[Federal Register Volume 89, Number 246 (Monday, December 23, 2024)]
[Rules and Regulations]
[Pages 104616-104855]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-28474]
[[Page 104615]]
Vol. 89
Monday,
No. 246
December 23, 2024
Part II
Department of Energy
-----------------------------------------------------------------------
10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for Walk-In
Coolers and Walk-In Freezers; Final Rule
Federal Register / Vol. 89 , No. 246 / Monday, December 23, 2024 /
Rules and Regulations
[[Page 104616]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2017-BT-STD-0009]
RIN 1904-AD79
Energy Conservation Program: Energy Conservation Standards for
Walk-In Coolers and Walk-In Freezers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
-----------------------------------------------------------------------
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 review its
existing standards to determine whether more-stringent standards would
be technologically feasible and economically justified, and would
result in significant energy savings. In this final rule, DOE is
adopting amended energy conservation standards for walk-ins. It has
determined that the amended energy conservation standards for these
products would result in significant conservation of energy and are
technologically feasible and economically justified.
DATES: The effective date of this rule is February 21, 2025. Compliance
with the amended standards established for walk-in non-display doors in
this final rule is required on and after December 23, 2027. Compliance
with the amended standards established for walk-in refrigeration
systems in this final rule is required on and after December 31, 2028.
ADDRESSES: The docket for this rulemaking, which includes Federal
Register notices, public meeting attendee lists and transcripts,
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.
For further information on how to review the docket, contact the
Appliance and Equipment Standards Program staff at (202) 287-1445 or by
email: [email protected].
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. Telephone: (240) 449-9387. 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: (202) 586-4798. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Final Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
1. Annualized Benefits and Costs
a. Non-Display Doors
b. Refrigeration Systems
c. Amended Standards
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Walk-Ins
III. General Discussion
A. General Comments
1. Comments Regarding the Proposed Standard Levels
2. Comments Regarding the Proposed Compliance Date
3. Comments Regarding Rulemaking Process
4. Comments Regarding Prescriptive Standards
5. Comments Regarding the Standards Equations
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 Products
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. General Feedback
b. Display Doors
c. Non-Display Doors
d. Panels
e. Dedicated Condensing Units and Single-Packaged Dedicated
Systems
f. Unit Coolers
2. Cost Analysis
a. Teardown Analysis
b. Cost Estimation Method
c. Low-GWP Refrigerants
d. More Efficient Single-Speed Compressors
e. Variable-Speed Compressors
f. Unit Coolers
g. Capital Expenditures Represented in MPCs
h. Manufacturer Markups and Shipping Costs
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. Nominal Daily Run Hours
4. Estimated Annual Energy Consumption
F. Life-Cycle Cost and Payback Period Analysis
1. Consumer Sample
2. Equipment Cost
a. Application of the Low-GWP Refrigerant Transition to Specific
Regions
3. Installation Cost
a. Refrigeration Systems
b. Cooler and Freezer Panels
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
[[Page 104617]]
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. Discussion of MIA Comments
a. Conversion Costs
b. Manufacturer Markup Scenarios
c. Manufacturing Capacity Constraints
d. Cumulative Regulatory Burden
e. Refrigerant Transition Costs
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. National 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-In Cooler
and Walk-In Freezer Standards
a. Refrigeration Systems
b. Doors
c. Panels
d. Combined Benefits of Amended Standards
2. Annualized Benefits and Costs of the Adopted Standards
a. Non-Display Doors
b. Refrigeration Systems
c. Amended Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866, 13563, and 14094
B. Review Under the Regulatory Flexibility Act
1. Need for, and Objectives of, Rule
2. Significant Issues Raised by Public Comments in Response to
the IRFA
3. Description and Estimated Number of Small Entities Affected
4. Description of Reporting, Recordkeeping, and Other Compliance
Requirements
a. Doors
b. Panels
c. Refrigeration Systems
d. Doors and Refrigeration Systems
5. Significant Alternatives Considered and Steps Taken To
Minimize Significant Economic Impacts on Small Entities
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
M. Congressional Notification
VII. Approval of the Office of the Secretary
I. Synopsis of the Final Rule
The Energy Policy and Conservation Act (Pub. L. 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, as codified) Title III, Part C of EPCA,\2\ added by
Public Law 95-619, Title IV, section 441(a), established the Energy
Conservation Program for Certain Industrial Equipment, which sets forth
a variety of provisions designed to improve energy efficiency. (42
U.S.C. 6311-6317) Such equipment includes walk-in coolers and walk-in
freezers (``walk-ins'' or ``WICFs''), the subject of this document. (42
U.S.C. 6311(1)(G)) DOE defines ``walk-ins'' 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).
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
Pursuant to EPCA, DOE is required to review its existing energy
conservation standards for covered equipment no later than 6 years
after issuance of any final rule establishing or amending a standard.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1)) Pursuant to that statutory
provision, DOE must publish either a notification of determination that
standards for the product do not need to be amended, or a notice of
proposed rulemaking (``NOPR'') including new proposed energy
conservation standards (proceeding to a final rule, as appropriate).
(Id.) 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 significant conservation of energy. (42
U.S.C. 6295(o)(3)(B)) DOE has conducted this review of the energy
conservation standards for walk-ins under EPCA's 6-year lookback
authority described herein.
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 each component of walk-ins (i.e., doors,
panels, and refrigeration systems). 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 determined that TSL 1 represents the maximum improvement in energy
efficiency that is technologically feasible and economically justified
for non-display doors and that TSL 2 represents the maximum improvement
in energy efficiency that is technologically feasible and economically
justified for refrigeration systems. DOE is not amending energy
conservation standards for display doors or panels at this time and the
existing standards will remain in effect. The adopted 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 standards apply to all walk-in non-display doors listed in
table I.1 and manufactured in, or imported into, the
[[Page 104618]]
United States starting on December 23, 2027.
BILLING CODE 6450-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.000
The adopted standards for walk-in refrigeration standards, 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 standards apply to all walk-in refrigeration systems listed in
Table I.2 and manufactured in, or imported into, the United States
starting on December 31, 2028.
[[Page 104619]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.001
[[Page 104620]]
A. Benefits and Costs to Consumers 3
---------------------------------------------------------------------------
\3\ All monetary values in this document are expressed in 2023
dollars unless indicated otherwise. For purposes of discounting
future monetary values, the present year in the analysis was 2024.
---------------------------------------------------------------------------
Table I.3 through table I.4 summarize DOE's evaluation of the
economic impacts of the adopted 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 8.5 years for
both refrigeration systems and non-display doors (see section IV.F of
this document).
---------------------------------------------------------------------------
\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.C of this document).
[GRAPHIC] [TIFF OMITTED] TR23DE24.002
[GRAPHIC] [TIFF OMITTED] TR23DE24.003
BILLING CODE 6450-01-C
DOE's analysis of the impacts of the adopted standards on consumers
is described in section IV.F of this document.
B. Impact on Manufacturers
The industry net present value (``INPV'') is the sum of the
discounted cash flows to the industry from the base year (2024) through
the end of the analysis period, which is 30 years from the analyzed
compliance date. For walk-in display doors, non-display doors, and
panels, the analysis period is 2024-2057. For refrigeration systems,
the analysis period is 2024-2058. 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 $218.7 million,
[[Page 104621]]
$508.4 million, $926.0 million, and $542.0 million in 2023$,
respectively. Under the adopted 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 adopted standards, the change in INPV for non-
display door manufacturers is estimated to range from -0.4 percent to
0.7 percent, which is approximately -$2.0 million to $3.5 million.
Under the adopted 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 adopted
standards, the change in INPV for refrigeration system manufacturers is
estimated to range from -11.3 percent to -8.4 percent, which is
approximately -$61.2 million to -$45.7 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 $1.4 million and $90.1 million,
respectively.
DOE's analysis of the impacts of the adopted standards on
manufacturers is described in sections IV.J and V.B.2 of this document.
C. National Benefits and Costs 5
---------------------------------------------------------------------------
\5\ All monetary values in this document are expressed in 2023
dollars and, where appropriate, are discounted to 2024 unless
explicitly stated otherwise.
---------------------------------------------------------------------------
DOE's analyses indicate that the adopted energy conservation
standards for walk-ins would save a significant amount of energy. The
adopted TSLs are TSL 1 for walk-in non-display doors and TSL 2 for
walk-in refrigeration systems. 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 (2028-2057 for non-display doors and 2029-2058
for refrigeration systems) amount to 1.60 quadrillion British thermal
units (``Btu''), or quads of-full-fuel cycle energy savings.\6\ This
represents a savings of 6.3 percent relative to the energy use of these
products in the case without amended standards (referred to as the
``no-new-standards case'')
---------------------------------------------------------------------------
\6\ 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 of this document.
---------------------------------------------------------------------------
The cumulative net present value (``NPV'') of total consumer
benefits of the standards for walk-ins ranges from $2.00 billion USD
(at a 7-percent discount rate) to $4.74 billion USD (at a 3-percent
discount rate). This NPV expresses the estimated total value of future
operating-cost savings minus the estimated increased equipment and
installation costs for walk-in non-display doors purchased during the
period 2028-2057 and walk-in refrigeration systems purchased in 2029-
2058.
In addition, the adopted standards for walk-ins are projected to
yield significant environmental benefits. DOE estimates that the
standards will result in cumulative emission reductions (over the same
period as for energy savings) of 28.82 million metric tons (``Mt'') \7\
of carbon dioxide (``CO2''), 8.8 thousand tons of sulfur
dioxide (``SO2''), 53.8 thousand tons of nitrogen oxides
(``NOX''), 243.2 thousand tons of methane
(``CH4''), 0.3 thousand tons of nitrous oxide
(``N2O''), and 0.06 tons of mercury (``Hg'').\8\
---------------------------------------------------------------------------
\7\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\8\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2023 (AEO2023). AEO2023 represents current Federal and state
legislation and final implementation of regulations as of the time
of its preparation. See section IV.K of this document for further
discussion of AEO2023 assumptions that affect air pollutant
emissions.
---------------------------------------------------------------------------
DOE estimates the value of climate benefits from a reduction in
greenhouse gases (``GHG'') using 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 an updated set of SC-GHG estimates published in
2023 (``2023 SC-GHG''), as well as the 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'') in 2021 (``2021
Interim SC-GHG''), which DOE used in the notice of proposed rulemaking
for this rule before the updated values were available.\9\ These values
are discussed in section IV.L of this document. The climate benefits
associated with the average SC-GHG at a 2-percent near-term Ramsey
discount rate using the 2023 SC-GHG estimates are estimated to be $6.80
billion, and the climate benefits associated with the average 2021
Interim SC-GHG estimates at a 3-percent discount rate are estimated to
be $1.70 billion. DOE notes, however, that the adopted standards would
be economically justified even without inclusion of the estimated
monetized benefits of reduced GHG emissions.
---------------------------------------------------------------------------
\9\ 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.
https://www.epa.gov/system/files/documents/2023-12/eo12866_oil-and-gas-nsps-eg-climate-review-2060-av16-final-rule-20231130.pdf;
https://www.epa.gov/system/files/documents/2023-12/epa_scghg_2023_report_final.pdf (last accessed July 3, 2024).
---------------------------------------------------------------------------
DOE estimates the monetary health benefits of SO2 and
NOX emissions reductions using benefit per ton estimates
from the EPA's Benefits Mapping and Analysis Program \10\ as discussed
in section IV.L of this document. DOE did not monetize the reduction in
mercury emissions because the quantity is very small. DOE estimated the
present value of the health benefits would be $1.37 billion using a 7-
percent discount rate and, $3.33 billion using a 3-percent discount
rate.\11\ 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.
---------------------------------------------------------------------------
\10\ Estimating the Benefit per Ton of Reducing PM2.5
Precursors from 21 Sectors. https://www.epa.gov/benmap/estimating-benefit-ton-reducing-directly-emitted-pm25-pm25-precursors-and-ozone-precursors.
\11\ 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.5 Summary of Monetized Benefits and Costs of Adopted Energy
Conservation Standards for Table I.5 summarizes the monetized benefits
and costs expected to result from the amended 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.
BILLING CODE 6450-01-P
[[Page 104622]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.004
[[Page 104623]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.005
1. Annualized Benefits and Costs
The benefits and costs of the adopted 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.\12\
---------------------------------------------------------------------------
\12\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2020, 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., 2020 or 2030), and then discounted the present value from
each year to 2024. 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-in non-
display doors and refrigeration systems shipped during the periods
2028-2057 and 2029-2058, respectively. The benefits associated with
reduced emissions achieved as a result of the amended standards are
also calculated based on the lifetime of walk-in non-display doors and
refrigeration systems shipped during the period 2028-2057 and 2029-
2058, respectively. Total benefits for both the 3-percent and 7-percent
cases are presented using the average SC-GHG with a 2 percent near-term
Ramsey discount rate for the 2023 SC-GHG estimates and the average SC-
GHG with 3-percent discount rate for the 2021 interim SC-GHG estimates
in section IV.L of this document.
a. Non-Display Doors
Table I.6 presents the total estimated monetized benefits and costs
associated with the adopted standard for walk-in non-display doors,
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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards adopted in this rule
is $31.2 million per year in increased equipment costs, while the
estimated annual benefits are $123.4 million in reduced equipment
operating costs, $117.3 million in climate benefits (using the 2023 SC-
GHG estimates) or $34.8 million in climate benefits (using the 2021
interim SC-GHG estimates), and $52.0 million in health benefits. In
this case, the net benefit would amount to $261.5 million per year
(using the 2023 SC-GHG estimates) or $179.0 million per year (using the
2021 interim SC-GHG estimates).
Using a 3-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards is $32.0 million per
year in increased equipment costs, while the estimated annual benefits
are $147.9 million in reduced operating costs, $117.3 million in
climate benefits (using the 2023 SC-GHG estimates) or $34.8 million in
climate benefits (using the 2021 interim SC-GHG estimates), and $68.8
million in health benefits. In this case, the net benefit would amount
to $302.0 million per year (using the 2023 SC-GHG estimates) or $219.5
million per year (using the 2021 interim SC-GHG estimates).
[[Page 104624]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.006
[[Page 104625]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.007
b. Refrigeration Systems
Table I.7 presents the total estimated monetized benefits and costs
associated with the adopted standard for walk-in refrigeration systems,
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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards adopted in this rule
is $67.9 million per year in increased equipment costs, while the
estimated annual benefits are $180.9 million in reduced equipment
operating costs, $209.2 million in climate benefits (using the 2023 SC-
GHG estimates) or $61.7 million in climate benefits (using the 2021
interim SC-GHG estimates), and $89.0 million in health benefits. In
this case, the net benefit would amount to $411.2 million per year
(using the 2023 SC-GHG estimates) or $263.7 million per year (using the
2021 interim SC-GHG estimates).
Using a 3-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards is $61.7 million per
year in increased equipment costs, while the estimated annual benefits
are $222.0 million in reduced operating costs, $209.2 million in
climate benefits (using the 2023 SC-GHG estimates) or $61.7 million in
climate benefits (using the 2021 interim SC-GHG estimates), and $165
million in health benefits. In this case, the net benefit would amount
to $482.5 million per year (using the 2023 SC-GHG estimates) or $335.1
million per year (using the 2021 interim SC-GHG estimates).
[[Page 104626]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.008
[[Page 104627]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.009
c. Amended Standards
Table I.8 presents the total estimated monetized benefits and costs
associated with the adopted standard for walk-in non-display doors (TSL
1) and refrigeration systems (TSL 2), expressed 2023$ 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 adopted
in this rule is $99.1 million per year in increased equipment costs,
while the estimated annual benefits are $304.4 million in reduced
operating costs, $96.5 million in climate benefits, and $140.9 million
in health benefits. In this case, the net benefit would amount to
$442.7 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the standards is $101.2 million per year in increased
equipment costs, while the estimated annual benefits are $369.8 million
in reduced equipment operating costs, $96.5 million in climate
benefits, and $189.4 million in health benefits. In this case, the net
benefit would amount to $554.5 million per year.
[[Page 104628]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.010
[[Page 104629]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.011
BILLING CODE 6410-01-C
DOE's analysis of the national impacts of the adopted standards is
described in sections IV.H, IV.J.3, and IV.L of this document.
In the September 2023 NOPR, DOE requested comment on the
methodology used to present the change in producer cashflow (i.e.,
INPV) in the monetized benefits and costs tables. In response to the
September 2023 NOPR, the Air-Conditioning, Heating and Refrigeration
Institute (``AHRI'') stated agreement with DOE's methodology to present
the change in INPV in the monetized benefits and costs tables in table
1.6, table 1.7, and table V.100 of the September 2023 NOPR (which
correspond to table I.5, table I.8, and table V.125 in this final
rule), but stated the resultant dollar amounts do not support the kinds
of efficiency gains claimed, perhaps due to the errors called out in
determining the baseline. (AHRI, No. 72 at pp. 8-9) Hussmann commented
that it agrees with the views presented by AHRI on this topic.
(Hussmann, No. 75 at p. 10)
DOE maintained its methodology from the September 2023 NOPR and
presents change in INPV in the monetized benefits and costs tables in
this final rule. DOE discusses baseline design assumptions throughout
the engineering analysis, see section IV.C of this document. 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 determined that TSL 1 for non-display doors
and TSL 2 for refrigeration systems represents the maximum improvement
in energy efficiency that is technologically feasible and economically
justified.
D. Conclusion
DOE concludes that the standards adopted in this final rule
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 regard to
technological feasibility, equipment achieving these standard levels
are already commercially
[[Page 104630]]
available for all equipment classes covered by this final rule. As for
economic justification, DOE's analysis shows that the benefits of the
standards exceed, to a great extent, the burdens of the standards.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards adopted in this rule
is $99.1 million per year in increased equipment costs, while the
estimated annual benefits are $304.4 million in reduced equipment
operating costs, $326.5 million in climate benefits (using the 2023 SC-
GHG estimates) or $96.5 million in climate benefits (using the 2021
interim SC-GHG estimates), and $136 million in health benefits. In this
case, the net benefit would amount to $672.7 million per year (using
the 2023 SC-GHG estimates) or $442.7 million per year (using the 2021
interim SC-GHG estimates).
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.\13\ For
example, some covered products and equipment have most of their energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
the impacts of products with relatively constant demand. Accordingly,
DOE evaluates the significance of energy savings on a case-by-case
basis.
---------------------------------------------------------------------------
\13\ 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 full fuel cycle (``FFC'') energy savings of 1.60
quad, the equivalent of the primary annual energy use of 10.7 million
homes. In addition, they are projected to reduce cumulative
CO2 emissions by 28.82 Mt. over the time period of non-
display doors shipped from 2028-2057 and refrigeration systems shipped
from 2029-2058. Based on these findings, DOE has determined the energy
savings from the standard levels adopted in this final rule are
``significant'' within the meaning of 42 U.S.C. 6295(o)(3)(B). A more
detailed discussion of the basis for these conclusions is contained in
the remainder of this document and the accompanying TSD.
II. Introduction
The following section briefly discusses the statutory authority
underlying this final 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. (42 U.S.C. 6291-
6317, as codified) Title III, Part C of EPCA,\14\ added by Public Law
95-619, Title IV, section 441(a), established the Energy Conservation
Program for Certain Industrial Equipment, which sets forth a variety of
provisions designed to improve energy efficiency. (42 U.S.C. 6311-6317)
This equipment includes walk-ins, the subject of this document. (42
U.S.C. 6311(1)(G))
---------------------------------------------------------------------------
\14\ As noted previously, for editorial reasons, upon
codification in the U.S. Code, Part C was redesignated Part A-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 U.S.C. 6313), and the
authority to require information and reports from manufacturers (42
U.S.C. 6316; 42 U.S.C. 6296(a), (b), and (d)).
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); 42 U.S.C. 6297) DOE may, however, grant waivers of
Federal preemption in limited circumstances for particular State laws
or regulations, in accordance with the procedures and other provisions
set forth under EPCA. (42 U.S.C. 6316(a); 42 U.S.C. 6297(d))
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 covered equipment. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(3)(A) and 6295I) Manufacturers of covered
equipment must use the Federal test procedures as the basis for
certifying to DOE that their equipment complies with the applicable
energy conservation standards and as the basis for any representations
regarding the energy use or energy efficiency of the equipment. (42
U.S.C. 6316(a); 42 U.S.C. 6295(s); 42 U.S.C. 6314(d)). Similarly, DOE
must use these test procedures to evaluate whether a basic model
complies with the applicable energy conservation standard(s). (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.
EPCA set initial prescriptive energy conservation standards for
walk-ins and further required DOE to set performance standards. (42
U.S.C. 6313(f)) EPCA also required 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 six years after the issuance of any final rule
establishing or amending a standard, DOE must publish either a notice
of determination (``NOPD'') that standards for the equipment 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 must make the analysis on
which a NOPD or NOPR is based publicly available and provide an
opportunity for written comment. (42 U.S.C. 6316(a); 42 U.S.C.
6295(m)(2)) Not later than two years after a NOPR is issued, DOE must
publish a final rule amending the energy conservation standard for the
equipment. (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(3)(A))
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered equipment, including walk-ins. Any new or
amended standard for covered equipment must be designed to achieve the
maximum improvement in energy efficiency that the Secretary of Energy
(``Secretary'') 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. 6316(a); 42 U.S.C. 6295(o)(3)(B))
Moreover, DOE may not prescribe a standard if: (1) for certain
equipment, including walk-ins, no test procedure has been established
for the equipment, or (2) DOE determines by rule that the establishment
of such standard will not result in significant conservation of energy,
or is not technologically feasible or economically justified. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(A)-(B)) In
[[Page 104631]]
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:
The economic impact of the standard on manufacturers and consumers
of the equipment subject to the standard;
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, initial charges, or maintenance expenses for the
covered equipment that are likely to result from the standard;
The total projected amount of energy (or as applicable, water)
savings likely to result directly from the standard;
Any lessening of the utility or the performance of the covered
equipment likely to result from the standard;
The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
standard;
The need for national energy and water conservation; and
Other factors the Secretary considers relevant.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA, as codified, 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, as codified, 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. A rule prescribing an energy conservation standard for a
type (or class) of product must specify a different standard level for
a type or class of products 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 considers such factors as the utility to
the consumer of such a 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))
DOE is publishing this final rule pursuant to its statutory
obligations pursuant to EPCA described herein. (42 U.S.C. 6311(f)(5);
42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1))
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 (``MDEC''), 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 annual walk-in energy factor (``AWEF''), which
is measured in Btu/W-h (see table II.3).
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.012
[[Page 104632]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.013
[GRAPHIC] [TIFF OMITTED] TR23DE24.014
BILLING CODE 6410-01-C
As previously mentioned, EPCA also specifies prescriptive energy
conservation standards for walk-ins. These prescriptive standards are
codified at 10 CFR 431.306(a) and (b). First, all walk-in doors
narrower than 3 feet 9 inches and shorter than 7 feet must have
automatic door closers that firmly close all walk-in doors that have
been closed to within 1 inch of full closure, and must also have strip
doors, spring hinged doors, or other methods of minimizing infiltration
when doors are open. Additionally, walk-ins must contain wall, ceiling,
and door insulation of at least R-25 for coolers and R-32 for freezers,
excluding glazed portions of doors and structural members, and floor
insulation of at least R-28 for freezers. Walk-in evaporator fan motors
of under 1 horsepower (``hp'') and less than 460 volts must be
electronically commutated motors (brushless direct current motors) or
three-phase motors, and walk-in condenser fan motors of under 1
horsepower must use permanent split capacitor motors, electronically
commutated motors, or three-phase motors. Interior light sources must
have an efficacy of 40 lumens per watt or more, including any ballast
losses; less-efficacious lights may only be used in conjunction with a
timer or device that turns off the lights within 15 minutes of when the
walk-in is unoccupied. See 42 U.S.C. 6313(f)(1).
EPCA also requires that walk-in freezers with transparent reach-in
doors must have triple-pane glass with either heat-reflective treated
glass or gas fill for doors and windows. Transparent walk-in cooler
doors must have either double-pane glass with heat-reflective treated
glass and gas fill or triple-pane glass with heat-reflective treated
glass or gas fill. (42 U.S.C. 6313(f)(3)(A)-(B)) For walk-ins with
transparent reach-in doors, EPCA also prescribes specific anti-sweat
heater-related requirements: walk-ins without anti-sweat heater
controls must have a heater power draw of no more than 7.1 or 3.0 watts
per square foot of door opening for freezers and coolers, respectively.
Walk-ins with anti-sweat heater controls must either have a heater
power draw of no more than 7.1 or 3.0 watts per square foot of door
opening for freezers and coolers, respectively, or the anti-sweat
heater controls must reduce the energy use of the heater in a quantity
corresponding to the relative humidity of the air outside the door or
to the condensation on the inner glass pane. See 42 U.S.C.
6313(f)(3)(C)-(D).
2. History of Standards Rulemaking for Walk-Ins
In a final rule published on June 3, 2014 (``June 2014 Final
Rule''), DOE promulgated 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,
AHRI and Lennox International, Inc. (``Lennox''), a manufacturer of
walk-in refrigeration systems, filed petitions for review of DOE's
final rule
[[Page 104633]]
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.\15\
After the Fifth Circuit issued its order, DOE established a Working
Group to negotiate energy conservation standards to replace the six
vacated standards (``ASRAC Working Group''). 80 FR 46521 (August 5,
2015). The ASRAC 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 (``ASRAC'') on December 18, 2015. (EERE-2015-BT-STD-
0016-0055 at p. 11)
---------------------------------------------------------------------------
\15\ 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-temperature; 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 with vacated standards--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.
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.
On September 5, 2023, DOE published a NOPR in the Federal Register
regarding energy conservation standards for walk-in coolers and
freezers (``September 2023 NOPR''). 88 FR 60746. Specifically, DOE
proposed amended standards for walk-in non-display doors and walk-in
refrigeration systems. DOE did not propose to amend the standard for
walk-in panels or display doors. The amended standards proposed for
non-display doors in the September 2023 NOPR were defined in terms of
maximum daily energy consumption. The amended standards proposed for
refrigeration systems in the September 2023 NOPR were defined in terms
of AWEF2, adopted in a test procedure final rule that published on May
4, 2023 (``May 2023 TP Final Rule''). The technical support document
(``TSD'') that presented the methodology and results of the September
2023 NOPR analysis (``September 2023 NOPR TSD'') is available at
www.regulations.gov/document/EERE-2017-BT-STD-0009-0046. Additionally,
on September 28, 2023, DOE published a notice of data availability
(``NODA'' (``September 2023 NODA'') summarizing additional comments
received on the June 2022 Preliminary Analysis (87 FR 39008) that were
considered but not discussed in the September 2023 NOPR. 88 FR 66710.
On September 27, 2023, DOE held a public webinar (``September 2023
Public Webinar'') in which it presented an overview of the topics
addressed in the September 2023 NOPR, allowed time for prepared general
statements by participants, and encouraged all interested parties to
share their views on issues affecting this rulemaking.
On March 14, 2024, DOE published a second NODA (``March 2024
NODA'') presenting an updated analysis for walk-in non-display doors
and refrigeration systems in light of additional data and comments
received in response to the September 2023 NOPR, and as a result,
presented life-cycle cost and payback period results and national
impacts for TSLs that were different from those analyzed for the
NOPR.\16\ 89 FR 18555. DOE's final rule analysis considers these data
and comments, and DOE's responses to those comments and analysis
adjustments are presented in the March 2024 NODA, with no further
adjustment in the final rule analysis except as discussed in this final
rule. The remaining comments received in response to the September 2023
NOPR are summarized and responded to in this final rule. Additionally,
DOE received comments in response to the March 2024 NODA, which it also
addresses in this final rule.
---------------------------------------------------------------------------
\16\ As discussed in section IV.E.1, the TSLs analyzed in this
final rule for non-display doors and refrigeration systems are
largely consistent with the TSLs analyzed in the March 2024 NODA.
---------------------------------------------------------------------------
DOE received comments in response to the September 2023 NOPR and
March 2024 NODA from the interested parties listed in table II.4 and
table II.5, respectively. DOE also received three anonymous comment
submissions in response to the September 2023 NOPR.
BILLING CODE 6410-01-P
[[Page 104634]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.015
[[Page 104635]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.016
BILLING CODE 6410-01-C
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\17\
To the extent that interested parties have provided written comments
that are substantively consistent with any oral comments provided
during the September 2023 Public Webinar, DOE cites the written
comments throughout this final rule. DOE did not identify any oral
comments provided during the September 2023 Public Webinar that are not
substantively addressed by written comments.
---------------------------------------------------------------------------
\17\ 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).
---------------------------------------------------------------------------
III. General Discussion
DOE developed this final rule after a review of the market for the
subject walk-ins. DOE also considered comments, data, and information
from interested parties that represent a variety of interests. This
final rule addresses issues raised by these commenters.
A. General Comments
This section summarizes general comments received from interested
parties regarding the proposed standards, rulemaking timing, and
process.
1. Comments Regarding the Proposed Standard Levels
Ballesteros expressed general support for the standards proposed in
the September 2023 NOPR, stating that the benefits would outweigh the
burdens. (Ballesteros, No. 56 at p. 1)
DuPont supported panel efficiency standards remaining the same and
the non-display door efficiencies remaining at 4-inch insulation
thickness. DuPont stated that added efficiency could create a WICF
supply shortage above current constraints. (DuPont, No. 74 at p. 2)
The CA IOUs supported DOE's proposal to adopt TSL 2 for WICFs. The
CA IOUs also supported DOE's proposal to establish energy conservation
standards for high-temperature systems. (CA IOUs, No. 76 at p. 1)
In response to the March 2024 NODA, ASAP et. al. and the CA IOUs
recommended that DOE adopt TSL 2 analyzed in the March 2024 NODA. (ASAP
et al., No. 90 at pp. 1-2; CA IOUs, No. 91 at p. 1) However, ASAP et
al. additionally urged DOE to consider higher standards for non-display
doors associated with the use of thicker insulation. (ASAP et al., No.
90 at pp. 1-2)
DOE evaluated more-stringent standards for non-display doors
associated with the use of thicker insulation; these are considered in
TSL 3 of this final rule. The rationale for not adopting higher
standards for non-display doors that would likely necessitate thicker
insulation is discussed further in section V.C of this document.
AHRI recommended that DOE issue a no-new-standard approach for the
equipment covered in the September 2023 NOPR, which would provide an
additional 3 years of lead time to manufacturers and allow them to
complete the transition to low global warming potential (``GWP'')
refrigerants. (AHRI, No. 72 at p. 3 and No. 86 at p. 3)
NRAC also recommended that DOE issue a ``no-new-standard'' standard
for the equipment covered in the September 2023 NOPR to allow the
necessary time needed to complete the transition to A2Ls \18\ and low-
GWP refrigerants required by the EPA's American Innovation and
Manufacturing (``AIM'') Act of 2020 and also the new UL 60335-2-89
standard.\19\ NRAC commented that these regulations are placing
significant burdens on manufacturers and end
[[Page 104636]]
users, posing a high risk that none of the requirements will be met in
the proposed timeframes. (NRAC, No. 73 at pp. 1-2)
---------------------------------------------------------------------------
\18\ Refrigerants in the A2L subgroup, as categorized by ASHRAE
Standard 34, have lower toxicity and lower flammability than other
subgroups.
\19\ UL 60335-2-89, 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.
---------------------------------------------------------------------------
DOE acknowledges that EPA's final rule published in the Federal
Register on October 24, 2023, to address hydrofluorocarbons through the
AIM Act (``October 2023 EPA Technology Transitions Final Rule'') will
require the heating, ventilation, air-conditioning, and refrigeration
(``HVACR'') industry to undertake a broad transition to lower-GWP
refrigerants. 88 FR 73098. DOE has considered this refrigerant
transition and the burdens that come with it in the analyses that
support this final rule. In summary, DOE analyzed all medium- and low-
temperature dedicated condensing system (i.e., dedicated condensing
unit and single-packaged dedicated system) representative units with R-
448A as the baseline refrigerant, which DOE has concluded is
representative of sub-300 GWP refrigerants that would likely be used in
medium- and low-temperature dedicated condensing systems. DOE also
analyzed R-290 as a design option for medium- and low-temperature
single-packaged dedicated systems. DOE used R-404A to analyze medium-
and low-temperature unit coolers, which provides a conservative
analysis because sub-300 GWP refrigerants would likely increase unit
cooler performance. DOE analyzed high-temperature single-packaged
dedicated systems and high-temperature unit coolers using R-134a
because DOE has not been able to identify a sub-300 GWP refrigerant
that could serve as a replacement for R-134a in high-temperature
applications that has enough performance data (e.g., compressor
coefficients) available to conduct a full engineering analysis for
high-temperature units. These analyses are further discussed in
sections IV.C.1.e, IV.C.1.f, and IV.F.2.a of this document. DOE also
considers the potential manufacturer investments associated with the
transition to low-GWP refrigerants in response to refrigerant
regulations in section V.B.2.e of this document. Through these
analyses, DOE has determined that the standards promulgated in this
final rule are technologically feasible and economically justified
given the refrigerant transition required of the HVACR industry.
NAFEM requested that DOE find that no-new-standards are justified
at this time. NAFEM stated that DOE previously promulgated standards
for WICFs in 2014, but six of the classes were remanded by the United
States Court of Appeals for the Fifth Circuit; NAFEM further stated
that DOE promulgated revised standards for these six classes in 2017,
with compliance deadlines of 2020. NAFEM stated that based on this
timeline, the latest technologies are still being implemented into the
latest equipment. NAFEM commented that there has not been sufficient
time to develop, test, and make available the types of new technologies
that would impact the most recent energy efficiency standards and
otherwise justify revising those standards in the next several years.
(NAFEM, No. 67 at p. 2)
As indicated by NAFEM, compliance with the existing standards has
been required for multiple years. Compliance with the current energy
conservation standards for walk-in doors and medium-temperature
dedicated condensing systems was required on June 5, 2017, over 7 years
ago. Compliance with the current energy conservation standards for unit
coolers and low-temperature dedicated condensing systems was required
on July 10, 2020, over 4 years ago. EPCA requires that any new or
amended standard for covered equipment 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)) As part of DOE's assessment of
whether adopting amended standards is economically justified, DOE
considers the potential impact on manufacturers, including the
potential investments required to develop, test, produce, and market
compliant equipment. See sections IV.J and V.B.2 of this document for
details on the manufacturer impact analysis. As discussed further in
section V.C of this document, DOE is adopting amended standards for
walk-ins that are technologically feasible and economically justified.
DOE also received comments that the standards proposed in the
September 2023 NOPR and/or that updated analysis presented in the March
2024 NODA are too stringent.
AHRI and Hussmann commented that in the September 2023 NOPR, DOE
determined that TSL 3 is not economically justified; however, DOE
determined that TSL 2 is economically justified. AHRI and Hussmann
further stated that for unit coolers, both TSL 3 and TSL 2 incorporate
the max-tech design options for all unit cooler equipment classes.
(AHRI, No. 72 at p. 4; Hussmann, No. 75 at pp. 2-3) Therefore, Hussmann
recommended that efficiency levels for TSL 2 for unit coolers be set at
the intermediate (EL 1) levels. (Hussmann, No. 75 at pp. 2-3) Hussmann
also recommended that DOE propose an AWEF2 of 9.15 for medium-
temperature unit coolers and an AWEF2 of 4.30 for low-temperature unit
coolers. (Hussmann, No. 75 at pp. 5-7)
DOE notes that it determined in the September 2023 NOPR that, for
refrigeration systems, TSL 3 was not economically justified. 88 FR
60746, 60852. This determination was made despite certain efficiency
levels for certain equipment classes that made up TSL 3 being
economically justified. In the September 2023 NOPR, DOE tentatively
determined that TSL 2 was economically justified. 88 FR 60746, 60853.
Given that some efficiency levels for some representative units that
made up TSL 3 in the September 2023 NOPR were cost effective, there was
overlap in the efficiency levels that made up TSL 3 and the efficiency
levels that made up TSL 2 for certain representative units. 88 FR
60746, 60786-60787. Medium-temperature unit coolers and low-temperature
unit coolers were two of the equipment classes where the efficiency
levels between TSL 3 and TSL 2 were the same. DOE is required to set
standards that achieve the maximum improvement in energy that the
Secretary determines is technologically feasible and economically
justified (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A)); therefore, in
the September 2023 NOPR DOE proposed the economically justified maximum
technology levels for medium- and low-temperature unit cooler equipment
classes. DOE is adopting amended standards based on the updated
analyses from the March 2024 NODA in this final rule that achieve the
maximum improvement in energy that the Secretary determines is
technologically feasible and economically justified. DOE notes that in
this final rule it is adopting the max-tech efficiency level for low-
temperature and high-temperature ducted unit coolers but is not
adopting the max-tech efficiency level for all analyzed capacities of
medium-temperature unit coolers in this final rule. See section V.C of
this document for further discussion.
Lennox commented that the baseline design assumptions and AWEF2
levels may result in proposed AWEF2 standard levels that would drive
financials considerably more unfavorably to manufacturers and
consumers. Lennox requested that DOE correct discrepancies in baseline
assumptions and costs associated with higher efficiency levels in the
September 2023 NOPR and September 2023 NOPR TSD. (Lennox, No. 70 at p.
8) Lennox stated that once DOE has addressed the technical issues
Lennox identified in the September 2023 NOPR,
[[Page 104637]]
DOE must re-run the NOPR analysis to determine if the proposed
standards are technologically feasible and economically justified.
Lennox recommended that the final standards be no more stringent than
those proposed in the September 2023 NOPR. (Lennox, No. 70 at p. 6) In
response to the March 2024 NODA analysis, Lennox stated that DOE must
address various technical issues--baseline design assumptions and costs
of attaining higher efficiency levels, reduced incremental margins
assumptions to attain higher efficiency levels, and product lifetime
assumptions--to ensure that any new WICF energy conservation standard
is ``technologically feasible and economically justified'', as required
by statute. (Lennox, No. 87 at p. 3) Lennox further stated that section
7 of the NODA support document presents updated AWEF2 calculations for
refrigeration system equipment classes at TSLs presented in the NODA
that lack justification. (Id. at pp. 7-8) Lennox commented it has
significant concerns regarding this rulemaking's technical and cost
analysis, and DOE has not demonstrated that amended energy conservation
standards are appropriate. (Id. at p. 8)
In the March 2024 NODA, DOE reviewed and updated parts of its
analyses based on stakeholder feedback from the September 2023 NOPR and
DOE's own findings. As such, in the March 2024 NODA, DOE presented
updated LCC and PBP results, as well as national impacts. 89 FR 18555.
Additionally, in this final rule, DOE further reviewed and updated its
analyses based on stakeholder feedback from both the September 2023
NOPR and March 2024 NODA, in particular for refrigeration systems and
through comments raised by Lennox. DOE addresses and discusses Lennox's
indicated technical issues in section IV of this document. The updated
analytical results that reflect the comments that have been addressed
can be found in section V of this document. DOE has concluded that the
analyses in this final rule are representative of the performance
capabilities and costs of WICF components to justify the adopted
standards. When proposing a standard level, DOE considers the benefits
and burdens of each TSL as discussed in section V.C.1 of this document.
As a result, DOE is adopting a standard level that represents the
maximum improvement in energy efficiency that is technologically
feasible and economically justified for both consumers and
manufacturers.
Senneca and Frank Door commented that the standards proposed in the
September 2023 NOPR for WICFs contain procedural and substantive flaws,
which affect the technical feasibility and economic justification of
the proposed standards and have the potential to violate EPCA and the
Administrative Procedure Act. (Senneca and Frank Door, No. 78 at p. 1)
Senneca and Frank Door asserted that DOE used inaccurate inputs to
calculate several values that are integral to DOE's evaluation of
whether the proposed standards are economically justified, and that,
therefore, DOE should withdraw the September 2023 NOPR and redo the
evaluation with accurate inputs in every calculated value. (Senneca and
Frank Door, No. 78 at p. 6) Senneca and Frank Door commented that the
proposed standards would result in the elimination of certain types
and/or sizes of doors and the elimination of anti-sweat heat, which the
commenters stated would violate 42 U.S.C. 6295(o)(4). (Senneca and
Frank Door, No. 78 at pp. 5-6) Following publication of the March 2024
NODA, Senneca commented that the NODA does not address flaws in the
September 2023 NOPR. Senneca stated that DOE cannot identify technology
options that, when applied in a real-world context as opposed to
modeling, are capable of achieving the level of reductions that would
be required under either set of standards; in effect, DOE has failed to
meet its burden for both the standards in the September 2023 NOPR and
the March 2024 NODA.
Imperial Brown stated that the 0.06 coefficient to calculate the
March 2024 NODA MDEC for low-temperature doors is too stringent.
Imperial Brown stated that this reduction leads to MDEC requirements
that Imperial Brown believes the industry cannot achieve. Imperial
Brown stated that it supports energy conservation but is concerned that
the MDEC proposed is unattainable. (Imperial Brown, No. 84 at pp. 1-3)
RSG commented that the proposed changes in maximum daily energy
consumption for non-display doors would pose a significant challenge
because RSG and other manufacturers have already implemented reduced
anti-sweat heat as a design option to the meet the current standards.
RSG stated that the reduction in maximum daily energy consumption
outpaces the technology changes for reduced, real-world power
consumption; therefore, RSG suggested that DOE refrain from adopting
such significant reduction in the maximum daily energy consumption at
this time. (RSG, No. 69 at p. 1)
DOE notes that in the March 2024 NODA, DOE reviewed and updated
parts of its analyses based on stakeholder feedback from the September
2023 NOPR and DOE's own findings. In the March 2024 NODA, DOE presented
an updated engineering analysis for non-display doors based on
stakeholder feedback in response to the September 2023 NOPR and
presented updated LCC and PBP results, as well as national impacts. 89
FR 18555. Specifically, in the March 2024 NODA, DOE presented energy
consumption allowances for electricity-consuming devices that may be
present on non-display doors and updated the energy consumption due to
thermal load for low-temperature non-display doors. DOE addresses and
discusses the feedback received from Senneca and Frank Door, Imperial
Brown, and RSG in section IV and V of this document. In this final
rule, DOE is adopting standards for non-display doors that are less
stringent (i.e., allow a higher MDEC) than those proposed in the
September 2023 NOPR. In consideration of stakeholder feedback and
uncertainty as to whether all non-display doors could implement certain
design options (i.e., improved frame systems and reduced anti-sweat
heat) DOE is adopting a standard level that does not necessitate the
use of those design options, which is discussed in section V.C.1.a of
this document. Based on the considerations discussed in section V.C.1.a
of this document, DOE has concluded that the adopted standards for non-
display doors would not result in the elimination of certain types and/
or sizes of doors; nor would the adopted standards result in the
elimination of anti-sweat heat. Further, DOE has concluded that the
reduction in MDEC is achievable by the walk-in door industry. DOE has
concluded that the analyses in this final rule are sufficiently
representative of the performance capabilities and costs of WICF
components to justify the adopted standards.
Rep. Bice expressed strong opposition to multiple rules recently
proposed by DOE that would add new regulations. Rep. Bice expressed
concern that the consistent proposals coming out of DOE are adding
burdensome energy conservation standards to products Americans use on a
regular basis. Rep. Bice stated that increased standards will increase
production costs for manufacturers and retail prices for consumers and
asserted that this would cost millions of dollars with little long-term
benefit. (Rep. Bice, No. 82 at p. 1)
As previously discussed, EPCA requires that DOE must periodically
evaluate the appropriateness of
[[Page 104638]]
amended energy conservation standards and publish either a NOPD stating
that standards for the equipment do not need to be amended, or a NOPR
including new proposed energy conservation standards not later than 6
years after the issuance of any final rule establishing or amending a
standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1)) DOE has concluded
that the standards adopted in this final rule are economically
justified and will save consumers $442.7 million annually (2023$) over
the lifetime of equipment shipped (see section I.C.1.c of this document
for details).
2. Comments Regarding the Proposed Compliance Date
In the September 2023 NOPR, DOE estimated publication of a final
rule regarding amended energy conservation standards for walk-ins in
2024; therefore, for purposes of the September 2023 NOPR analysis, DOE
used 2027 as the first year of compliance with any amended standards
for walk-ins, consistent with the requirements of EPCA (see 42 U.S.C.
6313(f)(5)(B)(i)). 88 FR 60746, 60791.
In response, AHRI commented that the proposal requires as much as a
15-percent increase in efficiency. AHRI stated that a maximum 5-percent
increase in efficiency would be acceptable, depending on other related
requirements, however, AHRI also stated the 2027 timing for compliance
is not desirable even if DOE were to amend unit cooler energy
efficiency minimums by 5 percent given the EPA Significant New
Alternatives Policy Program (``SNAP'') 23 activities and test method
changes that would require efficiency improvements. (AHRI, No. 72 at p.
5) AHRI commented that should DOE adopt the standards proposed in the
September 2023 NOPR without any changes, AHRI suggests that DOE target
to publish this final rule by June 2025 with a 3-year compliance period
(i.e., compliance required by June 2028). AHRI recommended that if
there are changes to the September 2023 NOPR based on stakeholder
comments, the compliance date should be pushed back further. (Id. at p.
14)
Lennox commented that a 3-year lead time to comply with potential
amended WICF energy conservation standards is inadequate. Lennox
commented that manufacturer engineering, lab, and product development
resources are already overburdened through 2026 due to required
compliance with EPA's ``technology transition'' final rule. Lennox
added that manufacturer resources are additionally strained by
competing out-of-sequence rulemakings, which impose a cumulative
regulatory burden on WICF manufacturers. Lennox requested that DOE
allow an additional 2 years' lead time (for a total of 5 years) to
comply with any amended WICF energy conservation standards; Lennox
added that the 5-year lead time would allow for WICF manufacturers to
implement required changes after the required EPA refrigerant
transition. Lennox commented that due to these factors, manufacturing
capacity and/or engineering resource constraints are significant and
may indeed limit consumer access to, as well as increase costs for,
WICF under a 3-year, versus a 5-year, compliance period. Lennox further
commented that even a 5-year compliance period is feasible only if DOE
issues final standards that are no more stringent than those proposed
in the NOPR. (Lennox, No. 70 at pp. 1-3, 9)
Additionally, in response to the March 2024 NODA, Lennox stated
that as an alternative to allowing a longer compliance period, DOE
should postpone the rulemaking process until the low-GWP products are
available to ensure DOE meets the statutory criteria in promulgating
energy conservation standards that are ``economically justified.''
Lennox stated that increasing the energy efficiency of WICF products
using low-GWP refrigerants presents significant uncertainty regarding
costs and stated that DOE has not adequately addressed this issue, as
the design and manufacture of WICF equipment that uses low-GWP
refrigerants is complex and involves A2L refrigerants that present
significant engineering challenges different from existing refrigerants
used. Lennox stated it is premature for DOE to consider tightening
standards for WICF equipment that is not yet on the market. (Lennox,
No. 87 at p. 2) Lennox stated that DOE should not move to a final rule
regarding WICF equipment, but rather DOE should continue to improve its
analysis to ensure that the proposed standards are economically
justified. Lennox also stated that given the substantial redesign of
WICF equipment that is already underway regarding EPA requirements to
transition to equipment that uses low-GWP refrigerant, Lennox believes
DOE's best course would defer further rulemaking until that redesigned
equipment is better understood and engineering and lab capacity becomes
available to better assess amended WICF energy conservation standards.
(Lennox, No. 87 at pp. 4-5) NRAC commented that engineering resources
will be fully consumed by the transition to low-GWP refrigerants and
transitioning all product lines to the new safety standards. NRAC
commented that it will have insufficient time to meet the 2027 amended
standard compliance date and requested a pause on the amended standards
until after the transition to low-GWP refrigerants is complete. NRAC
commented that the proposed rulemaking would require a transition to
new low-GWP A2L refrigerants as well as a change in all the safety
standards, which would in turn require changes to testing and design of
current equipment. NRAC recommended a pause, delay, or no-new-standards
rulemaking to benefit the environment and all parties. (NRAC, No. 73 at
pp. 2-3)
DOE understands that Federal and State refrigerant regulations,
such as EPA's October 2023 EPA Technology Transitions Final Rule,
require manufacturers of WICF refrigeration systems to cease
manufacturing equipment that uses high-GWP HFC refrigerants and to
begin manufacturing redesigned equipment that uses low-GWP refrigerants
before that rule's compliance date, which would occur prior to the
expected compliance date of new and amended DOE standards. As discussed
in section V.B.2.e of this document, DOE expects that the research and
development and capital investment required to comply with the October
2023 EPA Technology Transitions Final Rule may exceed the typical
industry R&D and capital expenses. DOE has quantitatively estimated
those expenditures in its Government Regulatory Impact Model (``GRIM'')
\20\ in the no-new-standards case and standards case to reflect the
increased operating expenses and reduced cash flow experienced by
industry due to Federal refrigerant regulations. DOE qualitatively
discusses potential engineering and laboratory resource constraints in
section V.B.2.cof this document.
---------------------------------------------------------------------------
\20\ The GRIMs developed for this final rule are available for
download at: www.regulations.gov/docket/EERE-2017-BT-STD-0009/document.
---------------------------------------------------------------------------
Regarding the timeline to comply with EPA refrigerant regulations,
in the notice of proposed rulemaking published in the Federal Register
on December 15, 2022 (``December 2022 EPA Technology Transitions
NOPR''), EPA proposed a January 1, 2025 compliance date for the
refrigeration categories that apply to walk-in refrigeration systems
(i.e., remote condensing units and cold storage warehouse systems). 87
FR 76738, 76810. In the October 2023 EPA Technology Transitions Final
Rule, EPA determined that due to the need for
[[Page 104639]]
certain SNAP approvals,\21\ updates to building codes, equipment
design, testing, and certifications, technician trainings, and
manufacturing facility upgrades, providing additional time to comply
was reasonable for certain subsectors in retail food refrigeration,
including the categories applicable to walk-in refrigeration systems.
88 FR 73098, 73149-73152. As such, EPA finalized a compliance date of
January 1, 2026, for both remote condensing units and cold storage
warehouses, delaying compliance one year from what was proposed in the
December 2022 EPA Technology Transitions NOPR.
---------------------------------------------------------------------------
\21\ The EPA SNAP program evaluates and approves alternative
refrigerants to those that are no longer compliant.
---------------------------------------------------------------------------
In the September 2023 NOPR and March 2024 NODA, DOE analyzed a 3-
year compliance lead-in period for walk-in doors, panels, and
refrigeration systems, which DOE modeled as requiring compliance in
2027. DOE notes that it has some flexibility under EPCA to delay the
effective date of amended standards: if the Secretary determines that a
3-year period is inadequate, the Secretary may establish an effective
date for WICFs manufactured beginning on the date that is not more than
5 years after the date of publication of a final rule for WICFs. (42
U.S.C. 6313(f)(5)(B)(ii)) DOE received comments regarding industry's
ability to meet the standards proposed in the September 2023 NOPR
specific to walk-in refrigeration systems. Although most manufacturers
emphasized that a 3-year lead-in and 2027 compliance date would not be
feasible due to engineering and laboratory resource constraints related
to the refrigerant transition, RSG commented that a 2027 compliance
date would be viable to meet the standards proposed in the September
2023 NOPR for walk-in refrigeration systems. (RSG, No. 69 at p. 3) AHRI
commented that if DOE adopted the standards proposed in the September
2023 NOPR, a June 2028 compliance date would be feasible for industry.
Generally, DOE understands that aligning compliance dates to avoid
multiple successive redesigns can help to reduce cumulative regulatory
burden. However, most stakeholder comments indicate that the rulemaking
timelines and compliance periods for DOE and EPA regulations make it
challenging to redesign and retest walk-in refrigeration systems
simultaneously to meet both the October 2023 EPA Technology Transitions
Final Rule and new and amended DOE standards. Specifically,
manufacturers are in the midst of redesigning walk-in refrigeration
systems to comply with the October 2023 EPA Technology Transitions
Final Rule by January 1, 2026, and may not be able to incorporate the
necessary updates to comply with new and amended DOE standards within
the same design cycle. Furthermore, DOE is not aware of significant
walk-in refrigeration system shipments currently rated above the
baseline efficiency level (i.e., EL 0). Thus, DOE expects that most
manufacturers will need to update their equipment portfolios to meet
the standards adopted in this final rule. Therefore, based on
stakeholder comments and DOE's assessment of the investments and
redesign required to meet the adopted levels, combined with the
overlapping Federal refrigerant regulations, DOE is extending the
compliance period so that compliance is required by December 31, 2028
(modeled as 2029), approximately 1 year later than the expected
compliance year (2027) analyzed in the September 2023 NOPR (which was
based on a 3-year compliance period).
DOE has determined that spreading out the DOE compliance date for
amended energy conservation standards from the October 2023 EPA
Technology Transitions Final Rule compliance date will help alleviate
manufacturers' concerns about engineering and laboratory resource
constraints. Furthermore, the longer compliance period will help
mitigate cumulative regulatory burden by allowing manufacturers more
flexibility to spread investments across approximately 4 years instead
of 3 years. Manufacturers will also have more time to recoup any
investments made to redesign walk-in equipment for the October 2023 EPA
Technology Transitions Final Rule as compared to a 3-year compliance
period.
DOE did not receive comments regarding the 3-year compliance period
analyzed in the September 2023 NOPR for walk-in doors or panels.
Therefore, DOE maintains the 3-year compliance period for the amended
walk-in non-display doors standard in this final rule, which DOE models
as 2028. As previously discussed, DOE is not amending the standard for
walk-in panels and display doors.
3. Comments Regarding Rulemaking Process
In response to the September 2023 NOPR and March 2024 NODA, DOE
received several comments regarding the process of the rulemaking.
In response to both the September 2023 NOPR and the March 2024
NODA, AHRI requested that DOE consider a pause in its current
rulemakings relating to energy conservation standards for walk-ins,
given the efforts now underway across the HVACR industry to transition
to new classes of refrigerants with low GWP for the AIM Act. AHRI
commented that since most substitute refrigerants capable of complying
with the AIM Act are A2Ls, SNAP approvals contain highly prescriptive
use conditions and limitations, including conformance to safety
standards that are now in the process of being updated and revised,
such as ASHRAE 15 \22\ and UL 60335-2-89. AHRI commented that State and
local building codes further complicate the picture, with many
prohibiting A2Ls and requiring updating, which can take 2 to 5 years to
complete--eight States have updated their codes and more than 20 have
yet to authorize A2L refrigerants for commercial refrigeration. (AHRI,
No. 72 at pp. 1-2 and No. 86 at pp. 1-3)
---------------------------------------------------------------------------
\22\ ASHRAE Standard 15, Safety Standard for Refrigeration
Systems and ANSI/ASHRAE Standard 34-2022, Designation and Safety
Classification of Refrigerants.
---------------------------------------------------------------------------
DOE is statutorily required to publish either a NOPD if it finds
that standards for the equipment do not need to be amended, or a NOPR
including new proposed energy conservation standards not later than 6
years after the issuance of any final rule establishing or amending a
standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1)) The final rules
that established the current standards for walk-in doors and
refrigeration systems were issued in 2014 and 2017, respectively.
Further, EPCA specifically prescribed that no later than January 1,
2020, DOE shall publish a final rule to determine if standards for
walk-ins should be amended. (42 U.S.C. 6313(f)(5)) DOE is conducting
this rulemaking pursuant to these statutory requirements.
Regarding AHRI's comments surrounding the transition to low-GWP
refrigerants in response to Federal refrigerant regulations, DOE
considered the refrigerant transition and the burdens that come with it
in the analyses that support this final rule. With respect to AHRI's
concern that some State and local building codes currently prohibit
A2Ls, DOE notes that although it considers the potential impacts of
refrigerant regulations on walk-in refrigeration systems in its
analysis, the energy conservation standards adopted in this final rule
generally do not require the use of specific refrigerants (e.g.,
A2Ls).\23\
[[Page 104640]]
Furthermore, DOE is aware of ongoing efforts by industry groups and
other stakeholders to work with State and local officials to update
building codes to allow for alternative refrigerants, such as A2Ls.
Additionally, DOE notes that EPA, to the extent practicable, took
building codes into account in its consideration of availability of
substitutes in the October 2023 EPA Technology Transitions Final Rule.
88 FR 73098, 73136. As such, DOE understands that EPA established
compliance dates for the transition to low-GWP refrigerants with the
expectation that jurisdictions will prioritize completing building code
updates with the October 2023 EPA Technology Transitions Final Rule
deadlines in mind. Id. DOE notes that the change in the EPA compliance
date for walk-in refrigeration systems (i.e., from January 1, 2025
proposed in the December 2022 EPA Technology Transitions NOPR to
January 1, 2026 finalized in the October 2023 EPA Technology
Transitions Final Rule) provides additional time for jurisdictions to
update their building codes or legislation accordingly. As previously
discussed, DOE is finalizing a compliance date of December 31, 2028,
for walk-in refrigeration systems (approximately 3 years after the
October 2023 EPA Technology Transitions Final Rule compliance date for
walk-in refrigeration systems), which DOE believes is sufficient time
for manufacturers to comply with the adopted standards, accounting for
other regulatory obligations. DOE expects that all states will have
updated their building codes to reference the updated mechanical codes
and safety standards by the December 31, 2028, compliance date.
---------------------------------------------------------------------------
\23\ DOE notes that it expects that manufacturers of lower-
capacity medium temperature single-packaged dedicated condensing
systems would generally incorporate propane compressors at the
standard level adopted in this final rule. However, the charge of
propane required for these systems is within the acceptable charge
limits specified in an EPA SNAP rule for propane in a refrigeration
circuit (300 grams) for refrigeration systems with end-uses in the
retail food industry. 89 FR 50410, 50467.
---------------------------------------------------------------------------
Ravnitsky supported DOE's efforts to improve the energy efficiency
of walk-ins, stating that the benefits estimated by DOE are substantial
for the consumers, economy, and environment. Ravnitsky recommended that
DOE adopt a negotiated rulemaking process to revise the standards for
walk-ins. (Michael Ravnitzky, No. 55 at pp. 1-3)
The Appliance Standards and Rulemaking Federal Advisory Committee
(``ASRAC'') allows DOE to use negotiated rulemaking as a method to
engage all interested parties, gather data, and attempt to reach
consensus on establishing energy conservation standards. ASRAC has not
voted to proceed with a negotiated rulemaking regarding energy
conservation standards for WICFs. Further, there was no additional
information provided to suggest that a negotiated rulemaking would
result in standards significantly different than those proposed in the
September 2023 NOPR or adopted in this final rule. Therefore, DOE is
adopting this final rule after using the typical rulemaking process.
Senneca commented that the information contained in the March 2024
NODA undermines DOE's standards proposed in the September 2023 NOPR.
Senneca stated that the failure to consider the energy consumption of
the additionally analyzed electricity-consuming devices (i.e., heating
vents, heated viewing windows, lights, and thermometer/temperature
alarms) despite having documented that they are all included on models
of doors covered by the proposed standards invalidates DOE's
conclusions that the proposed standards are technologically feasible
and economically justified as they were based on a model door that is
not representative of doors in the market. Senneca commented that DOE
should withdraw the proposed standards and restart the process so that
additional electrical components can be included in the required
analysis. (Senneca, No. 92 at pp. 1-2) Senneca stated that DOE cannot
propose new standards in a NODA. Senneca stated that the new standards
cannot be considered a logical outgrowth of the September 2023 NOPR.
Senneca also stated that the standards are not amendments to existing
standards and that they are entirely new standards for entirely new
classes of equipment. (Senneca, No. 92 at pp. 2-3) Senneca further
stated that if DOE considered product literature and non-public
information, DOE must first make data and information available to the
public as part of the rulemaking docket before using that data and
information. (Senneca, No. 92 at p. 3) Hormann and Jamison supported
the comments made by Senneca and Frank Door in response to the
September 2023 NOPR and March 2024 NODA. (Hormann, No. 85 at p. 1;
Jamison, No. 83 at p. 1)
As noted previously, under EPCA DOE has authority to amend the
energy conservation standards applicable to certain industrial
equipment, including equipment meeting the definition of walk-in
coolers and walk-in freezers. (42 U.S.C. 6295(m); 6316(a); 6311(20)).
In doing so, DOE may make certain standards more stringent and can
impose additional standards on equipment that fall within the
definition of a covered equipment category that previously were not
subject to existing regulation. Consistent with EPCA's purposes, this
authority allows DOE to amend standards to adjust to technological
innovations and changes in the marketplace. DOE further has authority
to establish separate equipment classes 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 short,
DOE has authority to amend the energy conservation standards applicable
to walk-ins and to add certain equipment classes, as adopted in this
final rule.
DOE further responds that it did not propose new standards in the
March 2024 NODA. As discussed in the March 2024 NODA, upon
consideration of the views shared in the September 2023 Public Webinar
and public comments DOE received in response to the September 2023
NOPR, the March 2024 NODA presented an analysis with updated portions
of DOE's NOPR analysis for walk-in non-display doors and refrigeration
systems on which DOE had sought comments, data, and information. 89 FR
18555, 18556. In the March 2024 NODA, DOE demonstrated how the updated
analysis applied to the existing equipment classes through the
inclusion of the MDEC allowances (see section IV.A.1.a of this
document) for non-display doors and the impact on the standards
equations proposed in the September 2023 NOPR, which functionally would
make them sub-classes within the existing class structure. (Id. at 89
FR 18576). DOE did not propose any new TSLs and sought further public
input. Id. In this final rule, DOE has incorporated additional feedback
regarding the March 2024 NODA analysis (see section IV of this final
rule) and adopted standards that reflect the totality of feedback
received during this rulemaking process, including the comments
regarding energy use of electricity-consuming components, in response
to both the September 2023 NOPR and the March 2024 NODA. The standards
adopted in this final rule are within the range of alternatives
proposed in the September 2023 NOPR.
