment-weighted average MPC for all display doors
is expected to increase by 63.6 percent relative to the no-new-
standards case shipment-weighted average MPC for all display doors in
2027. In the preservation of gross margin percentage scenario, the
increase in cashflow from the higher MSP outweighs the $25.5 million in
conversion costs, causing a positive change in INPV at TSL 3 under this
scenario. Under the preservation of operating profit scenario,
manufacturers earn the same per-unit operating profit as would be
earned in the no-new-standards case, but manufacturers do not earn
additional profit from their investments. In this scenario, the
manufacturer markup decreases in 2028, the year after the analyzed
compliance year. This reduction in the manufacturer markup and the
$25.5 million in conversion costs incurred by manufacturers cause a
large negative change in INPV at TSL 3 under the preservation of
operating profit scenario. See section IV.J.2.d of this document or
chapter 12 of the NOPR TSD for additional details about the
manufacturer markup scenarios.
Non-Display Doors
Table V.58--Manufacturer Impact Analysis Results for Walk-In Non-Display Doors
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-new-
Unit standards TSL 1 TSL 2 TSL 3
case
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV............................. 2022$ Million....... 536.7 522.6 to 529.4............. 511.2 to 522.5............ 485.1 to 549.4.
Change in INPV *................. %................... .......... (2.6) to (1.4)............. (4.8) to (2.6)............ (9.6) to 2.4.
Free Cash Flow * (2026).......... 2022$ Million....... 42.6 35.7....................... 30.0...................... 22.5.
Change in Free Cash Flow * (2026) %................... .......... (16.1)..................... (29.5).................... (47.1)
Product Conversion Costs......... 2022$ Million....... .......... 2.4........................ 3.8....................... 15.8.
Capital Conversion Costs......... 2022$ Million....... .......... 13.4....................... 25.0...................... 32.5.
Total Conversion Costs........... 2022$ Million....... .......... 15.8....................... 28.9...................... 48.3.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Parentheses (-) negative values.
At TSL 1, the standard represents a combination of efficiency
levels where NPV at a 7-percent discount rate is maximized.\83\ The
change in INPV is expected to range from -2.6 to -1.4 percent. At this
level, free cash flow is estimated to decrease by 16.1 percent compared
to the no-new-standards case value of $42.6 million in the year 2026,
the year before the standards year.
---------------------------------------------------------------------------
\83\ As discussed in section IV.E.1 of this document, the TSL
construction has an additional constraint that improvements to
insulation are harmonized across non-display doors and structural
panels to avoid a circumstance where DOE would propose a standard
where one component would require increased insulation thickness,
but not the other. Aligning the insulation thickness of non-display
doors and panels avoids a potential unintended consequence where the
installation of replacement non-display doors would trigger the
replacement of some, or all, of the attached WICF enclosure (panels)
because the thickness of the components do not match.
---------------------------------------------------------------------------
DOE expects that all non-display door equipment classes (NM.L,
NM.M, NO.L, NO.M) would require anti-sweat heater controls. For low-
temperature classes (NM.L, NO.L), DOE expects that manufacturers would
also need to incorporate improved framing systems and reduced anti-
sweat heat. For non-display door medium temperature classes (NM.M,
NO.M), TSL 1 corresponds to EL 1. For non-display door low-temperature
classes (NM.L, NO.L), TSL 1 corresponds to EL 3. Currently,
approximately 61 percent of non-display door shipments meet the TSL 1
efficiencies. Capital conversion costs may be necessary to purchase
additional foaming equipment to incorporate improved frame designs for
low-temperature non-display doors, which account for approximately 32
percent of non-display door shipments. Product conversion costs may be
necessary to update and test new non-display door designs. DOE
estimates capital conversion costs of $13.4 million and product
conversion costs of $2.4 million. Conversion costs total $15.8 million.
At TSL 1, the shipment-weighted average MPC for non-display doors
is expected to increase by 1.6 percent relative to the no-new-standards
case shipment-weighted average MPC for non-display doors in 2027. In
the preservation of gross margin percentage scenario, the minor
increase in cashflow from the higher MSP is slightly outweighed by the
$15.8 million in conversion costs, causing a slightly negative change
in INPV at TSL 1 under this scenario. Under the preservation of
operating profit scenario, manufacturers earn the same per-unit
operating profit as would be earned in the no-new-standards case, but
manufacturers do not earn additional profit from their investments. In
this scenario, the manufacturer markup decreases in 2028, the year
after the analyzed compliance year. This reduction in the manufacturer
markup and the $15.8 million in conversion costs incurred by
manufacturers cause a slightly negative change in INPV at TSL 1 under
the preservation of operating profit scenario.
At TSL 2, the standard represents a combination of efficiency
levels for all
[[Page 60828]]
representative units where FFC is maximized while constrained to a
positive NPV at a 7-percent discount rate.\84\ The change in INPV is
expected to range from -4.8 to -2.6 percent. At this level, free cash
flow is estimated to decrease by 29.5 percent compared to the no-new-
standards case value of $42.6 million in the year 2026, the year before
the standards year.
---------------------------------------------------------------------------
\84\ As with TSL 1, DOE applied the additional constraint that
improvements to insulation are harmonized across non-display doors
and panels to avoid a circumstance where DOE would propose a
standard where one component would require increased insulation
thickness, but not the other.
---------------------------------------------------------------------------
At TSL 2, DOE expects that all non-display doors (NM.L, NM.M, NO.L,
NO.M) would require anti-sweat heater controls, improved framing
systems and reduced anti-sweat heat. For non-display door equipment
classes, TSL 2 corresponds to EL 3. Currently, approximately 12 percent
of non-display door shipments meet TSL 2 efficiencies. Capital
conversion costs may be necessary to purchase additional foaming
equipment to incorporate improved frame designs for all non-display
doors. Product conversion costs may be necessary to update and test new
non-display door designs. DOE estimates capital conversion costs of
$25.0 million and product conversion costs of $3.8 million. Conversion
costs total $28.9 million.
At TSL 2, the shipment-weighted average MPC for non-display doors
is expected to increase by 2.8 percent relative to the no-new-standards
case shipment-weighted average MPC for non-display doors in 2027. In
the preservation of gross margin percentage scenario, the minor
increase in cashflow from the higher MSP is slightly outweighed by the
$28.9 million in conversion costs, causing a slightly negative change
in INPV at TSL 2 under this scenario. Under the preservation of
operating profit scenario, manufacturers earn the same per-unit
operating profit as would be earned in the no-new-standards case, but
manufacturers do not earn additional profit from their investments. In
this scenario, the manufacturer markup decreases in 2028, the year
after the analyzed compliance year. This reduction in the manufacturer
markup and the $28.9 million in conversion costs incurred by
manufacturers cause a slightly negative change in INPV at TSL 2 under
the preservation of operating profit scenario.
At TSL 3, the standard represents the max-tech efficiency levels
for all equipment classes. The change in INPV is expected to range from
-9.6 to 2.4 percent. At this level, free cash flow is estimated to
decrease by 47.1 percent compared to the no-new-standards case value of
$42.6 million in the year 2026, the year before the standards year.
The design options DOE analyzed at TSL 3 for non-display doors
included anti-sweat heater controls, improved framing systems, reduced
anti-sweat heat, and insulation thickness of at least 6 inches. DOE
estimates that no non-display door shipments currently meet the max-
tech efficiency levels. For the 43 OEMs that manufacture walk-in non-
display doors, increasing insulation thickness from the assumed
baseline thickness of 3.5 inches for medium-temperature (NM.M, NO.M)
and 4 inches for low-temperature (NM.L, NO.L) non-display doors to 6
inches would require purchasing new foaming equipment since most
manufacturers are only able to manufacture non-display doors up to 5
inches thick. Additionally, non-display door manufacturers were
concerned about the flow of foam and the curing time of foam at max-
tech. New foaming equipment to accommodate 6-inch non-display doors
would require significant capital investment and is a key driver of
capital conversion costs. Of the 43 non-display door OEMs identified,
40 are small, domestic businesses. DOE estimates capital conversion
costs of $32.5 million and product conversion costs of $15.8 million.
Conversion costs total $48.3 million.
At TSL 3, the shipment-weighted average MPC for all non-display
doors is expected to increase by 15.8 percent relative to the no-new-
standards case shipment-weighted average MPC for non-display doors in
2027. In the preservation of gross margin percentage scenario, the
increase in cashflow from the higher MSP slightly outweighs the $48.3
million in conversion costs, causing a positive change in INPV at TSL 3
under this scenario. Under the preservation of operating profit
scenario, manufacturers earn the same per-unit operating profit as
would be earned in the no-new-standards case, but manufacturers do not
earn additional profit from their investments. In this scenario, the
manufacturer markup decreases in 2028, the year after the analyzed
compliance year. This reduction in the manufacturer markup and the
$48.3 million in conversion costs incurred by manufacturers cause a
negative change in INPV at TSL 3 under the preservation of operating
profit scenario.
DOE seeks comments, information, and data on the capital conversion
costs and product conversion costs estimated for each efficiency level
and TSL for walk-in display and non-display doors. See chapter 12 of
the NOPR TSD for the estimated conversion costs for each analyzed
efficiency level.
Panels
Table V.59--Manufacturer Impact Analysis Results for Walk-In Panels
----------------------------------------------------------------------------------------------------------------
No-new-
Unit standards TSL 1 TSL 2 TSL 3
case
----------------------------------------------------------------------------------------------------------------
INPV........................... 2022$ Million.... 875.2 875.2 875.2 676.5 to 787.4.
Change in INPV *............... %................ .......... .......... .......... (22.7) to (10.0).
Free Cash Flow * (2026)........ 2022$ Million.... 78.6 78.6 78.6 (22.0).
Change in Free * Cash Flow * %................ .......... .......... .......... (128.0).
(2026).
Product Conversion Costs....... 2022$ Million.... .......... .......... .......... 74.5.
Capital Conversion Costs....... 2022$ Million.... .......... .......... .......... 166.8.
Total Conversion Costs......... 2022$ Million.... .......... .......... .......... 241.3.
----------------------------------------------------------------------------------------------------------------
* Parentheses (-) negative values.
At TSL 1 and TSL 2, the standard for all walk-in panel equipment
classes are set to the baseline efficiency level (EL 0). As a result,
there are no changes to INPV, no changes in industry free cash flow,
and no conversion costs.
At TSL 3, the standard represents the max-tech energy efficiency
for all equipment classes. The change in INPV is expected to range from
-22.7 to -10.0 percent. At this level, free cash flow is estimated to
decrease by 128.0
[[Page 60829]]
percent compared to the no-new-standards case value of $78.6 million in
the year 2026, the year before the standards year. Currently,
approximately 3 percent of domestic panel shipments meet the
efficiencies required at TSL 3.
The design options DOE analyzed at max-tech include increasing
insulation thickness to 6 inches across all equipment classes. At this
level, DOE assumes all manufacturers will need to purchase new foaming
equipment. Increasing the insulation thickness for all panel equipment
classes to 6 inches would require significant capital investment. Like
non-display doors, most manufacturers are currently able to manufacture
panels up to 5 inches thick. A standard level necessitating 6-inch
panels would likely require new, costly foaming equipment for all
manufacturers. Additionally, DOE estimates that every additional inch
of foam increases panel cure times by roughly 10 minutes, which means
that manufacturers would likely need to purchase additional equipment
to maintain existing throughput. Some OEMs may need to invest in
additional manufacturing space to accommodate the extra foaming
stations. Of the 42 walk-in panel OEMs, 38 OEMs are small, domestic
businesses. In interviews, manufacturers expressed concern about
industry's ability to source the necessary foaming equipment to
maintain existing production capacity within the 3-year compliance
period due to the long lead times and limited number of foam fixture
suppliers. DOE estimates capital conversion costs of $166.8 million and
product conversion costs of $74.5 million. Conversion costs total
$241.3 million.
At TSL 3, the large conversion costs result in a free cash flow
dropping below zero in the years before the standards year. The
negative free cash flow calculation indicates manufacturers may need to
access cash reserves or outside capital to finance conversion efforts.
At TSL 3, the shipment-weighted average MPC for all panels is
expected to increase by 17.4 percent relative to the no-new-standards
case shipment-weighted average MPC for all panels in 2027. In the
preservation of gross margin percentage scenario, the increase in
cashflow from the higher MSP is outweighed by the $241.3 million in
conversion costs, causing a negative change in INPV at TSL 3 under this
scenario. Under the preservation of operating profit scenario,
manufacturers earn the same per-unit operating profit as would be
earned in the no-new-standards case, but manufacturers do not earn
additional profit from their investments. In this scenario, the
manufacturer markup decreases in 2028, the year after the analyzed
compliance year. This reduction in the manufacturer markup and the
$241.3 million in conversion costs incurred by manufacturers cause a
large negative change in INPV at TSL 3 under the preservation of
operating profit scenario.
DOE seeks comments, information, and data on the capital conversion
costs and product conversion costs estimated for each efficiency level
and TSL for walk-in panels. See chapter 12 of the NOPR TSD for the
estimated conversion costs for each analyzed efficiency level.
Refrigeration Systems
Table V.60--Manufacturer Impact Analysis Results for Walk-In Refrigeration Systems
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-new-
Unit standards TSL 1 TSL 2 TSL 3
case
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV............................. 2022$ Million....... 490.1 447.2 to 453.0............. 442.2 to 452.2............ 330.5 to 456.2.
Change in INPV *................. %................... .......... (8.7) to (7.6)............. (9.8) to (7.7)............ (32.6) to 11.5.
Free Cash Flow (2026)............ 2022$ Million....... 44.8 21.7....................... 20.7...................... 7.3.
Change in Free Cash Flow (2026) * %................... .......... (51.6)..................... (53.7).................... (83.7).
Product Conversion Costs......... 2022$ Million....... .......... 25.3....................... 28.0...................... 47.1.
Capital Conversion Costs......... 2022$ Million....... .......... 32.1....................... 32.1...................... 47.5.
Total Conversion Costs........... 2022$ Million....... .......... 57.4....................... 60.1...................... 94.6.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Parentheses (-) negative values.
At TSL 1, the standard represents a combination of efficiency
levels where NPV at a 7-percent discount rate is maximized. The change
in INPV is expected to range from -8.7 to -7.6 percent. At this level,
free cash flow is estimated to decrease by 51.6 percent compared to the
no-new-standards case value of $44.8 million in the year 2026, the year
before the standards year. Currently, DOE has no evidence of
significant shipments meeting efficiency levels above the baseline
efficiency level (EL 0).
DOE expects that at TSL 1, low- and medium-temperature indoor
dedicated condensing system equipment classes \85\ would generally
require larger condenser coils; low- and medium-temperature outdoor
dedicated condensing system equipment classes would generally require
self-regulating crank case heater controls with a temperature switch;
low-temperature outdoor dedicated condensing systems would also
generally require electronically commutated variable-speed condenser
fan motors; some low- and medium-temperature single-packaged dedicated
system equipment classes would require variable-speed evaporator fans;
lower-capacity low- and medium-temperature single-packaged dedicated
condensing units would generally require propane compressors; high-
temperature outdoor single-packaged dedicated condensing systems would
generally require self-regulating crank case heater controls with a
temperature switch and variable-speed condenser fans; high-temperature
indoor single-packaged dedicated condensing systems would generally
require up to 1.5 inches of thermal insulation. DOE expects that at TSL
1, most unit cooler equipment classes would incorporate improved
evaporator coil designs. See Table IV.28 for the efficiency levels by
representative unit for TSL 1.
---------------------------------------------------------------------------
\85\ Dedicated condensing system equipment classes include
dedicated condensing units, matched-pair refrigeration systems
(consisting of a paired dedicated condensing unit and unit cooler)
and single-packaged dedicated systems.
---------------------------------------------------------------------------
Capital conversion costs are driven by incorporating design options
such as larger condenser coils, improved evaporator coils, and/or
ambient subcooling circuits, which would likely necessitate new tooling
for updated baseplate designs across some refrigeration system
capacities and equipment classes. Implementing these design options
would also require notable engineering resources and testing time, as
manufacturers redesign models. Manufacturers would also need to
qualify, source, and test new high-
[[Page 60830]]
efficiency components. DOE estimates capital conversion costs of $32.1
million and product conversion costs of $25.3 million. Conversion costs
total $57.4 million.
At TSL 1, the shipment-weighted average MPC for all refrigeration
systems is expected to increase by 1.5 percent relative to the no-new-
standards case shipment-weighted average MPC for all refrigeration
systems in 2027. In the preservation of gross margin percentage
scenario, the minor increase in cashflow from the higher MSP is
slightly outweighed by the $57.4 million in conversion costs, causing a
slightly negative change in INPV at TSL 1 under this scenario. Under
the preservation of operating profit scenario, manufacturers earn the
same per-unit operating profit as would be earned in the no-new-
standards case, but manufacturers do not earn additional profit from
their investments. In this scenario, the manufacturer markup decreases
in 2028, the year after the analyzed compliance year. This reduction in
the manufacturer markup and the $57.4 million in conversion costs
incurred by manufacturers cause a slightly negative change in INPV at
TSL 1 under the preservation of operating profit scenario.
At TSL 2, the standard represents a combination efficiency levels
where FFC is maximized while constrained to a positive NPV at a 7-
percent discount rate. The change in INPV is expected to range from -
9.8 to -7.7 percent. At this level, free cash flow is estimated to
decrease by 53.7 percent compared to the no-new-standards case value of
$44.8 million in the year 2026, the year before the standards year.
At TSL 2, DOE expects that manufacturers would need to incorporate
similar design options as TSL 1. In addition to the design options
analyzed at TSL 1, DOE expects that some low-temperature and indoor
medium-temperature dedicated condensing system equipment classes would
require larger condenser coils and/or ambient subcooling circuits. DOE
expects that more medium-temperature outdoor dedicated condensing
system equipment classes would require electronically commutated
condenser fan motors and may require ambient subcooling circuits. DOE
also expects that more low- and medium-temperature single-packaged
dedicated system equipment classes would require larger evaporator
coils and variable-speed evaporator fans. Low-temperature single-
packaged dedicated system equipment classes would also generally
require thermal insulation up to 4 inches in thickness (i.e.,
SP.M.O.002, SP.M.I.002). High-temperature single-packaged dedicated
condensing systems would generally require up to 1.5 inches of thermal
insulation, electronically commutated variable-speed condenser fan
motors, and ambient subcooling. DOE expects that at TSL 2, more unit
cooler equipment classes would incorporate the max-tech design options
(i.e., all equipment classes except for high-temperature non-ducted
unit coolers, which would generally require evaporator coils 4 rows
deep at TSL 2). See Table IV.26 for the efficiency levels by
representative unit for TSL 2.
DOE expects manufacturers would incur similar capital conversion
costs at TSL 2 and TSL 1 since most manufacturers could rely on similar
tooling investments at both TSLs. DOE expects manufacturers would incur
slightly more conversion costs compared to TSL 1 as they update and
test more refrigeration system capacities across their portfolio. DOE
estimates capital conversion costs of $32.1 million and product
conversion costs of $28.0 million. Conversion costs total $60.1
million.
At TSL 2, the shipment-weighted average MPC for all refrigeration
systems is expected to increase by 2.6 percent relative to the no-new-
standards case shipment-weighted average MPC for all refrigeration
systems in 2027. In the preservation of gross margin percentage
scenario, the increase in cashflow from the higher MSP is slightly
outweighed by the $60.1 million in conversion costs, causing a slightly
negative change in INPV at TSL 2 under this scenario. Under the
preservation of operating profit scenario, manufacturers earn the same
per-unit operating profit as would be earned in the no-new-standards
case, but manufacturers do not earn additional profit from their
investments. In this scenario, the manufacturer markup decreases in
2028, the year after the analyzed compliance year. This reduction in
the manufacturer markup and the $60.1 million in conversion costs
incurred by manufacturers cause a negative change in INPV at TSL 2
under the preservation of operating profit scenario.
At TSL 3, the standard represents the max-tech efficiency for all
equipment classes. The change in INPV is expected to range from -32.6
to 11.5 percent. At this level, free cash flow is estimated to decrease
by 83.7 percent compared to the no-new-standards case value of $44.8
million in the year 2026, the year before the standards year.
At TSL 3, all manufacturers would need to incorporate all analyzed
design options to meet the efficiencies required. DOE expects that
medium- and low-temperature dedicated condensing system equipment
classes would require larger condenser coils, variable capacity
compressors, and electronically commutated variable-speed condenser fan
motors. Additionally, low- and medium-temperature outdoor dedicated
condensing system equipment classes would generally require self-
regulating crank case heater controls with a temperature switch, and
ambient subcooling circuits. DOE anticipates that low- and medium-
temperature single-packaged dedicated system equipment classes would
also require larger evaporator coils, variable speed evaporator fans,
and thermal insulation up to 4 inches in thickness. DOE expects that
lower-capacity low- and medium-temperature single-packaged dedicated
condensing units would require propane compressors. DOE expects that
high-temperature dedicated condensing system equipment classes would
require the same design options as medium- and low-temperature
dedicated condensing systems except for larger condensing coils and
variable capacity compressors. Additionally, DOE expects that high-
temperature single-packaged dedicated condensing systems would require
up to 1.5 inches of thermal insulation and would not require larger
evaporator coils or variable speed evaporator fans. DOE anticipates
that lower-capacity low- and medium-temperature unit cooler equipment
classes would require evaporator coils 4 rows deep at TSL 3. Finally,
DOE anticipates that higher-capacity low- and medium-temperature unit
cooler equipment classes and all high-temperature unit cooler equipment
classes would require evaporator coils 5 rows deep at TSL 3. See Table
IV.24 for the efficiency levels by representative unit for TSL 3.
