Energy Conservation Program: Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers

Federal RegisterFeb 27, 2023

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DEPARTMENT OF ENERGY

10 CFR Part 430

[EERE-2017-BT-STD-0003]

RIN 1904-AD80

Energy Conservation Program: Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Notice of proposed rulemaking and announcement of public meeting.

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 refrigerators, refrigerator-freezers, and freezers. EPCA also requires the U.S. Department of Energy (“DOE” or “the Department”) to periodically determine whether more stringent standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking (“NOPR”), DOE proposes amended energy conservation standards for refrigerators, refrigerator-freezers, and freezers, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.

DATES:

Comments:

DOE will accept comments, data, and information regarding this NOPR no later than April 28, 2023.

Meeting:

DOE will hold a public meeting via webinar on Tuesday, April 11, 2023, from 1:00 p.m. to 4:00 p.m., in Washington, DC. See section VII, “Public Participation,” for webinar registration information, participant instructions and information about the capabilities available to webinar participants. Comments regarding the likely competitive impact of the proposed standard should be sent to the Department of Justice contact listed in the

ADDRESSES

section on or before March 29, 2023.

ADDRESSES:

Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at

www.regulations.gov,

under by docket number EERE-2017-BT-STD-0003. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, identified by docket number EERE-2017-BT-STD-0003, by any of the following methods:

Email: ConsumerRefrigFreezer2017STD0003@ee.doe.gov.

Include the docket number EERE-2017-BT-STD-0003 in the subject line of the message.

Postal Mail:

Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 287-1445. If possible, please submit all items on a compact disc (“CD”), in which case it is not necessary to include printed copies.

Hand Delivery/Courier:

Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, 950 L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202) 287-1445. If possible, please submit all items on a CD, in which case it is not necessary to include printed copies.

No telefacsimiles (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on this process, see section VII of this document.

Docket:

The docket for this activity, which includes

Federal Register

notices, comments, and other supporting documents/materials, is available for review at

www.regulations.gov.

All documents in the docket are listed in the

www.regulations.gov

index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.

The docket web page can be found at

www.regulations.gov/docket/EERE-2017-BT-STD-0003.

The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section VII of this document for information on how to submit comments through

www.regulations.gov.

EPCA requires the Attorney General to provide DOE a written determination of whether the proposed standard is likely to lessen competition. The U.S. Department of Justice Antitrust Division invites input from market participants and other interested persons with views on the likely competitive impact of the proposed standard. Interested persons may contact the Division at

energy.standards@usdoj.gov

on or before the date specified in the

DATES

section. Please indicate in the “Subject” line of your email the title and Docket Number of this proposed rule.

FOR FURTHER INFORMATION CONTACT:

Mr. Lucas Adin, 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: (202) 287-5904. Email:

ApplianceStandardsQuestions@ee.doe.gov.

Mr. Matthew Schneider, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (240) 597-6265. Email:

matthew.schneider@hq.doe.gov.

For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:

ApplianceStandardsQuestions@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Synopsis of the Proposed Rule

1. Benefits and Costs to Consumers

2. Impact on Manufacturers

3. National Benefits and Costs

4. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Consumer Refrigerators, Refrigerator-Freezers, and Freezers