In the September 2023 NOPR, DOE summarized the NOPR stage
deviations from 10 CFR part 430, subpart C, appendix A (which DOE
referred to as the ``Process Rule'' in that document). 88 FR 60746,
60756. In response to the September 2023 NOPR, Senneca and Frank Door
disagreed with DOE's decision to deviate from the process outlined for
the development of new
[[Page 104641]]
efficiency standards, specifically regarding DOE's decision not to
publish a Framework Document due to alleged redundancy and to reduce
the comment period for interested parties to respond to the proposed
rule by 20 percent. Senneca and Frank Door commented that if redundancy
and multiplicity of comment opportunities were valid reasons to deviate
from the Process Rule, no standards development rulemaking would need
to follow the process adopted by DOE in that rule. Senneca and Frank
Door commented that DOE's rulemaking process intentionally includes
requirements to explain aspects of the rulemaking in multiple documents
and provide interested parties with multiple opportunities to comment.
Senneca and Frank Door additionally commented that the previous
opportunities for interested parties to provide comments were not, in
fact, opportunities to comment on the proposed standards themselves,
but instead were opportunities for interested parties to inform DOE's
decisions on whether to propose amended standards and what the proposed
standards should be. Senneca and Frank Door commented that DOE's
rationale for limiting the opportunity for the public to participate in
the development of the proposed standards was further weakened when two
leading trade associations jointly requested additional time to comment
due to the complexity of the issues presented in the proposal, a
request that DOE refused to accommodate. Senneca and Frank Door
commented that DOE's decision to deviate from the Process Rule sets a
precedent to continue deviating from the Process Rule. (Senneca and
Frank Door, No. 78 at pp. 2-3)
Senneca and Frank Door commented that prior opportunities to
comment on the technological feasibility and economic costs of the
potential new standards did not sufficiently capture important
information from WICF door manufacturers. Senneca and Frank Door
commented that the single manufacturer of WICF doors to comment on
DOE's Preliminary Analysis does not manufacture any doors that would be
covered by the proposed standards, and that DOE's reliance on
information from this manufacturer to justify reducing the amount of
information made available to the public, shorten the length of the
comment period, and support the conclusion that the proposed standards
are technically feasible and economically justified is inconsistent
with DOE's commitment to robust participation. (Id.)
In a final rule published on December 13, 2021, DOE adopted a
provision allowing it to depart from the general guidance in 10 CFR
part 430, subpart C, appendix A so long as DOE provides notice and an
explanation (86 FR 70892, 70896). This rule restored DOE's authority to
deviate on a case-by-case basis, which was included in previous
versions of appendix A. (61 FR 36974) The provisions at 10 CFR part
430, subpart C, appendix A contain procedures, interpretations and
policies that are generally applicable to the development of energy
conservation standards, but DOE may, as provided in the rule itself,
deviate from this appendix to account for the specific circumstances of
a particular rulemaking. See section (3)(a) of appendix A to subpart C
of 10 CFR part 431. If DOE concludes that changes to the procedures,
interpretations, or policies in 10 CFR part 430, subpart C, appendix A
are necessary or appropriate, DOE will provide notice in the Federal
Register of modifications to this appendix with an accompanying
explanation. See section (3)(b) of appendix A to subpart C of 10 CFR
part 431.
As provided in the September 2023 NOPR, 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. As such, in the September 2023 NOPR, DOE determined that
publication of a separate framework document would be largely redundant
given previously published documents. DOE maintains its determination
that publication of a separate framework document would be largely
redundant for this rulemaking. Further, 10 CFR part 430, subpart C,
appendix A as amended does not require that a framework document and
preliminary analysis be published in the pre-NOPR stage and states that
such pre-NOPR documents could take several forms depending upon the
specific proceeding. See section 6(a) of appendix A to subpart C of 10
CFR part 430.
As also 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
the September 2023 NOPR analysis remained largely the same as the June
2022 Preliminary Analysis, and in light of the 60-day comment period
DOE provided with its June 2022 Preliminary Analysis, DOE determined
that a 60-day comment period was appropriate for the September 2023
NOPR and provided interested parties with a meaningful opportunity to
comment on the proposed rule. 88 FR 60746, 60756. Additionally, DOE
made subsequent updates to the September 2023 NOPR analysis in the
March 2024 NODA and provided interested parties an opportunity to
comment on those updates. 89 FR 18555.
Regarding Senneca and Frank Door's assertion that previous
opportunities for interested parties to provide comments were not
opportunities to comment on the proposed standards themselves, DOE
notes that stakeholders were given the opportunity to comment on the
assumptions used in analyses that fed into the standards proposed in
the September 2023 NOPR. As discussed previously in this section, the
analysis presented in the September 2023 NOPR remained largely the same
as the analysis presented in the June 2022 preliminary analysis.
Additionally, the March 2024 NODA afforded stakeholders an additional
opportunity to comment on the updated analysis. As such, stakeholders
were given multiple opportunities to provide input on the analyses and
assumptions that support this final rule.
Regarding Senneca and Frank Door's assertion that prior
opportunities to comment on the technological feasibility and economic
costs of the potential new standards did not sufficiently capture
important information from WICF door manufacturers, DOE notes that in
addition to public comments, DOE sought feedback from WICF door
manufacturers during confidential manufacturer interviews. Feedback
from these interviews has been incorporated throughout the September
2023 NOPR analysis and this final rule analysis.
4. Comments Regarding Prescriptive Standards
Kolpak requested that DOE clarify its requirements for minimizing
infiltration when doors are open and suggested that DOE require spring-
loaded hinges causing the door to self-close and either fan-driven air
curtains, strip curtains, or strip doors. (Kolpak, No. 66, Attachment 1
at pp. 2-3)
[[Page 104642]]
The prescriptive standards for walk-ins were set in EPCA by
Congress and were subsequently codified by DOE at 10 CFR 431.306(a)(2).
It is required that each walk-in cooler or walk-in freezer manufacturer
on or after January 1, 2009, have strip doors, spring-hinged doors, or
other methods of minimizing infiltration when doors are open. DOE is
not updating the prescriptive standards for walk-ins in this
rulemaking.
5. Comments Regarding the Standards Equations
DOE presented several potential energy conservation standards
curves for refrigeration systems as supporting data for the March 2024
NODA. See section 7 of the NODA support document.\24\
---------------------------------------------------------------------------
\24\ ``Detailed Data for Engineering Analysis and National
Impact Analysis for the Notice of Data Availability Pertaining to
Walk-in Coolers and Walk-In Freezers.'' Available at
www.regulations.gov/document/EERE-2017-BT-STD-0009-0079.
---------------------------------------------------------------------------
AHRI, Hussmann, and Lennox stated that for the medium-temperature
and low-temperature unit cooler (UC.M and UC.L) equipment classes, the
efficiency level selected is the same for TSL 1, 2 and 3 but that there
are different standards equations for TSL 3 than TSL 1 and 2 in the
NODA support document. (AHRI, No. 86 at pp. 5-6; Hussmann, No. 88 at
pp. 3-4; Lennox, No. 87 at p. 6) AHRI requested that DOE clarify the
difference between the equations for TSL 1 and 2 and those for TSL 3.
(AHRI, No. 86 at pp. 5-6)
DOE notes that the standards equations shown for medium-temperature
and low-temperature unit coolers in the March 2024 NODA support
document at TSL 3 should have matched those for TSL 1 and TSL 2, as the
same efficiency level was selected for each TSL. The equations for TSL
3 were erroneously different from those at TSL 1 and 2 for medium-
temperature and low-temperature unit coolers. DOE also notes that in
the NODA support document, the equation for the high-temperature,
ducted unit coolers at TSL 2 was erroneously written and did not
account for the updated NODA analysis. In this final rule, the equation
at TSL 2, which is the adopted standard level, has been corrected to
reflect the changes made in the March 2024 NODA analysis. DOE does not
believe these typographical errors impacted commenters' ability to
evaluate and provide input on DOE's updated analysis.
AHRI and Lennox asked how the equation (- 6.43 x 10-6 x
qnet + 9.97) that increases the minimum AWEF2 from 9.65 in
the September 2023 NOPR to a higher minimum AWEF2 up to 9.9 in the
March 2024 NODA for net capacities greater than or equal to 9 kBtu/h
and less than 54 kBtu/h was determined. (AHRI, No. 86 at p. 5; Lennox
No. 87 at pp. 7-8) AHRI asserted that the AWEF2 standard should reflect
a decrease and not an increase and recommended that DOE review the
rationale and reconcile it with the change in the AWEF2 standard.
(AHRI, No. 86 at p. 5)
In the September 2023 NOPR, for medium-temperature and low-
temperature unit coolers, DOE proposed standards at constant AWEF2
values (i.e., the proposed AWEF2 standard did not vary with capacity).
Specifically, DOE proposed a standard equal to the average AWEF2
corresponding to the selected efficiency levels of each representative
capacity in the selected TSL. Stakeholders pointed out that the
proposed AWEF2 levels were above the ``max-tech'' levels for some of
the representative capacities. (AHRI, No. 72 at p. 4; Hussmann, No. 75
at p. 2) Additionally, the proposed AWEF2 levels were below the ``max-
tech'' levels for other representative capacities. In the March 2024
NODA, DOE presented standards equations for medium-temperature unit
coolers that vary with capacity, following the representative-capacity
efficiency levels more closely, but not exceeding any of the ``max-
tech'' levels for specific representative capacities. As such, the
presented standards equation resulted in AWEF2 values that were greater
than what was proposed in the September 2023 NOPR for capacities
between 9 kBtu/h and 54 kBtu/h for medium-temperature unit coolers.
See section IV.E.1 for discussion regarding how DOE set the
standards equations for the standards adopted in this final rule.
B. Scope of Coverage
This final rule 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 (``[deg]F'')
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 previously established separate
standards for the principal components that make up a walk-in (i.e.,
doors, panels, and refrigeration systems). In this final rule, DOE has
continued with this approach.
A ``door'' means an assembly installed in an opening on an interior
or exterior wall that is used to allow access or to 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.
In response to the September 2023 NOPR, AHRI commented that DOE is
expanding the scope of the rulemaking to include CO2 unit
coolers, multi-circuit single-packaged dedicated systems, and ducted
fan coil units, but DOE has not been able to procure a CO2-
dedicated condensing unit and did not test or allow for CO2-
dedicated condensing units. AHRI commented that the walk-in market will
probably adopt CO2-dedicated condensing units. (AHRI, No. 72
at p. 7)
In response to AHRI's assertion that DOE did not allow for
CO2-dedicated condensing units, DOE notes that the test
procedure for walk-in refrigeration systems does not explicitly define
scope based on refrigerant, as discussed in the May 2023 TP Final Rule.
88 FR 28780, 28786. Notwithstanding the fact that DOE did not adopt
test procedures specifically for CO2-dedicated condensing
units addressing the unique characteristics of CO2, DOE has
concluded that all such condensing units currently available, whether
in the United States or elsewhere, can be tested using the existing
test procedures set forth at 10 CFR part 431, subpart R, appendices C
and C1. Specifically, DOE's understanding is that no modifications are
needed to test CO2-dedicated condensing units under the
walk-in dedicated condensing unit test procedure, provided the
CO2 exiting the condensing unit is liquid. DOE also
[[Page 104643]]
notes that there are CO2-dedicated condensing units
certified in DOE's Compliance Certification Database (``CCD'')
currently. On this basis, and the fact that no petitions for waiver of
the DOE test procedure for condensing units have been submitted, DOE
concludes that the current test procedures and energy conservation
standards are applicable to such equipment. If a manufacturer believes
that a CO2-dedicated condensing unit contains one or more
design characteristics that prevent testing of the basic model(s)
according to the prescribed DOE test procedures or cause the prescribed
test procedures to evaluate the CO2-dedicated condensing
unit in a manner so unrepresentative of its true energy consumption
characteristics as to provide materially inaccurate comparative data,
then manufacturers can petition for a waiver in accordance with 10 CFR
431.401. DOE notes that in the May 2023 TP Final Rule, DOE adopted test
provisions specific for CO2 unit coolers and added new
provisions to appendix C1 because the industry test procedure
referenced in the DOE test procedure at the time (AHRI 1250-2009,
referenced in appendix C) did not accommodate CO2 unit
coolers. The procedure and provisions that DOE adopted were consistent
with waivers and interim waivers granted to manufacturers of
CO2 unit coolers. 88 FR 28780, 28786.
See section IV.A.1 of this document for discussion of the equipment
classes analyzed in this final rule.
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 as
the basis for certifying to DOE that their equipment complies with the
applicable energy conservation standards and as the basis for any
representations regarding the energy use or energy efficiency of the
equipment. (42 U.S.C. 6316(a); 42 U.S.C. 6295(s); and 42 U.S.C.
6314(d)). Similarly, DOE must use these test procedures to evaluate
whether a basic model complies with the applicable energy conservation
standard(s). 10 CFR 429.110(e). The current test procedure for walk-in
display and non-display doors is codified at 10 CFR part 431, subpart
R, appendix A (``appendix A''), which includes provisions for
determining maximum daily energy consumption, the metric on which
current standards for walk-in display and non-display doors are based.
10 CFR 431.306 The current test procedure for walk-in panels is
codified at 10 CFR part 431, subpart R, appendix B (``appendix B''),
which includes provisions for determining R-value, the metric on which
current standards for walk-in panels are based. The current test
procedure for walk-in refrigeration systems is codified at 10 CFR part
431, subpart R, appendix C (``appendix C''). Appendix C includes
provisions for determining AWEF, the metric on which current standards
for walk-in refrigeration systems are based.
In the September 2023 NOPR analysis, DOE used the test procedures
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 referred to as 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 efficiency
metric, AWEF2, for refrigeration systems. (See 10 CFR part 431, subpart
R, appendix C1.) The engineering analysis results and the adopted
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 energy conservation standards
promulgated as a result of this rulemaking.
D. Technological Feasibility
1. General
As discussed, 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))
To determine whether potential amended standards would be
technologically feasible, DOE first develops a list of all known
technologies and design options that could improve the efficiency of
the products or equipment that are the subject of the rulemaking. DOE
considers technologies incorporated in commercially available products
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). Section IV.A.2 of this document discusses the technology
options identified by DOE for this analysis. For further details on the
technology assessment conducted for this final rule, see chapter 3 of
the final rule TSD.
After DOE has determined which, if any, technologies and design
options are technologically feasible, it further evaluates each
technology and design option in light of the following additional
screening criteria: (1) practicability to manufacture, install, and
service; (2) adverse impacts on product utility or availability; (3)
adverse impacts on health or safety; and (4) unique-pathway proprietary
technologies. 10 CFR 431.4; 10 CFR part 430, subpart C, appendix A,
sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5). Those technology options that
are ``screened out'' based on these criteria are not considered
further. Those technology and design options that are not screened out
are considered as the basis for higher efficiency levels that DOE could
consider for potential amended standards. Section IV.B of this document
discusses the results of the screening analysis conducted for this
final rule. For further details on the screening analysis conducted for
this final rule, see chapter 4 of the final rule TSD.
2. Maximum Technologically Feasible Levels
EPCA requires that for any proposed rule that prescribes an amended
or new energy conservation standard or prescribes no amendment or no
new standard for a type (or class) of covered product, DOE must
determine the maximum improvement in energy efficiency or maximum
reduction in energy use that is technologically feasible for each type
(or class) of covered products. 42 U.S.C. 6316(a); 42 U.S.C.
6295(p)(1). Accordingly, in the engineering analysis, DOE identifies
the maximum efficiency level currently available on the market. DOE
also defines a ``max-tech'' efficiency level representing the maximum
theoretical efficiency that can be achieved through the application of
all available technology options retained from the screening
analysis.\25\ In many cases, the max-tech efficiency level is not
commercially available because it is not currently economically
feasible.
---------------------------------------------------------------------------
\25\ In applying these design options, DOE would only include
those that are compatible with each other that when combined, would
represent the theoretical maximum possible efficiency.
---------------------------------------------------------------------------
The max-tech levels that DOE determined for this analysis are
described in section IV.C.1 of this document and in chapter 5 of the
final rule TSD.
E. Energy Savings
1. Determination of Savings
For each trial standard level, DOE projected energy savings from
application of the TSL to walk-in doors,
[[Page 104644]]
panels, and refrigeration systems purchased in the 30-year period that
begins in the year of compliance with the amended standards (2028-2057
for doors and panels, 2029-2058 for refrigeration systems).\26\ The
savings are measured over the entire lifetime of walk-ins purchased in
the 30-year analysis 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.
---------------------------------------------------------------------------
\26\ DOE also presents a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (``NIA'') spreadsheet models
to estimate national energy savings (``NES'') from potential amended
standards for walk-ins. 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 are the
savings in the energy that is used to generate and transmit the site
electricity. For natural gas, the primary energy savings are considered
to be equal to the site energy savings. DOE also calculates NES in
terms of full-fuel-cycle (``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.\27\ 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.
---------------------------------------------------------------------------
\27\ 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. 6316(a); 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.\28\ For
example, some covered products and equipment have most of their energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
the impacts of products 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.
---------------------------------------------------------------------------
\28\ 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 adopted in this final rule are
projected to result in national energy savings of 1.60 quad, the
equivalent of the primary annual energy use of 10.6 million homes.
Based on the amount of FFC savings, the corresponding reduction in
emissions, and the need to confront the global climate crisis, DOE has
determined the energy savings from the standard levels adopted in this
final rule 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 potential new or amended standards 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 payback period (``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 cost (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
[[Page 104645]]
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 IV.H of this document,
DOE uses the NIA spreadsheet models to project national energy savings.
d. Lessening of Utility or Performance of Products
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
adopted 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 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 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)) To assist the Department of Justice (``DOJ'')
in making such a determination, DOE transmitted copies of its proposed
rule and the NOPR TSD to the Attorney General for review, with a
request that the DOJ provide its determination on this issue. In its
assessment letter responding to DOE, DOJ concluded that the proposed
energy conservation standards for walk-ins are unlikely to have a
significant adverse impact on competition. DOE is publishing the
Attorney General's assessment at the end of this final rule.
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 adopted 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
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 adopted standards are likely to result in
environmental benefits in the form of reduced emissions of air
pollutants and 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 IV.L 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 effect potential amended 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) and 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 IV.F of this document.
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 considered 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 GRIM,
to assess manufacturer impacts of potential standards. These three
spreadsheet tools are available on the DOE website for this rulemaking:
https://www.energy.gov/eere/buildings/walk-coolers-and-walk-freezers.
Additionally, DOE used outputs from the latest version of the Energy
Information Administration's (``EIA's'') Annual Energy Outlook
(``AEO'') 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
[[Page 104646]]
market for the products concerned, including the purpose of the
products, the industry structure, manufacturers, market
characteristics, and technologies used in the products. 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) market and industry trends, and (5) 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 final rule TSD for further discussion of the
market and technology assessment.
1. Equipment Classes
When evaluating and establishing or amending 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
considers such factors as the utility of the feature to the consumer
and other factors DOE determines are appropriate. (Id.)
As noted previously, rather than establishing standards for
complete walk-in systems, DOE has established separate standards for
each of the principal components that make up a walk-in (i.e., doors,
panels, and refrigeration systems). DOE's analysis for each component
is discussed in the following sections.
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.
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. Display doors are
further divided based on walk-in temperature (i.e., cooler/medium-
temperature or freezer/low-temperature). DOE currently defines separate
energy conservation standards for these two classes of display doors:
medium-temperature and low-temperature. 10 CFR 431.306(c).
In the September 2023 NOPR, DOE considered distinguishing display
door classes by the presence or absence of a motorized door opener for
the purposes of its analysis. DOE analyzed medium- and low-temperature
display doors without motorized door openers and medium-temperature
display doors with motorized door openers. Id. DOE did not identify any
motorized display doors for low-temperature applications and therefore
did not analyze such equipment in the September 2023 NOPR. 88 FR 60746,
60761. Ultimately, in the September 2023 NOPR, DOE did not find that
amended standards for display doors were economically justified and
therefore, DOE did not propose any amendments to the class structure
for display doors. 88 FR 60746, 60841-60843.
DOE did not receive any comments regarding the equipment classes
analyzed for display doors in the September 2023 NOPR. DOE maintains
its conclusion from the September 2023 NOPR for this final rule, and
for the purposes of this analysis, evaluated amended standards for
display doors by presence or absence of a motorized door opener.
Therefore, DOE evaluated the display door equipment classes in Table
IV.1 for this final rule. However, as discussed further in section
V.C.1.a of this document, DOE has determined that amended standards for
display doors are not economically justified; therefore, DOE is not
adopting equipment classes that differ from the existing classes for
display doors.
[GRAPHIC] [TIFF OMITTED] TR23DE24.017
DOE discusses representative units, baseline assumptions for
representative unit efficiency, and design options analyzed at higher
efficiency levels for walk-in display doors in section IV.C.1 of this
document. Consistent with the September 2023 NOPR, DOE 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 final rule. 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 did not receive any comments regarding
this in response to the September 2023 NOPR and 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.a and IV.A.2.b of this document.
Non-Display Doors
Non-display doors are all doors not considered display doors. (10
CFR 431.302) Non-display doors are mainly used to allow people and
products to be moved into and out of the walk-in. Non-display doors are
further divided into equipment classes 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. Id. DOE defines passage doors as any doors that are not display
doors or freights doors. Id. Passage and freight doors are further
divided based on walk-in temperature (i.e., cooler/medium-temperature
or freezer/low-temperature). DOE currently defines separate energy
conservation standards for the following walk-in non-display door
classes (10 CFR 431.306(d)):
Passage Door, Medium-temperature
Passage Door, Low-temperature
Freight Door, Medium-temperature
Freight Door, Low-temperature
[[Page 104647]]
In the September 2023 NOPR, DOE proposed to combine passage and
freight non-display door classes and instead differentiate non-display
doors by whether or not they have motorized door openers. 88 FR 60746,
60761. Unlike door size, DOE tentatively determined that the presence
or absence of a motorized door opener was a performance-related feature
that justified adopting a different standard. 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). Id.
As discussed in the March 2024 NODA, DOE received comments in
response to the September 2023 NOPR indicating that other electricity-
consuming devices such as heated vents, heated viewing windows, lights,
and thermometer/temperature alarms provide functionality. These
physical and functional attributes, which can be installed on non-
display doors, were not considered in the representative units analyzed
in the September 2023 NOPR but would be included in the calculation of
daily energy consumption (``DEC'') per the test procedure. The current
MDEC standards allow for additional electrical components such as
heated vents, heated viewing windows, lights, and thermometer/
temperature alarms to be included and considered in the DEC
calculation. However, the basis of the energy conservation standards
proposed in the September 2023 NOPR only accounted for the electrical
energy consumption from anti-sweat heat around the perimeter of the
door (and motors for doors classified as ``motorized non-display
doors''). As a result, in the March 2024 NODA, DOE tentatively
concluded that the proposed standards as outlined in the September 2023
NOPR may be difficult to meet for basic models of doors that have
additional electrical components beyond what DOE considered in its
representative units. 89 FR 18555, 18556-18559.
Therefore, in the March 2024 NODA, DOE presented an updated
analysis that included MDEC allowances for non-display doors with
certain electricity-consuming devices based on the feedback received in
response to the September 2023 NOPR. These MDEC allowances represent
additional energy consumption added to the adopted standard calculation
based on the presence of these certain electricity-consuming devices.
The MDEC allowances implement the four features as adders which
effectively result in a less-stringent standard when applied to the
base equipment class. In the March 2024 NODA, DOE considered MDEC
allowances, which represent additional equipment classes of non-display
doors, if manufacturers offer basic models with any combination of the
following four electricity-consuming devices:
[square] Lighting
[square] Anti-sweat heat for viewing window
[square] Digital temperature display with or without alarms
[square] Heated pressure relief vent
The four features are implemented as adders, which effectively
result in a less-stringent standard when applied to the base equipment
class. For example, if a basic model is sold with lighting, then the
basic model would be subject to the adopted standard for that equipment
class (i.e., manual or motorized, low-temperature or medium-temperature
non-display door) plus the lighting MDEC allowance. The allowances are
additive, i.e., maximum allowed MDEC is increased for each of the
devices that is present on the door.
Each of these electrical components is a performance-related
feature that provides functionality to the consumer when installed on a
non-display door. Pursuant to EPCA, 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
the equipment's capacity or other performance-related feature justifies
a different standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q)(1)(B)) In
the March 2024 NODA, DOE noted that these devices constitute a
performance-related feature that justifies a higher standard. DOE
sought comment in the March 2024 NODA on the MDEC allowances for the
specified electricity-consuming devices. 89 FR 18555, 18559. DOE
discusses comments received regarding the MDEC allowances in section
IV.C.1.c of this document.
In this final rule, DOE is adopting the approach outlined in the
updated analysis from the March 2024 NODA, that lighting, anti-sweat
heat for viewing windows, digital temperature displays with or without
alarms, and heated pressure-relief vents constitute performance-related
features that justify a higher MDEC standard. Each equipment class of
non-display doors is being further subdivided based on whether each
electricity-consuming device is present or not present. DOE analyzed
the equipment classes listed in Table IV.2 for walk-in non-display
doors. DOE further evaluated the MDEC allowances for classes of non-
display doors with lighting, anti-sweat heat for viewing windows,
digital temperature displays with or without alarms, and/or heated
pressure relief vents.
[GRAPHIC] [TIFF OMITTED] TR23DE24.018
DOE discusses representative units, baseline assumptions for
representative unit efficiency, and design options analyzed at higher
efficiency levels for walk-in non-display doors in section IV.C.1.c of
this document. DOE discusses MDEC allowances and the comments received
in response to the March 2024 NODA regarding the MDEC allowances in
section IV.C.1.c 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
[[Page 104648]]
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. DOE expected that setting an R-value requirement for walk-in
cooler floor panels would cause manufacturers to stop selling cooler
floor panels to avoid the certification burden. 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 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
Floor Panel, Low-Temperature
DOE has not established energy conservation 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
September 2023 NOPR, DOE proposed maintaining the current panel
equipment classes. 88 FR 60746, 60761-60762. DOE received no comment
regarding panel equipment classes in response to the September 2023
NOPR. As such, DOE is maintaining its current equipment classes for
walk-in panels. Table IV.3 summarizes the equipment classes for walk-in
panels.
[GRAPHIC] [TIFF OMITTED] TR23DE24.019
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.
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.
As discussed in the September 2023 NOPR, in general, DOE has
separated packaged equipment from split dedicated condensing
systems,\29\ as packaged equipment provides consumers with more options
for space-constrained applications. Single-packaged dedicated 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. Single-packaged dedicated
systems are constrained by the overall dimensions and weight
limitations of the equipment; therefore, manufacturers cannot employ
the same technologies, such as increased heat exchanger sizes. In the
September 2023 NOPR, DOE tentatively concluded that single-packaged
system and split system walk-in refrigeration systems cannot be
combined into the same equipment class because single-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. For these reasons, in
the September 2023 NOPR, DOE evaluated single-packaged dedicated
systems separately from split systems. 88 FR 60746, 60762-60763.
---------------------------------------------------------------------------
\29\ 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.
---------------------------------------------------------------------------
DOE did not receive any comments in response to the September 2023
NOPR or March 2024 NODA regarding its separation of equipment classes
for single-packaged dedicated systems and split systems. Further, DOE
maintains its conclusion that separate equipment classes are warranted
for single-packaged dedicated systems and split systems. Therefore, in
this final rule, DOE maintained a separate analysis for single-packaged
dedicated systems and split systems equipment classes.
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. DOE
established a test procedure for high-temperature unit coolers, matched
refrigeration systems, and single-
[[Page 104649]]
packaged dedicated condensing systems, but did not establish a test
procedure in the May 2023 TP Final Rule for high-temperature dedicated
condensing units tested alone. 88 FR 28780, 28816-28817. As such, DOE
did not analyze high-temperature dedicated condensing units as an
equipment class, but did analyze high-temperature unit coolers, matched
refrigeration systems, and single-packaged dedicated condensing systems
in the September 2023 NOPR analysis. 88 FR 60746, 60762-60763.
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 either sold in ducted or non-ducted
configurations, dependent on the configuration of the walk-in box and
surrounding space. Ducting adds flexibility to the installation
location and removes refrigeration equipment from the refrigerated
storage space. However, ducting imposes a higher external static
pressure on the system's fans and therefore, a ducted system has
greater energy consumption to maintain the same or sufficient airflow
(and sufficient cooling capacity) as a system without ducting. DOE
tentatively concluded ducting of high-temperature units constitutes a
performance-related feature. Therefore, in the September 2023 NOPR, DOE
evaluated high-temperature ducted and non-ducted units as separate
equipment classes. Id.
For the September 2023 NOPR, different from the treatment of
medium-temperature and low-temperature matched refrigeration systems
and single-packaged dedicated systems, DOE evaluated high-temperature
matched refrigeration systems and high-temperature single-packaged
dedicated systems as a single equipment class because 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 tentatively determined that a
single class of equipment encompassing high-temperature matched
refrigeration systems and single-packaged dedicated systems is
appropriate. In its September 2023 NOPR 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. Id.
DOE did not receive any comments in response to the September 2023
NOPR or March 2024 NODA regarding its selection of high-temperature
refrigeration system equipment classes. Further, DOE maintains its
conclusions that the high-temperature refrigeration system classes
proposed in the September 2023 NOPR are appropriate. Therefore, in this
final rule, DOE maintained the high-temperature equipment classes
analyzed in the September 2023 NOPR.
DOE analyzed and is establishing the equipment classes for
refrigeration systems for this final rule presented in Table IV.4.
BILLING CODE 6410-01-P
[[Page 104650]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.020
In the September 2023 NOPR, DOE evaluated multiple capacities in
each equipment class to better ascertain the relationship between
efficiency and net capacity. In this final rule, DOE maintained the
same approach and evaluated multiple capacities in each equipment
class. This is discussed in more detail in the Representative Units
subsection of section IV.C.1.e of this document.
2. Technology Options
DOE considered separate technology options for whole walk-ins,
doors and panels, and refrigeration systems.
a. Fully Assembled Walk-Ins
Although DOE has set standards for walk-in components (i.e.,
panels, doors, and refrigeration systems) rather than fully assembled
walk-ins, EPCA gives DOE authority to establish standards that address
fully assembled walk-ins. (42 U.S.C. 6313(f)(4)). Hence, DOE has
considered technologies that could be relevant for fully assembled
walk-ins in its technology assessment. In the market analysis and
technology assessment presented in chapter 3 of the June 2022
Preliminary Analysis TSD and in the September 2023 NOPR, 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:
(1) Energy storage systems,
(2) Refrigeration system override,
(3) Automatic evaporator fan shut-off,
(4) Non-penetrative internal racks and shelving,
(5) Humidity sensors,
(6) Fiber optic natural lighting, and
(7) Heat reclaim valve.
DOE received no comments on the technology options that might
improve the efficiency of whole walk-ins in response to the September
2023 NOPR. DOE maintained the same technology options for whole walk-
ins for this final rule analysis. DOE further discusses these
technology options in chapter 3 of the final rule TSD.
b. Doors and Panels
In the NOPR 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. The technology options analyzed for doors in the September
2023 NOPR are listed in Table IV.5.
[[Page 104651]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.021
BILLING CODE 6410-01-C
DOE received comments regarding several of the technology options
pertaining to the screening or use of these technology options in the
engineering analysis in response to the September 2023 NOPR and March
2024 NODA. DOE summarizes those comments and addresses them further in
sections IV.B and IV.C of this document.
DOE did not receive any comments suggesting that specific new
technology options for doors and panels be considered; therefore, DOE
is considering the same technology options for doors and panels in this
final rule that it considered in the September 2023 NOPR.
c. Refrigeration Systems
In the September 2023 NOPR, DOE identified 17 technology options
that would be expected to improve the efficiency of refrigeration
systems,
1. Improved evaporator and condenser fan blades,
2. Improved evaporator and condenser coils,
3. Evaporator fan control,
4. Oil management systems,
5. Hydrocarbon refrigerants,\30\
---------------------------------------------------------------------------
\30\ Hydrocarbon refrigerants were not listed as a technology
option in the September 2023 NOPR notice. 88 FR 60746, 60764-60765.
However, they were listed as a technology option on p. 3-41 of
chapter 3 of the NOPR TSD and considered in the September 2023 NOPR
analysis as a design option to improve AWEF2 of certain
refrigeration system representative units.
---------------------------------------------------------------------------
6. Ambient subcooling,
7. Higher efficiency fan motors,
8. Higher efficiency compressors,
9. Variable-speed compressors,
10. Liquid suction heat exchanger,
11. Adaptive defrost,
12. Hot gas defrost,
13. Floating head pressure,
14. Variable-speed condenser fan control,
15. Economizer cooling,
16. Crankcase heater controls, and
17. Improved thermal insulation for single-packaged dedicated
systems.
88 FR 60746, 60764-60765.
Regarding the technology options analyzed in the September 2023
NOPR, the CA IOUs recommended that DOE consider additional design
options in its analysis that could justify even more cost-effective
savings for TSL 2, specifically evaporator fin density, two-speed
condenser fan modulation, more-efficient single-speed compressors,
electronic expansion valves, and efficiency improvements to condensate
pan heating. (CA IOUs, No. 76 at p. 1) Similarly, ASAP et al.
recommended that DOE consider electronic expansion valves (``EEVs'') as
a design option for outdoor refrigeration systems. (ASAP et al., No. 77
at pp. 2-3)
DOE notes that evaporator fin density and more-efficient single-
speed compressors were considered as technology options in the
September 2023 NOPR as a part of improved evaporator coils and higher
efficiency compressors, respectively. See sections 3.3.7.2 and 3.3.8.3
of chapter 3 of the September 2023 NOPR TSD. In response to these
recommendations, DOE considered two-speed condenser fan controls, EEVs,
and condensate pan heating controls as technology options for this
final rule analysis. In response to comments submitted on the September
2023 NOPR, DOE also evaluated more efficient single-speed compressors
in the March 2024 NODA. 89 FR 18555, 18560-18561. A more detailed
discussion of additional comments submitted in response to the
technology and design options analyzed in the September 2023 NOPR and
March 2024 NODA is included in section IV.B.1.c and the Design Options
subsection of sections IV.C.1.e and IV.C.1.f of this document.
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:
[[Page 104652]]
(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 results 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 sum, 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 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 and September 2023 NOPR, 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. DOE initially established the current approach
in its April 15, 2011, final rule in which DOE found that a component-
based approach would address the unique challenges posed in regulating
the energy efficiency performance of walk-in envelopes. 76 FR 21580,
21582. As noted in that rule, these challenges include the fact that
walk-in units are frequently assembled using components made by
multiple manufacturers, and walk-in installers may not be equipped to
test all the components that comprise a walk-in. The screened-out
options included the following:
Energy storage systems,
Refrigeration system override,
Automatic evaporator fan shut-off,
Non-penetrative internal racks and shelving,
Humidity sensors, and
Heat reclaim valves.
88 FR 60746, 60765.
Furthermore, in this final rule, DOE is screening out fiber optic
natural lighting because it would not affect rated energy consumption
of the walk-in components as measured by the DOE test procedure.
DOE did not receive any comments in response to the September 2023
NOPR screening analysis regarding technologies applicable to fully
assembled walk-ins. As such, in this final rule, DOE has screened out
all technology options for fully assembled walk-ins for the same
rationale as provided in the September 2023 NOPR. For details of this
screening analysis, see section 4.2.1 of chapter 4 of the final rule
TSD.
b. Doors and Panels
In the September 2023 NOPR, 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'') for doors, and any increase in overall
thermal improvement of a panel would not be captured by the test
procedure that measures R-value of insulation only 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.
88 FR 60746, 60765-60766.
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. 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.
Id.
Additionally, DOE tentatively 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 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 thermal performance
of the panel, including structural materials, is not captured by the
current test procedure. Therefore, such technologies were screened out.
Id.
Additionally, in the September 2023 NOPR, DOE screened out the
technology option to utilize insulation from the box/cooler wall to
minimize door anti-sweat heat power. 88 FR 60746, 60766. As discussed
in the September 2023 NOPR, DOE recognizes that an ideally designed
walk-in box ensures that panel design could reduce door sweating;
however, 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. Id.
Furthermore, in the September 2023 NOPR, 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.
[[Page 104653]]
Id.
DOE screened out panel and door insulation thicker than 6 inches
because DOE received feedback during manufacturer interviews that it is
not practicable to manufacture and install. DOE tentatively concluded
that insulation thicker than 6 inches would be heavy, unwieldy, and
take up space that the consumer would otherwise use. Additionally,
panels and non-display doors greater than 6 inches that use foam-in-
place insulation would take an excessive amount of time to cure,
impacting the practicability to manufacture, install, and service. Id.
In response to the September 2023 NOPR, Senneca and Frank Door
commented that aerogels and vacuum-insulated panels are not usable as
framing materials and cannot support the weight of the product; nor can
they hold fasteners such as screws and bolts. Senneca and Frank Door
commented that DOE's conclusion that the proposed standards are
technologically feasible based on a manufacturer's ability to use
aerogels and vacuum-insulated panels should be withdrawn. Senneca and
Frank Door stated that two-part polyurethane foam is essential to the
ability of a walk-in door to function properly because it is an
insulator and the method manufacturers use to keep the framing
materials and metal skins adhered to one another. Senneca and Frank
Door commented that incorporating aerogels or vacuum insulation would
lessen the utility and performance of WICF doors. Senneca and Frank
Door also stated that aerogels cannot be exposed to moisture, which is
present in all WICFs. Senneca and Frank Door stated that neither
aerogels nor vacuum insulation are commercially available for use by
WICF door manufacturers. (Senneca and Frank Door, No. 78 at pp. 3-5)
Furthermore, Senneca and Frank Door commented that DOE's estimated
costs of incorporating aerogels and vacuum insulation into WICF doors
are severely underestimated. (Senneca and Frank Door, No. 78 at p. 10)
DOE did not consider aerogels and vacuum-insulated panels as design
options in the September 2023 NOPR to improve thermal insulation of
framing materials of doors and/or panels. In section 3.3.5.1 of the
September 2023 NOPR TSD, DOE discusses potential thermal improvements
through the use of insulation thickness and materials relevant to non-
display doors and panels. In that section, DOE describes the primary
method through which to improve insulating capacity--i.e., by
increasing insulation thickness using existing foam materials. DOE also
stated that other options to improve the insulating capacity of the
envelope could include the use of insulating materials that have higher
thermal resistance per inch of thickness than materials currently used,
such as aerogels and vacuum-insulated panels. While these were
mentioned as potential technology options, DOE did not evaluate the use
of aerogels or vacuum-insulated panels in the September 2023 NOPR
analysis as alternative insulating materials in non-display doors and
panels. Similarly, in this final rule analysis, DOE did not consider
the use of aerogels or vacuum-insulated panels.
As discussed in the September 2023 NOPR, 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 walk-in users; (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. It can also be affected by the thermal resistance of the
door frame and edge materials. To ensure the temperature of the door
surface stays above the dewpoint 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 United States without having a potential
negative impact on the safety and functionality of the walk-in.
Therefore, DOE screened out the elimination of anti-sweat heater
systems in the September 2023 NOPR on the basis of safety of
technology. 88 FR 60746, 60766. However, DOE screened in reduced anti-
sweat heat. Id. at 88 FR 60767. DOE evaluated the energy savings and
cost associated with reducing rated anti-sweat heater power for medium-
temperature and low-temperature doors based on a combination of
certified values in DOE's Compliance Certification (``CCMS'') database,
rated anti-sweat heater power per linear foot of wire based on product
literature, and information received during confidential interviews
with manufacturers. Id. at 88 FR 60770.
In response to the September 2023 NOPR, Senneca and Frank Door
commented that reducing the amount of anti-sweat heat would lessen the
utility, performance, and safety of walk-in doors such that doors could
freeze shut and puddles or ice patches could form on the floor. Senneca
and Frank Door commented that reducing or eliminating anti-sweat heat
is not sufficient to meet the proposed standard. (Senneca and Frank
Door, No. 78 at pp. 4-5) NAFEM commented that the prior WICF rulemaking
resulted in safety concerns because by reducing the door perimeter
heater's wattage, passage doors are more likely to freeze closed and
temporarily trap workers. NAFEM commented that WICF manufacturers have
reported an increase in consultants requesting corrective action
concepts and strategies to allow trapped workers to open frozen doors
through secondary, fail-safe methods other than the emergency release
handles or push buttons used on most walk-in doors. (NAFEM, No. 67 at
p. 3)
DOE also received comments in response to the September 2023 NOPR
from RSG and Kolpak supporting the levels of reduced anti-sweat heat
that DOE analyzed. (Kolpak, No. 66, Attachment 1 at p. 1; RSG, No. 69
at p. 1) Kolpak agreed with DOE's proposal to reduce anti-sweat heater
wire power and commented that the anti-sweat heater wires on its non-
display doors have already been reduced to 1 W/ft for medium-
temperature and 5 W/ft for low-temperature. Additionally, Kolpak
commented that the anti-sweat heater wire power on its non-display
doors use bimetallic thermostat controls that turn the heater wire off
once it has reached a temperature required to remove condensation.
(Kolpak, No. 66, Attachment 1 at p. 1) RSG commented that it has
already reduced heater wire power to the level proposed in the
September 2023 NOPR; therefore, the reduced heater wire power values
proposed in the September 2023 NOPR should be acceptable for most
applications. (RSG, No. 69 at p. 1)
In response to the March 2024 NODA, DOE received additional
comments regarding the screening of reduced anti-sweat heat.\31\
---------------------------------------------------------------------------
\31\ DOE did not update its analysis regarding anti-sweat heat
around the perimeter of the door leaf in the March 2024 NODA. DOE
nevertheless considered these comments as part of developing the
final rule.
---------------------------------------------------------------------------
Although RSG previously commented in support of the levels of anti-
sweat heat analyzed in the September 2023 NOPR, in response to the
March 2024 NODA, RSG commented that to meet the standards in the March
2024 NODA, RSG's door frame anti-sweat heaters would need to be reduced
to half the current wattage and this reduction could result in
formation of condensate
[[Page 104654]]
water, which is a safety slip issue. RSG stated that the heater wire
wattages were reduced about 50 percent to meet the 2017 door MDEC
standards. RSG commented that a balance should exist between energy
consumption and safety when considering new energy requirements. RSG
commented that technology options for walk-in door construction have
not significantly changed since 2017 and are limited largely to
existing components and insulation science. RSG commented that manual
non-display doors may be a category best suited for no new changes,
similar to panels. (RSG, No. 89 at p. 1) Despite the fact that RSG
previously commented in support of the reduced anti-sweat heat levels
that DOE analyzed, DOE is viewing RSG's latest comment in response to
the March 2024 NODA as its current position on the screening of this
technology option.
Imperial Brown commented that door perimeter heater cables are
critical components of walk-in freezer doors that eliminate
condensation or frost formation at the door perimeter. Imperial Brown
commented that in a worst-case scenario, a door could become frozen
shut, leading to entrapment and risk of death. Imperial Brown stated
that it reduced the power consumption of its perimeter heater cables in
response to the first WICF standards rulemaking and even though
Imperial Brown has not witnessed freezing issues since, condensation
issues are not uncommon, especially in high-humidity geographical
areas. Imperial Brown commented it does not believe that it can further
reduce the power rating of its perimeter heater cables without risking
doors freezing shut and endangering lives. Imperial Brown commented it
targets heater cables rated at 4.5 to 5.5 W/ft of door perimeter for
PVC frame doors and non-PVC frame doors, respectively. Imperial Brown
stated that because heater cables are only available in limited ohms/ft
ratings, the real heat cable W/ft will differ from the target number
and that deviation can be as much as 25 percent. Imperial
Brown provided a description of how it wires its doors. (Imperial
Brown, No. 84 Attachment 1 at p. 2) Imperial Brown commented it does
not know of ways to reduce energy consumption of its--or competitors'--
freezer door perimeter heater cables without producing unacceptable
products. Imperial Brown commented that condensation on door gaskets
may lead to mold growth (health hazard) and frost formation around the
door (life hazard). (Imperial Brown, No. 84 at p. 3) Imperial Brown
also provided DEC numbers for several of its models. (Imperial Brown,
No. 84, Attachment 2)
Regarding NAFEM's comments that the prior rulemaking (i.e., June
2014 Final Rule) resulted in safety concerns, DOE notes the performance
standards finalized in the prior rulemaking and in this rulemaking are
not prescriptive, i.e., they don't prescribe use of specific design
options or technologies to reduce energy consumption. Therefore,
manufacturers may comply with MDEC standards using any technologies
they see fit, and the standard levels themselves set no explicit
requirements on anti-sweat heater wattage levels. In the June 2014
Final Rule, DOE included anti-sweat heat for both cooler and freezer
non-display doors in its analysis but did not analyze reduced anti-
sweat heat as a design option; therefore, the standard levels adopted
for non-display doors in the June 2014 Final Rule were representative
of baseline anti-sweat heat wattage used in non-display doors at the
time. 79 FR 32050. Furthermore, there are several factors besides anti-
sweat heat wattage that could affect the chances that a low-temperature
non-display door would freeze shut, including but not limited to the
humidity of the environment, the thermal characteristics of the door,
how well the walk-in door is sealed during construction and
installation, and how often the door is opened. RSG and Imperial Brown
commented that in response to the MDEC standards that went into effect
in 2017 they both reduced the anti-sweat heat on their non-display
doors to a level that they indicate is the minimum level required to
restrict the formation and freezing of condensation to prevent safety
issues under typical conditions in the field. Imperial Brown commented
that it has not witnessed doors freezing shut with the current anti-
sweat heat levels that it uses. Stakeholder feedback primarily
indicates that further reducing anti-sweat heat beyond what is used to
meet the existing standards increases the risk of condensation forming
on non-display doors. Based on public comments and data included in
those public comments and a review of certified data, DOE has concluded
that manufacturers offer models for sale that use anti-sweat heat
wattage around the perimeter of the door leaf at levels equal to or
lower than those analyzed for the reduced anti-sweat heat design option
in the September 2023 NOPR. For example, DOE identified 20
manufacturers of medium-temperature non-display doors that use anti-
sweat heater wire wattage around the perimeter of the door leaf that is
less than or equal to what DOE analyzed for the reduced anti-sweat heat
design option. Similarly, DOE has identified low-temperature non-
display doors with anti-sweat heat levels that are at or below the
reduced ASH level that DOE analyzed in this rulemaking. The presence of
these doors on the market with lower ASH wattage than what DOE analyzed
indicates that manufacturers are safely applying these designs in the
field today without leading to an increase in safety incidents or
increasing risks. As such, DOE is not screening out reduced anti-sweat
heat as a technology option for non-display doors in this final rule.
However, as discussed in section V.C.1.b of this document, DOE does not
expect that the standard level adopted in this final rule for non-
display doors would necessitate the use of reduced anti-sweat heat.
Rather, DOE expects that manufacturers would incorporate anti-sweat
heat controls, which only limit or turn off anti-sweat heat when anti-
sweat heat is not necessary based on the ambient conditions, to meet
the standard level adopted in this final rule for non-display doors.
DOE does not expect to see an increase in condensation when the anti-
sweat heat is turned off when ambient conditions do not result in a
need to reduce the humidity.
The September 2023 NOPR and March 2024 NODA also evaluated reduced
thermal conduction load through improved framing systems and materials.
In response, Kolpak commented that it supports requiring more-efficient
frames. (Kolpak, No. 66, Attachment 1 at p. 3)
Senneca and Frank Door commented that DOE's determination that the
proposed standards are technologically feasible for all non-display
doors does not consider doors that are manufactured separately from the
walk-in box in which they are installed. Senneca and Frank Door stated
that these types of doors must be bolted onto the walk-in box in the
field using various fasteners and the commenters are unaware of any
framing materials for these types of doors with a low enough U-factor
that could meet the proposed standard levels. (Senneca and Frank Door,
No. 78 at p. 5) Additionally, Senneca and Frank Door commented that
common framing materials include aluminum, plastics, and wood and that
the commenters are unaware of any framing materials with a low enough
U-factor to comply with the proposed standards. (Senneca and Frank
Door, No. 78 at pp. 3-4) Imperial Brown stated that non-PVC frame doors
are a necessity for applications that have higher structural
requirements (e.g.,
[[Page 104655]]
bigger doors with heavier pass-thru traffic or doors installed in areas
with seismic or high wind exposures). (Imperial Brown, No. 84 at p. 2)
Despite mixed support and opposition of thermal improvements to
framing systems in doors, DOE is aware through public comments and
review of the market that better thermally insulating (and therefore
less energy consumptive) frame systems exist on the market. Some
stakeholder comments suggest that such thermally-improved frame designs
may have reduced structural rigidity compared to traditional (e.g.,
wood) framing systems. Nonetheless, DOE expects that non-display doors
with thermally-improved frames can maintain a certain level of
resiliency to typical structural loads (e.g., accommodating typical
walk-in traffic) because they are available for sale in the walk-in
market. As such, DOE is not screening out the improved frame design
option for non-display doors in this final rule. Nevertheless, due to
the variability in structural loads that walk-in doors may be subject
to, DOE recognizes that there is not full certainty that the best
thermally-insulating frame systems available on the market would be
sufficiently robust in certain circumstances. If there are cases where
thermally-improved frame designs are not sufficiently robust in
structure, then this could result in the need for earlier replacement
of certain non-display doors. DOE considers and discusses the impact to
consumer economics as a result of a potentially reduced lifetime for
non-display doors in section IV.F.7 of this document.
In this final rule, DOE is screening out the same technologies for
doors and panels that it screened out in the September 2023 NOPR. DOE
further discusses considerations for adopting a standard level that
could require reduced anti-sweat heat and improved frame design options
in section V.C.1.a of this document.
c. Refrigeration Systems
In the September 2023 NOPR, 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 the DOE test procedures outlined in the
newly adopted appendix C1. 88 FR 60746, 60766. DOE did not receive any
comments in response to the September 2023 NOPR regarding its tentative
conclusion. DOE maintains this conclusion for the final rule.
In the September 2023 NOPR, DOE responded to CA IOU comments
requesting that DOE include EEVs as a standalone technology option. 88
FR 66710, 66713. The CA IOUs commented that an EEV would reduce cycling
losses and therefore save energy when compared to a thermostatic
expansion valve (``TXV''). Id. Because the tests conducted as part of
the test procedure in appendix C1 are steady-state tests, DOE
tentatively concluded that a test performed with a TXV would result in
the same measured efficiency as a test of the same unit performed with
an EEV. Id. In response, the CA IOUs commented they disagree with DOE's
statement that DOE cannot include EEVs as a technology option because
the test procedure measures refrigeration performance at steady-state
conditions and would therefore not capture the energy savings of EEVs
because, according to a study conducted by Hill Phoenix, an 8.7-percent
reduction in kWh was found when using an EEV rather than a mechanical
TXV at steady-state temperature. (CA IOUs, No. 76 at pp. 5-6)
DOE was not able to determine if the Hill Phoenix study was
conducted at steady-state conditions from a chart shown by the CA IOUs
with their comment. DOE notes that a refrigeration system with steady
ambient air temperature and steady refrigerated storage space
temperature may not qualify as a steady-state test. A steady-state test
must include no compressor cycling, as the DOE test procedure
specifies. See 10 CFR part 431, subpart R, appendix C1 and section
C3.6.1 of AHRI 1250-2020. DOE was unable to find the complete study
conducted by Hill Phoenix that the CA IOUs reference, so DOE is unable
to confirm that the test was conducted at test conditions
representative of the DOE test procedure for walk-in refrigeration
equipment. DOE likewise cannot confirm that the savings seen in Hill
Phoenix's study would be measurable by the DOE test procedure in
appendix C1. Therefore, DOE determined it was appropriate to still
screen out EEVs as a standalone design option given that no evidence
has been presented to indicate that adding EEVs to walk-in
refrigeration equipment would result in a measurable increase in
efficiency when tested according to the DOE test procedure. EEVs within
the context of the floating head pressure design option are discussed
in more detail in section IV.C.1.e of this document.
In this final rule analysis, DOE has determined that the following
technologies will not have an effect on walk-in refrigeration system
efficiency as measured by appendix C1, and therefore is screening them
out on that basis:
Adaptive defrost,
Hot gas defrost,
Oil management systems,
Economizer cooling, and
Electronic expansion valves.
In the September 2023 NOPR, DOE also screened out three-phase
motors as a technology option. 88 FR 60746, 60766. The 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 technology
option because it could result in the unavailability of this equipment
with certain performance features for certain consumers. Id.
Furthermore, in the September 2023 NOPR, DOE screened out improved
evaporator and condenser coils for high-temperature refrigeration
systems on the grounds of having adverse impacts on the functionality
of the equipment in response to stakeholder feedback regarding the
space constraints imposed when installing high-temperature
refrigeration systems. 88 FR 60746, 60766.
DOE did not receive comments in response to its tentative
conclusions regarding the screening of improved evaporator and
condenser coils for high-temperature refrigeration systems and three-
phase motors. DOE maintains its conclusions from the September 2023
NOPR and is screening out three-phase motors and improved evaporator
and condenser coils for high-temperature refrigeration systems in this
final rule.
2. Remaining Technologies
a. Doors and Panels
Through a review of each technology, DOE 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 this analysis. In 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 non-display doors, and
Increased insulation thicknesses up to 6 inches for non-
display doors and panels.
DOE determined that these technology options are technologically
feasible because they are being used or have previously been used in
[[Page 104656]]
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; do
not result in adverse impacts on consumer utility, product
availability, health, or safety; and do not utilize unique-pathway
proprietary technologies). For additional details, see chapter 4 of the
final rule TSD.
b. Refrigeration Systems
Through a review of each technology, DOE 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 this analysis. In summary, DOE did not screen out the
following technology options for walk-in refrigeration systems:
Improved condenser and evaporator fan blades,
Improved evaporator and condenser coils for medium- and low-
temperature refrigeration systems,
Off-cycle and on-cycle evaporator fan control,
Hydrocarbon refrigerants,
Ambient subcooling,
Higher-efficiency condenser and evaporator fan motors
(excluding three-phase motors),
Higher-efficiency compressors,
Variable-speed compressors,
Liquid suction heat exchanger,
Head pressure control,
Condenser fan speed control (two-speed and variable-speed),
Crankcase heater controls,
Improved thermal insulation for single-packaged dedicated
systems, and
Condensate pan heating controls.
DOE 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 of the remaining technology options meet the other screening
criteria (i.e., practicable to manufacture, install, and service; do
not result in adverse impacts on consumer utility, product
availability, health, or safety; and do not utilize unique-pathway
proprietary technologies). For additional details, see chapter 4 of the
final rule TSD.
In response to the September 2023 NOPR, NAFEM commented that the
remaining design options for refrigeration systems are not new
technologies and most were considered in the last WICF rulemaking.
NAFEM stated that, therefore, these technologies do not serve as
actionable opportunities for manufacturers to increase energy
efficiency. (NAFEM, No. 67 at p. 3) In response, DOE notes that the
technology options that DOE considers in the screening analysis and
then the engineering analysis do not need to be technologies that were
not considered in previous rulemakings. DOE has determined that the
technology options identified as remaining technologies would increase
the efficiency of walk-ins as measured by the test procedure and pass
all screening criteria. The technologies could be in use already or
have been used. This is considered when determining which design
options are representative of the baseline units in the engineering
analysis.
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 (i.e., doors, panels, 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 equipment cost at each efficiency level (i.e., the
``cost analysis''). In determining the performance of higher-efficiency
equipment, DOE considers technologies and design option combinations
not eliminated by the screening analysis. For each equipment class, DOE
estimates the baseline cost, as well as the incremental cost for the
equipment 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 equipment (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 equipment on the market) may be
extended using the design-option approach to interpolate to define
``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).
For this final rule analysis, DOE used a design-option approach for
doors, panels, dedicated condensing units, single-packaged dedicated
systems, and high-temperature unit coolers. DOE used an efficiency-
level approach for medium- and low-temperature unit coolers. These
approaches are discussed in the following sections.
a. General Feedback
In response to the March 2024 NODA analysis, DOE received several
comments of general feedback pertaining to the efficiency analysis.
AHRI requested a release of all documents and data, while
maintaining individual manufacturer confidentiality, used to support
the proposed amendments in the September 2023 NOPR and March 2024 NODA
specifically related to unit coolers and refrigeration systems. AHRI
stated its concern that DOE is not using physical units running in
different conditions to complete off-cycle tests to determine the
wattage, alternate refrigerants, and single-speed compressor changes.
AHRI recommended DOE test physical products using a data evaluation
process such as an alternative efficiency determination method
(``AEDM'') with validation that reflects the changes DOE proposed in
the September 2023 NOPR and updated in the March 2024 NODA for all
dedicated condensing units and unit coolers. AHRI stated that its
members do not see the same results in real life that DOE has detailed
in the September 2023 NOPR and March 2024 NODA. (AHRI, No. 86 at p. 4)
DOE collects data to inform the rulemaking process in many
different ways. Some of this data is pulled from public sources such as
product catalogs or public stakeholder comments. Other data sources are
not public, such as information received through the public request for
comments identified by stakeholders as confidential business
information or information shared with DOE during confidential
interviews. In an effort to be as open as possible and
[[Page 104657]]
solicit the best feedback possible, DOE publishes summary data and
analyses in the TSDs that accompany rulemaking documents and, in the
case of walk-ins, the engineering spreadsheets used in the rulemaking.
Many of the assumptions or values that feed into these analyses are a
result of aggregated and anonymized confidential feedback. DOE is
unable to share additional data that informs the walk-ins rulemaking
given its legal obligations to maintain confidentiality of such data,
even if sources were anonymized. DOE received comments that requested
the release of specific data, which are discussed in the following
sections.
To understand the efficiencies of units currently available on the
market, DOE conducted a round of refrigeration system testing.
Additional analysis and teardowns of these units also informed the off-
cycle power and design option performance considered in this
rulemaking. It would be overly burdensome for DOE to conduct a physical
test for every representative unit with every combination of design
options analyzed in this final rule analysis. Therefore, this round of
testing was used to validate the refrigeration systems engineering
analysis at certain efficiency levels and representative capacities, as
manufacturer tests are used to validate AEDMs. Based on these
validations, DOE has determined that the refrigeration system analyses
conducted to support this final rule are representative of the
performance of walk-in refrigeration systems. Specific instances of
validating analysis through physical testing are described in the
following sections. DOE also notes that the refrigeration engineering
spreadsheet used for this final rule, which details the analysis for
medium- and low-temperature dedicated condensing systems, includes all
assumptions and values that feed into the analysis and is available on
the docket. Additionally, the engineering analysis approach is further
described in more detail in chapter 5 of the final rule TSD.
Lennox stated that DOE must continue to review the baseline design
assumptions and the methods and associated costs of attaining increased
efficiency levels. Lennox stated that DOE should clearly demonstrate
that it has correlated the baseline designs and methods to improve
efficiency to actual products and test results. (Lennox, No. 87 at p.
3)
As stated previously in this section, DOE has validated various
efficiency levels for different representative capacities using
physical test results. Additionally, DOE has validated the costs
analyses in this final rulemaking using physical teardowns. As such,
DOE has determined that the engineering analyses for walk-in
refrigeration systems in this final rule are representative of walk-in
refrigeration systems and that the cost-efficiency correlations
developed are also representative.
b. 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 September 2023
NOPR based on the presence or absence of a motor. DOE did not evaluate
higher efficiency levels for motorized display doors in the September
2023 NOPR analysis, and therefore it did not further consider the
representative units for those motorized display doors. DOE analyzed
three representative door sizes for manually opening display doors. The
representative units were based on the number of door openings within a
common frame; DOE has identified that as many as five door openings can
be contained within a single frame. Additionally, DOE based its
representative door sizes on typical height and width of doors found in
equipment product literature. 88 FR 60746, 60768.
In response to the September 2023 NOPR, Anthony commented that
although DOE is not amending the energy conservation standards for
walk-in display doors, the definition of ``door'' changed in the test
procedure rulemaking, which has the effect of decreasing the energy use
allowed for lighting and anti-sweat heaters for display doors, except
for the case when a door has a single opening. Anthony stated that the
effect violates the prohibition in EPCA of adopting energy standards
that impair the functionality of a pre-existing product. (Anthony, No.
71 at p. 1) Anthony stated that manufacturers will switch to single-
opening doors per frame, which complicates wiring and installation,
increases the cost, and does not serve customer preferences. (Anthony,
No. 71 at p. 2)
Anthony commented that with DOE's recently adopted single-door
interpretation, doors with multiple openings are penalized compared to
multiple individual doors installed in the same-size opening. Anthony
stated that this penalty is not justified because the two installations
would effectively be the same, and Anthony suggested that treating
doors with multiple openings as multiple individual doors would be more
consistent with field installation practices. Anthony provided a
comparison of how the energy conservation standard for display doors
changes based on whether the single-opening interpretation or multi-
opening interpretation is used. The comparison shows that the maximum
daily energy consumption standard increases for the multi-door
interpretation, which is based on the surface of area of a single door
and multiplying it by the number of doors in the system. (Anthony, No.