Currently, DOE has no evidence of significant shipments meeting the
max-tech levels. As such, DOE assumes that all manufacturers would need
to redesign their refrigeration system models to incorporate a range of
design options to meet TSL 3 efficiencies. Capital conversion costs are
driven by incorporating design options such as larger condenser coils,
improved evaporator coils, and/or ambient subcooling circuits, which
would likely necessitate new tooling for updated baseplate designs
across the full range of refrigeration system capacities and equipment
classes. Implementing these design options would also require notable
engineering resources and testing time, as manufacturers redesign
[[Page 60831]]
models and potentially increase the footprint of refrigeration systems
to accommodate larger condensers and/or evaporators.
Manufacturers would also need to qualify, source, and test new
high-efficiency components. For medium- and low-temperature dedicated
condensing system equipment classes that would likely require variable
capacity compressors to meet the max-tech levels, manufacturers could
face challenges sourcing variable capacity compressors across their
portfolio of capacity offerings since the availability of variable
capacity compressors for walk-in applications is limited. At the time
of this NOPR publication, the few variable capacity compressor product
lines DOE identified are not advertised for the North American market.
Additionally, the identified product lines may not have a sufficient
range of available compressor capacities to replace compressors in all
walk-in applications. DOE estimates capital conversion costs of $47.5
million and product conversion costs of $47.1 million. Conversion costs
total $94.6 million.
At TSL 3, the shipment-weighted average MPC for all refrigeration
systems is expected to increase by 55.5 percent relative to the no-new-
standards case shipment-weighted average MPC for all refrigeration
systems in 2027. In the preservation of gross margin percentage
scenario, the increase in cashflow from the higher MSP outweighs the
$94.6 million in conversion costs, causing a positive change in INPV at
TSL 3 under this scenario. Under the preservation of operating profit
scenario, manufacturers earn the same per-unit operating profit as
would be earned in the no-new-standards case, but manufacturers do not
earn additional profit from their investments. In this scenario, the
manufacturer markup decreases in 2028, the year after the analyzed
compliance year. This reduction in the manufacturer markup and the
$94.6 million in conversion costs incurred by manufacturers cause a
significant negative change in INPV at TSL 3 under the preservation of
operating profit scenario.
DOE seeks comments, information, and data on the capital conversion
costs and product conversion costs estimated for each TSL for walk-in
refrigeration systems.
b. Direct Impacts on Employment
To quantitatively assess the potential impacts of amended energy
conservation standards on direct employment in the walk-in industry,
DOE used the GRIM to estimate the domestic labor expenditures and
number of direct employees in the no-new-standards case and in each of
the standards cases during the analysis period. DOE calculated these
values using statistical data from the 2021 ASM,\86\ BLS employee
compensation data,\87\ results of the engineering analysis, and
manufacturer interviews.
---------------------------------------------------------------------------
\86\ U.S. Census Bureau, Annual Survey of Manufactures.
``Summary Statistics for Industry Groups and Industries in the U.S.
(2021).'' Available at: www.census.gov/data/tables/time-series/econ/asm/2018-2021-asm.html (Last accessed February 14, 2023).
\87\ U.S. Bureau of Labor Statistics. Employer Costs for
Employee Compensation. March 17, 2023. Available at: www.bls.gov/news.release/pdf/ecec.pdf (Last accessed April 12, 2023).
---------------------------------------------------------------------------
Labor expenditures related to product manufacturing depend on the
labor intensity of the product, the sales volume, and an assumption
that wages remain fixed in real terms over time. The total labor
expenditures in each year are calculated by multiplying the total MPCs
by the labor percentage of MPCs. The total labor expenditures in the
GRIM were then converted to total production employment levels by
dividing production labor expenditures by the average fully burdened
wage multiplied by the average number of hours worked per year per
production worker. To do this, DOE relied on the ASM inputs: Production
Workers Annual Wages, Production Workers Annual Hours, Production
Workers for Pay Period, and Number of Employees. DOE also relied on the
BLS employee compensation data to determine the fully burdened wage
ratio. The fully burdened wage ratio factors in paid leave,
supplemental pay, insurance, retirement and savings, and legally
required benefits.
The number of production employees is then multiplied by the U.S.
labor percentage to convert total production employment to total
domestic production employment. The U.S. labor percentage represents
the industry fraction of domestic manufacturing production capacity for
the covered equipment. This value is derived from manufacturer
interviews, equipment database analysis, and publicly available
information. DOE estimates that approximately 90 percent of doors, 95
percent of panels, and 70 percent of refrigeration systems are
manufactured domestically.
The domestic production employees estimate covers production line
workers, including line supervisors, who are directly involved in
fabricating and assembling products within the OEM facility. Workers
performing services that are closely associated with production
operations, such as materials handling tasks using forklifts, are also
included as production labor. DOE's estimates only account for
production workers who manufacture the specific equipment covered by
this proposed rulemaking.
Non-production workers account for the remainder of the direct
employment figure. The non-production employees estimate covers
domestic workers who are not directly involved in the production
process, such as sales, engineering, human resources, and management.
Using the amount of domestic production workers calculated above, non-
production domestic employees are extrapolated by multiplying the ratio
of non-production workers in the industry compared to production
employees. DOE assumes that this employee distribution ratio remains
constant between the no-new-standards case and standards cases.
In evaluating the impact of energy efficiency standards on
employment, DOE performed separate analyses on all three walk-in
component manufacturer industries: doors, panels, and refrigeration
systems.
Using the GRIM, DOE estimates in the absence of amended energy
conservation standards there would be 4,351 domestic workers for walk-
in doors, 7,534 domestic workers for walk-in panels, and 877 domestic
workers for walk-in refrigeration systems in 2027. Table V.61, Table
V.62, and Table V.63 show the range of the impacts of potential amended
energy conservation standards on U.S. manufacturing employment in the
door, panel, and refrigeration systems markets, respectively.
[[Page 60832]]
Table V.61--Direct Employment Impacts for Domestic Walk-In Door Manufacturers in 2027
----------------------------------------------------------------------------------------------------------------
Trial standard levels
No-new-standards --------------------------------------------------------
case 1 2 3
----------------------------------------------------------------------------------------------------------------
Direct Employment in 2027 4,351 4,434 4,526 4,710
(Production Workers + Non-
Production Workers)................
Potential Changes in Direct ................. (3,193) to 83 (3,193) to 175 (3,193) to 359
Employment in 2027 *...............
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses denote negative values.
Table V.62--Direct Employment Impacts for Domestic Walk-In Panel Manufacturers in 2027
----------------------------------------------------------------------------------------------------------------
Trial standard levels
No-new-standards --------------------------------------------------------
case 1 2 3
----------------------------------------------------------------------------------------------------------------
Direct Employment in 2027 7,534 7,534 7,534 7,689
(Production Workers + Non-
Production Workers)................
Potential Changes in Direct ................. ................. ................. (5,529) to 155
Employment in 2027 *...............
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses denote negative values.
Table V.63--Direct Employment Impacts for Domestic Walk-In Refrigeration System Manufacturers in 2027
----------------------------------------------------------------------------------------------------------------
Trial standard levels
No-new-standards --------------------------------------------------------
case 1 2 3
----------------------------------------------------------------------------------------------------------------
Direct Employment in 2027 877 894 905 958
(Production Workers + Non-
Production Workers)................
Potential Changes in Direct ................. (644) to 17 (644) to 28 (644) to 81
Employment in 2027 *...............
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses denote negative values.
The direct employment impacts shown in Table V.61 through Table
V.63 represent the potential domestic employment changes that could
result following the compliance date of amended energy conservation
standards. The upper bound estimate corresponds to the change in the
number of domestic workers that would result from amended energy
conservation standards if manufacturers continue to produce the same
scope of covered equipment within the United States after compliance
takes effect. To establish a conservative lower bound, DOE assumes all
manufacturers would shift production to foreign countries with lower
costs of labor.
Additional detail on the analysis of direct employment can be found
in chapter 12 of the NOPR TSD. Additionally, the employment impacts
discussed in this section are independent of the employment impacts
from the broader U.S. economy, which are documented in chapter 16 of
the NOPR TSD.
c. Impacts on Manufacturing Capacity
Doors
Display Doors
In interviews, display door manufacturers indicated that
implementing vacuum-insulated glass across all equipment classes and
configurations would require significant engineering resources and
testing time to ensure adequate durability in all commercial settings.
Manufacturers also emphasized that there are currently a very limited
number of suppliers of vacuum-insulated glass. In interviews,
manufacturers expressed concerns that the 3-year time period between
the announcement of the final rule and the compliance date of the
amended energy conservation standard might be insufficient to design
and test a full portfolio of new doors.
Non-Display Doors
The production of non-display doors is very similar to the
production of panels and faces the same capacity challenges as panels,
which is discussed in the following paragraphs. As indicated in the
panel discussion, DOE does not anticipate capacity constraints at a
standard that moves manufacturers to 5 inches of thickness.
DOE seeks comment on whether manufacturers expect manufacturing
capacity constraints would limit walk-in display and non-display door
availability to consumers in the timeframe of the amended standard
compliance date (2027).
Panels
Manufacturers indicated that design options that necessitate
thicker panels could lead to longer production times for panels. In
general, every additional inch of foam increases cure times by roughly
10 minutes. Based on information from manufacturer interviews and the
engineering analysis, DOE understands that a number of manufacturers
are able to produce panels above the baseline today and that a standard
based on 5-inch panels is not likely to lead to equipment shortages in
the industry. However, a standard that necessitates 6-inch panels for
any of the panel equipment class would require manufacturers to add
foaming equipment to maintain throughput due to longer curing times or
to purchase all new tooling to enable production if the manufacturer's
current equipment cannot accommodate 6-inch panels.
DOE seeks comment on whether manufacturers expect manufacturing
capacity constraints would limit walk-in panel availability to
consumers in the timeframe of the amended standard compliance date
(2027).
Refrigeration Systems
Manufacturers raised concerns about technical resource constraints
due to overlapping regulations. Manufacturers may face resource
constraints should EPA finalize its proposals in the December 2022 AIM
NOPR and DOE set more stringent standards that necessitate the redesign
of the majority
[[Page 60833]]
of models. These manufacturers stated that meeting EPA's proposed
refrigerant regulation would take significant amounts of engineering
resources, laboratory time, and investment.
Based on manufacturer feedback from confidential interviews and
publicly available information, DOE expects the walk-in refrigeration
system industry would need to invest approximately $29.5 million over a
two-year time period (2023-2024) to redesign models for low-GWP
refrigerants and retrofit manufacturing facilities to accommodate
flammable refrigerants in order to comply with EPA's proposal. Should
amended standards require significant product development or capital
investment, the 3-year period between the announcement of the final
rule and the compliance date of the amended energy conservation
standard might be insufficient to complete the dual development needed
to meet both EPA and DOE regulations.
DOE seeks comment on whether manufacturers expect manufacturing
capacity constraints or engineering resource constraints would limit
walk-in refrigeration system availability to consumers in the timeframe
of the amended standard compliance date (2027).
d. Impacts on Subgroups of Manufacturers
Using average cost assumptions to develop industry cash flow
estimates may not capture the differential impacts among subgroups of
manufacturers. Small manufacturers, niche players, or manufacturers
exhibiting a cost structure that differs substantially from the
industry average could be affected disproportionately. DOE investigated
small businesses as a manufacturer subgroup that could be
disproportionally impacted by energy conservation standards and could
merit additional analysis. DOE did not identify any other adversely
impacted manufacturer subgroups for this rulemaking based on the
results of the industry characterization.
DOE analyzes the impacts on small businesses in a separate analysis
in section VI.B of this document as part of the Regulatory Flexibility
Analysis. In summary, the Small Business Administration (``SBA'')
defines a ``small business'' as having 1,250 employees or less for
NAICS 333415, ``Air Conditioning and Warm Air Heating Equipment and
Commercial and Industrial Refrigeration Equipment Manufacturing.'' For
a discussion of the impacts on the small business manufacturer
subgroup, see the Regulatory Flexibility Analysis in section VI.B of
this document and chapter 12 of the NOPR TSD.
e. Cumulative Regulatory Burden
One aspect of assessing manufacturer burden involves looking at the
cumulative impact of multiple DOE standards and the product/equipment-
specific regulatory actions of other Federal agencies that affect the
manufacturers of a covered product or equipment. While any one
regulation may not impose a significant burden on manufacturers, the
combined effects of several existing or impending regulations may have
serious consequences for some manufacturers, groups of manufacturers,
or an entire industry. Assessing the impact of a single regulation may
overlook this cumulative regulatory burden. In addition to energy
conservation standards, other regulations can significantly affect
manufacturers' financial operations. Multiple regulations affecting the
same manufacturer can strain profits and lead companies to abandon
product lines or markets with lower expected future returns than
competing products. For these reasons, DOE conducts an analysis of
cumulative regulatory burden as part of its rulemakings pertaining to
appliance efficiency.
Table V.64--Compliance Dates and Expected Conversion Expenses of Federal Energy Conservation Standards Affecting
Walk-In OEMs
----------------------------------------------------------------------------------------------------------------
Industry
Number of OEMs Approx. Industry conversion
Federal energy conservation Number of OEMs affected by standards conversion costs costs/product
standard * today's rule compliance (millions $) revenue ***
** year (%)
----------------------------------------------------------------------------------------------------------------
Consumer Pool Heaters, 88 FR 20 1 2028 $48.4 (2021$) 1.5
34624 (May 30, 2023)........
Commercial Water Heating 14 1 2026 34.60 (2020$) 4.7
Equipment,[dagger] 87 FR
30610 (May 19, 2022)........
Consumer Furnaces,[dagger] 87 15 4 2029 150.6 (2020$) 1.4
FR 40590 (July 7, 2022).....
Microwave Ovens, 88 FR 39912 18 2 2026 46.1 (2021$) 0.7
(June 20, 2023).............
Consumer Conventional Cooking 34 1 2027 183.4 (2021$) 1.2
Products, 88 FR 6818
[dagger] (February 1, 2023).
Refrigerators, Freezers, and 49 1 2027 1,323.6 (2021$) 3.8
Refrigerator-
Freezers,[dagger] 88 FR
12452 (February 27, 2023)...
Room Air Conditioners, 88 FR 8 1 2026 24.8 (2021$) 0.4
34298 (May 26, 2023)........
Miscellaneous Refrigeration 38 2 2029 126.9 (2021$) 3.1
Products,[dagger] 88 FR 7840
(February 7, 2023)..........
Dishwashers,[dagger] 88 FR 22 1 2027 125.6 (2021$) 2.1
32514 (May 19, 2023)........
Consumer Water Heaters 22 1 2030 228.1 (2022$) 1.3
[dagger] [Dagger]...........
Automatic Commercial Ice 23 2 2027 15.9 (2022$) 0.6
Makers,[dagger] 88 FR 30508
(May 11, 2023)..............
Consumer Boilers [dagger] 24 1 2030 69.5 (2022$) 2.6
[Dagger]....................
----------------------------------------------------------------------------------------------------------------
* This column presents the total number of OEMs identified in the energy conservation standard rule that is
contributing to cumulative regulatory burden.
** This column presents the number of OEMs producing walk-ins that are also listed as OEMs in the identified
energy conservation standard that is contributing to cumulative regulatory burden.
*** This column presents industry conversion costs as a percentage of product revenue during the conversion
period. Industry conversion costs are the upfront investments manufacturers must make to sell compliant
products/equipment. The revenue used for this calculation is the revenue from just the covered product/
equipment associated with each row. The conversion period is the time frame over which conversion costs are
made and lasts from the publication year of the final rule to the compliance year of the energy conservation
standard. The conversion period typically ranges from 3 to 5 years, depending on the rulemaking.
[dagger] These rulemakings are at the NOPR stage, and all values are subject to change until finalized through
publication of a final rule.
[Dagger] At the time of issuance of this WICFs proposed rule, the consumer water heaters and consumer boilers
proposed rules have been issued and are pending publication in the Federal Register. Once published, the
proposed rule pertaining to consumer water heaters will be available at: www.regulations.gov/docket/EERE-2017-BT-STD-0019 and the proposed rule pertaining to consumer boilers will be available at: www.regulations.gov/docket/EERE-2012-BT-STD-0047.
[[Page 60834]]
Other Federal Regulations
The December 2022 AIM NOPR \88\ proposes to restrict the use of
hydrofluorocarbons in specific sectors or subsectors, including use in
walk-in refrigeration systems. DOE understands that switching from non-
flammable to flammable refrigerants requires time and investment to
redesign walk-in refrigeration systems and upgrade production
facilities to accommodate the additional structural and safety
precautions required. As discussed in sections IV.C.1.d of this
document, DOE tentatively expects manufacturers will need to transition
to an A2L or A3 refrigerant or CO2 to comply with upcoming
refrigerant regulations, such as the December 2022 AIM NOPR, prior to
the expected 2027 compliance date of any potential energy conservation
standards. DOE tentatively determined that dedicating condensing
systems would not suffer a performance penalty when switching to the
likely low-GWP alternative (i.e., R-454A), and, therefore, DOE has
continued to use R-448A and R-449A as the baseline refrigerant for all
medium- and low-temperature dedicated condensing units and single-
packaged dedicated systems in this NOPR analysis. DOE also does not
expect that unit coolers would suffer a performance penalty when
switching to low-GWP alternatives since increased refrigerant glide
does not decrease unit cooler performance. Therefore, DOE has continued
to use R-404A for medium- and low-temperature unit coolers and R-134A
for high-temperature unit coolers in this NOPR analysis.
---------------------------------------------------------------------------
\88\ The proposed rule was published on December 15, 2022. 87 FR
76738.
---------------------------------------------------------------------------
Although DOE maintains the use of current refrigerants (i.e., R-
448A, R-449A, R-404A, and R-134A) in its engineering analysis due to
its tentative conclusion that there will be performance parity with the
likely low-GWP alternatives, DOE still considers the cost associated
with the refrigerant transition in its GRIM because the change in
refrigerant is independent of DOE actions related to any amended energy
conservation standards. Investments required to transition to flammable
refrigerants in response to EPA's proposed rule, should it be
finalized, necessitates a level of investment beyond typical annual R&D
and capital expenditures. DOE accounted for the costs associated with
redesigning walk-in refrigeration systems to make use of flammable
refrigerants and retrofitting production facilities to accommodate
flammable refrigerants in the GRIM in the no-new-standards case and
standards cases to reflect the cumulative regulatory burden from
Federal refrigerant regulation. DOE relied on manufacturer feedback in
confidential interviews. a report prepared for EPA,\89\ and written
comments from AHRI in response to the June 2022 Preliminary Analysis to
estimate the industry refrigerant transition costs. Based on feedback,
DOE assumed that the transition to low-GWP refrigerants would require
industry to invest approximately $14.5 million in R&D and $15.0 million
in capital expenditures (e.g., investments in new charging equipment,
leak detection systems, etc.).
---------------------------------------------------------------------------
\89\ See pp. 5-113 of the ``Global Non-CO2 Greenhouse
Gas Emission Projections & Marginal Abatement Cost Analysis:
Methodology Documentation'' (2019). Available at www.epa.gov/sites/default/files/2019-09/documents/nonco2_methodology_report.pdf.
---------------------------------------------------------------------------
DOE requests comments on the magnitude of costs associated with
transitioning walk-in refrigeration systems and production facilities
to accommodate low-GWP refrigerants that would be incurred between the
publication of this NOPR and the proposed compliance date of amended
standards. Quantification and categorization of these costs, such as
engineering efforts, testing lab time, certification costs, and capital
investments (e.g., new charging equipment), would enable DOE to refine
its analysis.
DOE requests information regarding the impact of cumulative
regulatory burden on manufacturers of walk-ins associated with multiple
DOE standards or product/equipment-specific regulatory actions of other
Federal agencies.
3. National Impact Analysis
This section presents DOE's estimates of the NES and the NPV of
consumer benefits that would result from each of the TSLs considered as
potential amended standards.
a. Significance of Energy Savings
To estimate the energy savings attributable to potential amended
standards for walk-in coolers and freezers, DOE compared their energy
consumption under the no-new-standards case to their anticipated energy
consumption under each TSL. The savings are measured over the entire
lifetime of products purchased in the 30-year period that begins in the
year of anticipated compliance with amended standards (2027-2056).
Table V.65 through Table V.70 presents DOE's projections of the NES for
each TSL considered for walk-in coolers and freezers. The savings were
calculated using the approach described in section IV.H of this
document.