3. Test Procedure

C. Deviation From Appendix A

III. General Discussion

A. Product Classes and Scope of Coverage

B. Test Procedure

C. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

D. Energy Savings

1. Determination of Savings

2. Significance of Savings

E. 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. Scope of Coverage and Product Classes

2. Technology Options

B. Screening Analysis

1. Screened-Out Technologies

2. Remaining Technologies

C. Engineering Analysis

1. Efficiency Analysis

a. Built-In Products

b. Representativeness of Reverse-Engineered and Analyzed Products

c. Baseline Efficiency/Energy Use

d. Higher Efficiency Levels

e. VIP Analysis and Max-Tech Levels

2. Cost Analysis

3. Cost-Efficiency Results

4. Manufacturer Selling Price

D. Markups Analysis

E. Energy Use Analysis

F. Life-Cycle Cost and Payback Period Analysis

1. Adjusted Volume Distribution

2. Product Cost

3. Installation Cost

4. Annual Energy Consumption

5. Energy Prices

6. Maintenance and Repair Costs

7. Product Lifetime

8. Discount Rates

9. Energy Efficiency Distribution in the No-New-Standards Case

10. Payback Period Analysis

G. Shipments Analysis

H. National Impact Analysis

1. Product Efficiency Trends

2. National Energy Savings

3. Net Present Value Analysis

I. Consumer Subgroup Analysis

J. Manufacturer Impact Analysis

1. Overview

2. Government Regulatory Impact Model and Key Inputs

a. Manufacturer Production Costs

b. Shipments Projections

c. Product and Capital Conversion Costs

d. Manufacturer Markup Scenarios

3. Manufacturer Interviews

a. Specialty Doors and Multiple Door Designs

b. Viability of Low-Cost Standard-Size Refrigerator-Freezers

c. Built-In Product Classes

d. Supply Chain Constraints

4. Discussion of MIA Comments

K. Emissions Analysis

1. Air Quality Regulations Incorporated in DOE's Analysis

L. Monetizing Emissions Impacts

1. Monetization of Greenhouse Gas Emissions

a. Social Cost of Carbon

b. Social Cost of Methane and Nitrous Oxide

2. Monetization of Other Emissions Impacts

M. Utility Impact Analysis

N. Employment Impact Analysis

V. Analytical Results and Conclusions

A. Trial Standard Levels

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Consumers

a. Life-Cycle Cost and Payback Period

b. Consumer Subgroup Analysis

c. Rebuttable Presumption Payback

2. Economic Impacts on Manufacturers

a. Industry Cash Flow Analysis Results

b. Direct Impacts on Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Subgroups of Manufacturers

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Significance of Energy Savings

b. Net Present Value of Consumer Costs and Benefits

c. Indirect Impacts on Employment

4. Impact on Utility or Performance of Products

5. Impact of Any Lessening of Competition

6. Need of the Nation To Conserve Energy

7. Other Factors

8. Summary of Economic Impacts

C. Conclusion

1. Benefits and Burdens of TSLs Considered for Refrigerator, Refrigerator-Freezer, and Freezer Standards

2. Annualized Benefits and Costs of the Proposed Standards

D. Reporting, Certification, and Sampling Plan

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description of Reasons Why Action Is Being Considered

2. Objectives of, and Legal Basis for, Rule

3. Description on Estimated Number of Small Entities Regulated

4. Description and Estimate of Compliance Requirements Including Differences in Cost, if Any, for Different Groups of Small Entities

5. Duplication, Overlap, and Conflict With Other Rules and Regulations

6. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Information Quality

VII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements for Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VIII. Approval of the Office of the Secretary

I. Synopsis of the Proposed Rule

The Energy Policy and Conservation Act, Public Law 94-163, as amended (“EPCA”) ,

authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part B of EPCA

established the Energy Conservation Program for Consumer Products Other Than Automobiles. (42 U.S.C. 6291-6309) These products include refrigerators, refrigerator-freezers, and freezers, the subject of this proposed rulemaking.

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.

For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.

Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later than 6 years after issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a notice of proposed rulemaking including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6295(m))

In accordance with these and other statutory provisions discussed in this document, DOE proposes amended energy conservation standards for refrigerators, refrigerator-freezers, and freezers. The proposed standards, which are expressed in kWh/yr, are shown in Table I.1. These proposed standards, if adopted, would apply to all refrigerators, refrigerator-freezers, and freezers listed in Table I.1 manufactured in, or imported into, the United States starting on the date 3 years after the publication of the final rule for this proposed rule.

Table I.1—Proposed Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers

Product class

Equations for maximum energy use

(kWh/yr)

Based on AV

(ft

)

Based on av

(L)

1. Refrigerator-freezers and refrigerators other than all-refrigerators with manual defrost

6.79AV + 191.3

0.240av + 191.3.

1A. All-refrigerators—manual defrost

5.77AV + 164.6

0.204av + 164.6.

2. Refrigerator-freezers—partial automatic defrost

(6.79AV + 191.3)*K2

(0.240av + 191.3)*K2.

3. Refrigerator-freezers—automatic defrost with top-mounted freezer

6.86AV + 198.6 + 28I

0.242av + 198.6 + 28I.

3-BI. Built-in refrigerator-freezer—automatic defrost with top-mounted freezer

8.24AV + 238.4 + 28I

0.291av + 238.4 + 28I.

3A. All-refrigerators—automatic defrost

(6.01AV + 171.4)*K3A

(0.212av + 171.4)*K3A.

3A-BI. Built-in All-refrigerators—automatic defrost

(7.22AV + 205.7)*K3ABI

(0.255av + 205.7)*K3ABI.

4. Refrigerator-freezers—automatic defrost with side-mounted freezer

6.89AV + 241.2 + 28I

0.243av + 241.2 + 28I.

4-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer

8.79AV + 307.4 + 28I

0.310av + 307.4 + 28I.