71 at pp. 3-4)
Anthony stated that the standard for display doors has an offset
(0.41 kWh/day for medium-temperature display doors and 0.29 kWh/day for
low-temperature display doors) that's intended to account for effects
that do not scale for surface area, such as heat transfer through
framing materials, anti-sweat heater power, and lighting power. Anthony
commented that with the single-door interpretation, there is a lower
allowable maximum daily energy consumption, because that offset term is
applied once, and therefore the maximum daily energy consumption would
be much greater for multiple single-door systems compared to one
multiple-opening door. Anthony stated that this incentivizes the usage
of multiple single doors. (Anthony, No. 71 at pp. 4-8)
Anthony commented that the multi-door interpretation results in the
same maximum daily energy consumption as multiple single doors and a
single multiple-opening door and is, therefore, the logical
interpretation. (Anthony, No. 71 at p. 8)
The amended definition of ``door'' adopted in the May 2023 TP Final
Rule was not a change in the test procedure, but rather an intent to
better clarify DOE's existing scope, test procedure provisions, and
application of the standards to walk-in doors. 88 FR 28780, 28788.
``Door'' was previously defined at 10 CFR 431.302 as ``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 door panel, glass, framing
materials, door plug, mullion, and any other elements that form the
door or part of its connection to the wall.'' As amended, door is now
defined at 10 CFR 431.302 as ``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
[[Page 104658]]
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.'' The frame and all elements that form the door
or part of its connection to the wall has always been a part of the
definition.
Given that DOE clarified in the May 2023 TP Final Rule that doors
with multiple leaves within a single frame would be considered a door
under the existing test procedure and standards, DOE chose to analyze
representative units that reflect the display doors available on the
market, which consist of doors with one through five leaves within a
single frame. DOE did not receive any other comments regarding the
representative units of display doors analyzed in the September 2023
NOPR. Therefore, in this final rule, DOE analyzed the same
representative units for manually opening display doors as were
analyzed in the September 2023 NOPR. Table IV.6 lists the display door
classes and sizes that DOE analyzed in its engineering analysis for
this final rule, where the dimensions listed are consistent with the
surface area that is used to determine the maximum daily energy
consumption.
[GRAPHIC] [TIFF OMITTED] TR23DE24.022
Baseline Efficiency, Design Options, and Higher Efficiency Levels
To determine the baseline efficiency of manually opening display
doors in the September 2023 NOPR, 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 September 2023 NOPR. 88 FR
60746, 60768.
In the September 2023 NOPR, 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 (EL 1) and DR3 (EL 2). Id. DOE did not evaluate
any changes to the amount of lighting or anti-sweat heat across
efficiency levels and included lighting controls and anti-sweat heat
controls in all efficiency levels (from baseline to max-tech).
[GRAPHIC] [TIFF OMITTED] TR23DE24.023
In response to the September 2023 NOPR, Anthony commented that
based on its own market research of manufacturer websites, the average
wattage for lighting of display doors is nearly double what DOE asserts
is reflective of the industry. Anthony further stated that the display
doors that employ the low-wattage LED lighting fixtures are low-end
models, which make up approximately 17 percent of the display door
market, and therefore are not representative of the typical display
door. Anthony commented that, based on its experience and research,
approximately 20 percent of customers that purchase these low-end
models replace the lighting with higher-performing lighting that is
typical for most higher-end display doors. Anthony suggested that
aftermarket replacement
[[Page 104659]]
of lighting may become more common practice given the inadequacy of the
level of lighting DOE proposes to require. (Anthony, No. 71 at pp. 2-3)
Anthony stated that if DOE does not correct the errors in its
analysis, it is likely that purchasers of display doors will buy
aftermarket higher-wattage lighting and higher-voltage anti-sweat
heaters designed to preserve and enhance the fundamental display
functionality of the doors. (Anthony, No. 71 at p. 2)
DOE notes that its efficiency analysis is intended to be reflective
and representative of the display door market. In order to evaluate the
potential increase in cost and any downstream quantitative impact to
consumers, DOE must assign a baseline design in order to evaluate the
potential for higher-efficiency designs. DOE developed its baseline
representative units from the existing market. DOE analyzes a pathway
to higher efficiency in its engineering analysis, but DOE does not
require that this exact pathway be taken. For display doors, DOE only
requires that the MDEC performance standard in terms of kWh/day be met.
While manufacturers are required to meet the prescriptive requirements
applicable to display doors (see 10 CFR 431.302(a) and (b)),
manufacturers are free to meet the MDEC standard using any design
options they deem necessary. The design options evaluated by DOE should
not be interpreted as prescriptive requirements, but rather possible
steps along a potential efficiency improvement path. In this final
rule, DOE is not adopting amended standards for display doors and is
therefore not requiring any level of lighting that is different from
what may already be required to meet the existing standards.
Additionally, DOE recognizes that if manufacturers require higher
lighting wattage for certain basic models of display doors, they may
need to implement more efficient designs (e.g., more thermally
efficient glass packs) in order to meet the existing standard, which
could limit the pathways to higher efficiency. See section V.C.1 for
further discussion of the viability of higher efficiency levels for
display doors and DOE's conclusions regarding not amending standards
for display doors.
Lastly, DOE defines a ``manufacturer of a walk-in cooler or walk-in
freezer'' as any person who (1) manufactures a component of a walk-in
cooler or walk-in freezer that affects energy consumption, including
but not limited to refrigeration, doors, lights, windows, or walls; or
(2) manufactures or assembles the complete walk-in cooler or walk-in
freezer. 10 CFR 431.302. In a final rule pertaining to compliance,
certification, and enforcement of walk-ins (``March 2011 Final Rule''),
DOE adopted this definition of manufacturer of a walk-in cooler or
walk-in freezer and discussed the responsibility of certification and
compliance. 76 FR 12422, 12442-12444 (March 7, 2011). DOE stated in the
March 2011 Final Rule that component manufacturers are responsible for
certifying compliance of the components they manufacture for walk-in
applications and ensure compliance with the applicable standards for
those components. 76 FR 12422, 12444. DOE noted in that final rule that
the adopted definition of ``manufacturer'' extends the compliance
responsibility to both the component manufacturer and the assembler,
even though the component manufacturer is responsible for
certification.
Assemblers of the complete walk-in system are required to use only
components that are certified to meet the Federal energy conservation
standards in the assembled walk-in. Id. If an assembler was to purchase
a compliant component and then alter the component in a manner that
affects the energy efficiency or consumption of the component, the
assembler would be considered the manufacturer of the component and
would be responsible for testing, compliance, and certification of the
altered component. Failure to comply with these requirements would
subject the assembler to civil penalties pursuant to 10 CFR
429.102(a)(1). If the alteration renders the component noncompliant
with the applicable energy conservation standard, use of the component
in a complete walk-in cooler or walk-in freezer would render the
assembled unit noncompliant and subject the assembler to civil
penalties pursuant to 10 CFR 429.102(a)(6), both for the noncompliant
component and the noncompliant complete walk-in.
For example, if an assembler purchases a compliant display door and
replaces the display door's lighting with aftermarket lighting, the
assembler would be considered the manufacturer of the altered display
door and be responsible for testing and certifying the door as
compliant with applicable DOE energy conservation standards. Failure to
do so would subject the assembler to civil penalties. If the after-
market lighting rendered the display door noncompliant with the
applicable DOE energy conservation standard, use of the altered door in
a complete walk-in would subject the assembler to civil penalties, both
for the manufacture of the noncompliant display door and the
manufacture of the noncompliant complete walk-in cooler or walk-in
freezer. See generally 10 CFR 429.102 and 429.120.
Anthony commented that DOE's use of a single static value for anti-
sweat heater wattage does not take into account the need for heat
scaling with walk-in space or with the number of openings in a door
assembly. Anthony stated that as a result, manufacturers will be
required to use anti-sweat heaters that are inadequate to eliminate
condensation, which could lead to aftermarket installation of higher-
voltage anti-sweat heaters or more costly products. (Anthony, No. 71 at
p. 3)
As mentioned previously, DOE only requires that the MDEC
performance standard in terms of kWh/day be met. While manufacturers
are required to meet the prescriptive requirements applicable to
display doors (see 10 CFR 431.302(a) and (b)), manufacturers are free
to meet the MDEC standard using any design options they choose. In this
final rule, DOE is not adopting amended standards for display doors,
and it is therefore not requiring any level of anti-sweat that is
different from what is already required by the existing standards.
Regarding aftermarket installation of higher-voltage anti-sweat
heaters, if assemblers were to install a display door with aftermarket
anti-sweat heat replacing the anti-sweat heater of the originally
purchased display door, they would be at risk of installing a non-
compliant display door.
For this final rule, DOE maintained the analysis conducted for the
September 2023 NOPR for display doors.
c. Non-Display Doors
Representative Units and Baseline Efficiency
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 September 2023 NOPR. In
the June 2022 Preliminary Analysis, DOE analyzed three representative
sizes for each class of non-display doors. 88 FR 60746, 60769. DOE did
not receive any comments regarding the representative units analyzed
for the September 2023 NOPR. In this final rule, DOE analyzed the same
non-display door representative sizes that it evaluated in the
September 2023 NOPR. Table IV.8 lists the non-display door classes and
sizes that DOE analyzed in the engineering analysis for this final
rule.
To determine non-display door baseline efficiency for each
[[Page 104660]]
representative unit, DOE relied on the current energy conservation
standards. In the September 2023 NOPR, DOE determined for its analysis
that baseline non-display doors had 3.5-inch-thick insulation for
coolers and 4-inch-thick insulation for freezers, wood framing
materials, a viewing window, and anti-sweat heat around the perimeter
of the door leaf without controls. DOE did not consider lighting or
other electrical components in its baseline representative units for
non-display doors. Id. As such, DOE only considered design options
relevant to the design of the baseline representative units, including
anti-sweat controls, reduced anti-sweat heat, improvements to the
framing systems to make the frame more thermally insulative, and
increased insulation thickness. Id. at 88 FR 60770.
As previously mentioned, DOE received comments in response to the
September 2023 NOPR that resulted in reconsideration of the equipment
classes that were proposed for non-display doors to account for other
electricity-consuming devices that DOE did not consider in its
representative units and baseline for analysis. In response to comments
received regarding the September 2023 NOPR analysis, DOE recognized
that it cannot include all other possible electrical components in its
baseline representative units and cannot analyze reduced energy
consumption for other electrical components because not all doors
contain these components. Therefore, in the March 2024 NODA, DOE
updated its analysis to present equipment classes with MDEC allowances
for non-display doors if manufacturers offer basic models with certain
electricity-consuming devices. 89 FR 18555, 18556-18559.
DOE considered the additional electrical component energy
consumption through the use of MDEC allowances. Therefore, DOE
maintained the same representative units with components and features
that are generally applicable for most doors and could be analyzed for
reduced energy consumption at the baseline. DOE did not receive any
comments regarding this update approach presented in the March 2024
NODA. For this final rule, DOE evaluated the same representative units
and considers the additional electrical components through the use of
the MDEC allowances. Table IV.8 lists the non-display door classes and
sizes that DOE analyzed baseline and higher efficiency levels for in
the engineering analysis for this final rule.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.024
Design Options and Higher Efficiency Levels
For the September 2023 NOPR analysis, DOE evaluated the design
options listed in Table IV.9 for non-display doors. The following
subsections discuss the comments received regarding these design
options and the implementation of these design options to achieve
higher efficiency levels.
[[Page 104661]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.025
In response to the September 2023 NOPR analysis, Senneca and Frank
Door commented that DOE's recommended methods for compliance with the
new standards do not account for how several of these methods are
currently used by manufacturers and how that limits a manufacturer's
ability to use those methods to generate the additional energy savings
required to meet the proposed standards. (Senneca and Frank Door, No.
78 at pp. 3-4)
DOE analyzes units and design options based on an evaluation of the
current market. DOE understands that some models on the market may
utilize the higher-efficiency design options analyzed in the
engineering analysis; however, many of the models using higher-
efficiency design options are also outperforming the current MDEC
standards (i.e., have rated DEC below the baseline). As discussed in
section V.C.1 of this document, DOE estimated that 35 percent of the
non-display door market can already meet the standards DOE is adopting
for non-display doors through the use of higher efficiency design
options such as those analyzed in this rulemaking. Further, DOE notes
that the standards finalized in this rulemaking are not prescriptive;
manufacturers may comply with them using any technologies they see fit.
As previously discussed in section IV.B.1.b of this document, DOE
screened out the same technology options in this final rule as it did
in the September 2023 NOPR. Therefore, for this final rule, DOE
analyzed the same design options for non-display doors as it did in the
September 2023 NOPR.
i. Reduced Anti-Sweat Heater Power
In the September 2023 NOPR, DOE considered reduced anti-sweat
heater power as a design option for all non-display doors. For medium-
temperature doors, DOE evaluated a reduction in anti-sweat heater power
to 2 W/ft based on an evaluation of certified data in DOE's private
CCMS database, which had approximately 93 percent of models reported a
rated anti-sweat heater power of less than or equal to 2 W/ft. For low-
temperature doors, DOE evaluated a reduction in anti-sweat heater power
to 5 W/ft 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. Table IV.10 shows the baseline and reduced anti-
sweat heater wire power evaluated in the September 2023 NOPR.
[[Page 104662]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.026
As discussed in section IV.B.1.b of this document, DOE received
multiple comments both in favor of screening out the reduced anti-sweat
heat design option and supporting the levels of reduced anti-sweat heat
that DOE analyzed. As discussed in that section, DOE ultimately
included reduced anti-sweat heat as a technology option for all non-
display doors in this final rule because manufacturers offer models for
sale with anti-sweat heat at or below the reduced anti-sweat heat
wattage values that DOE analyzed. Regarding the power in W/ft that DOE
analyzed for the reduced anti-sweat heat design option, Kolpak
supported the reduced anti-sweat heater wire power values that were
analyzed. (Kolpak, No. 66, Attachment 1 at p. 1) As such, DOE
maintained the values evaluated for reduced anti-sweat heater wire
power for the September 2023 NOPR in this final rule analysis.
ii. Improved Thermal Conduction Load Through Improved Frame Systems and
Increased Insulation Thickness
As discussed in the September 2023 NOPR TSD, DOE determined U-
factors for each representative door size by scaling the U-factors
determined from tested non-display doors based on theoretical U-
factors. DOE also assumed each non-display door had a window sized at 2
ft\2\. Wood frames are the least efficient framing material currently
found on the market and were selected as the baseline framing material.
Polyurethane door frames are more thermally insulative and were
selected as the improved framing material. See section 5.7.1.3 of the
September 2023 NOPR TSD.
Based on stakeholder feedback and detailed calculations provided by
Kolpak in response to the September 2023 NOPR, in the March 2024 NODA,
DOE reevaluated the analyzed U-factors for both medium-temperature and
low-temperature non-display doors. 89 FR 18555, 18559-18560. For
medium-temperature doors, DOE found that the thermal conduction load at
the proposed energy conservation standard level (EL 3) from the
September 2023 NOPR is representative of the achievable thermal
conduction load of non-display doors on the market. Therefore, in the
March 2024 NODA, DOE did not make any adjustment to the U-factors
evaluated for the medium-temperature non-display doors at EL 3. Id. For
low-temperature doors, DOE further analyzed available data for the
March 2024 NODA and tentatively determined that the thermal conduction
load by area in the proposed standard level from the September 2023
NOPR was lower than that calculated using the data DOE evaluated.
Therefore, DOE increased the U-factors at EL 3 (which corresponded to
the proposed standard level in the September 2023 NOPR) for each
representative unit of low-temperature non-display doors by 9 percent
for the March 2024 NODA. DOE tentatively determined that this increase
in U-factor would be more representative of the low-temperature non-
display doors currently on the market. 89 FR 18555, 18559-18560.
In response to the September 2023 NOPR, Senneca and Frank Door
commented that the design options analyzed that are technologically
feasible and not already utilized by manufacturers would not be
sufficient to meet the proposed energy consumption. For example,
Senneca and Frank Door stated that increasing thickness to 6 inches
would not result in a U-factor necessary to meet the proposed standard.
(Senneca and Frank Door, No. 78 at pp. 3-4) DOE's test data and
information provided by Kolpak demonstrate that there are doors
currently on the market that meet or exceed the thermal conduction load
that DOE analyzed at EL 3 (i.e., the proposed standard level from the
September 2023 NOPR) without increasing insulation thickness. See
chapter 5 of the final rule TSD for plots of DOE's test data compared
to the efficiency levels DOE analyzed in this final rule. Further, as
discussed in section V.C.1.b of this document, DOE does not expect that
the standard level adopted in this final rule for non-display doors
would necessitate the implementation of design options that would
decrease U-factor (e.g., improved frame or increased insulation
thickness), as the standard level adopted in this final rule includes
the baseline U-factor analyzed.
In the March 2024 NODA, DOE requested comment on the
representativeness of the adjustments made to the U-factors for the
low-temperature non-display doors. Id. Senneca stated that because
Kolpak manufactures and distributes complete walk-in coolers and
freezers, its data is not representative of the energy efficiency that
can be achieved by companies that manufacture and distribute walk-in
cooler and freezer
[[Page 104663]]
doors that are sold and installed separately. (Senneca, No. 92 at p. 3)
Senneca's comment suggests that non-display doors that are sold
separately from the walk-in in which they are installed may have
different energy consumption than doors sold with a complete walk-in.
However, DOE received additional data in response to the March 2024
NODA from another manufacturer, Imperial Brown, that manufactures walk-
in doors for ``new construction, retrofit and remodel applications''
and states its ``models are compatible with all manufacturers of cold
storage systems.'' \32\ (Imperial Brown, No. 84, Attachment 2) DOE
reviewed the data provided by Imperial Brown and found that the thermal
load characteristics of these models are well within the thermal load
that DOE determined to be required to meet the adopted standard for
this final rule. Therefore, DOE has concluded that the data provided by
Kolpak, and subsequently by Imperial Brown, are representative of the
energy efficiency that can be achieved for all non-display doors,
including those that are sold separately from the walk-in in which they
are installed.
---------------------------------------------------------------------------
\32\ See imperialbrown.com/products/doors.
---------------------------------------------------------------------------
Also in response to the March 2024 NODA, RSG stated that it already
uses low-density, high-insulation foam core material without a wood
frame, so the thermal load technology exceeds the DOE baseline. (RSG,
No. 89 at p. 1)
DOE did not receive any other comments in response to its
adjustment of thermal conduction load/U-factors made in the March 2024
NODA. For this final rule, DOE maintained the same thermal conduction
load and U-factors as the March 2024 NODA.
Maximum Daily Energy Consumption Allowances
As previously discussed, in the March 2024 NODA, DOE updated its
analysis to present maximum daily energy consumption allowances for
non-display doors where manufacturers offer basic models with certain
electricity-consuming devices. 89 FR 18555, 18556-18559. To develop the
MDEC allowances specific for walk-in non-display doors with certain
electrical components, DOE reviewed the data and calculations submitted
by Kolpak, as well as product literature from hardware and instrument
manufacturers. In its comment, Kolpak provided information regarding
the following components that are included on its basic models of non-
display doors: anti-sweat heat on viewing windows; lighting and
mechanisms to turn the lighting on or off (e.g., manual toggle
switches, door-open timers, occupancy sensors); heated ventilators
(also called heated pressure relief vents); and temperature alarms.
(Kolpak, No. 66, Attachment 1 at pp. 1-2) Kolpak provided information
on model numbers of electrical components, rated wattage of those
components, number of electrical components on its doors, and the
calculation of the direct and indirect electrical energy consumption
for all electrical components. (Kolpak, No. 66, Attachment 2) Using the
detail provided by Kolpak, DOE also looked into the hardware and
instrument manufacturers' product offerings for electrical components
to better understand the range of potential options for these
additional electrical components. Based on this, DOE grouped the
electrical components into four categories for the March 2024 NODA:
lighting, anti-sweat heat for viewing windows, digital temperature
displays/alarms, and heated pressure relief vents. 89 FR 18555, 18557.
Table IV.11 presents the MDEC allowances for lighting, anti-sweat heat
for viewing windows, digital temperature displays/alarms, and heated
pressure relief vents from the March 2024 NODA and the underlying
assumptions used to determine the MDEC allowances.
[GRAPHIC] [TIFF OMITTED] TR23DE24.027
BILLING CODE 6410-01-C
In the March 2024 NODA, DOE sought comment on the MDEC allowances
developed for the specified electricity-consuming devices. DOE also
[[Page 104664]]
sought comment on the assumed wattages, presence or absence of
controls, and location that were considered in the calculation of MDEC
allowances for the specified electricity-consuming devices. 89 FR
18555, 18559. In response, DOE received several comments that were
supportive of the approach and the MDEC allowances developed.
ASAP et al. supported DOE's approach regarding non-display doors
with additional electrical components but encouraged DOE to gather
additional information to ensure that the energy use allowances for
non-display doors with additional electrical components reflect the use
of efficient components. (ASAP et al., No. 90 at p. 2)
The CA IOUs supported DOE's evaluation of the identified additional
non-display door electricity-consuming components and agreed that DOE
cannot analyze reduced energy consumption for these electrical
components as they are not included with all non-display doors. The CA
IOUs supported the grouping of these components into four categories,
the conservative assumption that certain additional electrical
components contribute to indirect walk-in refrigeration load, and the
proposed MDEC allowances in the March 2024 NODA. The CA IOUs also
supported the relevant revisions to the walk-in non-display door
standards equations set forth in the March 2024 NODA. (CA IOUs, No. 91
at p. 2)
Imperial Brown supported providing separate MDEC allowances for
lighting, anti-sweat heat for viewing windows, digital temperature
displays/alarms, and heated pressure relief vents. Imperial Brown
further stated that the MDEC allowance for lighting, digital
temperature displays/alarms, and heated pressure relief vents are
reasonable for medium- and low-temperature doors. (Imperial Brown, No.
84 at p. 1) Imperial Brown provided data to support its comments.
(Imperial Brown, No. 84, Attachment 2)
RSG stated that DOE's suggestion to account for lights, heated
viewing windows, heated vents, and digital temperature displays in the
MDEC equations are a step in the right direction. RSG stated that the
equations for MDEC from Table II.24 of the March 2024 NODA remain
overly restrictive. (RSG, No. 89 at p. 1)
As discussed in the previous subsection (Improved Thermal
Conduction Load Through Improved Frame Systems and Increased Insulation
Thickness), Senneca stated that because Kolpak manufactures and
distributes complete walk-in coolers and freezers, its data is not
representative of the energy efficiency that can be achieved by
companies that manufacture and distribute walk-in cooler and freezer
doors that are sold and installed separately. (Senneca, No. 92 at p. 3)
As summarized in this section, two manufacturers that offer doors that
are sold and installed separately from the walk-in box commented in
support of some of the maximum daily energy consumption allowances and
provided specific feedback to support their comments and
recommendations for the MDEC allowances.\33\ DOE discusses the feedback
received from these manufacturers in the following subsections.
---------------------------------------------------------------------------
\33\ See imperialbrown.com/products/doors, master-bilt.com/product_category/walk-in-repair/, and norlake.com/nor-lake-products/foodservice/products/walk-in-repair/.
---------------------------------------------------------------------------
DOE also received several specific comments regarding each
component. The subsections that follow describe the underlying
assumptions for each category of electrical components and the relevant
comments received in response to the September 2023 NOPR and the March
2024 NODA.
i. Lighting
In response to the September 2023 NOPR, Kolpak encouraged DOE to
adopt an efficiency requirement for light bulbs used in doors that is
more stringent than 40 lumens/W. Kolpak commented that it uses LED
light bulbs that have an efficacy of at least 88 lumens/W and controls,
and therefore it does not have a means of further reducing energy
consumption from lighting. (Kolpak, No. 66, Attachment 1 at p. 1)
Kolpak also stated that it supports DOE requiring non-display doors to
have light controls such as occupancy sensors or door-open timers
instead of manual toggle light switches. (Kolpak, No. 66, Attachment 1
at p. 3)
As discussed in the March 2024 NODA, for the lighting category, DOE
considered lighting, a night light, and a pilot light located on a
switch to develop an appropriate DEC allowance for doors that have
lighting. 89 FR 18555, 18557. Lighting provides visibility within the
walk-in, particularly near the entrance and exit of the walk-in, and is
commonly controlled by a switch. Switches used for turning the lights
on and off often have a pilot light so that the switch can be located
in the dark. As included in Kolpak's comment and calculations, a night
light could also be attached to the walk-in door.
Based on Kolpak's provided data and a review of product
literature,\34\ in the March 2024 NODA, DOE assumed lighting would have
rated power of 13 W, a switch with a pilot light would have a rated
power of 0.3 W, and a night light would have a rated power of 1 W. The
lighting wattage used to develop the MDEC allowance was based on the
information and calculations provided by Kolpak, which specify an LED
light fixture with an efficacy of 88 lumens/W.
---------------------------------------------------------------------------
\34\ See https://www.kasonind.com/files/pdf/Kason_Catalog_lightingElectrical_Digital.pdf.
---------------------------------------------------------------------------
Based on a review of models certified to DOE, DOE also assumed that
these components would not be controlled by demand-based controls, and
therefore it used the percent time off (``PTO'') values specified for
lighting and other electricity-consuming devices without controls,
timers, or auto-shut-off systems, per Table A.2 of appendix A, along
with the rated power to determine the direct electrical energy
consumption. Based on a review of product literature and doors it has
tested, DOE assumed that the light and night light would be located on
the interior of the walk-in, and the switch may be located on either
the interior or exterior of the walk-in; therefore, all the three
components associated with lighting were conservatively assumed to be
sited on the internal face of the door for the purposes of determining
the indirect electrical energy consumption. See 10 CFR part 431,
subpart R, appendix A, sections 6.3.2.2 and 6.3.3.
In response to the March 2024 NODA, ASAP et al. stated that
controls could be implemented to reduce lighting energy usage. (ASAP et
al., No. 90 at p. 2) RSG stated that the door light allowance appears
low. RSG stated that walk-in lighting is a safety issue and there needs
to be enough lumens to sufficiently light the walk-in entrance and
interior to allow the operators the ability to safely perform their
duties. RSG recommended that a 17 to 20 W light with around 1,500-
lumens output would be a better assumption than 13 W. (RSG, No. 89 at
pp. 1-2)
Based on the feedback received from RSG and ASAP et al., for this
final rule DOE evaluated the MDEC allowance for lighting based on
updated assumptions using (1) a 20 W light bulb in the MDEC calculation
instead of a 13 W light bulb, and (2) demand-based controls. DOE
compared the MDEC allowance calculated using these two assumptions with
the MDEC allowance calculated in the March 2024 NODA. The two scenarios
are shown in Table IV.12. These two changes in assumptions mostly
offset each other in terms of the
[[Page 104665]]
daily energy consumption from the lighting because the higher wattage
lightbulb increases the daily energy consumption, however, the demand-
based controls reduce the daily energy consumption.
[GRAPHIC] [TIFF OMITTED] TR23DE24.028
DOE has concluded that the MDEC allowances presented in the March
2024 NODA sufficiently capture the additional energy consumption of
lighting, which provides visibility within the walk-in, specifically
near the entrance and exit of the walk-in near the door. Therefore, DOE
is adopting the MDEC allowances calculated for the March 2024 NODA.
ii. Anti-Sweat Heater for Viewing Window
DOE included windows in its representative units of non-display
doors. However, as discussed in the March 2024 NODA, DOE did not
consider additional anti-sweat heat specific to the window. 89 FR
18555, 18557-18558. Antisweat heaters are a performance-related feature
used on viewing windows to prevent (1) condensation from collecting on
the glass, and (2) fogging of the glass.
In response to the September 2023 NOPR, Kolpak commented that it is
standard for medium-temperature non-display doors with viewing windows
to have an anti-sweat heater wire around the frame of the window and
for low-temperature non-display doors with viewing windows to have an
anti-sweat heater wire and heated glass coating on the outer pane of
glass. Kolpak commented that its widely used supplier used to provide a
10 W/ft anti-sweat heater wire without controls. Kolpak stated that it
uses a 5 W/ft heater wire with controls in the frame of the viewport
window. Kolpak stated that it cannot find additional means to reduce
the energy consumption of the anti-sweat heater wire in the viewing
window frame further. (Kolpak, No. 66 Attachment 1 at p. 1) Kolpak also
stated that it supports DOE requiring non-display doors to have anti-
sweat heater wire maximums for viewing windows similar to the maximums
for the non-display doors and controls for non-display door anti-sweat
heater wires and controls for window anti-sweat heater wires. (Kolpak,
No. 66, Attachment 1 at p. 3)
Based on Kolpak's provided data and a review of product literature,
for the March 2024 NODA, DOE assumed that if anti-sweat heat is
included around and/or on viewing windows, that anti-sweat heat would
have a rated power of 34 W for medium-temperature (i.e., cooler)
applications and 84 W for low-temperature (i.e., freezer) applications.
DOE also assumed that these components would be controlled by some
demand-based controls based on the information provided by Kolpak, and
therefore DOE used the PTO values specified for anti-sweat heat with
controls, timers, or auto-shut-off systems per Table A.2 of appendix A,
along with the rated power to determine the direct electrical energy
consumption. DOE assumed that for the purposes of determining the
indirect electrical energy consumption of the anti-sweat heater, 75
percent of the total power is attributed to the interior and 25 percent
of the total power is attributed to the exterior of the walk-in,
consistent with the assumptions outlined in the DOE test procedure. See
10 CFR part 431, subpart R, appendix A, sections 6.3.2.2 and 6.3.3.
In response to the March 2024 NODA, Imperial Brown stated that the
MDEC allowance for anti-sweat heat of viewing windows for low-
temperature doors is too stringent. Imperial Brown stated that it
offers a 12'' x 12'' nominal viewing window from its vendor that
consumes 50 W for low-temperature installations and does not include
demand-based controls, which yields a total DEC of 1.74 kWh/day above
the MDEC allowance in the NODA. Imperial Brown stated it is not aware
of a vendor that provides view windows with controls for its
application. Imperial Brown stated it also offers a 12'' x 24'' nominal
viewing window, which accommodates a wider range of human height, that
consumes 84 W for low-temperature installations and does not include
demand-based controls. Imperial Brown stated that the DEC for this
window heat is 3.11 kWh/day. Imperial Brown recommended that the MDEC
for heated windows be defined per square foot of window and that the
maximum acceptable area of a viewing window be defined. (Imperial
Brown, No. 84 at p. 1)
While Imperial Brown stated it is not aware of a vendor that
provides view windows with controls for its application, DOE notes that
Kolpak stated in its comment that it requested that its viewing window
vendor make windows with bimetallic thermostats to control the heater
wire around the viewport. There is no indication that the applications
for these two manufacturers of non-display doors are any different;
therefore, DOE has no evidence that other manufacturers could not
implement anti-sweat controls on the viewing windows used in non-
display doors. Therefore, DOE has concluded that calculating the MDEC
allowance for anti-sweat heat for viewing windows based on the presence
of controls is appropriate.
DOE further evaluated Imperial Brown's suggestion that the MDEC
allowance for heated viewing windows be defined per square foot of
window. To do this, DOE collected the information provided by Kolpak
and Imperial Brown and reviewed additional information found in product
literature of a manufacturer of heated viewing windows.\35\ DOE
calculated the direct and indirect electrical energy
[[Page 104666]]
consumption for each viewing window size and anti-sweat wattage used,
based on the presence of controls, and plotted the MDEC allowance by
window area to develop a linear relationship. These updated MDEC
allowances calculated per area of window size and the linear
relationship based on the area of the viewing window can be found in
Table IV.13.
---------------------------------------------------------------------------
\35\ See norfabinc.com/wp-content/uploads/2022/04/VU-PORT-Spec-Sheet-5-Watt-1.pdf.
---------------------------------------------------------------------------
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.029
BILLING CODE 6410-01-C
DOE has concluded that the MDEC allowances presented in the March
2024 NODA would sufficiently capture the additional energy consumption
required for doors that require heated viewing windows. As shown in
Table IV.13, the MDEC allowance varies by window size and amount of
anti-sweat heat presented per window size. Per Imperial Brown's
recommendation, DOE has concluded that setting the MDEC allowance for
heated viewing windows per area of viewing window (in square feet)
would sufficiently capture the difference in additional energy that
would be consumed by anti-sweat heaters on viewing windows for smaller
and larger windows. DOE does not intend to limit the maximum acceptable
area of a viewing window; however, the wattage of the anti-sweat heater
for the 14-inch by 24-inch windows for both medium- and low-temperature
applications were the maximum wattages that DOE found based on public
comment and manufacturer literature. As such, DOE is maintaining the
MDEC allowances for heating viewing windows for medium- and low-
temperature applications from the March 2024 NODA as the maximum
allowance. DOE's calculations were based on the four window sizes that
it has identified through comments and a review of product literature.
Therefore, DOE has concluded that the MDEC allowances defined by window
area as shown in Table IV.13 are appropriate, and DOE is adopting them
in this final rule for non-display doors with heated viewing windows.
iii. Digital Temperature Displays With or Without Alarms
A digital temperature display allows users to easily monitor the
temperature of the walk-in. The digital temperature display is
connected to a thermocouple that measures the temperature of the walk-
in, and the interface on the exterior of the walk-in displays the
temperature within the walk-in compartment. In the March 2024 NODA,
based on review of product literature and Kolpak's data, DOE had
determined that a digital temperature display could be paired with
alarms or stand alone (i.e., without alarms). 89 FR 18555, 18558. The
alarms alert kitchen staff or others if the refrigerated goods within
the walk-in compartment are in conditions that are too warm or too
cold, which may spoil or ruin these goods. Additionally, alarms can
sound if the walk-in door is left open for too long. Kolpak commented
that walk-ins with multiple compartments that have only one exterior
door but have doors on interior partitions that separate the
compartments often have two temperature alarms on the exterior door so
that the alarms can be heard by those outside of the walk-in. (Kolpak,
No. 6, Attachment 1 at p. 2) Kolpak also stated that it supports DOE
requiring non-display doors to have temperature alarms with a maximum
energy usage such as 7 W each but allow multiple temperature alarms on
one door. (Kolpak, No. 66, Attachment 1 at p. 3) Additionally, through
its review of hardware and instrument manufacturers' product offerings,
DOE identified that a panic or entrapment
[[Page 104667]]
alarm could be installed for use in the event that a user is unable to
exit the walk-in. Based on Kolpak's provided data and a review of
hardware manufacturers' product literature,\36\ in the March 2024 NODA,
DOE assumed a digital temperature display without alarms would have a
rated power of 2.4 W and a digital temperature display with alarms
would have rated power of 4 W. In consideration of Kolpak's comment
that a walk-in comprising two compartments may require two temperature
displays with alarms to be located on the exterior non-display door,
DOE assumed that digital temperature display with alarm(s) would have a
total rated power of 8 W. DOE assumed based on a review of Kolpak's
data and product literature that the digital temperature display with
or without alarms would always be on, and as such used the PTO
specified for other electricity-consuming devices without controls,
timers, or auto-shut-off systems, per Table A.2 of appendix A, along
with the rated power to determine the direct electrical energy
consumption. The temperature display and alarms would likely be sited
on the exterior of the walk-in door to be seen and heard; however,
components of the display would be located interior to the walk-in,
such as the thermocouple. Therefore, DOE conservatively assumed these
components would be sited on both the internal and external face of the
door for the purposes of determining the indirect electrical energy
consumption. See 10 CFR part 431, subpart R, appendix A, sections
6.3.2.2 and 6.3.3. Additionally, DOE assumed that a door would either
have one or the other but would not have both (1) a digital temperature
display without an alarm, and (2) a digital temperature display with
alarms.
---------------------------------------------------------------------------
\36\ See https://www.kasonind.com/files/pdf/Kason_Catalog_lightingElectrical_Digital.pdf.
---------------------------------------------------------------------------
As previously mentioned, DOE received general support from ASAP et
al. and the CA IOUs regarding the MDEC allowances and support from
Imperial Brown regarding the MDEC allowance for digital temperature
displays/alarms. DOE did not receive any other comments regarding its
assumptions for determining the MDEC allowances or the MDEC allowances
themselves for doors with a (1) digital temperature display without an
alarm, or (2) digital temperature display with alarms. In this final
rule, DOE is maintaining the MDEC allowances for doors with a (1)
digital temperature display without an alarm, or (2) digital
temperature display with alarms as calculated for the March 2024 NODA.
These calculated allowances can be found in Table IV.14. Consistent
with the March 2024 NODA, DOE assumed that a door would either have one
or the other but would not have both (1) a digital temperature display
without an alarm, and (2) a digital temperature display with alarms. As
such, only one of these MDEC allowances would apply based on whether
there is or is not an alarm connected to the digital temperature
display. This is demonstrated in the standards equations presented in
section I of this document.
iv. Heated Pressure Relief Vent
Heated ventilators, or heated pressure relief vents, are
performance-related features that allow doors to open more easily when
there is a pressure differential between the interior and the exterior
of the walk-in.
In response to the September 2023 NOPR, Kolpak stated that heated
ventilators can affect energy consumption of non-display doors and were
not detailed in DOE's proposal. Kolpak stated that some manufacturers
put heated ventilators on a non-door panel so that they are not
considered in the energy consumption calculation of a door; however,
Kolpak places these devices on the door, where its energy consumption
is captured in the daily energy consumption calculation. Kolpak
commented that it uses the lowest-wattage heated ventilator available
and cannot find additional means to decrease the energy consumption of
the heated ventilators. Kolpak stated that it asked its supplier of
heated ventilators to explore adding a bimetallic thermostat control to
the heating element, but there are concerns regarding quality due to
the nature of its applications. (Kolpak, No. 66 at p. 2) Kolpak's data
indicates that a 4 W heated ventilator is used on doors for both
medium-temperature and low-temperature installations. (Kolpak, No. 66,
Attachment 2) Kolpak also stated that it supports DOE requiring non-
display doors to have heated ventilators to have a maximum energy usage
such as 4 W unless the compartment is over 2,500 cubic feet and heated
ventilators' energy usage to be included in the door calculation even
if on a wall panel. (Kolpak, No. 66, Attachment 1 at p. 3)
In the March 2024 NODA, DOE evaluated an MDEC allowance for non-
display doors with heated ventilators. 89 FR 18555, 18558. DOE had
tentatively determined, however, that while medium-temperature
applications may require a pressure relief vent, it may not be
necessary for the pressure relief vent to be heated. Therefore, DOE did
not develop a MDEC allowance for medium-temperature non-display doors.
Id.
Additionally, based on review of hardware manufacturers' product
literature and the recommendations for pressure relief vents based on
the size of a walk-in,\37\ DOE tentatively determined that a heated
pressure relief vent for low-temperature walk-in applications could
require up to 23 W of heat to prevent freezing and therefore provide
sufficient airflow between the walk-in compartment and the exterior.
DOE assumed based on a review of Kolpak's data and hardware
manufacturers' product literature that the heater component of the
pressure relief vent would always be on, and as such used the PTO
specified for other electricity-consuming devices without controls,
timers, or auto-shut-off systems, per Table A.2 of appendix A, along
with the rated power to determine the direct electrical energy
consumption. Because the heated vent is located between both the
exterior and interior of the walk-in, it is considered to be located
interior to the walk-in for the purposes of determining the indirect
electrical energy consumption. See 10 CFR part 431, subpart R, appendix
A, sections 6.3.2.2 and 6.3.3.
---------------------------------------------------------------------------
\37\ See www.kasonind.com/files/pdf/Kason_Catalog_WalkIn_Digital.pdf.
---------------------------------------------------------------------------
As previously mentioned, DOE received general support from ASAP et
al. and the CA IOUs regarding the MDEC allowances and support from
Imperial Brown regarding the MDEC allowance for heated pressure relief
vents. ASAP et al. encouraged DOE to further investigate the
discrepancy between Kolpak's suggested ventilator heater power and the
power allowance included in the NODA for low-temperature non-display
doors. (ASAP et al., No. 90 at p. 2)
Based on product literature of heated pressure relief vents, DOE
assumes that the required wattage would scale with walk-in volume. A 4
W heated pressure relief vent may be sufficient for a small walk-in up
to 2,000 or 2,500 cubic feet, which is consistent with Kolpak's
comment; however, larger walk-ins (i.e., greater than 2,500 cubic feet)
may require a heated pressure relief vent up to 23 W. Because the
performance standards are separated out by component, doors are tested
and rated based on the energy consumption of the door alone,
independent of the volume of the walk-in that the door would be
installed in. Therefore, DOE conservatively used 23 W for the heated
pressure relief vent, recognizing that heated pressure relief vents
installed on
[[Page 104668]]
walk-in doors could have rated power as high as 23 W.
DOE calculated the MDEC allowances (i.e., the sum of the direct and
indirect electrical energy consumption) for low-temperature doors with
heated pressure relief vents, which can be found in Table IV.14.
v. Door Leaf Perimeter Anti-Sweat Heat
In the March 2024 NODA, DOE did not analyze an MDEC allowance
specific to anti-sweat heat around the perimeter of the door leaf
because this electricity-consuming device was already included in the
representative units analyzed. In response to the April 2024 NODA,
Imperial Brown stated that the portion of the equation that accounts
for the perimeter heater cable is out of line compared to the MDEC
allowance for heated view windows. Imperial Brown stated that the DEC
for heater cables should not be a function of AND, but a
function of door-opening perimeter, because total heater cable power
consumption is based upon length. Imperial Brown described the anti-
sweat heat wiring pathways of its non-display doors. Imperial Brown
asserted that the A factor in the MDEC equation must be increased or
the equation needs to include a dedicated portion for the door
perimeter heater cable component where PND is the perimeter
of the non-display door opening. (Imperial Brown, No. 84 at pp. 2-3)
Anti-sweat heater wire is generally applied to the perimeter of the
door leaf or the frame that comes into contact with the door leaf.
However, DOE notes that the energy conservation standards for non-
display doors are expressed as a function of AND, which
includes the frame of the door in addition to the door leaf. The area
of the door frame and door leaf can vary for doors of the same overall
area AND. For the purposes of the analysis, DOE analyzed a
representative door leaf area and frame area, but this may vary across
door models with the same overall area. The energy conservation
standards proposed in the September 2023 NOPR and the updated standards
equations shown in the March 2024 NODA already included perimeter anti-
sweat heat for non-display doors. Therefore, DOE is not adopting a
separate allowance for the perimeter anti-sweat heat. As further
discussed in section V.C of this document, DOE is adopting standards
less stringent than proposed in the September 2023 NOPR. Therefore, the
A factor in the MDEC equation has been increased.
vi. Components Summary
Table IV.14 presents the updated MDEC allowances for lighting,
anti-sweat heat for viewing windows, digital temperature displays/
alarms, and heated pressure relief vents for this final rule.
[GRAPHIC] [TIFF OMITTED] TR23DE24.030
As discussed previously, each of these electrical components
provides some functionality to the consumer when installed on a non-
display door. Additionally, having these electrical components
installed on the door limits the number of electrical connections that
need to be wired when installing a walk-in. Pursuant to EPCA, 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 the equipment's capacity or other performance-related
feature justifies a different standard. (42 U.S.C. 6316(a); 42 U.S.C.
6295(q)(1)(B)) DOE has tentatively determined that that the devices it
has listed previously constitute a performance-related feature that
justifies a higher standard and therefore is adopting the MDEC
allowances for non-display doors that include these components on or
within the door.
DOE notes that the information described previously and in Table
IV.14 was used to develop the MDEC allowances for basic models of non-
display doors that have any number of these components sited on or
within the non-display doors. However, DOE notes that for the purposes
of determining DEC in accordance with the Federal test procedure at
appendix A, manufacturers must follow the instructions for calculating
both direct and indirect electrical energy consumption of components as
described in appendix A.
In the March 2024 NODA, DOE reviewed non-public manufacturer data
submitted to DOE's CCD to estimate the percentage of the market that
includes these other electricity-consuming devices on non-display
doors. DOE's estimates of shipments containing electricity-consuming
devices from the March 2024 NODA are shown in Table IV.15.
[[Page 104669]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.031
In response, RSG stated that lighting is included in 100 percent of
its medium- and low-temperature manual doors. RSG stated that the
viewing window shipment numbers DOE estimated appear to be close. RSG
stated that 100 percent of RSG's medium- and low-temperature manual
doors contain one or more of the digital temperature display and/or
heated vent options. (RSG, No. 89 at p. 2) DOE has accounted for this
in its updated equipment efficiency distributions shown in Table IV.51
of this document.
d. Panels
Representative Units
In the September 2023 NOPR, DOE evaluated the same representative
units for each panel equipment class that it evaluated for the June
2014 Final Rule. 88 FR 60746, 60770. DOE did not receive any comments
regarding the representative units of panels analyzed in the September
2023 NOPR. In this final rule, DOE maintained the same representative
units for each panel equipment class. Table IV.16 summarizes the
representative units evaluated for walk-in panel equipment classes.
[GRAPHIC] [TIFF OMITTED] TR23DE24.032
Baseline Efficiency, Design Options, and Efficiency Levels
In the September 2023 NOPR, DOE evaluated increasing insulation
thickness to obtain higher insulation R-values for panels as calculated
pursuant to appendix B of subpart R to 10 CFR part 431. The thermal
resistance of insulating materials increases approximately linearly
with material thickness. 88 FR 60746, 60771.
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). Id.
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. Id.
DOE did not receive any comments regarding the specifics of the
efficiency analysis (i.e., baseline efficiency, design options, and
efficiency levels) DOE conducted for panels in the September 2023 NOPR.
For the panels' efficiency analysis, DOE maintained the same baseline
efficiency, design options, and efficiency levels in this final rule.
[[Page 104670]]
e. Dedicated Condensing Units and Single-Packaged Dedicated Systems
Refrigerants Analyzed
i. Background and NOPR Analysis
As previously mentioned, 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, under the AIM Act,
which proposed refrigerant regulations regarding acceptable GWP limits
for various air-conditioning and refrigeration systems. 87 FR 76738.
The December 2022 EPA Technology Transitions NOPR proposed to establish
a limit of 300 GWP for refrigeration systems with remote condensing
units in retail food refrigeration systems and cold storage warehouses
with less than 200 pounds (``lbs'') of charge, which includes split-
system walk-in refrigeration systems covered under the scope of the
September 2023 NOPR. EPA proposed this take effect January 1, 2025. EPA
finalized its proposals in the October 2023 EPA Technology Transitions
Final Rule published on October 24, 2023, with an extended effective
date of January 1, 2026. 88 FR 73098.
In the September 2023 NOPR, DOE estimated the potential performance
penalties associated with transitioning medium- and low-temperature
refrigeration systems from R-448A and R-449A to lower-GWP alternatives
by modeling the performance of three potential replacement A2L
refrigerants, which have GWPs less than 300: R-454A, R-454C, and R-
455A. DOE tentatively determined that R-454A would be the most likely
replacement refrigerant for medium- and low-temperature walk-in
refrigeration systems once the regulations proposed in the December
2022 EPA Technology Transitions NOPR take effect. DOE also tentatively
determined that R-454A would have comparable performance to the
currently used refrigerant R-448A. 88 FR 60746, 60772. As there was
limited compressor performance data available for R-454A at the time,
DOE used R-448A as the basis for its engineering analysis for medium-
and low-temperature dedicated condensing units and single-packaged
dedicated systems.\38\ Id. In the September 2023 NOPR, DOE requested
performance data for walk-in refrigeration systems using R-454A, R-
454C, and/or R-455A. DOE also sought comment on its tentative
determinations that R-454A is the most likely replacement for the
current refrigerants being used (e.g., R-448A and R-449A) for medium-
and low-temperature refrigeration systems and that walk-in dedicated
condensing systems would not suffer a performance penalty when
switching from R-448A or R-449A to R-454A. Id.
---------------------------------------------------------------------------
\38\ DOE notes that a more efficient single-speed compressor
that used propane was analyzed as a design option for some single-
packaged dedicated systems. A propane compressor was analyzed if the
charge limit for propane was sufficient to provide the analyzed
capacity and the propane compressor resulted in increased
efficiency.
---------------------------------------------------------------------------
Also as discussed in the September 2023 NOPR, DOE tentatively
determined that high-temperature refrigeration systems currently use R-
134a exclusively. 88 FR 60746, 60773. Due to the October 2023 EPA
Technology Transitions Final Rule, walk-in cooler refrigeration systems
that use R-134a will be banned from being manufactured and instead will
be required to be manufactured with a low-GWP substitute will be
required by 2025 or 2026 depending on the sector.\39\ In the September
2023 NOPR, DOE analyzed high-temperature refrigeration systems using R-
134a given that at the time of publishing no clear low-GWP replacement
had been identified by the high-temperature refrigeration system
industry or refrigerant manufacturers. Id. In the September 2023 NOPR,
DOE also requested comment on any potential low-GWP replacements for
high-temperature systems. Id.
---------------------------------------------------------------------------
\39\ The compliance date for manufacture of products using
lower-GWP refrigerants for self-contained ``retail food
refrigeration standalone units'' is January 1, 2025, while the
compliance date for manufacture of ``retail food remote condensing
units'' and ``cold storage warehouses'' is January 1, 2026. 40 CFR
part 84, subpart B.
---------------------------------------------------------------------------
Additionally, for the September 2023 NOPR, DOE analyzed R-290
(propane) as a design option for medium- and low-temperature single-
packaged dedicated systems. The current charge limit for R-290 for
single-packaged systems is 300 grams.\40\ 88 FR 60746, 60772. DOE did
not analyze R-290 as a design option for dedicated condensing units,
since it is not suitable for use in split systems under current
regulations, and because DOE tentatively determined that split-system
charge requirements would exceed the 300-gram limit. Id. Additionally,
DOE was unable to identify compressors for high-temperature
applications designed for use with R-290. As such, DOE did not analyze
R-290 as a design option for high-temperature refrigeration systems.
---------------------------------------------------------------------------
\40\ EPA published a final rule pertaining to hydrocarbon
refrigerants on June 13, 2024.. 89 FR 50410. This rule limits the
acceptable charge of propane in a refrigeration circuit to 300 grams
for refrigeration systems with end-uses in the retail food industry.
89 FR 50410, 50467.
---------------------------------------------------------------------------
ii. Candidate Replacements for Current Refrigerants
As previously mentioned, DOE sought comment on its tentative
determinations that R-454A is the most likely replacement for the
current refrigerants being used for low- and medium-temperature
refrigeration systems (i.e., R-448A and R-449A). 88 FR 60746, 60772.
In response to the September 2023 NOPR, RSG stated that there is no
firm way forward in the regulatory landscape or industry regarding A2L
refrigerants and testing. (RSG, No. 69 at p. 2) Additionally, RSG
stated that the inclusion of per- and polyfluoroalkyl substances `PFAS'
(``forever chemical'') as components of most A2Ls (e.g., R-454) has
raised concerns domestically and globally, leading to bans of the
chemicals in increasing numbers. RSG requested that DOE consider this
as a factor in proposing technologies for energy savings. (RSG, No. 69
at p. 2) AHRI and Hussmann commented that PFAS and perfluorooctanoic
acid (``PFOA'') regulations by EPA and States could prohibit the use of
R-454A and stated that Maine has PFA reporting requirements starting on
January 1, 2025. (AHRI, No. 72 at p. 10; Hussmann, No. 75 at p. 10)
AHRI and Hussmann commented that States that are Climate Alliance
members, such as New York, may pursue regulations with GWP limits lower
than 150. (Id.) AHRI commented that by the time the standards go into
effect, EPA may have lowered the GWP allowance from 300 to 150. (AHRI,
No. 72 at p. 10)
DOE is not currently aware of any current or proposed regulations
(other than certain State regulations \41\ that were considered in the
March 2024 NODA and are further discussed in the ``NODA Analysis''
subsection of this section) that would limit walk-in refrigeration
systems to refrigerants with less than 150 GWP or regulate PFAS present
in refrigerants. As a result, DOE did not consider potential future
bans of PFAS, or further future restrictions to the GWP of refrigerants
used in walk-in refrigeration systems in this analysis.
---------------------------------------------------------------------------
\41\ California established (effective January 1, 2022) a limit
of 150 GWP for retail food refrigeration equipment and cold storage
warehouses with more than 50 lbs of charge. Washington also
established (effective January 1, 2025 for new equipment and January
1, 2029 for retrofit equipment) a limit of 150 GWP for retail food
refrigeration equipment and cold storage warehouses with more than
50 lbs of charge.
---------------------------------------------------------------------------
AHRI, Hussmann, and Lennox commented that customers that have
refrigeration circuits both above and below 200 lb may not want to have
two different refrigerants on the same site
[[Page 104671]]
and would use a refrigerant below 150 GWP. (AHRI, No. 72 at p. 10;
Hussmann, No. 75 at p. 10; Lennox, No. 70 at p. 7)
DOE recognizes that customers will, and do, have varying needs that
may impact their choice of refrigerant used in a walk-in. However, DOE
selected the most representative refrigerant to account for the
behavior of the entire walk-in industry. As a result, DOE did not
consider locations with installations above and below 200 lb in this
analysis and only considered walk-in installations below 200 lb of
refrigerant, focusing on sub-300 GWP refrigerants for split-system
walk-in refrigeration systems, except as discussed further in the NODA
Analysis subsection.
The CA IOUs recommended that DOE consider R-471A, a new refrigerant
in the marketplace, as a refrigerant that would comply with potential
future regulations that require sub-150 GWP refrigerants for walk-in
refrigeration systems. The CA IOUs commented that because R-471A
impacts WICF efficiency, offers 30-percent energy savings over
CO2, and has a GWP of less than 150, it is likely to replace
R-454A in the long term. (CA IOUs, No. 76 at p. 11) ASAP et al.
commented that both R-454A and R-471A may exceed the efficiency of R-
404A over a broad range of operating conditions. (ASAP et al., No. 77
at pp. 5-6) NRAC commented that R-471A is not suitable for low-
temperature applications. (NRAC, No. 73 at p. 2)
DOE is aware that R-471A could be used as a refrigerant for medium-
temperature walk-in refrigeration systems in the future; however, there
is currently not enough publicly available data on R-471A to analyze in
this rulemaking. Therefore, DOE did not consider R-471A as a
refrigerant for medium-temperature systems in this final rule analysis.
In this final rule analysis DOE maintained the refrigerants analyzed
for medium- and low-temperature dedicated condensing systems from the
NOPR analysis and conducted all analyses using R-448A as a performance
proxy for R-454A.
As previously mentioned, in the September 2023 NOPR, DOE also
requested comment on any potential low-GWP replacements for high-
temperature systems. 88 FR 60746, 60773.
AHRI, Hussmann, and NRAC cited R-471A as a possible replacement for
R-134a for high-temperature applications. (AHRI, No. 72 at pp. 10-11;
Hussmann, No. 75 at p. 11; NRAC, No. 73 at p. 2) Hussmann stated that
little information on R-471A is available, but the manufacturer could
provide details. (Hussmann, No. 75 at p. 11) As discussed previously in
this section, DOE does not have sufficient data to analyze the
performance of R-471A.
AHRI commented that R-1234yf (GWP < 1) can replace R-134a for
remote system applications and is commonly applied in commercial
refrigeration today. (AHRI, No. 72 at p. 10) DOE acknowledges that R-
1234yf is a potential replacement for R-134a in high-temperature walk-
in applications. DOE has not been able to identify any performance data
for R-1234yf compatible compressors for high-temperature applications
and therefore did not analyze R-1234yf as a refrigerant in this
analysis.
AHRI stated that it is aware of A1 refrigerants with performance
similar to R-134a and a GWP below 300, but it noted these cannot be
used in low-temperature applications above atmospheric pressure and
these have considerably lower capacity compared to A2L alternatives.
AHRI commented that like-for-like capacity units require larger
condensing units and unit coolers for these A1 refrigerants compared to
their A2L counterparts. (AHRI, No. 72 at pp. 10-11) Given the limited
information provided by AHRI about potential sub-300 GWP A1
refrigerants, and their potential downsides, DOE did not analyze such
refrigerants for high-temperature refrigeration systems in this final
rule.
ASAP et al. commented that R-513A--which is currently used in
ENERGY STAR[supreg]-rated service-over-counter commercial refrigeration
equipment (``CRE'')--is a low-GWP replacement for R-134a in high-
temperature applications with similar reported efficiency. (ASAP et
al., No. 77 at pp. 5-6) DOE notes that R-513A has a GWP of 573, which
is lower than the GWP of R-134a but would not comply with the October
2023 EPA Technology Transitions Final Rule regulation. Thus, DOE did
not consider R-513A as a refrigerant for high-temperature applications
in its engineering analysis for this final rule.
Based on the feedback received and a review of publicly available
resources, DOE has not been able to identify a sub-300 GWP refrigerant
that could serve as a replacement for R-134a in high-temperature
applications that has enough performance data (e.g., compressor
coefficients) available to conduct a full engineering analysis for
high-temperature single-packaged dedicated condensing systems. As such,
DOE is maintaining the analysis conducted in the September 2023 NOPR
and analyzing high-temperature single-packaged dedicated systems using
R-134a.
iii. Performance of Alternative Refrigerants
For the September 2023 NOPR, DOE estimated potential performance
penalties associated with transitioning from R-448A and R-449A to a
lower-GWP refrigerant by modeling the performance of three potential
replacement A2L refrigerants for dedicated condensing units: R-454A, R-
454C, and R-455A. DOE tentatively concluded R-454A would be the most
likely replacement for split-system walk-in refrigeration systems
because R-454A has the lowest glide and would be the highest-
performance sub-300 GWP replacement for R-448A and R-449A of the three
refrigerants analyzed. DOE also tentatively concluded that medium- and
low-temperature walk-in refrigeration systems would not suffer a
performance penalty when switching from R-448A or R-449A to R-454A. DOE
requested performance data for walk-in refrigeration systems using R-
454A, R-454C, and/or R-455A. 88 FR 60746, 60771-60772.
In response to the September 2023 NOPR, ASAP et al. supported DOE's
refrigerant assumptions in the engineering analysis and noted that
these assumptions may result in conservative standard levels,
particularly for low- and medium-temperature systems, when considering
the upcoming switch to low-GWP refrigerants. (ASAP et al., No. 77 at
pp. 5-6)
RSG commented that it appears that some A2Ls perform similar to
HFCs, such as R-449. (RSG, No. 69 at p. 2) NRAC commented that
preliminary testing on R-454A, R-454C, and R-455A shows R-454A to be
the best performer of the three and the one closest to R-448A/R-449A in
terms of performance; however, more time is needed to thoroughly test
for all scenarios, applications, and equipment types. (NRAC, No. 73 at
p. 2) AHRI and Lennox commented that DOE's supposition that A2L
refrigerants are of equal performance to HFCs has proven to not be
true, as the new refrigerants are generally worse in overall
performance. (AHRI, No. 72 at p. 15; Lennox, No. 70 at p. 10) DOE notes
that in the September 2023 NOPR it did not make statements about the
performance of A2Ls in general compared to HFC refrigerants. As
discussed previously in this section, based on currently available
data, DOE tentatively determined that specifically R-454A has similar
performance to R-448A and R-
[[Page 104672]]
449A for walk-in dedicated condensing units.
RSG commented that A2L refrigerants require significantly more
components and design limitations than HFC refrigerants that may affect
performance. (RSG, No. 69 at p. 2) AHRI, Hussmann, and Lennox commented
that A2L refrigerants have higher ancillary power requirements from
additional solenoid valves, sensors, and controls that are required to
meet the safety standards, and motors could consume more power due to
tighter spacing and additional grilles. (AHRI, No. 72 at p. 10;
Hussmann, No. 75 at pp. 10-11; Lennox, No. 70 at p. 7) In response to
the March 2024 NODA, AHRI recommended that DOE review UL 60335-2-89.
AHRI stated that DOE's evaluation did not consider the safety shut-off
valves that will run during the on- and off-cycle condition. AHRI also
stated that due to the mitigation requirements, there are some cases
where some condenser fans will run when the compressor is off. (AHRI,
No. 86 at p. 8) In response to these comments, DOE reviewed UL 60335-2-
89, the relevant safety standard for using A2L refrigerants with walk-
in refrigeration systems. DOE found a requirement for additional leak
detection sensors, which DOE already assumed would be included and
determined would result in negligible additional wattage. Per section
1.7.5 of Annex 101.DVU of UL 60335-2-89, when a leak detection system
is present, condenser fans only have to run when a leak is detected and
therefore would not have increased power consumption as measured during
a test conducted in accordance with the DOE test procedure at appendix
C1. Furthermore, DOE found no requirement for valves that are not
already present in WICF refrigeration systems and that would consume
appreciable power. Additionally, DOE has determined that any grille
spacing requirements would not increase fan power consumption by a
measurable amount. As such, DOE did not include any allowance for
additional power consumption as a result of a transition to A2L
refrigerants.
Lennox commented that technologies that are currently in use may
not be able to be directly applied to low-GWP refrigeration systems
without thorough evaluation. (Lennox, No. 70 at p. 5) DOE is not aware
of current technologies or design options analyzed in this analysis
that cannot be used with low-GWP refrigerants, including A2Ls.
AHRI and Lennox stated that while R-454A performs better than R-
454C and R-455A for dedicated condensing units, R-455A performs better
than R-454A for unit coolers. Additionally, AHRI and Lennox commented
that R-455A has an advantage in the marketplace due to mitigation cost
and use allowance because of its lower flammability limit (``LFL'').