Table V.65--Cumulative National Energy Savings for Walk-In Coolers and Freezer Doors; 30 Years of Shipments 2027-
2056
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(quads)
-----------------------------------------------
Primary energy.................................................. 0.53 0.62 0.89
FFC energy...................................................... 0.54 0.64 0.92
----------------------------------------------------------------------------------------------------------------
[[Page 60835]]
Table V.66 Cumulative National Energy Savings for Walk-In Coolers and Freezer Panels; 30 Years of Shipments 2027-
2056
----------------------------------------------------------------------------------------------------------------
Trial Standard Level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(quads)
-----------------------------------------------
Primary energy.................................................. 0.00 0.00 0.63
FFC energy...................................................... 0.00 0.00 0.64
----------------------------------------------------------------------------------------------------------------
Table V.67--Cumulative National Energy Savings for Walk-In Coolers and Freezer Refrigeration Systems; 30 Years
of Shipments
[2027-2056]
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(quads)
-----------------------------------------------
Primary energy.................................................. 0.68 0.89 3.02
FFC energy...................................................... 0.70 0.91 3.10
----------------------------------------------------------------------------------------------------------------
OMB Circular A-4 \90\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis using 9 years, rather than 30
years, of product shipments. The choice of a 9-year period is a proxy
for the timeline in EPCA for the review of certain energy conservation
standards and potential revision of and compliance with such revised
standards.\91\ The review timeframe established in EPCA is generally
not synchronized with the product lifetime, product manufacturing
cycles, or other factors specific to walk-ins. Thus, such results are
presented for informational purposes only and are not indicative of any
change in DOE's analytical methodology. The NES sensitivity analysis
results based on a 9-year analytical period are presented in Table
V.70. The impacts are counted over the lifetime of walk-in components
purchased in 2027-2035.
---------------------------------------------------------------------------
\90\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf (last
accessed April 26, 2023).
\91\ EPCA requires DOE to review its standards at least once
every 6 years, and requires, for certain products, a 3-year period
after any new standard is promulgated before compliance is required,
except that in no case may any new standards be required within 6
years of the compliance date of the previous standards. (42 U.S.C.
6316(a); 42 U.S.C. 6295(m)) While adding a 6-year review to the 3-
year compliance period adds up to 9 years, DOE notes that it may
undertake reviews at any time within the 6 year period and that the
3-year compliance date may yield to the 6-year backstop. A 9-year
analysis period may not be appropriate given the variability that
occurs in the timing of standards reviews and the fact that for some
products, the compliance period is 5 years rather than 3 years.
Table V.68--Cumulative National Energy Savings for Walk-In Coolers and Freezers Doors; 9 Years of Shipments
[2027-2035]
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(quads)
-----------------------------------------------
Primary energy.................................................. 0.14 0.16 0.24
FFC energy...................................................... 0.14 0.17 0.24
----------------------------------------------------------------------------------------------------------------
Table V.69--Cumulative National Energy Savings for Walk-In Coolers and Freezers Panels; 9 Years of Shipments
[2027-2035]
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(quads)
-----------------------------------------------
Primary energy.................................................. .............. .............. 0.17
FFC energy...................................................... .............. .............. 0.18
----------------------------------------------------------------------------------------------------------------
[[Page 60836]]
Table V.70--Cumulative National Energy Savings for Walk-In Coolers and Freezers Refrigeration Systems; 9 Years
of Shipments
[2027-2035]
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(quads)
-----------------------------------------------
Primary energy.................................................. 0.19 0.24 0.83
FFC energy...................................................... 0.19 0.25 0.85
----------------------------------------------------------------------------------------------------------------
b. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
consumers that would result from the TSLs considered for walk-in
components. In accordance with OMB's guidelines on regulatory
analysis,\92\ DOE calculated NPV using both a 7-percent and a 3-percent
real discount rate. Table V.71 through Table V.73 shows the consumer
NPV results with impacts counted over the lifetime of products
purchased in 2027-2056.
---------------------------------------------------------------------------
\92\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf (last
accessed April 26, 2023).
Table V.71--Cumulative Net Present Value of Consumer Benefits for Walk-In Coolers and Freezers Doors; 30 Years
of Shipments
[2027-2056]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Discount rate -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
-----------------------------------------------
3 percent....................................................... 1.56 1.74 -7.96
7 percent....................................................... 0.70 0.77 -4.65
----------------------------------------------------------------------------------------------------------------
Table V.72--Cumulative Net Present Value of Consumer Benefits for Walk-In Coolers and Freezers Panels; 30 Years
of Shipments
[2027-2056]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Discount rate -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
-----------------------------------------------
3 percent....................................................... .............. .............. -5.18
7 percent....................................................... .............. .............. -3.10
----------------------------------------------------------------------------------------------------------------
Table V.73--Cumulative Net Present Value of Consumer Benefits for Walk-In Coolers and Freezers Refrigeration
Systems; 30 Years of Shipments
[2027-2056]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Discount rate -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
-----------------------------------------------
3 percent....................................................... 1.49 1.62 -25.14
7 percent....................................................... 0.64 0.68 -12.99
----------------------------------------------------------------------------------------------------------------
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V.74 through Table V.76. The impacts are
counted over the lifetime of products purchased in 2027-2035. As
mentioned previously, such results are presented for informational
purposes only and are not indicative of any change in DOE's analytical
methodology or decision criteria.
[[Page 60837]]
Table V.74--Cumulative Net Present Value of Consumer Benefits for Walk-In Coolers and Freezers Doors; 9 Years of
Shipments
[2027-2035]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Discount rate -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
-----------------------------------------------
3 percent....................................................... 0.56 0.63 -2.86
7 percent....................................................... 0.34 0.37 -2.27
----------------------------------------------------------------------------------------------------------------
Table V.75--Cumulative Net Present Value of Consumer Benefits for Walk-In Coolers and Freezers Panels; 9 Years
of Shipments
[2027-2035]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Discount rate -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
-----------------------------------------------
3 percent....................................................... .............. .............. -1.91
7 percent....................................................... .............. .............. -1.54
----------------------------------------------------------------------------------------------------------------
Table V.76--Cumulative Net Present Value of Consumer Benefits for Walk-In Coolers and Freezers Refrigeration
Systems; 9 Years of Shipments
[2027-2035]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Discount rate -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
-----------------------------------------------
3 percent....................................................... 0.55 0.60 -9.18
7 percent....................................................... 0.32 0.34 -6.42
----------------------------------------------------------------------------------------------------------------
The previous results reflect the use of a default trend to estimate
the change in price for walk-in coolers and freezers over the analysis
period (see section IV.F.1 of this document). DOE also conducted a
sensitivity analysis that considered one scenario with a lower rate of
price decline than the reference case and one scenario with a higher
rate of price decline than the reference case. The results of these
alternative cases are presented in appendix 10C of the NOPR TSD. In the
high-price-decline case, the NPV of consumer benefits is higher than in
the default case. In the low-price-decline case, the NPV of consumer
benefits is lower than in the default case.
c. Indirect Impacts on Employment
DOE estimates that that amended energy conservation standards for
walk-in coolers and freezers would reduce energy expenditures for
consumers of those products, with the resulting net savings being
redirected to other forms of economic activity. These expected shifts
in spending and economic activity could affect the demand for labor. As
described in section IV.N of this document, DOE used an input/output
model of the U.S. economy to estimate indirect employment impacts of
the TSLs that DOE considered. There are uncertainties involved in
projecting employment impacts, especially changes in the later years of
the analysis. Therefore, DOE generated results for near-term timeframes
(2027-2036), where these uncertainties are reduced.
The results suggest that the proposed standards would be likely to
have a negligible impact on the net demand for labor in the economy.
The net change in jobs is so small that it would be imperceptible in
national labor statistics and might be offset by other, unanticipated
effects on employment. Chapter 16 of the NOPR TSD presents detailed
results regarding anticipated indirect employment impacts.
4. Impact on Utility or Performance of Products
As discussed in section III.F.1.d of this document, DOE has
tentatively concluded that the standards proposed in this NOPR would
not lessen the utility or performance of the walk-in coolers and
freezers under consideration in this rulemaking. Manufacturers of these
products currently offer units that meet or exceed the proposed
standards.
5. Impact of Any Lessening of Competition
DOE considered any lessening of competition that would be likely to
result from new or amended standards. As discussed in section III.F.1.e
of this document, the Attorney General determines the impact, if any,
of any lessening of competition likely to result from a proposed
standard, and transmits such determination in writing to the Secretary,
together with an analysis of the nature and extent of such impact. To
assist the Attorney General in making this determination, DOE has
provided DOJ with copies of this NOPR and the accompanying TSD for
review. DOE will consider DOJ's comments on the proposed rule in
determining whether to proceed to a final rule. DOE will publish and
respond to DOJ's comments in that document. DOE invites comment
[[Page 60838]]
from the public regarding the competitive impacts that are likely to
result from this proposed rule. In addition, stakeholders may also
provide comments separately to DOJ regarding these potential impacts.
See the ADDRESSES section for information to send comments to DOJ.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the Nation's energy security, strengthens the economy, and reduces the
environmental impacts (costs) of energy production. Reduced electricity
demand due to energy conservation standards is also likely to reduce
the cost of maintaining the reliability of the electricity system,
particularly during peak-load periods. Chapter 15 in the NOPR TSD
presents the estimated impacts on electricity generating capacity,
relative to the no-new-standards case, for the TSLs that DOE considered
in this rulemaking.
Energy conservation resulting from potential energy conservation
standards for walk-in coolers and freezers is expected to yield
environmental benefits in the form of reduced emissions of certain air
pollutants and greenhouse gases. Table V.77 provides DOE's estimate of
cumulative emissions reductions expected to result from the TSLs
considered in this rulemaking. The emissions were calculated using the
multipliers discussed in section IV.K. DOE reports annual emissions
reductions for each TSL in chapter 13 of the NOPR TSD.
Table V.77--Cumulative Emissions Reduction for Walk-In Coolers and Freezers Shipped in 2027-2054
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................................... 20.68 25.91 149.54
CH4 (thousand tons)............................................. 1.55 1.94 11.63
N2O (thousand tons)............................................. 0.22 0.27 1.63
NOX (thousand tons)............................................. 9.96 12.48 75.08
SO2 (thousand tons)............................................. 6.86 8.60 71.84
Hg (tons)....................................................... 0.05 0.06 0.46
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................................... 2.07 2.60 11.49
CH4 (thousand tons)............................................. 187.92 235.47 1086.42
N2O (thousand tons)............................................. 0.01 0.01 0.06
NOX (thousand tons)............................................. 32.23 40.38 174.00
SO2 (thousand tons)............................................. 0.13 0.16 0.80
Hg (tons)....................................................... 0.00 0.00 0.00
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................................... 22.75 28.50 161.03
CH4 (thousand tons)............................................. 189.47 237.41 1098.04
N2O (thousand tons)............................................. 0.22 0.28 1.68
NOX (thousand tons)............................................. 42.18 52.86 249.08
SO2 (thousand tons)............................................. 6.99 8.76 72.64
Hg (tons)....................................................... 0.05 0.06 0.47
----------------------------------------------------------------------------------------------------------------
Note: Negative values refer to an increase in emissions.
As part of the analysis for this rulemaking, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2 that DOE
estimated for each of the considered TSLs for walk-ins. Section IV.L of
this document discusses the SC-CO2 values that DOE used. Table V.78
presents the value of CO2 emissions reduction at each TSL for each of
the SC-CO2 cases. The time-series of annual values is presented for the
proposed TSL in chapter 14 of the NOPR TSD.
Table V.78--Present Value of CO2 Emissions Reduction for Walk-In Coolers and Freezers Shipped in 2027-2056
----------------------------------------------------------------------------------------------------------------
SC-CO2 case
---------------------------------------------------------------
Discount rate and statistics
TSL ---------------------------------------------------------------
3% 95th
5% Average 3% Average 2.5% Average percentile
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
---------------------------------------------------------------
1............................................... 0.24 1.02 1.59 3.11
2............................................... 0.30 1.28 1.99 3.89
3............................................... 0.90 3.81 5.94 11.58
----------------------------------------------------------------------------------------------------------------
[[Page 60839]]
As discussed in section IV.L.2 of this document, DOE estimated the
climate benefits likely to result from the reduced emissions of methane
and N2O that DOE estimated for each of the considered TSLs for walk-in
coolers and freezers. Table V.79 presents the value of the CH4
emissions reduction at each TSL, and Table V.80 presents the value of
the N2O emissions reduction at each TSL. The time-series of annual
values is presented for the proposed TSL in chapter 14 of the NOPR TSD.
Table V.79--Present Value of Methane Emissions Reduction for Walk-In Coolers and Freezers Shipped in 2027-2056
----------------------------------------------------------------------------------------------------------------
SC-CH4 case
---------------------------------------------------------------
Discount rate and statistics
TSL ---------------------------------------------------------------
3% 95th
5% Average 3% Average 2.5% Average percentile
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
---------------------------------------------------------------
1............................................... 0.09 0.27 0.37 0.71
2............................................... 0.11 0.34 0.47 0.89
3............................................... 0.34 1.00 1.40 2.66
----------------------------------------------------------------------------------------------------------------
Table V.80--Present Value of Nitrous Oxide Emissions Reduction for Walk-In Coolers and Freezers Shipped in 2027-
2056
----------------------------------------------------------------------------------------------------------------
SC-N2O case
---------------------------------------------------------------
Discount rate and statistics
TSL ---------------------------------------------------------------
3% 95th
5% Average 3% Average 2.5% Average percentile
----------------------------------------------------------------------------------------------------------------
(billion 2022$)
---------------------------------------------------------------
1............................................... 0.00 0.00 0.01 0.01
2............................................... 0.00 0.00 0.01 0.01
3............................................... 0.00 0.01 0.02 0.04
----------------------------------------------------------------------------------------------------------------
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in the future
global climate and the potential resulting damages to the global and
U.S. economy continues to evolve rapidly. DOE, together with other
Federal agencies, will continue to review methodologies for estimating
the monetary value of reductions in CO2 and other GHG emissions. This
ongoing review will consider the comments on this subject that are part
of the public record for this and other rulemakings, as well as other
methodological assumptions and issues. DOE notes that the proposed
standards would be economically justified even without inclusion of
monetized benefits of reduced GHG emissions.
DOE also estimated the monetary value of the health benefits
associated with NOX and SO2 emissions reductions anticipated to result
from the considered TSLs for walk-ins. The dollar-per-ton values that
DOE used are discussed in section IV.L of this document. Table V.81
presents the present value for NOX emissions reduction for each TSL
calculated using 7-percent and 3-percent discount rates, and Table V.82
presents similar results for SO2 emissions reductions. The results in
these tables reflect application of EPA's low dollar-per-ton values,
which DOE used to be conservative. The time-series of annual values is
presented for the proposed TSL in chapter 14 of the NOPR TSD.
Table V.81--Present Value of NOX Emissions Reduction for Walk-Ins
Shipped in 2027-2056
------------------------------------------------------------------------
TSL 3% Discount rate 7% Discount rate
------------------------------------------------------------------------
(million 2022$)
---------------------------------------
1............................... 2,066.09 865.00
2............................... 2,588.54 1,083.62
3............................... 7,697.98 3,187.29
------------------------------------------------------------------------
[[Page 60840]]
Table V.82--Present Value of SO2 Emissions Reduction for Walk-Ins
Shipped in 2027-2056
------------------------------------------------------------------------
3% Discount 7% Discount
TSL rate rate
------------------------------------------------------------------------
(million 2022$)
-------------------------------
1....................................... 478.11 204.03
2....................................... 599.00 255.59
3....................................... 1,778.80 750.45
------------------------------------------------------------------------
Not all the public health and environmental benefits from the
reduction of greenhouse gases, NOx, and SO2 are captured in
the values above, and additional unquantified benefits from the
reductions of those pollutants as well as from the reduction of direct
PM and other co-pollutants may be significant. DOE has not included
monetary benefits of the reduction of Hg emissions because the amount
of reduction is very small.
7. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) No
other factors were considered in this analysis.
8. Summary of Economic Impacts
Table V.83 through Table V.85 present the NPV values that result
from adding the estimates of the potential economic benefits resulting
from reduced GHG and NOX and SO2 emissions to the
NPV of consumer benefits calculated for each TSL considered in this
rulemaking. The consumer benefits are domestic U.S. monetary savings
that occur as a result of purchasing the covered equipment, and are
measured for the lifetime of products shipped in 2027-2056. The climate
benefits associated with reduced GHG emissions resulting from the
adopted standards are global benefits, and are also calculated based on
the lifetime of walk-ins shipped in 2027-2056.
Table V.83--Consumer NPV Combined With Present Value of Climate Benefits and Health Benefits for Walk-In Doors
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Using 3% discount rate for Consumer NPV and Health Benefits (billion 2022$)
----------------------------------------------------------------------------------------------------------------
5% Average SC-GHG case.......................................... 2.83 3.24 -5.83
3% Average SC-GHG case.......................................... 3.25 3.74 -5.12
2.5% Average SC-GHG case........................................ 3.55 4.09 -4.62
3% 95th percentile SC-GHG case.................................. 4.37 5.05 -3.24
----------------------------------------------------------------------------------------------------------------
Using 7% discount rate for Consumer NPV and Health Benefits (billion 2022$)
----------------------------------------------------------------------------------------------------------------
5% Average SC-GHG case.......................................... 1.32 1.51 -3.61
3% Average SC-GHG case.......................................... 1.75 2.01 -2.90
2.5% Average SC-GHG case........................................ 2.04 2.36 -2.40
3% 95th percentile SC-GHG case.................................. 2.86 3.32 -1.03
----------------------------------------------------------------------------------------------------------------
Table V.84--Consumer NPV Combined With Present Value of Climate Benefits and Health Benefits for Walk-In Panels
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Using 3% discount rate for Consumer NPV and Health Benefits (billion 2022$)
----------------------------------------------------------------------------------------------------------------
5% Average SC-GHG case.......................................... .............. .............. -3.73
3% Average SC-GHG case.......................................... .............. .............. -3.24
2.5% Average SC-GHG case........................................ .............. .............. -2.90
3% 95th percentile SC-GHG case.................................. .............. .............. -1.96
----------------------------------------------------------------------------------------------------------------
Using 7% discount rate for Consumer NPV and Health Benefits (billion 2022$)
----------------------------------------------------------------------------------------------------------------
5% Average SC-GHG case.......................................... .............. .............. -2.41
3% Average SC-GHG case.......................................... .............. .............. -1.92
2.5% Average SC-GHG case........................................ .............. .............. -1.58
3% 95th percentile SC-GHG case.................................. .............. .............. -0.64
----------------------------------------------------------------------------------------------------------------
Table V.85--Consumer NPV Combined With Present Value of Climate Benefits and Health Benefits for Walk-In
Refrigeration Systems
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Using 3% discount rate for Consumer NPV and Health Benefits (billion 2022$)
----------------------------------------------------------------------------------------------------------------
5% Average SC-GHG case.......................................... 3.10 3.73 -18.00
3% Average SC-GHG case.......................................... 3.64 4.44 -15.61
2.5% Average SC-GHG case........................................ 4.02 4.93 -13.93
3% 95th percentile SC-GHG case.................................. 5.05 6.29 -9.32
----------------------------------------------------------------------------------------------------------------
[[Page 60841]]
Using 7% discount rate for Consumer NPV and Health Benefits (billion 2022$)
----------------------------------------------------------------------------------------------------------------
5% Average SC-GHG case.......................................... 1.42 1.70 -9.54
3% Average SC-GHG case.......................................... 1.96 2.41 -7.15
2.5% Average SC-GHG case........................................ 2.34 2.90 -5.47
3% 95th percentile SC-GHG case.................................. 3.38 4.26 -0.86
----------------------------------------------------------------------------------------------------------------
C. Conclusion
When considering new or amended energy conservation standards, the
standards that DOE adopts for any type (or class) of covered product
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. 6316(a); 42 U.S.C.
6295(o)(2)(A)) In determining whether a standard is economically
justified, the Secretary must determine whether the benefits of the
standard exceed its burdens by, to the greatest extent practicable,
considering the seven statutory factors discussed previously. (42
U.S.C. 6295(o)(2)(B)(i)) The new or amended standard must also result
in significant conservation of energy. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(3)(B))
For this NOPR, DOE considered the impacts of amended standards for
walk-ins at each TSL, beginning with the maximum technologically
feasible level, to determine whether that level was economically
justified. Where the max-tech level was not justified, DOE then
considered the next most efficient level and undertook the same
evaluation until it reached the highest efficiency level that is both
technologically feasible and economically justified and saves a
significant amount of energy.
To aid the reader as DOE discusses the benefits and/or burdens of
each TSL, tables in this section present a summary of the results of
DOE's quantitative analysis for each TSL. In addition to the
quantitative results presented in the tables, DOE also considers other
burdens and benefits that affect economic justification. These include
the impacts on identifiable subgroups of consumers who may be
disproportionately affected by a national standard and impacts on
employment.
1. Benefits and Burdens of TSLs Considered for Walk-Ins Standards
a. Doors
Table V.87, Table V.88, Table V.90, and Table V.91 summarize the
quantitative impacts estimated for each TSL for walk-in display doors
and non-display doors. National impacts for walk-in doors are measured
over the lifetime of walk-ins purchased in the 30-year period that
begins in the anticipated year of compliance with amended standards
(2027-2056). The energy savings, emissions reductions, and value of
emissions reductions refer to full-fuel-cycle results.