5. Refrigerator-freezers—automatic defrost with bottom-mounted freezer

(7.61AV + 272.6)*K5 + 28I

(0.269av + 272.6)*K5 + 28I.

5-BI. Built-In Refrigerator-freezers—automatic defrost with bottom-mounted freezer

(8.65AV + 309.9)*K5BI + 28I

(0.305av + 309.9)*K5BI + 28I.

5A. Refrigerator-freezer—automatic defrost with bottom-mounted freezer with through-the-door ice service

(7.26AV + 329.2)*K5A

(0.256av + 329.2)*K5A.

5A-BI. Built-in refrigerator-freezer—automatic defrost with bottom-mounted freezer with through-the-door ice service

(8.21AV + 370.7)*K5ABI

(0.290av + 370.7)*K5ABI.

6. Refrigerator-freezers—automatic defrost with top-mounted freezer with through-the-door ice service

7.14AV + 280.0

0.252av + 280.0.

7. Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door ice service

(6.92AV + 305.2)*K7

(0.244av + 305.2)*K7.

7-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer

(8.82AV + 384.1)*K7BI

(0.311av + 384.1)*K7BI.

8. Upright freezers with manual defrost

5.57AV + 193.7

0.197av + 193.7.

9. Upright freezers with automatic defrost

7.76AV + 205.5 + 28I

0.274av + 205.5 + 28I.

9-BI. Built-In Upright freezers with automatic defrost

9.37AV + 247.9 + 28I

0.331av + 247.9 + 28I.

10. Chest freezers and all other freezers except compact freezers

7.29AV + 107.8

0.257av + 107.8.

10A. Chest freezers with automatic defrost

10.24AV + 148.1

0.362av + 148.1.

11. Compact refrigerator-freezers and refrigerators other than all-refrigerators with manual defrost

7.68AV + 214.5

0.271av + 214.5.

11A. Compact all-refrigerators—manual defrost

6.66AV + 186.2

0.235av + 186.2.

12. Compact refrigerator-freezers—partial automatic defrost

(7.68AV + 214.5)*K12

(0.271av + 214.5)*K12.

13. Compact refrigerator-freezers—automatic defrost with top-mounted freezer

10.62AV + 305.3 + 28I

0.375av + 305.3 + 28I.

13A. Compact all-refrigerators—automatic defrost

(8.25AV + 233.4)*K13A

(0.291av + 233.4)*K13A.

14. Compact refrigerator-freezers—automatic defrost with side-mounted freezer

6.14AV + 411.2 + 28I

0.217av + 411.2 + 28I.

15. Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer

10.62AV + 305.3 + 28I

0.375av + 305.3 + 28I.

16. Compact upright freezers with manual defrost

7.35AV + 191.8

0.260av + 191.8.

17. Compact upright freezers with automatic defrost

9.15AV + 316.7

0.323av + 316.7.

18. Compact chest freezers

7.86AV + 107.8

0.278av + 107.8.

AV = Total adjusted volume, expressed in ft

, as determined in appendices A and B of subpart B of 10 CFR part 430.

av = Total adjusted volume, expressed in Liters.

I = 1 for a product with an automatic icemaker and = 0 for a product without an automatic icemaker.

Door Coefficients (

e.g.,

K3A) are as defined in Table I.2.

Table I.2—Description of Door Coefficients for Proposed Maximum Energy Use Equations for Refrigerators, Refrigerator-Freezers, and Freezers

Door coefficient

Products with a

transparent door

Products without

a transparent door

with a door-in-door

Products without a transparent

door or door-in-door

with added external doors

N/A

1 + 0.02 * (N

−1).

K3A

1.10

N/A

N/A.

K3ABI

K13A

1.06

1 + 0.02 * (N

−2).

K5BI

K5A

1 + 0.02 * (Nd−3).

K5ABI

1 + 0.02 * (Nd−2).

K7BI

K12

N/A

1 + 0.02 * (N

−1).

is the number of external doors.

1. Benefits and Costs to Consumers

Table I.3 presents DOE's evaluation of the economic impacts of the proposed standards on consumers of refrigerators, refrigerator-freezers, and freezers, as measured by the average life-cycle cost (“LCC”) savings and the simple payback period (“PBP”).

The average LCC

savings are positive for all product classes for which a standard is proposed, and the PBP is less than the average lifetime of refrigerators, refrigerator-freezers, and freezers, which varies by product class (see section IV.F.7 of this document).

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).