(AHRI, No. 72 at p. 10; Lennox, No. 70 at p. 7)
DOE's understanding is that the use of A2L refrigerants is a
greater concern for the performance of dedicated condensing units than
for unit coolers due to the high glide of A2L refrigerants.\42\
Therefore, DOE's performance impact assessment of A2Ls focused on
dedicated condensing units rather than on unit coolers. As such, DOE
has not conducted analysis on A2L refrigerant performance in unit
coolers to determine which A2L refrigerant performs best in unit
coolers. Feedback collected during manufacturer interviews indicated
that the very high glide of R-455A \43\ made it a poor refrigerant
candidate for dedicated condensing units as compared to other
alternatives. Because a unit cooler would be paired with a dedicated
condensing in over 80 percent of applications, R-455A would likely not
be used as a refrigerant in unit cooler applications. Additionally,
based on DOE's understanding of safety standard UL 60335-2-89, walk-in
refrigeration systems using safety shut-off valves such as the liquid
line solenoids already included on most if not all walk-in
refrigeration system installations would not face charge limits that
are restrictive enough to interfere with the use of any A2Ls, including
R-454A.\44\ Based on this, DOE has concluded that R-454A and R-454C are
still the most likely replacement refrigerants for walk-in
applications.
---------------------------------------------------------------------------
\42\ The DOE test procedure for walk-in unit coolers and
dedicated condensing units tested alone is based on specification of
the dewpoint temperature corresponding with unit cooler exit or
dedicated condensing unit inlet pressure. See AHRI 1250-2020 tables
12-17. The average two-phase refrigerant temperature associated with
this condition is lower for a higher-glide refrigerant, which is
more favorable for unit coolers and less favorable for dedicated
condensing units.
\43\ As show in Table 5.6.4 of the NOPR TSD, R-455A has a glide
of 17 [deg]F at walk-in test conditions, while R-448A has a glide of
8.2 [deg]F, R454A has a glide of 8.6 [deg]F, and R-454C has a glide
of 11.8 [deg]F.
\44\ UL 60335-2-89 states that if safety shut-off valves are
included in a system, the max releasable charge is equal to only the
charge downstream of the valve. UL 60335-2-89 Annex 101.DVU section
1.4.3.7. In this case, restrictions are only placed on the charge
weight of the releasable charge, not the total system charge. DOE
has determined that UL 60335-2-89's charge weight restrictions for
various walk-in box volumes would far exceed the releasable charge
between the liquid line solenoid and the compressor charge for
representative systems paired with these boxes.
---------------------------------------------------------------------------
iv. NODA Analysis
Additionally, in response to the September 2023 NOPR, DOE received
comment that R-454C or R-455A would be more likely replacements for R-
448A and R-449A than R-454A, because California and Washington State
have regulations that prohibit the use of a refrigerant with a GWP
greater than 150 for systems with more than 50 lb of charge. These
comments are summarized in the March 2024 NODA. 89 FR 18555, 18562-
18563.
In the March 2024 NODA, DOE acknowledged that certain localities
already require WICF refrigeration systems to be designed for use with
sub-150 GWP refrigerants.\45\ 89 FR 18555, 18562. In the September 2023
NOPR, DOE tentatively concluded that the highest-performing sub-150 GWP
refrigerant appropriate for use in split-system walk-in refrigeration
systems is R-454C. See section 5.6.3.1 of the September 2023 NOPR TSD.
To assess the potential impact of State-level sub-150 GWP requirements,
DOE reviewed the energy efficiency ratio (``EER'') of R-454C
compressors with capacities representative of walk-in refrigeration
systems and compared these EERs to those of the baseline compressors
analyzed in the September 2023 NOPR. DOE determined the R-454C EERs at
operating conditions representative for the A test conditions
prescribed in the DOE test procedure for walk-in refrigeration systems,
adjusting the condensing dewpoint up 2 [deg]F to account for the higher
refrigerant temperature glide of R-454C as compared to R-448A or R-
454A.
---------------------------------------------------------------------------
\45\ California established (effective January 1, 2022) a limit
of 150 GWP for retail food refrigeration equipment and cold storage
warehouses with more than 50 lb of charge. Washington also
established (effective January 1, 2025 for new equipment and January
1, 2029 for retrofit equipment) a limit of 150 GWP for retail food
refrigeration equipment and cold storage warehouses with more than
50 lb of charge.
---------------------------------------------------------------------------
DOE found that trends in the R-454C compressor efficiencies
generally aligned with the compressor EERs used in the September 2023
NOPR analysis, except for the DC.M.O.025 and DC.M.I.025 representative
units. At this 25 kBtu/h capacity DOE found that the available R-454C
compressor had an EER that is 4 percent less than that of the
compressor analyzed in the September 2023 NOPR. Based on this, DOE
determined that using the R-454C compressor analyzed could result in an
AWEF2 that is 2 percent lower for 25 kBtu/h medium-temperature
dedicated condensing units than a comparable unit using an R-454A-
compatible compressor. As such, and in the absence of more efficient
compressors of the same type compatible with R-454C, DOE tentatively
determined that to
[[Page 104673]]
achieve the standard proposed in the September 2023 NOPR (based on the
performance of R-448A), a medium-temperature walk-in refrigeration
system using a sub-150 GWP refrigerant may need to incorporate
additional design options beyond what DOE presumed in the September
2023 NOPR. To determine the cost of these additional design options,
DOE constructed the cost curves corresponding to use of the R-454C
compressor (with a roughly 2-percent reduction of AWEF2 for each
evaluated design) and calculated the additional cost to attain the
proposed AWEF2 by interpolating along the cost-efficiency curves. Based
on this analysis in the March 2024 NODA, DOE tentatively determined
that the additional manufacturer sales price (``MSP'') required to
achieve the AWEF2 at TSL 1 from the March 2024 NODA for less-than-150
GWP refrigerant would be $381 for 25 kBtu/h medium-temperature indoor
dedicated condensing units and $96 for 25 kBtu/h medium-temperature
outdoor dedicated condensing units. 89 FR 18555, 18563.
In the March 2024 NODA, DOE requested comment on the estimated
additional MSP associated with 25 kBtu/h medium-temperature indoor and
outdoor dedicated condensing units achieving the proposed AWEF2
standard levels while operating with a refrigerant with less than 150
GWP. 89 FR 18555, 18563.
In response to the March 2024 NODA, Lennox stated that the cost
increases appear low for the medium-temperature indoor and outdoor
dedicated condensing units achieving the proposed AWEF2 standard levels
while operating with a refrigerant with less than 150 GWP. Lennox
stated that due to the high glide of the lower-GWP refrigerants, the
reduction in cooling capacity will need to be offset in the product
design through increased coil surface or other design improvements that
will increase product cost. (Lennox, No. 87 at p. 5)
DOE notes that the 150-GWP MSP adders presented in the March 2024
NODA consider additional design improvements to achieve AWEF2 levels
based on sub-300 GWP refrigerants and do not represent the total cost
of converting a system designed for R-448A to use a sub-150 GWP A2L.
Given the lack of specific data and feedback on the 150 GWP cost
adders, DOE was unable to adjust the methodology used to determine
these adders. Therefore, in this final rule analysis, DOE maintained
the methodology used in the March 2024 NODA to determine 150-GWP cost
adders for medium-temperature 25 kBtu/h indoor and outdoor dedicated
condensing units. Using this methodology, DOE determined that the
DC.M.O.025 representative unit would increase in MPC by $128 when using
sub-150 GWP refrigerants for that standard level finalized in this
final rule, and the DC.M.I.025 representative unit would increase by
$390. Adders for each trial standard level analyzed are summarized in
Table IV.17. The approach to apply the 150-GWP cost adders as a
sensitivity to consumer impacts are discussed in section IV.F.2.a. of
this document.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.033
v. Final Rule Analysis Summary
In this final rule, DOE maintained the refrigerants analyzed in the
September 2023 NOPR analysis for dedicated condensing units and single-
packaged dedicated condensing systems. Specifically, DOE analyzed all
medium- and low-temperature representative units with R-448A as the
baseline refrigerant, which DOE has concluded is representative of sub-
300 GWP refrigerants that would likely be used in medium- and low-
temperature dedicated condensing systems. As discussed previously, for
DC.M.O.025 and DC.M.I.025, DOE considered the cost adder associated
with using a refrigerant that is sub-150 GWP. DOE analyzed R-290 as a
design option for medium- and low-temperature single-packaged dedicated
systems. Finally, DOE analyzed high-temperature single-packaged
dedicated systems using R-134a in this final rule analysis.
Representative Units
Table IV.18 lists the representative units analyzed in the
September 2023 NOPR for walk-in dedicated condensing units and single-
packaged dedicated systems.
[[Page 104674]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.034
In response to the representative units analyzed in the September
2023 NOPR, AHRI 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 kBtu/h with a rotary
compressor, then any unit with a capacity below 9 kBtu/h with a
hermetic compressor may be at a disadvantage. (AHRI, No. 72 at p. 6)
DOE analyzed two representative units for high-temperature
dedicated condensing systems in the September 2023 NOPR. The smallest
capacity that DOE analyzed was a 2 kBtu/h high-temperature single-
packaged dedicated system that used a hermetic reciprocating
compressor, not a rotary compressor. Thus, DOE considered the
efficiency impact of using reciprocating compressors for lower-capacity
units by analyzing a representative 2 kBtu/h unit and a representative
7 kBtu/h unit. In this final rule analysis, DOE analyzed the same
representative units for high-temperature single-packaged dedicated
systems.
AHRI commented that it had previously recommended that DOE add
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 for
high-temperature applications. AHRI highlighted that DOE did not
analyze high-temperature dedicated condensing units in the NOPR
analysis and
[[Page 104675]]
therefore is not proposing to establish an equipment class for high-
temperature dedicated condensing units. AHRI stated that DOE is
continuing to disallow the use of high-temperature dedicated condensing
units without a waiver. AHRI commented that due to the smaller size of
this market and the continual evolution to lower-GWP refrigerants, as
well as transitions to the new product safety standards (UL 60335-2-
89), DOE's stance is a disservice to an already smaller,
disenfranchised market segment. AHRI recommended that DOE analyze
indoor and outdoor high-temperature dedicated condensing systems with
capacities of 2, 9, and 25 kBtu/h. (AHRI, No. 72 at pp. 7-8)
As discussed in the May 2023 TP Final Rule, DOE's evaluation of the
wine cellar market indicates that specific high-temperature dedicated
condensing units are rarely, if ever, sold outside of matched-pair
configurations. 88 FR 28780, 28810. As such, in the May 2023 TP Final
Rule, DOE did not establish specific test provisions for high-
temperature dedicated condensing units tested alone. Id. Instead, DOE
assumed that high-temperature dedicated condensing units would be
tested as a part of matched pairs. Thus, a matching unit cooler would
be available for conducting a matched-pair test including any such
condensing unit, and manufacturers would not be required to petition
for waiver, as suggested by AHRI. Details of this decision not to
include test provisions specific for high-temperature dedicated
condensing units tested alone are outlined in the May 2023 TP Final
Rule. 88 FR 28780, 28810. Because there is no test procedure for high-
temperature dedicated condensing units tested alone and DOE has not
received any comments indicating that the analysis for single-packaged
high-temperature refrigeration systems would not be representative of
high-temperature matched pairs, DOE did not separately analyze such
products as representative units in this final rule. While high-
temperature matched refrigeration systems were not separately analyzed
as representative units, the energy conservation standards set forth in
this final rule for high-temperature systems encompass high-temperature
single-packaged dedicated systems and high-temperature matched
refrigeration systems.
In response to the September 2023 NOPR, AHRI commented that
multiple commenters had asked DOE to analyze additional representative
units at a broader range of capacities, but it noted that below
approximately 4 kBtu/h, DOE is simply maintaining the current AWEF but
converting it to AWEF2. AHRI commented that DOE is overlooking the fact
that lower-capacity compressors are less efficient than higher-capacity
compressors. AHRI stated that for the medium-temperature dedicated
condensing systems, the AWEF2 minimums do not take this into account,
thus continuing to exacerbate the original issue both commented on and
known to DOE. AHRI commented that the prior walk-in market had gone
down to 1/2-3/4 HP medium-temperature indoors, but because DOE did not
analyze hermetic reciprocating compressors originally, it has been
impossible to meet the minimum AWEF in many cases. (AHRI, No. 72 at pp.
6-7)
As discussed in the September 2023 NOPR, DOE did not analyze
medium-temperature dedicated condensing units with a capacity less than
4 kBtu/h, because DOE tentatively determined that those systems would
have to be equipped with all available design options to meet the
current standards. DOE notes that despite the technologies necessary
for these units to achieve minimum AWEF2 standards, there are medium-
temperature dedicated condensing systems certified in the CCD. As such,
DOE did not evaluate higher efficiency levels for medium-temperature
dedicated condensing units with capacity less than 4 kBtu/h in the
September 2023 NOPR; instead, DOE proposed to maintain the current
standard level for this equipment, but convert it from the current AWEF
metric to the AWEF2 metric based on the appendix C1 test procedure. 88
FR 60746, 60774. This tentative determination was an acknowledgement
that, among other factors, smaller-capacity compressors used in these
units are less efficient than the larger-capacity compressors used in
larger units. Based on testing and analysis conducted, DOE has
determined that converting AWEF to AWEF2 at the baseline efficiency
level does not result in more stringent standards. As such, in this
final rule analysis DOE is not analyzing medium-temperature dedicated
condensing units below 4 kBtu/h for the same reasons outlined in the
September 2023 NOPR.
For the reasons outlined previously, in this final rule DOE
analyzed the same representative units for dedicated condensing units
and single-packaged dedicated systems that it analyzed in the September
2023 NOPR.
Design Options
i. Design Options Analyzed for NOPR
In the September 2023 NOPR, DOE used a design-option approach to
evaluate potential efficiency improvements for walk-in dedicated
condensing units and single-packaged dedicated systems. 88 FR 60746,
60768. DOE considered the technologies listed in Table IV.19 as design
options for dedicated condensing units and single-packaged dedicated
systems in the September 2023 NOPR.
[[Page 104676]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.035
BILLING CODE 6410-01-C
ii. More Efficient Single-Speed Compressors
In the September 2023 NOPR, DOE analyzed higher-efficiency
compressors as a design option for dedicated condensing units and
single-packaged dedicated systems. 88 FR 60746, 60777. The higher-
efficiency compressor design options included both higher-efficiency
single-speed compressors and variable-speed compressors. As discussed
in section 5.7.2.1 of the September 2023 NOPR TSD, DOE did not analyze
more efficient single-speed compressors for medium- and low-temperature
dedicated condensing units due to concerns that an analysis based on
more efficient semi-hermetic compressors would not be achievable by
scroll compressor technology and therefore could limit or eliminate
scroll compressor technology for which there is functionality to the
consumer; instead, DOE only analyzed variable-speed compressors as a
compressor design option for these equipment classes and did not
analyze any changes to type of compressor (i.e., scroll or semi-
hermetic) at higher efficiency levels for a given representative unit.
For single-packaged dedicated systems, DOE considered both higher-
efficiency single-speed compressors and variable-speed compressors in
the September 2023 NOPR analysis.
In response to the September 2023 NOPR, ASAP et al. and the CA IOUs
recommended that DOE analyze higher-efficiency single-speed
compressors, without changing compressor type, as design options for
dedicated condensing units (i.e., swapping a less efficient scroll
compressor for a more efficient scroll compressor). These comments are
summarized in the March 2024 NODA. In response to these comments, in
the March 2024 NODA, DOE analyzed more efficient single-speed
compressors for medium- and low-temperature dedicated condensing units.
89 FR 18555, 18560-18561. DOE identified higher-efficiency single-speed
compressors that could be incorporated into the following
representative units: DC.M.O.054, DC.M.I.054, and DC.M.O.124. Id.
Details of this analysis can be found in the March 2024 NODA. Id.
In response to the March 2024 NODA, DOE received the following
comments. The CA IOUs supported DOE's updated walk-in refrigeration
system analysis presented in the March 2024 NODA, specifically DOE's
evaluation of a high-efficiency single-speed compressor design option
for certain equipment classes. The CA IOUs encouraged DOE to further
investigate higher-efficiency compressors as a design option for all
walk-in refrigeration system equipment classes in the next rulemaking
and after the commercial refrigeration market has completed the
transition to low-GWP refrigerants. (CA IOUs, No. 91 at p. 2) DOE may
evaluate the compressor market when beginning any future rulemakings to
understand which units may have more efficient single-speed compressors
available as a design option.
AHRI and Lennox stated they do not agree that selecting a larger
compressor is reasonable for increasing AWEF, as not every model will
have a larger compressor available. (AHRI, No. 86 at pp. 7-8; Lennox,
No. 87 at p. 5) AHRI requested to see real-world testing of compressors
in units to evaluate this change. AHRI stated that looking at
compressor data alone is not reflective and suggested that the
interaction between compressors, coil designs, airflow levels, and
refrigerant characteristics needs to be validated to determine
performance. (AHRI, No. 86 at pp. 7-8)
DOE notes that it identified a range of single-speed compressors
from 50 kBtu/h to 60 kBtu/h with EERs higher than the baseline
compressor(s) analyzed for the DC.M.O.054, DC.M.I.054, and DC.M.O.124
representative units. To analyze this range of more efficient
compressors, DOE selected a compressor that had larger capacity than
the baseline compressor. DOE selected this compressor because its EER
was in line with the capacity versus the EER trend of higher-efficiency
scroll compressors. The capacity of the higher-efficiency compressor
selected for the analysis of this representative unit did not play into
its selection, nor would it cause the representative unit to be more
efficient than if a lower-capacity compressor with the same EER were
selected. While the selected compressor is larger than the baseline
compressor, DOE has determined it is still representative of this
capacity range that the representative unit analyzes. DOE has
determined that manufacturers would be able to select a higher-
efficiency compressor from this range
[[Page 104677]]
with a capacity that best suits their needs.
DOE's refrigeration system analysis for the March 2024 NODA did
evaluate a compressor's impact on the refrigeration system as a whole,
including condenser coil and condenser fan characteristics. DOE is
unable to conduct real-world testing for every representative unit with
every configuration of design options analyzed in this final rule due
to time and resource constraints that make such a task unrealistic.
Instead, DOE has made use of the most representative data available to
model the performance of representative units to the best of its
ability. DOE notes that publicly available compressor performance
coefficients retrieved from manufacturer literature have been a key
component of all DOE's walk-in refrigeration systems analyses including
the analysis endorsed by the ASRAC Working Group.\46\ As such, DOE has
determined that compressor performance coefficients are a
representative method to estimate the energy consumption and mass flow
of compressors available on the market today. DOE is maintaining this
method of analyzing compressors in this final rule analysis.\47\
---------------------------------------------------------------------------
\46\ ASRAC Working Group transcripts are docketed at
regulations.gov/docket/EERE-2015-BT-STD-0016/document.
\47\ Compressor coefficients used in this final rule analysis
can be found on the ``Comp DB'' tab of the final rule refrigeration
systems engineering analysis spreadsheet docketed at
regulations.gov/docket/EERE-2017-BT-STD-0009/document.
---------------------------------------------------------------------------
In this final rule, DOE is maintaining the higher-efficiency
single-speed compressor analysis for the following representative
units, as analyzed for the March 2024 NODA: DC.M.O.054, DC.M.I.054, and
DC.M.O.124. Details of this analysis can be found in section 5.7.2.1 of
the final rule TSD.
iii. Condenser Fan Controls
In the September 2023 NOPR analysis, DOE analyzed variable-speed
condenser fans for outdoor dedicated condensing units and outdoor
single-packaged dedicated systems. 88 FR 60746, 60777. As discussed in
the September 2023 NOPR, when analyzing variable-speed condenser fans,
DOE only considered variable-speed motors and controls, not two-speed
motors and controls. 88 FR 60746, 60776. As stated in the September
2023 NOPR, this decision was based on manufacturer interviews and DOE's
analysis, which showed that fully variable-speed fans are more
effective at increasing a unit's efficiency than two-speed fans and
that the costs for variable- and two-speed electronically commutated
motors (``ECMs'') are similar. Id.
In response, the CA IOUs recommended that DOE include two-speed
condenser fan modulation as a technology option, in addition to
considering fan speed cycling and variable-speed modulation. The CA
IOUs disagreed with DOE's conclusion that variable-speed and two-speed
ECMs have similar costs, suggesting that the controllers for variable-
speed ECMs cost more to manufacture than those for two-speed ECMs. The
CA IOUs provided links to a walk-in condensing unit equipped with a
two-speed condenser fan, and two fan controllers. (CA IOUs, No. 76 at
p. 3)
Prompted by the CA IOUs' comments, DOE investigated the costs of
two-speed and variable-speed motor costs and the costs of necessary
controls for two-speed and variable-speed operation and was not able to
find a considerable difference in cost based on the information
available. In this final rule, DOE has determined that due to the
almost identical construction of two-speed and variable-speed ECMs, and
the similar complexity in two-speed and variable-speed controllers,
there is generally not a discernible difference between the cost of a
variable-speed condenser fan setup and that of a two-speed condenser
fan setup. Therefore, in this final rule, DOE is not analyzing two-
speed fans as a design option.
Additionally, AHRI commented that DOE should reconsider using
variable-speed condenser fan motors as a technology option. AHRI
commented that variable-speed condenser fan motors are typically used
in applications with modulating or two-stage compressors, versus single
stage; however, AHRI stated that modulating and two-stage compressors
are not needed to meet AWEF2 and would add significant costs if used.
(AHRI, No. 72 at p. 7)
In its analysis, DOE found that there are efficiency benefits of
using variable-speed condenser fans with single-stage compressors.
Specifically, variable-speed condenser fans allow for reduced fan speed
at lower ambient temperatures to reduce condenser head pressure.
Furthermore, AHRI commented that most dedicated condensing units
use condenser fan motors under 1 HP, and with supply of these fans
limited on the market, manufacturers would face challenges sourcing
variable-speed condenser fan motors across their portfolio of capacity
offerings since the availability for walk-in applications is also
limited. AHRI stated that suppliers of motors in the smallest size
range for walk-in use are difficult to find because walk-in market
motors are too large to use in the reach-in market and too small
compared to those needed in the air-conditioning condensing unit
market. The motors needed to achieve AWEF2 for dedicated condensing
unit product lines are not readily available off the shelf for the
sizes needed in these markets, with volumes inadequate to justify
development by condenser fan motor original equipment manufacturers
(``OEMs''). (AHRI, No. 72 at p. 7)
DOE notes that it has identified dedicated condensing systems with
variable-speed condenser fan motors.\48\ Thus, DOE has determined that
variable-speed condenser fan motors are available on the market.
Therefore, DOE is considering variable-speed condenser fan motors as a
design option in this analysis.
---------------------------------------------------------------------------
\48\ See a line of dedicated condensing units with variable-
speed fan motors as an optional specification in the following
catalog: www.heatcraftrpd.com/dA/6dcf836788/NEW-BN-TB-CU-AIRCOOLED-HAD-.5-6.pdf.
---------------------------------------------------------------------------
iv. Condensate Pan Heater
As discussed in the September 2023 NODA, DOE did not include drain
line heaters on any of the single-packaged dedicated condensing system
representative equipment analyzed in the September 2023 NOPR analysis,
as DOE tentatively determined that such devices would typically be
provided as a feature that may be optionally installed by a contractor.
88 FR 66710, 66714.
In response, the CA IOUs recommended that DOE consider condensate
pan heating technology options, such as water level sensors or hot gas
routing, for packaged systems. In response to an earlier exchange with
DOE in which DOE believed the CA IOUs referred to the drain line
heater, the CA IOUs stated that, in fact, they were referring to the
condensate pan heater inside the packaged system. The CA IOUs stated
that the condensate pan heater is usually installed by the manufacturer
on top of the walk-in box for indoor units, and they provided an
illustration of the difference between the drain line and condensate
pan heaters. The CA IOUs commented that manufacturers include the
condensate pan heater in the packaged system because the condensate
cannot be piped to a drain and must be evaporated. The CA IOUs
recommended that DOE consider technologies that reduce the energy use
of the condensate pan heater, such as water level sensors or hot gas
routing, as technology options for packaged systems. (CA IOUs, No. 76
at pp. 9-10)
[[Page 104678]]
Throughout investigative testing conducted to support this final
rule single-packaged dedicated system analysis, DOE has not encountered
a condensate pan heater like the one pictured in figure 6 of the CA
IOUs' comment. (CA IOUs, No. 76 at p. 10) DOE has calibrated the AWEF2s
of the efficiency levels analyzed in this final rule using results from
this testing. DOE did not include electric resistance condensate pan
heaters in its baseline representative units for single-packaged
dedicated systems. Therefore, DOE did not analyze any design options to
reduce the energy consumption of condensate pan heaters.
v. Design Option Order
In response to the September 2023 NOPR, ASAP et al. recommended
that, in general, DOE should ensure that the order of design options
analyzed in the engineering analysis prioritizes cost-effective design
options ahead of ones that are not cost-effective. (ASAP et al., No. 77
at p. 2)
In the September 2023 NOPR and March 2024 NODA, DOE generally
ordered design options by cost-effectiveness (i.e., AWEF2 improvement/
incremental cost). Design options with greater cost-effectiveness
(i.e., greater AWEF2 improvement per incremental cost) were implemented
before less cost-effective design options. In some cases, due to
performance characteristics of design options or manufacturer feedback,
less cost-effective design options preceded more cost-effective
options. For example, during interviews manufacturers indicated that if
they were to equip units with a variable-speed condenser fan they would
only consider ECMs, since all ECMs can be variable-speed if equipped
with a variable-speed controller. Therefore, the ECM condenser fan
design option always came before the variable-speed condenser fan
design option.
ASAP et al. recommended that DOE consider a standard level for
outdoor dedicated condensing units that assumes the use of a variable-
speed condensing fan (``VSCF''). ASAP et al. commented that according
to its and DOE's respective analyses, VSCFs would be a cost-effective
design option, particularly for the medium-temperature outdoor
dedicated condensing units. ASAP et al. stated that the combination of
design options at TSL 2 plus a VSCF would result in a discounted
lifetime operating cost of several hundred dollars less than that of
TSL 2. ASAP et al. recommended that DOE reorder the design options for
the outdoor DCU classes such that the addition of a VSCF comes before a
larger condensing coil and that DOE consider adopting standards that
reflect the use of a VSCF. (ASAP et al., No. 77 at pp. 1-2)
Variable-speed or cycling condenser fans are two other examples of
design options that required prerequisite design options. For most
representative units in DOE's analysis, these design options generally
did not improve the efficiency of a unit unless that unit was equipped
with a larger condenser coil. For this reason, DOE applied the larger
condenser coil design option before cycling or variable-speed condenser
fans, despite the larger condenser coil appearing to be a less cost-
effective design option in the September 2023 NOPR analysis and March
2024 NODA analysis.
DOE maintained the same design option ordering scheme for this
final rule analysis. The specific criteria for ordering design options
are discussed in Chapter 5 of the accompanying TSD.
vi. Larger Condenser Coils
In the September 2023 NOPR analysis, DOE analyzed improved
condenser coils for all dedicated condensing units and low- and medium-
temperature single-packaged dedicated systems. 88 FR 60746, 60777. In
response to this analysis, AHRI commented that DOE should not consider
increased condenser coils as a design option, because larger condenser
coils cannot be considered independent of considering fan motors and
fan blades. Additionally, AHRI commented that AHRI members have
received customer complaints about increased coil sizes that make the
unit footprint larger, which, AHRI states, is not always a customer
preference in certain applications. (AHRI, No. 72 at p. 7)
In the September 2023 NOPR analysis, when DOE applied the larger
condenser coil design option, the fan power was also increased to match
the airflow needed by a larger coil. This fan power increase was
modeled as either a larger fan or additional fans depending on the
magnitude of the condenser coil size increase. In either scenario, the
MPC of the representative unit accounts for the increased coil size as
well as either the larger fan size or added fans through increased cost
of motors, fan blades, and fan mounting assemblies. See section 5.7.2.2
of the NOPR TSD. Additionally, the September 2023 NOPR analysis
captured the MPC and shipping increases related to the larger case size
resulting from a larger condenser coil. In its review of the market,
DOE has identified existing dedicated condensing units that have larger
coil sizes consistent with the improved condenser coil design option
DOE analyzed. DOE is not aware of any impacts to consumers that would
prevent manufacturers implementing larger condenser coils for the
equipment classes this design option was analyzed for. Based on its
analysis, DOE has concluded that the increased condenser coil can be a
cost-effective design option and therefore is considering it for this
final rule.
vii. Floating Head Pressure Controls
In the June 2022 Preliminary Analysis, DOE analyzed head pressure
controls as a design option for outdoor dedicated condensing system
equipment classes. See section 5.7.2.7 of the preliminary analysis TSD
for details. Head pressure controls allow outdoor condensing units'
head pressure to ``float'' down to a minimum condensing pressure as the
ambient air temperature falls. This allows the compressor to operate
more efficiently and therefore reduces the power consumption of the
system without reducing the capacity. In the June 2022 Preliminary
Analysis DOE evaluated two design options pertaining to head pressure
control for the representative units of outdoor dedicated condensing
units and outdoor single-packaged dedicated systems analyzed. These two
design options were floating head pressure and floating head pressure
with an EEV.\49\ DOE assumed fixed head pressure would be the baseline
design. Based on information collected during previous rulemakings, DOE
determined the minimum condensing pressure associated with these design
options and converted all minimum condensing pressures to minimum
condensing dewpoint temperatures so that the values would be
refrigerant agnostic. DOE assumed this minimum condensing dewpoint
would apply at the lowest ambient rating condition (i.e., 35 [deg]F).
At the intermediate rating temperature of 59 [deg]F, DOE estimated the
head pressure for fixed and floating systems when using a TXV based on
testing results. DOE did not have testing results for a system with an
EEV, so DOE calculated the degree to which the pressure would ``float''
down based on an assumption that the condenser temperature difference
(i.e., difference between entering air and refrigerant temperature)
would scale with the capacity. DOE used test results and scaling to
estimate a minimum
[[Page 104679]]
dewpoint offset at 59 [deg]F. Minimum condensing dewpoints at the 35
[deg]F C test point and at the 59 [deg]F B test point are summarized in
Table IV.20.
---------------------------------------------------------------------------
\49\ Systems equipped with an EEV could potentially operate with
an even lower head pressure because the greater flexibility of the
electronic controls allows an EEV to have a wider range of orifice
open area without leading to unstable operation in warm ambient
conditions.
---------------------------------------------------------------------------
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.036
In addition to the minimum condensing dewpoints imposed by head
pressure control strategies, different compressor types have different
minimum condensing dewpoints. The minimum condensing dewpoint
temperatures for hermetic, semi-hermetic, scroll, and rotary
compressors used in the June 2022 Preliminary Analysis are listed in
Table IV.21. Therefore, DOE determined the minimum condensing dewpoints
at the B (59 [deg]F) and C (35 [deg]F) test points as the maximum of
the minimum condensing dewpoint allowed by the floating head pressure
control scheme and the compressor type of the representative unit. For
example, at the 35 [deg]F C test condition, representative units using
hermetic compressors would not be able to float down to a minimum
condensing dewpoint of 67 [deg]F, even if installed with floating head
pressure with an EEV, because those systems would be constrained to the
higher of the minimum condensing dewpoints based on compressor type and
head pressure control scheme; therefore, at the 35 [deg]F C test
condition, representative units with hermetic compressors would only be
able to float to a head pressure that corresponds to a minimum
condensing dewpoint temperature of 85 [deg]F.
[GRAPHIC] [TIFF OMITTED] TR23DE24.037
For the September 2023 NOPR analysis, DOE tentatively determined
that the minimum condensing dewpoint temperatures used for the floating
head pressure design option in the June 2022 Preliminary Analysis were
higher than needed. 88 FR 66710, 66715-66716; section 5.2.7.2 of the
NOPR TSD. DOE aggregated interview feedback and tentatively determined
that 71.8 [deg]F is a representative minimum condensing dewpoint at the
C test for walk-in refrigeration systems using the floating head
pressure design option. DOE assumed that the difference between the C
test and B test minimum condensing dewpoints would remain the same as
the difference between the June 2022 preliminary analysis C and B test
minimum condensing dewpoints. During interviews, manufacturers
indicated that floating head pressure was a standard design on all
walk-in condensing systems and that this minimum condensing dewpoint
temperature could be achieved by systems using TXVs. Additionally,
during interviews manufacturers stated that changing a TXV for an EEV
would not allow for lower head pressure settings and manufacturers had
received feedback from customers and field technicians that lower head
pressure settings even on equipment with EEVs result in decreased
reliability and increased warranty claims. Therefore, DOE did not
consider an additional step down in head pressure (and minimum
condensing dewpoint) associated with EEVs. The minimum condensing
dewpoints used in the September 2023 NOPR analysis are summarized in
Table IV.22.
[[Page 104680]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.038
Based on testing results and feedback from manufacturer interviews,
DOE tentatively determined that most dedicated condensing systems would
need this floating head pressure design option to achieve the current
AWEF standards. As such, DOE considered floating head pressure controls
in the baseline designs for all outdoor dedicated condensing system
representative units in the September 2023 NOPR analysis and did not
consider floating head pressure controls with an EEV as a design
option. FR 66710, 66715-66716; section 5.2.7.2 of the NOPR TSD.
In response to the September 2023 NOPR, the CA IOUs commented that
EEVs save energy compared to traditional floating head pressure coupled
with a mechanical TXV, because EEVs have a much lower pressure
differential requirement and therefore can function at lower discharge
pressures than a mechanical TXV. (CA IOUs, No. 76 at p. 4) The CA IOUs
stated that the EEV would only impact utility if it were improperly
controlling reduction in head pressure or the compressor were oversized
without variable-capacity control. (CA IOUs, No. 76 at pp. 4-5)
The CA IOUs also commented that DOE should consider a broader range
of minimum condensing dewpoint temperatures than what was shown in
Table 5.7.11 of the NOPR TSD to account for the energy savings from
EEVs. The CA IOUs stated that semi-hermetic compressors can have
saturated condensing temperatures (``SCTs'') as low as 55 [deg]F and
scroll compressors can have SCTs as low as 40 [deg]F. (CA IOUs, No. 76
at pp. 6-7)
The CA IOUs commented that DOE's statement that a lower condensing
dewpoint temperature than what is published in compressor literature
may lead to concerns about potential unit reliability only applies to
systems with poor piping practices, bad superheat settings, compressor
cycling, and oil return issues. The CA IOUs stated that a proper system
should benefit from lower head pressure. (CA IOUs, No. 76 at pp. 7-8)
Similarly, ASAP et al. recommended that DOE consider EEVs as a
design option for outdoor refrigeration systems. ASAP et al. commented
that EEVs could allow refrigeration systems to operate at lower head
pressure relative to TXVs, saving energy. ASAP et al. stated that EEVs
are much more precise than mechanical TXVs in controlling temperatures
and pressures; thus, a refrigeration system using an EEV may be able to
operate at lower head pressures without impacting utility or
reliability. ASAP et al. further commented that EEV floating head
pressure controls are used in the market today and that the technology
is likely to be implemented by manufacturers to improve outdoor
refrigeration system efficiency. (ASAP et al., No. 77 at pp. 2-3) ASAP
et al. reiterated their comments about EEVs in response to the March
2024 NODA. (ASAP et al., No. 90 at p. 1)
As previously discussed in this section, DOE received feedback
during manufacturer interviews that minimum condensing dewpoints lower
than 71.8 [deg]F affect walk-in refrigeration system reliability and
increase warranty claims regardless of the type of expansion device
used in the system. Regardless of the type of expansion valve (i.e.,
TXV or EEV) used in a system, a lower head pressure results in
subcooling, which is more difficult to control, leading to a liquid-
vapor mixture instead of a pure liquid entering the expansion device.
As such, if manufacturers specified lower head pressures, WICF
installers may adjust these back to a condensing dewpoint of 71.8
[deg]F when installing in the field, negating any potential savings.
DOE notes that different compressors within the same type have
different minimum condensing dewpoints (i.e., SCTs, as referred to by
the CA IOUs). The values presented in Table 5.7.11 of the September
2023 NOPR TSD are intended to be representative of a typical minimum
condensing dewpoint for the given compressor type, not the absolute
minimum possible. DOE reviewed compressor performance data for the
scroll and semi-hermetic compressors analyzed in this final rule
analysis and determined that the minimum condensing dewpoint values in
Table 5.7.11 of the September 2023 NOPR TSD are too conservative. Based
on publicly available compressor performance data, DOE determined that
50 [deg]F is a representative minimum condensing dewpoint for scroll
compressors and 60 [deg]F is a representative minimum condensing
dewpoint for semi-hermetic compressors. Therefore, DOE updated the
minimum condensing dewpoints assumed for scroll and semi-hermetic
compressors in this final rule analysis. As discussed previously, DOE
determines the minimum condensing dewpoints at the B (59 [deg]F) and C
(35 [deg]F) test points as the maximum of the minimum condensing
dewpoint allowed by the floating head pressure control scheme and the
compressor type of the representative unit. Since the floating head
pressure control scheme only allows a minimum condensing temperature of
71.8 [deg]F for the C test, and 73.5 [deg]F for the B test, the
reduction in minimum condensing dewpoint for scroll and semi-hermetic
compressors does not impact this final rule analysis.
Additionally, as manufacturers do not have control of piping
practices, superheat settings, and equipment oversizing in the field,
they are forced to accommodate a variety of field installation
situations with conservative factory settings and recommendations for
minimum condensing dewpoint temperature. As specified in section
3.5.2.4 of the appendix C1 test procedure, walk-in refrigeration
systems must be set up for testing according to applicable field
installation instructions. While a reduction in head pressure may be
possible to reduce energy for certain installations, DOE does not have
confidence that this reduction in head pressure through the use of an
EEV would be possible in all potential installation scenarios that a
basic model could be used in.
[[Page 104681]]
At this time, DOE is not considering a reduction to the floating
head pressure design options' minimum head pressure value in this final
rule analysis and is not adding a design option to further reduce the
minimum condensing dewpoint by using an EEV.
viii. Variable-Speed Compressors
In the September 2023 NOPR analysis, DOE considered variable-speed
compressors as a maximum-technology design option for dedicated
condensing units and low- and medium-temperature single-packaged
dedicated systems. 88 FR 60746, 60776.
AHRI commented that DOE is considering variable-capacity
compressors to meet the max-tech levels; however, manufacturers could
face challenges sourcing variable-capacity compressors. (AHRI, No. 72
at p. 6) Based on compressor manufacturer literature, DOE has
determined that variable-capacity compressors are available for walk-in
refrigeration systems at this time. Therefore, DOE is considering
variable-capacity compressors as a design option for this final rule
analysis.
ix. Design Options Analyzed for Final Rule Analysis
See Table IV.23 for a full list of design options analyzed for
dedicated condensing units and single-packaged dedicated systems in
this final rule analysis.
[GRAPHIC] [TIFF OMITTED] TR23DE24.039
BILLING CODE 6410-01-C
The specifics of modeling each design option are discussed in
chapter 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 anticipated changes
resulting from potential energy conservation standards against the
baseline model. 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.
There are currently energy conservation standards for medium- and
low-temperature indoor dedicated condensing systems and for medium- and
low-temperature outdoor dedicated condensing systems. These standards
were established based on an analysis of dedicated condensing unit
representative units using the AWEF metric and test procedures in
appendix C. In the May 2023 TP Final Rule, DOE established a new test
procedure and metric, AWEF2, for walk-in refrigeration systems in
appendix C1. In the September 2023 NOPR, DOE set baseline efficiency
levels for medium- and low-temperature dedicated condensing unit
representative units at the current minimum standard level using the
appendix C test procedure (see appendix C to subpart R to 10 CFR part
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. When transitioning from one metric to another DOE
must ensure that new standards based on the new metric do not result in
backsliding. The method DOE used in the September 2023 NOPR to set
baseline levels for units currently subject to standards accomplishes
this by translating current AWEF baselines to AWEF2 baselines.
In the May 2023 TP Final Rule DOE also established new test
procedures for single-packaged dedicated systems and high-temperature
refrigeration systems. For this equipment that was not analyzed in
previous walk-in rulemakings 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. All analysis for
these equipment classes was done according to appendix C1.
In response to the baselines set in the September 2023 NOPR, AHRI
and Hussmann commented that on the 10.0 tab of the NOPR analysis
spreadsheet, the baseline minimum condensing dewpoint temperature is
much higher than that of currently produced equipment. AHRI and
Hussmann suggested that it is currently more likely
[[Page 104682]]
that baseline units are in the 80 [deg]F range and not the 101 [deg]F
range. AHRI and Hussmann commented that the TSD references 180 psig
head pressure, but that is not represented by actual refrigerant
properties; likewise, AHRI and Hussmann commented that in the NOPR, DOE
states head pressure will float down to 150 psig, but that value is not
reflected in the analysis spreadsheet. (AHRI, No. 72 at p. 19;
Hussmann, No. 75 at p. 9)
As discussed in the Floating Head Pressure Controls subsection
under Design Options, the fixed head pressure design option that AHRI
and Hussmann reference with the 101 [deg]F minimum condensing dewpoint
was not considered as a baseline design option for any walk-in
refrigeration system. Based on manufacturer feedback during interviews,
DOE determined that all walk-in refrigeration systems employ the
floating head pressure design option at baseline. Therefore, DOE did
not analyze any representative units with fixed head pressure in the
September 2023 NOPR analysis. DOE is maintaining that all
representative units of dedicated condensing units will have floating
head pressure at baseline efficiency in this final rule analysis. See
appendix 5A of the final rule TSD, which shows a full list of design
options that each representative unit includes at baseline.
AHRI commented that past walk-in analyses of medium- and low-
temperature units mistakenly focused only on scroll compressors and
discus semi-hermetic reciprocating compressors. AHRI stated that as a
result, the majority of walk-in OEMs transitioned from hermetic
reciprocating compressors to scroll compressors on smaller-capacity
units and similarly discus semi-hermetic reciprocating compressors on
larger-capacity systems. AHRI commented that DOE never fully evaluated
higher-efficiency fixed-speed reciprocating compressors in the previous
WICF energy conservation standards rules. AHRI stated that this
oversight rendered OEMs unable to use these market-standard compressors
as the baseline. (AHRI, No. 72 at p. 6)
As mentioned previously, DOE uses products currently on the market
to determine the characteristics of baseline representative units. DOE
used compressor types of baseline units in the September 2023 NOPR
based on currently available models. As AHRI indicated in its comment,
the majority of these representative units used scroll and semi-
hermetic compressors. However, DOE found several single-packaged
dedicated condensing systems use hermetic reciprocating compressors.
Therefore, DOE analyzed these representative units with hermetic
reciprocating compressors rather than scroll or semi-hermetic
compressors at the baseline in the September 2023 NOPR analysis. DOE is
maintaining the compressor types used at baseline in the September 2023
NOPR in this final rule analysis.
AHRI and Lennox commented that many of the technologies outlined
and listed as increasing efficiency are already in use on some standard
equipment and would not further increase efficiency on those products.
AHRI and Lennox listed these technologies already in use in some
products as: higher-efficiency condenser fan motors; off-cycle
evaporator fan controls; head pressure controls; crankcase heater
controls; higher-efficiency evaporator fan motors; ambient subcooling;
improved condenser coil; variable-speed condenser fan control; and
evaporator fan control--on-cycle. (AHRI, No. 72 at p. 5; Lennox, No. 70
at pp. 4-5)
DOE recognizes that some design options analyzed may already be in
use in standard equipment. For some representative units, higher-
efficiency design options are used at baseline to reach the current
AWEF standard. For example, the DC.M.I.009 representative unit has a
larger condenser coil and ECM at baseline. On the contrary, the
DC.M.O.009 representative unit has no higher-efficiency design options
at baseline. Thus, DOE has concluded that the design options analyzed,
including those mentioned by AHRI and Lennox, could be implemented in
equipment to improve efficiency of certain representative units.
In response to comments received on the September 2023 NOPR, DOE
revised the assumptions about baseline unit characteristics by
increasing the off-cycle power and crankcase heater power of low-
temperature dedicated condensing system equipment classes in the March
2024 NODA. 89 FR 18555, 18561-18562. As discussed in the March 2024
NODA, these adjustments were based on a review of manufacturer
specifications for crankcase heater wattage and a review of low-
temperature off-cycle power test data. Id.
In response to these off-cycle power increases, AHRI stated that
the updated crankcase heater wattages for low-temperature dedicated
condensing units and single-packaged dedicated systems are still low.
AHRI requested actual test data with all test conditions reflective of
off-cycle power for a wider sampling of crankcase heaters as well as
effects on low-temperature outdoor units. AHRI stated it is aware that
there are multiple methodologies OEMs are using to control units
operating at low-temperature conditions, and it would like to see DOE
evaluate how controls play into off-cycle power by testing real-world
products. (AHRI, No. 86 at p. 8) RSG stated that the crankcase heater
power values presented in Table II.4 of the NODA appear to be
sufficient. RSG asked if a system incorporates more than one
compressor, whether the crankcase heater allowance multiplies with the
number of compressors and how that would factor into the calculations.
(RSG, No. 89 at p. 2)
The off-cycle power data DOE used to inform the crankcase heater
power and off-cycle controls power for low-temperature dedicated
condensing systems is summarized in Table IV.24. DOE's March 2024 NODA
analysis estimations are on average 3 percent greater than the measured
power of the tested units. Additionally, DOE has determined that unit
number 4 is an outlier and that the controls present on this unit that
account for the additional off-cycle power are not generally
representative of low-temperature units currently on the walk-in
market. DOE's estimations of crankcase heater power are a function of a
unit's net capacity and do not consider the number of compressors
specified for the unit. Based on this test data and manufacturer
specifications for crankcase heater wattages, DOE has determined that
the methodology used to calculate the low-temperature dedicated
condensing unit off-cycle power for the March 2024 NODA analysis is
representative and, therefore, DOE used the same methodology for this
final rule analysis. Details of this methodology are discussed in
Chapter 5 of the final rule TSD.
BILLING CODE 6410-01-P
[[Page 104683]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.040
RSG suggested that off-cycle power for dedicated condensing units
will be different than for single-packaged dedicated systems. RSG
stated that off-cycle power for single-packaged dedicated systems may
include evaporator fans, crankcase heaters, electronic controls,
solenoids, and EEVs. (RSG, No. 89 at p. 2)
Both dedicated condensing units and single-packaged dedicated
systems incorporate off-cycle evaporator fan power into their AWEF2
calculations. The DOE test procedure at appendix C1 for dedicated
condensing units tested alone specifies that off-cycle evaporator fan
power will be 20 percent of on-cycle evaporator fan power. See AHRI
1250-2020 equations 118, 137, 163, and 180. Depending on which
evaporator fan control design option the baseline representative unit
is equipped with (i.e., no controls, cycling controls, or variable-
speed controls), the baseline single-packaged dedicated systems
analyzed in the March 2024 NODA may have baseline off-cycle evaporator
fan power that is equal to 100, 50, or 20 percent of on-cycle
evaporator fan power. DOE's single-packaged dedicated system off-cycle
test data suggests that single-packaged dedicated systems will have
ancillary off-cycle power (i.e., off-cycle power excluding evaporator
fan power) very similar to that of dedicated condensing units. DOE has
validated the single-packaged dedicated system ancillary off-cycle
power assumptions used in the March 2024 NODA analysis with this test
data. See Table IV.25 for a comparison of single-packaged ancillary
off-cycle test data and ancillary off-cycle power assumptions from the
March 2024 NODA engineering analysis. DOE has determined that unit
number 4 is not representative of typical single-packaged dedicated
system off-cycle power, as the crankcase heater is a lower wattage than
recommended by the compressor manufacturer.
[GRAPHIC] [TIFF OMITTED] TR23DE24.041
BILLING CODE 6410-01-C
DOE maintained the baselining methodology from the September 2023
NOPR and March 2024 NODA in this final rule analysis.
Higher Efficiency Levels
Consistent with the analysis for previous walk-in refrigeration
system
[[Page 104684]]
rulemakings (i.e., the June 2014 Final Rule and the July 2017 Final
Rule), in the September 2023 NOPR, DOE added the remaining applicable
design options that were not used in the baseline of 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 response to the September 2023 NOPR, DOE received comments from
stakeholders regarding the higher efficiency levels analyzed for
dedicated condensing units and single-packaged dedicated systems.
The CA IOUs recommended that DOE consider including additional
design options (e.g., variable-speed evaporator fans, improved
compressors, and larger condensing coils) for low-temperature outdoor
single-packaged systems, as they are included for indoor low-
temperature single-packaged systems. The CA IOUs stated that many
indoor and outdoor systems offered by the same manufacturer differ only
by their weatherproof housing, while the internal components remain the
same. The CA IOUs commented that both indoor and outdoor single-
packaged systems include reciprocating and scroll compressor options,
resulting in different efficiencies. The CA IOUs also stated that
manufacturers offer condensing coils of differing sizes, and
manufacturers offer different efficiency condensing fan motor options
(i.e., ECM and PSC) for outdoor systems. Thus, the CA IOUs recommended
that DOE consider additional design options, including larger
condensing coils, for outdoor low-temperature packaged systems. (CA
IOUs, No. 76 at pp. 10-11) DOE notes that many of the additional design
options indicated by the CA IOUs (e.g., variable-speed evaporator fans
and larger condensing coils) are included in the baseline design for
the representative units analyzed for outdoor low-temperature single-
packaged dedicated units. DOE did not analyze improved compressors for
outdoor low-temperature single-packaged dedicated system representative
units, as the improved compressors (hermetic reciprocating propane
compressors) identified for these units did not improve the AWEF2 of
outdoor units. Appendix 5A of the final rule TSD shows a full list of
design options that each representative unit includes at baseline.
AHRI asserted that the low-temperature and indoor medium-
temperature dedicated condensing system equipment classes are already
the hardest categories to meet minimum AWEF and when considering the
current AWEF standards, the proposed changes by DOE would require
significant design modifications to achieve the new minimum AWEF2.
(AHRI, No. 72 at p. 6)
DOE notes that it is obligated to consider all efficiency levels
above baseline. Additionally, DOE considers the significance of the
modifications necessary to achieve these efficiency levels through the
cost analysis and the MIA. See section IV.C.2 for discussion of the
cost analysis and section IV.J for discussion of the MIA. Some
efficiency levels above baseline for the equipment classes specified by
AHRI were found to be cost-effective and technologically feasible, so
they were included in the proposed standard level in the September 2023
NOPR. DOE is maintaining the higher efficiency levels analyzed in the
September 2023 NOPR analysis in this final rule analysis and is
therefore analyzing the design options mentioned in AHRI's comment in
this final rule analysis.
DOE maintained the methodology from the September 2023 NOPR to
determine higher efficiency levels in this final rule analysis.
Engineering Spreadsheet
As part of the September 2023 NOPR, DOE published the engineering
spreadsheet used to analyze dedicated condensing units and single-
packaged dedicated systems (``September 2023 refrigeration system
engineering spreadsheet''). See EERE-2017-BT-STD-0009-0052. DOE
received specific stakeholder feedback regarding the content of the
engineering spreadsheet, which is summarized and addressed in the
following paragraphs.
AHRI and Hussmann commented that in the NOPR analysis spreadsheet,
the formulas in cells F7 and F8 of tab 2.0 and cell E7 of tab 7.0 do
not align with that found in the TSD. AHRI and Hussmann recommended DOE
provide explanations for the calculations so a valid review could be
done. (AHRI, No. 72 at p. 2; Hussmann, No. 75 at p. 9) As discussed in
the September 2023 NOPR TSD, DOE developed a correlation between
condenser core volume \50\ and condenser load divided by condenser
temperature difference. See section 5.7.2.2 of the September 2023 NOPR
TSD. The equations in cells F7 and F8 of the September 2023
refrigeration system engineering spreadsheet use those correlations to
calculate condenser coil core volume for the baseline and improved
condenser coils.
---------------------------------------------------------------------------
\50\ DOE defined ``condenser core volume'' as fin area times
finned length.
---------------------------------------------------------------------------
AHRI and Hussmann commented that in the NOPR analysis spreadsheet,
DOE assumes that all coil rows are 1.08 inches; however, AHRI and
Hussmann commented that some coils use different row spacing, which
could be negatively impacted. (AHRI, No. 72 at p. 2; Hussmann, No. 75
at p. 9) DOE used 1.08 inches as a representative value for a coil row
in the September 2023 NOPR based on teardowns, review of diagrams in
product literature, and manufacturer interview feedback. DOE has
determined that 1.08 inches appropriate represents the sizing of a coil
row. Thus, in this final rule, DOE is maintaining a representative coil
row size of 1.08 inches in the final rule engineering analysis
spreadsheet.
AHRI and Hussmann recommended that DOE fix the errors in the NOPR
analysis spreadsheet and redo all analyses before finalizing any new
targets. (AHRI, No. 72 at p. 2; Hussmann, No. 75 at p. 9) DOE made
several corrections to the September 2023 refrigeration system
engineering spreadsheet for the March 2024 NODA. Stakeholder comments
that informed these corrections are summarized and addressed in the
March 2024 NODA. 89 FR 18555, 18563-18564. Additionally, DOE published
an updated engineering spreadsheet for single-packaged dedicated
equipment and dedicated condensing units. See EERE-2017-BT-STD-0009-
0080. DOE did not receive any further comments regarding the
engineering analysis spreadsheet in response to the March 2024 NODA.
DOE posted an updated refrigeration systems engineering spreadsheet for
this final rule analysis.\51\
---------------------------------------------------------------------------
\51\ See regulations.gov/docket/EERE-2017-BT-STD-0009/document.
---------------------------------------------------------------------------
f. Unit Coolers
Refrigerants Analyzed
As discussed in section IV.C.1.e of this document, the October 2023
EPA Technology Transitions Final Rule requires the use of low-GWP
refrigerants for walk-in coolers and freezers. A key concern about the
transition to lower-GWP refrigerants relative to the performance of
refrigeration systems is the potential for higher refrigerant glide to
impact performance; however, as discussed previously in section
IV.C.1.e of this document, increased refrigerant glide increases unit
cooler performance. DOE based its unit cooler analysis on low-glide
refrigerants. Specifically, DOE used R-404A to analyze medium- and low-
temperature unit coolers and R-
[[Page 104685]]
134a to analyze high-temperature unit coolers. 88 FR 60746, 60780. DOE
expects that high-glide refrigerants would have better performance,
thus it is expected that unit coolers will be able to meet the adopted
standards with the refrigerant changes mandated by the October 2023 EPA
Technology Transitions Final Rule.
DOE did not receive any comments in response to the refrigerants
analyzed in the September 2023 NOPR for unit coolers. In response to
the March 2024 NODA, Lennox stated that further test evaluation
indicates the efficiency and capacity performance of R-454A is actually
3 to 4 percent lower than that of R-448A in unit coolers. (Lennox, No.
70 at p. 7) DOE notes that R-404A, not R-448A, was used in the unit
cooler analysis. DOE analyzed the capacity of unit coolers certified in
the CCD and compared identical unit cooler models certified with both
R-404A and R-448A. DOE found that capacity for R-404A unit coolers was
at least 25 percent less and on average 34 percent less than equivalent
R-448A unit coolers. This results in at least a 6-percent reduction and
an average reduction of 9 percent in AWEF2 when swapping R-448A for R-
404A. As such, based on this and Lennox's assertions in its comments,
DOE expects any analysis conducted using R-404A to be a conservative
approach and that unit coolers would not suffer a performance penalty
when switching from R-404A to R-454A. In this final rule analysis, DOE
is maintaining the refrigerants analyzed in the September 2023 NOPR and
using R-404A to analyze medium- and low-temperature unit coolers and R-
134A to analyze high-temperature unit coolers.
Representative Units
The representative unit cooler capacities analyzed in the September
2023 NOPR are listed in Table IV.26.
[GRAPHIC] [TIFF OMITTED] TR23DE24.042
DOE did not receive comment on the representative unit cooler
capacities analyzed in the September 2023 NOPR. Therefore, in this
final rule, DOE analyzed the same representative units for unit coolers
that it analyzed in the September 2023 NOPR.
Efficiency Levels for Medium- and Low-Temperature Unit Coolers
In the September 2023 NOPR, DOE analyzed medium- and low-
temperature unit coolers using an efficiency-level approach. 88 FR
60746, 60781. 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 final rule, this
database is referenced as ``the unit cooler performance database.'' The
following subsections describe how the unit cooler performance database
was constructed and how it was used to define the efficiency levels
analyzed in this final rule. Additionally, comments pertaining to the
unit cooler performance database and the unit cooler efficiency
analysis that DOE received in response to the September 2023 NOPR and
March 2024 NODA are summarized and addressed.
i. Constructing the Unit Cooler Performance Database
As discussed in the September 2023 NOPR, the CCD includes few unit
coolers rated above baseline. 88 FR 60746, 60781. However, after
evaluating certified unit cooler capacities, DOE 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 AWEF2 in accordance with
appendix C1 to subpart R of 10 CFR part 431 using certified capacity
from the CCD, fan powers published in manufacturer literature, and
default defrost power calculations based on test procedure equations in
AHRI 1250-2020. DOE posted to the docket a version of the unit cooler
performance database with identifying information and information
obtained through confidential manufacturer interviews removed. See
EERE-2017-BT-STD-0009-0064.
In response to the NOPR, AHRI and Lennox commented that DOE's unit
cooler performance database should have used equation C45 of AHRI 1250-
2020 to calculate the defrost heat (Btu/h) for low-temperature unit
coolers instead of equations C25, C26, and C27 of AHRI 1250-2020, which
are for unit coolers with hot gas defrost. (AHRI, No. 72 at p. 9;
Lennox, No. 70 at p. 5) Equation C45 from AHRI 1250-2020 appendix C is
used to calculate the defrost heat of single-packaged
[[Page 104686]]
dedicated systems, matched pairs, or unit coolers tested alone, but all
of these equipment have measured defrost power during the defrost test.
As the measured defrost power of unit coolers is not certified in the
CCD or readily published in most manufacturer literature, DOE instead
estimated a representative defrost power for each unit cooler in the
database using the defrost calculations for dedicated condensing units
tested alone, which is why equations C46, C47, and C48 of AHRI 1250-
2020, which are used for dedicated condensing units tested alone, were
used. DOE notes that equations C46, C47, and C48 from AHRI 1250-2020
are identical to equations C25, C26, and C27.
Lennox commented that defrost heat seems low for unit coolers
compared to tested values and off-cycle power seems high for unit
coolers. (Lennox, No. 70 at p. 5) As discussed in this section, DOE
calculated defrost heat for low-temperature unit coolers in the unit
cooler performance database using the defrost calculations from AHRI
1250-2020 for dedicated condensing units tested alone. For unit coolers
with two- or variable-speed fan motors, DOE assumed that off-cycle fan
power would be based on the fan(s) running at 50-percent speed, the
minimum speed allowed by the DOE test procedure. Section 4.2 of
appendix C to AHRI 1250-2020. DOE calculated fan power for this 50-
percent speed assuming this operation would consume 20 percent of the
full speed power, based on equation 118 in AHRI 1250-2020. Since the
defrost heat and off-cycle fan power in the unit cooler performance
database are based on the industry test procedure, AHRI 1250-2020, DOE
has determined that the values in the unit cooler performance database
are representative. It is DOE's understanding that the defrost heat
values in AHRI 1250-2020 were established based on a test program of
representative electric-defrost low-temperature unit coolers spanning a
range of capacities. Thus, DOE has determined that the defrost heat
values can be considered to be representative.
Lennox also suggested that DOE verify net capacities of unit
coolers through testing with all listed refrigerants. (Lennox, No. 70
at p. 5) DOE notes that testing the unit coolers in the unit cooler
performance database with all listed refrigerants was not practical
given time and resource constraints. The unit cooler database contains
data that is certified to DOE; thus, DOE has determined that using the
net capacities in the unit cooler database in its analysis is
appropriate and representative of the market.
AHRI commented that DOE should not use the CCD net capacity and
literature fan power to calculate AWEF2 because the AWEF values
certified in the CCD are often shown as the minimum and literature fan
power is not necessarily associated with either the unit's net capacity
or AWEF in the CCD. (AHRI, No. 72 at p. 19) Lennox commented that the
motor wattage data from catalogs may not be representative of actual
performance. (Lennox, No. 70 at p. 5) Through a review of the market
and available data, DOE has determined that fan powers found in product
literature are the most representative fan powers available for the
units included in the unit cooler performance database. Additionally,
as discussed in the previous paragraphs, DOE used CCD net capacity, not
CCD AWEF, to construct the unit cooler performance database. DOE
expects that the net capacities certified in the CCD are appropriate
and representative as they are certified to DOE.
AHRI recommended that DOE establish and validate a data-based basis
for calculating AWEF2 through testing. (AHRI, No. 72 at p. 19) Since
DOE has concluded that fan power, net capacity, and defrost power in
the unit cooler performance database (the inputs for unit cooler AWEF2
calculations) are representative, DOE has determined that the
calculated AWEF2s are representative and do not need extensive
validation from testing.
In response to the September 2023 NOPR, Lennox stated that as unit
cooler rows increase, unit cooler fans have to increase their power
draw due to the increased internal static pressure (``ISP''). This
comment is summarized and addressed in the March 2024 NODA. 89 FR
18555, 18564. As discussed in the March 2024 NODA, manufacturer product
catalogs, which were the primary source of fan powers for the unit
cooler performance database, generally do not show an increase in fan
power as rows increase. Id. DOE acknowledged that an increase in ISP
caused by additional rows would result in an increased fan power if all
other system characteristics were held constant. DOE analyzed unit
cooler systems using CoilDesigner and tentatively determined that
increasing the number of heat exchanger rows from two to three or three
to four would result in roughly a 6-percent increase in unit cooler fan
power, and increasing heat exchanger rows from four to five would
result in roughly a 4-percent unit cooler fan power increase.\52\ Based
on an analysis of the AWEFs in the unit cooler performance database,
DOE tentatively determined that the most likely scenario is that
catalogs report the maximum power draw for unit cooler fans. As such,
unit coolers with fewer than four or five rows have overestimated fan
powers in the unit cooler performance database. Based on these
conclusions in the March 2024 NODA, DOE tentatively determined that the
maximum technology levels proposed in the September 2023 NOPR were
still technologically feasible, as the units used to set these values
had accurate fan powers. As such, in the March 2024 NODA, DOE did not
adjust the fan powers of any units in the unit cooler database.