Display Doors
Walk-in display door efficiency levels contained in each TSL are
shown in Table V.86 and described in section IV.E.1 of this document.
Table V.87 and Table V.88 summarize the quantitative impacts estimated
for each TSL for walk-in display doors.
Table V.86--Walk-In Display Doors Efficiency Level Mapping by Trial Standard Level
----------------------------------------------------------------------------------------------------------------
Equipment class TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Low Temperature (DW.L).......................................... 0 0 2
Medium Temperature (DW.M)....................................... 0 0 2
----------------------------------------------------------------------------------------------------------------
Table V.87--Summary of Analytical Results for Walk-In Display Doors TSLs: National Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Cumulative FFC National Energy Savings
----------------------------------------------------------------------------------------------------------------
Quads........................................................... .............. .............. 0.25
CO2 (million metric tons)....................................... .............. .............. 4.5
CH4 (thousand tons)............................................. .............. .............. 37.8
N2O (thousand tons)............................................. .............. .............. 0.0
NOX (thousand tons)............................................. .............. .............. 8.4
SO2 (thousand tons)............................................. .............. .............. 1.4
Hg (tons)....................................................... .............. .............. 0.01
----------------------------------------------------------------------------------------------------------------
Present Value of Benefits and Costs (3% discount rate, billion 2022$)
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. .............. .............. 0.86
Climate Benefits *.............................................. .............. .............. 0.25
Health Benefits **.............................................. .............. .............. 0.49
-----------------------------------------------
Total Monetized Benefits [dagger]........................... .............. .............. 1.60
Consumer Incremental Product Costs [Dagger]..................... .............. .............. 8.41
Consumer Net Benefits........................................... .............. .............. -7.54
-----------------------------------------------
[[Page 60842]]
Total Net Monetized Benefits................................ .............. .............. -6.81
----------------------------------------------------------------------------------------------------------------
Present Value of Benefits and Costs (7% discount rate, billion 2022$)
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. .............. .............. 0.38
Climate Benefits *.............................................. .............. .............. 0.25
Health Benefits **.............................................. .............. .............. 0.20
-----------------------------------------------
Total Monetized Benefits [dagger]........................... .............. .............. 0.83
Consumer Incremental Product Costs [Dagger]..................... .............. .............. 4.61
Consumer Net Benefits........................................... .............. .............. -4.22
-----------------------------------------------
Total Net Monetized Benefits................................ .............. .............. -3.78
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-ins shipped in 2027-2056. These results
include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the SC-CO2, SC-CH4 and SC-N2O. Together,
these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated
with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and
value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits
of reducing GHG emissions, this analysis uses the interim estimates presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for NOX and SO2) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. The health benefits are presented at real discount rates of 3 and 7 percent. See section IV.L
of this document for more details.
[dagger] Total and net benefits include consumer, climate, and health benefits. For presentation purposes, total
and net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-
percent discount rate.
[Dagger] Costs include incremental equipment costs as well as installation costs.
Table V.88--Summary of Analytical Results for Walk-Ins Display Doors TSLs: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 * TSL 2 * TSL 3 *
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (million 2022$) (No-new-standards 278.0 278.0 215.5 to 355.6.
case INPV = 278.0).
Industry NPV (% change)....................... -- -- (22.5) to 27.9.
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2022$)
----------------------------------------------------------------------------------------------------------------
DW.L.......................................... -- -- (1,106).
DW.M.......................................... -- -- (1,247).
Shipment-Weighted Average *................... -- -- (1,232).
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
DW.L.......................................... -- -- 44.0.
DW.M.......................................... -- -- 99.1.
Shipment-Weighted Average *................... -- -- 93.2.
----------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost
----------------------------------------------------------------------------------------------------------------
DW.L.......................................... -- -- 100.
DW.M.......................................... -- -- 100.
Shipment-Weighted Average *................... -- -- 100.
----------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values. The entry ``--'' means not applicable because there is no change in
the standard at certain TSLs.
* Weighted by shares of each product class in total projected shipments in 2027.
For walk-in display doors, DOE first considered TSL 3, which
represents the max-tech efficiency levels. At TSL 3, DOE expects
display doors would require the use of vacuum-insulated glass as a
substitute for the prescriptive minimum design of double-pane or
triple-pane insulated glass packs for medium-temperature doors and low-
temperature doors, respectively. TSL 3 would save an estimated 0.25
quads of energy, an amount DOE considers significant. Under TSL 3, the
NPV of consumer benefit would be -$4.22 billion using a discount rate
of 7 percent, and -$7.54 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 4.5 Mt of
CO2, 1.4 thousand tons of SO2, 8.4 thousand tons
of NOX, 0.01 tons of Hg, 37.8 thousand tons of
CH4, and 0.0 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 3 is $0.25 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 3 is $ 0.20 billion using a 7-percent
[[Page 60843]]
discount rate and $0.49 billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 3 is -$6.81
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 3 is -$3.78 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 3 for walk-in display doors, the average LCC impact ranges
from a savings of -$1,247 for DW.M to -$1,106 for DW.L. The simple
payback period ranges from 44.0 years for DW.L to 99.1 years for DW.M.
The fraction of consumers experiencing a net LCC cost is 100 percent
for all walk-in display doors.
At TSL 3 for walk-in display doors, the projected change in INPV
ranges from a decrease of $62.5 million to an increase of $77.6
million, which corresponds to a decrease of 22.5 percent and an
increase of 27.9 percent, respectively. DOE estimates industry would
invest $25.5 million to redesign walk-in display doors to incorporate
vacuum-insulated glass.
DOE estimates that there are no walk-in display door shipments that
currently meet the max-tech efficiency levels. For the 10 OEMs that
manufacture walk-in display doors, implementing vacuum-insulated glass
would require significant engineering resources and testing time to
ensure adequate durability of their doors in all commercial settings.
In interviews, manufacturers emphasized that there are currently a very
limited number of suppliers of vacuum-insulated glass. Door
manufacturers expressed concerns that the 3-year conversion period
between the publication of the final rule and the compliance date of
the amended energy conservation standard might be insufficient to
design and test a full portfolio of vacuum-insulated doors that meet
the max-tech efficiencies and maintain their internal metrics over the
door lifetime.
The Secretary tentatively concludes that at TSL 3 for all walk-in
display doors, the benefits of energy savings, emission reductions, and
the estimated monetary value of the emissions reductions would be
outweighed by the economic burden in the form of negative NPV of
consumer benefits, and the impacts on manufacturers, including the
large conversion costs and profit margin impacts that could result in a
large reduction in INPV. No manufacturers currently offer equipment
that meet the efficiency levels required at TSL 3. Walk-in display door
manufacturers raised concern about their ability to incorporate vacuum
insulated glass across all their offerings, while also maintaining
important display door performance characteristics, within three years.
Consequently, the Secretary has tentatively concluded that TSL 3 is not
economically justified.
Although DOE considered proposed amended standard levels for walk-
in display doors by grouping the efficiency levels for low- and medium-
temperature display doors into TSLs, DOE evaluates all analyzed
efficiency levels in its analysis. As defined in section IV.E.1, TSL 2
and TSL 1 require efficiency levels with positive consumer NPV at a 7-
percent discount rate. As shown in appendix 8E of the NOPR TSD, none of
the efficiency level improvements to walk-in display doors yield
positive consumer benefit for any of the considered equipment classes,
resulting in TSL 2 and TSL 1 with efficiency levels at the current
baseline.
Therefore, based on the previous considerations, the Secretary is
tentatively proposing to not amend energy conservation standards for
walk-in display doors at this time.
Non-Display Doors
Walk-in non-display door efficiency levels contained in each TSL
are shown in Table V.89 and described in section IV.E.1 of this
document. Table V.90 and Table V.91 summarize the quantitative impacts
estimated for each TSL for walk-in non-display doors.
Table V.89--Walk-In Non-Display Door Efficiency Level Mapping by Trial Standard Level
----------------------------------------------------------------------------------------------------------------
Equipment class TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Non-Motorized Low Temperature (NM.L)............................ 3 3 5
Non-Motorized Medium Temperature (NM.M)......................... 1 3 6
Motorized Low Temperature (NO.L)................................ 3 3 5
Motorized Medium Temperature (NO.M)............................. 1 3 6
----------------------------------------------------------------------------------------------------------------
Table V.90--Summary of Analytical Results for Walk-In Non-display Doors TSLs: National Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Cumulative FFC National Energy Savings
----------------------------------------------------------------------------------------------------------------
Quads........................................................... 0.54 0.64 0.67
CO2 (million metric tons)....................................... 10.0 11.8 12.4
CH4 (thousand tons)............................................. 82.7 97.6 102.7
N2O (thousand tons)............................................. 0.1 0.1 0.1
NOX (thousand tons)............................................. 18.4 21.8 22.9
SO2 (thousand tons)............................................. 3.1 3.6 3.8
Hg (tons)....................................................... 0.02 0.02 0.03
----------------------------------------------------------------------------------------------------------------
Present Value of Benefits and Costs (3% discount rate, billion 2022$)
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 1.99 2.35 2.47
Climate Benefits *.............................................. 0.57 0.67 0.71
Health Benefits **.............................................. 1.12 1.33 1.40
-----------------------------------------------
Total Monetized Benefits [dagger]........................... 3.68 4.35 4.58
Consumer Incremental Product Costs [Dagger]..................... 0.43 0.61 2.89
[[Page 60844]]
Consumer Net Benefits........................................... 1.56 1.74 -0.41
-----------------------------------------------
Total Net Monetized Benefits................................ 3.25 3.74 1.69
----------------------------------------------------------------------------------------------------------------
Present Value of Benefits and Costs (7% discount rate, billion 2022$)
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 0.93 1.11 1.16
Climate Benefits *.............................................. 0.57 0.67 0.71
Health Benefits **.............................................. 0.48 0.56 0.59
-----------------------------------------------
Total Monetized Benefits [dagger]........................... 1.98 2.34 2.47
Consumer Incremental Product Costs [Dagger]..................... 0.23 0.34 1.59
Consumer Net Benefits........................................... 0.70 0.77 -0.43
-----------------------------------------------
Total Net Monetized Benefits................................ 1.75 2.01 0.88
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-ins shipped in 2027-2056. These results
include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the SC-CO2, SC-CH4 and SC-N2O. Together,
these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated
with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and
value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits
of reducing GHG emissions, this analysis uses the interim estimates presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for NOX and SO2) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. The health benefits are presented at real discount rates of 3 and 7 percent. See section IV.L
of this document for more details.
[dagger] Total and net benefits include consumer, climate, and health benefits. For presentation purposes, total
and net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-
percent discount rate.
[Dagger] Costs include incremental equipment costs as well as installation costs.
Table V.91--Summary of Analytical Results for Walk-In Non-Display Doors TSLs: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 * TSL 2 * TSL 3 *
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (million 2022$) (No-new-standards case 522.6 to 529.4 511.2 to 522.5 485.1 to 549.4
INPV = 536.7).........................................
Industry NPV (% change)................................ (2.6) to (1.4) (4.8) to (2.6) (9.6) to 2.4
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2022$)
----------------------------------------------------------------------------------------------------------------
NM.L................................................... 724 723 307
NM.M................................................... 203 86 (291)
NO.L................................................... 1,194 1,192 932
NO.M................................................... 306 113 (266)
Shipment-Weighted Average *............................ 388 308 (80)
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
NM.L................................................... 1.3 1.3 2.8
NM.M................................................... 2.4 3.2 8.2
NO.L................................................... 1.0 1.0 2.1
NO.M................................................... 1.8 2.4 6.3
Shipment-Weighted Average *............................ 2.0 2.5 6.3
----------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost
----------------------------------------------------------------------------------------------------------------
NM.L................................................... 2 2 37
NM.M................................................... 2 11 96
NO.L................................................... 1 2 9
NO.M................................................... 0 3 95
Shipment-Weighted Average *............................ 2 2 37
----------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values. The entry ``--'' means not applicable because there is no change in
the standard at certain TSLs.
* Weighted by shares of each product class in total projected shipments in 2027.
For walk-in non-display doors, DOE first considered TSL 3, which
represents the max-tech efficiency levels. At TSL 3, DOE expects all
non-display doors would require the following additional design
options: anti-sweat heater controls, improved framing systems, reduced
anti-sweat heat, and insulation thickness of 6 inches.
[[Page 60845]]
For walk-in non-display doors, TSL 3 would save an estimated 0.68
quads of energy, an amount DOE considers significant. Under TSL 3, the
NPV of consumer benefits would be -$0.43 billion using a discount rate
of 7 percent, and -$0.41 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 12.4 Mt of
CO2, 3.8 thousand tons of SO2, 22.9 thousand tons
of NOX, 0.03 tons of Hg, 102.7 thousand tons of
CH4, and 0.1 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 3 is $0.71 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 3 is $0.59 billion using a 7-percent discount rate and $1.40
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 3 is $0.88
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 3 is $1.69 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 3, the average LCC impact ranges from a savings of -$291 for
medium-temperature manual non-display doors to $932 for low-temperature
motorized non-display doors. The simple payback period ranges from 2.1
years for low-temperature motorized non-display doors to 8.2 years for
medium-temperature manual non-display doors. The fraction of consumers
experiencing a net LCC cost ranges from 7 percent for low-temperature
motorized non-display doors to 78 percent for medium-temperature manual
non-display doors.
At TSL 3, the projected change in INPV ranges from a decrease of
$51.6 million to an increase of $12.7 million, which corresponds to a
decrease of 9.6 percent and an increase of 2.4 percent, respectively.
DOE estimates industry would invest $48.3 million to purchase new
foaming equipment and tooling to increase insulation thickness to 6
inches for all walk-in non-display doors.
DOE estimates that there are no walk-in non-display door shipments
that currently meet the max-tech efficiency levels. For the 43 OEMs
that manufacture walk-in non-display doors, increasing insulation
thickness from the assumed baseline thickness of 3.5 inches for medium-
temperature and 4 inches for low-temperature non-display doors to 6
inches would require purchasing new foaming equipment since most
manufacturers are only able to manufacture non-display doors up to 5
inches thick. Additionally, non-display door manufacturers were
concerned about the flow of foam and the curing time of foam at max-
tech. New foaming equipment to accommodate 6-inch non-display doors
would require significant capital investment and is a key driver of
capital conversion costs. Of the 43 non-display door OEMs identified,
40 are small, domestic businesses.
Furthermore, of the 43 walk-in non-display door OEMs, 39 OEMs also
produce walk-in panels. Most of these OEMs use the same panel foaming
systems to produce non-display doors that they use to produce panels;
however, panel shipments dwarf shipments of non-display doors. Because
the same product lines are used, these OEMs offer non-display doors in
the same range of thickness as panels. It is typical to align the
thickness of non-display doors and panels to avoid a situation where
the walk-in door protrudes from the surrounding panel enclosure. Were
the thickness of non-display doors and panels to be different in an
installation, consumers may need to prematurely replace the surrounding
panels to accommodate a thicker non-display door. Thus, a standard that
would require 6-inch-thick non-display doors may inadvertently force
consumers to purchase some or all panels of the walk-in that are 6-
inches thick so that the thickness of the entire walk-in is the same or
that there is appropriate structural transition between the door and
panels of differing thicknesses. As discussed in section V.C.1.b,
panels of 6-inch thickness do not have positive consumer benefits.
The Secretary tentatively concludes that at TSL 3 for walk-in non-
display doors, the benefits of energy savings, emission reductions, and
the estimated monetary value of the emissions reductions would be
outweighed by the economic burden of negative NPV of consumer benefits,
and the impacts on manufacturers, including the conversion costs and
profit margin impacts that could result in a reduction in INPV, and the
absence of manufacturers currently offering products meeting the
efficiency levels required at this TSL, including all small businesses
of non-display doors. Manufacturers of non-display doors would need to
increase insulation thickness to 6 inches across all equipment classes,
necessitating large capital investments. Additionally, no walk-in non-
display door manufacturers offer models in the CCD that meet the
efficiency level required at TSL 3. Nearly all the non-display door
OEMs identified are small, domestic businesses. Lastly, to purchase
walk-in doors at TSL 3, consumers may also be required to purchase some
or all panels of their walk-ins at a level that is not economically
justified for the thickness of the door and panel to be uniform.
Consequently, the Secretary has tentatively concluded that TSL 3 is not
economically justified.
DOE then considered TSL 2 for walk-in non-display doors, which
represents efficiency level 3 for all non-display doors. At TSL 2, DOE
expects that all walk-in non-display doors would require anti-sweat
heater controls, improved framing systems and reduced anti-sweat heat.
TSL 2 would save an estimated 0.64 quads of energy, an amount DOE
considers significant. Under TSL 2, the NPV of consumer benefit would
be $0.77 billion using a discount rate of 7 percent, and $1.74 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 2 are 11.8 Mt of
CO2, 3.6 thousand tons of SO2, 21.8 thousand tons
of NOX, 0.02 tons of Hg, 97.6 thousand tons of
CH4, and 0.1 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 2 is $0.67 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 2 is $0.56 billion using a 7-percent discount rate and $1.33
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 2 is $2.01
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 2 is $3.74 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 2, the average LCC impact ranges from a savings of $86 for
medium-temperature, manual non-display doors to $1,192 for low-
[[Page 60846]]
temperature motorized non-display doors. The simple payback period
ranges from 1.0 years for low-temperature, motorized non-display doors
to 3.2 years for medium-temperature, manual non-display doors. The
fraction of consumers experiencing a net LCC cost ranges from 2 percent
for low-temperature, motorized non-display doors to 11 percent for
medium-temperature, manual non-display doors.
At TSL 2, the projected change in INPV ranges from a decrease of
$25.5 million to a decrease of $14.2 million, which corresponds to
decreases of 4.8 percent and 2.6 percent, respectively. DOE estimates
that industry must invest $28.9 million to comply with standards for
non-display doors set at TSL 2. DOE estimates that approximately 12
percent of non-display door shipments currently meet TSL 2
efficiencies. At this level, DOE expects manufacturers would need to
update non-display door models to incorporate anti-sweat heater
controls, improved door frame designs, and reduced anti-sweat heat. DOE
does not expect manufacturers would need to increase insulation
thickness to meet the efficiency levels required by TSL 2.
After considering the analysis and weighing the benefits and
burdens, the Secretary has tentatively concluded that a standard set at
TSL 2 for walk-in non-display doors would be economically justified. At
this TSL, the average LCC savings for all non-display door consumers
are positive, and the greatest fraction of consumers to experience net
cost is estimated at 11 percent for medium-temperature, manual non-
display doors. At TSL 2, the FFC national energy savings are
significant and the NPV of consumer benefits is positive using both a
3-percent and 7-percent discount rate. Notably, the benefits to
consumers vastly outweigh the cost to manufacturers. At TSL 2, the NPV
of consumer benefits, even measured at the more conservative discount
rate of 7 percent is over 28 times higher than the maximum estimated
manufacturers' loss in INPV. The standard levels at TSL 2 are
economically justified even without weighing the estimated monetary
value of emissions reductions. When those emissions reductions are
included--representing $0.67 billion in climate benefits (associated
with the average SC-GHG at a 3-percent discount rate), and $1.33
billion (using a 3-percent discount rate) or $0.56 billion (using a 7-
percent discount rate) in health benefits--the rationale for setting
standards at TSL 2 for walk-in doors is further strengthened.
Therefore, based on the previous considerations, DOE proposes to
adopt the energy conservation standards for walk-in non-display doors
at TSL 2. The proposed amended energy conservation standards for walk-
in non-display doors, which are expressed as kWh/year, are shown in
Table V.92.
Table V.92--Proposed Amended Energy Conservation Standards for Walk-In Non-Display Doors
----------------------------------------------------------------------------------------------------------------
Equipment class
---------------------------------------------------------------------------------------- Maximum daily energy
Display/non-display Opening mechanism Temperature consumption (kWh/day) *
----------------------------------------------------------------------------------------------------------------
Non-Display.......................... Manual................. Medium................. 0.01 x And + 0.25
Low.................... 0.06 x And + 1.32
Manual................. Medium................. 0.01 x And + 0.39
Low.................... 0.05 x And + 1.56
----------------------------------------------------------------------------------------------------------------
* And is the representative value of surface area of the non-display door as determined in accordance with the
DOE test procedure at 10 CFR part 431, subpart R, appendix A and applicable sampling plans.
b. Panels
The efficiency levels contained in each TSL are shown in Table V.93
and described in section IV.E.1 of this document. Table V.94 and Table
V.95 summarize the quantitative impacts estimated for each TSL for
walk-in panels. The national impacts are measured over the lifetime of
walk-ins purchased in the 30-year period that begins in the anticipated
year of compliance with amended standards (2027-2056). The energy
savings, emissions reductions, and value of emissions reductions refer
to full-fuel-cycle results.