Table I.3—Impacts of Proposed Energy Conservation Standards on Consumers of Refrigerators, Refrigerator-Freezers, and Freezers

[TSL 5]

Product class

Average LCC savings

(2021$)

Simple

payback period

(years)

PC 3

36.04

5.3

PC 5

49.73

4.8

PC 5BI

39.94

5.7

PC 5A

115.76

5.7

PC 7

101.33

5.0

PC 9

69.26

3.9

PC 10

N/A

PC 11A (residential)

9.97

2.1

PC 11A (commercial)

3.42

3.2

PC 17

21.90

5.0

PC 18

17.59

4.2

DOE's analysis of the impacts of the proposed standards on consumers is described in section IV.F of this document.

2. Impact on Manufacturers

All monetary values in this document are expressed in 2021 dollars.

The industry net present value (“INPV”) is the sum of the discounted cash flows to the industry from the NOPR publication year through the end of the analysis period (2023-2056). Using a real discount rate of 9.1 percent, DOE estimates that the INPV for manufacturers of refrigerators, refrigerator-freezers, and freezers, in the case without amended standards is $4.97 billion. Under the proposed standards, the change in INPV is estimated to range from −20.2 percent to −16.0 percent, which is approximately −$1.0 billion to −$792.8 million. In order to bring products into compliance with amended standards, it is estimated that the industry would incur total conversion costs of $1.32 billion.

DOE's analysis of the impacts of the proposed standards on manufacturers is described in section IV.J of this document. The analytic results of the manufacturer impact analysis (“MIA”) are presented in section V.B.2 of this document.

3. National Benefits and Costs

DOE's analyses indicate that the proposed energy conservation standards for refrigerators, refrigerator-freezers, and freezers would save a significant amount of energy. Relative to the case without amended standards, the lifetime energy savings for refrigerators, refrigerator-freezers, and freezers purchased in the 30-year period that begins in the anticipated year of compliance with the amended standards (2027-2056) amount to 5.3 quadrillion British thermal units (“Btu”), or quads.

This represents a savings of 12 percent relative to the energy use of these products in the case without amended standards (referred to as the “no-new-standards case”).

The quantity refers to full-fuel-cycle (“FFC”) energy savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting primary fuels (

i.e.,

coal, natural gas, petroleum fuels), and, thus, presents a more complete picture of the impacts of energy efficiency standards. For more information on the FFC metric, see section IV.H.2 of this document.

The cumulative net present value (“NPV”) of total consumer benefits of the proposed standards for refrigerators, refrigerator-freezers, and freezers ranges from $6.6 billion (at a 7-percent discount rate) to $20.4 billion (at a 3-percent discount rate). This NPV expresses the estimated total value of future operating-cost savings minus the estimated increased product costs for refrigerators, refrigerator-freezers, and freezers purchased in 2027-2056.

In addition, the proposed standards for refrigerators, refrigerator-freezers, and freezers are projected to yield significant environmental benefits. DOE estimates that the proposed standards would result in cumulative emission reductions (over the same period as for energy savings) of 179.2 million metric tons (“Mt”)

of carbon dioxide (“CO

”), 83.1 thousand tons of sulfur dioxide (“SO

”), 274.4 thousand tons of nitrogen oxides (“NO

”), 1,204.7 thousand tons of methane (“CH

”), 1.9 thousand tons of nitrous oxide (“N

O”), and 0.5 tons of mercury (“Hg”).

A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO

are presented in short tons.

DOE calculated emissions reductions relative to the no-new-standards case, which reflects key assumptions in the

Annual Energy Outlook 2022

(“

AEO2022”

AEO2022

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

AEO2022

assumptions that effect air pollutant emissions.

DOE estimates the value of climate benefits from a reduction in greenhouse gases (GHG) using four different estimates of the social cost of CO

(“SC-CO

”), the social cost of methane (“SC-CH

”), and the social cost of nitrous oxide (“SC-N

O”). Together these represent the social cost of GHG (SC-GHG).

DOE used interim SC-GHG values developed by an Interagency

Working Group on the Social Cost of Greenhouse Gases (IWG).

The derivation of these values is discussed in section IV.L of this document. For presentational purposes, the climate benefits associated with the average SC-GHG at a 3-percent discount rate are estimated to be $8.1 billion. DOE does not have a single central SC-GHG point estimate and it emphasizes the importance and value of considering the benefits calculated using all four SC-GHG estimates.

On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in

Louisiana

Biden,

No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the preliminary injunction is no longer in effect, pending resolution of the federal government's appeal of that injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in that case from “adopting, employing, treating as binding, or relying upon” the interim estimates of the social cost of greenhouse gases—which were issued by the Interagency Working Group on the Social Cost of Greenhouse Gases on February 26, 2021—to monetize the benefits of reducing greenhouse gas emissions. As reflected in this rule, DOE has reverted to its approach prior to the injunction and presents monetized greenhouse gas abatement benefits where appropriate and permissible under law.