---------------------------------------------------------------------------
\52\ CoilDesigner is a heat exchanger coil simulation tool.
CoilDesigner Version 4.8.20221.110 was used for this analysis.
---------------------------------------------------------------------------
In response to the March 2024 NODA, AHRI and Lennox stated that
adding two more rows to the existing unit cooler coil significantly
changes the dimension of the evaporator and adds static pressure to
airflow, thereby increasing the motor power consumption. AHRI and
Lennox stated that, therefore, the expected increase in AWEF2 should be
less. AHRI and Lennox stated that the lower the capacity, the more
reduced the AWEF2 standard should be. AHRI and Lennox stated that for
these reasons, the costs are underestimated, and they referred DOE to
its member comments in response to the September 2023 NOPR. (AHRI, No.
86 at p. 4; Lennox, No. 87 at p. 6)
DOE agrees that unit cooler fan power should increase for higher-
row unit coolers. Thus, DOE revised its unit cooler fan power analysis
for this final rule. DOE adjusted the fan power of units in the unit
cooler database assuming that the reported catalog fan power was
accurate for units with the greatest number of tube rows and fins per
inch for a given product family and brand, and that units with fewer
rows and fewer fins per inch within that given family would have lower
fan powers. The relationship between fan power and tube rows is
discussed above. Regarding fan power trends with fins per inch, DOE
assumed that reducing fins per inch from eight to six reduces fan power
by 2.5 percent and that reducing fins per inch from six to four reduces
fan power by 3.5 percent, based on review of literature reports of
airflow trends versus both fins per inch and row numbers for unit
coolers. The details of this fan power adjustment are described in
chapter 5 of the final rule
[[Page 104687]]
TSD. When implementing these changes to the analysis, the calculated
AWEF2 values of the lower-row unit coolers increased, thus reflecting
the trend noted by commenters, i.e., that the AWEF2 improvement
associated with row number increase should not be as great as DOE
calculated based on the initial assumption that fan power does not
increase as the number of rows increase. The cost changes that resulted
due to this change are discussed in the Assigning Costs to Efficiency
Levels subsection of section IV.C.2.f of this document.
In response to the March 2024 NODA unit cooler analysis, Hussmann
stated that there is no way to review what DOE did for unit coolers
unless they provide the database of information. (Hussmann, No. 88 at
p. 4) Additionally, AHRI requested the updated unit cooler database
with the number of rows for each unit cooler. (AHRI, No. 86 at p. 4)
DOE notes that the unit cooler performance database docketed with the
September 2023 NOPR analysis contained all the information DOE is able
to disclose while retaining the anonymity of units in the database and
not violating non-disclosure agreements of manufacturer interviews
under which some data in the unit cooler performance database was
collected. DOE notes that the posted unit cooler database provides all
the inputs used for the AWEF2 calculation. As such, the unit cooler
performance database docketed in support of this final rule analysis
contains no additional information. Furthermore, DOE notes that in the
unit cooler performance database that is docketed with this final rule,
there are five less unit entries than in the unit cooler performance
database that was docketed with the September 2023 NOPR. DOE determined
that these units were not representative of the unit cooler market and
therefore removed them. These five units were not used in the September
2023 NOPR efficiency analysis so the efficiency levels are unaffected
by the removal of these units.
ii. Analyzing Representative Units Using the Unit Cooler Performance
Database
As discussed in section 5.8.2 of the September 2023 NOPR TSD, DOE
identified units in the unit cooler performance database that were a
part of manufacturers' product configurations that had net capacities
within 10 percent of each representative unit's net capacity and
grouped them together. These groups of unit coolers with similar
configurations and capacities were used to analyze the representative
units selected for this analysis.
In response to this methodology used to analyze representative
units, Hussmann commented that the representative models used from the
unit cooler database are not representative of the broader population
of models. Hussmann stated that while the only model selected to
represent the UC.M.075 representative unit and the capacity point is 7
percent above the goal, there are 376 models in the same capacity range
in the CCD, many of which are much closer to the goal capacity value.
Hussmann stated that similarly, only two UC.L.075 models were selected
for representation and are 8 to 9 percent from the goal capacity, while
373 models could have been used, many of which have capacity values
much closer to the goal. Hussmann noted that for the lower capacity
points, multiple units were selected that provide a range of models.
Hussmann provided charts to show both the representative models and all
possible models that could have been used, indicating models that it
believed would have been better choices for representation. (Hussmann,
No. 75 at pp. 3-5) DOE notes that it selected models for the NOPR
analysis that not only were within 10 percent of the capacity goal but
also differed only in the number of tube rows, to isolate the impact of
this design option. The alternative selections mentioned by Hussmann
have more differences than tube rows and thus could not be used to
isolate the impact of the tube row addition. Figure IV.1 shows the
calculated AWEF2 values for three-, four-, and five-row medium-
temperature unit cooler models in the database using the methodology
used in the NOPR but with fan power calculation adjusted as described
in this section. The calculated AWEF2 values are compared in this
figure to the EL 1 and EL 2 efficiency levels used in the analysis,
indicating that the selected efficiency levels are appropriate.
iii. Baseline Efficiency
For each equipment class, DOE generally selects a baseline model as
a reference point for each class, and measures anticipated changes
resulting from potential energy conservation standards against the
baseline model. 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.
DOE concluded while conducting the NOPR analysis that baseline
medium- and low-temperature unit coolers with a capacity less than or
equal to 25 kBtu/h typically had two evaporator rows and baseline units
with a capacity greater than 25 kBtu/h typically had three evaporator
tube rows. Table IV.27 lists representative units and the number of
baseline evaporator tube rows DOE used in the September 2023 NOPR.
BILLING CODE 6410-01-P
[[Page 104688]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.043
In response to the September 2023 NOPR, DOE received comments on
the baseline assumption for medium- and low-temperature unit coolers.
Lennox recommended that DOE further review unit cooler designs of
the current market to ensure that the baseline design is representative
of the current market and not a carryover from the prior WICF
rulemaking. Lennox stated that the approach to add rows to two- and
three-row unit cooler designs has likely already been implemented to
attain the current AWEF standard levels. (Lennox, No. 70 at p. 4)
AHRI, Hussmann, and Lennox commented that section 5.8 in the TSD
assumes all baseline coils are either two or three rows; however, many
coils are already four rows to meet the current AWEF requirements.
(AHRI, No. 72 at pp. 3-4 and No. 86 at p. 6; Hussmann, No. 75 at p. 1;
Lennox, No. 70 at p. 4) AHRI stated that the presumption that most
coils are two-row is erroneous, as the more common baseline is now four
rows. (AHRI, No. 72 at p. 9) AHRI and Hussmann estimated that 5 percent
of current coils are two row, about 30 percent are three row, and the
remaining 65 percent are four row. (AHRI, No. 72 at pp. 3-4 and No. 86
at p. 6; Hussmann, No. 75 at p. 1) Lennox estimated that 5 percent of
current coils are two row, about 30 percent are three row, and the
remaining 55 percent are four row, 5 percent are five row, and 5
percent are six row. (Lennox, No. 70 at p. 4)
As discussed, DOE sets the baseline unit as a unit that just meets
the current energy conservation standards. DOE analyzed the unit cooler
performance database in response to these comments and found that 4
percent of units in the database have two-row coils, 22 percent have
three rows, 52 percent have four rows, and 22 percent have five rows.
Additionally, DOE plotted the AWEF and capacity of the medium-
temperature units in the database while differentiating row numbers.
See Figure IV.1. These plots show that baseline efficiency levels are
achievable by three-row units for all capacities. As such, for this
final rule analysis DOE updated the representative row numbers for each
baseline unit to be three rows.
[GRAPHIC] [TIFF OMITTED] TR23DE24.044
[[Page 104689]]
iv. Maximum Technology Levels
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 and
that, while fan power does increase, the fan power increase is
significantly less than the capacity increase, resulting in more
efficient units.
In the September 2023 NOPR, to set the maximum technology level for
medium- and low-temperature unit coolers, DOE selected the highest-
efficiency unit cooler available for each representative capacity from
the unit cooler performance database. The highest-efficiency unit
coolers at each representative capacity corresponded to an increase in
two evaporator tube rows. Table IV.28 lists the unit cooler
representative units evaluated in the September 2023 NOPR and the
number of tube rows used to reach the highest efficiency level
analyzed.
[GRAPHIC] [TIFF OMITTED] TR23DE24.045
BILLING CODE 6410-01-C
In response to the September 2023 NOPR, DOE received comment on the
maximum technology evaporator tube rows.
AHRI questioned the AWEF2 values at EL 2 in DOE's NOPR analysis.
AHRI commented that the source for EL 2 values was not provided, and if
they came from the ``unit cooler performance database,'' the
information on the quantity of rows was not provided to evaluate. AHRI
requested that DOE provide the number of rows for the list of models so
AHRI can further assess the data. (AHRI, No. 72 at pp. 4-5) AHRI also
stated that AWEF gains in the vicinity of 15 percent for unit coolers
is an aggressive expectation for adding a row to coils. (AHRI, No. 72
at p. 9) Lennox also commented that the unit cooler database does not
specify the number of coil rows, so Lennox is unable to analyze
further. (Lennox, No. 70 at p. 4)
DOE determined the AWEF2 values based on the unit cooler
performance database. As discussed previously in this section, DOE
grouped units within a range of capacities into a single representative
capacity. Then, DOE determined the efficiency and cost increase
associated with adding one- and two-coil rows to the baseline model.
DOE notes that the number of coil rows associated with each unit is
confidential data informed by feedback obtained through manufacturer
interviews. As mentioned previously, DOE is unable to publish this data
publicly. Regarding AHRI's assertion that a 15-percent increase in AWEF
is an aggressive expectation for adding a coil row, DOE notes that only
some representative units analyzed for low-temperature unit coolers
have efficiency increases as high as 15 percent, and these correspond
to an additional two rows added to baseline.
AHRI and Hussmann commented that DOE should conduct the unit cooler
analysis assuming that three-row coils will move to four-row coils and
that four-row coils will be maintained. (AHRI, No. 72 at p. 4;
Hussmann, No. 75 at p. 2) In its review of the market, DOE found unit
coolers that have coils with five rows across the range of
representative unit capacities. Thus, DOE analyzed five-row coils as
the maximum technology option for unit coolers.
Lennox commented that increasing four-row designs to five- and six-
row designs is not cost-effective because adding coil rows has
diminishing returns on improving efficiency. Lennox stated that
effective heat exchange of adding rows drops because the heat has
already been largely added to the refrigerant in the existing rows,
therefore heat remaining in the air is lessened. (Lennox, No. 70 at p.
4)
In response to the March 2024 NODA, AHRI reiterated that increasing
four-row unit coolers to five or six rows is not cost-effective and
that additional rows have diminishing efficiency returns. (AHRI, No. 86
at pp. 6-7)
DOE notes that it did not identify any six-row unit coolers in the
unit cooler performance database. In its analysis, DOE recognizes that
increasing a four-row design to a five-row design results in a lower
efficiency increase than increasing a three-row design to a four-row
design and, therefore, the efficiency increase from EL 0 to EL 1 is
greater than the efficiency increase from EL 1 to EL 2. Cost-
effectiveness of any design option is determined by analyses in
sections IV.F and IV.H of this document.
As shown in Figure IV.1, the max-tech levels from the September
2023 NOPR for medium-temperature unit coolers are achievable by four-
and five-row unit coolers on the market today. In this final rule
analysis, DOE is making the conservative assumption that all unit
coolers would have to go to five-row coils at max-tech levels.
Defining maximum technology levels for unit coolers is discussed in
more detail in chapter 5 of the final rule TSD.
[[Page 104690]]
v. Intermediate Efficiency Levels
As discussed in the September 2023 NOPR, 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. 88 FR 60746, 60782.
DOE did not receive comments on defining intermediate efficiency
levels for unit coolers in response to the September 2023 NOPR;
therefore, DOE is defining intermediate efficiency levels using the
same methodology as was used in the September 2023 NOPR in this final
rule analysis. In this final rule analysis, due to the change in tube-
row assumptions for baseline and max-tech levels, DOE correspondingly
assumes that all intermediate efficiency levels would use four tube
rows.
Defining and determining the efficiency of intermediate efficiency
levels is discussed in more detail in chapter 5 of the final rule TSD.
General Comments
In response to the September 2023 NOPR, DOE received several
general comments about the unit cooler efficiency level analysis.
Hussmann recommended that DOE address its concerns regarding its unit
cooler analysis and consider the proposed revision to the AWEF2
standards before finalizing any new targets. (Hussmann, No. 75 at p. 7)
Lennox stated that DOE must address various technical issues before
proceeding with any new WICF energy conservation standard. Lennox
further stated that DOE must review the baseline design assumptions and
associated costs of attaining increased efficiency levels. (Lennox, No.
70 at pp. 3-4) Lennox recommended DOE further review that the methods
to achieve improved efficiency are viable and that the associated costs
are accurate (Lennox, No. 70 at p. 4) Lennox also stated that DOE must
verify data inputs and correct errors in formulas and calculations
before determining if amended AWEF standard levels are justified.
(Lennox, No. 70 at p. 5) In the previous sections, DOE addressed
specific concerns raised by stakeholders about the unit cooler
efficiency level analysis to ensure it is technologically feasible. As
such, DOE has determined that the unit cooler efficiency levels
presented in the March 2024 NODA are technologically feasible. Their
cost-effectiveness is assessed in sections IV.F and IV.H. of this final
rule.
In response to the efficiency levels presented in the March 2024
NODA, AHRI asked for the updated analysis for the UC.L.009
representative unit and what the difference between the three different
designs at baseline, EL 1, and EL 2 are. AHRI stated that it did not
understand why Table 3.1 (of the NODA support document) lists two
different design options but the analysis uses three different options.
(AHRI, No. 86 at p. 4) DOE notes that the design option codes in Table
3.1 of the NODA support document are for dedicated condensing systems
and single-packaged dedicated systems, as those were the equipment
classes analyzed using a design-option analysis. The UC.L.009
representative unit was analyzed using an efficiency-level approach. As
discussed in the previous sections, a baseline, intermediate, and max-
tech level were defined for each medium- and low-temperature unit
cooler representative unit. DOE found that the intermediate level
generally represented an additional tube row being added to the
baseline unit cooler heat exchanger, and the max-tech level represented
two additional tube rows being added.
Design Options
In the September 2023 NOPR, DOE did not directly analyze any design
options for medium- and low-temperature unit coolers as an efficiency-
level analysis was conducted. In response to the efficiency-level
analysis for medium- and low-temperature unit coolers, DOE received
several comments about specific design options, which are summarized
and addressed below.
NAFEM commented that DOE's proposal to increase evaporator tube
rows in order to increase efficiency for unit coolers is not a new
technology but an extension of an existing technology. NAFEM commented
that manufacturers' options for adopting new technologies in order to
increase energy efficiency are limited, which poses an issue and a
challenge applicable to all permutations of walk-ins. (NAFEM, No. 67 at
p. 3) As discussed in section IV.A.2.c of this document, the design
options that DOE analyzes do not need to be new technologies. Based on
the unit cooler performance database, DOE has determined that
efficiency levels above baseline are possible to achieve. Additional
evaporator coil rows are the primary technology option DOE has
identified for manufacturers to meet these levels above baseline.
Despite some units already employing additional tube rows, DOE has
determined efficiency levels above baseline are achievable with this
technology. Additionally, DOE notes that the standards finalized in
this rulemaking are not prescriptive; manufacturers may comply with
them using any technologies they see fit.
The CA IOUs recommended that DOE include evaporator fin density (up
to eight fins per inch) as a design option for medium-temperature unit
coolers. (CA IOUs, No. 76 at p. 2) The CA IOUs commented that although
high fin densities may cause excessive ice buildup in low-temperature
applications, this is not the case for medium-temperature applications.
(CA IOUs, No. 76 at p. 2) DOE notes that standard medium-temperature
unit cooler conditions have refrigerant temperatures below freezing.
Therefore, during high-load conditions resulting in long on-cycles,
frost can still form on the coils. For this reason, fin density higher
than seven fins per inch may impact the functionality of medium-
temperature evaporators. Therefore, DOE is only considering fin density
up to six fins per inch in this analysis and screening out high fin
densities based on the possibility of having adverse impacts to the
equipment performance or functionality.
As discussed in the September 2023 NODA, DOE did not analyze
permanent magnet synchronous (``PMS'') motors as a design option for
unit coolers in the September 2023 NOPR analysis due to the
prescriptive requirements in EPCA (42 U.S.C. 6313(f)(1)(E)) requiring
unit cooler motors under 1 hp use ECM or three-phase motors. 88 FR
66710, 66717.
In response to the September 2023 NOPR, the CA IOUs recommended
that DOE consider PMS motors as the maximum technologically feasible
option for evaporator fan motors because they are, on average, 15- to
27-percent more efficient than ECMs. The CA IOUs commented that in the
2014 Final Rule for walk-ins, DOE acknowledged that EPCA grants DOE the
authority to permit alternative motor types for evaporator fan motors
if DOE determines that, on average, those other motors use no more
energy in evaporative fan applications than ECMs; therefore, the CA
IOUs encouraged DOE to evaluate the PMS AC motors as a
[[Page 104691]]
design option. (CA IOUs, No. 76 at pp. 3-4)
DOE acknowledges that EPCA grants the Secretary of Energy the
authority to allow alternative motor types for WICF evaporator fan
motors if the Secretary of Energy determines that, on average, those
other motors use no more energy in evaporator fan applications than
ECMs. (42 U.S.C. 6313(f)(2)(B)). DOE attempted to evaluate the
performance of PMS fan motors in WICF evaporator fan applications.
However, based on a review of the PMS motors currently on the market,
these motors do not span the range of WICF fan wattages and revolutions
per minute needed for proper operations. Therefore, at this time, DOE
cannot make a determination regarding the energy consumption of PMS
motors relative to the energy consumption of ECMs in WICF evaporator
fan applications and is not analyzing PMS motors as a design option in
this final rule.
High-Temperature Design-Option Approach
As discussed in the September 2023 NOPR, DOE was unable to
construct a performance database for high-temperature unit coolers
because there are no high-temperature units certified in the CCD;
therefore, DOE conducted a design option approach for high-temperature
unit coolers. 88 FR 60746, 60781. In the September 2023 NOPR, the
design options remaining for unit coolers after screening were improved
evaporator coil, improved evaporator fan blades, off-cycle evaporator
fan control, and on-cycle evaporator fan control. However, DOE only
analyzed improved evaporator coils and off-cycle evaporator fan
controls. DOE had 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. This left off-cycle fan controls and
improved evaporator coils as the only remaining design option for high-
temperature unit coolers in the September 2023 NOPR analysis.
As discussed in the September 2023 NOPR, 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 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 AWEF2 values used
to define the high-temperature baseline efficiency level through
testing. 88 FR 60746, 60782.
As discussed in the September 2023 NOPR, DOE defined the maximum
technology level for high-temperature unit coolers as a representative
unit with all the design options applied. As discussed in the unit
cooler Efficiency Levels subsection of section IV.C.1.f 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. 88 FR 60746, 60782.
DOE did not identify any intermediate efficiency levels for high-
temperature unit coolers in the September 2023 NOPR analysis.
DOE received no comments in response to the high-temperature unit
cooler design option analysis and is therefore maintaining this
methodology in the final rule analysis. Details of this analysis can be
found 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
equipment, 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 commercially available equipment, component-by-component, to
develop a detailed bill of materials for the equipment.
Catalog teardowns: In lieu of physically deconstructing
equipment, DOE identifies each component using parts diagrams
(available from manufacturer websites or appliance repair websites, for
example) to develop the bill of materials for the equipment.
Price surveys: If neither a physical nor catalog teardown
is feasible (e.g., for tightly integrated products such as fluorescent
lamps, which are infeasible to disassemble and for which parts diagrams
are unavailable), cost-prohibitive, or 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 catalog (virtual) teardowns.
As discussed in the September 2023 NOPR, 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 physical teardown analysis to create
detailed bills 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 MPC for equipment at various
efficiency levels spanning the full range of efficiencies from the
baseline to the maximum technology available. 88 FR 60746, 60782-60783.
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 of this
document).
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,
[[Page 104692]]
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.,\53\
PolymerUpdate,\54\ the U.S. geologic survey (``USGS''),\55\ and the
Bureau of Labor Statistics (``BLS'').\56\
---------------------------------------------------------------------------
\53\ For more information on MEPS Intl, please visit
www.meps.co.uk/.
\54\ For more information on PolymerUpdate, please visit
www.polymerupdate.com.
\55\ For more information on the USGS metal price statistics,
please visit www.usgs.gov/centers/nmic/commodity-statistics-and-information.
\56\ 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 final rule 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 \57\ (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.\58\
---------------------------------------------------------------------------
\57\ Fastmarkets, available at www.fastmarkets.com/amm-is-part-of-fastmarkets.
\58\ U.S. Department of Labor, Bureau of Labor Statistics,
Producer Price Indices, available at www.bls.gov/ppi/.
---------------------------------------------------------------------------
During development of the analysis for the September 2023 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 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 final rule TSD.
c. Low-GWP Refrigerants
DOE received comments in response to the September 2023 NOPR
regarding the cost impacts of alternative refrigerants. AHRI, Hussmann,
and Lennox commented that the safety standard would require additional
components such as guards, grilles, labels, non-ignition sources, etc.
that would result in increased cost. (AHRI, No. 72 at p. 10; Hussmann,
No. 75 at pp. 10-11; Lennox, No. 70 at p. 7) Hussmann stated that
associated costs to meet the safety requirements of using A2L or
CO2 refrigerants could add 20 to 400 percent to equipment
costs, resulting in higher product prices for customers. (Hussmann, No.
75 at p. 14) NRAC commented that refrigeration systems would require
added components, including safety shut-off valves, leak-detection
sensors, and mitigation boards, and since these components are not
readily available in the marketplace yet, costs cannot be determined.
(NRAC, No. 73 at p. 3)
DOE also received the following comments in response to the March
2024 NODA. AHRI stated that the increases in MPC and MSP seem low when
considering tooling, materials, and development costs required to fully
address the capacity reduction due to high glide of refrigerants with
less than 150 GWP. AHRI also stated that additional costs for A2L
refrigerants will include at minimum the cost of A2L sensor, wiring,
and control components for mitigation. AHRI and its members requested
to see test data of products operating per the test procedure. AHRI
stated that the rules for commercial refrigeration and acceptability
are contained in SNAP 26 and that it has not yet been released. AHRI
recommended that DOE wait for the release of SNAP 26 so it can be
addressed properly. (AHRI, No. 86 at p. 8) Lennox also stated that the
updated safety standards for A2L refrigerant require safety mitigation
measures, in both the products as delivered and during installation,
that DOE must consider. (Lennox, No. 87 at p. 5) RSG stated that there
will be large costs associated with refrigerant leak detection and
mitigation that should be factored into the overall costs associated
with the deployment of refrigeration systems that operate with A2L
refrigerants and that RSG would like to see those upfront costs of leak
detection and mitigation factored into the LCC and PBP for this
equipment to assist with determining the path forward. (RSG, No. 89 at
p. 2)
DOE notes that on June 13, 2024, EPA published a Final Rule in the
Federal Register regarding protection of stratospheric ozone: listing
of substitutes under the Significant New Alternatives Policy Program
(``SNAP'') in commercial and industrial refrigeration, also known as
SNAP 26. 89 FR 50410. In this Final Rule EPA listed R-454A and R-454C
(among other refrigerants) as acceptable substitutes for cold storage
warehouses,\59\ retail food refrigeration supermarket systems, and
retail food remote condensing units. As these are the primary
refrigerants DOE is assuming the walk-in refrigeration system industry
will adopt (see Refrigerants Analyzed subsection of section IV.C.1.e of
this document), DOE has determined that a lack of certainty around SNAP
approval is no longer a factor in the refrigerant transition.
---------------------------------------------------------------------------
\59\ R-454A is only an acceptable alternative for systems under
200 lbs of charge, which matches the restrictions finalized in the
October 2023 EPA Technology Transitions Final Rule.
---------------------------------------------------------------------------
DOE acknowledges that the transition to lower GWP refrigerants may
impact the cost of WICF refrigeration systems. Considering the safety
requirements outlined in UL 60335-2-89, DOE has concluded that walk-in
dedicated condensing systems using A2L refrigerants would require the
addition of a refrigerant leak detection system. Therefore, DOE
included the cost of a refrigerant leak detection system in all
dedicated condensing units and single-packaged dedicated system
representative units analyzed. Because
[[Page 104693]]
the refrigerant leak detection system is required independent of
efficiency, DOE applied this cost across all baseline and higher
efficiency levels analyzed. Therefore, this had no impact to the
incremental MPCs analyzed. Details of this cost addition are outlined
in chapter 5 of the final rule TSD.
Additionally, based on the properties of R-454A and the current
design of walk-in refrigeration systems, DOE has concluded that there
would likely be modest tooling and development conversion costs to
convert the condenser, evaporator, and refrigerant piping of an R-448A
system to use R-454C. See section IV.C.2.g of this document for further
discussion on DOE's accounting for how tooling and development costs
are incorporated into MPCs.
In response to the March 2024 NODA, DOE received the following
comments specifically relating to single-packaged dedicated systems.
AHRI and Lennox stated that DOE significantly underestimated a <1-
percent cost increase to achieve a 34-percent increase of AWEF2 while
considering HFC refrigerant for transition for the following
representative units: SP.M.O.009, SP.M.I.009, SP.L.O.006, SP.L.I.006,
and SP.L.O.002. AHRI and Lennox commented that DOE should have looked
at the EPA technology transition rule on self-contained products. AHRI
and Lennox stated that while the charge amount is a challenge to
achieve the performance requirement, achieving a higher AWEF2 number
could cause a tremendous cost increase. AHRI stated the ballpark number
could be in the range of 30-40 percent vs. DOE's estimation of less
than 1 percent. AHRI and Lennox stated that for SP.M.O.002 and
SP.L.I.002, DOE's estimated MPC increases of 42 percent and 31 percent,
respectively, may be underestimated for lower GWP refrigerants
requiring potential changes to heat exchangers and cabinetry. AHRI and
Lennox stated that for the SP.L.I.002 representative unit, DOE has only
considered up to EL 4 at TSL 1 and TSL 2, which does not include
propane or any other low-GWP refrigerant. AHRI stated that propane must
be considered part of the AWEF2 if DOE is intending to adopt TSL 1 or
TSL 2. AHRI stated that this could also impact the MPC. AHRI and Lennox
stated that there is no consideration of heat exchanger design impact
or any additional components to be accommodated to achieve higher
AWEF2. (AHRI, No. 86 at p. 9; Lennox, No. 87 at pp. 7-8)
As indicated previously in this section, DOE acknowledges that the
transition to lower GWP refrigerants may result in increased equipment
costs across WICF refrigeration systems. However, DOE has determined
based on the information available at this time, that any change in
cost to manufacture equipment that is compatible with lower GWP
refrigerants is not likely to significantly affect incremental costs to
improve efficiency analyzed in this rulemaking (i.e., the costs to
implement these changes will likely be similar at each efficiency
level). AHRI did not specify what cost it is requesting to be included
in this analysis of single-packaged dedicated systems. Based on
manufacturer feedback, it is DOE's understanding that major changes to
heat exchangers and cabinetry would not be necessary for single-
packaged dedicated systems' transition to low-GWP refrigerants. Given
the lack of specific data provided by AHRI on what the cost increases
for single-packaged dedicated systems would be attributed to, DOE has
maintained the cost approach from the March 2024 NODA in the final rule
cost analysis.
d. More Efficient Single-Speed Compressors
In the September 2023 NOPR, DOE analyzed higher-efficiency
compressors for dedicated condensing units and single-packaged
dedicated systems. The higher-efficiency compressor design options
included both higher-efficiency single-speed compressors and variable-
speed compressors. For single-packaged dedicated systems, DOE
considered both higher-efficiency single-speed compressors and
variable-speed compressors in the September 2023 NOPR. However, DOE did
not consider higher-efficiency single-speed compressors for dedicated
condensing units in the September 2023 NOPR. See section 5.7.2.1 of the
September 2023 NOPR TSD for further discussion. In response to the
comments received on the September 2023 NOPR from ASAP et al. and the
CA IOUs (ASAP et al., No. 77 at p. 2; CA IOUs, No. 76 at pp. 8-9), for
the March 2024 NODA, DOE reviewed publicly available compressor
performance data and identified compressors with capacities roughly
between 50 and 60 kBtu/h that have higher efficiencies than the
compressors in that capacity range used in the September 2023 NOPR
analysis. DOE determined that compressors in that capacity range could
be used on the following representative units: DC.M.O.054, DC.M.I.054,
and DC.M.O.124. In the March 2024 NODA, DOE presented updated cost-
efficiency curves that incorporated more-efficient single-speed
compressors as design options on those three representative units. DOE
requested comment on the updated cost-efficiency results for the 54
kBtu/h indoor and outdoor medium-temperature dedicated condensing units
and the 124 kBtu/h outdoor medium-temperature dedicated condensing unit
presented in section 3 of the NODA support document. 89 FR 18555,
18560-18561.
In response to the March 2024 NODA, AHRI stated that since there
are multiple technologies (i.e., scroll and semi-hermetic compressors)
offered above the capacities of 54 kBtu/h, the cost is underestimated
by as much as 40 percent in some cases. (AHRI, No. 86 at pp. 7-8)
Lennox stated that DOE significantly underestimated costs for
compressors with improved efficiency. (Lennox, No. 87 at p. 5) Based on
these comments, it is unclear to DOE if the commenters are stating that
the costs are underestimated because they believe that, in some cases,
units would need to swap a scroll compressor for a semi-hermetic
compressor or if the costs are underestimated because the costs of
swapping for a higher efficiency compressor of the same type (scroll or
semi-hermetic) are too low. As discussed in the March 2024 NODA, DOE
analyzed compressors at efficiencies that have options for both scroll
and semi-hermetic compressors to ensure that the analysis only included
compressors that did not remove consumer choice. 89 FR 18555, 18560.
For the DC.M.O.054, DC.M.I.054, and DC.M.O.124 representative units
modeled in the engineering analysis, DOE associated the incremental
cost for a higher-efficiency compressor with the cost of swapping a
representative scroll compressor with a higher-efficiency scroll
compressor, as DOE determined that scroll compressors are more
representative for these representative units than semi-hermetic
compressors. Without further clarity about why this incremental cost is
being underestimated, DOE maintained its methodology for the final rule
cost analysis. DOE notes that it reviewed and updated compressor
pricing for the final rule cost analysis to align with current pricing
trends. See chapter 5 of the final rule TSD for further details on how
component costs were updated.
e. Variable-Speed Compressors
In response to the September 2023 NOPR, ASAP et al. commented that
DOE may be overestimating the cost of variable-speed compressors and,
as a result, the economic analysis does not show levels incorporating
variable-speed compressors to be cost-effective. ASAP et al. commented
that in DOE's NOPR analysis for CRE, DOE used a
[[Page 104694]]
lower incremental cost associated with variable-speed compressors;
thus, ASAP et al. recommended that DOE further investigate the cost of
variable-speed compressors for walk-ins. (ASAP et al., No. 77 at p. 3)
In the September 2023 NOPR, DOE was unable to collect sufficient cost
information for variable-speed compressors from product teardowns and
manufacturer interviews. Therefore, DOE calculated the cost of
variable-speed compressors using compressor pricing data previously
collected from teardowns of other refrigeration and HVAC products to
develop a price multiplier to estimate the cost increase of a variable-
speed compressor compared to a single-speed compressor. For the final
rule analysis, DOE was still unable to find sufficient cost information
for variable-speed compressors specifically used for walk-ins. In
contrast, variable-speed compressors are more prevalent in the CRE
market and, as a result, DOE was able to ascertain price information
for compressors used for CREs through product teardowns and online
quotes. DOE notes that those compressor prices would not be directly
applicable to walk-ins, as application temperatures and refrigerated
volumes for CREs differ from those of walk-ins. Because of the
differing availability for compressors, DOE estimates that a variable-
speed compressor for a walk-in dedicated condensing system has a larger
incremental cost compared to CRE. Ultimately, DOE maintained the
methodology used to estimate incremental costs for variable-speed
compressors for dedicated condensing systems used in the September 2023
NOPR in this final rule.
f. Unit Coolers
In the September 2023 NOPR, DOE developed linear cost-efficiency
correlations for each representative unit, which DOE used to determine
the MPC increase from the baseline efficiency level to the higher
efficiency levels for unit coolers. For additional details, see section
5.8.6 of the September 2023 NOPR TSD. For the September 2023 NOPR, DOE
did not consider that adding rows to the unit cooler heat exchanger
would require an increase in cabinet size when determining the MPCs
associated with each efficiency level. In response, AHRI, Hussmann, and
Lennox commented that current unit cooler coil and cabinet designs are
optimized around four-row designs and increasing efficiency would be
more costly than what DOE estimated when considering packaging,
freight, materials, and scrap. (AHRI, No. 72 at pp. 3-4, 9; Hussmann,
No. 75 at pp. 2, 12; Lennox, No. 70 at p. 4) DOE subsequently updated
its analysis for the March 2024 NODA to account for costs related to
expanding the cabinet to accommodate additional tube rows. 89 FR 18555,
18564. The average cost adder associated with expanding cabinet sizes
was $11 for the representative capacities DOE analyzed. DOE notes that
most of the cost adder is comprised of material costs for additional
cabinet sheet metal and packaging associated with an expanded cabinet.
DOE did not include capital expenditures, such as retooling investments
required for an expanded cabinet, in the MPCs. For further discussion
on this, see section IV.C.2.g of this document.
In response to the March 2024 NODA, Lennox and AHRI stated that the
baseline MPC for unit coolers are about 50 percent low and that they
are unable to comment on the incremental costs for EL 1 and EL 2 due to
uncertainty surround the definition of the higher efficiency levels
(AHRI, No. 86 at p. 5; Lennox, No. 87 at pp. 5-6) AHRI and Hussmann
stated that the $11 cost adder applied to higher efficiency unit
coolers seems low, particularly for larger capacity units. (AHRI, No.
86 at p. 8; Hussmann, No. 88 at p. 2) For this final rule analysis, DOE
reviewed its cost modeling methodology considering these comments
regarding underestimated costs. Upon reviewing product literature and
the representative units being modeled, DOE updated several inputs to
the unit cooler cost modeling, which may be better aligned with
industry's cost estimates. Regarding the $11 cost adder, DOE maintained
the methodology used to develop the cost adder. With updates to
material pricing, DOE still found that $11 was the average cost adder
and that the cost adder did not vary significantly with capacity. See
chapter 5 of the final rule TSD for further details on the updates made
to MPC modeling for unit coolers. For further discussion of the capital
conversion costs associated with additional tube rows, see section
IV.J.3.a of this document.
Assigning Costs to Efficiency Levels
In the September 2023 NOPR analysis, DOE developed cost-efficiency
curves for unit coolers by correlating cost with AWEF2 for groups of
similar units within designated capacity ranges. As discussed
previously, the changes made in this final rule analysis to adjust the
fan power of some units in the unit cooler performance database will
result in a different relationship between cost and AWEF2. As DOE was
developing these new relationships, it identified a change in
methodology that would increase the number of units considered in the
cost analysis and more closely align the incremental costs of each
efficiency level to the increased manufacturer production cost of
adding additional tube rows to unit cooler heat exchangers. Whereas
DOE's NOPR analysis previously correlated costs directly with AWEF2,
DOE estimated costs for efficiency levels above baseline would be
associated with tube row increases for this final rule. Additionally,
DOE slightly revised baseline costs for each representative unit to use
more data from the unit cooler database in an effort to assign more
representative costs to the units analyzed. The updated costs are
presented in Appendix 5A of the final rule TSD and the details of the
revised cost methodology are discussed in chapter 5 of the final rule
TSD.
g. Capital Expenditures Represented in MPCs
In response to the September 2023 NOPR, Lennox disagreed with the
costs associated with components cited for each TSL in the NOPR and
sections 5.7 and 5.8 of the NOPR TSD. Lennox stated that the costs must
consider current design and capital costs associated to realize the
advancements. Lennox commented that moving from four-row to five-row
coils or increasing equipment face area will require sweeping changes
likely to increase the cost significantly over DOE's estimates. Lennox
commented that DOE's estimated cost of larger condenser coils overlooks
capital costs, which Lennox stated would be a significant cost factor.
(Lennox, No. 70 at pp. 8-9) AHRI and Hussmann also stated that capital
costs should be included when estimating costs for unit coolers with
more than four tube rows. (AHRI, No. 72 at pp. 3-4; Hussmann, No. 75 at
pp. 1-2)
In response to the March 2024 NODA, AHRI reiterated that because
unit coolers are optimized around four-row coils, increasing efficiency
by adding tube rows would be much more costly than estimated by DOE,
considering major tooling and other factors. AHRI and Lennox stated
that DOE underestimated cost increases for MPCs and MSPs associated
with requirements for walk-ins to use A2L refrigerants, considering
tooling, materials, and development costs. (AHRI, No. 86 at pp. 6-7;
Lennox, No. 87 at p. 5)
Regarding the tooling and equipment costs, DOE accounts for
manufacturing equipment, tooling, and building depreciation in its MPCs
and the one-time, upfront investments in property, plant, and equipment
necessary to adapt
[[Page 104695]]
or change existing production facilities (i.e., capital conversion
costs) in its MIA. As such, DOE notes that the depreciation component
of the MPCs in the engineering analysis requires estimates of capital
investments (e.g., tooling, fixtures, equipment). To estimate those
capital investments for the engineering analysis, DOE uses data
collected from teardowns and manufacturer interviews and estimated
annual production volumes for each equipment class to model a
``greenfield'' facility--using brand-new equipment that has not yet
depreciated through use--which includes the equipment, tooling, and
space requirements necessary to carry out the manufacturing processes
on a representative unit. See chapter 5 of the final rule TSD for
additional details on the cost model and estimation of MPCs. Regarding
the development costs, DOE accounts for the one-time, upfront
investments in research, development, testing, marketing, and other
non-capitalized costs necessary to make product designs comply with new
or amended energy conservation standards (i.e., product conversion
costs) in its MIA. See section IV.J.2.c of this document or chapter 12
of the final rule TSD for additional information on conversion costs.
h. Manufacturer Markups 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 10-K reports
\60\ filed by publicly traded manufacturers whose combined equipment
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. DOE maintained
the industry average manufacturer markups used in the September 2023
NOPR and March 2024 NODA for this final rule analysis. See chapter 12
of the final rule TSD or section IV.J.2.d of this document for
additional detail on the manufacturer markups.
---------------------------------------------------------------------------
\60\ U.S. Securities and Exchange Commission, Electronic Data
Gathering, Analysis, and Retrieval (EDGAR) system. Available at
www.sec.gov/edgar/search/ (last accessed May 7, 2024).
---------------------------------------------------------------------------
In the September 2023 NOPR analysis, DOE estimated a per-unit
shipping cost for each dedicated condenser and single-package dedicated
system representative unit at each efficiency level based on the size
and weight of the given unit. 88 FR 60746, 60784. 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. DOE did
not estimate a per-unit shipping cost for unit coolers because DOE
assumed that higher efficiency unit coolers would not require increased
shipping costs as a result of additional tube rows or other efficiency-
improving technologies; therefore, there would be no incremental
shipping cost associated with higher efficiency levels. As discussed in
section IV.C.2.f of this document, DOE accounted for the incremental
cost of efficiency improving technologies for unit coolers as part of
the manufacturing production cost. DOE maintained its shipping cost
methodology for refrigeration systems from the March 2024 NODA. For
further discussion on the methodology used for estimating shipping
costs, as well as some minor analytical updates made to the shipping
costs for non-display doors and panels, see chapter 5 of the final rule
TSD.
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/(W-h))
versus MSP (in dollars) for refrigeration systems. The methodology for
developing the curves started with determining the energy consumption
or efficiency 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 final rule
TSD for additional details on the engineering analysis and appendix 5A
of the final rule TSD for complete cost-efficiency results.
D. Markups Analysis
The markups analysis develops appropriate markups (e.g.,
distributor markups, retailer markups, contractor markups) in the
distribution chain and sales taxes to convert the MSP 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.
DOE developed baseline and incremental markups for each actor in
the distribution chain. Baseline markups are applied to the price of
products 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.\61\
---------------------------------------------------------------------------
\61\ Because the projected price of standards-compliant products
is typically higher than the price of baseline products, 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.
---------------------------------------------------------------------------
Regarding its markup analysis in the September 2023 NOPR analysis,
DOE received comments from AHRI, Hussmann, and Lennox.
Lennox commented that the NOPR Table IV.22 indicates a
significantly discounted incremental markup from the baseline markup,
which Lennox stated is not aligned with business practices. Lennox
commented that significantly reduced margins can cause manufacturers to
exit the market. Lennox commented that businesses strive to maintain
margin percentages to meet investor expectations for return on
investment. Lennox additionally commented that when previous DOE
rulemakings have impacted equipment manufactured by Lennox, the
increased cost associated with increased efficiency standard levels has
not resulted in lower markup percentages. Lennox recommended that DOE
apply a consistent markup level reflective of the current market markup
to reflect current practices to maintain investor expectations in terms
of return on investment. (Lennox, No. 70 at pp. 5-6)
In response to Lennox, DOE notes that, as previously mentioned, the
incremental markup is meant to reflect the changes in a firm's variable
costs that are associated with improving efficiency and change as a
function of
[[Page 104696]]
equipment MSP. These incremental markups are determined for each agent
in the distribution channel and described in detail in chapter 6 of the
final rule TSD. With regard to capturing the businesses practice of
maintaining margins to meet investor expectations, DOE refers to the
manufacturer markup, which is applied to the MPCs to arrive at the MSPs
and captures a manufacturer's profit margin (constant markup). The MSPs
derived in the engineering analysis and used in the LCC and PBP
analyses and NIA reflect a constant manufacturer markup 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. See section IV.C.2.h or section IV.J.3.b of this
document for additional information.
As part of this analysis, DOE identifies key market participants
and distribution channels. For walk-in coolers and freezers, the main
parties in the distribution chain are: direct-to-consumer sales
(national accounts), HVAC and refrigeration contractors, walk-in cooler
and walk-in freezer distributors, OEMs, and wholesalers. The magnitude,
in terms of units shipped through each channel, is shown in Table
IV.29.
In the context of this analysis, OEMs are mostly manufacturers of
envelope insulation panels who may also sell and install entire walk-in
units to final consumers. 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.29
shows the distribution channels DOE defined for this analysis. Table
IV.30 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 subsequent LCC analysis,
regional markup multipliers were developed and 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. After identifying the six distribution channels listed in Table
IV.29, DOE relied on economic data from the U.S. Census Bureau \62\ and
other sources \63\ to determine how prices are marked up as equipment
is passed from the manufacturer to the customer.
---------------------------------------------------------------------------
\62\ U.S. Census Bureau. Electrical, Hardware, Plumbing, and
Heating Equipment and Supplies: 2020. 2020. Washington, DC Report
No. EC-02-421-17.
\63\ Heating, Air Conditioning & Refrigeration Distributors
International. 2012 Profit Report (2011 Data). 2012. Columbus, OH.
---------------------------------------------------------------------------
Lennox, supported by AHRI, commented that its analysis of e-
commerce channels for dedicated condensing equipment, unit coolers, and
single-package refrigeration unit systems demonstrates (today) that e-
commerce is a channel used to source refurbished used equipment. Lennox
stated that dedicated condensing units and unit coolers require
knowledgeable personnel to specify the equipment. Further, Lennox
commented that EPA's technology transition to low-GWP refrigerants
including A2Ls and CO2 coming to the market can increase the
complexity of selection (of equipment) substantially, which may
adversely affect the rate of e-commerce adoption. Additionally, Lennox
commented that single-package refrigeration units, on the other hand,
could have increased e-commerce adoption because of the self-contained
nature of the equipment and its simpler application. (Lennox, No. 70 at
pp. 7-8; AHRI, No. 72 at p. 11)
Lennox commented it is not aware of readily available information
on the size of the e-commerce channel. (Id.) Hussmann commented that
few of its customers leverage e-commerce in limited applications
through internal systems, and they are an insignificant driver in terms
of sales. (Hussmann, No. 75 at p. 11)
For this final rule analysis, DOE agrees with Lennox's (and AHRI'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 is
outside the scope of this rulemaking and 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 September 2023 NOPR analysis.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.046
[[Page 104697]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.047
BILLING CODE 6410-01-C
Chapter 6 of the final rule 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. DOE's
methodology for this final rule is unchanged from that presented in its
September 2023 NOPR analysis.
1. Trial Standard Levels
In the September 2023 NOPR, 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. TSL 3 in the September
2023 NOPR represented the efficiency levels that use the combination of
design options for each representative unit at the maximum
technologically feasible level. TSLs 1 and 2 in the September 2023 NOPR
represented combinations of efficiency levels of all representative
units that each provided progressively more energy savings while
delivering a positive savings benefit to consumers. At TSLs 1 and 2,
the efficiency levels for non-display doors and structural panels were
constrained such that improvements to insulation were harmonized across
non-display doors and structural panels to avoid a circumstance where
DOE would
[[Page 104698]]
propose a standard where one component would necessitate increased
insulation thickness, but not the other. Thus, the efficiency levels at
TSLs 1 and 2 were 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 sought comment in the September 2023 NOPR on its assumptions and
rationale for harmonizing panel and non-display door thicknesses at a
given TSL. 88 FR 60746, 60786.
In response to the September 2023 NOPR, RSG stated agreement with
DOE's proposal to harmonize panel and door thickness as this move
should have a positive impact across the industry. (RSG, No. 69 at p.
2) Kolpak also agreed that panels and non-display doors should be of
the same thickness so that the doors and panels are flush. (Kolpak, No.
66, Attachment 1 at p. 2) In light of the comments received from RSG
and Kolpak, DOE maintained its approach from the September 2023 NOPR
harmonizing structural panel and door insulation thicknesses for a
given TSL.
ASAP et al. recommended that DOE revisit the proposed efficiency
levels for certain single-packaged equipment classes. ASAP et al.
referenced DOE's stated intent for TSL 2 (i.e., the proposed level) to
represent the combination of design options that results in the
greatest energy savings with a positive net present value at 7 percent
for a given equipment class. ASAP et al. asserted for several single-
packaged equipment classes, it appears that the proposed standards do
not reflect DOE's intended criteria for TSL 2. In particular, ASAP et
al. stated that the following equipment classes for WICF refrigeration
systems could be revisited: (1) in the case of outdoor medium-
temperature single-packaged dedicated systems (SP.M.O), DOE proposed
efficiency level ``EL'' 1, but EL 3 appears to be cost-effective; (2)
in the case of outdoor low-temperature single-packaged dedicated
systems (SP.L.O), DOE proposed the baseline level, but EL 2 appears to
be cost-effective; (3) in the case of indoor high-temperature single-
packaged dedicated systems (SP.H.I), DOE's LCC results show positive
savings at TSL 3 (equivalent to EL 2 for both representative units),
and it is unclear whether DOE has selected the correct EL to satisfy
the TSL 2 criteria for this equipment class; and (4) in the case of
ducted indoor and outdoor, high-temperature single-packaged dedicated
systems (SP.H.I.D and SP.H.O.D) equipment classes, TSL 2 is stated to
represent EL 6 (4.83 AWEF) for the SP.H.OD 7 kBtu/h representative
unit, but the proposed standard is only 4.41 AWEF, which does not
correspond to any evaluated EL. (ASAP et al., No. 77 at p. 6)
Similarly, the CA IOUs recommended that DOE consider crankcase
heater controls and enhanced thermal insulation design options in TSL 2
for low-temperature outdoor single-packaged systems (SP.L.O). The CA
IOUs stated that, according to DOE's engineering analysis, the
crankcase heater controls increase the efficiency of outdoor low-
temperature packaged systems with minimal additional cost, and that
improved thermal insulation improves AWEF2 with minimal cost. (CA IOUs,
No. 76 at p. 11)
As mentioned previously, in the September 2023 NOPR, TSL 2
represented combinations of efficiency levels that provided
progressively more energy savings than TSL 1 while maintaining positive
savings benefit to consumers. 88 FR 60746, 60786. In the March 2024
NODA, DOE analyzed three slightly different TSLs than what was analyzed
in the September 2023 NOPR. In the March 2024 NODA, TSL 1 represented
the efficiency levels that yield AWEF2 values closest to those AWEF2
values that align with TSL 2 from the September 2023 NOPR, and TSL 3
represented max-tech efficiency levels. DOE notes that while LCC
analysis results often can correlate with national impact analysis
(``NIA'') results, this is not always the case. In the case of non-
ducted high-temperature single-packaged dedicated systems analyzed in
the September 2023 NOPR, the LCC savings were positive, but the NIA
results were negative for TSL 3. 88 FR 60746, 60850. Additionally, in
light of the comments received by ASAP et al. and the CA IOUs, DOE
analyzed a new intermediate TSL 2 in the March 2024 NODA. Specifically,
DOE mapped: (1) EL 8 to TSL 2 for SP.M.O.002 and EL 3 to TSL 2 for
SP.M.O.009; (2) EL 2 to TSL 2 for SP.L.O, which represents a level with
crankcase heater controls; (3) EL 2 to TSL 2 for SP.H.I; (4) EL 2 and 6
to TSL 2 for SP.H.I.D and SP.H.O.D, respectively. In the case of non-
ducted high-temperature single-packaged dedicated systems analyzed in
the September 2023 NOPR, the LCC savings were positive, but the NIA
results were negative for TSL 3. 89 FR 18555, 18565-18566. In this
final rule, DOE is adopting TSL 2 for refrigeration systems, which as
discussed in this paragraph is consistent with the suggestions of ASAP
et al.
Regarding ASAP et al.'s comment about the ducted indoor and
outdoor, high-temperature single-packaged dedicated systems, DOE's
engineering and economic analysis was based on representative external
static pressures for the evaporator and condenser sections of the
system. However, when developing the equation for the proposed
standards, DOE applied an additional adjustment factor to the AWEF2
value that corresponds to TSL 2 to account for the potential range in
external static pressures that could be allowed for different systems.
As such, the AWEF2 values that result from the equation proposed in the
September 2023 NOPR are lower than the AWEF2 values that correspond to
the representative units at TSL 2, to account for additional energy
that would be used in a test to deliver the higher external static
pressure (half of the maximum allowed for the system, in accordance
with the test procedure) for such systems that have higher pressure
capability. These adjustment factors were based on the highest external
static pressure available on the market for the given equipment class.
DOE adopted this approach rather than set standards for ducted high-
temperature dedicated systems that vary both with capacity and external
static pressure capability.
In the March 2024 NODA, DOE presented three TSLs for refrigeration
systems and non-display doors. For refrigeration systems, TSL 3
included the efficiency levels that use the combination of design
options for each representative unit at the max-tech level. TSL 1
represented the efficiency levels in the NODA that yielded AWEF2 values
closest to those AWEF2 values of the proposed standards (TSL 2) in the
September 2023 NOPR. TSL 2 was an intermediate TSL that was higher than
TSL 1 but below the max-tech level. For non-display doors, TSL 3
included the efficiency levels that used the combination of design
options for each representative unit at the max-tech level. TSL 1 and
TSL 2 were intermediate TSLs between baseline and TSL 3. 89 FR 18555,
18565-18567.
In this final rule, DOE analyzed three TSLs for walk-in doors,
panels, and refrigeration systems. For display doors and panels, DOE
analyzed the same three TSLs as it did in the September 2023 NOPR,
where TSL 3 was the max-tech efficiency levels and TSL 1 and 2 were set
to the baseline because the consumer savings were negative for all the
other available efficiency levels. To
[[Page 104699]]
summarize here for display doors connected to a TSL 2 refrigeration
system: For low-temperature display doors at EL 1, the improvement from
3-pane glass with argon fill to 3-pane glass with krypton fill results
in an average LCC impact of -$5 with 67 percent of consumers having a
net cost. At EL 2 (max-tech), the improvement for low-temperature
display doors from 3-pane glass with krypton fill to 2-pane vacuum-
insulated glass results in an average LCC impact of -$1,062 with 100
percent of consumers having a net cost. For medium-temperature display
doors at EL 1, the improvement from 2-pane glass with argon fill to 3-
pane glass with argon fill results in an average LCC impact of -$29
with 94 percent of consumers having a net cost. At EL 2 (max-tech), the
improvement for medium-temperature display doors from 2-pane glass with
argon fill to 2 pane vacuum-insulated glass results in an average LCC
impact of -$1,304 with 100 percent of consumers having a net cost. For
panels connected to a TSL 2 refrigeration system: For low-temperature
floor panels (PF.L) at EL 1, the improvement from 3.5 inches of
insulation to 4 inches of insulation results in an average LCC impact
of -$0.16 per ft\2\ with 91 percent of consumers having a net cost. At
EL 2 with the improvement to 5 inches of insulation the average LCC
impact is-$0.19 per ft\2\ with 74 percent of consumers having a net
cost. At EL 3 (max tech) with the improvement is to 6 inches of
insulation the average LCC impact is -$0.52 per ft\2\ with 83 percent
of consumers having a net cost. For low-temperature structural panels
(PS.L) at EL 1, the improvement from 4 inches of insulation to 5 inches
of insulation results in an average LCC impact of -$0.10 per ft\2\ with
67 percent of consumers having a net cost. At EL 2 (max tech) with the
improvement is to 6 inches of insulation the average LCC impact is -
$0.24 per ft\2\ with 70 percent of consumers having a net cost. For
medium-temperature structural panels (PS.M) at EL 1, the improvement
from 3.5 inches of insulation to 4 inches of insulation results in an
average LCC impact of -$0.47 per ft\2\ with 100 percent of consumers
having a net cost. At EL 2 with the improvement is to 5 inches of
insulation the average LCC impact is -$1.37 per ft\2\ with 100 percent
of consumers having a net cost. At EL 3 (max tech) with the improvement
is to 6 inches of insulation the average LCC impact is -$2.37 per ft\2\
with 100 percent of consumers having a net cost. Detailed consumer
results are presented by EL in appendix 8C of this final rule TSD.
For non-display doors, dedicated condensing units, and single-
packaged dedicated systems, DOE generally analyzed the same three TSLs
as it did in the March 2024 NODA.\64\ For unit coolers, DOE generally
analyzed the same three TSLs as it did in the September 2023 NOPR.\65\
---------------------------------------------------------------------------
\64\ DOE notes that in this final rule, TSL 2 for low-
temperature, outdoor dedicated condensing units matches the mapping
of the March 2024 NODA TSL 1, not the March 2024 NODA TSL 2. This
difference only changed the efficiency level mapping of the highest
capacity representative unit.
\65\ For the highest capacity representative unit of medium-
temperature unit coolers the efficiency level mapped in TSL 1 and 2
has changed from efficiency level 2 in the September 2023 NOPR to
efficiency level 0 in this final rule.
---------------------------------------------------------------------------
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.048
[[Page 104700]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.049
[GRAPHIC] [TIFF OMITTED] TR23DE24.050
[[Page 104701]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.051
[GRAPHIC] [TIFF OMITTED] TR23DE24.052
[[Page 104702]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.053
When setting standards equations that vary with capacity for
refrigeration systems of walk-ins, DOE used as a guide the efficiency
levels of the selected TSL. The AWEF2 values associated with these
efficiency levels can vary as a function of representative capacity.
For example, for the outdoor, medium-temperature dedicated condensing
units, DOE analyzed five representative units (at five different
capacities). At each TSL, each representative unit may be mapped to a
different efficiency level that may correspond to a different AWEF2
value. Once a TSL has been selected to propose or adopt, DOE developed
an equation to define the selected standard level at all capacities
(not just the representative capacities analyzed). The equation aligns
with the efficiency levels of the representative units associated with
the selected TSL. The equation may take the form of a set of equations
to more closely follow the analyzed ELs. To avoid setting a standard
made up of an excessive number of equations, DOE may use a line
providing a best fit through a set of efficiency levels and capacities.
In this final rule, DOE is setting standards equations for
refrigeration systems as a function of capacity for most equipment
classes by using sets of equations that provide a balance of limiting
the number of equations covering the relevant capacity range and
maintaining reasonable consistency with the AWEF2 associated with the
selected TSL. For medium-temperature unit coolers, the finalized
standard represents fewer equations than presented in the March 2024
NODA, while also considering both the September 2023 NOPR and March
2024 NODA comments and not overshooting the representative capacity
efficiency levels associated with the selected TSL.
DOE used a line of best fit that is a function of door surface area
to develop the non-display door standards equations presented in the
September 2023 NOPR, March 2024 NODA, and this final rule. Each
equipment class for doors has three representative units (small,
medium, and large surface area). Similar to refrigeration systems, at
each TSL, each representative unit is mapped to an efficiency level
that corresponds to a different DEC value. For the TSL that is
selected, DOE used a line of best fit through the DEC values of each
representative unit to determine the first two terms of the standard
equations. For the remaining terms of the standard equations, which
correspond to the allowances for additional electrical components, DOE
developed coefficients to represent the additional energy consumption
allowance for a component which are then multiplied by a 1 or a 0 based
on the presence or absence of that component in a basic model. DOE
maintained this approach for setting the amended standards equations
for non-display doors in this final rule.
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-
[[Page 104703]]
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 September 2023 NOPR analysis.
[GRAPHIC] [TIFF OMITTED] TR23DE24.054
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 appendices
of the 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 incorporated into the energy use
calculation. Detailed equations and input data are presented for each
equipment type in chapter 7 of this final rule TSD.
a. 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 32050, 32083; 82 FR 31808, 31842.
During the rest of the time, the system is in off-mode, so the only
energy consumption is from the controls, crankcase heat, and evaporator
fan.
AHRI commented that DOE's application of 16 hours per day run time
is significantly low. AHRI suggested using, based on engineering manual
guidelines for a range of applications, the following nominal run-time
hours: (AHRI, No. 72 at p. 11)
35 [deg]F room with no timer: 16 hours,
35 [deg]F room with timer: 16 hours,
Blast coolers/freezers with positive defrost: 18 hours,
Storage freezer 18 hours,
Coolers with hot gas or electric defrost 18 hours, and
50 [deg]F rooms and higher with coil temperatures above 32
[deg]F: 20-22 hours.
(Id.)
[[Page 104704]]
Additionally, NRAC presented the following run-time hours: high-
temperature 20 hours, medium-temperature 16 hours, and low-temperature
18 hours. (NRAC, No. 73 at p. 2)
In response to AHRI and NRAC, DOE notes that the run-time
guidelines provided for low- and medium-temperature equipment are in
alignment with those used by DOE in the September 2023 NOPR analysis.
With regard to the comments regarding the run-time hours of high-
temperature equipment, DOE notes that the values submitted by AHRI are
identical to those submitted by Lennox in the September 2023 NOPR where
it was noted that the run-time guidelines Lennox provided were
specifically for determining the box cooling load for prep-room
applications; and DOE then noted that these guidelines encompass
equipment not currently covered by the standard. 88 FR 60746, 60789. It
continues that DOE's response is still valid, where applying 16 hours
as the nominal run-time hours for high-temperature single-packaged
dedicated condensing systems and unit coolers is appropriate as a
modeling assumption because the intended cooling temperature of high-
temperature equipment is like that of medium-temperature systems at 35
[deg]F. 88 FR 60746, 60789.
For this final rule, 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 September
2023 NOPR for all other classes. DOE notes that it will continue in its
subgroup analysis to 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.1 of this
document. DOE's applied run-time hours are shown in Table IV.38.
[GRAPHIC] [TIFF OMITTED] TR23DE24.055
4. Estimated Annual Energy Consumption
Table IV.39 through Table IV.42 show the average annual energy
consumption for the equipment considered in this final rule.
[GRAPHIC] [TIFF OMITTED] TR23DE24.056
[[Page 104705]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.057
[GRAPHIC] [TIFF OMITTED] TR23DE24.058
[[Page 104706]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.059
Chapter 7 of the final rule 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 (MSP, 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.
1. Consumer Sample
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'').\66\ 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.
---------------------------------------------------------------------------
\66\ U.S. Energy Information Administration. Commercial
Buildings Energy Consumption Survey 2018, 2022.
---------------------------------------------------------------------------
Inputs to the LCC calculation include the installed cost to the
consumer, operating expenses, the lifetime of the product, and a
discount rate. Inputs to the calculation of total installed cost
include the cost of the equipment--which includes MPCs, manufacturer
markups, retailer and distributor markups, and sales taxes--and
installation costs. Inputs to the calculation of operating expenses
include AEC, energy prices and price projections, repair and
maintenance costs, equipment lifetimes, and discount rates. Inputs to
the PBP calculation include the installed cost to the consumer and
first year operating expenses. DOE created distributions of values for
equipment 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 Monte
Carlo simulations 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
calculates the LCC for equipment at each trial standard 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
[[Page 104707]]
efficiency distribution. In performing an iteration of the Monte Carlo
simulation for a given consumer, product efficiency is chosen based on
its probability. If the chosen equipment's 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 are already projected
to purchase more-efficient products in a given case, DOE avoids
overstating the potential benefits from increasing equipment
efficiency.