Table V.93--Walk-In Panel Efficiency Level Mapping by Trial Standard Level
----------------------------------------------------------------------------------------------------------------
Equipment class TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Floor Low Temperature (PF.L).................................... 0 0 3
Structural Low Temperature (PS.L)............................... 0 0 2
Structural Medium Temperature (PS.M)............................ 0 0 3
----------------------------------------------------------------------------------------------------------------
Table V.94--Summary of Analytical Results for Walk-In Coolers and Freezers Panel TSLs: National Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Cumulative FFC National Energy Savings
----------------------------------------------------------------------------------------------------------------
Quads........................................................... .............. .............. 0.64
CO2 (million metric tons)....................................... .............. .............. 11.7
CH4 (thousand tons)............................................. .............. .............. 98.2
N2O (thousand tons)............................................. .............. .............. 0.1
NOX (thousand tons)............................................. .............. .............. 21.8
SO2 (thousand tons)............................................. .............. .............. 3.6
Hg (tons)....................................................... .............. .............. 0.02
----------------------------------------------------------------------------------------------------------------
[[Page 60847]]
Present Value of Benefits and Costs (3% discount rate, billion 2022$)
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. .............. .............. 2.28
Climate Benefits *.............................................. .............. .............. 0.65
Health Benefits **.............................................. .............. .............. 1.28
Total Monetized Benefits [dagger]............................... .............. .............. 4.22
Consumer Incremental Product Costs [Dagger]..................... .............. .............. 7.46
Consumer Net Benefits........................................... .............. .............. -5.18
Total Net Monetized Benefits.................................... .............. .............. -3.24
----------------------------------------------------------------------------------------------------------------
Present Value of Benefits and Costs (7% discount rate, billion 2022$)
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. .............. .............. 1.02
Climate Benefits *.............................................. .............. .............. 0.65
Health Benefits **.............................................. .............. .............. 0.52
Total Monetized Benefits [dagger]............................... .............. .............. 2.20
Consumer Incremental Product Costs [Dagger]..................... .............. .............. 4.12
Consumer Net Benefits........................................... .............. .............. -3.10
Total Net Monetized Benefits.................................... .............. .............. -1.92
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-in coolers and freezers shipped in 2027-
2056. These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-
2056.
* Climate benefits are calculated using four different estimates of the SC-CO2, SC-CH4 and SC-N2O. Together,
these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated
with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and
value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits
of reducing GHG emissions, this analysis uses the interim estimates presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for NOX and SO2) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. The health benefits are presented at real discount rates of 3 and 7 percent. See section IV.L
of this document for more details.
[dagger] Total and net benefits include consumer, climate, and health benefits. For presentation purposes, total
and net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-
percent discount rate.
[Dagger] Costs include incremental equipment costs as well as installation costs.
Table V.95--Summary of Analytical Results for Walk-In Coolers and Freezers Panel TSLs: Manufacturer and Consumer
Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 * TSL 2 * TSL 3 *
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (million 2022$) (No-new- 875.2 875.2 676.5 to 787.4.
standards case INPV = 875.2).
Industry NPV (% change)................... -- -- (22.7) to (10.0).
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings per ft\2\ (2022$)
----------------------------------------------------------------------------------------------------------------
PF.L...................................... -- -- (1.61).
PS.L...................................... -- -- (0.50).
PS.M...................................... -- -- (2.33).
Shipment-Weighted Average *............... -- -- (1.92).
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
PF.L...................................... -- -- 26.1.
PS.L...................................... -- -- 10.1.
PS.M...................................... -- -- 54.0.
Shipment-Weighted Average *............... -- -- 43.7.
----------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost (%)
----------------------------------------------------------------------------------------------------------------
PF.L...................................... -- -- 95.
PS.L...................................... -- -- 64.
PS.M...................................... -- -- 100.
Shipment-Weighted Average *............... -- -- 92.
----------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values. The entry ``--'' means not applicable because there is no change in
the standard at certain TSLs.
* Weighted by shares of each product class in total projected shipments in 2027.
For panels, DOE first considered TSL 3, which represents the max-
tech efficiency levels. At TSL 3, DOE expects that all panels would
require an insulation thickness of 6 inches.
[[Page 60848]]
TSL 3 would save an estimated 0.64 quads of energy, an amount DOE
considers significant. Under TSL 3, the NPV of consumer benefit would
be -$3.10 billion using a discount rate of 7 percent, and -$5.18
billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 11.79 Mt of
CO2, 3.6 thousand tons of SO2, 21.8 thousand tons
of NOX, 0.02 tons of Hg, 982 thousand tons of
CH4, and 0.1 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 3 is $0.65 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 3 is $0.52 billion using a 7-percent discount rate and $1.28
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 3 is -$1.92
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 3 is -$3.24 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 3, the average LCC impact ranges from a savings of -$2.33
per square foot of panel for medium-temperature, structural panels to -
$0.50 per square foot of panel for low-temperature, structural panels.
The simple payback period ranges from 10.1 years for low-temperature,
structural panels to 54.0 years for medium-temperature, structural
panels. The fraction of consumers experiencing a net LCC cost ranges
from 64 percent for low-temperature, structural panels to 100 percent
for medium-temperature, structural panels.
At TSL 3, the projected change in INPV ranges from a decrease of
$198.8 million to a decrease of $87.9 million, which corresponds to
decreases of 22.7 percent and 10.0 percent, respectively. DOE estimates
that industry must invest $241.3 million to update panel designs and
purchase new foaming equipment and tooling to increase insulation
thickness to 6 inches across all panel models.
DOE estimates that 3 percent of walk-in panel shipments currently
meet the max-tech levels. Increasing the insulation thickness for all
panel equipment classes to 6 inches would require significant capital
investment. Like walk-in non-display doors, most manufacturers are
currently able to manufacture walk-in panels up to 5 inches thick. A
standard level necessitating 6-inch panels would likely require new,
costly foaming equipment for all manufacturers. Additionally, DOE
estimates that every additional inch of foam increases panel cure times
by roughly 10 minutes, which means that manufacturers would likely need
to purchase additional equipment to maintain existing throughput. Some
OEMs may need to invest in additional manufacturing space to
accommodate the extra foaming stations. Of the 42 walk-in panel OEMs,
38 OEMs are small, domestic businesses. In interviews, manufacturers
expressed concern about industry's ability to source the necessary
foaming equipment to maintain existing production capacity within the
3-year compliance period due to the long lead times and limited number
of foam fixture suppliers.
The Secretary tentatively concludes that at TSL 3 for walk-in
panels, the benefits of energy savings, emission reductions, and the
estimated monetary value of the emissions reductions would be
outweighed by the economic burden, in the form of negative NPV, on many
consumers, and the impacts on manufacturers, including the large
conversion costs, profit margin impacts that could result in a large
reduction in INPV, and the small number of manufacturers currently
offering products meeting the efficiency levels required at this TSL,
including most small businesses. A majority of panel consumers would
experience a net cost ranging from 64 percent for low-temperature,
structural panels to 100 percent for medium-temperature, structural
panels and the average LCC savings would be negative. The potential
reduction in INPV could be as high as 22.7 percent. The drop in
industry value and reduction in free cash flow after the compliance
year is driven by a range of factors, but most notably the changes are
driven by conversion cost investments manufacturers must make to
redesign and produce more efficient walk-in panels. Most manufacturers
would need to dedicate significant resources to purchase all new
foaming equipment. Due to the longer curing times, some manufacturers
may need to both replace existing foaming equipment and purchase
additional foaming equipment to maintain current production capacity.
Furthermore, most panel manufacturers are small, domestic
manufacturers. Consequently, the Secretary has tentatively concluded
that TSL 3 is not economically justified.
Although DOE considered proposed amended standard levels for walk-
in panels by grouping the efficiency levels for low- and medium-
temperature structural panels and low-temperature floor panels into
TSLs, DOE evaluates all analyzed efficiency levels in its analysis. As
defined in section IV.E.1 of this document, TSL 2 and TSL 1 require
efficiency levels with positive consumer NPV at a 7 percent discount
rate. As shown in appendix 8E of the NOPR TSD, none of the efficiency
level improvements to insulated panels yield positive consumer benefit
for any of the considered equipment classes, resulting in TSL 2 and TSL
1 with efficiency levels at the current baseline.
Therefore, based on the previous considerations, the Secretary is
tentatively proposing to not amend energy conservation standards for
walk-in panels at this time.
c. Refrigeration Systems
The efficiency levels contained in each TSL are shown in Table V.96
and described in section IV.E.1 of this document. Table V.97 and Table
V.98 summarize the quantitative impacts estimated for each TSL for
walk-ins. The national impacts are measured over the lifetime of walk-
ins purchased in the 30-year period that begins in the anticipated year
of compliance with amended standards (2027-2056). The energy savings,
emissions reductions, and value of emissions reductions refer to full-
fuel-cycle results.
Table V.96--Walk-In Refrigeration System Efficiency Levels by Trial Standard Level
----------------------------------------------------------------------------------------------------------------
Capacity
Type Equipment class (kBtu/hr) TSL 1 TSL 2 TSL 3
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing Systems............ DC.L.I.................... 3 1 1 2
DC.L.I.................... 9 0 0 1
DC.L.I.................... 25 2 2 3
[[Page 60849]]
DC.L.I.................... 54 1 1 2
DC.L.O.................... 3 2 2 3
DC.L.O.................... 9 3 3 5
DC.L.O.................... 25 5 7 8
DC.L.O.................... 54 3 4 5
DC.L.O.................... 75 3 3 5
DC.M.I.................... 9 0 0 1
DC.M.I.................... 25 1 1 2
DC.M.I.................... 54 2 2 3
DC.M.I.................... 75 2 2 3
DC.M.O.................... 9 1 2 7
DC.M.O.................... 25 2 3 8
DC.M.O.................... 54 3 3 7
DC.M.O.................... 75 3 3 8
DC.M.O.................... 124 2 3 8
Single-Packaged Dedicated Condensing SP.H.I.................... 2 1 1 2
Systems.
SP.H.I.................... 7 2 2 2
SP.H.ID................... 2 2 2 2
SP.H.ID................... 7 2 2 2
SP.H.O.................... 2 4 5 6
SP.H.O.................... 7 3 5 6
SP.H.OD................... 2 4 5 6
SP.H.OD................... 7 3 6 6
SP.L.I.................... 2 4 4 7
SP.L.I.................... 6 2 2 3
SP.L.O.................... 2 0 0 4
SP.L.O.................... 6 0 0 4
SP.M.I.................... 2 2 3 5
SP.M.I.................... 9 1 1 3
SP.M.O.................... 2 5 7 9
SP.M.O.................... 9 3 3 5
Unit Coolers............................ UC.H.I.................... 9 0 0 1
UC.H.I.................... 25 0 0 1
UC.H.ID................... 9 1 1 1
UC.H.ID................... 25 1 1 1
UC.L...................... 3 1 2 2
UC.L...................... 9 2 2 2
UC.L...................... 25 1 2 2
UC.L...................... 54 2 2 2
UC.L...................... 75 1 2 2
UC.M...................... 3 1 2 2
UC.M...................... 9 2 2 2
UC.M...................... 25 1 2 2
UC.M...................... 54 2 2 2
UC.M...................... 75 1 2 2
----------------------------------------------------------------------------------------------------------------
Table V.97--Summary of Analytical Results for Walk-In Refrigeration
System TSLs: National Impacts
------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3
------------------------------------------------------------------------
Cumulative FFC National Energy Savings
------------------------------------------------------------------------
Quads............................ 0.70 0.91 3.10
CO2 (million metric tons)........ 12.8 16.7 56.8
CH4 (thousand tons).............. 106.8 139.8 474.0
N2O (thousand tons).............. 0.1 0.2 0.6
NOX (thousand tons).............. 23.8 31.1 105.4
SO2 (thousand tons).............. 3.9 5.1 17.4
Hg (tons)........................ 0.03 0.04 0.12
------------------------------------------------------------------------
Present Value of Benefits and Costs (3% discount rate, billion 2022$)
------------------------------------------------------------------------
Consumer Operating Cost Savings.. 1.91 2.31 -9.16
Climate Benefits *............... 0.72 0.95 3.22
Health Benefits **............... 1.42 1.86 6.31
Total Monetized Benefits [dagger] 4.06 5.12 0.37
Consumer Incremental Product 0.42 0.69 15.99
Costs [Dagger]..................
Consumer Net Benefits............ 1.49 1.62 -25.14
Total Net Monetized Benefits..... 3.64 4.44 -15.61
------------------------------------------------------------------------
[[Page 60850]]
Present Value of Benefits and Costs (7% discount rate, billion 2022$)
------------------------------------------------------------------------
Consumer Operating Cost Savings.. 0.88 1.06 -4.17
Climate Benefits *............... 0.72 0.95 3.22
Health Benefits **............... 0.59 0.77 2.63
Total Monetized Benefits [dagger] 2.19 2.79 1.67
Consumer Incremental Product 0.23 0.38 8.82
Costs [Dagger]..................
Consumer Net Benefits............ 0.64 0.68 -12.99
Total Net Monetized Benefits..... 1.96 2.41 -7.15
------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-in
coolers and freezers shipped in 2027-2056. These results include
benefits to consumers which accrue after 2056 from the products
shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the
SC-CO2, SC-CH4 and SC-N2O. Together, these represent the global SC-
GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3 percent discount rate are
shown; however, DOE emphasizes the importance and value of considering
the benefits calculated using all four sets of SC-GHG estimates. To
monetize the benefits of reducing GHG emissions, this analysis uses
the interim estimates presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX
and SO2. DOE is currently only monetizing (for NOX and SO2) PM2.5
precursor health benefits and (for NOX) ozone precursor health
benefits, but will continue to assess the ability to monetize other
effects such as health benefits from reductions in direct PM2.5
emissions. The health benefits are presented at real discount rates of
3 and 7 percent. See section IV.L of this document for more details.
[dagger] Total and net benefits include consumer, climate, and health
benefits. For presentation purposes, total and net benefits for both
the 3-percent and 7-percent cases are presented using the average SC-
GHG with 3-percent discount rate.
[Dagger] Costs include incremental equipment costs as well as
installation costs.
Table V.98--Summary of Analytical Results for Walk-In Coolers and Freezers Refrigeration System TSLs:
Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 * TSL 2 * TSL 3 *
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (million 2022$) (No- 447.2 to 453.0........... 442.2 to 452.2.......... 330.5 to 546.2
new-standards case INPV = 490.1).
Industry NPV (% change).......... (8.7) to (7.6)........... (9.8) to (7.7).......... (32.6) to 11.5
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2022$)
----------------------------------------------------------------------------------------------------------------
DC.L.I........................... 163...................... 163..................... (5,218)
DC.L.O........................... 237...................... 172..................... (15,792)
DC.M.I........................... 567...................... 567..................... (2,047)
DC.M.O........................... 101...................... 136..................... (1,896)
SP.H.I........................... 124...................... 124..................... 103
SP.H.ID.......................... 296...................... 296..................... 296
SP.H.O........................... 159...................... 126..................... (53)
SP.H.OD.......................... 437...................... 305..................... 270
SP.L.I........................... 180...................... 180..................... (1,575)
SP.L.O........................... --....................... --...................... (1,278)
SP.M.I........................... 114...................... 103..................... (1,577)
SP.M.O........................... 186...................... 177..................... (1,116)
UC.H............................. --....................... --...................... (152)
UC.H.ID.......................... 237...................... 237..................... 237
UC.L............................. 1,080.................... 1,306................... 1,306
UC.M............................. 170...................... 212..................... 212
Shipment-Weighted Average \*\.... 308...................... 353..................... (2,384)
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
DC.L.I........................... 4.0...................... 4.0..................... inf
DC.L.O........................... 1.4...................... 3.6..................... inf
DC.M.I........................... 3.4...................... 3.4..................... inf
DC.M.O........................... 1.6...................... 2.6..................... 21.6
SP.H.I........................... 1.3...................... 1.3..................... 2.5
SP.H.ID.......................... 1.7...................... 1.7..................... 1.7
SP.H.O........................... 0.4...................... 2.9..................... 9.0
SP.H.OD.......................... 0.2...................... 3.4..................... 3.8
SP.L.I........................... 3.8...................... 3.8..................... inf
SP.L.O........................... ......................... ........................ 39.0
SP.M.I........................... 3.0...................... 3.5..................... inf
SP.M.O........................... 0.9...................... 1.2..................... 50.8
UC.H............................. ......................... ........................ inf
UC.H.ID.......................... 0.7...................... 0.7..................... 0.7
UC.L............................. 0.9...................... 1.2..................... 1.2
[[Page 60851]]
UC.M............................. 2.0...................... 2.0..................... 2.0
Shipment-Weighted Average \*\.... 2.0...................... 2.4..................... 32.0
----------------------------------------------------------------------------------------------------------------
Percent of Consumers that Experience a Net Cost (%)
----------------------------------------------------------------------------------------------------------------
DC.L.I........................... 11....................... 11...................... 100
DC.L.O........................... 0........................ 8....................... 100
DC.M.I........................... 1........................ 1....................... 100
DC.M.O........................... 0........................ 1....................... 96
SP.H.I........................... 2........................ 2....................... 3
SP.H.ID.......................... 0........................ 0....................... 0
SP.H.O........................... 0........................ 3....................... 81
SP.H.OD.......................... 0........................ 4....................... 13
SP.L.I........................... 7........................ 7....................... 100
SP.L.O........................... --....................... --...................... 100
SP.M.I........................... 4........................ 5....................... 100
SP.M.O........................... 0........................ --...................... 100
UC.H............................. --....................... 0....................... 61
UC.H.ID.......................... 0........................ 0....................... 0
UC.L............................. 3........................ 8....................... 8
UC.M............................. 9........................ 10...................... 10
Shipment-Weighted Average \*\.... 4........................ 6....................... 60
----------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values. The entry ``--'' means not applicable because there is no change in
the standard at certain TSLs.
* Weighted by shares of each product class in total projected shipments in 2027.
For walk-in refrigeration systems, DOE first considered TSL 3,
which represents the max-tech efficiency levels. At this level, DOE
expects that medium- and low-temperature dedicated condensing system
equipment classes \93\ would require larger condenser coils, variable
capacity compressors, and electronically commutated variable-speed
condenser fan motors. Additionally, low- and medium-temperature outdoor
dedicated condensing system equipment classes would generally require
self-regulating crank case heater controls with a temperature switch,
and ambient subcooling circuits. DOE anticipates that low- and medium-
temperature single-packaged dedicated system equipment classes would
also require larger evaporator coils, variable speed evaporator fans,
and thermal insulation up to 4 inches in thickness. DOE expects that
lower-capacity low- and medium-temperature single-packaged dedicated
condensing units would require propane compressors. DOE expects that
high-temperature dedicated condensing system equipment classes would
require the same design options as medium- and low-temperature
dedicated condensing systems except for larger condensing coils and
variable capacity compressors.\94\ Additionally, DOE expects that high-
temperature single-packaged dedicated condensing systems would require
up to 1.5 inches of thermal insulation and would not require larger
evaporator coils or variable speed evaporator fans.\95\ DOE anticipates
that lower-capacity low- and medium-temperature unit cooler equipment
classes would require evaporator coils 4 rows deep at TSL 3. Finally,
DOE anticipates that higher-capacity low- and medium-temperature unit
cooler equipment classes and all high-temperature unit cooler equipment
classes would require evaporator coils 5 rows deep at TSL 3.
---------------------------------------------------------------------------
\93\ Dedicated condensing system equipment classes include
dedicated condensing units, matched-pair refrigeration systems
(consisting of a paired dedicated condensing unit and unit cooler)
and single-packaged dedicated systems.
\94\ As discussed in section IV.C.1.d, DOE did not consider
larger condensing coils or variable capacity compressors for high-
temperature dedicated condensing systems.
\95\ As discussed in section IV.C.1.d of this document, DOE did
not consider larger evaporator coils or off cycle variable speed
evaporator fans for high-temperature single-packaged dedicated
condensing systems and only considered improved thermal insulation
up to 1.5 inches.
---------------------------------------------------------------------------
TSL 3 would save an estimated 3.10 quads of energy, an amount DOE
considers significant. Under TSL 3, the NPV of consumer benefit would
be -$12.99 billion using a discount rate of 7 percent, and -$25.14
billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 56.8 Mt of
CO2, 17.4 thousand tons of SO2, 105.4 thousand
tons of NOX, 0.12 tons of Hg, 474.0 thousand tons of
CH4, and 0.6 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 3 is $3.22 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 3 is $2.63 billion using a 7-percent discount rate and $6.31
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 3 is -$7.15
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 3 is -$15.61 billion. The estimated
total NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 3, the average LCC impact ranges from a savings of -$15,792
for low-temperature outdoor dedicated condensing units to $1,306 for
low-temperature unit coolers. The simple payback period ranges from 1.2
years for low-temperature unit coolers to an infinite payback period
for low-temperature dedicated condensing units, medium-temperature
dedicated condensing units, low- and medium-temperature indoor single-
packaged dedicated systems, and nonducted high-temperature unit
coolers. several equipment classes. The fraction of
[[Page 60852]]
consumers experiencing a net LCC cost ranges from 0 percent for high-
temperature ducted unit coolers and high-temperature indoor ducted
single-packaged dedicated system to 100 percent for low-temperature
indoor and outdoor dedicated condensing units, medium-temperature
indoor dedicated condensing units, and low- and medium-temperature
indoor and outdoor single-packaged dedicated systems.