See Interagency Working Group on Social Cost of Greenhouse Gases, Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide. Interim Estimates Under Executive Order 13990, Washington, DC, February 2021 (“February 2021 SC-GHG TSD”

). www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.

DOE estimated the monetary health benefits of SO

and NO

emissions reductions, also discussed in section IV.L of this document. DOE estimated the present value of the health benefits would be $5.3 billion using a 7-percent discount rate, and $14.2 billion using a 3-percent discount rate.

DOE is currently only monetizing (for SO

and NO

) PM

2.5

precursor health benefits and (for NO

) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM

2.5

emissions.

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.4 summarizes the economic benefits and costs expected to result from the proposed standards for refrigerators, refrigerator-freezers, and freezers. There are other important unquantified effects, including certain unquantified climate benefits, unquantified public health benefits from the reduction of toxic air pollutants and other emissions, unquantified energy security benefits, and distributional effects, among others.

Table I.4—Summary of Monetized Benefits and Costs of Proposed Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers

[TSL 5]

Billion 2021$

3% discount rate

Consumer Operating Cost Savings

32.7

Climate Benefits *

8.1

Health Benefits **

14.2

Total Benefits †

55.1

Consumer Incremental Product Costs ‡

12.3

Net Benefits

42.7

7% discount rate

Consumer Operating Cost Savings

13.6

Climate Benefits * (3% discount rate)

8.1

Health Benefits **

5.3

Total Benefits †

27.0

Consumer Incremental Product Costs

6.9

Net Benefits

20.1

Note:

This table presents the costs and benefits associated with product name shipped in 2027-2056. These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056.

* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO

), methane (SC-CH

), and nitrous oxide (SC-N

O) (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate) (see section IV.L of this document). Together these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown, but the Department does not have a single central SC-GHG point estimate. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the Federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in

Louisiana

Biden,

No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the preliminary injunction is no longer in effect, pending resolution of the Federal government's appeal of that injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in that case from “adopting, employing, treating as binding, or relying upon” the interim estimates of the social cost of greenhouse gases—which were issued by the Interagency Working Group on the Social Cost of Greenhouse Gases on February 26, 2021—to monetize the benefits of reducing greenhouse gas emissions. As reflected in this rule, DOE has reverted to its approach prior to the injunction and presents monetized greenhouse gas abatement benefits where appropriate and permissible under law.

** Health benefits are calculated using benefit-per-ton values for NO

and SO

. DOE is currently only monetizing (for SO

and NO

) PM

2.5

precursor health benefits and (for NO

) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM

2.5

emissions.

See

section IV.L of this document for more details.

† Total and net benefits include those consumer, climate, and health benefits that can be quantified and monetized. For presentation purposes, total and net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with a 3-percent discount rate, but the Department does not have a single central SC-GHG point estimate. DOE emphasizes the importance and value of considering the benefits calculated using all four SC-GHG estimates.

The benefits and costs of the proposed standards can also be expressed in terms of annualized values. The monetary values for the total annualized net benefits are (1) the reduced consumer operating costs, minus (2) the increase in product purchase prices and installation costs, plus (3) the value of climate and health benefits of emission reductions, all annualized.

To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2022, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE calculated a present value associated with each year's shipments in the year in which the shipments occur (

e.g.,

2030), and then discounted the present value from each year to 2022. 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 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 refrigerators, refrigerator-freezers, and freezers shipped in 2027-2056. The benefits associated with reduced emissions achieved as a result of the proposed standards are also calculated based on the lifetime of refrigerators, refrigerator-freezers, and freezers shipped in 2027-2056. Total benefits for both the 3-percent and 7-percent cases are presented using the average GHG social costs with a 3-percent discount rate. Estimates of SC-GHG values are presented for all four discount rates in section IV.L of this document.

Table I.5 presents the total estimated monetized benefits and costs associated with the proposed standard, expressed in terms of annualized values. The results under the primary estimate are as follows.

Using a 7-percent discount rate for consumer benefits and costs and health benefits from reduced NO

and SO

emissions, and the 3-percent discount rate case for climate benefits from reduced GHG emissions, the estimated cost of the standards proposed in this rule is $730.0 million per year in increased equipment costs, while the estimated annual monetized benefits are $1.4 billion in reduced equipment operating costs, $467.9 million in climate benefits, and $563.3 million in health benefits. In this case, the net monetized benefit would amount to $1.7 billion per year.