DOE calculated the LCC and PBP for consumers of walk-ins as if each
were to purchase new equipment in the expected year of required
compliance with new or amended standards. Amended standards would apply
to walk-ins manufactured after December 31, 2028 for refrigeration
equipment, and January 1, 2028 for envelope components after the date
on which any new or amended standard is published.\67\ (42 U.S.C.
6313(f)(5)(B)(i)) At this time, DOE estimates publication of a final
rule in late 2024; therefore, for purposes of its analysis, DOE used
2028 as the first year of compliance with any amended standards for
walk-ins for envelope components, and 2029 for refrigeration systems
because the compliance date is late in the calendar year.
---------------------------------------------------------------------------
\67\ Refrigeration equipment refers to equipment classified
under this rulemaking as: dedicated condensing systems, single-
packaged dedicated condensing systems, and unit coolers (see section
IV.A.1.c of this document). Envelope components refer to the
equipment classified under this rulemaking as: display doors, non-
display doors, and panels (see sections IV.A.1.a and IV.A.1.b of
this document).
---------------------------------------------------------------------------
Table IV.43 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 model, and of all the inputs
to theLCC and PBP analyses,are contained in chapter 8 of the TSD and
its appendices.
[GRAPHIC] [TIFF OMITTED] TR23DE24.060
2. Equipment Cost
To calculate consumer equipment 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 equipment and higher-efficiency equipment because DOE applies
an incremental markup to the increase in MSP associated with higher-
efficiency equipment.
Senneca and Frank Door commented that there were inconsistencies
between
[[Page 104708]]
DOE's documentation of the applied historical price index between the
September 2023 NOPR and TSD as DOE cited multiple producer price index
(``PPI'') indices. Senneca and Frank Door further noted that in their
opinion, any PPI index would be inappropriate for projecting the future
price of non-display doors. (Senneca and Frank Door, No. 78 at pp. 8-
10)
DOE's analysis limits the impacts of potential future price
uncertainty as it pertains to the cost impacts to consumers and more
broadly to the Nation. For WICFs, DOE identified two potential
historical producer price indices to create upper and lower analytical
bounds on walk-in prices, which DOE used to inform its decision in this
final rule. DOE notes that it has not applied any price trends in its
reference case, indicating that prices will remain static relative to
inflation into the future--as it did in the September 2023 NOPR. In
response to Senneca and Frank Door's comment that there were
inconsistencies between the documentation and applied price indices in
the TSD and September 2023 NOPR, DOE acknowledges the typographical
error in the September 2023 NOPR notice, 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) which is corrected here in this final rule; see Table
IV.44. While Senneca and Frank Door is of the opinion any PPI index
would be inappropriate for projecting the future price of non-display
doors, they did not provide an alternative methodology that they
considered appropriate; nor did they provide information or data which
DOE could use with its current methodology. DOE notes that the PPI
series of historical data used in the September 2023 NOPR was series
PCU3334153334153 for Commercial refrigerators and related equipment,
(``CRE'') while not specifically for walk-in doors, include the
production of doors for commercial refrigerators-which are both solid
and transparent in design and an appropriate analog for walk-in non-
display, and display doors. In the absence of more specific
information, DOE will continue to use the PPI trend for CRE (PPI
PCU3334153334153) that includes equipment with solid (non-display)
doors.
For this final rule analysis, DOE continued to use the same
methodology as the September 2023 NOPR to determine the high and low
trends, where DOE examined historical PPI data for commercial
refrigerators and related equipment manufacturing available between
1980 and a portion of 2024 from the BLS.69 70 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.
---------------------------------------------------------------------------
\69\ At the time of writing data were available through April of
2024.
\70\ Product series ID: PCU3334153334153. Available at
www.bls.gov/ppi/.
---------------------------------------------------------------------------
As in the September 2023 NOPR a spike in the trend of annual real
prices between 2021 and 2022 can be observed. However, when the PPI is
examined at a month-by-month level, the nominal PPI from 2022 through
2024 shows the PPI to leveling off. Additionally, the engineering
analysis was conducted in 2024 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 benefits scenario results shown in section V.C of
this document.
[[Page 104709]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.061
ASAP et al. requested that DOE harmonize its approach to projecting
future prices of equipment with variable-speed controllers with its
ongoing rulemaking for Commercial Refrigerators, Freezers, and
Refrigerator-
[[Page 104710]]
Freezers (``CRE''). 88 FR 70238. (ASAP et al., No. 77 at p. 3)
In response to ASAP et al., which requested that DOE include the
declining price trend for variable-speed controllers as it has applied
in its CRE analysis, DOE has not included this trend in its reference
case, consistent with the analysis presented in the September 2023
NOPR, but has included it in the high benefits sensitivity scenario.
Further, the MPCs of the controllers themselves to which the trend is
applied are not significant enough when compared to the total LCC
impacts that they would change DOE's policy decision regarding amended
standards, see Table IV.45.
[GRAPHIC] [TIFF OMITTED] TR23DE24.062
[[Page 104711]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.063
DOE received no other comments on its future price trend. For this
analysis, DOE maintained the same approach for determining future
equipment prices as in the September 2023 NOPR and assumed that
equipment prices would be constant over time in terms of real dollars,
i.e., constant 2023 prices.
a. Application of the Low-GWP Refrigerant Transition to Specific
Regions
As discussed in section IV.C.1.e of this document, the States of
California and Washington require the use of sub-150-GWP refrigerants.
As discussed in section IV.C.2.c of this document, DOE has determined
that an increase in MSP to use sub-150-GWP refrigerants will affect
dedicated condensing systems of 25 kBtu/h capacity as a function
increased efficiency. In the September 2023 NOPR, DOE conducted its LCC
analysis at the geographic level of census regions, where the region
containing the States of California and Washington is the Western
Region (Region 4).\71\ To approximate any additional costs to consumers
derived from the State level initiatives in California and Washington
associated with moving to low-GWP refrigerants, DOE applied the cost of
the additional design options determined in section IV.C.1.e of this
document to the fraction of consumers in the Western Census Region
based on population as a sensitivity analysis, see appendix 8E of the
final rule TSD.\72\ These weights and additional design option costs
are shown in Table IV.46. DOE notes that these additional consumer
costs are the results of state regulations and would be incurred in the
absence of this final rule.
---------------------------------------------------------------------------
\71\ See www2.census.gov/geo/pdfs/maps-data/maps/reference/us_regdiv.pdf.
\72\ See www.census.gov/data/tables/time-series/demo/popest/2020s-state-total.html.
---------------------------------------------------------------------------
[[Page 104712]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.064
3. Installation Cost
a. Refrigeration Systems
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the product. In the September
2023 NOPR, DOE found that the data from RSMeans 2023 \73\ (``RSMeans'')
did not indicate that installation costs would be impacted with
increased efficiency improvement. 88 FR 60746, 60794.
---------------------------------------------------------------------------
\73\ Reed Construction Data, RSMeans Facilities Maintenance &
Repair 2023 Cost Data Book, 2023.
---------------------------------------------------------------------------
However, for refrigeration systems in the September 2023 NOPR DOE
tentatively concluded that in the standards case there would be costs
associated with improvements to controls. 88 FR 60746, 60795. 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. RSMeans shows that the amount of time to configure most
controls is half an hour of labor, while for variable-capacity HVAC
drives--used as a proxy for variable-capacity refrigeration
compressors--the amount of labor is 2 hours. DOE assumed the average
nonunion shop rate to be $154 (2023$) per hour.\74\ The difference in
approach from the September 2023 NOPR and this final rule is that DOE
has removed the commission charges associated with the crankcase heater
and variable-speed condenser fan motors design options (CCHC, VSCF) as
these are factory configured to provide optimal operation. 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. 88 FR 60746, 60795.
---------------------------------------------------------------------------
\74\ See series 230953103620 and 230953103680.
---------------------------------------------------------------------------
[[Page 104713]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.065
b. Cooler and Freezer Panels
In the September 2023 NOPR, DOE included an 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. 88 FR 60746, 60796.
ASAP et al. and RBA commented they were concerned that DOE is
adding additional unwarranted installation costs for panel insulation
greater than 4 inches, and that DOE's analysis appeared to assume that
all walk-in panels with insulation greater than 4 inches would have a
$0.50 per ft\2\ installation cost increase associated with required
thermal barriers for non-
[[Page 104714]]
sprinklered building installations. ASAP et al. and RBA commented that
the metal facing requirement is only relevant for non-sprinklered
buildings, which they expect to represent a very small portion of walk-
in installations--walk-ins under 400 ft\2\ in area. Additionally, ASAP
et al. and RBA commented that metal facing requirement to be inclusive
of panels with 4 inches of insulation in non-sprinklered buildings.
(ASAP et al., No. 77 at p. 5; RBA, No. 68 at pp. 1-2)
DOE revised the installation cost for medium-temperature structural
panels: since DOE assumes a baseline low-temperature panel is 4 inches
thick, there would be no additional installation charges for low-
temperature panels in the amended standards case. To address additional
installation costs for medium-temperature structural panels for WICF
under 400 ft\2\ DOE maintained the installation cost of $0.50 per ft\2\
for medium-temperature panels equal to or greater than 4 inches thick
and applied the additional installation costs to the fraction of small
businesses in the consumer sample (see chapter 8 of the final rule
TSD).
For further information on the derivation of installation costs,
see chapter 7 of the final rule TSD.
4. Annual Energy Consumption
For each consumer from the consumer sample (see section IV.F.1of
this document), DOE determined the energy consumption for walk-ins of
the different efficiency levels determined in the engineering analysis
(see section IV.C 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 changes
in consumer costs than average electricity prices. Therefore, DOE
applied average electricity prices for the energy use of the equipment
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 2023 using data from Edison
Electric Institute's Typical Bills and Average Rates
reports.75 76 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).\77\
---------------------------------------------------------------------------
\75\ Edison Electric Institute, Typical Bills and Average
Rates--Summer 2023, 2024, ISBN: 978-1-938066-08-5.
\76\ Edison Electric Institute, Typical Bills and Average
Rates--Winter 2023, 2023, ISBN: 978-1-938066-05-4.
\77\ 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. Available at ees.lbl.gov/publications/non-residential-electricity-prices.
---------------------------------------------------------------------------
For this final rule, DOE maintained the methodology it used in the
September 2023 NOPR analysis where electricity prices 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''),\78\
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 most recent publication of 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 used to
calculate the marginal electricity rates can be found in appendix 8B of
the final rule TSD.
---------------------------------------------------------------------------
\78\ Available at www.eia.doe.gov/cneaf/electricity/page/eia861.html.
---------------------------------------------------------------------------
[[Page 104715]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.066
BILLING CODE 6410-01-C
a. Future Electricity Prices
To estimate energy prices in future years in the September 2023
NOPR analysis, DOE multiplied the 2022 energy prices by the projection
of annual average price changes for each of the nine census divisions
from the Reference case in AEO2023, which has an end year of 2050.\79\
To estimate price trends after 2050, DOE assumed constant real prices
at the 2050 rate. 88 FR 60747, 60797.
---------------------------------------------------------------------------
\79\ EIA. Annual Energy Outlook 2023 with Projections to 2050.
Available at www.eia.gov/forecasts/aeo/ (last accessed February 13,
2023). Note: AEO2023 is the most recent edition as the EIA is not
publishing a 2024 edition.
---------------------------------------------------------------------------
Senneca and Frank Door commented that there is no basis for DOE to
assume that energy prices will remain static after 2050, noting that
the prices would fluctuate. (Senneca and Frank Door, No. 78 at pp. 6-7)
DOE agrees with Senneca and Frank Door that when average annual
electricity prices are observable in retrospect, they indeed fluctuate.
The future price projection estimated in AEO2023 is a modelled
projection, and AEO has determined that its projections beyond 2050 are
too uncertain to include at this time. DOE is required to estimate the
value of energy savings in its analysis and needs a price of
electricity for future years beyond 2050 to accomplish this task. For
DOE to add manufactured fluctuations to this projection for the sake of
aesthetics would introduce unneeded uncertainties to this analysis.
Finally, by maintaining constant prices at 2050 levels, DOE is in
effect minimizing the benefits of this rulemaking because the price at
2050 is the lowest over the period from 2022 to 2050. For this final
rule, DOE will maintain the use of static 2050 prices in its future
commercial electricity prices for years beyond the horizon of the
AEO2023 projection.
6. Maintenance and Repair Costs
Repair costs are associated with repairing or replacing equipment
components that have failed in an appliance; maintenance costs are
associated with maintaining the operation of the equipment. Typically,
small incremental increases in equipment efficiency entail no, or only
minor, changes in repair and maintenance costs compared to baseline
efficiency equipment.
DOE received comments regarding its modeling assumptions for
maintenance and repair costs where DOE applied to each an annual cost
of 10 percent in response to the September 2023 NOPR. 88 FR 60746,
60797.
[[Page 104716]]
AHRI commented that the technologies listed are currently used
today but could not comment on actual dollars associated with them.
(AHRI, No. 72 at p. 11) RSG commented that shifts toward WICF
technologies described in the screening analysis (see chapter 4 of the
TSD) would most certainly increase maintenance and repair costs by
significant amounts. RSG added that these costs would be for
specialized component sourcing/availability, specialized service
training, special safety concerns, and mitigation, etc. (RSG, No. 69 at
p. 2) Hussmann agreed with the views presented by AHRI regarding
information about the maintenance and repair costs of WICFs with the
technologies described in section IV.C of the September 2023 NOPR.
(Hussmann, No. 75 at p. 11)
ASAP et al., the CA IOUs, and Senneca and Frank Door, commented
that they disagreed with the applied maintenance and repair costs.
(ASAP et al., No. 77 at p. 4; CA IOUs, No. 76 at pp. 11-12; Senneca and
Frank Door, No. 78 at p. 7)
Senneca and Frank Door provided no details regarding the
appropriateness of the applied maintenance and repair costs.
ASAP et al. commented that the assumed maintenance costs
contributed heavily to negative LCC savings at higher efficiency
levels. ASAP et al. further encouraged DOE to examine its commercial
air conditioning rule--where it was assumed that maintenance costs did
not increase with improved efficiency; and in its CRE NOPR where
additional labor ($15 per year) was considered for the cleaning of
microchannel condenser coils.80 81 ASAP et al. encouraged
DOE to adopt maintenance costs modeling assumptions where additional
costs would only apply to larger condenser coil design options. (ASAP
et al., No. 77 at p. 4)
---------------------------------------------------------------------------
\80\ U.S. Department of Energy, Energy Conservation Program:
Energy Conservation Standards for Air-Cooled Commercial Package Air
Conditioners and Heat Pumps Direct Final Rule, EERE-2022-BT-STD-
0015, May 2024, https://www.regulations.gov/document/ EERE-2022-BT-
STD-0015.
\81\ U.S. Department of Energy, Energy Conservation Program:
Energy Conservation Standards for Commercial Refrigerators,
Freezers, and Refrigerator-Freezers Notice of Proposed Rulemaking,
EERE-2017-BT-STD-0007, October 2023, https://www.regulations.gov/document/EERE-2017-BT-STD-0007-0056.
---------------------------------------------------------------------------
The CA IOUs requested that DOE reconsider its maintenance cost
modeling assumptions. The CA IOUs commented DOE's assumption that
maintenance and repair costs are equal to 10 percent of the unit total
cost per year is not accurate. The CA IOUs commented that the
maintenance costs for condenser coil cleaning are not directly
proportional to coil size (or cost); rather, the cost is due to the
refrigeration technician's labor to access the walk-in condenser coil.
The CA IOUs provided information on typical refrigeration technician
charges of $100 to $250 per hour depending on the region, with a
minimum of an hour for any service call, while other technicians have a
``flat truck roll fee'' ranging between $50 and $150 per service
call.\82\ Further, the CA IOUs maintained that the labor-cost
difference to clean a small or a larger coil is therefore relatively
small compared to the total cost of arriving on site and cleaning
condenser coils. The CA IOUs added that the maintenance costs for
refrigerant leak repair and recharging depend on the condensing unit
location relative to the unit cooler (refrigerant piping length). (CA
IOUs, No. 76 at p. 11)
---------------------------------------------------------------------------
\82\ A truck roll is changed when a field technician gets
dispatched to a customer or other field agent's location to solve a
problem with an asset.
---------------------------------------------------------------------------
The CA IOUs further commented that other components like EEVs and
variable-speed condenser fans improve efficiency and may increase unit
costs but can also increase the life of componentry due to the reduced
number of times the fan cycles on and off. The CA IOUs recommended
evaluating the repair cost of refrigeration components (i.e.,
contactors, start relays, fan motors, expansion valves, thermostats)
based on the component's average useful life and the component's price
and maintenance costs based on reliable data sources such as average
labor rates, time, and fixed charges by refrigeration technicians. (CA
IOUs, No. 76 at p. 12)
This comment aligns with AHRI's comment that increased repair and
maintenance costs would be commensurate with the increased usage rate
employed to achieve minimum efficiency. (AHRI, No. 72 at p. 11)
AHRI and Hussmann commented that electronically commutated
variable-speed condenser fan motors require an electronic control
module. AHRI and Hussmann commented that use of this sort of motor
requires the use of diagnostic tools to troubleshoot the ECM, which
would add to costs and servicing of systems. AHRI and Hussmann added
that such motors are normally programmed at the factory for parameters
such as head pressure and the outdoor ambient temperature along with
run-time. AHRI and Hussmann commented that therefore, DOE should also
consider costs for this for both OEMs and service technicians as part
of the analysis. (AHRI, No. 72 at p. 7; Hussmann, No. 75 at p. 11)
Based on the comments received, DOE revisited its maintenance costs
modeling assumptions for this final rule analysis.
For panels, maintenance activities encompass periodic cleaning and
visual inspection for damage. DOE is only considering improvements to
efficiency by increasing the thickness of polyurethane foam for cooler
and freezer panels. When examining the per ft\2\ of MPC for panels,
DOE's analysis shows that the cost delta between baseline and max tech
panel thickness is approximately $1 (one) per ft\2\. DOE finds the
material cost for repair to be marginal and without significant
difference to the no-new-standards case; as such, DOE did not apply
repair costs as a function of panel efficiency.
Display door and non-display door maintenance activities encompass
periodic cleaning, visual inspection of all components, lubrication,
and component adjustments to account for wear from use (e.g., adjusting
the door sweep, fastener tightness). There is no indication that the
time required to perform these activities would be a function of
improved efficiency.83 84 85 86
---------------------------------------------------------------------------
\83\ frankdoor.com/plugins/pdfJS/web/viewer.html?file=/webFiles/files/3/Installation/DropTrac%20Installation.pdf.
\84\ frankdoor.com/plugins/pdfJS/web/viewer.html?file=/webFiles/files/10/Installation/Torsion%20Springs.pdf.
\85\ imperialbrown.com/sites/default/files/2017-10/ICC5%20Full%20Manual%20Book_130130.pdf.
\86\ norlake.com/wp-content/uploads/2020/07/132617-Walk-in-Manual.pdf.
---------------------------------------------------------------------------
Similarly, for refrigeration systems, maintenance activities
encompass--but are not limited to--visual periodic inspection of all
components for wear (e.g., fastener tightness, component pitting),
cycle-check of all modes, lubrication, and cleaning (motor, evaporator,
condenser coils, drains/lines, etc.). Ibid.
Based on the comments received and manufacturer's literature cited,
DOE has concluded that maintenance costs are unlikely to materially
change with improved efficiency for walk-in panels and non-display
doors. For refrigeration systems, DOE agrees with the CA IOUs and ASAP
et al. that there may be a potential increased labor associated with
cleaning refrigeration systems; however, it would be marginal when
compared to the cost of dispatching a technician to perform the
periodic maintenance. DOE has therefore concluded that the difference
in maintenance costs between equipment in the no-new-standards and the
[[Page 104717]]
amended standards case would be minimal and is not included in this
final rule. To account for the circumstances described by AHRI and
Hussmann where additional repair costs may be required for
troubleshooting some components DOE has continued to apply the 10
percent MPC per year to account for the increase in material and labor
(troubleshooting) cost associated with troubleshooting and remedying
functional issues.
7. Equipment Lifetimes
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.
DOE received multiple comments regarding the lifetimes of walk-ins.
AHRI and Lennox stated that walk-in lifetimes were generally understood
to be 7 to 9 years--depending on usage and maintenance. (AHRI, No. 72
at pp. 5-6 and No. 86 at p. 9; Lennox, No. 70 at p. 6 and No. 87 at pp.
3-4)
NAFEM agreed with DOE's lifetimes of 20 years for insulated panels
and doors. (NAFEM, No. 67 at p. 3) ASAP et al. commented that DOE
should consider increasing the lifetimes of walk-in panels, citing an
industry report estimating door and panel lifetimes to be between 12
and 25 years--as well as the fact that manufacturers offer warranties
of 15 to 20 years for walk-in panels--suggesting that the expected
lifetimes of walk-in panels significantly exceed DOE's estimations.
(ASAP et al., No. 77 at p. 4) By way of support, ASAP et al. provided
the warranty agreement from PAR Engineering Inc., which offers a 20-
year warranty on its panel installations.\87\ In response to ASAP et
al. and NAFEM, DOE notes that it represents lifetimes as a distribution
of values, and for panels in the September 2023 NOPR this distribution
was characterized with a minimum, maximum, and average lifetime of 2,
25 and 12 years respectively. Further DOE examined the warranty periods
from other manufacturers and found that for panels, these ranged from 1
year 88 89 through the 20 years, with warranties offered to
the original purchasers of panels typically in the 10- to 15-year
range.90 91 92 93 94 95 96 97 98
---------------------------------------------------------------------------
\87\ www.commercialcooling.com/wp-content/uploads/Commercial-Cooling-20-Year-Standard-Panel-Warranty.pdf (Last Accessed: May 10,
2024).
\88\ kpsglobal.com/terms-and-conditions/for-sale-warranty/ (Last
Accessed: May 30, 2024).
\89\ aicheatexchangers.com/wp-content/uploads/2020/09/AIC-Warranty-Statement-LWI-17-02.pdf (Last accessed: May 30, 2024).
\90\ https://norlake.com/wp-content/uploads/2020/07/walk-in-refrigeration-warranties-089604.pdf (Last Accessed: May 30, 2024).
\91\ https://assets.welbilt.com/m/2b0660daf5344f58/original/Warranty-Policy.pdf?__hstc=70905295.ac632688bb7470ba06bf11662e737cbd.1717093685617.1717093685617.1717093685617.1&__hssc=70905295.1.1717093685617&__hsfp=3523199817 (Last Accessed: May 30, 2024).
\92\ https://www.kolpak.com/Service/Kolpak-Warranty (Last
Accessed: May 30, 2024).
\93\ https://imperialbrown.com/sites/default/files/2017-09/Walk-ins%20Warranty_0.pdf (Last Accessed: May 30, 2024).
\94\ https://www.everidge.com/wp-content/uploads/2018/08/ThermalRite-Warranty-Final-6.4.2020.pdf (Last Accessed: May 30,
2024).
\95\ https://leerinc.com/wp-content/uploads/2021/10/Leer-Inc.-Walk-In-Warranty-Packet_v0921.pdf (Last Accessed: May 30, 2024).
\96\ https://www.uscooler.com/support/warranty/ (Last Accessed:
May 30, 2024).
\97\ http://www.americanpanel.com/materials/Service/APC_Walk-in_Warranty_02-22.pdf (Last Accessed: May 30, 2024).
\98\ http://www.ballyrefboxes.com/Bally_FAQ/Bally_warranty.asp
(Last Accessed: May 30, 2024).
---------------------------------------------------------------------------
Based on the comments received and literature examined DOE is
maintaining the lifetime from the September 2023 NOPR for all doors and
panels. DOE notes that the lifetimes, for modeling purposes, are
characterized as a distribution and this distribution for panels
accounts for lifetimes greater than 20 years. For this final rule DOE
updated the lifetimes for refrigeration equipment to the values shown
in Table IV.49.
Additionally, DOE maintained the 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. 88 FR 60746, 60798.
Table IV.49 shows the revised (italicized) minimum, maximum and
average lifetimes for walk-in envelope components and refrigeration
systems.
[GRAPHIC] [TIFF OMITTED] TR23DE24.067
As discussed in section IV.B.1.b of this document, although better
thermally insulating frame systems for non-display doors exist on the
market, some stakeholder comments suggested that such frame designs may
have reduced structural rigidity compared to traditional (e.g., wood)
framing systems. While the presence of this design feature in the walk-
in market does indicate its suitability in a range of current
applications and suggests it does not have a detrimental impact on
product performance or lifetime, DOE is also aware that there is
variability in structural loads that walk-in doors may be subject to
(see generally discussion during the NOPR public meeting as part
[[Page 104718]]
of the previous rulemaking cycle for this equipment, EERE-2008-BT-STD-
0015-0088 at pp. 238-241) and recognizes that there may be remaining
uncertainty regarding the structural suitability of the best thermally-
insulating frame systems available on the market in certain
applications, and the extent to which structural performance of the
door frame may affect product lifetime. More specifically, in the
absence of structural performance data, DOE cannot be certain whether
the differences in non-display door framing systems currently in the
market are due to manufacturer design preferences or specific
durability requirements; e.g., large sliding doors manufactured
separately from the walk-in in which they are installed may warrant a
frame with greater structural durability than doors manufactured
together with the surrounding panels as a complete system. If these
framing system decisions are driven by durability considerations in
such specific cases then establishing standards that DOE expects would
necessitate thermally-improved frame designs could result in the need
for earlier replacement of certain non-display doors in such
applications. Those additional replacement costs would outweigh the
savings in operating costs brought about through energy efficiency
improvements.
Given the application-specific nature of this aspect of non-display
door design and construction, DOE does not have information on the
frequency with which earlier replacement might be required in certain
circumstances, or how much sooner such a replacement might be required
compared to the average 8.5 year service lifetime assumed in this
analysis. Hence, DOE cannot accurately estimate the magnitude of the
lifetime impact (if any) of the thermally-improved frame design option,
and has not included it in its analysis. Given these uncertainties, DOE
instead developed an upper bound sensitivity analysis for consideration
as part of the selection of standard levels. The sensitivity analysis
assumes that in certain circumstances a consumer might experience a
reduction in lifetime. As there is no data or information that DOE is
aware of regarding the relationship between the structural performance
of the door frame and how it may affect product lifetime DOE made the
modelling assumption for this sensitivity that lifetimes could be
reduced by as much as one-half, i.e., requiring replacement at 4.3
years instead of 8.5 years. For example, for a baseline low-temperature
motorized non-display door (NO.L), connected to a TSL 2 refrigeration
system, the total installed cost is estimated to be $6,931 with an
average lifetime of 8.5 years (see Table IV.49). In a circumstance
where the consumer of a low-temperature motorized non-display door
(NO.L) with the thermally improved frame design were to experience a
reduction in lifetime by one-half (from 8.5 years to 4.3 years), the
consumer would be faced with having to purchase a new standards-case
door to maintain the same service lifetime as a non-display door
without the thermally improved frame design. As shown in Table IV.50,
for those consumers, this would decrease their overall life-cycle cost
savings benefits under such a circumstance due to the need to purchase
and install replacement equipment earlier than they would have under
the no-new-standards case. At TSL 3, this could reduce the LCC savings
benefits to a loss over the 8.5-year timespan of approximately -$8,369.
Similarly, for a NO.L at TSL 2 the decrease in overall life-cycle costs
savings benefits could be reduced to -$7,935. DOE notes that this
sensitivity is not intended to be representative of the non-display
door market as a whole nor any specific segment of the market, but to
address stakeholder concerns regarding the robustness of thermally
improved frames in certain circumstances and as a consideration in
assessing the benefits and burdens of this rule, as discussed in
section V.C.1.b. of this document.
[GRAPHIC] [TIFF OMITTED] TR23DE24.068
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 final rule, 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 walk-ins.\99\ 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.
---------------------------------------------------------------------------
\99\ 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.
---------------------------------------------------------------------------
AHRI commented that in a recent refrigerator rulemaking, AHAM
brought to DOE's attention the fact it does not take into account
operating costs, including energy, as deductible business expenses for
Federal and some State income taxes. AHRI cited equation 8.6
[[Page 104719]]
from the Energy Efficiency Program for Consumer Products and Commercial
and Industrial Equipment: Walk-In Coolers and Walk-In Freezers TSD,
which explicitly refers to the tax effects on the cost of debt for
commercial customers. AHRI asked if DOE has modified its LCC model to
include the effects of the deductibility of operating costs for income
tax purposes for commercial customers in its LCC analysis, and if not,
why not? (AHRI, No. 72 at p. 8)
In the February 2023 NOPR for Energy Conservation Program: Energy
Conservation Standards for Refrigerators, Refrigerator-Freezers, and
Freezers, AHAM commented that operating costs and the depreciation of
capital investments are deductible costs for commercial end-users from
Federal and State corporate income taxes. Further, AHAM suggested that
DOE should incorporate the effects of tax deductibility in the LCC
analysis. 89 FR 3026, 3053-3054. DOE maintains its response from the
January 2024 Direct Final Rule for Energy Conservation Program: Energy
Conservation Standards for Refrigerators, Refrigerator-Freezers, and
Freezers, where DOE noted that in the comment, the estimation of
commercial discount rates accounts for the tax deductibility of the
energy costs and capital investment depreciation and therefore the net
present value of the future operating cost savings in the LCC analysis
already reflect that effect. 89 FR 3026, 3054. Therefore, DOE did not
modify its LCC model for this final rule.
DOE received no further comments on its discount rate methodology
and analysis used in the September 2023 NOPR analysis and maintained
its approach for this final rule. See chapter 8 of this final rule TSD
for further details on the development of consumer discount rates.
9. Energy Efficiency Distribution in the No-New-Standards Case
To accurately 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 equipment efficiencies under the no-
new-standards case (i.e., the case without amended or new energy
conservation standards) in the compliance year. This approach reflects
the fact that some consumers may purchase equipment with efficiencies
greater than the baseline levels in the absence of new or amended
standards.
To estimate the energy efficiency distribution of walk-ins for 2028
and 2029, DOE used information provided from stakeholders and records
from DOE's CCMS database. The estimated market shares for the no-new-
standards case for walk-in cooler and freezer panels and doors are
shown in Table IV.51. See chapter 8 of the final rule TSD for further
information on the derivation of the efficiency distributions. DOE did
not change its approach from the March 2024 NODA in this final rule
analysis.
AHRI commented 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
baseline (current) walk-ins standard. (AHRI, No. 72 at p. 12)
Regarding refrigeration systems, DOE agrees with the statement from
AHRI, and continues with the modeling assumption from the September
2023 NOPR that all walk-in cooler and freezer refrigeration systems
would be at baseline in the no-new-standards case. For non-display
doors and panels (for which DOE did not receive any comments in
response to the September 2023 NOPR or March 2024 NODA), DOE will
continue to apply the rates of more-efficient designs found in DOE's
CCMS database.\100\ DOE related the fraction of designs in the CCMS
database to the different panel and non-display door efficiency levels
based on the percentage reduction in daily energy consumption (kWh/day)
(see sections IV.C.1.c and IV.C.1.d of this document). 88 FR 60746,
60798-60799.
---------------------------------------------------------------------------
\100\ U.S. Department of Energy. Compliance Certification
Database. 2023. www.regulations.doe.gov/certification-data/ (last
accessed Feb. 1, 2023).
[GRAPHIC] [TIFF OMITTED] TR23DE24.069
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 is the amount of time (expressed in years) it
takes the consumer to recover the additional installed cost of more-
efficient equipment, compared to baseline equipment, through energy
cost savings. Payback periods that exceed the life of the equipment
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
[[Page 104720]]
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 of purchasing a product complying with
an energy conservation standard level 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. (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 equipment shipments to calculate the
national impacts of potential amended or new energy conservation
standards on energy use, NPV, and future manufacturer cash flows.\101\
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. The age
distribution of in-service equipment 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.
---------------------------------------------------------------------------
\101\ 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.
---------------------------------------------------------------------------
As in the September 2023 NOPR, 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, where 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
AEO2023 Reference case.\102\ To estimate the lifetime of walk-in boxes,
DOE used the distribution from the LCC (see chapter 8 of this final
rule TSD).
---------------------------------------------------------------------------
\102\ 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 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, supported by Hussmann and Lennox, commented that historical
data do not suggest a move to ``larger'' equipment, specifically; they
have observed growth across multiple product lines, including
``smaller'' capacity products. AHRI, Hussmann, and Lennox commented
that there is a gap in considering the small unit (less than 1
horsepower) market size as an artifact of having left this out in
original assessments and possibly omitting market contributors such as
wine cellars, and this would inappropriately skew market percentages
toward larger sizes. (AHRI, No. 72 at p. 12; Hussmann, No. 75 at p. 11;
Lennox, No. 70 at p. 8)
DOE thanks AHRI, Hussmann and Lennox for their comments regarding
the growth of ``smaller'' capacity units. However, no information or
data were provided by the commenters and there is no publicly available
data on the subject that DOE can credibly analyze. For this analysis,
DOE continued to maintain the constant market shares for refrigeration
equipment as presented in the September 2023 NOPR analysis.
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 today's
final rule.
RSG commented that in its experience, increased equipment costs for
more-efficient equipment may drive a reduction in new sales and the
necessity of maintaining current equipment and/or buying old or used
equipment, stunting the benefits of improved efficiency regulations.
(RSG, No. 69 at p. 2)
For this analysis, DOE continues to use the assumption in the
September 2023 NOPR analysis that a decrease in shipments is unlikely
in the walk-in market. DOE maintains 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. DOE examined the impacts of
amended standards on shipments as a sensitivity in appendix 9A of the
final rule TSD. This sensitivity shows that the potential impact from
increased prices for the amended standards to be a reduction in overall
FFC energy savings of 1.07 and 0.35 percent for refrigeration systems
and envelope components, respectively. 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 amended standards
case.
2. Shipments Results
The projected walk-in box shipments results shown in Table IV.52
are inclusive of the different analytical compliance dates for envelope
components (2028) and refrigeration systems (2029). The analysis
accounts for envelope component shipments from 2028 through 2057, and
for refrigeration system s from 2029 (the analytical start) through
2058.
BILLING CODE 6410-01-P
[[Page 104721]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.070
H. National Impact Analysis
The NIA assesses the national energy savings (``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.\103\ (``Consumer'' in this context refers to
consumers of the equipment being regulated.) DOE calculates the NES and
NPV for the potential standard levels considered based on projections
of annual equipment 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, equipment costs, and NPV of consumer benefits over the
lifetime of walk-in refrigeration systems sold from 2029 through 2058,
and walk-in panels and doors sold from 2028 through 2057.\104\
---------------------------------------------------------------------------
\103\ The NIA accounts for impacts in the United States and U.S.
territories.
\104\ Because the anticipated compliance date is late in the
year for refrigeration systems, December 31, 2028, for analytical
purposes, DOE conducted the analysis for shipments during the period
2029-2058. Similarly, the anticipated compliance date for panels and
doors, January 1, 2028, for analytical purposes, DOE conducted the
analysis for shipments during the period 2028-2057.
---------------------------------------------------------------------------
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 equipment with efficiencies greater than the standard.
DOE uses a software model to calculate the energy savings and the
national consumer costs and savings from each TSL. The NIA model uses
typical values (as opposed to probability distributions) as inputs.
Table IV.53 summarizes the inputs and methods DOE used for the NIA
analysis for the final rule. Discussion of these inputs and methods
follows the table. See chapter 10 of the final rule TSD for further
details.
[[Page 104722]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.071
BILLING CODE 6410-01-C
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 amended-
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 shipments projection period, DOE maintained constant
efficiencies.
DOE used the shipments-weighted energy efficiency distribution for
2028 for envelope components and 2029 for refrigeration systems (the
assumed date of compliance with a new standard) as a starting point. To
represent the distribution of walk-in energy efficiencies in 2028 and
2029, DOE used the same market shares as used in the no-new-standards
case for the LCC analysis (see section IV.C.1 of this document). The
approach is further described in chapter 10 of the final rule 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 (2028 and 2029). 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.
DOE did not receive any comments regarding a future shift toward
more-efficient walk-ins, and maintained the modeling assumptions from
the September 2023 NOPR where efficiency would remain constant over
time in this analysis. 88 FR 60746, 60801.
2. National Energy Savings
The NES analysis involves a comparison of national energy
consumption of the considered equipment 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 equipment (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
[[Page 104723]]
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 equipment is sometimes associated with a
direct rebound effect, which refers to an increase in utilization of
the equipment due to the increase in efficiency and reduction in
operating cost. 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--an assumption
agreed with by AHRI, Hussmann, and RSG. (AHRI, No. 72 at p. 12;
Hussmann, No. 75 at p. 11; RSG, No. 69 at p. 2) Because of this, as in
the September 2023 NOPR, DOE has not applied a rebound effect for this
analysis. 88 FR 60746, 60801.
In 2011, 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 (August 18, 2011). After evaluating the
approaches discussed in the August 18, 2011 document, DOE published a
statement of amended policy in which DOE 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 (August 17, 2012). NEMS is a public domain,
multi-sector, partial equilibrium model of the U.S. energy sector \105\
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 10B of the final rule TSD.
---------------------------------------------------------------------------
\105\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2023, DOE/EIA-0581(2023), May 2023.
Available at https://www.eia.gov/outlooks/aeo/nems/overview/pdf/0581(2023).pdf (last accessed July 3, 2024).
---------------------------------------------------------------------------
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 (which include 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 costs. DOE calculates operating cost savings over the
lifetime of equipment shipped during the projection period.
As discussed in section IV.F.2 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. As discussed in section IV.F DOE maintained constant real prices
throughout this analysis. DOE's projection of equipment prices is
described in appendix 10C of the final rule TSD.
To evaluate the effect of uncertainty regarding the price trend
estimates, DOE investigated the impact of different equipment price
projections on the consumer NPV for the considered TSLs for WICFs. In
addition to the default price trend, DOE considered two equipment price
sensitivity cases: (1) a price decline case based on lower 95-percent
of the estimated parameter from exponential fit using the commercial
refrigerator PPI from 1980 to 2023 and (2) a price increase case based
on the upper 95-percent of the estimated parameter from exponential fit
using the commercial refrigerator PPI from 2005 to 2023. The derivation
of these price trends and the results of these sensitivity cases are
described in appendix 10C of the final rule TSD.
The operating cost savings are energy cost savings, which 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 regional 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 final rule TSD.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
final rule, 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.\106\ 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.
---------------------------------------------------------------------------
\106\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. Available at www.whitehouse.gov/omb/information-for-agencies/circulars (last accessed May 31, 2024). DOE
used the prior version of Circular A-4 (September 17, 2003) in
accordance with the effective date of the November 9, 2023 version.
---------------------------------------------------------------------------
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. The principal users of WICF
are food and beverage sales and service. For this final rule, DOE
analyzed the impacts of the considered standard levels on the following
two subgroups: (1) consumers with high warm air-infiltration
applications, and (2) small businesses.
1. High Warm Air-Infiltration Applications
In response to comments to the September 2023 NOPR DOE is
maintaining the subgroup to approximate the impacts for businesses
where walk-ins are operated in environments with higher warm air-
[[Page 104724]]
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.
AHRI and Lennox commented that it would be feasible to expect that
customers operating in regions where electricity is more expensive than
the national average and in high warm air applications will be
incentivized to reduce their energy cost to purchase a refrigeration
system with efficiencies higher than a customer operating in regions
where the electricity costs are lower than or at the average national
rate. (AHRI, No.72 at p. 12; Lennox, No. 70 at p. 8) DOE agrees with
AHRI and Lennox's comments that consumers in regions with higher
electricity prices may be incentivized to purchase more efficient
equipment. However, this is at odds with other comments from AHRI where
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 (current) walk-ins
standard. (AHRI, No. 72 at p. 12) As neither AHRI or Lennox submitted
any evidence to support the notion of changing consumer purchase or
operating behavior, and, as discussed in IV.F.9 DOE agrees with the
statement from AHRI, and continues with the modeling assumption from
the September 2023 NOPR did not include regional variations in
purchasing or operating behaviors.
The results of this analysis can be found in Table V.51, which show
increased benefits for all equipment in terms of LCC savings. This is a
direct result of the increased hours of operation.
2. Small Businesses
This subgroups analysis used subsets of the CBECS 2018 sample
composed of businesses that are small businesses in the consumer sample
(see section IV.F.1 of this document for a full discussion of the
consumer sample). 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
the costs experienced by small businesses. DOE did not receive any
comments regarding the small business subgroup analysis from the
September 2023 NOPR and maintained the same approach for this final
rule.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.072
[[Page 104725]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.073
BILLING CODE 6410-01-C
The results of the small business subgroup analysis show increased
consumer benefit across most equipment, as shown in Table V.49 through
Table V.51. The increase in benefits is driven by the higher
electricity prices attributed to small business customers.
Chapter 11 in the final rule TSD describes the consumer subgroup
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 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, equipment shipments, manufacturer markups, and
investments in R&D and manufacturing capital required to produce
compliant equipment. 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
[[Page 104726]]
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 final rule 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., 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,\107\ corporate annual reports, the U.S. Census Bureau's
Annual Survey of Manufactures (``ASM''),\108\ and reports from Dun &
Bradstreet.\109\
---------------------------------------------------------------------------
\107\ U.S. Securities and Exchange Commission, Electronic Data
Gathering, Analysis, and Retrieval (EDGAR) system. Available at
www.sec.gov/edgar/search/ (last accessed March 7, 2024).
\108\ U.S. Census Bureau, Annual Survey of Manufactures.
``Summary Statistics for Industry Groups and Industries in the U.S
(2022).'' Available at www.census.gov/data/tables/time-series/econ/asm/2018-2021-asm.html (last accessed March 7, 2024).
\109\ The Dun & Bradstreet Hoovers login is available at
app.dnbhoovers.com (last accessed March 7, 2024).
---------------------------------------------------------------------------
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. 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 final rule 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 2024 (the base year of the analysis) and continuing to
2057, 30 years after the 2028 compliance date for doors and panels. For
refrigeration systems, the GRIM arrives at a series of annual cash
flows beginning in 2024 (the base year of the analysis) and continuing
to 2058, 30 years after the modeled 2029 compliance date. DOE
calculated INPVs by summing the stream of annual discounted cash flows
during this period. For manufacturers of walk-in doors, panels, and
refrigeration systems, 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 final rule
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 products can affect the revenues,
gross margins, and cash flow of the industry. In this rulemaking, DOE
relied 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 final rule 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 2024 (the base year) extending 30 years after
the expected compliance date. 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.
[[Page 104727]]
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'') of all types are
calculated using a stock model, with principal inputs that include
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 final rule 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 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 product designs can be fabricated and assembled. Product
conversion costs are investments in research, development, testing,
marketing, and other non-capitalized costs necessary to make product
designs comply with new or amended energy conservation standards.
DOE relied on information derived from manufacturer interviews,
equipment teardown analyses, 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 the 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 were 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
efficiency distribution assumptions in the shipments analysis, DOE
estimated the industry costs associated with re-rating compliant models
in accordance with appendix C1.
For this final rule, DOE refined its capital and product conversion
cost analysis but generally maintained its methodology from the
September 2023 NOPR. Specifically, DOE updated its conversion cost
estimates from the September 2023 NOPR to 2023$ for this final rule.
For capital conversion costs, DOE incorporated updated estimates of
equipment, tooling, conveyer, and space generated from the equipment
teardown and engineering teardown analyses. For refrigeration systems,
DOE conducted further research into the specific production equipment
currently being used by walk-in OEMs to fabricate tube-and-fin heat
exchangers and incorporated updated equipment specifications and costs.
In response to comments, DOE adjusted its analysis to more accurately
account for how implementing design options on representative units of
different capacities would contribute to capital conversion cost
estimates. As a result of these updates, DOE found that unit coolers
would require capital conversion costs beyond the retooling cost
estimated in the September 2023 NOPR. For unit coolers, in response to
stakeholder comments, DOE revised its capital conversion cost analysis
to reflect the assumed distribution of row number frequency using
results from its unit cooler database (see Table IV.56). For product
conversion costs, DOE incorporated the most recent BLS wage data into
its estimates.\110\ See chapter 12 of the final rule TSD for further
details on the updates made to conversion cost estimates.
---------------------------------------------------------------------------
\110\ Bureau of Labor Statistics, U.S. Department of Labor,
Occupational Outlook Handbook, Mechanical Engineers. (May 2023)
Available at: www.bls.gov/ooh/architecture-and-engineering/mechanical-engineers.htm. (Last accessed June 20, 2024).
[GRAPHIC] [TIFF OMITTED] TR23DE24.074
For product conversion costs, in response to stakeholder comments
to the September 2023 NOPR regarding the increase in testing and
certification costs associated with new safety standards (i.e., UL
60335-2-89) (see AHRI, No. 72 at pp. 2-3 and No. 86 at p. 3), DOE also
doubled refrigeration system product conversion costs associated with
UL testing and industry certification for this final rule.
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 amended 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 final rule TSD.
d. Manufacturer Markup Scenarios
MSPs include direct manufacturing production costs (i.e., labor,
materials, and overhead estimated in DOE's MPCs)
[[Page 104728]]
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. DOE addresses comments in response to the September 2023 NOPR
related to its manufacturer markup scenarios in section IV.J.3.b of
this document.
Under the preservation of gross margin percentage scenario, DOE
applied a uniform ``gross margin percentage'' 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 MPCs increase with efficiency,
this scenario implies that the per-unit dollar profit will increase.
Consistent with the September 2023 NOPR and March 2024 NODA, 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.\111\ 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 equipment. Therefore, this scenario represents a
high bound of industry profitability under amended energy conservation
standards. To address manufacturer concerns about reduced margins and
profitability under potential amended standards, DOE also analyzes a
preservation of operating profit scenario.
---------------------------------------------------------------------------
\111\ 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
manufacturer markup scenarios is presented in section V.B.2.a of this
document.
3. Discussion of MIA Comments
a. Conversion Costs
Kolpak commented that increasing door and/or panel thickness would
decrease manufacturing capacity, increase manufacturing costs, and
increase its carbon footprint. (Kolpak, No. 66 at p. 2) RSG stated
general agreement with DOE's estimates of capital conversion costs at
each TSL analyzed in the September 2023 NOPR for WICF doors, panels,
and refrigeration systems. RSG commented that the highest impact for
walk-in non-display doors and panels would be attributed to increased
insulation thickness. RSG estimated one new charging station would be
required at each manufacturing location at a cost of approximately
$200,000. (RSG, No. 69 at pp. 2-3)
DOE agrees with commenters that increasing non-display door and/or
panel thickness would increase production costs and could impact
manufacturing capacity due to longer cure times. DOE accounts for these
factors in its MPCs (see section IV.C of this document or chapter 5 of
the final rule TSD) and conversion cost analysis (see section IV.J.2.c
of this document or chapter 12 of the final rule TSD).
Hussmann commented that DOE's assumption regarding the September
2023 NOPR capital conversion costs between TSL 1 and TSL 2 will be
similar is faulty in the case of unit coolers, because moving to five-
row coils will require a much larger investment than just moving up to
four coils, due to current manufacturer optimization around two- to
four-row coils. (Hussmann, No. 75 at p. 12) AHRI similarly commented
that DOE's assumption that for unit coolers, the capital conversion
costs between TSL 1 and TSL 2 presented in the September 2023 NOPR will
be similar because they can rely on similar tooling investments is
incorrect, as moving to five-row coils will require a much larger
capital investment than just moving up to four-row coils. AHRI stated
that manufacturers have optimized around two- to four-row coils and
requiring a switch to five rows represents a major change that has not
been accounted for. (AHRI, No. 72 at p. 13)
In the September 2023 NOPR, DOE did not consider that adding
additional rows to the unit cooler heat exchanger would require an
increase in cabinet size when determining the MPCs and capital
investments associated with each efficiency level. DOE based this
assumption on manufacturers' unit cooler product catalogs, which
included unit cooler case dimensions. In response to stakeholder
comments to the September 2023 NOPR, DOE updated its analysis in the
March 2024 NODA and assumed that the unit cooler case would have to be
expanded to accommodate an additional row at the max-tech efficiency
level for every unit cooler representative unit and presented updated
unit cooler cost efficiency curves in the March 2024 NODA support
document.\112\ In response to comments to the March 2024 NODA regarding
underestimating incremental costs associated with additional rows, DOE
reexamined its cost modeling for unit coolers for this final rule.
Based on further review of product literature and its modeling of
representative units, DOE updated several inputs to the unit cooler
cost modeling, which may be better aligned with industry's cost
estimates. The updated costs are presented in appendix 5A of the final
rule TSD and details of the revised cost methodology are discussed in
chapter 5 of the final rule TSD. For this final rule, DOE also revised
its capital conversion cost estimates for unit coolers to reflect the
additional tooling and equipment costs associated with incorporating
additional rows to unit cooler heat exchangers. DOE further revised its
capital conversion cost estimates for unit coolers to account for the
estimated row frequency distribution of models on the market. See
section V.B.2.a of this document and chapter 12 of the final rule TSD
for unit cooler conversion cost estimates.
---------------------------------------------------------------------------
\112\ ``Detailed Data for Engineering Analysis and National
Impact Analysis for the Notice Of Data Availability Pertaining to
Walk-in Coolers And Walk-In Freezers.'' Available at
www.regulations.gov/document/EERE-2017-BT-STD-0009-0079.
---------------------------------------------------------------------------
[[Page 104729]]
AHRI and Lennox stated that it was difficult to provide feedback on
the September 2023 NOPR refrigeration system conversion cost estimates
at each TSL due to discrepancies in the design options assumed at
baseline and the costs associated with higher efficiency levels. AHRI
and Lennox generally disagreed with the component costs presented in
the September 2023 NOPR as they stated that costs needed to reflect
state-of-the-art design and true capital costs to realize the
advancements. AHRI and Lennox commented that the costs at efficiency
levels that necessitate larger heat exchangers should include the
capital costs, which would be a significant cost factor. AHRI and
Lennox cited as an example moving from four-row to five-row coils, or
increasing face area, which would require sweeping changes due to
capital costs beyond what is indicated in appendix 5A.5 of the
September 2023 NOPR TSD. (AHRI, No. 72 at p. 13; Lennox, No. 70 at pp.
8-9)
In response to the March 2024 NODA, AHRI reiterated that because
unit coolers are optimized around four-row coils, increasing efficiency
by adding tube rows would be much more costly than estimated by DOE,
considering major tooling and other factors. AHRI and Lennox stated
that DOE underestimated cost increases for MPCs and MSPs associated
with requirements for walk-ins to use A2L refrigerants, considering
tooling, materials, and development costs. (AHRI, No. 86 at pp. 6-7;
Lennox, No. 87 at p. 5)
Regarding the underlying assumptions of the WICF refrigeration
system engineering analysis, see section IV.C of this document or
chapter 5 of the final rule TSD for details on the analyzed design
options and efficiency levels. Regarding the capital investments
associated with increasing the size of the heat exchanger, DOE accounts
for the incremental increase in manufacturing equipment, tooling, and
building depreciation in its MPCs and the one-time, upfront investments
in property, plant, and equipment necessary to adapt or change existing
production facilities (i.e., capital conversion costs) in its MIA. As
such, DOE notes that the production costs derived in the engineering
analysis already include estimates of capital investments in the form
of depreciation costs. See section IV.C.2.g of this document for
further discussion on how DOE estimates depreciation costs and chapter
5 of the final rule TSD for additional details on the cost model and
estimation of MPCs. See chapter 12 of the final rule TSD for the
breakdown of production costs (i.e., material, labor, depreciation,
overhead) used in the MIA.
b. Manufacturer Markup Scenarios
In terms of baseline assumptions, AHRI commented it is unclear
whether DOE preserved margin percentage in its financial calculations,
and, if not, AHRI commented the correct approach should be to preserve
margin percentage and not just margin dollars. (AHRI, No. 72 at pp. 5-
6)
For the September 2023 NOPR, DOE analyzed two manufacturer markup
scenarios in its MIA: (1) the preservation of gross margin percentage
and (2) the preservation of operating profit. DOE assumed a fixed gross
margin percentage in its LCC and PBP analyses for the September 2023
NOPR. In other words, the LCC and PBP results reflect the conservative
assumption that manufacturers would preserve gross margin percentage
(not just per-unit dollars), which aligns with AHRI's suggestion. DOE
maintained that approach for this final rule analysis.
c. Manufacturing Capacity Constraints
RSG stated its agreement that meeting higher efficiency levels than
what was proposed in the September 2023 NOPR for walk-in non-display
doors and panels would impact its capacity and capability to deliver
product by the 2027 compliance date analyzed in the September 2023
NOPR. As an example, RSG commented that each additional inch of foamed
non-display door or panel can double production time according to
internal manufacturing studies. (RSG, No. 69 at p. 3)
DOE agrees with commenters that increasing non-display door and/or
panel thickness would impact manufacturing capacity due to longer cure
times. As with standards proposed in the September 2023 NOPR, the
design options analyzed for the efficiency levels adopted in this final
rule do not include increased insulation thickness for non-display
doors or panels.
AHRI stated agreement with DOE's analysis that the limited number
of suppliers of vacuum-insulated glass, along with the associated
substantial cost increase for the conversion, would sharply limit the
availability of walk-in display doors and non-display doors within the
compliance timeframe proposed in the September 2023 NOPR. (AHRI, No. 72
at p. 13)
Aligned with the standards proposed in the September 2023 NOPR, DOE
notes that it is not adopting more-stringent efficiency levels for
display doors in this final rule. See section V.B.2.c of this document
for a discussion on manufacturing capacity and section V.C.1 for a
discussion of the analyzed TSLs and their associated benefits and
burdens.
DuPont commented that its specialty XPS production lines have
historically been capacity constrained. DuPont commented that should
panel efficiency standards be increased, WICF-specific XPS capacity
with increased insulation thickness would be reduced. DuPont stated
that more stringent efficiency levels for WICFs would result in
increases in insulation procurement to sustain demand. DuPont included
a table to demonstrate this, showing volume increases of 14 percent (to
meet EL 1) to 71 percent (to meet max-tech) for coolers and 25 percent
(to meet EL 1) to 50 percent (to meet max-tech) for freezers, based on
thicker insulation requirements. DuPont commented that if XPS
production volume remained consistent and there were no alternative
insulation product to XPS, given key specialty XPS technical
performance properties in this WICF application, then increased WICF
efficiency standards could result in a proportionate decrease in WICF
panel and non-display door area production capacity, due to XPS supply
constraints. DuPont supported the panel and non-display door efficiency
levels proposed in the September 2023 NOPR, noting that requiring
increased insulation thickness would potentially create a WICF supply
shortage. (DuPont, No. 74 at pp. 1-2)
In this final rule, DOE is adopting TSL 1 for non-display doors and
no-new-standards for panels, which DOE believes manufacturers can meet
without increasing insulation thickness of non-display doors and
panels. As such, DOE does not expect there would be capacity
constraints related to sourcing XPS for walk-ins as a direct result of
this rulemaking.
Regarding constraints for walk-in systems, RSG noted that component
availability, especially regarding A2L special components (e.g.,
compressors, sensors, etc.), seem to be tracking for general
availability by 2026. RSG commented that 2027 is likely the earliest
viable compliance date to harmonize industry, design, test, and
regulation. (RSG, No. 69 at p. 3)
AHRI and Lennox commented that there would likely be significant
manufacturing constraints and engineering resource constraints if DOE
requires manufacturers to comply with energy efficiency standards for
walk-in refrigeration systems by 2027 (the compliance year analyzed in
the September 2023 NOPR). Specifically, AHRI and Lennox stated that
some
[[Page 104730]]
manufacturers have limited internal laboratory capacity and are
obligated to use third-party laboratories, which are currently at
maximum capacity. AHRI and Lennox further stated that until the
transition to low-GWP refrigerants is complete, tests cannot be
suspended and rooms modified to support the May 2023 TP Final Rule--a
process that could delay WICF production by 8 to 12 months. In addition
to the engineering and testing time, AHRI and Lennox noted that
manufacturing and related component fabrication and reconfiguration of
production lines would require a significant amount of effort while
manufacturers are preoccupied with ramping up testing and production of
low-GWP walk-in refrigeration systems. AHRI and Lennox also commented
that current supply chain challenges and long lead times from component
suppliers could delay the building of prototypes and subsequent
laboratory testing. AHRI and Lennox emphasized that the standards
proposed in the September 2023 NOPR calling for an efficiency increase
of up to 15 percent might require a complete redesign of the product.
(AHRI, No. 72 at p. 14; Lennox, No. 70 at p. 9) Hussmann commented that
it agrees with the views presented by AHRI. (Hussmann, No. 75 at pp.
12-13)
AHRI commented that the standards proposed in the September 2023
NOPR makes it difficult to have a complete equipment offering,
particularly for low-temperature condensing units and, to some extent,
unit coolers. AHRI commented it expects major application gaps even
with extensive unit redesign and utilization of all major, identified
energy-saving measures. (AHRI, No. 72 at p. 20)
DOE recognizes that testing and redesigning walk-in refrigeration
systems to comply with EPA's refrigerant regulations and DOE's amended
energy conservation standards requires engineering time, laboratory
resources, and capital investment. DOE analyzed the potential impacts
of the December 2022 EPA Technology Transitions NOPR in its September
2023 NOPR. Based on the December 2022 EPA Technology Transitions NOPR,
DOE modeled the walk-in refrigeration system industry transitioning to
low-GWP refrigerants prior to EPA's proposed January 1, 2025 compliance
date. However, EPA has since finalized refrigerant restrictions
affecting walk-in refrigeration systems with a January 1, 2026
compliance date (i.e., the October 2023 EPA Technology Transitions
Final Rule). As such, walk-in refrigeration system manufacturers will
have an additional year to comply with the October 2023 EPA Technology
Transitions Final Rule compared to the timeline detailed in the
December 2022 EPA Technology Transitions NOPR. Furthermore, in this
final rule, DOE is adopting a compliance date of December 31, 2028
(modeled as 2029, the first full year of compliance) for refrigeration
systems to help alleviate potential laboratory and engineering resource
constraints related to the dual development associated with EPA and DOE
regulations. See section III.A.2 of this document for additional
discussion on the DOE compliance date.
d. Cumulative Regulatory Burden
RSG cited innovation and design cycle as the primary challenges
posed by cumulative regulatory burden. RSG commented that DOE proposals
can place manufacturers in a cycle of chasing the regulation, with less
focused time and freedom to innovate for better overall solutions.
(RSG, No. 69 at p. 3) Lennox commented that manufacturers face a
significant cumulative regulatory burden resulting from multiple DOE
standards and equipment-specific regulatory actions taken by other
Federal agencies, which will negatively affect WICF manufacturers by
causing OEMs to invest more time, money, and resources in testing and
manufacturing products to comply with the DOE standards. Lennox
recommended that DOE consider the impact of related State regulations,
safety codes, and various standards changes when proposing new or
amended standards for walk-ins. (Lennox, No. 70 at pp. 10-11)
NRAC commented that refrigerant regulation (e.g., October 2023 EPA
Technology Transitions Final Rule) and changes to safety standards
(i.e., UL 60335-2-89) contribute to cumulative regulatory burden and
will require significant engineering resources and laboratory testing.
(NRAC, No. 73 at p. 3)
AHRI and Hussmann commented that there is significant cumulative
regulatory burden associated with DOE energy conservation standards,
EPA regulations (i.e., transition to low-GWP refrigerants, PFAS/PFOA
regulations), and changes to safety standards, as well as various State
regulations. AHRI and Hussmann commented that these changes require
engineering resources, validation testing, verification costs,
establishment of new supply chains, and independent laboratory testing.
AHRI and Hussmann noted that DOE's proposed changes to medium electric
motors \113\ and small, non-small electric motors standards (also
referred to as ``expanded scope electric motors'') \114\ also
contribute to cumulative regulatory burden. AHRI and Hussmann commented
that these motor regulations may require equipment changes to account
for larger motors, additional testing, safety agency approval, backward
compatibility for the replacement market, and a cost increase to go
along with the higher efficiency motors. (AHRI, No. 72 at p. 16;
Hussmann, No. 75 at p. 14)
---------------------------------------------------------------------------
\113\ In a direct final rule published on June 1, 2023 (``June
2023 Electric Motors Direct Final Rule''), DOE prescribed the energy
conservation standards for electric motors manufactured on and after
June 1, 2027. 88 FR 36066.
\114\ In a proposed rule published on December 15, 2023
(``December 2023 ESEM NOPR''), DOE proposed energy conservation
standards for expanded scope electric motors manufactured on and
after January 1, 2029. 88 FR 87062.
---------------------------------------------------------------------------
AHRI commented that its members are weighing a range of decisions
and design changes due to regulations requiring low-GWP refrigerants.
AHRI commented that manufacturers do not consider the October 2023 EPA
Technology Transitions Final Rule and DOE energy conservation standards
rulemakings as independent of each other; AHRI commented that taken
together, the EPA and DOE regulatory actions impose an unreasonable
burden and are at high risk of resulting in requirements that are
nearly impossible to meet in the required timeframes. AHRI commented
that manufacturers are experiencing heavy backlog and extensive time to
market because certification organizations and laboratories have
limited resources. AHRI requested that DOE account for the fact that
all commercial refrigeration equipment must meet UL-60335-2-89, which
will replace current safety standards in 2024 and which will require
more resources, time, and laboratory facilities. (AHRI, No. 72 at pp.