At TSL 3, the projected change in INPV ranges from a decrease of
$159.6 million to an increase of $56.2 million, which corresponds to a
decrease of 32.6 percent and an increase of 11.5 percent, respectively.
DOE estimates that industry must invest $94.6 million to redesign walk-
in refrigeration systems and purchase new tooling to accommodate
changes to the condensers and/or evaporators for most analyzed
capacities and equipment classes.
Currently, DOE has no evidence of significant shipments meeting the
max-tech levels. As such, all manufacturers would need to redesign
their walk-in refrigeration system models to incorporate a range of
design options to meet TSL 3 efficiencies. Capital conversion costs are
driven by incorporating design options such as larger condenser coils,
improved evaporator coils, and/or ambient subcooling circuits, which
would likely necessitate new tooling for updated baseplate designs
across the full range of refrigeration system capacities and equipment
classes. Implementing these design options would also require notable
engineering resources and testing time, as manufacturers redesign
models and potentially increase the footprint of refrigeration systems
to accommodate larger condensers and/or evaporators.
Manufacturers would also need to qualify, source, and test new
high-efficiency components. For medium- and low-temperature dedicated
condensing system equipment classes that would likely require variable
capacity compressors to meet the max-tech levels, manufacturers could
face challenges sourcing variable capacity compressors across their
portfolio of capacity offerings since the availability of variable
capacity compressors for walk-in applications is limited. At the time
of this NOPR publication, the few variable capacity compressor product
lines DOE identified are not advertised for the North American market.
Additionally, the identified product lines may not have a sufficient
range of available compressor capacities to replace compressors in all
walk-in applications.
The Secretary tentatively concludes that at TSL 3 for walk-in
refrigeration systems, the benefits of energy savings, emissions
reductions, and the estimated monetary value of the emissions
reductions would be outweighed by the economic burden on many consumers
in the form of negative NPV of consumer benefits, and the impacts on
manufacturers, including the large conversion costs, and profit margin
impacts that could result in a large reduction in INPV. Most low- and
medium-temperature dedicated condensing system and single-packaged
dedicated system consumers (ranging from 96 to 100 percent) would
experience a net cost and the average LCC savings would be negative. At
this level, there is risk of greater reduction in INPV at max-tech if
manufacturers maintain their operating profit in the presence of
amended efficiency standards on account of having higher costs but
similar profits. Most manufacturers would need to dedicate notable
capital and engineering resources to incorporate all analyzed design
options across their entire range of equipment classes and capacity
offerings. Furthermore, manufacturers may face challenges sourcing
variable capacity compressors given the limited availability of
variable capacity compressor product lines designed for walk-in
applications. Consequently, the Secretary has tentatively concluded
that TSL 3 is not economically justified.
DOE then considered TSL 2 for walk-in refrigeration systems. DOE
expects that for medium- and low-temperature dedicated condensing
systems, TSL 2 would not include variable capacity compressors.
DOE expects that at TSL 2, low-temperature and indoor medium-
temperature dedicated condensing system equipment classes would
generally require larger condenser coils; low- and medium-temperature
outdoor dedicated condensing system equipment classes would also
generally require self-regulating crank case heater controls with a
temperature switch; additionally, low-temperature outdoor dedicated
condensing system equipment classes would generally require
electronically commutated variable-speed condenser fan motors and may
require ambient subcooling circuits; low- and medium-temperature
single-packaged dedicated system equipment classes would generally
require larger evaporator coils and variable speed evaporator fans;
low-temperature single-packaged dedicated system equipment classes
would generally require thermal insulation up to 4 inches in thickness;
lower-capacity low- and medium-temperature single-packaged dedicated
condensing units would generally require propane compressors; high-
temperature indoor dedicated condensing system equipment classes would
generally incorporate max-tech design options; and high-temperature
outdoor dedicated condensing system equipment classes would generally
require self-regulating crank case heater controls with a temperature
switch, thermal insulation up to 1.5 inches in thickness, and
electronically commutated variable speed condenser fans. DOE expects
that at TSL 2 all unit cooler equipment classes would incorporate the
max-tech design options, except for high-temperature non-ducted unit
coolers, which would generally require evaporator coils 4 rows deep at
TSL 2.
TSL 2 would save an estimated 0.91 quads of energy, an amount DOE
considers significant. Under TSL 2, the NPV of consumer benefit would
be $0.68 billion using a discount rate of 7 percent, and $1.62 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 2 are 16.7 Mt of
CO2, 5.1 thousand tons of SO2, 31.1 thousand tons
of NOX, 0.04 tons of Hg, 139.8 thousand tons of
CH4, and 0.2 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 2 is $.95 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 2 is $0.77 billion using a 7-percent discount rate and $1.68
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 2 is $2.41
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 6 is $4.44 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 2, the average LCC impact ranges from a savings of $103 for
medium-temperature indoor single-packaged dedicated systems to $1,306
for low-temperature non-ducted unit coolers. The simple payback period
ranges from 0.0 years for low-temperature outdoor single-packaged
dedicated systems to 4.0 years for low-
[[Page 60853]]
temperature indoor dedicated condensing units. The fraction of
consumers experiencing a net LCC cost ranges from 0 percent for high-
temperature indoor ducted single-packaged dedicated systems and high-
temperature unit coolers to 11 percent for low-temperature indoor
single-packaged dedicated systems.
At TSL 2, the projected change in INPV ranges from a decrease of
$47.8 million to a decrease of $37.9 million, which corresponds to
decreases of 9.8 percent and 7.7 percent, respectively. DOE estimates
that industry must invest $60.1 million to redesign walk-in
refrigeration systems and purchase some new tooling to accommodate
changes to the condensers and/or evaporators for select capacities and
equipment classes. At this level, DOE expects manufacturers could reach
the TSL 2 efficiencies without implementing all the max-tech design
options. Specifically, only some analyzed dedicated condensing system
representative units would have to incorporate larger condenser coils
or ambient subcooling, reducing the expected capital and product
conversion costs at this level (i.e., DC.L.O.009, DC.L.O.075, and all
DC.M.O representative units would not require larger condensers or
ambient subcooling, which together account for approximately 31 percent
of industry refrigeration system unit shipments). Additionally, at this
level, DOE does not expect manufacturers would need to implement
variable capacity compressors, further reducing industry product
conversion costs as compared to TSL 3.
After considering the analysis and weighing the benefits and
burdens, the Secretary has tentatively concluded that a standard set at
TSL 2 for refrigeration systems would be economically justified. At
this TSL, the average LCC savings for all refrigeration equipment is
positive. The consumers of low-temperature indoor single-packaged
dedicated systems will be most affected with 11 percent of consumers
experiencing a net cost, the consumers of the remaining equipment are
estimated to experience a net cost between 0 and 10 percent of the
time. The FFC national energy savings are significant and the NPV of
consumer benefits is positive using both a 3-percent and 7-percent
discount rate. Notably, the benefits to consumers vastly outweigh the
cost to manufacturers. At TSL 2, the NPV of consumer benefits, even
measured at the more conservative discount rate of 7 percent is over 33
times higher than the maximum estimated manufacturers' loss in INPV.
The standard levels at TSL 2 are economically justified even without
weighing the estimated monetary value of emissions reductions. When
those emissions reductions are included--representing $0.95 billion in
climate benefits (associated with the average SC-GHG at a 3-percent
discount rate), and $1.86 billion (using a 3-percent discount rate) or
$0.77 billion (using a 7-percent discount rate) in health benefits--the
rationale for setting standards at TSL 2 for walk-in refrigeration
systems is further strengthened.
Therefore, based on the previous considerations, DOE proposes to
adopt energy conservation standards for walk-in refrigeration systems
at TSL 2. The proposed amended energy conservation standards for walk-
in refrigeration systems, which are expressed as AWEF2, are shown in
Table V.99.
Table V.99--Proposed Amended Energy Conservation Standards for Walk-In Refrigeration Systems
----------------------------------------------------------------------------------------------------------------
Equipment class Minimum AWEF2 (Btu/W-h) *
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing System--High, Indoor, Non-Ducted with
a Net Capacity (qnet) of:
<7000 Btu/h............................................ 7.80E-04 x qnet + 2.20
>=7000 Btu/h........................................... 7.66
Dedicated Condensing system--High, Outdoor, Non-Ducted with
a Net Capacity (qnet) of:
<7000 Btu/h............................................ 1.02E-03 x qnet + 2.47
>=7000 Btu/h........................................... 9.62
Dedicated Condensing system--High, Indoor, Ducted with a
Net Capacity (qnet) of:
<7000 Btu/h............................................ 2.46E-04 x qnet + 1.55
>=7000 Btu/h........................................... 3.27
Dedicated Condensing system--High, Outdoor, Ducted with a
Net Capacity (qnet) of:
<7000 Btu/h............................................ 3.76E-04 x qnet + 1.78
>=7000 Btu/h........................................... 4.41
Dedicated Condensing unit and Matched Refrigeration System--
Medium, Indoor with a Net Capacity (qnet) of:
<8000 Btu/h............................................ 5.58
>=8000 Btu/h and <25000 Btu/h.......................... 3.00E-05 x qnet + 5.34
>=25000 Btu/h.......................................... 6.09
Dedicated Condensing unit and Matched Refrigeration System--
Medium, Outdoor with a Net Capacity (qnet) of:
<25000 Btu/h........................................... 2.13E-05 x qnet + 7.15
>=25000 Btu/h.......................................... 7.68
Dedicated Condensing unit and Matched Refrigeration System--
Low, Indoor with a Net Capacity (qnet) of:
<25000 Btu/h........................................... 2.50E-05 x qnet + 2.36
>=25000 Btu/h and <54000 Btu/h......................... 1.72E-06 x qnet + 2.94
>=54000 Btu/h.......................................... 3.03
Dedicated Condensing unit and Matched Refrigeration System--
Low, Outdoor with a Net Capacity (qnet) of:
<9000 Btu/h............................................ 9.83E-05 x qnet + 2.63
>=9000 Btu/h and <25000 Btu/h.......................... 3.06E-05 x qnet + 3.23
>=25000 Btu/h and <75000 Btu/h......................... 4.96E-06 x qnet + 3.88
>=75000 Btu/h.......................................... 4.25
Single-Packaged Dedicated Condensing system--Medium, Indoor
with a Net Capacity (qnet) of:
<9000 Btu/h............................................ 9.86E-05 x qnet + 4.91
>=9000 Btu/h........................................... 5.8
Single-Packaged Dedicated Condensing system--Medium,
Outdoor with a Net Capacity (qnet) of:
<9000 Btu/h............................................ 2.47E-04 x qnet + 4.89
>=9000 Btu/h........................................... 7.11
Single-Packaged Dedicated Condensing system--Low, Indoor
with a Net Capacity (qnet) of:
<6000 Btu/h............................................ 8.00E-05 x qnet + 1.8
[[Page 60854]]
>=6000 Btu/h........................................... 2.28
Single-Packaged Dedicated Condensing system--Low, Outdoor
with a Net Capacity (qnet) of:
<6000 Btu/h............................................ 1.63E-04 x qnet + 1.8
>=6000 Btu/h........................................... 2.77
Unit Cooler--High Non-Ducted with a Net Capacity (qnet) of:
<9000 Btu/h............................................ 10.34
>=9000 Btu/h and <25000 Btu/h.......................... 3.83E-04 x qnet + 6.9
>=25000 Btu/h.......................................... 16.46
Unit Cooler--High Ducted with a Net Capacity (qnet) of:
<9000 Btu/h............................................ 6.93
>=9000 Btu/h and <25000 Btu/h.......................... 3.64E-04 x qnet + 3.66
>=25000 Btu/h.......................................... 12.76
Unit Cooler--Medium.................................... 9.65
Unit Cooler--Low....................................... 4.57
----------------------------------------------------------------------------------------------------------------
* Where qnet is net capacity as determined in accordance with Sec. 431.304 and certified in accordance with 10
CFR part 429.
2. Annualized Benefits and Costs of the Proposed Standards
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized net benefit is
(1) the annualized national economic value (expressed in 2022$) of the
benefits from operating products that meet the proposed standards
(consisting primarily of operating cost savings from using less energy,
minus increases in product purchase costs, and (2) the annualized
monetary value of the climate and health benefits from emission
reductions.
Table V.100 shows the annualized values for walk-in non-display
doors and refrigeration systems under TSL 2, expressed in 2022$. The
results under the primary estimate are as follows.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated cost of the standards
proposed in this rule is $126.4 million per year in increased equipment
costs, while the estimated annual benefits are $280.6 million in
reduced equipment operating costs, $190.1 million in climate benefits,
and $245.6 million in health benefits. In this case. The net benefit
would amount to $589.8 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $129.6 million per year in
increased equipment costs, while the estimated annual benefits are
$338.6 million in reduced operating costs, $190.1 million in climate
benefits, and $331.3 million in health benefits. In this case, the net
benefit would amount to $730.5 million per year.
Table V.100--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Walk-Ins
[TSL 2]
----------------------------------------------------------------------------------------------------------------
Million 2022$/year
-----------------------------------------------
Low-net- High-net-
Primary benefits benefits
estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
3% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 260.0 265.3 264.9
Climate Benefits *.............................................. 90.4 92.6 90.0
Health Benefits **.............................................. 177.7 182.1 177.0
Total Monetized Benefits [dagger]............................... 528.1 540.0 531.9
Consumer Incremental Product Costs [Dagger]..................... 72.4 102.6 64.7
Monetized Net Benefits.......................................... 455.7 437.4 467.2
Change in Producer Cashflow (INPV [Dagger][Dagger])............. (7.6)-(5.4) (7.6)-(5.4) (7.6)-(5.4)
----------------------------------------------------------------------------------------------------------------
7% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 214.1 218.8 218.3
Climate Benefits * (3% discount rate)........................... 90.4 92.6 90.0
Health Benefits **.............................................. 132.2 135.3 131.7
Total Monetized Benefits [dagger]............................... 436.7 446.7 440.0
Consumer Incremental Product Costs [Dagger]..................... 70.7 95.4 64.1
Monetized Net Benefits.......................................... 366.0 351.2 376.0
Change in Producer Cashflow (INPV [Dagger][Dagger])............. (7.6)-(5.4) (7.6)-(5.4) (7.6)-(5.4)
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with walk-in coolers and freezers shipped in 2027-
2056. These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-
2056.
[[Page 60855]]
* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO2), methane
(SC-CH4), and nitrous oxide (SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent discount rates;
95th percentile at 3 percent discount rate) (see section IV.L of this document). Together these represent the
global SC-GHG. For presentational purposes of this table, the climate benefits associated with the average SC-
GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and value of considering
the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG
emissions, this analysis uses the interim estimates presented in the Technical Support Document: Social Cost
of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 published in February 2021
by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for SO2 and NOX) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. See section IV.L of this document for more details.
[dagger] Total and net benefits include those consumer, climate, and health benefits that can be quantified and
monetized. For presentation purposes, total and net benefits for both the 3-percent and 7-percent cases are
presented using the average SC-GHG with 3-percent discount rate.
[Dagger] Costs include incremental equipment costs as well as installation costs.
[Dagger][Dagger] Operating Cost Savings are calculated based on the life cycle costs analysis and national
impact analysis as discussed in detail. See sections IV.F and IV.H document. DOE's NIA includes all impacts
(both costs and benefits) along the distribution chain beginning with the increased costs to the manufacturer
to manufacture the product and ending with the increase in price experienced by the consumer. DOE also
separately conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J of this
document. In the detailed MIA, DOE models manufacturers' pricing decisions based on assumptions regarding
investments, conversion costs, cashflow, and margins. The MIA produces a range of impacts, which is the rule's
expected impact on the INPV. The change in INPV is the present value of all changes in industry cash flow,
including changes in production costs, capital expenditures, and manufacturer profit margins. The annualized
change in INPV is calculated using the industry weighted average cost of capital values of 9.4 percent for
walk-in non-display doors and 10.2 percent for walk-in refrigeration systems that are estimated in the
manufacturer impact analysis (see chapter 12 of the NOPR TSD for a complete description of the industry
weighted average cost of capital). For walk-ins, those values are -$7.6 million to -$5.4 million. DOE accounts
for that range of likely impacts in analyzing whether a TSL is economically justified. See section V.C of this
document. DOE is presenting the range of impacts to the INPV under two markup scenarios: the Preservation of
Gross Margin scenario, which is the manufacturer markup scenario used in the calculation of Consumer Operating
Cost Savings in this table, and the Preservation of Operating Profit Markup scenario, where DOE assumed
manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the above
table, drawing on the MIA explained further in section IV.J of this document, to provide additional context
for assessing the estimated impacts of this proposal to society, including potential changes in production and
consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. If DOE were to include the INPV into
the annualized net benefit calculation for this proposed rule, the annualized net benefits would range from
$448.1 million to $450.3 million at 3-percent discount rate and would range from $358.4 million to $360.6
million at 7-percent discount rate. Parentheses () indicate negative values. DOE seeks comment on this
approach.
D. Reporting, Certification, and Sampling Plan
Manufacturers, including importers, must use product-specific
certification templates to certify compliance to DOE. For walk-in
coolers and freezers, the certification template reflects the general
certification requirements specified at 10 CFR 429.12 and the product-
specific requirements specified at 10 CFR 429.53. As discussed in the
previous paragraphs, DOE is not proposing to amend the product-specific
certification requirements for this equipment in this proposed
rulemaking.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866, 13563, and 14094
Executive Order (``E.O.'') 12866, ``Regulatory Planning and
Review,'' as supplemented and reaffirmed by E.O. 13563, ``Improving
Regulation and Regulatory Review,'' 76 FR 3821 (Jan. 21, 2011) and
amended by E.O. 14094, ``Modernizing Regulatory Review,'' 88 FR 21879
(April 11, 2023), requires agencies, to the extent permitted by law, to
(1) propose or adopt a regulation only upon a reasoned determination
that its benefits justify its costs (recognizing that some benefits and
costs are difficult to quantify); (2) tailor regulations to impose the
least burden on society, consistent with obtaining regulatory
objectives, taking into account, among other things, and to the extent
practicable, the costs of cumulative regulations; (3) select, in
choosing among alternative regulatory approaches, those approaches that
maximize net benefits (including potential economic, environmental,
public health and safety, and other advantages; distributive impacts;
and equity); (4) to the extent feasible, specify performance
objectives, rather than specifying the behavior or manner of compliance
that regulated entities must adopt; and (5) identify and assess
available alternatives to direct regulation, including providing
economic incentives to encourage the desired behavior, such as user
fees or marketable permits, or providing information upon which choices
can be made by the public. DOE emphasizes as well that E.O. 13563
requires agencies to use the best available techniques to quantify
anticipated present and future benefits and costs as accurately as
possible. In its guidance, the Office of Information and Regulatory
Affairs (``OIRA'') in the Office of Management and Budget (``OMB'') has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. For the reasons stated in the preamble,
this proposed regulatory action is consistent with these principles.
Section 6(a) of E.O. 12866 also requires agencies to submit
``significant regulatory actions'' to OIRA for review. OIRA has
determined that this final regulatory action constitutes a
``significant regulatory action'' within the scope of section 3(f)(1)
of E.O. 12866. Accordingly, pursuant to section 6(a)(3)(C) of E.O.
12866, DOE has provided to OIRA an assessment, including the underlying
analysis, of benefits and costs anticipated from the final regulatory
action, together with, to the extent feasible, a quantification of
those costs; and an assessment, including the underlying analysis, of
costs and benefits of potentially effective and reasonably feasible
alternatives to the planned regulation, and an explanation why the
planned regulatory action is preferable to the identified potential
alternatives. These assessments are summarized in this preamble and
further detail can be found in the technical support document for this
rulemaking.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (``IRFA'')
for any rule that by law must be proposed for public comment, unless
the agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by E.O. 13272, ``Proper Consideration of Small Entities in
Agency Rulemaking,'' 67 FR 53461 (Aug. 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
[[Page 60856]]
available on the Office of the General Counsel's website (energy.gov/gc/office-general-counsel). DOE has prepared the following IRFA for the
products that are the subject of this rulemaking.
For manufacturers of walk-ins, the SBA has set a size threshold,
which defines those entities classified as ``small businesses'' for the
purposes of the statute. DOE used the SBA's small business size
standards to determine whether any small entities would be subject to
the requirements of the rule. (See 13 CFR part 121.) The size standards
are listed by North American Industry Classification System (``NAICS'')
code and industry description and are available at www.sba.gov/document/support--table-size-standards. Manufacturing of walk-ins is
classified under NAICS 333415, ``Air Conditioning and Warm Air Heating
Equipment and Commercial and Industrial Refrigeration Equipment
Manufacturing.'' The SBA sets a threshold of 1,250 employees or fewer
for an entity to be considered as a small business for this category.
1. Description of Reasons Why Action Is Being Considered
DOE is proposing amended energy conservation standards for walk-
ins. EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. Title III, Part
C of EPCA, added by Public Law 95-619, Title IV, section 441(a) (42
U.S.C. 6311-6317, as codified), established the Energy Conservation
Program for Certain Industrial Equipment, which sets forth a variety of
provisions designed to improve energy efficiency. This equipment
includes walk-ins, the subject of this document. (42 U.S.C. 6311(1)(G))
EPCA prescribed initial standards for these products. (42 U.S.C.