Using a 3-percent discount rate for all benefits and costs, the estimated cost of the proposed standards is $707.4 million per year in increased equipment costs, while the estimated annual monetized benefits are $1.9 billion in reduced operating costs, $467.9 million in climate benefits, and $815.2 million in health benefits. In this case, the net monetized benefit would amount to $2.5 billion per year.

Table I.5—Annualized Monetized Benefits and Costs of Proposed Energy Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers

[TSL 5]

Million 2021$/year

Primary

estimate

Low-net-benefits

estimate

High-net-benefits

estimate

3% discount rate

Consumer Operating Cost Savings

1,878.6

1,745.5

2,030.6

Climate Benefits *

467.9

453.4

482.4

Health Benefits **

815.2

790.3

840.1

Total Benefits †

3,161.7

2,989.3

3,353.1

Consumer Incremental Product Costs ‡

707.4

774.3

681.3

Net Benefits

2,454.3

2,215.0

2,671.9

7% discount rate

Consumer Operating Cost Savings

1,431.7

1,339.6

1,534.2

Climate Benefits * (3% discount rate)

467.9

453.4

482.4

Health Benefits **

563.3

547.4

579.1

Total Benefits †

2,462.9

2,340.4

2,595.7

Consumer Incremental Product Costs

730.0

788.4

706.3

Net Benefits

1,732.9

1,552.0

1,889.4

Note:

This table presents the costs and benefits associated with refrigerators, refrigerator-freezers, and freezers shipped in 2027-2056. These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the

AEO 2022

Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition, incremental equipment costs reflect a medium decline rate in the Primary Estimate, a low decline rate in the Low Net Benefits Estimate, and a high decline rate in the High Net Benefits Estimate. The methods used to derive projected price trends are explained in section IV.H.3 of this document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.

* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this document). For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown, but the Department does not have a single central SC-GHG point estimate, and it emphasizes the importance and value of considering the benefits calculated using all four SC-GHG estimates. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the Federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in

Louisiana

Biden,

** Health benefits are calculated using benefit-per-ton values for NO

and SO

. DOE is currently only monetizing (for SO

and NO

) PM

2.5

precursor health benefits and (for NO

) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM

2.5

emissions. The health benefits are presented at real discount rates of 3 and 7 percent. See section IV.L of this document for more details.

† Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with a 3-percent discount rate, but the Department does not have a single central SC-GHG point estimate.

DOE's analysis of the national impacts of the proposed standards is described in sections IV.H, IV.K, and IV.L of this document.

4. Conclusion

DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. Specifically, with regard to technological feasibility, products achieving these proposed standard levels are already commercially available for all covered product classes. As for economic justification, DOE's analysis shows that the benefits of the proposed standard exceed, to a great extent, the burdens of the proposed standards.

Using a 7-percent discount rate for consumer benefits and costs and NO

and SO

reduction benefits, and a 3-percent discount rate case for GHG social costs, the estimated cost of the proposed standards for refrigerators, refrigerator-freezers, and freezers is $730.0 million per year in increased product costs, while the estimated annual monetized benefits are $1.4317 billion in reduced product operating costs, $467.9 million in climate benefits and $563.3 million in health benefits. The net monetized benefit amounts to $1.7329 billion per year.

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.

For example, some covered products and equipment have substantial energy consumption occur during periods of peak energy demand. The impacts of these products on the energy infrastructure can be more pronounced than products with relatively constant demand. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis.

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 proposed standards are projected to result in estimated national energy savings of 5.3 quads (FFC), the equivalent of the electricity use of 57 million homes in one year. In addition, they are projected to reduce GHG emissions. Based on these findings, DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B). A more detailed discussion of the basis for this tentative conclusion is contained in the remainder of this document and the accompanying technical support document (“TSD”).

DOE also considered more stringent energy efficiency levels as potential standards and is still considering them in this rulemaking. However, DOE has tentatively concluded that the potential burdens of the more stringent energy efficiency levels would outweigh the projected benefits.

Based on consideration of the public comments DOE receives in response to this document and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy efficiency levels presented in this document that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.

II. Introduction

The following section briefly discusses the statutory authority underlying this proposed rule, as well as some of the relevant historical background related to the establishment of standards for refrigerators, refrigerator-freezers, and freezers.