2-3 and No. 86 at p. 3)
Regarding cumulative regulatory burden, DOE analyzes cumulative
regulatory burden pursuant to section 13(g) of the Process Rule. (10
CFR 431.4; 10 CFR 430, subpart C, appendix A, section 13(g)). DOE
analyzes and considers the impact on manufacturers of multiple product/
equipment-specific Federal regulatory actions. DOE notes that
regulations not yet finalized are not considered as cumulative
regulatory burden, as the timing, cost, and impacts of unfinalized
rules are speculative. However, to aid stakeholders in identifying
potential cumulative regulatory burden, DOE lists rulemakings that have
proposed rules with tentative compliance dates, compliance levels, and
compliance cost estimates. The results of this analysis
[[Page 104731]]
can be found in section V.B.2.e of this document.
Regarding EPA refrigerant regulations, as discussed in prior
sections, DOE recognizes that redesigning walk-in refrigeration system
designs to comply with the October 2023 EPA Technology Transitions
Final Rule and DOE's amended energy conservation standards requires
significant engineering resources and capital investment. DOE accounts
for these impacts in its cumulative regulatory burden analysis. DOE
analyzed the potential impacts of the December 2022 EPA Technology
Transitions NOPR in its September 2023 NOPR. Based on the December 2022
EPA Technology Transitions NOPR, DOE modeled the WICF refrigeration
system industry transitioning to low-GWP refrigerants prior to EPA's
proposed January 1, 2025 compliance date. However, EPA has since
finalized refrigerant restrictions affecting walk-ins (i.e., the
October 2023 EPA Technology Transitions Final Rule). EPA finalized a
January 1, 2026 compliance date for the refrigeration categories that
apply to walk-in refrigeration systems (i.e., remote condensing units
and cold storage warehouse systems).
DOE accounts for industry refrigerant transition expenses in its
GRIM in the no-new-standards case and standards cases. Although
refrigerant transition costs are independent of DOE adopting new and
amended standards, DOE incorporates these expenses into its GRIM to
better reflect the state of industry finances and annual cashflow. For
the September 2023 NOPR, DOE relied on a range of sources, including
feedback gathered during confidential manufacturer interviews, in
response to the June 2022 Preliminary Analysis. In response to written
comments to the September 2023 NOPR, DOE revised its refrigerant
transition R&D estimates. See section V.B.2.e of this document for
additional discussion of how DOE accounts for cumulative regulatory
burden in its analysis.
Regarding State refrigerant regulations, those transition costs
would be reflected in the refrigerant transition costs estimated in
this final rule. DOE notes that since most State refrigerant
regulations generally align with the October 2023 EPA Technology
Transitions Final Rule GWP restrictions for walk-ins, DOE does not
expect that individual State refrigerant regulations would
significantly contribute to refrigerant transition costs beyond what
was assessed for the October 2023 EPA Technology Transitions Final
Rule. DOE notes that two States have established lower GWP limits for
certain walk-in refrigeration systems as compared to the October 2023
EPA Technology Transition Final Rule. Specifically, California and
Washington prohibited refrigerants with a GWP of 150 or greater for new
retail food refrigeration equipment and cold storage warehouses
containing more than 50 lbs of refrigerant, which includes certain WICF
refrigeration systems, as of January 1, 2022 in California \115\ and as
of January 1, 2025 in the State of Washington.\116\ DOE developed cost
adders for certain representative units, consistent with the March 2024
NODA, for this final rule. See subsection ``Refrigerants Analyzed'' of
section IV.C.1.e of this document for additional information about WICF
refrigeration systems designed to use refrigerants with a GWP of 150 or
less. See section IV.F.2.a of this document for DOE's sensitivity
analysis of sub-150 GWP refrigerants on consumers.
---------------------------------------------------------------------------
\115\ California Air Resource Board, ``California Significant
New Alternatives Policy (SNAP).'' Available at ww2.arb.ca.gov/our-work/programs/california-significant-new-alternatives-policy-snap/retail-food-refrigeration (last accessed May 23, 2024).
\116\ State of Washington Department of Ecology, WAC 173-443-
040. Available at app.leg.wa.gov/WAC/default.aspx?cite=173-443-040
(last accessed May 23, 2024).
---------------------------------------------------------------------------
Regarding stakeholders' comments on the increase in per-unit
testing burden as a result of the transition to UL 60335-2-89, DOE
updated its product conversion costs and its refrigerant transition R&D
expenses to reflect the increase in testing burden. As discussed in
section IV.J.2.c of this document, DOE doubled the costs associated
with testing and certifying to the new UL safety standard in response
to written comments and secondary research.
Regarding potential PFAS/PFOA regulations restricting the use of
certain A2L refrigerants, DOE notes that EPA has not yet proposed any
regulations concerning the use of PFAS in refrigerants. Furthermore,
DOE notes that the October 2023 EPA Technology Transitions Final Rule
finalized restrictions for WICF refrigeration systems using a GWP limit
approach, which inherently permits the use of any substitutes
consistent with the restrictions. DOE also notes that EPA's ``PFAS
Strategic Roadmap'' sets timelines for specific actions and outlines
EPA's commitments to new policies to safeguard public health, protect
the environment, and hold polluters accountable.\117\
---------------------------------------------------------------------------
\117\ U.S. Environmental Protection Agency, ``Per- and
Polyfluoroalkyl Substances (PFAS).'' Available at: www.epa.gov/pfas
(last accessed May 31, 2024).
---------------------------------------------------------------------------
Regarding the June 2023 Electric Motors Direct Final Rule, DOE did
not observe motors that would fall under the scope of the June 2023
Electric Motors Direct Final Rule in its testing and teardowns of WICF
refrigeration systems conducted in support of this rulemaking. While it
is possible that larger capacity dedicated condensing units or unit
coolers incorporate a motor subject to the June 2023 Electric Motors
Direct Final Rule, DOE does not have sufficient evidence to conclude
that these in-scope motors are significantly used for WICF
applications. Regarding the December 2023 ESEM NOPR, DOE acknowledges
that some walk-in refrigeration systems may currently incorporate
motors subject to standards proposed in the December 2023 ESEM NOPR.
However, the compliance date analyzed in this final rule precedes the
proposed ESEM standard compliance date (January 1, 2029) and, based on
the design option pathway analyzed in the WICF engineering analysis,
WICF refrigeration systems would likely require a motor that is outside
the scope of the December 2023 ESEM NOPR (e.g., an electronically
commutated motor) to meet the efficiency levels adopted in this final
rule. Furthermore, as DOE did not identify any walk-in manufacturers
that also manufacture ESEMs, DOE did not include the December 2023 ESEM
NOPR in its cumulative regulatory burden analysis.
e. Refrigerant Transition Costs
RSG noted that its analysis shows a significant increase in cost
across most areas of operation and production to accommodate low-GWP
refrigerants, including (but not limited to) production capital,
system/end-product cost, laboratory testing, agency certification,
engineering resources, and manufacturing operations and safety. RSG
commented that DOE has assured that care will be taken to consider the
financial impact on manufacturers and customers alike with such
proposed regulation amendments. (RSG, No. 69 at p. 3) NRAC commented
that the transition to low-GWP refrigerants, as required by EPA, would
increase engineering efforts and laboratory testing by 40 to 50
percent. NRAC commented that certification costs will increase and
additional components will be required for refrigerant mitigation;
however, those costs are still uncertain and cannot currently be
quantified. (NRAC, No. 73 at p. 3)
AHRI and Lennox commented that DOE's estimate of $14.5 million in
R&D and $15.0 million in capital expenditures related to the transition
to low-GWP refrigerants presented in the September 2023 NOPR seems
reasonable if industry has facility modifications already complete and
[[Page 104732]]
development in final stages as of the end of 2023, assuming transitions
across the industry are primarily to A2L and A3 refrigerants. However,
AHRI and Lennox commented that if these measures are not in place by
the end of 2023, development expenses and laboratory capital expenses
could be much higher since third-party testing expenses have likely
increased by 30 to 40 percent since the manufacturer interviews were
conducted. AHRI and Lennox asserted that if the transition is more
heavily weighted to CO2, then the overall cost could be
approximately doubled for lab facilities, 50 percent more for
manufacturing, and 50 percent more for laboratory testing. AHRI and
Lennox provided a cost breakdown of R&D (engineering efforts 40
percent; lab testing hours 30 percent; third-party testing 20 percent;
certification costs 10 percent) and capital investment (tooling 45
percent; new charging equipment 10 percent; lab upgrades 35 percent;
personnel training 5 percent; leak detection systems 5 percent) for the
refrigerant transition. (AHRI, No. 72 at pp. 14-15; Lennox, No. 70 at
p. 10)
In response to the September 2023 NOPR, AHRI and Hussmann provided
cost categories associated with transitioning walk-in refrigeration
systems and production facilities to accommodate low-GWP refrigerants.
This list included: (a) contracting with safety agencies to understand
requirements; (b) testing, product changes, certification, and creation
of new files for A2L using a new safety standard (i.e., UL 60335-2-89);
(c) acquiring necessary equipment associated with new safety-standard
testing; (d) laboratory upgrades, such as new sensors, ventilation
equipment, storage facilities, facilities to accommodate higher
pressures, calorimeters, and load skids to work with A2L and
CO2 refrigerants; (f) new equipment such as vacuum pumps,
reclaim equipment, and leak detectors as well as technician training to
safely use flammable refrigerants; (g) building and insuring or
contracting special buildings for required safety tests; (h)
development, testing, and contracting with safety agencies to find,
test, qualify, and certify items for a mitigation control system to
sense for leaks, control safety aspects, and to implement mitigation
actions; and (i) engineering efforts, including sizing and selecting
all new components, updating all drawings and BOMs, creating all new
items such as warning labels and installation instructions, and
providing training to customers and technicians. (AHRI, No. 72 at pp.
15-16, Hussmann, No. 75 at p. 13-14)
In response to AHRI, Lennox, and Hussmann, DOE notes that it
appreciates the level of detail provided regarding the costs and
categories of expenses associated with transitioning to low-GWP
refrigerants. In the September 2023 NOPR, 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.,) between 2023 (the September 2023 NOPR
reference year) and 2025 (the proposed EPA compliance date for WICF
refrigeration systems covered by this rulemaking). In response to
stakeholder comments, DOE revised its R&D estimates to account for
higher third-party laboratory testing costs. DOE also adjusted the
timeline of when manufacturers would need to make investments related
to the refrigerant transition to align with the revised compliance
dates for walk-in refrigeration systems in the October 2023 EPA
Technology Transitions Final Rule. As such, for this final rule, DOE
models that the transition to low-GWP refrigerants would require
industry to invest approximately $15.7 million in R&D and $12.4 million
in capital expenditures from 2024 (the final rule reference year) and
2026 (the EPA compliance date for WICF refrigeration systems covered by
this rulemaking). As with the September 2023 NOPR, DOE notes that its
refrigerant transition estimates of $15.7 million in R&D and $12.4
million in capital expenditures reflect an estimate of future
investments industry would incur to comply with Federal or State
refrigerant regulations. Therefore, estimated investments made in 2023
or earlier are not reflected in the GRIM. DOE acknowledges that
manufacturers have already invested a significant amount of time and
capital into transitioning walk-in refrigeration systems to low-GWP
refrigerants.
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 reductions in 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 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 final rule 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
EPA.\118\
---------------------------------------------------------------------------
\118\ Available at www.epa.gov/sites/production/files/2021-04/documents/emission-factors_apr2021.pdf (last accessed July 12,
2021).
---------------------------------------------------------------------------
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 final rule 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 and the Inflation Reduction Act.\119\
---------------------------------------------------------------------------
\119\ 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 May 1, 2024).
---------------------------------------------------------------------------
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
[[Page 104733]]
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.\120\ The AEO 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, for
states subject to SO2 emissions limits under CSAPR, 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.
---------------------------------------------------------------------------
\120\ 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), and EPA issued the CSAPR Update for the 2008
ozone NAAQS. 81 FR 74504 (Oct. 26, 2016).
---------------------------------------------------------------------------
However, beginning in 2016, SO2 emissions began to fall
as a result of the Mercury and Air Toxics Standards (``MATS'') for
power plants.\121\ 77 FR 9304 (Feb. 16, 2012). The final rule
establishes power plant emission standards for mercury, acid gases, and
non-mercury metallic toxic pollutants. 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 will generally reduce
SO2 emissions. DOE estimated SO2 emissions
reduction using emissions factors based on AEO2023.
---------------------------------------------------------------------------
\121\ 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. Depending on the configuration of the power sector in the
different regions and the need for allowances, however, NOX
emissions might not remain at the limit in the case of lower
electricity demand. That would mean that 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. 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 final 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 the emissions benefits and presents
the values considered in this final rule.
1. Monetization of Greenhouse Gas Emissions
To monetize the climate benefits of reducing GHG emissions, the
September 2023 NOPR used the interim social cost of greenhouse gases
(``SC-GHG'') 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
Interagency Working Group on the SC-GHG (``IWG'') (``2021 interim SC-
GHG estimates''). As a member of the IWG involved in the development of
the February 2021 interim SC-GHG TSD, DOE agreed that the 2021 interim
SC-GHG estimates represented the most appropriate estimate of the SC-
GHG until revised estimates were developed reflecting the latest, peer-
reviewed science. See 87 FR 78382, 78406-78408 for discussion of the
development and details of the 2021 interim SC-GHG estimates. The IWG
has continued working on updating the interim estimates but has not
published final estimates.
Accordingly, in the regulatory analysis of its December 2023 Final
Rule, ``Standards of Performance for New, Reconstructed, and Modified
Sources and Emissions Guidelines for Existing Sources: Oil and Natural
Gas Sector Climate Review,'' the EPA estimated climate benefits using a
new, updated set of SC-GHG estimates (``2023 SC-GHG estimates''). EPA
documented the methodology underlying the new estimates in the RIA for
the December 2023 Final Rule and in greater detail in a technical
report entitled ``Report on the Social Cost of Greenhouse Gases:
Estimates Incorporating Recent Scientific Advances'' that was presented
as Supplementary Material to the RIA.\122\ The 2023 SC-GHG estimates
incorporate recent research addressing recommendations of the National
Academies of Science, Engineering, and Medicine (National Academies),
responses to public comments on an earlier sensitivity analysis using
draft SC-GHG estimates included in EPA's December 2022 proposal in the
oil and natural gas sector standards of performance rulemaking, and
comments from a 2023 external peer review of the accompanying technical
report.\123\
---------------------------------------------------------------------------
\122\ www.epa.gov/system/files/documents/2023-12/eo12866_oil-and-gas-nsps-eg-climate-review-2060-av16-final-rule-20231130.pdf;
https://www.epa.gov/system/files/documents/2023-12/epa_scghg_2023_report_final.pdf (last accessed July 3, 2024).
\123\ www.epa.gov/environmental-economics/scghg.
---------------------------------------------------------------------------
On December 22, 2023, the IWG issued a memorandum directing that
when agencies ``consider applying the SC-GHG in various contexts . . .
agencies should use their professional judgment to determine which
estimates of the SC-GHG reflect the best available evidence, are most
appropriate for particular analytical contexts, and best facilitate
sound decision-making''
[[Page 104734]]
consistent with OMB Circular A-4 and applicable law.\124\
---------------------------------------------------------------------------
\124\ https://www.whitehouse.gov/wp-content/uploads/2023/12/IWG-Memo-12.22.23.pdf (last accessed July 3, 2024).
---------------------------------------------------------------------------
DOE has been extensively involved in the IWG process and related
work on the SC-GHGs for over a decade. This involvement includes DOE's
role as the Federal technical monitor for the seminal 2017 report on
the SC-GHG issued by the National Academies, which provided extensive
recommendations on how to strengthen and update the SC-GHG
estimates.\125\ DOE has also participated in the IWG's work since 2021.
DOE technical experts involved in this work reviewed the 2023 SC-GHG
methodology and report in light of the National Academies'
recommendations and DOE's understanding of the state of the science.
---------------------------------------------------------------------------
\125\ Valuing Climate Damages: Updating Estimation of the Social
Cost of Carbon Dioxide [verbar] The National Academies Press.
(available at: https://nap.nationalacademies.org/catalog/24651/valuing-climate-damages-updating-estimation-of-the-social-cost-of)
(last accessed July 3, 2024).
---------------------------------------------------------------------------
Based on this review, in a July NODA for consumer gas-fired
instantaneous water heaters, DOE proposed for public comment its
preliminary determination that the updated 2023 SC-GHG estimates,
including the approach to discounting, represent a significant
improvement in estimating the SC-GHG through incorporating the most
recent advancements in the scientific literature and by addressing
recommendations on prior methodologies. 89 FR 59693, 59700. In DOE's
final action in the consumer gas-fired instantaneous water heaters
rulemaking, DOE will address any comments and make a final
determination on whether to apply the updated 2023 SC-GHG estimates in
that rulemaking. In this final rule, DOE is presenting estimates using
both the updated 2023 SC-GHG values and the interim 2021 interim SC-GHG
estimates. While DOE did not present results using the updated 2023 SC-
GHG values in the proposal, DOE believes that providing this
information here, in addition to results calculated using the 2021
interim SC-GHG values, is appropriate to give the public more complete
information regarding the benefits of this rule. DOE notes, however,
that the adopted standards would be economically justified using either
set of SC-GHG values, and even without inclusion of the estimated
monetized benefits of reduced GHG emissions.
As DOE explained in the July NODA, it was the agency's preliminary
assessment that the 2023 SC-GHG estimates represent a significant
improvement because the 2023 SC-GHG estimates implement the key
recommendations of the National Academies, and they incorporate the
extensive scientific findings and methodological advances that have
occurred since the last IWG substantive updates to the methodology in
2013, and the methodologically consistent updates to add estimates for
methane and nitrous oxide in 2016.
The 2023 SC-GHG estimates have also been peer-reviewed. As
indicated by their statements, the peer reviewers strongly supported
the new methodology, calling it ``a huge advance,'' ``a real step
change'' and ``an important improvement'' in estimating the SC-GHG, and
noting that it addressed the National Academies' and others'
recommendations and ``generally represents well the emerging consensus
in the literature.''
DOE also preliminarily determined that the most significant
improvements in the 2023 SC-GHG estimates are consistent with the
recommendations made by the National Academies. In its report, the
National Academies' principal recommendation was to develop and use ``a
new framework that would strengthen the scientific basis, provide
greater transparency, and improve characterization of the uncertainties
of the estimates.'' \126\ The IWG's estimates since 2010 have relied on
averaging the values produced by three integrated assessment models,
each of which generates a set of SC-GHG estimates based on the inputs
and assumptions built into that particular model.\127\ The National
Academies recommended an entirely new approach that would ``unbundle''
this process and instead use a framework in which each step of the SC-
GHG calculation is developed as one of four separate but integrated
``modules'': the socioeconomic module, the climate module, the damages
module, and the discounting module. The report provided detailed
recommendations on developing and using these modules, including how to
address discounting, socioeconomic projections, climate modeling, and
uncertainty.
---------------------------------------------------------------------------
\126\ Report Recommends New Framework for Estimating the Social
Cost of Carbon [verbar] National Academies (available at: https://www.nationalacademies.org/news/2017/01/report-recommends-new-framework-for-estimating-the-social-cost-of-carbon) (last accessed
July 3, 2023).
\127\ See https://www.epa.gov/system/files/documents/2023-12/epa_scghg_2023_report_final.pdf, 6. (last accessed July 3, 2023).
---------------------------------------------------------------------------
In the July 2024 NODA, DOE preliminarily concluded that the 2023
SC-GHG estimates are consistent with the National Academies' (2017)
recommendations and represent major scientific advancements over the
IWG's approach. In addition, DOE supported the incorporation of more
recent scientific findings and data throughout the development of each
of the 2023 SC-GHG modules and the underlying components of those
modules.
Thus, in accordance with the IWG memo, and having reviewed the 2023
SC-GHG methodologies and updates, DOE preliminarily determined that the
updated 2023 SC-GHG estimates reflect the best available scientific and
analytical evidence and methodologies, are accordingly the most
appropriate for analytical use, and best facilitate sound decision-
making by substantially improving the transparency of the estimates and
representations of uncertainty inherent in such estimates. For this
final rule, DOE used these updated 2023 SC-GHG values to monetize the
climate benefits of the emissions reductions associated at each TSL for
walk-in coolers and freezers. In future rulemakings, DOE will continue
to evaluate the scientific literature and use our professional judgment
to apply the SC-GHG estimates that are most appropriate to use at that
time.
The September 2023 NOPR for walk-in coolers and freezers was
developed and published prior to EPA's December 2023 final rule and
accordingly used the 2021 interim SC-GHG estimates published by the
IWG, rather than the updated 2023 SC-GHG estimates. As noted above, DOE
preliminarily found in the July NODA that using the 2023 SC-GHG
estimates provides a better-informed range of potential climate
benefits associated with amended standards. However, for consistency
with September 2023 NOPR, DOE also provides the SC-GHG associated with
this rule based on the interim 2021interim SC-GHG estimates, in
addition to the 2023 SC-GHG estimates, for the purposes of the summary
results presented in sections I.C and V.B and V.C of this final rule.
The 2023 EPA technical report presents SC-GHG values for emissions
years through 2080; therefore, DOE did not monetize the climate
benefits of GHG emissions reductions occurring after 2080 when using
the 2023 estimates for the SC-GHG. DOE expects additional climate
impacts to accrue from GHG emissions changes post 2080, but due to a
lack of readily available SC-GHG estimates for emissions years beyond
2080 and the relatively small emission effects expected from those
years, DOE has not monetized these additional impacts in this analysis.
Similarly, the interim 2021 interim SC-
[[Page 104735]]
GHG estimates include values through 2070. DOE expects additional
climate benefits to accrue for products still operating after 2070, but
a lack of available SC-GHG estimates published by the IWG for emissions
years beyond 2070 prevents DOE from monetizing these potential benefits
in this analysis.
The overall climate benefits are generally greater when using the
higher, updated 2023 SC-GHG estimates, compared to the climate benefits
calculated using the older 2021 interim SC-GHG estimates, which were
used in the September 2023 NOPR. The net benefits of the rule are
positive, however, under either SC-GHG calculation methodology; in
fact, the net benefits of the rule are positive without including any
monetized climate benefits at all. The adopted standards would be
economically justified even without inclusion of the estimated
monetized benefits of reduced GHG emissions using either methodology,
therefore the conclusions of the analysis (as presented in section V.C
of this document) are not dependent on which set of estimates of the
SC-GHG are used in the analysis or on the use of the SC-GHG at all. The
adopted standard level would remain the same under either SC-GHG
calculation methodology.
DOE's derivations of the SC-CO2, SC-N2O, and
SC-CH4 values used for this final rule 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.K of this document.
a. Social Cost of Carbon
The SC-CO2 values used for this final rule are presented
using two sets of SC-GHG estimates. One set is the 2023 SC-GHG
estimates published by the EPA, which are shown in Table IV.57 in 5-
year increments from 2020 to 2050.\128\ The set of annual values that
DOE used is presented in appendix 14A of the final rule TSD. These
estimates include values out to 2080. DOE expects additional climate
benefits to accrue for products still operating after 2080, but a lack
of available SC-CO2 estimates for emissions years beyond
2080 prevents DOE from monetizing these potential benefits in this
analysis.
---------------------------------------------------------------------------
\128\ www.epa.gov/system/files/documents/2023-12/eo12866_oil-and-gas-nsps-eg-climate-review-2060-av16-final-rule-20231130.pdf;
www.epa.gov/system/files/documents/2023-12/epa_scghg_2023_report_final.pdf (last accessed July 3, 2024).
---------------------------------------------------------------------------
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.075
[[Page 104736]]
DOE also presents results using interim SC-CO2 values
based on the values developed for the February 2021 SC-GHG TSD, which
are shown in Table IV.58 in 5-year increments from 2020 to 2050. The
set of annual values that DOE used, which was adapted from estimates
published by EPA in 2021,\129\ 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.
---------------------------------------------------------------------------
\129\ 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 Feb. 21, 2023).
[GRAPHIC] [TIFF OMITTED] TR23DE24.076
DOE multiplied the CO2 emissions reduction estimated for
each year by the SC-CO2 value for that year for both sets of
SC-CO2 estimates. DOE adjusted the values to 2023$ 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 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
final rule are presented using two sets of SC-GHG estimates. One set is
the 2023 SC-GHG estimates published by the EPA. Table IV.59 shows the
updated sets of SC-CH4 and SC-N2O estimates in 5-
year increments from 2020 to 2050. The full set of annual values used
is presented in appendix 14A of the final rule TSD. These estimates
include values out to 2080.
[GRAPHIC] [TIFF OMITTED] TR23DE24.077
DOE also presents results using interim SC-CH4 and SC-
N2O values based on the values developed for the February
2021 SC-GHG TSD. Table IV.60 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 unrounded values used in the calculations is presented in
appendix 14A of the final rule TSD. These estimates include values out
to 2070.
[[Page 104737]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.078
BILLING CODE 6410-01-C
DOE multiplied the CH4 and N2O emissions
reduction estimated for each year by the SC-CH4 and SC-
N2O estimates for both sets of SC-GHG. DOE adjusted the
values to 2023$ using the implicit price deflator for 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 final rule, DOE estimated the monetized value of
NOX and SO2 emissions reductions from electricity
generation using benefit-per-ton estimates for that sector from the
EPA's Benefits Mapping and Analysis Program.\130\ Table 5 of the EPA
TSD provides a summary of the health impact endpoints quantified in the
analysis. 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, 2035, 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 (rather than extrapolated) to be conservative. 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 final rule TSD).
---------------------------------------------------------------------------
\130\ 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.''
Available at www.epa.gov/benmap/estimating-benefit-ton-reducing-directly-emitted-pm25-pm25-precursors-and-ozone-precursors.
---------------------------------------------------------------------------
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
final rule 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 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 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 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
[[Page 104738]]
indicate that expenditures in the utility sector generally create fewer
jobs (both directly and indirectly) than expenditures in other sectors
of the economy.\131\ Bureau of Economic Analysis input-output
multipliers also show a lower labor intensity per million dollars of
activity for utilities as compared to other industries.\132\ 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.
---------------------------------------------------------------------------
\131\ See U.S. Bureau of Labor Statistics. Industry Output and
Employment. Available at https://www.bls.gov/emp/data/industry-out-and-emp.htm (last accessed August 19, 2024).
\132\ See U.S. Department of Commerce-Bureau of Economic
Analysis. Regional Input-Output Modeling System (RIMS II) User's
Guide. Available at: bea.gov/resources/methodologies/RIMSII-user-guide (last accessed August 19, 2024).
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this final rule using an input/output model of the
U.S. economy called Impact of Sector Energy Technologies version 4
(``ImSET'').\133\ 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.
---------------------------------------------------------------------------
\133\ Livingston, O.V., et al. 2015. ImSET 4.0: Impact of Sector
Energy Technologies Model Description and User's Guide. Pacific
Northwest National Laboratory. PNNL-24563.
---------------------------------------------------------------------------
DOE notes that ImSET is not a general equilibrium forecasting
model, and it notes 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 overestimate actual job impacts over the long
run for this rule. Therefore, DOE used ImSET only to generate results
for near-term timeframes (2033 for walk-in envelope components, and
2034 for walk-in refrigeration systems), where these uncertainties are
reduced. For more details on the employment impact analysis, see
chapter 16 of the final rule 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-
ins. It addresses the TSLs examined by DOE, the projected impacts of
each of these levels if adopted as energy conservation standards for
walk-ins, and the standards levels that DOE is adopting in this final
rule. Additional details regarding DOE's analyses are contained in the
final rule 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 final rule, 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
TSLs 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 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 final rule
TSD provides detailed information on the LCC and PBP analyses.
Table V.1 through Table V.48 show the LCC and PBP results for the
TSLs considered for each equipment class. In the first of the pair of
tables, the simple payback is measured relative to the baseline
product. In the second table, the impacts are measured relative to the
efficiency distribution in the no-new-standards case in the compliance
year (see section IV.F.9 of this document). Because some consumers
purchase products with higher efficiency in the no-new-standards case,
the average savings are less than the difference between the average
LCC of the baseline equipment 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. To aid the reader the
LCC and PBP results for the amended standards have been italicized.
Display Doors
BILLING CODE 6410-01-P
[[Page 104739]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.079
[[Page 104740]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.080
[[Page 104741]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.081
[[Page 104742]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.082
[[Page 104743]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.083
Non-Display Doors
[[Page 104744]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.084
[[Page 104745]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.085
[[Page 104746]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.086
[[Page 104747]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.087
[[Page 104748]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.088
[[Page 104749]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.089
[[Page 104750]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.090
Panels
[[Page 104751]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.091
[[Page 104752]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.092
[[Page 104753]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.093
[[Page 104754]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.094
[[Page 104755]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.095
[[Page 104756]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.096
Dedicated Condensing Units
[GRAPHIC] [TIFF OMITTED] TR23DE24.097
[GRAPHIC] [TIFF OMITTED] TR23DE24.098
[[Page 104757]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.099
[GRAPHIC] [TIFF OMITTED] TR23DE24.100
[GRAPHIC] [TIFF OMITTED] TR23DE24.101
[[Page 104758]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.102
[GRAPHIC] [TIFF OMITTED] TR23DE24.103
[GRAPHIC] [TIFF OMITTED] TR23DE24.104
Single-Packaged Dedicated Systems
[[Page 104759]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.105
[GRAPHIC] [TIFF OMITTED] TR23DE24.106
[GRAPHIC] [TIFF OMITTED] TR23DE24.107
[[Page 104760]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.108
[GRAPHIC] [TIFF OMITTED] TR23DE24.109
[GRAPHIC] [TIFF OMITTED] TR23DE24.110
[[Page 104761]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.111
[GRAPHIC] [TIFF OMITTED] TR23DE24.112
[GRAPHIC] [TIFF OMITTED] TR23DE24.113
[[Page 104762]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.114
[GRAPHIC] [TIFF OMITTED] TR23DE24.115
[GRAPHIC] [TIFF OMITTED] TR23DE24.116
[[Page 104763]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.117
[GRAPHIC] [TIFF OMITTED] TR23DE24.118
[GRAPHIC] [TIFF OMITTED] TR23DE24.119
[[Page 104764]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.120
Unit Coolers
[GRAPHIC] [TIFF OMITTED] TR23DE24.121
[GRAPHIC] [TIFF OMITTED] TR23DE24.122
[[Page 104765]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.123
[GRAPHIC] [TIFF OMITTED] TR23DE24.124
[GRAPHIC] [TIFF OMITTED] TR23DE24.125
[[Page 104766]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.126
[GRAPHIC] [TIFF OMITTED] TR23DE24.127
[GRAPHIC] [TIFF OMITTED] TR23DE24.128
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 final rule TSD presents the complete LCC and PBP
results for the subgroups.
[[Page 104767]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.129
[[Page 104768]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.130
[[Page 104769]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.131
[[Page 104770]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.132
[[Page 104771]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.133
[[Page 104772]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.134
[[Page 104773]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.135
c. Rebuttable-Presumption Payback
As discussed in section IV.F 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 were calculated
using distributions that reflect the range of energy use in the field.
Table V.52 through 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 this rule 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), which
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.
[[Page 104774]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.136
[[Page 104775]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.137
[[Page 104776]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.138
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of amended energy
conservation standards on manufacturers of walk-ins. The next section
describes the expected impacts on manufacturers at each considered TSL.
Chapter 12 of the final rule 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 impacts 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.\134\ 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.
---------------------------------------------------------------------------
\134\ 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. For walk-in display doors, non-display doors, and
panels, the analysis period is 2024-2057 (30 years after the modeled
2028 compliance year). For refrigeration systems, the analysis period
is 2024-2058 (30 years after the modeled 2029 compliance year). The
``change in INPV'' results refer to the difference in industry value
between the no-new-
[[Page 104777]]
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 of 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.55, Table V.56, Table V.57, and Table V.58 show the MIA
results for each TSL for walk-in display door, non-display door, panel,
and refrigeration system industries, respectively.
Doors
Display Doors
[GRAPHIC] [TIFF OMITTED] TR23DE24.139
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
(i.e., 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
-32.1 percent to 31.5 percent. At this level, free cash flow is
estimated to decrease by 78.4 percent compared to the no-new-standards
case value of $17.0 million in the year 2027, the year before the
standards year. DOE estimates that no display door shipments currently
meet the max-tech efficiency levels.
DOE expects manufacturers of display doors would likely need to
incorporate 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, five are small, domestic businesses.
DOE estimates capital conversion costs of $5.2 million and product
conversion costs of $32.2 million. Conversion costs total $37.4
million.
At TSL 3, the shipment-weighted average MPC for all display doors
is expected to increase by 80.7 percent relative to the no-new-
standards case shipment-weighted average MPC for all display doors in
2028. In the preservation of gross margin percentage scenario, the
increase in cashflow from the higher MSP outweighs the $37.4
[[Page 104778]]
million in conversion costs, causing a significant 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 analyzed compliance
year. This reduction in the manufacturer markup and the $37.4 million
in conversion costs incurred by manufacturers cause a significant
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 final rule TSD for additional details about the manufacturer markup
scenarios.
Non-Display Doors
[GRAPHIC] [TIFF OMITTED] TR23DE24.140
At TSL 1, the standard represents EL 1 for all non-display door
equipment classes. The change in INPV is expected to range from -0.4
percent to 0.7 percent. At this level, free cash flow is estimated to
decrease by 1.2 percent compared to the no-new-standards case value of
$40.3 million in the year 2027, the year before the standards year.
DOE expects that all non-display door equipment classes (i.e.,
NM.L, NM.M, NO.L, NO.M) would likely require anti-sweat heater
controls. Currently, approximately 32.0 percent of non-display-door
shipments meet the TSL 1 efficiencies. DOE does not expect
manufacturers would incur significant capital investments at this TSL
as new equipment or tooling is likely not required. Product conversion
costs may be necessary to update and test new non-display-door designs.
DOE estimates total conversion costs of $1.4 million, all of which are
product conversion costs.
At TSL 1, the shipment-weighted average MPC for non-display doors
is expected to increase by 1.5 percent relative to the no-new-standards
case shipment-weighted average MPC for non-display doors in 2028. In
the preservation of gross margin percentage scenario, the minor
increase in cash flow from the higher MSP slightly outweighs the $1.4
million in conversion costs, causing a slightly positive 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 analyzed compliance
year. This reduction in the manufacturer markup and the $1.4 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 EL 3 for all non-display door
equipment classes. The change in INPV is expected to range from -6.5
percent to -2.6 percent. At this level, free cash flow is estimated to
decrease by 38.4 percent compared to the no-new-standards case value of
$40.3 million in the year 2027, the year before the standards year.
At TSL 2, DOE expects that all non-display doors (i.e., NM.L, NM.M,
NO.L, NO.M) would likely require anti-sweat heater controls, improved
framing systems, and reduced anti-sweat heat. Currently, approximately
14.2 percent of non-display-door shipments meet TSL 2 efficiencies.
Capital conversion costs may be necessary to purchase additional
foaming equipment to incorporate thermally-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 $30.0 million and product conversion costs of $5.8
million. Conversion costs total $35.7 million.
At TSL 2, the shipment-weighted average MPC for non-display doors
is expected to increase by 5.1 percent relative to the no-new-standards
case shipment-weighted average MPC for non-display doors in 2028. In
the preservation of gross margin percentage
[[Page 104779]]
scenario, the increase in cash flow from the higher MSP is slightly
outweighed by the $35.7 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 analyzed compliance year. This reduction in the manufacturer
markup and the $35.7 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 levels
for all equipment classes. The change in INPV is expected to range from
-18.2 percent to -6.5 percent. At this level, free cash flow is
estimated to decrease by 107.2 percent compared to the no-new-standards
case value of $40.3 million in the year 2027, 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 approximately 11.1 percent of non-display door shipments
currently meet the max-tech efficiency levels. For the 51 OEMs that
manufacture walk-in non-display doors, increasing insulation thickness
from the assumed baseline thickness of 3.5 inches for medium-
temperature (i.e., NM.M, NO.M) and 4 inches for low-temperature (i.e.,
NM.L, NO.L) non-display doors to 6 inches would likely 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 51 non-display-door OEMs identified, 44 are
small, domestic businesses. DOE estimates capital conversion costs of
$77.9 million and product conversion costs of $23.8 million. Conversion
costs total $101.7 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 non-display
doors is expected to increase by 15.5 percent relative to the no-new-
standards case shipment-weighted average MPC for non-display doors in
2028. In the preservation of gross margin percentage scenario, the
increase in cash flow from the higher MSP is outweighed by the $101.7
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 analyzed compliance year.
This reduction in the manufacturer markup and the $101.7 million in
conversion costs incurred by manufacturers cause a large negative
change in INPV at TSL 3 under the preservation of operating profit
scenario.
Panels
[GRAPHIC] [TIFF OMITTED] TR23DE24.141
At TSL 1 and TSL 2, the standard for all walk-in panel equipment
classes is set to the baseline efficiency level (i.e., 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
-27.6 percent to -15.7 percent. At this level, free cash flow is
estimated to decrease by 159.5
[[Page 104780]]
percent compared to the no-new-standards case value of $82.9 million in
the year 2027, the year before the standards year. Currently,
approximately 8.1 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 43 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 $234.0 million and
product conversion costs of $78.8 million. Conversion costs total
$312.7 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 16.4 percent relative to the no-new-standards
case shipment-weighted average MPC for all panels in 2028. In the
preservation of gross margin percentage scenario, the increase in cash
flow from the higher MSP is outweighed by the $312.7 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 analyzed compliance year.
This reduction in the manufacturer markup and the $312.7 million in
conversion costs incurred by manufacturers cause a large negative
change in INPV at TSL 3 under the preservation of operating profit
scenario.
Refrigeration Systems
[GRAPHIC] [TIFF OMITTED] TR23DE24.142
BILLING CODE 6410-01-C
At TSL 1, the change in INPV is expected to range from -9.2 percent
to -7.3 percent. At this level, free cash flow is estimated to decrease
by 58.6 percent compared to the no-new-standards case value of $49.7
million in the year 2028, the year before the standards year.
Currently, DOE has no evidence of significant shipments meeting
efficiency levels above the baseline efficiency level (i.e., EL 0).
DOE expects that at TSL 1, manufacturers would likely need to
incorporate the following design options: for low- and medium-
temperature indoor dedicated condensing system equipment
[[Page 104781]]
classes \135\ would generally require larger condenser coils; low- and
medium-temperature outdoor dedicated condensing system equipment
classes would generally require self-regulating crankcase heater
controls with a temperature switch; low-temperature outdoor dedicated
condensing systems would also generally require ambient subcooling
circuits; some low- and medium-temperature single-packaged dedicated
system equipment classes would require electronically commutated
condenser fan motors; high-temperature outdoor single-packaged
dedicated condensing systems would generally require self-regulating
crankcase heater controls with a temperature switch and variable-speed
condenser fans; and most high-temperature indoor single-packaged
dedicated condensing systems would generally require up to 1.5 inches
of thermal insulation and electronically commutated condenser fan
motors. DOE expects that at TSL 1, most unit cooler equipment classes
would incorporate improved evaporator coil designs. See section IV.E.1
of this document for the efficiency levels by representative unit for
TSL 1. See chapter 12 of the final rule TSD for a table of analyzed
design options above baseline for each considered representative
capacity by TSL.
---------------------------------------------------------------------------
\135\ 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-efficiency components. DOE estimates
capital conversion costs of $33.2 million and product conversion costs
of $41.5 million. Conversion costs total $74.6 million.
At TSL 1, the shipment-weighted average MPC for all refrigeration
systems is expected to increase by 2.7 percent relative to the no-new-
standards case shipment-weighted average MPC for all refrigeration
systems in 2029. In the preservation of gross margin percentage
scenario, the increase in cash flow from the higher MSP is outweighed
by the $74.6 million in conversion costs, causing a 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 2029, the analyzed compliance
year. This reduction in the manufacturer markup and the $74.6 million
in conversion costs incurred by manufacturers cause a negative change
in INPV at TSL 1 under the preservation of operating profit scenario.
At TSL 2, the change in INPV is expected to range from -11.3
percent to -8.4 percent. At this level, free cash flow is estimated to
decrease by 70.9 percent compared to the no-new-standards case value of
$49.7 million in the year 2028, the year before the standards year.
At TSL 2, DOE expects that manufacturers would likely incorporate
similar design options as TSL 1. For most representative capacities
analyzed, the efficiency levels and associated design options are the
same at TSL 1 and TSL 2. However, at TSL 2 for DC.M.O, DOE expects
manufacturers would likely need to incorporate electronically
commutated condenser fan motors, in addition to the design options
analyzed at TSL 1. DOE further expects that some DC.M.O units may need
to incorporate improved compressors to meet the efficiency levels
required. At TSL 2, more unit cooler equipment classes would need to
incorporate the max-tech design options compared to TSL 1. See section
IV.E.1 of this document for the efficiency levels by representative
unit for TSL 2. See chapter 12 of the final rule TSD for a table of
analyzed design options above baseline for each considered
representative capacity by TSL.
DOE expects industry would incur more capital conversion costs at
TSL 2 compared to TSL 1 as more unit cooler equipment classes would
incorporate the max-tech design options (i.e., would require evaporator
coils 5 rows deep). DOE expects manufacturers would incur more product
conversion costs compared to TSL 1 as they update and test more
refrigeration system capacities across their portfolio. DOE estimates
capital conversion costs of $40.7 million and product conversion costs
of $49.4 million. Conversion costs total $90.1 million.
At TSL 2, the shipment-weighted average MPC for all refrigeration
systems is expected to increase by 4.1 percent relative to the no-new-
standards case shipment-weighted average MPC for all walk-in
refrigeration systems in 2029. In the preservation of gross margin
percentage scenario, the increase in cash flow from the higher MSP is
outweighed by the $90.1 million in conversion costs, causing a 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 2029, the analyzed
compliance year. This reduction in the manufacturer markup and the
$90.1 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 -33.4
percent to 5.3 percent. At this level, free cash flow is estimated to
decrease by 117.0 percent compared to the no-new-standards case value
of $49.7 million in the year 2028, 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 crankcase 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
[[Page 104782]]
require larger evaporator coils or variable-speed evaporator fans.
Finally, DOE anticipates that low-, medium-, and high-temperature unit
cooler equipment classes would require evaporator coils 5 rows deep at
TSL 3. See section IV.E.1 of this document for the efficiency levels by
representative unit for TSL 3. See chapter 12 of the final rule TSD for
a table of analyzed design options above baseline for each considered
representative capacity by TSL. 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 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 final rule 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 $65.6 million and product conversion costs of $83.6
million. Conversion costs total $149.1 million.
At TSL 3, the shipment-weighted average MPC for all refrigeration
systems is expected to increase by 54.4 percent relative to the no-new-
standards case shipment-weighted average MPC for all refrigeration
systems in 2029. In the preservation of gross margin percentage
scenario, the increase in cash flow from the higher MSP outweighs the
$149.1 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 2029, the analyzed compliance
year. This reduction in the manufacturer markup and the $149.1 million
in conversion costs incurred by manufacturers cause a significant
negative change in INPV at TSL 3 under the preservation of operating
profit scenario.
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,\136\ BLS employee
compensation data,\137\ results of the engineering analysis, and
manufacturer interviews.
---------------------------------------------------------------------------
\136\ U.S. Census Bureau. December 2022. (2021) Annual Survey of
Manufactures. ``Summary Statistics for Industry Groups and
Industries.'' Available at www.census.gov/data/tables/time-series/econ/asm/2018-2021-asm.html (last accessed March 8, 2024).
\137\ U.S. Bureau of Labor Statistics. December 15, 2023.
Employer Costs for Employee Compensation. Available at www.bls.gov/news.release/archives/ecec_12152023.pdf (last accessed March 8,
2024).
---------------------------------------------------------------------------
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. Consistent with the September 2023 NOPR, 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 final rule.
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 4,346 domestic production and
non-production workers for walk-in doors and 7,858 domestic production
and non-production workers for walk-in panels in 2028. For
refrigeration systems, DOE estimates in the absence of amended energy
conservation standards there would be 1,018 domestic production and
non-production workers in 2029, using the GRIM. Table V.59, Table V.60,
and
[[Page 104783]]
Table V.61 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.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.143
[GRAPHIC] [TIFF OMITTED] TR23DE24.144
[GRAPHIC] [TIFF OMITTED] TR23DE24.145
BILLING CODE 6410-01-C
The direct employment impacts shown in Table V.59 through Table
V.61 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 continued to produce the same
scope of covered equipment within the United States after compliance
takes effect (DOE models a 2028 compliance year for walk-in display
doors, non-display doors, and panels, and a 2029 compliance year for
refrigeration systems). To establish a conservative lower bound, DOE
assumes all manufacturers would shift production to foreign countries
with lower costs of labor. For walk-in doors, DOE expects that the
likelihood of manufacturers moving production locations due to the
adopted TSL are low. For display doors, DOE is not adopting more
stringent standards in this final rule. For non-display doors, DOE
expects manufacturers would be able to meet the adopted level (i.e.,
TSL 1 for non-display doors) with existing equipment. DOE's engineering
analysis indicates that non-display door manufacturers could reach TSL
1 by incorporating anti-sweat heater controls, which does not require
new equipment or significant capital investment. For walk-in panels,
DOE is not adopting more stringent standards in this final rule. For
walk-in refrigeration systems, some manufacturers currently produce at
least a portion of their walk-in refrigeration systems in countries
with lower labor costs. At the adopted level (i.e., TSL 2 for
refrigeration systems), DOE expects some manufacturers would need to
invest in new equipment and tooling to incorporate larger or improved
heat exchanger designs. If standards necessitate large expenditures to
re-tool facilities, it is possible some manufacturers would reevaluate
[[Page 104784]]
domestic production siting options. However, DOE notes that
manufacturers of walk-in refrigeration systems did not express specific
concerns about changes to domestic production employment in response to
the September 2023 NOPR or the March 2024 NODA.
Additional detail on the analysis of direct employment can be found
in chapter 12 of the final rule 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 final rule 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 for WICF applications. 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. In this final rule,
DOE is not adopting more stringent standards for walk-in display door
equipment classes.
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. In this
final rule, DOE is not adopting standard levels that would likely
necessitate increasing insulation thickness of non-display doors.
Therefore, DOE does not expect manufacturers will face long-term
capacity constraints due to the standard levels detailed in this final
rule.
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. In this final rule,
DOE is not adopting more stringent standards for walk-in panel
equipment classes.
Refrigeration Systems
Manufacturers raised concerns about technical resource constraints
due to overlapping regulations. In confidential interviews and public
comments in response to the September 2023 NOPR and March 2024 NODA,
manufacturers asserted that due to the October 2023 EPA Technology
Transitions Final Rule (compliance required for walk-ins starting
January 1, 2026), they may face resource constraints should DOE
maintain a 3-year compliance period and set more stringent standards
that necessitate the redesign of the majority of models. These
manufacturers stated that meeting the October 2023 EPA Technology
Transitions Final Rule 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 $28.1 million over a
2-year time period (2024-2025) to redesign models for low-GWP
refrigerants and retrofit manufacturing facilities to accommodate
flammable refrigerants in order to comply with EPA's refrigerant
regulation. 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.
As discussed in section III.A.2 of this document, DOE is extending
the compliance lead-in period and requiring compliance with amended DOE
standards for refrigeration systems on December 31, 2028 instead of 3-
years after this final rule is published in the Federal Register,
mitigating concerns about resource constraints. Additionally, as
compared to the December 2022 EPA Technology Transitions NOPR, EPA
provided an additional year to comply with its GWP restrictions for
WICFs (January 1, 2026 instead of January 1, 2025).
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 final rule 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. 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
[[Page 104785]]
burden as part of its rulemakings pertaining to appliance efficiency.
DOE evaluates equipment/product-specific regulations that will take
effect approximately 3 years before the modeled 2028 compliance year
for doors and panels and 3 years after the modeled 2029 compliance year
for refrigeration systems (2025-2032).
The DOE energy conservation standards regulations potentially
contributing to cumulative regulatory burden are presented in Table
V.62. In addition to the proposed and adopted energy conservation
standards rulemakings identified, DOE also considers refrigerant
regulations, such as the October 2023 EPA Technology Transitions Final
Rule, in its cumulative regulatory burden analysis. DOE discusses these
refrigerant regulations in the subsection, ``Refrigerant Regulations''
included in this section.
BILLING CODE 6410-01-P
[[Page 104786]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.195
[[Page 104787]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.196
Refrigerant Regulations
The October 2023 EPA Technology Transitions Final Rule restricts
the use of hydrofluorocarbons in specific sectors or subsectors,
including use in walk-in refrigeration systems. Consistent with the
September 2023 NOPR, DOE considered the impacts of the refrigerant
transition in this final rule analysis. 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.e and
IV.C.1.f of this document, DOE expects manufacturers will likely need
to transition to an A2L or A3 refrigerant or CO2 to comply
with upcoming refrigerant regulations prior to the expected December
31, 2028 \138\ compliance date of any potential energy conservation
standards. In this final rule, DOE maintained the refrigerants analyzed
in the September 2023 NOPR analysis for dedicated condensing units,
single-packaged dedicated condensing systems, and unit coolers.
Consistent with the March 2024 NODA, DOE reviewed the EERs of R-454C
compressors with capacities representative of walk-in refrigeration
systems to assess the potential impact of State-level sub-150 GWP
requirements. See the ``Refrigerants Analyzed'' subsections in sections
IV.C.1.e and IV.C.1.f of this document for additional information about
the refrigerants analyzed in the WICF refrigeration system engineering
analysis.
---------------------------------------------------------------------------
\138\ Modeled as 2029 (the first full year of compliance) in
this final rule.
---------------------------------------------------------------------------
DOE considers the cost associated with the refrigerant transition
in its GRIM in the no-new-standards case and standards case because
investments required to transition to low-GWP refrigerants in response
to the October 2023 EPA Technology Transition Final Rule necessitates a
level of investment beyond typical annual R&D and capital expenditures.
DOE considers the expenses associated with the refrigerant transition
as independent of DOE actions related to any new and amended energy
conservation standards. In other words, manufacturers would need to
comply with the October 2023 EPA Technology Transitions Final Rule
regardless of whether or not DOE amended standards. For the September
2023 NOPR, DOE relied on manufacturer feedback in confidential
interviews, a report prepared for EPA,\139\ and written comments from
AHRI in response to the June 2022 Preliminary Analysis to estimate the
industry refrigerant transition costs. For this final rule, DOE refined
its R&D estimate to reflect feedback from written comments in response
to the September 2023 NOPR. DOE also DOE updated its refrigerant
transition capital expenditure estimates from the September 2023 NOPR
to 2023$ for this final rule. Furthermore, DOE adjusted the timeline of
when manufacturers would need to make investments related to the
refrigerant transition to align with the revised compliance dates for
walk-in refrigeration systems in the October 2023 EPA Technology
Transitions Final Rule.
---------------------------------------------------------------------------
\139\ 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.
---------------------------------------------------------------------------
Based on feedback, DOE assumed that the transition to low-GWP
refrigerants would require industry to invest approximately $15.7
million in R&D and $12.4 million in capital expenditures (e.g.,
investments in new charging equipment, leak detection systems, etc.)
from 2024 (the final rule reference year) and 2026 (EPA compliance
date). Consistent with the September 2023 NOPR, DOE notes that its
refrigerant transition estimates of $15.7 million in R&D and $12.4
million capital expenditures reflect an estimate of future investments
industry would incur to comply with Federal or State refrigerant
regulations. DOE acknowledges that manufacturers have already invested
a significant amount of time and capital into transitioning WICF
refrigeration systems to low-GWP refrigerants. However, as the GRIM
developed for this rulemaking only analyzes future cashflows, starting
with the reference year of the analysis (2024) and continuing 30 years
after the analyzed compliance year, the MIA conducted for this final
rule only reflects changes in annual cash flow and associated
refrigerant transition expenses starting in 2024.
3. National Impact Analysis
This section presents DOE's estimates of the national energy
savings and the NPV of consumer benefits that would result from each of
the TSLs considered as potential amended standards.
a. National 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 (2028-2057 for
[[Page 104788]]
envelope components, and 2029-2058 for refrigeration systems) Table
V.63 through Table V.65 present DOE's projections of the national
energy savings 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.
[GRAPHIC] [TIFF OMITTED] TR23DE24.146
[GRAPHIC] [TIFF OMITTED] TR23DE24.147
[GRAPHIC] [TIFF OMITTED] TR23DE24.148
[[Page 104789]]
OMB Circular A-4 \140\ 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.\141\ 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.66
through Table V.68. The impacts are counted over the lifetime of walk-
ins purchased over the periods of 2028-2057 for envelope components,
and 2029-2058 for refrigeration systems.
---------------------------------------------------------------------------
\140\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. Available at www.whitehouse.gov/omb/information-for-agencies/circulars (last accessed May 31, 2024). DOE
used the prior version of Circular A-4 (September 17, 2003) in
accordance with the effective date of the November 9, 2023 version.
\141\ 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.
[GRAPHIC] [TIFF OMITTED] TR23DE24.149
[GRAPHIC] [TIFF OMITTED] TR23DE24.150
[[Page 104790]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.151
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-ins.\142\
In accordance with OMB Circular A-4, DOE calculated NPV using both a 7-
percent and a 3-percent real discount rate. Table V.69 through Table
V.71 shows the consumer NPV results with impacts counted over the
lifetime of products purchased during the periods of 2028-2057 for
envelope components, and 2029-2058 for refrigeration systems.
---------------------------------------------------------------------------
\142\ See section IV.H.3 of this document for the more detailed
discussion on the NPV of consumer costs and benefits.
[GRAPHIC] [TIFF OMITTED] TR23DE24.152
[[Page 104791]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.153
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V.72 through Table V.74. The impacts are
counted over the lifetime of products purchased during the periods of
2028-2036 for envelope components, and 2029-2037 for refrigeration
systems. 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.
[GRAPHIC] [TIFF OMITTED] TR23DE24.154
[[Page 104792]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.155
[GRAPHIC] [TIFF OMITTED] TR23DE24.156
[GRAPHIC] [TIFF OMITTED] TR23DE24.157
BILLING CODE 6410-01-C
The previous results reflect the use of a default trend to estimate
the change in price for walk-ins over the analysis period (see section
IV.H of this
[[Page 104793]]
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 final rule 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 amended energy conservation standards for walk-
ins will 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 (2028 through
2032 for envelope components and 2029 through 2033 for refrigeration
systems), where these uncertainties are reduced.
The results suggest that the adopted standards are 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 final rule 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
concluded that the standards adopted in this final rule will not lessen
the utility or performance of the walk-ins under consideration in this
rulemaking. In performing the engineering analysis, DOE considers
design options that would not lessen the utility or performance of the
individual classes of equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV) and 42
U.S.C. 6316(a)) As presented in the screening analysis (chapter 4 of
the final rule TSD), DOE eliminates from consideration any design
options that reduce the utility of the equipment. Further, DOE is aware
that manufacturers currently offer units with expected performance that
meets or exceeds the adopted standards for some equipment classes.
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, EPCA directs the Attorney General of the United
States (``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 in writing 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. To assist the Attorney General
in making this determination, DOE provided the Department of Justice
(``DOJ'') with copies of the NOPR and the TSD for review. In its
assessment letter responding to DOE, DOJ concluded that the proposed
energy conservation standards for walk-ins are unlikely to have a
significant adverse impact on competition. DOE is publishing the
Attorney General's assessment at the end of this final rule.
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 final rule 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-ins is expected to yield environmental benefits in
the form of reduced emissions of certain air pollutants and GHGs. Table
V.75 through Table V.77 provide 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.L. DOE reports annual emissions reductions for
each TSL in chapter 13 of the final rule TSD.
BILLING CODE 6410-01-P
[[Page 104794]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.158
[[Page 104795]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.159
[[Page 104796]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.160
[[Page 104797]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.161
[[Page 104798]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.162
As part of the analysis for this rule, DOE estimated monetized
climate benefits likely to result from the reduced emissions of
CO2 that DOE estimated for each of the considered TSLs for
walk-in coolers and freezers. Section IV.L of this document discusses
the two separate sets of SC-CO2 estimates that DOE used.
Table V.78 through Table V.83 present 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 selected
TSL in chapter 14 of the final rule TSD.
[[Page 104799]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.163
[GRAPHIC] [TIFF OMITTED] TR23DE24.164
[[Page 104800]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.165
[GRAPHIC] [TIFF OMITTED] TR23DE24.166
[[Page 104801]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.167
[GRAPHIC] [TIFF OMITTED] TR23DE24.168
As discussed in section IV.L.2, 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-ins Table V.84 through Table V.89 present the value of the
CH4 emissions reduction at each TSL, and Table V.90 through
Table V.95 present the value of the N2O emissions reduction
at each TSL. The time-series of annual values is presented for the
selected TSL in chapter 14 of the final rule TSD.
[[Page 104802]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.169
[GRAPHIC] [TIFF OMITTED] TR23DE24.170
[[Page 104803]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.171
[GRAPHIC] [TIFF OMITTED] TR23DE24.172
[[Page 104804]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.173
[GRAPHIC] [TIFF OMITTED] TR23DE24.174
[[Page 104805]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.175
[GRAPHIC] [TIFF OMITTED] TR23DE24.176
[[Page 104806]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.177
[GRAPHIC] [TIFF OMITTED] TR23DE24.178
[[Page 104807]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.179
[GRAPHIC] [TIFF OMITTED] TR23DE24.180
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 continue 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, however, that the adopted standards would be economically
justified even without inclusion of monetized benefits of reduced GHG
emissions.
DOE also estimated the monetary value of the economic 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.96 presents the present value for NOX
emissions reduction for each TSL calculated using 7-percent and 3-
percent discount rates, and Table V.97 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 selected TSL in chapter 14 of the final rule TSD.
[[Page 104808]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.181
[GRAPHIC] [TIFF OMITTED] TR23DE24.182
[[Page 104809]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.183
[GRAPHIC] [TIFF OMITTED] TR23DE24.184
[[Page 104810]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.185
[GRAPHIC] [TIFF OMITTED] TR23DE24.186
Not all the public health and environmental benefits from the
reduction of GHGs, 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.102 through Table V.107 presents the NPV values that result
from adding the estimates of the 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 walk-in envelope components shipped in
2028-2057, and walk-in refrigeration systems shipped in 2029-2058. 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-in envelope components shipped in 2028-
2057, and walk-in refrigeration systems shipped in 2029-2058.
[[Page 104811]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.187
[[Page 104812]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.188
[[Page 104813]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.189
[[Page 104814]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.190
[[Page 104815]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.191
[GRAPHIC] [TIFF OMITTED] TR23DE24.192
C. Conclusion
When considering new or amended energy conservation standards, the
standards that DOE adopts for any type (or class) of covered equipment
must be designed to achieve the maximum improvement in energy
efficiency that the Secretary determines is technologically feasible
and economically justified. (42 U.S.C. 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. 6316(a); 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 final rule, DOE considered the impacts of new and 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-In Cooler and Walk-
In Freezer Standards
a. Refrigeration Systems
The efficiency levels contained in each TSL are shown in Table
V.108 and described in section IV.E.1 of this document. Table V.109 and
Table V.110 summarize the quantitative impacts
[[Page 104816]]
estimated for each TSL for walk-in refrigeration systems. 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 (2029-2058 The energy savings, emissions reductions,
and value of emissions reductions refer to full-fuel-cycle results. DOE
is presenting monetized benefits of GHG emissions reductions in
accordance with the applicable Executive orders, and DOE would reach
the same conclusion presented in this notice in the absence of the
estimated benefits from reductions in GHG emissions, including the
estimates published by EPA in December 2023 or the Interim Estimates
presented by the Interagency Working Group in 2021.
[[Page 104817]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.193
[[Page 104818]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.194
[[Page 104819]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.197
[[Page 104820]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.198
[[Page 104821]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.199
[[Page 104822]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.200
BILLING CODE 6410-01-C
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 \143\ 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 crankcase 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.\144\ 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.\145\
Finally, DOE anticipates that low-, medium-, and high-temperature unit
cooler equipment classes would require evaporator coils 5 rows deep at
TSL 3.
---------------------------------------------------------------------------
\143\ 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.
\144\ As discussed in section 5.7 of the final rule TSD, DOE did
not consider larger condensing coils or variable capacity
compressors for high-temperature dedicated condensing systems.