6313(f)(1)) EPCA provides that, not later than 6 years after the
issuance of any final rule establishing or amending a standard, DOE
must publish either a notice of determination that standards for the
product do not need to be amended, or a NOPR including new proposed
energy conservation standards (proceeding to a final rule, as
appropriate). (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1))
DOE prescribed the energy conservation standards for walk-in doors,
panels, and refrigeration systems manufactured on and after June 5,
2017 in a final rule published on June 3, 2014. 79 FR 32050. After
publication of the June 2014 Final Rule, AHRI and Lennox International,
Inc. (``Lennox''), a manufacturer of walk-in refrigeration systems,
filed petitions for review of DOE's final rule and DOE's subsequent
denial of a petition for reconsideration of the rule (79 FR 59090
(October 1, 2014)) with the United States Court of Appeals for the
Fifth Circuit. Lennox Int'l v. Dep't of Energy, Case No. 14-60535 (5th
Cir.). A settlement agreement was reached among the parties under which
the Fifth Circuit vacated energy conservation standards for six of the
refrigeration system equipment classes--the two standards applicable to
multiplex condensing refrigeration systems (subsequently re-named as
``unit coolers'') operating at medium and low-temperatures and the four
standards applicable to dedicated condensing refrigeration systems
operating at low-temperatures.\96\ After the Fifth Circuit issued its
order, DOE established a Working Group to negotiate energy conservation
standards to replace the six vacated standards. 80 FR 46521 (August 5,
2015). In a final rule published on July 10, 2017, DOE adopted energy
conservation standards for the six classes of walk-in refrigeration
systems were vacated--specifically, unit coolers and low-temperature
dedicated condensing systems manufactured. 82 FR 31808. The rule
required compliance with the six new standards on and after July 10,
2020. This rulemaking is in accordance with DOE's obligations under
EPCA.
---------------------------------------------------------------------------
\96\ The 13 other standards established in the June 2014 Final
Rule (i.e., the four standards applicable to dedicated condensing
refrigeration systems operating at medium temperatures; the three
standards applicable to panels; and the six standards applicable to
doors) were not vacated. The compliance date for the remaining
standards was on or after June 5, 2017.
---------------------------------------------------------------------------
2. Objectives of, and Legal Basis for, Rule
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. Title III, Part
C of EPCA, added by Public Law 95-619, Title IV, section 441(a) (42
U.S.C. 6311-6317, as codified), established the Energy Conservation
Program for Certain Industrial Equipment, which sets forth a variety of
provisions designed to improve energy efficiency. This equipment
includes walk-ins, the subject of this document. (42 U.S.C. 6311(1)(G))
EPCA prescribed initial standards for these products. EPCA further
provides that, not later than 6 years after the issuance of any final
rule establishing or amending a standard, DOE must publish either a
notice of determination that standards for the product do not need to
be amended, or a NOPR including new proposed energy conservation
standards (proceeding to a final rule, as appropriate). (42 U.S.C.
6316(a); 42 U.S.C. 6295(m)(1))
3. Description on Estimated Number of Small Entities Regulated
DOE conducted a market survey using public information and
subscription-based company reports to identify potential small
manufacturers. DOE constructed databases of walk-in doors, panels, and
refrigeration systems based on its review of models listed in DOE's
Compliance Certification Database (CCD),\97\ and supplemented the
information in CCD with information from the California Energy
Commission's Modernized Appliance Efficiency Database System (for
refrigeration systems),\98\ individual company websites, and prior
walk-in rulemakings (79 FR 32050) to create a comprehensive database of
walk-in components available on the U.S. market and their
characteristics. DOE examined this database to identify companies that
manufacture, produce, import, or assemble the equipment covered by this
rulemaking. DOE then consulted publicly available data, such as
manufacturer websites, manufacturer specifications and product
literature, import/export logs (e.g., bills of lading from Panjiva
\99\), and basic model numbers, to identify original equipment
manufacturers (OEMs) of walk-in doors, panels, and refrigeration
systems. DOE further relied on public data and subscription-based
market research tools (e.g., Dun & Bradstreet reports \100\) to
determine company, location, headcount, and annual revenue. DOE
screened out companies that do not offer equipment covered by this
rulemaking, do not meet the SBA's definition of a ``small business,''
or are foreign-owned and operated.
---------------------------------------------------------------------------
\97\ U.S. Department of Energy's Compliance Certification
Database is available at: www.regulations.doe.gov/certification-data/#q=Product_Group_s%3A* (Last accessed January 27, 2023).
\98\ California Energy Commission's Modernized Appliance
Efficiency Database System is available at:
cacertappliances.energy.ca.gov/Pages/Search/AdvancedSearch.aspx.
(Last accessed January 27, 2023.)
\99\ S&P Global. Panjiva Market Intelligence is available at:
panjiva.com/import-export/United-States (Last accessed April 11,
2023).
\100\ The Dun & Bradstreet Hoovers subscription login is
available at app.dnbhoovers.com. (Last accessed April 11, 2023).
---------------------------------------------------------------------------
Using these data sources, DOE identified 79 original equipment
manufacturers (OEMs) of WICFs that could be potentially affected by
this rulemaking. Of these 79 OEMs, 58 are small, domestic
manufacturers. DOE notes that some manufacturers may produce more than
one of the principal components of WICFs: doors, panels,
[[Page 60857]]
and refrigeration systems. Forty-four of the small, domestic OEMs
manufacture doors; 38 of the small, domestic OEMs manufacture panels;
and 14 of the small, domestic OEMs manufacture refrigeration systems.
4. Description and Estimate of Compliance Requirements Including
Differences in Cost, if Any, for Different Groups of Small Entities
a. Doors
In this NOPR, DOE is proposing not to amend energy conservation
standards for walk-in display doors. Walk-in display doors would remain
at the current DOE minimum efficiency. Manufacturers, including small
business manufacturers, would not need to make additional investments
for walk-in display doors to comply with the proposed standard levels.
In this NOPR, DOE is proposing to amend energy conservation
standards for walk-in non-display doors. Of the 44 small, domestic OEMs
of walk-in doors, 40 manufacture non-display doors. At TSL 2, DOE
expects manufacturers would need to update all non-display door designs
to incorporate anti-sweat heater controls, improved door frame designs,
and reduced anti-sweat heat. DOE does not expect manufacturers would
need to increase insulation thickness to meet the efficiency levels
required by the proposed level. However, manufacturers may need to
invest in improved frame designs, which are most commonly made of
polyurethane foam. Capital conversion costs are investments in
property, plant, and equipment necessary to adapt or change existing
production facilities such that new compliant equipment designs can be
fabricated and assembled. Product conversion costs are investments in
research, development, testing, marketing, and other non-capitalized
costs necessary to make equipment designs comply with amended energy
conservation standards. For the purposes of this IRFA, DOE assumed that
the industry capital and product conversion costs would be evenly
distributed across the 43 walk-in non-display door OEMs to avoid
underestimating the potential capital and R&D investments small
manufacturers may incur as a result of the proposed standard. DOE's
investment estimates are based on results from the equipment teardown
analysis, which assumed an average, representative production volume
and feedback from higher volume manufacturers in confidential
interviews. However, many of the small manufacturers have lower
production volumes and require less production capacity (e.g., fewer
foam fixtures).
Therefore, DOE estimates that the 38 small businesses that only
manufacture swinging non-display doors (i.e., NM.L, NM.M) may each
incur $0.6 million in capital and product conversion costs and that the
two small businesses that also manufacture motorized doors (i.e., NO.L,
NO.M), may each incur conversion costs of approximately $1.2 million to
meet the efficiencies required at TSL 2. Based on market research tools
(e.g., Dun & Bradstreet reports), DOE estimates that the annual revenue
of small, domestic walk-in non-display door OEMs range from
approximately $1.8 million to approximately $276.8 million, with an
average annual revenue of $32.6 million. Conversion costs range from
$0.6 million to $1.2 million, with average per OEM conversion costs of
$0.6 million, which are approximately 2.9 percent of company revenue,
on average, over the 3-year conversion period. See Table VI.1 for
additional details. See section IV.J.2.c of the document and chapter 12
of the NOPR TSD for additional information on the conversion cost
methodology and estimates.
Table VI.1--Potential Small Business Impacts: Walk-In Non-Display Doors
----------------------------------------------------------------------------------------------------------------
Average conversion
Range of estimated annual revenue Average per OEM costs as a % of
Number of small, domestic OEMs ($ millions) conversion costs conversion period
($ millions) revenue
----------------------------------------------------------------------------------------------------------------
11................................. <=5.0............................ 0.6 7.3
10................................. >5.0 and <=15.0.................. 0.6 2.3
11................................. >15.0 and <=30.0................. 0.7 0.9
8.................................. >30.0............................ 0.7 0.3
----------------------------------------------------------------------------------------------------------------
DOE seeks comments, information, and data on the number of small
businesses in the walk-in display and non-display door market, the
names of those small businesses, and their market shares by equipment
class. DOE also requests comment on the potential impacts of the
proposed standards on small walk-in display and non-display door
manufacturers.
b. Panels
In this NOPR, DOE is proposing not to amend energy conservation
standards for walk-in panels. Therefore, DOE does not expect that
manufacturers of walk-in panels, including small business
manufacturers, would be directly impacted by the efficiency levels
proposed in this NOPR as the levels would remain at the current DOE
minimum efficiency.
DOE seeks comments, information, and data on the number of small
businesses in the walk-in panel industry, the names of those small
businesses, and their market shares by equipment class. DOE also
requests comment on the potential impacts of the proposed standards on
small walk-in panel manufacturers.
c. Refrigeration Systems
In this NOPR, DOE is proposing to amend energy conservation
standards for walk-in refrigeration systems. At TSL 2, DOE expects some
manufacturers of low-temperature and indoor medium-temperature
dedicated condensing system equipment classes would generally need to
incorporate larger condenser coils and/or ambient subcooling circuits;
manufacturers of low- and medium-temperature outdoor dedicated
condensing system equipment classes would also generally need to
incorporate self-regulating crank case heater controls with a
temperature switch; additionally, low-temperature outdoor dedicated
condensing system equipment classes would generally require
electronically commutated variable-speed condenser fan motors and may
require ambient subcooling circuits; manufacturers of low- and medium-
temperature single-packaged dedicated system equipment classes would
generally need to incorporate larger evaporator coils and variable-
speed evaporator fans; manufacturers of low-temperature single-packaged
dedicated system equipment classes would also generally require thermal
insulation up to 4 inches in thickness; manufacturers of lower-capacity
low- and medium-temperature single-
[[Page 60858]]
packaged dedicated condensing units would generally need to incorporate
propane compressors; manufacturers of high-temperature indoor dedicated
condensing system equipment classes would generally have to incorporate
max-tech design options; and manufacturers of high-temperature outdoor
dedicated condensing system equipment classes would generally have to
incorporate self-regulating crank case heater controls with a
temperature switch, thermal insulation up to 1.5 inches in thickness,
and electronically commutated variable speed condenser fans. DOE
expects that at TSL 2 all unit cooler equipment classes would
incorporate the max-tech design options, except for high-temperature
non-ducted unit coolers, which would generally require evaporator coils
4 rows deep at TSL 2.
Of the 14 small, domestic OEMs of walk-in refrigeration systems,
five OEMs only manufacture high-temperature units (i.e., SP.H.I,
SP.H.ID, SP.H.O, SP.H.OD, UC.H, and/or UC.H.ID), three OEMs only
manufacture low- and medium temperature dedicated condensing systems,
two OEMs only manufacture low- and medium temperature unit coolers, and
the remaining four OEMs manufacture low and medium temperature
dedicated condensing systems and unit coolers.
For the five high-temperature OEMs, at TSL 2, DOE does not expect
these small manufacturers would incur any capital conversion costs.
Based on information gathered during manufacturer interviews, DOE
understands that manufacturers of high-temperature units typically
purchase the heat exchangers used for walk-in systems and would
therefore not incur any capital conversion costs as a direct result of
the proposed rule. For the remaining nine small, domestic OEMs of
dedicated condensing systems and/or unit coolers, manufacturers would
need to invest in new tooling to accommodate larger condenser coils,
ambient subcooling, and/or larger evaporator coils. For the purposes of
this IRFA, DOE assumed that the industry capital and product conversion
costs for each equipment class would be evenly distributed across the
OEMs that manufacture those equipment classes to avoid underestimating
the potential capital and R&D investments small manufacturers may incur
as a result of the proposed standard. DOE believes this conservative
approach represents an upper bound of potential small business
investments. DOE's investment estimates are based on results from the
equipment teardown analysis, which assumed an average, representative
production volume and array of capacity offerings. However, small
manufacturers have lower production volumes and require less production
capacity (e.g., lower tooling costs).
Based on market research tools (e.g., Dun & Bradstreet reports),
DOE estimates that annual revenue of small, domestic walk-in
refrigeration system OEMs range from approximately $3.7 million to
approximately $276.8 million, with an average annual revenue of $74.9
million. The conversion costs range from $0.3 million to $3.8 million,
with average per OEM conversion costs of $1.8 million, which are
approximately 2.6 percent of company revenue, on average, over the 3-
year conversion period. See Table VI.2 for additional details.
Table VI.2--Potential Small Business Impacts: Walk-In Refrigeration Systems
----------------------------------------------------------------------------------------------------------------
Conversion
Estimated Estimated Estimated costs as a
capital product total Estimated % of
Company conversion conversion conversion annual revenue conversion
costs ($ costs ($ costs ($ ($ millions) period
millions) millions) millions) revenue
----------------------------------------------------------------------------------------------------------------
Manufacturer 1..................... 0.0 0.3 0.3 3.7 2.8
Manufacturer 2..................... 0.0 0.3 0.3 3.9 2.6
Manufacturer 3..................... 1.3 0.8 2.1 6.3 11.3
Manufacturer 4..................... 0.0 0.3 0.3 8.9 1.2
Manufacturer 5..................... 0.0 0.3 0.3 10.7 1.0
Manufacturer 6..................... 1.3 0.8 2.1 11.4 6.3
Manufacturer 7..................... 1.3 0.8 2.1 13.1 5.4
Manufacturer 8..................... 0.8 0.7 1.5 33.8 1.5
Manufacturer 9..................... 2.1 1.5 3.6 88.7 1.4
Manufacturer 10.................... 2.1 1.7 3.8 110.3 1.1
Manufacturer 11.................... 2.1 1.5 3.6 116.2 1.0
Manufacturer 12.................... 2.1 1.7 3.8 156.3 0.8
Manufacturer 13.................... 0.0 0.3 0.3 208 0.1
Manufacturer 14.................... 0.8 0.7 1.5 276.8 0.2
----------------------------------------------------------------------------------------------------------------
DOE seeks comments, information, and data on the number of small
businesses in the walk-in refrigeration system industry, the names of
those small businesses, and their market shares by equipment class. DOE
also requests comment on the potential impacts of the proposed
standards on small walk-in refrigeration system manufacturers.
5. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the proposed rule.
6. Significant Alternatives to the Rule
The discussion in the previous section analyzes impacts on small
businesses that would result from DOE's proposed rule, represented by
TSL 2 for walk-in doors, panels, and refrigeration systems. In
reviewing alternatives to the proposed rule, DOE examined energy
conservation standards set at lower efficiency levels for walk-in non-
display doors and refrigeration systems. While TSL 1 would reduce the
impacts on small business manufacturers of walk-in non-display doors
and refrigeration systems, it would come at the expense of a reduction
in energy savings. For walk-in non-display doors, TSL 1 achieves 1.1
percent lower energy savings compared to the energy savings at TSL 2.
For walk-in refrigeration systems, TSL 1 achieves 11.5 percent lower
energy savings compared to the energy savings at TSL 2.
[[Page 60859]]
Based on the presented discussion, establishing standards at TSL 2
for walk-in non-display doors and refrigeration systems balances the
benefits of the energy savings at TSL 2 with the potential burdens
placed on walk-ins manufacturers, including small business
manufacturers. Accordingly, DOE does not propose one of the other TSLs
considered in the analysis, or the other policy alternatives examined
as part of the regulatory impact analysis and included in chapter 17 of
the NOPR TSD.
Additional compliance flexibilities may be available through other
means. Manufacturers subject to DOE's energy efficiency standards may
apply to DOE's Office of Hearings and Appeals for exception relief
under certain circumstances. Manufacturers should refer to 10 CFR part
430, subpart E, and 10 CFR part 1003 for additional details.
C. Review Under the Paperwork Reduction Act
Under the procedures established by the Paperwork Reduction Act of
1995 (``PRA''), a person is not required to respond to a collection of
information by a Federal agency unless that collection of information
displays a currently valid OMB Control Number.
OMB Control Number 1910-1400, Compliance Statement Energy/Water
Conservation Standards for Appliances, is currently valid and assigned
to the certification reporting requirements applicable to covered
equipment, including walk-in coolers and freezers.
DOE's certification and compliance activities ensure accurate and
comprehensive information about the energy and water use
characteristics of covered products and covered equipment sold in the
United States. Manufacturers of all covered products and covered
equipment must submit a certification report before a basic model is
distributed in commerce, annually thereafter, and if the basic model is
redesigned in such a manner to increase the consumption or decrease the
efficiency of the basic model such that the certified rating is no
longer supported by the test data. Additionally, manufacturers must
report when production of a basic model has ceased and is no longer
offered for sale as part of the next annual certification report
following such cessation. DOE requires the manufacturer of any covered
product or covered equipment to establish, maintain, and retain the
records of certification reports, of the underlying test data for all
certification testing, and of any other testing conducted to satisfy
the requirements of part 429, part 430, and/or part 431. Certification
reports provide DOE and consumers with comprehensive, up-to date
efficiency information and support effective enforcement.
Revised certification data would be required for walk-in
refrigeration systems were this NOPR to be finalized as proposed;
however, DOE is not proposing amended certification or reporting
requirements for walk-in refrigeration systems in this NOPR. Instead,
DOE may consider proposals to establish certification requirements and
reporting for walk-in refrigeration systems under a separate rulemaking
regarding appliance and equipment certification. DOE will address
changes to OMB Control Number 1910-1400 at that time, as necessary.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
Manufacturers of walk-in doors and panels must certify to DOE that
their products comply with any applicable energy conservation
standards. In certifying compliance, manufacturers must test their
products according to the DOE test procedures for walk-ins, including
any amendments adopted for those test procedures. DOE has established
regulations for the certification and recordkeeping requirements for
all covered consumer products and commercial equipment, including walk-
ins. (See generally 10 CFR part 429). The collection-of-information
requirement for the certification and recordkeeping is subject to
review and approval by OMB under the Paperwork Reduction Act (``PRA'').
This requirement has been approved by OMB under OMB control number
1910-1400. Public reporting burden for the certification is estimated
to average 35 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
DOE is analyzing this proposed regulation in accordance with the
National Environmental Policy Act of 1969 (``NEPA'') and DOE's NEPA
implementing regulations (10 CFR part 1021). DOE's regulations include
a categorical exclusion for rulemakings that establish energy
conservation standards for consumer products or industrial equipment.
10 CFR part 1021, subpart D, appendix B5.1. DOE anticipates that this
rulemaking qualifies for categorical exclusion B5.1 because it is a
rulemaking that establishes energy conservation standards for consumer
products or industrial equipment, none of the exceptions identified in
categorical exclusion B5.1(b) apply, no extraordinary circumstances
exist that require further environmental analysis, and it otherwise
meets the requirements for application of a categorical exclusion. See
10 CFR 1021.410. DOE will complete its NEPA review before issuing the
final rule.
E. Review Under Executive Order 13132
E.O. 13132, ``Federalism,'' 64 FR 43255 (Aug. 10, 1999), imposes
certain requirements on Federal agencies formulating and implementing
policies or regulations that preempt State law or that have federalism
implications. The Executive order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE has examined this proposed rule and has
tentatively determined that it 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. EPCA governs
and prescribes Federal preemption of State regulations as to energy
conservation for the equipment that are the subject of this proposed
rule. States can petition DOE for exemption from such preemption to the
extent, and based on criteria, set forth in EPCA. (See 42 U.S.C.
6316(a) and (b); 42 U.S.C. 6297) Therefore, no further action is
required by Executive Order 13132.
[[Page 60860]]
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of E.O. 12988, ``Civil
Justice Reform,'' imposes on Federal agencies the general duty to
adhere to the following requirements: (1) eliminate drafting errors and
ambiguity, (2) write regulations to minimize litigation, (3) provide a
clear legal standard for affected conduct rather than a general
standard, and (4) promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Regarding the review required by section 3(a),
section 3(b) of E.O. 12988 specifically requires that Executive
agencies make every reasonable effort to ensure that the regulation:
(1) clearly specifies the preemptive effect, if any, (2) clearly
specifies any effect on existing Federal law or regulation, (3)
provides a clear legal standard for affected conduct while promoting
simplification and burden reduction, (4) specifies the retroactive
effect, if any, (5) adequately defines key terms, and (6) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in section 3(a) and section 3(b) to
determine whether they are met or it is unreasonable to meet one or
more of them. DOE has completed the required review and determined
that, to the extent permitted by law, this proposed rule meets the
relevant standards of E.O. 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (``UMRA'')
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, section 201 (codified at 2 U.S.C.