A. Authority

EPCA authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. Title III, Part B of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles. These products include refrigerators, refrigerator-freezers, and freezers, the subject of this document. (42 U.S.C. 6292(a)(1)) EPCA prescribed initial energy conservation standards for these products (42 U.S.C. 6295(b)(1)-(2)), and directed DOE to conduct three cycles of future rulemakings during which the Department was tasked with determining whether to amend these standards. (42 U.S.C. 6295(b)(3)(A)(i), (b)(3)(B), and (b)(4)). DOE has completed these rulemakings. 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 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. 6295(m)(1))

The energy conservation program under EPCA consists essentially of four parts: (1) testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA specifically include definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293), labeling provisions (42 U.S.C. 6294), energy conservation standards (42 U.S.C. 6295), and the authority to require information and reports from manufacturers (42 U.S.C. 6296).

Federal energy efficiency requirements for covered products established under EPCA generally supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions set forth under EPCA. (See 42 U.S.C. 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 each covered product. (42 U.S.C. 6295(o)(3)(A) and 42 U.S.C. 6295(r)) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 42 U.S.C. 6295(s)) Similarly, DOE must use these test procedures to determine whether the products comply with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)). The DOE test procedures for consumer refrigerators, refrigerator-freezers, and freezers appear at 10 CFR part 430, subpart B, appendix

A, Uniform Test Method for Measuring the Energy Consumption of Refrigerators, Refrigerator-Freezers, and Miscellaneous Refrigeration Products (“appendix A”) and 10 CFR part 430, subpart B, appendix B, Uniform Test Method for Measuring the Energy Consumption of Freezers (“appendix B”).

DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including refrigerators, refrigerator-freezers, and freezers. Any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that the Secretary of Energy (“Secretary”) determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(3)(B)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3))

Moreover, DOE may not prescribe a standard: (1) for certain products, including refrigerators, refrigerator-freezers, and freezers, if no test procedure has been established for the product, or (2) if DOE determines by rule that the standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:

(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;

(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;

(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;

(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;

(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;

(6) The need for national energy and water conservation; and

(7) Other factors the Secretary of Energy (“Secretary”) considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))

Further, EPCA establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. (42 U.S.C. 6295(o)(2)(B)(iii))

EPCA also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 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. 6295(o)(4))

Additionally, EPCA specifies requirements when promulgating an energy conservation standard for a covered product that has two or more subcategories. DOE must specify a different standard level for a type or class of product that has the same function or intended use, if DOE determines that products within such group: (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE deems appropriate.

Id.

Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))

Finally, pursuant to the amendments contained in the Energy Independence and Security Act of 2007 (“EISA 2007”), Public Law 110-140, any final rule for new or amended energy conservation standards promulgated after July 1, 2010, is required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into a single standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE's current test procedures for refrigerators, refrigerator-freezers, and freezers address standby mode and off mode energy use. In this proposed rule, DOE intends to incorporate such energy use into any amended energy conservation standards that it may adopt.

B. Background

1. Current Standards

In a final rule published on September 15, 2011 (“September 2011 Final Rule”), DOE prescribed the current energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers manufactured on and after September 15, 2014. 76 FR 57516. These standards are set forth in DOE's regulations at 10 CFR 430.32(a) and are repeated in Table I.2 of this document.

Table II.1—Current Federal Energy Conservation Standards for Consumer Refrigerators, Refrigerator-Freezers, and Freezers

Product class

Equations for

maximum energy use

(kWh/yr)

Based on AV

(ft

)

Based on av

(L)

1. Refrigerator-freezers and refrigerators other than all-refrigerators with manual defrost

7.99AV + 225.0

0.282av + 225.0

1A. All-refrigerators—manual defrost

6.79AV + 193.6

0.240av + 193.6

2. Refrigerator-freezers—partial automatic defrost

7.99AV + 225.0

0.282av + 225.0

3. Refrigerator-freezers—automatic defrost with top-mounted freezer without an automatic icemaker

8.07AV + 233.7

0.285av + 233.7

3-BI. Built-in refrigerator-freezer—automatic defrost with top-mounted freezer without an automatic icemaker

9.15AV + 264.9

0.323av + 264.9

3I. Refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic icemaker without through-the-door ice service

8.07AV + 317.7

0.285av + 317.7

3I-BI. Built-in refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic icemaker without through-the-door ice service

9.15AV + 348.9

0.323av + 348.9

3A. All-refrigerators—automatic defrost

7.07AV + 201.6

0.250av + 201.6

3A-BI. Built-in All-refrigerators—automatic defrost

8.02AV + 228.5

0.283av + 228.5

4. Refrigerator-freezers—automatic defrost with side-mounted freezer without an automatic icemaker

8.51AV + 297.8

0.301av + 297.8

4-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer without an automatic icemaker