\145\ As discussed in section 5.7 of the final rule TSD, 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 3.39 quads of energy, an amount DOE
considers significant. Under TSL 3, the NPV of consumer benefit would
be -$4.92 billion using a discount rate of 7 percent, and -$8.07
billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 60.55 million Mt
of CO2, 18.49 thousand tons of SO2, 113.20
thousand tons of NOX, 0.13 tons of Hg, 513.28 thousand tons
of CH4, and 0.59 thousand tons of N2O. The
estimated monetary value of the climate benefits from reduced GHG
emissions at TSL 3 is $14.24 billion (associated with the average SC-
GHG at a 2-percent near-term Ramsey discount rate using the 2023 SC-GHG
estimates) or $3.54 billion (associated with the average SC-GHG at a 3-
percent discount rate using the 2021 interim SC-GHG estimates). The
estimated monetary value of the health benefits from reduced
SO2 and NOX emissions at TSL 3 is $2.77 billion
using a 7-percent discount rate and $6.91 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated total NPV at TSL 3 is $12.09 billion
(using the 2023 SC-GHG estimates) or $1.39 billion (using the 2021
interim SC-GHG estimates). Using a 3-percent discount rate for consumer
benefits and costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or the 3-percent discount rate case for climate
benefits from reduced GHG emissions, the estimated total NPV at TSL 3
is $13.08 billion (using the 2023 SC-GHG estimates) or $2.38 billion
(using the 2021 interim SC-GHG estimates). 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 -$8,252
for low-temperature, outdoor, dedicated condensing units (DC.L.O), to
$1,304 for low-temperature unit coolers (UC.L). The simple payback
period ranges from 0.7 years for high-temperature, indoor, single-
packaged dedicated systems (SP.H.I) to 47.4 years for medium-
temperature, outdoor, single-packaged dedicated systems (SP.M.O). The
fraction of consumers experiencing a net LCC cost ranges from 0.4
percent for high-temperature, ducted, indoor, single-packaged dedicated
systems (SP.H.I.D) to 100.0 percent for low-
[[Page 104823]]
temperature and medium-temperature indoor and outdoor single-packaged
dedicated systems.
At TSL 3, the projected change in INPV ranges from a decrease of
$181.1 million to an increase of $28.9 million, which corresponds to a
decrease of 33.4 percent and an increase of 5.3 percent, respectively.
DOE estimates that industry must invest $149.1 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. DOE expects manufacturers may need to increase the size of the
cabinet to incorporate larger condenser coils or additional rows since
there might not be sufficient room to increase the size of the heat
exchanger within existing case dimensions. Some manufacturers may need
to purchase new equipment to maintain current production levels.
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 final rule publication, the few variable capacity compressor
product lines DOE identified appear to be primarily advertised for
markets outside of North America. 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 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 consumers of low- and
medium-temperature dedicated condensing system and single-packaged
dedicated system consumers (ranging from 0.4 to 100.0 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 significant
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 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 necessitate the use of variable capacity
compressors. DOE expects that at TSL 2, all dedicated condensing system
equipment classes would generally require electronically commutated
condenser fan motors; all outdoor dedicated condensing system equipment
would generally require self-regulating crankcase heater controls with
a temperature switch; additionally, low-temperature outdoor dedicated
condensing system equipment classes would generally require variable-
speed condenser fan motors and all but the highest capacity units would
generally require ambient subcooling circuits; some medium-temperature
outdoor dedicated condensing unit equipment classes would require
improved single-speed compressors; low-temperature and indoor medium-
temperature dedicated condensing unit equipment classes would generally
require larger condenser coils; low- and medium-temperature single-
packaged dedicated system equipment classes would generally require
larger evaporator coils and variable speed evaporator fans; lower-
capacity medium-temperature single-packaged dedicated condensing
systems would generally require propane compressors; higher capacity
indoor low-temperature single-packaged dedicated system equipment
classes would generally require thermal insulation up to 4 inches in
thickness; outdoor medium-temperature single-packaged dedicated system
equipment classes would generally require variable speed condenser
fans; lower capacity outdoor medium-temperature single-packaged
dedicated system equipment classes would generally require thermal
insulation up to 4 inches in thickness and ambient subcooling circuits;
high-temperature indoor, and outdoor ducted, dedicated condensing
system equipment classes would generally incorporate max-tech design
options; finally high-temperature outdoor non-ducted dedicated
condensing system equipment classes would generally require thermal
insulation up to 1.5 inches in thickness, and 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, and highest-capacity medium-temperature unit coolers,
which would generally only require 3-row deep evaporator coils.
TSL 2 would save an estimated 1.03 quads of energy, an amount DOE
considers significant. Under TSL 2, the NPV of consumer benefit would
be $1.07 billion using a discount rate of 7 percent, and $2.66 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 2 are 18.40 million Mt
of CO2, 5.62 thousand tons of SO2, 34.39 thousand
tons of NOX, 0.04 tons of Hg, 155.95 thousand tons of
CH4, and 0.18 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions at
TSL 2 is $4.33 billion (associated with the average SC-GHG at a 2-
percent near-term Ramsey discount rate using the 2023 SC-GHG estimates)
or $1.07 billion (associated with the average SC-GHG at a 3-percent
discount rate using the 2021 interim SC-GHG estimates). The estimated
monetary value of the health benefits from reduced SO2 and
NOX emissions at TSL 2 is $0.84 billion using a 7-percent
discount rate and $2.10 billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health
[[Page 104824]]
benefits from reduced SO2 and NOX emissions, and
either the 2-percent near-term Ramsey discount rate case or the 3-
percent discount rate case for climate benefits from reduced GHG
emissions, the estimated total NPV at TSL 2 is $6.24 billion (using the
2023 SC-GHG estimates) or $2.99 billion (using the 2021interim SC-GHG
estimates). Using a 3-percent discount rate for consumer benefits and
costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or the 3-percent discount rate case for climate
benefits from reduced GHG emissions, the estimated total NPV at TSL 2
is $9.09 billion (using the 2023 SC-GHG estimates) or $5.83 billion
(using the 2021 interim SC-GHG estimates). The estimated total NPV is
provided for additional information; however, DOE primarily relies upon
the NPV of consumer benefits when determining whether a standard level
is economically justified.
At TSL 2, the average LCC impact ranges from a savings of $66 for
medium-temperature unit coolers (UC.M) to $1,304 for low-temperature
unit coolers (UC.L).\146\ The simple payback period ranges from 0.2
years for low-temperature, outdoor, single-packaged dedicated systems
(SP.L.O) to 4.7 years for medium-temperature unit coolers (UC.M). The
fraction of consumers experiencing a net LCC cost ranges from 0 percent
for low-temperature, outdoor, single-packaged dedicated systems
(SP.L.O) and high-temperature, indoor, ducted single-packaged dedicated
systems (SP.H.I.D) to 42.8 percent for medium temperature unit coolers
(UC.M).
---------------------------------------------------------------------------
\146\ For this summary statement of consumer impacts DOE did not
include high-temperature unit coolers as DOE is not amending
standards for this equipment at this time.
---------------------------------------------------------------------------
At TSL 2, the projected change in INPV ranges from a decrease of
$61.2 million to a decrease of $45.7 million, which corresponds to
decreases of 11.3 percent and 8.4 percent, respectively. DOE estimates
that industry must invest $90.1 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, compared to max-tech, 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., all
DC.M.O representative units would not require larger condensers or
ambient subcooling, which accounts for approximately 50 percent of
industry dedicated 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 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 medium-temperature unit coolers will be most affected with
43 percent of consumers experiencing a net cost, the consumers of the
remaining equipment are estimated to experience a net cost between 1
and 36 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 19 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 $4.33 billion in climate benefits (associated
with the average SC-GHG at a 2-percent near-term Ramsey discount rate
using the 2023 SC-GHG estimates) or $1.07 billion in climate benefits
(associated with the average SC-GHG at a 3-percent discount rate using
the 2021 interim SC-GHG estimate), and $2.10 billion (using a 3-percent
discount rate) or $0.84 billion (using a 7-percent discount rate) in
health benefits--the rationale becomes stronger still.
Therefore, based on the previous considerations, DOE adopts energy
conservation standards for walk-in refrigeration systems at TSL 2. The
amended energy conservation standards for walk-in refrigeration
systems, which are expressed as AWEF2, are shown in Table V.111.
BILLING CODE 6410-01-P
[[Page 104825]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.201
[[Page 104826]]
b. Doors
Table V.113, Table V.114, Table V.116, and Table V.117 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 (2028-2057). The energy savings, emissions reductions, and
value of emissions reductions refer to full-fuel-cycle results. DOE is
presenting monetized benefits of GHG emissions reductions in accordance
with the applicable Executive orders, and DOE would reach the same
conclusion presented in this notice in the absence of the estimated
benefits from reductions in GHG emissions, including the estimates
published by EPA in December 2023 or the Interim Estimates presented by
the Interagency Working Group in 2021. The efficiency levels contained
in each TSL are described in section IV.E.1 of this document and shown
in Table V.112 and Table V.115 for display doors and non-display doors,
respectively.
Display Doors
Walk-in display door efficiency levels contained in each TSL are
shown in Table V.112 and described in section IV.E.1 of this document
and summarize the quantitative impacts estimated for each TSL for walk-
in display doors.
[GRAPHIC] [TIFF OMITTED] TR23DE24.202
[[Page 104827]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.203
[[Page 104828]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.204
[GRAPHIC] [TIFF OMITTED] TR23DE24.205
BILLING CODE 6410-01-C
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 0.13
quads of energy, an amount DOE considers significant. Under TSL 3, the
NPV of consumer benefit would be -$4.40 billion using a discount rate
of 7
[[Page 104829]]
percent, and -$7.91 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 2.41 million Mt of
CO2, 0.73 thousand tons of SO2, 4.49 thousand
tons of NOX, 0.01 tons of Hg, 20.38 thousand tons of
CH4, and 0.02 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions at
TSL 3 is 1.42 billion (associated with the average SC-GHG at a 2-
percent near-term Ramsey discount rate using the 2023 SC-GHG estimates)
or $1.00 billion (associated with the average SC-GHG at a 3-percent
discount rate using the 2021 interim SC-GHG estimates). The estimated
monetary value of the health benefits from reduced SO2 and
NOX emissions at TSL 3 is $0.11 billion using a 7-percent
discount rate and $0.27 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated total NPV at TSL 3 is -$3.72 billion
(using the 2023 SC-GHG estimates) or -$4.15 billion (using the 2021
interim SC-GHG estimates). Using a 3-percent discount rate for consumer
benefits and costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or the 3-percent discount rate case for climate
benefits from reduced GHG emissions, the estimated total NPV at TSL 3
is -$7.07 billion (using the 2023 SC-GHG estimates) or -$7.50 billion
(using the 2021 interim SC-GHG estimates). The estimated total NPV is
provided for additional information; however, DOE primarily relies upon
the NPV of consumer benefits when determining whether a standard level
is economically justified.
At TSL 3, when used in conjunction with a TSL 2 refrigeration
system, the average LCC impact ranges from a savings of -$1,304 for
medium-temperature display doors (DW.M), to -$1,062 for low-temperature
display doors (DW.L). The simple payback period ranges from 37.5 years
for low-temperature display doors (DW.L) to 196.0 years for medium-
temperature display doors (DW.M). The fraction of consumers
experiencing a net LCC cost is 100.0 percent for all equipment classes.
At TSL 3 for walk-in display doors, the projected change in INPV
ranges from a decrease of $70.2 million to an increase of $69.0
million, which corresponds to a decrease of 32.1 percent and an
increase of 31.5 percent, respectively. DOE estimates industry would
invest $37.4 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 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 concluded that TSL 3 is not
economically justified.
As discussed in section IV.E.1 of this document, DOE did not
incorporate the other analyzed efficiency levels above baseline into
TSL 2 or TSL 1 since the other analyzed efficiency levels do not yield
positive consumer benefits for either of the display door equipment
classes (see appendix 8C of the final rule TSD). Absent positive
consumer benefits, it is unlikely DOE will determine that there is a
sufficient economic basis to support amended standard levels. Here, DOE
has determined there is no combination of energy efficiency
improvements for display-doors that is economically justified.
Therefore, based on the previous considerations, the Secretary is not
amending 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.115 and described in section IV.E.1 of this
document. Table V.116 and Table V.117 summarize the quantitative
impacts estimated for each TSL for walk-in non-display doors.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.206
[[Page 104830]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.207
[[Page 104831]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.208
[[Page 104832]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.209
BILLING CODE 6410-01-C
For walk-in non-display doors, DOE first considered TSL 3, which
represents the max-tech efficiency levels. At TSL 3, DOE expects
manufacturers would likely need to incorporate the following additional
design options: anti-sweat heater controls, improved framing systems
filled with polyurethane foam instead of wood, reduced anti-sweat heat,
and insulation thickness of 6 inches.
For walk-in non-display doors, TSL 3 would save an estimated 1.07
quads of energy, an amount DOE considers significant. Under TSL 3, the
NPV of consumer benefit would be $0.71 billion using a discount rate of
7 percent, and $2.00 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 19.47 million Mt
of CO2, 5.97 thousand tons of SO2, 36.21 thousand
tons of NOX, 0.04 tons of Hg, 163.09 thousand tons of
CH4, and 0.19 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emission at TSL
3 is $4.63 billion (associated with the average SC-GHG at a 2-percent
near-term Ramsey discount rate using the 2023 SC-GHG estimates) or 1.17
billion (associated with the average SC-GHG at a 3-percent discount
rate using the 2021 interim SC-GHG estimates). The estimated monetary
value of the health benefits from reduced SO2 and
NOX emissions at TSL 3 is $0.98 billion using a 7-percent
discount rate and $2.31 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated total NPV at TSL 3 is $6.32 billion (using
the 2023 SC-GHG estimates) or 6.32 billion (using the 2021 interim SC-
GHG estimates). Using a 3-percent discount rate for consumer benefits
and costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or
[[Page 104833]]
the 3-percent discount rate case for climate benefits from reduced GHG
emissions, the estimated total NPV at TSL 3 is $8.93 billion year
(using the 2023 SC-GHG estimates) or $5.47 billion (using the 2021
interim SC-GHG estimates). The estimated total NPV is provided for
additional information; however, DOE primarily relies upon the NPV of
consumer benefits when determining whether a standard level is
economically justified.
At TSL 3, when used in conjunction with a TSL 2 refrigeration
system, the average LCC impact ranges from a savings of -$1 for manual,
medium-temperature non-display doors (NM.M), to $1,516 for motorized
low-temperature non-display doors (NO.L). The simple payback period
ranges from 1.6 years for motorized low-temperature non-display doors
(NO.L) to 6.9 years for manual, medium-temperature non-display doors
(NM.M). The fraction of consumers experiencing a net LCC cost ranges
from 4 percent for motorized low-temperature non-display doors (NO.L)
to 55 percent for manual, medium-temperature non-display doors (NM.M).
At TSL 3, the projected change in INPV ranges from a decrease of
$92.6 million to a decrease of $33.1 million, which corresponds to
decreases of 18.2 percent and 6.5 percent, respectively. DOE estimates
industry would invest $101.7 million to purchase new foaming equipment
and tooling to implement thermally-improved frame designs and increase
insulation thickness to 6 inches for all walk-in non-display doors.
DOE estimates that approximately 11.1 percent of walk-in non-
display door shipments currently meet the max-tech efficiency levels.
For the 51 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 likely 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. At TSL 3, DOE expects that manufacturers would also incorporate
thermally-improved frame designs. New foaming equipment to accommodate
thermally-improved frame designs and 6-inch non-display doors would
require significant capital investment and is a key driver of capital
conversion costs. In addition to the impacts that investments in new
foaming equipment may have for non-display door manufacturers overall,
it would also disproportionately impact small businesses since nearly
all non-display door manufacturers (44 of the 51 OEMs identified) are
small businesses and nearly half of the small businesses identified
have an estimated annual revenue of less than $6 million.
Furthermore, of the 51 walk-in non-display door OEMs, 40 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 likely necessitate 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.c of this document, panels of 6-inch thickness do not
have positive consumer benefits.
At levels that DOE expects would likely necessitate thermally-
improved frame designs (i.e., TSL 2 and TSL 3), some manufacturers
expressed concerns about potential impacts to equipment performance,
including maintaining adequate structural durability. Currently, a
variety of framing systems exist on the market. Many non-display doors
incorporate wood or other high-strength material framing systems, while
others incorporate thermally-improved framing systems filled with
polyurethane foam. Such thermally-improved frame designs may have
reduced structural rigidity compared to traditional (e.g., wood)
framing systems. While the presence of this design feature in the walk-
in market does indicate its suitability in a range of current
applications without any detrimental impact on product performance or
lifetime, DOE recognizes that there may be remaining uncertainty
regarding the structural suitability of the best thermally-insulating
frame systems available on the market in certain applications. Given
these concerns, and lacking structural performance data at this time
that could be used to quantify such differences, DOE cannot be certain
whether the differences in non-display door framing systems currently
in the market are due to manufacturer design preferences or specific
durability requirements (e.g., large sliding doors manufactured
separately from the walk-in in which they are installed may warrant a
frame with greater structural durability than doors manufactured
together with the surrounding panels as a complete system). If the
latter, establishing standards that DOE expects would necessitate
thermally-improved frame designs could result in the need for earlier
replacement of certain non-display doors due to their potentially
reduced structural rigidity in such applications. If the structural
integrity of a non-display door with thermally improved frame designs
were to be compromised this would require earlier replacement than
would have otherwise been expected. As discussed previously in the
sensitivity analysis in section IV.F.7 of this document, the cost
associated with more frequent replacements would far outweigh the
operating cost savings over the lifetime of the equipment, reducing the
economic justification at TSL 2 and TSL 3.\147\
---------------------------------------------------------------------------
\147\ In installations where the lifetime of the non-display
door is reduced as compared to the no-new-standards case, the
consumer would bear additional replacement costs that would outweigh
the savings in operating costs when considering the same service
lifetime as a non-display door without the thermally improved frame
design. This can be seen in Table IV.50 where the consumer LCC
savings is negative for all non-display doors at TSL 2 or TSL 3.
---------------------------------------------------------------------------
For these reasons, DOE cannot be certain that the thermally-
improved framing system associated with TSL 2 and TSL 3 efficiencies
would not negatively impact the durability of walk-in non-display
doors, and, consequently, these impacts may jeopardize the economic
benefits that would be achieved at these efficiency levels. DOE
emphasizes that its findings in this regard are based on the data
available at this time. Additional data that could become available, as
well as future advances in walk-in non-display door technologies and
design strategies, could alleviate any such concerns or uncertainties
regarding equipment performance and could lead DOE to reach a different
conclusion in a future rulemaking.
The Secretary concludes that at TSL 3 for walk-in non-display
doors, the benefits of energy savings, positive NPV of consumer
benefits, emission reductions, and the estimated monetary value of the
emissions reductions would be outweighed by the potential for
[[Page 104834]]
negative impacts to the durability of non-display doors, which may
jeopardize the economic benefits that would be achieved at these
efficiency levels, and the impacts on manufacturers, including the
conversion costs and profit margin impacts that could result in a
reduction in INPV, and the limited number of manufacturers currently
offering equipment meeting the efficiency levels required at this TSL,
including many small businesses of non-display doors. Manufacturers of
non-display doors would need to incorporate thermally-improved frame
designs and increase insulation thickness to 6 inches across all
equipment classes, necessitating large capital investments. 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 concluded that TSL
3 is not economically justified.
DOE then considered TSL 2 for walk-in non-display doors, which
represents EL 3 for all non-display doors. At TSL 2, DOE expects that
manufacturers would likely need to incorporate anti-sweat heater
controls, improved framing systems, and reduced anti-sweat heat into
all non-display door designs.
TSL 2 would save an estimated 0.99 quads of energy, an amount DOE
considers significant. Under TSL 2, the NPV of consumer benefit would
be $1.53 billion using a discount rate of 7 percent, and $3.44 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 2 are 18.02 million Mt
of CO2, 5.53 thousand tons of SO2, 33.51 thousand
tons of NOX, 0.04 tons of Hg, 150.92 thousand tons of
CH4, and 0.18 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions at
TSL 2 is $4.28 billion (associated with the average SC-GHG at a 2-
percent near-term Ramsey discount rate using the 2023 SC-GHG estimates)
or $1.08 billion (associated with the average SC-GHG at a 3-percent
discount rate using the 2021 interim SC-GHG estimates). The estimated
monetary value of the health benefits from reduced SO2 and
NOX emissions at TSL 2 is $0.91 billion using a 7-percent
discount rate and $2.13 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated total NPV at TSL 2 is $6.72 billion (using
the 2023 SC-GHG estimates) or $3.52 billion (using the 2021 interim SC-
GHG estimates). Using a 3-percent discount rate for consumer benefits
and costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or the 3-percent discount rate case for climate
benefits from reduced GHG emissions, the estimated total NPV at TSL 2
is $9.86 billion (using the 2023 SC-GHG estimates) or $6.65 billion
(using the 2021 interim SC-GHG estimates). The estimated total NPV is
provided for additional information; however, DOE primarily relies upon
the NPV of consumer benefits when determining whether a standard level
is economically justified.
At TSL 2, when used in conjunction with a TSL 2 refrigeration
system, the average LCC impact ranges from a savings of $315 for
manual, medium-temperature non-display doors (NM.M), to $1,583 for
motorized, low-temperature non-display doors (NO.L). The simple payback
period ranges from 0.8 years for motorized, low-temperature non-display
doors (NO.L) to 2.6 years for manual, medium-temperature non-display
doors (NM.M). The fraction of consumers experiencing a net LCC cost
ranges from 0.8 percent for motorized, low-temperature non-display
doors (NO.L) to 2.6 percent for manual, medium-temperature non-display
doors (NM.M).
At TSL 2, the projected change in INPV ranges from a decrease of
$32.8 million to a decrease of $13.1 million, which corresponds to
decreases of 6.5 percent and 2.6 percent, respectively. DOE estimates
that industry must invest $35.7 million to comply with standards for
non-display doors set at TSL 2. DOE estimates that approximately 14.2
percent of non-display door shipments currently meet TSL 2
efficiencies. DOE does not expect manufacturers would need to increase
insulation thickness to meet the efficiency levels required by TSL 2,
however, DOE expects manufacturers may need to purchase new foaming
equipment to incorporate thermally-improved frame designs. As
previously discussed, investments in new foaming equipment would
disproportionately impact small businesses since nearly all non-display
door manufacturers are small businesses and nearly half of the small
businesses identified have an estimated annual revenue of less than $6
million.
As discussed previously, manufacturer concerns surrounding the
potential impacts to equipment performance, including maintaining
adequate structural durability, applies to the efficiency levels
required at TSL 2. Although many non-display doors incorporate wood or
other high-strength material framing systems, other non-display doors
incorporate thermally-improved framing systems filled with polyurethane
foam. Such thermally-improved frame designs may have reduced structural
rigidity compared to traditional (e.g., wood) framing systems. Based on
the data currently available, DOE cannot be certain whether the
differences in non-display door framing systems currently in the market
are due to manufacturer design preferences or specific durability
requirements. If the structural integrity of a non-display door with
thermally improved frame designs were to be compromised, necessitating
earlier replacement than would have otherwise been expected, the cost
associated with more frequent replacements would far outweigh the
operating cost savings over the lifetime of the equipment, reducing the
economic justification at TSL 2. For these reasons, DOE cannot be
certain that the thermally-improved framing system associated with TSL
2 efficiencies would not negatively impact the durability of walk-in
non-display doors, and, consequently, these impacts may jeopardize the
economic benefits that would be achieved at these efficiency levels.
DOE emphasizes that its findings in this regard are based on the data
available at this time. Additional data that could become available, as
well as future advances in walk-in non-display door technologies and
design strategies, could alleviate any such concerns or uncertainties
regarding equipment performance and could lead DOE to reach a different
conclusion in a future rulemaking.
The Secretary concludes that at TSL 2 for walk-in non-display
doors, the benefits of energy savings, positive NPV of consumer
benefits, emission reductions, and the estimated monetary value of the
emissions reductions would be outweighed by the potential for negative
impacts to the performance of non-display doors in certain
applications, which may jeopardize the economic benefits that would be
achieved at TSL 2, and the impacts on manufacturers. Nearly all the
non-display door OEMs identified are small, domestic businesses.
Manufacturers of non-display doors would need to incorporate thermally-
improved frame designs across all equipment classes,
[[Page 104835]]
which could necessitate large capital investments relative to the
annual revenue of many small businesses. Consequently, the Secretary
has concluded that TSL 2 is not economically justified.
DOE then considered TSL 1 for walk-in non-display doors, which
represents EL 1 for all non-display doors. At TSL 1, DOE expects that
manufacturers would likely need to incorporate anti-sweat heater
controls into all non-display door designs.
The cumulative emissions reductions at TSL 1 are 10.42 million Mt
of CO2, 3.20 thousand tons of SO2, 19.37 thousand
tons of NOX, 0.02 tons of Hg, 87.23 thousand tons of
CH4, and 0.10 thousand tons of N2O The estimated
monetary value of the climate benefits from reduced GHG emissions at
TSL 1 is $2.48 billion (associated with the average SC-GHG at a 2-
percent near-term Ramsey discount rate using the 2023 SC-GHG estimates)
or $0.62 billion (associated with the average SC-GHG at a 3-percent
discount rate using the 2021 interim SC-GHG estimates). The estimated
monetary value of the health benefits from reduced SO2 and
NOX emissions at TSL 1 is $0.53 billion using a 7-percent
discount rate and $1.23 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated total NPV at TSL 1 is $3.94 billion (using
the 2023 SC-GHG estimates) or $2.09 billion (using the 2021 interim SC-
GHG estimates). Using a 3-percent discount rate for consumer benefits
and costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or the 3-percent discount rate case for climate
benefits from reduced GHG emissions, the estimated total NPV at TSL 1
is $5.79 billion (using the 2023 SC-GHG estimates) or $3.94 billion
(using the 2021 interim SC-GHG estimates). The estimated total NPV is
provided for additional information; however, DOE primarily relies upon
the NPV of consumer benefits when determining whether a standard level
is economically justified.
At TSL 1, when used in conjunction with a TSL 2 refrigeration
system, the average LCC impact ranges from a savings of $270 for
manual, medium-temperature non-display doors (NM.M), to $914 for
motorized, low-temperature non-display doors (NO.L). The simple payback
period ranges from 0.8 years for motorized, low-temperature non-display
doors (NO.L) to 2.0 years for manual, medium-temperature non-display
doors (NM.M). The fraction of consumers experiencing a net LCC cost
ranges from 1 percent for motorized, low-temperature non-display doors
(NO.L) to 6 percent for manual, medium-temperature non-display doors
(NM.M).
At TSL 1, the projected change in INPV ranges from a decrease of
$2.0 million to an increase of $3.5 million, which corresponds to a
decrease of 0.4 percent and an increase of 0.7 percent, respectively.
DOE estimates that industry must invest $1.4 million to comply with
standards for non-display doors set at TSL 1. DOE estimates that
approximately 32.0 percent of non-display door shipments currently meet
TSL 1 efficiencies. At this level, DOE expects manufacturers would
likely need to update non-display door models to incorporate anti-sweat
heater controls. DOE does not expect manufacturers would need to
incorporate thermally-improved frame designs or increase insulation
thickness to meet the efficiency levels required by TSL 1.
At TSL 1, DOE's analysis indicates that manufacturers could reach
the required efficiencies without incorporating thermally-improved
frame designs. Manufacturers did not express any specific concerns
regarding non-display door performance (i.e., structural durability) at
TSL 1. Based on the information available, DOE concludes that no
lessening of equipment performance or reduction of expected lifetime
would occur at TSL 1.
After considering the analysis and weighing the benefits and
burdens, the Secretary has concluded that a standard set at TSL 1 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 6 percent for medium-temperature, manual non-display
doors. At TSL 1, 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 1, the NPV of consumer
benefits, even measured at the more conservative discount rate of 7
percent is over 466 times higher than the maximum estimated
manufacturers' loss in INPV. The standard levels at TSL 1 are
economically justified even without weighing the estimated monetary
value of emissions reductions. When those emissions reductions are
included--representing $2.48 billion in climate benefits (associated
with the average SC-GHG at a 2-percent near-term Ramsey discount rate
using the 2023 SC-GHG estimates) or $0.62 billion in climate benefits
(associated with the average SC-GHG at a 3-percent discount rate using
the 2021 interim SC-GHG estimates), and $1.23 billion (using a 3-
percent discount rate) or $0.53 billion (using a 7-percent discount
rate) in health benefits--the rationale becomes stronger still.
Therefore, based on the previous considerations, DOE adopts the
energy conservation standards for walk-in non-display doors at TSL 1.
The amended energy conservation standards for walk-in non-display
doors, which are expressed as kWh/year, are shown in Table V.118.
BILLING CODE 6410-01-P
[[Page 104836]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.210
c. Panels
The efficiency levels contained in each TSL are shown in Table
V.119 and described in section IV.E.1 of this document. Table V.120 and
Table V.121 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 (2028-2057). The
energy savings, emissions reductions, and value of emissions reductions
refer to full-fuel-cycle results.
[GRAPHIC] [TIFF OMITTED] TR23DE24.211
[[Page 104837]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.212
[[Page 104838]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.213
[GRAPHIC] [TIFF OMITTED] TR23DE24.214
BILLING CODE 6410-01-C
For walk-in panels, DOE first considered TSL 3, which represents
the max-tech efficiency levels. At this level, DOE expects that
manufacturers would likely need to increase insulation thickness to 6
inches for all panel equipment classes.
TSL 3 would save an estimated 0.58 quads of energy, an amount DOE
considers significant. Under TSL 3, the NPV of consumer benefit would
be
[[Page 104839]]
-$2.41 billion using a discount rate of 7 percent, and -$3.88 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 10.46 million Mt
of CO2, 3.20 thousand tons of SO2, 19.53 thousand
tons of NOX, 0.02 tons of Hg, 88.44 thousand tons of
CH4, and 0.10 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions at
TSL 3 is $2.46 billion (associated with the average SC-GHG at a 2-
percent near-term Ramsey discount rate using the 2023 SC-GHG estimates)
or $0.61 billion (associated with the average SC-GHG at a 3-percent
discount rate using the 2021 interim SC-GHG estimates). The estimated
monetary value of the health benefits from reduced SO2 and
NOX emissions at TSL 3 is $0.49 billion using a 7-percent
discount rate and $1.20 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated total NPV at TSL 3 is $0.54 billion (using
the 2023 SC-GHG estimates) or -$1.31 billion (using the 2021 interim
SC-GHG estimates). Using a 3-percent discount rate for consumer
benefits and costs and health benefits from reduced NOX and
SO2 emissions, and either the 2-percent near-term Ramsey
discount rate case or the 3-percent discount rate case for climate
benefits from reduced GHG emissions, the estimated total NPV at TSL 3
is $0.54 billion (using the 2023 SC-GHG estimates) or -$1.31 billion
(using the 2021 interim SC-GHG estimates). The estimated total NPV is
provided for additional information; however, DOE primarily relies upon
the NPV of consumer benefits when determining whether a standard level
is economically justified.
At TSL 3, when used in conjunction with a TSL 2 refrigeration
system, the average per square foot LCC impact ranges from a savings of
-$2.37 for medium-temperature structural panels (PS.M), to -$0.24 for
low-temperature structural panels (PS.L). The simple payback period
ranges from 9.4 years for low-temperature structural panels (PS.L) to
36.4 years payback period for medium-temperature structural panels
(PS.M). The fraction of consumers experiencing a net LCC cost ranges
from 70 percent for low-temperature structural panels (PS.L) to 100
percent for medium-temperature structural panels (PS.M).
At TSL 3, the projected change in INPV ranges from a decrease of
$255.5 million to a decrease of $145.5 million, which corresponds to
decreases of 27.6 percent and 15.7 percent, respectively. DOE estimates
that industry must invest $312.7 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 8.1 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 43 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 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 equipment
meeting the efficiency levels required at this TSL, including most
small businesses. A majority of panel consumers would experience a net
cost ranging from 83 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 27.6 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 concluded that TSL 3 is not economically justified.
As discussed in section IV.E.1 of this document, DOE did not
incorporate the other analyzed efficiency levels above baseline into
TSL 2 or TSL 1 since the other analyzed efficiency levels do not yield
positive consumer benefits for any of the panel equipment classes (see
appendix 8C of the final rule TSD). Absent positive consumer benefits,
it is unlikely DOE will determine that there is a sufficient economic
basis to support amended standard levels. Here, DOE has determined
there is no combination of energy efficiency improvements for display-
doors that is economically justified. Therefore, based on the previous
considerations, the Secretary is not amending energy conservation
standards for walk-in panels at this time.
d. Combined Benefits of Amended Standards
For the final rule efficiency levels for refrigeration systems,
shown in Table V.111; and non-display doors, shown in Table V.118 the
combined quantitative impacts estimates are shown in Table V.122. 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, which is 2028-2057 for non-display doors, and
2029-2058 for refrigeration systems. The energy savings, emissions
reductions, and value of emissions reductions refer to full-fuel-cycle
results.
BILLING CODE 6410-01-P
[[Page 104840]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.215
[[Page 104841]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.216
2. Annualized Benefits and Costs of the Adopted Standards
The benefits and costs of the adopted standards can also be
expressed in terms of annualized values. The annualized net benefit is
(1) the annualized national economic value (expressed in 2023$) of the
benefits from operating products that meet the adopted 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.
a. Non-Display Doors
Table V.123 presents the total estimated monetized benefits and
costs associated with the adopted standard for walk-in non-display
doors, 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards adopted in this rule
is $31.2 million per year in increased equipment costs, while the
estimated annual benefits are $123.4 million in reduced equipment
operating costs, $117.3 million in climate benefits (using the 2023 SC-
GHG estimates) or $34.8 million in climate benefits (using the 2021
interim SC-GHG estimates), and $52.0 million in health benefits. In
this case, the net benefit would amount to $261.5 million per year
(using the 2023 SC-GHG estimates) or $179.0 million per year (using the
2021 interim SC-GHG estimates).
Using a 3-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards is $32.0 million per
year in increased equipment costs, while the estimated annual benefits
are $147.9 million in reduced operating costs, $117.3 million in
climate benefits (using the 2023 SC-GHG estimates) or $34.8 million in
climate benefits (using the 2021 interim SC-GHG estimates), and $68.8
million in health benefits. In this case, the net benefit would amount
to $302.0 million per year (using the 2023 SC-GHG estimates) or $219.5
million per year (using the 2021 interim SC-GHG estimates).
[[Page 104842]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.217
[[Page 104843]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.218
b. Refrigeration Systems
Table V.124 presents the total estimated monetized benefits and
costs associated with the adopted standard for walk-in refrigeration
systems, 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards adopted in this rule
is $67.9 million per year in increased equipment costs, while the
estimated annual benefits are $180.9 million in reduced equipment
operating costs, $209.2 million in climate benefits (using the 2023 SC-
GHG estimates) or $61.7 million in climate benefits (using the 2021
interim SC-GHG estimates), and $89.0 million in health benefits. In
this case, the net benefit would amount to $411.2 million per year
(using the 2023 SC-GHG estimates) or $263.7 million per year (using the
2021 interim SC-GHG estimates).
Using a 3-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards is $61.7 million per
year in increased equipment costs, while the estimated annual benefits
are $222.0 million in reduced operating costs, $209.2 million in
climate benefits (using the 2023 SC-GHG estimates) or $61.7 million in
climate benefits (using the 2021 interim SC-GHG estimates), and $165
million in health benefits. In this case, the net benefit would amount
to $482.5 million per year (using the 2023 SC-GHG estimates) or $335.1
million per year (using the 2021 interim SC-GHG estimates).
[[Page 104844]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.219
[[Page 104845]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.220
c. Amended Standards
Table V.125 presents the total estimated monetized benefits and
costs associated with the adopted standard for walk-in non-display
doors (TSL 1) and refrigeration systems (TSL 2), expressed 2023$ 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 either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards adopted in this rule
is $99.1 million per year in increased equipment costs, while the
estimated annual benefits are $304.4 million in reduced equipment
operating costs, $326.5 million in climate benefits (using the 2023 SC-
GHG estimates) or $96.5 million in climate benefits (using the 2021
estimates of the SC-GHG), and $136 million in health benefits. In this
case, the net benefit would amount to $672.7 million per year (using
the 2023 SC-GHG estimates) or $442.7 million per year (using the 2021
estimates of the SC-GHG).
Using a 3-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and either the 2-percent near-term Ramsey discount rate case
or the 3-percent discount rate case for climate benefits from reduced
GHG emissions, the estimated cost of the standards is $101.2 million
per year in increased equipment costs, while the estimated annual
benefits are $369.8 million in reduced operating costs, $326.5 million
in climate benefits (using the 2023 SC-GHG estimates) or $96.5 million
in climate benefits (using the 2021 estimates of the SC-GHG), and
$189.4 million in health benefits. In this case, the net benefit would
amount to $784.5 million per year (using the 2023 SC-GHG estimates) or
$554.5 million per year (using the 2021 estimates of the SC-GHG).
[[Page 104846]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.221
[[Page 104847]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.222
BILLING CODE 6410-01-C
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
[[Page 104848]]
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, OIRA in 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 final
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, as amended by E.O. 14094. 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'')
and a final regulatory flexibility analysis (``FRFA'') 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 available on the Office of the General Counsel's website
(www.energy.gov/gc/office-general-counsel). DOE has prepared the
following FRFA for the equipment 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. Need for, and Objectives of, 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))
2. Significant Issues Raised by Public Comments in Response to the IRFA
In response to the September 2023 NOPR, AHRI commented that it
could not provide market share on its members or distinguish whether
any are classified as small businesses. (AHRI, No. 72 at p. 17) An
anonymous commenter recommended special accommodations be given for
small businesses. (Anonymous, No. 57 at p. 1)
DOE acknowledges that it can be challenging to identify small
business manufacturers. DOE reviews a range of sources to identify
small businesses potentially subject to this rulemaking, as detailed in
the following section VI.B.3 of this document. Regarding special
accommodations for small businesses, DOE discusses additional
compliance flexibilities in section VI.B.5 of this document.
3. Description and Estimated Number of Small Entities Affected
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'') \148\ and supplemented the
information in CCD with information from the California Energy
Commission's Modernized Appliance Efficiency Database System (for
refrigeration systems),\149\ 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 ImportYeti
\150\), and basic model numbers, to identify 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) to determine company, location, head count, 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.
---------------------------------------------------------------------------
\148\ DOE's Compliance Certification Database is available at
www.regulations.doe.gov/certification-data/#q=Product_Group_s%3A*
(last accessed Jan. 26, 2024).
\149\ The California Energy Commission's Modernized Appliance
Efficiency Database System is available at
cacertappliances.energy.ca.gov/Pages/Search/AdvancedSearch.aspx
(last accessed Jan. 18, 2024).
\150\ ImportYeti, LLC. ImportYeti is available at:
www.importyeti.com (last accessed April 1, 2024).
---------------------------------------------------------------------------
Using these data sources, DOE identified 87 OEMs of WICFs that
could be potentially affected by this rulemaking. Of these 87 OEMs, 61
are small, domestic manufacturers. DOE notes that some manufacturers
may produce more than one of the principal
[[Page 104849]]
components of WICFs: doors, panels, and refrigeration systems. Of these
small, domestic OEMs, 49 manufacture doors; 38 manufacture panels; and
15 manufacture refrigeration systems.
4. Description of Reporting, Recordkeeping, and Other Compliance
Requirements
a. Doors
In this final rule, DOE is not amending energy conservation
standards for walk-in display doors. Therefore, DOE does not expect
that manufacturers of walk-in display doors, including small business
manufacturers, would be directly impacted by the efficiency levels
adopted in this final rule as the levels would remain at the current
DOE minimum efficiency.
In this final rule, DOE is amending energy conservation standards
for walk-in non-display doors. Of the 49 small, domestic OEMs of walk-
in doors, 44 manufacture non-display doors. Of these 44 small, domestic
OEMs of walk-in non-display doors, three also manufacture walk-in
refrigeration systems. Since these three small businesses would need to
meet the adopted standards for both non-display doors and refrigeration
systems, DOE presents the cumulative impacts of walk-in standards
separately in section VI.B.4.d of this document.
At TSL 1, DOE expects manufacturers would likely need to update all
non-display door designs to incorporate anti-sweat heater controls. DOE
does not expect manufacturers would need to incorporate thermally-
improved frame designs or increase insulation thickness to meet the
efficiency levels required by the adopted standard level. Therefore,
DOE does not expect industry, including small businesses, would incur
notable capital conversion costs. 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
subgroup analysis, DOE assumed that industry conversion costs would be
evenly distributed across the walk-in non-display door OEMs to avoid
underestimating the potential investments small manufacturers may incur
as a result of the adopted standard.
All 44 small, domestic OEMs of walk-in non-display doors
manufacture manual non-display doors (i.e., NM.L, NM.M). Twelve of
these 44 small businesses also manufacture motorized non-display doors
(i.e., NO.L, NO.M). DOE estimates that the 44 small businesses that
manufacture manual non-display doors may each incur $23,000 in
conversion costs and that the 12 small businesses that also manufacture
motorized doors may each incur additional conversion costs of
approximately $34,000 to meet the efficiencies required at TSL 1. DOE
did not identify any small businesses that only manufacture motorized
doors.
Based on market research tools (e.g., Dun & Bradstreet reports),
DOE estimates that the annual revenue of the small walk-in non-display
door OEMs that do not make walk-in refrigeration systems ranges from
approximately $0.3 million to approximately $217.0 million, with an
average annual revenue of $20.0 million. Conversion costs range from
$23,000 to $57,000, with average per OEM conversion costs of $33,000,
which is approximately 0.4 percent of company revenue, on average, over
the 3-year conversion period. See Table VI.1 for additional details.
[GRAPHIC] [TIFF OMITTED] TR23DE24.223
b. Panels
In this final rule, DOE is not amending 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
established in this final rule, as the levels would remain at the
current DOE minimum efficiency.
c. Refrigeration Systems
In this final rule, DOE is amending energy conservation standards
for walk-in refrigeration systems. DOE expects that at TSL 2,
manufacturers would likely need to incorporate the following design
options: all dedicated condensing system equipment classes would
generally incorporate EC condenser fan motors; all outdoor dedicated
condensing system equipment would generally incorporate self-regulating
crankcase heater controls with a temperature switch; additionally, low-
temperature outdoor dedicated condensing system equipment classes would
generally incorporate variable-speed condenser fan motors and all but
the highest capacity units would generally incorporate ambient
subcooling circuits; some medium-temperature outdoor dedicated
condensing unit equipment classes would incorporate improved single-
speed compressors; low-temperature and indoor medium-temperature
dedicated condensing unit equipment classes would generally incorporate
larger condenser coils; low- and medium-temperature single-packaged
dedicated system equipment classes would generally incorporate larger
evaporator coils and variable speed evaporator fans; lower-capacity
low- and medium-temperature single-packaged dedicated condensing units
would generally incorporate propane compressors; higher capacity indoor
low-temperature single-packaged dedicated system equipment classes
would generally incorporate thermal insulation up to 4 inches in
thickness; outdoor medium-temperature single-packaged dedicated system
equipment classes would generally incorporate variable speed condenser
fans; lower capacity outdoor medium-temperature single-packaged
dedicated system equipment classes would generally incorporate thermal
insulation up to 4 inches in thickness and ambient
[[Page 104850]]
subcooling circuits; high-temperature indoor, and outdoor ducted,
dedicated condensing system equipment classes would generally
incorporate max-tech design options; finally high-temperature outdoor
non-ducted dedicated condensing system equipment classes would
generally incorporate thermal insulation up to 1.5 inches in thickness
and 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, and higher-capacity medium-temperature unit coolers, which
would generally only require 3-row deep evaporator coils.
Of the 15 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), five OEMs only
manufacture low- and medium-temperature dedicated condensing systems,
two OEMs only manufacture low- and medium-temperature unit coolers, and
the remaining three OEMs manufacture low- and medium-temperature
dedicated condensing systems and unit coolers. As discussed in section
VI.B.4.a of this document, three of these 15 small, domestic OEMs also
manufacture walk-in non-display doors. Since these three small
businesses would need to meet the adopted standards for both non-
display doors and refrigeration systems, DOE presents the cumulative
impacts of walk-in standards separately in section VI.B.4.d of this
document.
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 final rule. For the remaining ten 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
subgroup analysis, 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 adopted standard. DOE
believes this conservative approach represents an upper bound of
potential small business investments. DOE's capital 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 walk-in refrigeration system
OEMs that do not make walk-in non-display doors ranges from
approximately $3.7 million to approximately $209.8 million, with an
average annual revenue of $77.1 million. The conversion costs range
from $0.5 million to $4.9 million, with average per OEM conversion
costs of $2.2 million, which are approximately 2.3 percent of company
revenue, on average, over the 4-year conversion period. See Table VI.2
for additional details.
BILLING CODE 6410-01-P
[GRAPHIC] [TIFF OMITTED] TR23DE24.224
d. Doors and Refrigeration Systems
As previously discussed, DOE identified three small businesses that
manufacture both non-display doors and refrigeration systems subject to
more stringent standards. To better reflect the overall impact of this
final rule on these three small businesses, DOE presents the estimated
conversion costs to comply with the adopted standards for both non-
display doors and refrigeration systems in Table VI.3.
[[Page 104851]]
[GRAPHIC] [TIFF OMITTED] TR23DE24.225
BILLING CODE 6410-01-C
5. Significant Alternatives Considered and Steps Taken To Minimize
Significant Economic Impacts on Small Entities
The discussion in the previous section analyzes impacts on small
businesses that would result from the adopted standards, represented by
TSL 1 for walk-in non-display doors and TSL 2 for walk-in refrigeration
systems. DOE is not adopting more stringent standards for display door
and panel equipment classes in this final rule. In reviewing
alternatives to the adopted standards, DOE examined energy conservation
standards set at lower efficiency levels for walk-in refrigeration
systems. While TSL 1 would reduce the impacts on small business
manufacturers of refrigeration systems, it would come at the expense of
a reduction in energy savings. For walk-in refrigeration systems, TSL 1
achieves 42.1 percent lower energy savings compared to the energy
savings at TSL 2.
Based on the presented discussion, establishing standards at TSL 1
for walk-in non-display doors and TSL 2 refrigeration systems balances
the benefits of the energy savings at TSL 1 (non-display doors) and TSL
2 (refrigeration systems) with the potential burdens placed on walk-in
manufacturers, including small business manufacturers. Accordingly, DOE
is not adopting one of the other TSLs considered in the analysis, or
the other policy alternatives examined as part of the RIA and included
in chapter 17 of the final rule TSD.
Additionally, DOE notes that statutory provisions under EPCA state
that should the Secretary determine that a 3-year period is inadequate,
the Secretary may establish an effective date for WICFs manufactured
beginning on the date that is not more than 5 years after the date of
publication of a final rule for WICFs. (See 42 U.S.C.
6313(f)(5)(B)(ii)) Pursuant to this EPCA provision, DOE is extending
the compliance period for WICF refrigeration systems so that compliance
is required December 31, 2028, approximately 1 year later than the
expected compliance year (2027) analyzed in the September 2023 NOPR
(which was based on a 3-year compliance period). DOE has determined
that a longer compliance period for WICF refrigeration systems is
warranted based on based on stakeholder comments and DOE's assessment
of the investments and redesign required to meet the adopted levels,
combined with the impact of overlapping Federal refrigerant
regulations. DOE understands that the longer compliance period will
help mitigate cumulative regulatory burden by allowing manufacturers of
WICF refrigeration systems, including small businesses, more
flexibility to spread investments across approximately 4 years instead
of 3 years. Manufacturers, including small businesses, will also have
more time to recoup any investments made to redesign walk-in equipment
for the October 2023 EPA Technology Transitions Final Rule as compared
to a 3-year compliance period.
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
Manufacturers of walk-ins 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.
Although DOE is adopting amended standards in terms of a new metric
for walk-in refrigeration systems, DOE is not amending certification or
reporting requirements for walk-in refrigeration systems in this final
rule. Instead, if determined to be necessary, DOE may consider
proposals to amend its certification requirements and reporting for
walk-in refrigeration systems under a separate rulemaking regarding
appliance and equipment certification. DOE will address changes to OMB
[[Page 104852]]
Control Number 1910-1400 at that time, as necessary.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act of 1969
(``NEPA''), DOE has analyzed this rule in accordance with NEPA and
DOE's NEPA implementing regulations (10 CFR part 1021). DOE has
determined that this rule qualifies for categorical exclusion under 10
CFR part 1021, subpart D, appendix B5.1 because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, none of the exceptions identified in B5.1(b)
apply, no extraordinary circumstances exist that require further
environmental analysis, and it meets the requirements for application
of a categorical exclusion. See 10 CFR 1021.410. Therefore, DOE has
determined that promulgation of this rule is not a major Federal action
significantly affecting the quality of the human environment within the
meaning of NEPA, and does not require an environmental assessment or an
environmental impact statement.
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 rule and has 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 final 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.
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 E.O. 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 final 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, sec. 201 (codified at 2 U.S.C. 1531).
For a 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 1 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)) 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 ``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 final 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 proposed rule or policy that may affect
family well-being. When developing a Family Policymaking Assessment,
agencies must assess whether: (1) the action strengthens or erodes the
stability or safety of the family and, particularly, the marital
commitment; (2) the action strengthens or erodes the authority and
rights of parents in the education, nurture, and supervision of their
children; (3) the action helps the family perform its functions, or
substitutes governmental activity for the function; (4) the action
increases or decreases disposable income or poverty of families and
children; (5) the proposed benefits of the action justify the financial
impact on the family; (6) the action may be carried out by State or
local government or by the family; and whether (7) the action
establishes an implicit or explicit policy concerning the relationship
between the behavior and personal responsibility of youth, and the
norms of society.
DOE has considered how the benefits of this final rule compare to
the possible financial impact on a family (the only factor listed that
is relevant to this rule). As part of its rulemaking process, DOE must
determine whether the energy conservation standards enacted in this
final rule are economically justified. As discussed in section V.C.1 of
this document, DOE has determined that the standards enacted in this
final rule are economically justified because the
[[Page 104853]]
benefits to consumers would far outweigh the costs to manufacturers.
Families will also see LCC savings as a result of this final rule.
Moreover, as discussed further in section V.B.1 of this document, DOE
has determined that for small businesses, average LCC savings and PBP
at the considered efficiency levels are improved (i.e., higher LCC
savings and lower PBP) as compared to the average for all households.
Further, the standards will also result in climate and health benefits
for families.
I. Review Under Executive Order 12630
Pursuant to E.O. 12630, ``Governmental Actions and Interference
with Constitutionally Protected Property Rights,'' 53 FR 8859 (March
18, 1988), DOE has determined that this 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 final rule under the OMB and DOE guidelines and has
concluded that it is consistent with applicable policies in those
guidelines.
K. Review Under Executive Order 13211
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 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 is likely to have a
significant adverse effect on the supply, distribution, or use of
energy; or (2) is designated by the Administrator of OIRA as a
significant energy action. For any 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 concluded that this regulatory action, which sets forth
amended energy conservation standards for walk-ins, is not a
significant energy action because the 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 final rule.
L. Information Quality
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy, 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 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 prepared a report describing that peer
review.\151\ 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 DOE's analyses. DOE is in the
process of evaluating the resulting report.\152\
---------------------------------------------------------------------------
\151\ 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 May 31, 2024).
\152\ The report is available at www.nationalacademies.org/our-work/review-of-methods-for-setting-building-and-equipment-performance-standards.
---------------------------------------------------------------------------
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of this rule prior to its effective date. The Office of
Information and Regulatory Affairs has determined that this final rule
meets the criteria set forth in 5 U.S.C. 804(2).
VII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this final
rule.
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 November
27, 2024, by Jeffrey Marootian, Principal Deputy 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 December 2, 2024.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
For the reasons set forth in the preamble, DOE amends part 431 of
chapter II, subchapter D, of title 10 of the Code of Federal
Regulations, as set forth below:
[[Page 104854]]
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. (1) All walk-in
cooler and walk-in freezer non-display doors manufactured starting on
June 5, 2017, and before December 23, 2027, must satisfy the following
standards:
Table 2 to Paragraph (d)(1)
------------------------------------------------------------------------
Equations for maximum energy
Equipment class consumption (kWh/day) *
------------------------------------------------------------------------
Passage Door, Medium-Temperature....... 0.05 And + 1.7.
Passage Door, Low-Temperature.......... 0.14 And + 4.8.
Freight Door, Medium-Temperature....... 0.04 And + 1.9.
Freight Door, Low-Temperature.......... 0.12 And + 5.6.
------------------------------------------------------------------------
* And represents the surface area of the non-display door.
(2) All walk-in cooler and walk-in freezer non-display doors
manufactured starting on December 23, 2027, must satisfy the following
standards:
Table 3 to Paragraph (d)(2)
------------------------------------------------------------------------
Maximum daily energy consumption
Equipment class (kWh/day)
------------------------------------------------------------------------
Non-Display Door, Manual, Medium- 0.02 x And + 0.58 + 0.33 x a + 0.07
Temperature. x b + 0.24 x c + e.
Non-Display Door, Manual, Low- 0.10 x And + 2.63 + 0.40 x a + 0.09
Temperature. x b + 0.30 x c + 0.85 x d + f.
Non-Display Door, Motorized, 0.02 x And + 0.77 + 0.33 x a + 0.07
Medium-Temperature. x b + 0.24 x c + e.
Non-Display Door, Motorized, Low- 0.09 x And + 2.88 + 0.40 x a + 0.09
Temperature. x b + 0.30 x c + 0.85 x d + f.
------------------------------------------------------------------------
And represents the surface area of the non-display door in square feet.
a = 1 for a door with lighting and = 0 for a door without lighting.
b = 1 for a door with a digital temperature display without alarms and =
0 for a door without a digital display without alarms.
c = 1 for a door with a digital temperature display with alarms and = 0
for a door without a digital temperature display with alarms.
d = 1 for a door with a heated pressure relief vent and = 0 for a door
without a heated pressure relief vent.
e = 0.06 x Awindow + 0.10, with a maximum value of 0.25 for a door with
a heated viewport window, and = 0 for a door without a heated viewport
window.
f = 0.54 x Awindow + 0.23, with a maximum value of 1.50 for a door with
a heated viewport window, and = 0 for a door without a heated viewport
window.
Awindow represents the surface area of the viewing window in square
feet.
(e) Walk-in cooler refrigeration systems. (1) All walk-in cooler
and walk-in freezer refrigeration systems manufactured starting on the
dates listed in the table and before December 31, 2028, except for
walk-in process cooling refrigeration systems (as defined in Sec.
431.302), must satisfy the following standards:
Table 4 to Paragraph (e)(1)
------------------------------------------------------------------------
Compliance date:
Minimum AWEF (Btu/ equipment
Equipment class W-h) * manufactured
starting on . . .
------------------------------------------------------------------------
Dedicated Condensing System-- 5.61.............. June 5, 2017.
Medium-Temperature, Indoor.
Dedicated Condensing System-- 7.60.............. ..................
Medium-Temperature, Outdoor.
Dedicated Condensing System--Low-
Temperature, Indoor with a Net
Capacity (qnet) of:
<6,500 Btu/h................ 9.091 x -\5\ x July 10, 2020.
qnet + 1.81.
>=6,500 Btu/h............... 2.40.............. ..................
Dedicated Condensing System--Low-
Temperature, 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-Temperature. 9.00.............. ..................
Unit Cooler--Low-Temperature
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.
(2) All walk-in cooler and walk-in freezer refrigeration systems
manufactured starting on December 31, 2028, except for walk-in process
cooling refrigeration systems (as defined in Sec. 431.302), must
satisfy the following standards:
[[Page 104855]]
Table 5 to Paragraph (e)(2)
------------------------------------------------------------------------
Net capacity Minimum AWEF2 *
Equipment class (qnet) * Btu/W-h
------------------------------------------------------------------------
Dedicated Condensing System-- <7,000 Btu/h...... 7.55 x 10-\4\ x
High-Temperature, Indoor, Non- >=7,000 Btu/h..... qnet + 2.37.
Ducted. 7.66.
Dedicated Condensing System-- <7,000 Btu/h...... 1.02 x 10-\3\ x
High-Temperature, Outdoor, Non- >=7,000 Btu/h..... qnet + 2.40.
Ducted. 9.55.
Dedicated Condensing System-- <7,000 Btu/h...... 2.46 x 10-\4\ x
High-Temperature, Indoor, >=7,000 Btu/h..... qnet + 1.55.
Ducted. 3.27.
Dedicated Condensing System-- <7,000 Btu/h...... 3.60 x 10-\4\ x
High-Temperature, Outdoor, >=7,000 Btu/h..... qnet + 1.88.
Ducted. 4.39.
Dedicated Condensing System <8,000 Btu/h...... 5.61
other than Single-Packaged-- >=8,000 Btu/h and 3.35 x 10-\5\ x
Medium-Temperature, Indoor. <25,000 Btu/h. qnet + 5.34.
>=25,000 Btu/h.... 6.18.
Dedicated Condensing System <25,000 Btu/h..... 1.61 x 10-\5\ x
other than Single-Packaged-- >=25,000 Btu/h and qnet + 7.26
Medium-Temperature, Outdoor. <54,000 Btu/h. 7.59 x 10-\6\ x
>=54,000 Btu/h.... qnet + 7.47.
7.88.
Dedicated Condensing System <9,000 Btu/h...... 4.64 x 10-\5\ x
other than Single-Packaged--Low- >=9,000 Btu/h and qnet + 2.18
Temperature, Indoor. <25,000 Btu/h. 2.52 x 10-\5\ x
>=25,000 Btu/h and qnet + 2.37
<54,000 Btu/h. 1.45 x 10-\6\ x
>=54,000 Btu/h.... qnet + 2.96.
3.04.
Dedicated Condensing System <9,000 Btu/h...... 9.93 x 10-\5\ x
other than Single-Packaged--Low- >=9,000 Btu/h and qnet + 2.62
Temperature, Outdoor. <25,000 Btu/h. 3.14 x 10-\5\ x
>=25,000 Btu/h and qnet + 3.23
<75,000 Btu/h. 4.72 x 10-\6\ x
>=75,000 Btu/h.... qnet + 3.90.
4.25.
Single-Packaged Dedicated <9,000 Btu/h...... 1.00 x 10-\4\ x
Condensing System--Medium- >=9,000 Btu/h..... qnet + 4.91.
Temperature, Indoor. 5.81.
Single-Packaged Dedicated <9,000 Btu/h...... 3.07 x 10-\4\ x
Condensing System--Medium- >=9,000 Btu/h..... qnet + 4.73.
Temperature, Outdoor. 7.49.
Single-Packaged Dedicated <6,000 Btu/h...... 8.00 x 10-\5\ x
Condensing System--Low- >=6,000 Btu/h..... qnet + 1.80.
Temperature, Indoor. 2.28.
Single-Packaged Dedicated <6,000 Btu/h...... 1.39 x 10-\4\ x
Condensing System--Low- >=6,000 Btu/h..... qnet + 1.95.
Temperature, Outdoor. 2.78.
Unit Cooler--High-Temperature <9,000 Btu/h...... 10.33
Non-Ducted. >=9,000 Btu/h and 3.83 x 10-\4\ x
<25,000 Btu/h. qnet + 6.89.
>=25,000 Btu/h.... 16.45.
Unit Cooler--High-Temperature <9,000 Btu/h...... 6.64
Ducted. >=9,000 Btu/h and 3.70 x 10-\4\ x
<25,000 Btu/h. qnet + 3.31.
>=25,000 Btu/h.... 12.57.
Unit Cooler--Medium-Temperature. <54,000 Btu/h..... 9.65
>=54,000 Btu/h and -3.10 x 10-\5\ x
<75,000 Btu/h. qnet + 11.32.
>=75,000 Btu/h.... 9.00.
Unit Cooler--Low-Temperature.... All............... 4.57.
------------------------------------------------------------------------
* Where qnet is net capacity as determined in accordance with Sec.
431.304 and certified in accordance with 10 CFR part 429.
Note: The following appendix will not appear in the Code of
Federal Regulations.
Appendix A
September 13, 2024
Ami Grace-Tardy
Assistant General Counsel for Legislation,
Regulation and Energy Efficiency
U.S. Department of Energy
Washington, DC 20585
[email protected]
Re: Energy Conservation Program: Standards for Walk-In Coolers and
Freezers DOE Docket No. EERE-2017-BT-STD-0009
Dear Assistant General Counsel Grace-Tardy:
I am responding to your July 15, 2024, letter seeking the views
of the Attorney General about the potential impact on competition of
proposed energy conservation standards for walk-in coolers and
freezers.
Your request was submitted under Section 325(o)(2)(B)(i)(V) of
the Energy Policy and Conservation Act, as amended (ECPA), 42 U.S.C.
6295(o)(2)(B)(i)(V), which requires the Attorney General to make a
determination of the impact of any lessening of competition that is
likely to result from the imposition of proposed energy conservation
standards. The Attorney General's responsibility for responding to
requests from other departments about the effect of a program on
competition has been delegated to the Assistant Attorney General for
the Antitrust Division in 28 CFR 0.40(g). The Assistant Attorney
General for the Antitrust Division has authorized me, as the Policy
Director for the Antitrust Division, to provide the Antitrust
Division's views regarding the potential impact on competition of
proposed energy conservation standards on his behalf.
In conducting its analysis, the Antitrust Division examines
whether a proposed standard may lessen competition, for example, by
substantially limiting consumer choice, by placing certain
manufacturers at an unjustified competitive disadvantage, or by 2
inducing avoidable inefficiencies in production or distribution of
particular products. A lessening of competition could result in
higher prices to manufacturers and consumers.
We have reviewed the proposed standards contained in the Notice
of Proposed Rulemaking (88 FR 60746, September 5, 2023), the
Proposed Rules (88 FR 66710, September 28, 2023), and the related
Technical Support Documents (TSD) that accompanied them. We have
also reviewed the Docket and public comments filed in response to
the related Request for Information.
Based on this review, our conclusion is that the proposed energy
conservation standards for walk-in coolers and freezers are unlikely
to have a significant adverse impact on competition.
Sincerely,
David G.B. Lawrence.
Policy Director.
[FR Doc. 2024-28474 Filed 12-20-24; 8:45 am]
BILLING CODE 6450-01-P