1531). For a proposed regulatory action likely to result in a rule that
may cause the expenditure by State, local, and Tribal governments, in
the aggregate, or by the private sector of $100 million or more in any
one year (adjusted annually for inflation), section 202 of UMRA
requires a Federal agency to publish a written statement that estimates
the resulting costs, benefits, and other effects on the national
economy. (2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal
agency to develop an effective process to permit timely input by
elected officers of State, local, and Tribal governments on a proposed
``significant intergovernmental mandate,'' and requires an agency plan
for giving notice and opportunity for timely input to potentially
affected small governments before establishing any requirements that
might significantly or uniquely affect them. On March 18, 1997, DOE
published a statement of policy on its process for intergovernmental
consultation under UMRA. 62 FR 12820. DOE's policy statement is also
available at www.energy.gov/sites/prod/files/gcprod/documents/umra_97.pdf.
This rule does not contain a Federal intergovernmental mandate, nor
is it expected to require expenditures of $100 million or more in any
one year by the private sector. As a result, the analytical
requirements of UMRA do not apply.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
Pursuant to E.O. 12630, ``Governmental Actions and Interference
with Constitutionally Protected Property Rights,'' 53 FR 8859 (Mar. 15,
1988), DOE has determined that this proposed rule would not result in
any takings that might require compensation under the Fifth Amendment
to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for Federal agencies to review
most disseminations of information to the public under information
quality guidelines established by each agency pursuant to general
guidelines issued by OMB. OMB's guidelines were published at 67 FR 8452
(Feb. 22, 2002), and DOE's guidelines were published at 67 FR 62446
(Oct. 7, 2002). Pursuant to OMB Memorandum M-19-15, Improving
Implementation of the Information Quality Act (April 24, 2019), DOE
published updated guidelines which are available at www.energy.gov/sites/prod/files/2019/12/f70/DOE%20Final%20Updated%20IQA%20Guidelines%20Dec%202019.pdf. DOE has
reviewed this NOPR under the OMB and DOE guidelines and has concluded
that it is consistent with applicable policies in those guidelines.
K. Review Under Executive Order 13211
E.O. 13211, ``Actions Concerning Regulations That Significantly
Affect Energy Supply, Distribution, or Use,'' 66 FR 28355 (May 22,
2001), requires Federal agencies to prepare and submit to OIRA at OMB,
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgates or is expected to lead to promulgation of a
final rule, and that (1) is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
DOE has tentatively concluded that this regulatory action, which
proposes amended energy conservation standards for walk-ins, is not a
significant energy action because the proposed standards are not likely
to have a significant adverse effect on the supply, distribution, or
use of energy, nor has it been designated as such by the Administrator
at OIRA. Accordingly, DOE has not prepared a Statement of Energy
Effects on this proposed rule.
L. Information Quality
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (``OSTP''), issued its Final Information
Quality Bulletin for Peer Review (``the Bulletin''). 70 FR 2664 (Jan.
14, 2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the Bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as ``scientific
[[Page 60861]]
information the agency reasonably can determine will have, or does
have, a clear and substantial impact on important public policies or
private sector decisions.'' 70 FR 2664, 2667.
In response to OMB's Bulletin, DOE conducted formal peer reviews of
the energy conservation standards development process and the analyses
that are typically used and has prepared a report describing that peer
review.\101\ Generation of this report involved a rigorous, formal, and
documented evaluation using objective criteria and qualified and
independent reviewers to make a judgment as to the technical/
scientific/business merit, the actual or anticipated results, and the
productivity and management effectiveness of programs and/or projects.
Because available data, models, and technological understanding have
changed since 2007, DOE has engaged with the National Academy of
Sciences to review DOE's analytical methodologies to ascertain whether
modifications are needed to improve the Department's analyses. DOE is
in the process of evaluating the resulting report.\102\
---------------------------------------------------------------------------
\101\ The 2007 ``Energy Conservation Standards Rulemaking Peer
Review Report'' is available at the following website: energy.gov/eere/buildings/downloads/energy-conservation-standards-rulemaking-peer-review-report-0 (last accessed April 17, 2023).
\102\ The report is available at www.nationalacademies.org/our-work/review-of-methods-for-setting-building-and-equipment-performance-standards.
---------------------------------------------------------------------------
VII. Public Participation
A. Participation in the Webinar
The time and date the webinar meeting are listed in the DATES
section at the beginning of this document. Webinar registration
information, participant instructions, and information about the
capabilities available to webinar participants will be published on
DOE's website: https://www.energy.gov/eere/buildings/public-meetings-and-comment-deadlines. Participants are responsible for ensuring their
systems are compatible with the webinar software.
B. Procedure for Submitting Prepared General Statements for
Distribution
Any person who has an interest in the topics addressed in this
proposed rule, or who is representative of a group or class of persons
that has an interest in these issues, may request an opportunity to
make an oral presentation at the webinar. Such persons may submit to
[email protected]. Persons who wish to speak
should include with their request a computer file in WordPerfect,
Microsoft Word, PDF, or text (ASCII) file format that briefly describes
the nature of their interest in this rulemaking and the topics they
wish to discuss. Such persons should also provide a daytime telephone
number where they can be reached.
C. Conduct of the Webinar
DOE will designate a DOE official to preside at the webinar/public
meeting and may also use a professional facilitator to aid discussion.
The meeting will not be a judicial or evidentiary-type public hearing,
but DOE will conduct it in accordance with section 336 of EPCA (42
U.S.C. 6306). A court reporter will be present to record the
proceedings and prepare a transcript. DOE reserves the right to
schedule the order of presentations and to establish the procedures
governing the conduct of the webinar. There shall not be discussion of
proprietary information, costs or prices, market share, or other
commercial matters regulated by U.S. anti-trust laws. After the webinar
and until the end of the comment period, interested parties may submit
further comments on the proceedings and any aspect of the proposed
rulemaking.
The webinar will be conducted in an informal, conference style. DOE
will present a general overview of the topics addressed in this
rulemaking, allow time for prepared general statements by participants,
and encourage all interested parties to share their views on issues
affecting this rulemaking. Each participant will be allowed to make a
general statement (within time limits determined by DOE), before the
discussion of specific topics. DOE will permit, as time permits, other
participants to comment briefly on any general statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly. Participants should
be prepared to answer questions by DOE and by other participants
concerning these issues. DOE representatives may also ask questions of
participants concerning other matters relevant to this rulemaking. The
official conducting the webinar/public meeting will accept additional
comments or questions from those attending, as time permits. The
presiding official will announce any further procedural rules or
modification of the above procedures that may be needed for the proper
conduct of the webinar.
A transcript of the webinar will be included in the docket, which
can be viewed as described in the Docket section at the beginning of
this notice. In addition, any person may buy a copy of the transcript
from the transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. Interested parties may submit comments, data, and other
information using any of the methods described in the ADDRESSES section
at the beginning of this document.
Submitting comments via www.regulations.gov. The
www.regulations.gov web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (``CBI'')). Comments submitted
through www.regulations.gov cannot be claimed as CBI. Comments received
through the website will waive any CBI claims for the information
submitted. For information on submitting CBI, see the Confidential
Business Information section.
DOE processes submissions made through www.regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of
[[Page 60862]]
comments are being processed simultaneously, your comment may not be
viewable for up to several weeks. Please keep the comment tracking
number that www.regulations.gov provides after you have successfully
uploaded your comment.
Submitting comments via email, hand delivery/courier, or postal
mail. Comments and documents submitted via email, hand delivery/
courier, or postal mail also will be posted to www.regulations.gov. If
you do not want your personal contact information to be publicly
viewable, do not include it in your comment or any accompanying
documents. Instead, provide your contact information in a cover letter.
Include your first and last names, email address, telephone number, and
optional mailing address. The cover letter will not be publicly
viewable as long as it does not include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via postal mail
or hand delivery/courier, please provide all items on a CD, if
feasible, in which case it is not necessary to submit printed copies.
No telefacsimiles (``faxes'') will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email two well-marked copies: one copy of the document marked
``confidential'' including all the information believed to be
confidential, and one copy of the document marked ``non-confidential''
with the information believed to be confidential deleted. DOE will make
its own determination about the confidential status of the information
and treat it according to its determination.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
(1) DOE requests comment on the methodology used to present the
change in producer cash flow (INPV) in the monetized benefits and costs
tables in Table I.6, Table I.7, and Table V.100.
(2) DOE seeks comment on the baseline and assumed reduction in
anti-sweat heater wire power listed in Table IV.10. DOE specifically
seeks feedback on whether the reduced anti-sweat heater wire power is
acceptable for use in walk-in doors at all climates and installations
throughout the U.S.
(3) DOE requests test results or performance data for walk-in
refrigeration systems using R-454A, R-454C, and/or R-455A.
Additionally, DOE requests comment on its tentative determination that
R-454A is the most likely replacement for R-448A and R-449A with a GWP
of less than 300 and that walk-in dedicated condensing systems would
not suffer a performance penalty when switching from R-448A or R-449A
to R-454A.
(4) DOE requests comment on any potential low-GWP replacements for
high-temperature systems. Additionally, DOE requests high-temperature
performance data or test results for any potential low-GWP alternatives
to R-134A.
(5) DOE seeks comment on e-commerce distribution channels,
including which types of walk-in equipment use this channel and the
size of this channel.
(6) DOE seeks comment on its assumptions and rationale for
harmonizing panel and non-display door thicknesses at a given TSL.
(7) DOE seeks information and data from which to create
representative distributions of run time hours for different walk-in
refrigeration equipment and temperature classes.
(8) DOE requests any comment, data, and sources of information for
the maintenance and repair costs of walk-in coolers and freezers with
the technologies described in IV.C.
(9) DOE requests information or data to characterize a shift toward
larger capacity equipment in its analysis. DOE seeks information about
the represented units, customer types (food service, food sales,
other), and business sizes effected.
(10) DOE requests comments on its assumption that there is no
rebound effect for walk-in coolers and freezers.
(11) DOE requests comments on its subgroups analysis.
(12) DOE seeks comments, information, and data on the capital
conversion costs and product conversion costs estimated for each
efficiency level and TSL for walk-in display and non-display doors. See
chapter 12 of the NOPR TSD for the estimated conversion costs for each
analyzed efficiency level.
(13) DOE seeks comments, information, and data on the capital
conversion costs and product conversion costs estimated for each
efficiency level and TSL for walk-in panels. See chapter 12 of the NOPR
TSD for the estimated conversion costs for each analyzed efficiency
level.
(14) DOE seeks comments, information, and data on the capital
conversion costs and product conversion costs estimated for each TSL
for walk-in refrigeration systems.
(15) DOE seeks comment on whether manufacturers expect
manufacturing capacity constraints would limit walk-in display and non-
display door availability to consumers in the timeframe of the amended
standard compliance date (2027).
(16) DOE seeks comment on whether manufacturers expect
manufacturing capacity constraints would limit walk-in panel
availability to consumers in the timeframe of the amended standard
compliance date (2027).
(17) DOE seeks comment on whether manufacturers expect
manufacturing capacity constraints or engineering resource constraints
would limit walk-in refrigeration system availability to consumers in
the timeframe of the amended standard compliance date (2027).
(18) DOE requests comments on the magnitude of costs associated
with transitioning walk-in refrigeration systems and production
facilities to accommodate low-GWP refrigerants that would be incurred
between the publication of this NOPR and the proposed compliance date
of amended standards. Quantification and categorization of these costs,
such as engineering efforts, testing lab time, certification costs, and
capital investments (e.g., new charging equipment), would enable DOE to
refine its analysis.
(19) DOE requests information regarding the impact of cumulative
regulatory burden on manufacturers of walk-ins associated with multiple
DOE
[[Page 60863]]
standards or product/equipment-specific regulatory actions of other
Federal agencies.
(20) DOE seeks comments, information, and data on the number of
small businesses in the walk-in display and non-display door market,
the names of those small businesses, and their market shares by
equipment class. DOE also requests comment on the potential impacts of
the proposed standards on small walk-in display and non-display door
manufacturers.
(21) DOE seeks comments, information, and data on the number of
small businesses in the walk-in panel industry, the names of those
small businesses, and their market shares by equipment class. DOE also
requests comment on the potential impacts of the proposed standards on
small walk-in panel manufacturers.
(22) DOE seeks comments, information, and data on the number of
small businesses in the walk-in refrigeration system industry, the
names of those small businesses, and their market shares by equipment
class. DOE also requests comment on the potential impacts of the
proposed standards on small walk-in refrigeration system manufacturers.
Additionally, DOE welcomes comments on other issues or data
relevant to the conduct of this rulemaking that may not specifically be
identified in this document.
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this notice of
proposed rulemaking and announcement of public meeting.
List of Subjects in 10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation test procedures, and Reporting and
recordkeeping requirements.
Signing Authority
This document of the Department of Energy was signed on August 11,
2023, by Francisco Alejandro Moreno, Acting Assistant Secretary for
Energy Efficiency and Renewable Energy, pursuant to delegated authority
from the Secretary of Energy. That document with the original signature
and date is maintained by DOE. For administrative purposes only, and in
compliance with requirements of the Office of the Federal Register, the
undersigned DOE Federal Register Liaison Officer has been authorized to
sign and submit the document in electronic format for publication, as
an official document of the Department of Energy. This administrative
process in no way alters the legal effect of this document upon
publication in the Federal Register.
Signed in Washington, DC, on August 11, 2023.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
For the reasons set forth in the preamble, DOE proposes to amend
part 431 of chapter II, subchapter D, of title 10 of the Code of
Federal Regulations, as set forth below:
PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C. 2461 note.
0
2. Amend Sec. 431.306 by revising paragraphs (d) and (e) to read as
follows:
Sec. 431.306 Energy conservation standards and their effective dates.
* * * * *
(d) Walk-in cooler and freezer non-display doors.
All walk-in cooler and walk-in freezer non-display doors
manufactured starting on June 5, 2017 and before [date 3 years after
the publication of the final rule] must satisfy the following
standards:
------------------------------------------------------------------------
Equations for maximum
Equipment class energy consumption (kWh/
day) *
------------------------------------------------------------------------
Passage Door, Medium Temperature............. 0.05 x And + 1.7
Passage Door, Low Temperature................ 0.14 x And + 4.8
Freight Door, Medium Temperature............. 0.04 x And + 1.9
Freight Door, Low Temperature................ 0.12 x And + 5.6
------------------------------------------------------------------------
* And represents the surface area of the non-display door.
All walk-in cooler and walk-in freezer non-display doors
manufactured starting on [date 3 years after the publication of the
final rule], must satisfy the following standards:
------------------------------------------------------------------------
Equations for maximum
Equipment class energy consumption (kWh/
day) *
------------------------------------------------------------------------
Non-Display Door, Manual, Medium Temperature. 0.01 x And + 0.25
Non-Display Door, Manual, Low Temperature.... 0.06 x And + 1.32
Non-Display Door, Motorized, Medium 0.01 x And + 0.39
Temperature.................................
Non-Display Door, Motorized, Low Temperature. 0.05 x And + 1.56
------------------------------------------------------------------------
* And represents the surface area of the non-display door.
(e) Walk-in cooler refrigeration systems.
All walk-in cooler and walk-in freezer refrigeration systems
manufactured starting on the dates listed in the table and before [date
3 years after the publication of the final rule], except for walk-in
process cooling refrigeration systems (as defined in Sec. 431.302),
must satisfy the following standards:
[[Page 60864]]
----------------------------------------------------------------------------------------------------------------
Compliance date: equipment
Equipment class Minimum AWEF (Btu/W-h) * manufactured starting on . . .
----------------------------------------------------------------------------------------------------------------
Dedicated Condensing System-- 5.61 June 5, 2017.
Medium, Indoor.
Dedicated Condensing System-- 7.60 ...................................
Medium, Outdoor.
Dedicated Condensing System--
Low, Indoor with a Net Capacity
(qnet) of:
<6,500 Btu/h................ 9.091 x 10-\5\ x qnet + 1.81 July 10, 2020.
>=6,500 Btu/h............... 2.40 ...................................
Dedicated Condensing System--
Low, Outdoor with a Net
Capacity (qnet) of:
<6,500 Btu/h................ 6.522 x 10-\5\ x qnet + 2.73 ...................................
>=6,500 Btu/h............... 3.15 ...................................
Unit Cooler--Medium......... 9.00 ...................................
Unit Cooler--Low with a Net
Capacity (qnet) of:
<15,500 Btu/h............... 1.575 x 10-\5\ x qnet + 3.91 ...................................
>=15,500 Btu/h.............. 4.15 ...................................
----------------------------------------------------------------------------------------------------------------
* Where qnet is net capacity as determined in accordance with Sec. 431.304 and certified in accordance with 10
CFR part 429.
All walk-in cooler and walk-in freezer refrigeration systems
manufactured starting on [date 3 years after the publication of the
final rule], except for walk-in process cooling refrigeration systems
(as defined in Sec. 431.302), must satisfy the following standards:
------------------------------------------------------------------------
Equipment class Minimum AWEF2 (Btu/W-h) *
------------------------------------------------------------------------
Dedicated Condensing System-- .....................................
High, Indoor, Non-Ducted with a
Net Capacity (qnet) of:
<7000 Btu/h.................. 7.80E-04 x qnet + 2.20
>=7000 Btu/h................. 7.66
Dedicated Condensing system-- .....................................
High, Outdoor, Non-Ducted with a
Net Capacity (qnet) of:
<7000 Btu/h.................. 1.02E-03 x qnet + 2.47
>=7000 Btu/h................. 9.62
Dedicated Condensing system-- .....................................
High, Indoor, Ducted with a Net
Capacity (qnet) of:
<7000 Btu/h.................. 2.46E-04 x qnet + 1.55
>=7000 Btu/h................. 3.27
Dedicated Condensing system-- .....................................
High, Outdoor, Ducted with a Net
Capacity (qnet) of:
<7000 Btu/h.................. 3.76E-04 x qnet + 1.78
>=7000 Btu/h................. 4.41
Dedicated Condensing unit and .....................................
Matched Refrigeration System--
Medium, Indoor with a Net
Capacity (qnet) of:
<8000 Btu/h.................. 5.58
>=8000 Btu/h and <25000 Btu/h 3.00E-05 x qnet + 5.34
>=25000 Btu/h................ 6.09
Dedicated Condensing unit and .....................................
Matched Refrigeration System--
Medium, Outdoor with a Net
Capacity (qnet) of:
<25000 Btu/h................. 2.13E-05 x qnet + 7.15
>=25000 Btu/h................ 7.68
Dedicated Condensing unit and .....................................
Matched Refrigeration System--
Low, Indoor with a Net Capacity
(qnet) of:
<25000 Btu/h................. 2.50E-05 x qnet + 2.36
>=25000 Btu/h and <54000 Btu/ 1.72E-06 x qnet + 2.94
h.
>=54000 Btu/h................ 3.03
Dedicated Condensing unit and .....................................
Matched Refrigeration System--
Low, Outdoor with a Net Capacity
(qnet) of:
<9000 Btu/h.................. 9.83E-05 x qnet + 2.63
>=9000 Btu/h and <25000 Btu/h 3.06E-05 x qnet + 3.23
>=25000 Btu/h and <75000 Btu/ 4.96E-06 x qnet + 3.88
h.
>=75000 Btu/h................ 4.25
Single-Packaged Dedicated .....................................
Condensing system--Medium,
Indoor with a Net Capacity
(qnet) of:
<9000 Btu/h.................. 9.86E-05 x qnet + 4.91
>=9000 Btu/h................. 5.8
Single-Packaged Dedicated .....................................
Condensing system--Medium,
Outdoor with a Net Capacity
(qnet) of:
<9000 Btu/h.................. 2.47E-04 x qnet + 4.89
>=9000 Btu/h................. 7.11
Single-Packaged Dedicated .....................................
Condensing system--Low, Indoor
with a Net Capacity (qnet) of:
<6000 Btu/h.................. 8.00E-05 x qnet + 1.8
>=6000 Btu/h................. 2.28
Single-Packaged Dedicated .....................................
Condensing system--Low, Outdoor
with a Net Capacity (qnet) of:
<6000 Btu/h.................. 1.63E-04 x qnet + 1.8
>=6000 Btu/h................. 2.77
Unit Cooler--High Non-Ducted with .....................................
a Net Capacity (qnet) of:
<9000 Btu/h.................. 10.34
>=9000 Btu/h and <25000 Btu/h 3.83E-04 x qnet + 6.9
>=25000 Btu/h................ 16.46
Unit Cooler--High Ducted with a .....................................
Net Capacity (qnet) of:
<9000 Btu/h.................. 6.93
>=9000 Btu/h and <25000 Btu/h 3.64E-04 x qnet + 3.66
>=25000 Btu/h................ 12.76
Unit Cooler--Medium.............. 9.65
[[Page 60865]]
Unit Cooler--Low................. 4.57
------------------------------------------------------------------------
* Where qnet is net capacity as determined in accordance with Sec.
431.304 and certified in accordance with 10 CFR part 429.
[FR Doc. 2023-17583 Filed 9-1-23; 8:45 am]
BILLING CODE 6450-01-P