10.22AV + 357.4

0.361av + 357.4

4I. Refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic icemaker without through-the-door ice service

8.51AV + 381.8

0.301av + 381.8

4I-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic icemaker without through-the-door ice service

10.22AV + 441.4

0.361av + 441.4

5. Refrigerator-freezers—automatic defrost with bottom-mounted freezer without an automatic icemaker

8.85AV + 317.0

0.312av + 317.0

5-BI. Built-In Refrigerator-freezers—automatic defrost with bottom-mounted freezer without an automatic icemaker

9.40AV + 336.9

0.332av + 336.9

5I. Refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic icemaker without through-the-door ice service

8.85AV + 401.0

0.312av + 401.0

5I-BI. Built-In Refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic icemaker without through-the-door ice service

9.40AV + 420.9

0.332av + 420.9

5A. Refrigerator-freezer—automatic defrost with bottom-mounted freezer with through-the-door ice service

9.25AV + 475.4

0.327av + 475.4

5A-BI. Built-in refrigerator-freezer—automatic defrost with bottom-mounted freezer with through-the-door ice service

9.83AV + 499.9

0.347av + 499.9

6. Refrigerator-freezers—automatic defrost with top-mounted freezer with through-the-door ice service

8.40AV + 385.4

0.297av + 385.4

7. Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door ice service

8.54AV + 432.8

0.302av + 432.8

7-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door ice service

10.25AV + 502.6

0.362av + 502.6

8. Upright freezers with manual defrost

5.57AV + 193.7

0.197av + 193.7

9. Upright freezers with automatic defrost without an automatic icemaker

8.62AV + 228.3

0.305av + 228.3

9I. Upright freezers with automatic defrost with an automatic icemaker

8.62AV + 312.3

0.305av + 312.3

9-BI. Built-In Upright freezers with automatic defrost without an automatic icemaker

9.86AV + 260.9

0.348av + 260.9

9I-BI. Built-in upright freezers with automatic defrost with an automatic icemaker

9.86AV + 344.9

0.348av + 344.9

10. Chest freezers and all other freezers except compact freezers

7.29AV + 107.8

0.257av + 107.8

10A. Chest freezers with automatic defrost

10.24AV + 148.1

0.362av + 148.1

11. Compact refrigerator-freezers and refrigerators other than all-refrigerators with manual defrost

9.03AV + 252.3

0.319av + 252.3

11A. Compact all-refrigerators—manual defrost

7.84AV + 219.1

0.277av + 219.1

12. Compact refrigerator-freezers—partial automatic defrost

5.91AV + 335.8

0.209av + 335.8

13. Compact refrigerator-freezers—automatic defrost with top-mounted freezer

11.80AV + 339.2

0.417av + 339.2

13I. Compact refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic icemaker

11.80AV + 423.2

0.417av + 423.2

13A. Compact all-refrigerators—automatic defrost

9.17AV + 259.3

0.324av + 259.3

14. Compact refrigerator-freezers—automatic defrost with side-mounted freezer

6.82AV + 456.9

0.241av + 456.9

14I. Compact refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic icemaker

6.82AV + 540.9

0.241av + 540.9

15. Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer

11.80AV + 339.2

0.417av + 339.2

15I. Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic icemaker

11.80AV + 423.2

0.417av + 423.2

16. Compact upright freezers with manual defrost

8.65AV + 225.7

0.306av + 225.7

17. Compact upright freezers with automatic defrost

10.17AV + 351.9

0.359av + 351.9

18. Compact chest freezers

9.25AV + 136.8

0.327av + 136.8

AV = Total adjusted volume, expressed in ft

, as determined in appendices A and B of subpart B of this part.

av = Total adjusted volume, expressed in Liters.

2. History of Standards Rulemaking for Consumer Refrigerators, Refrigerator-Freezers, and Freezers

On November 15, 2019, DOE published a request for information (“RFI”) to collect data and information to help DOE determine whether any new or amended standards for consumer refrigerators, refrigerator-freezers, and freezers would result in a significant amount of additional energy savings and whether those standards would be technologically feasible and economically justified. 84 FR 62470 (“November 2019 RFI”).

Comments received following the publication of the November 2019 RFI helped DOE identify and resolve issues related to the subsequent preliminary analysis.

DOE published a notice of public meeting and availability of the preliminary TSD on October 15, 2021 (“October 2021 Preliminary Analysis”). 86 FR 57378. DOE subsequently held a public meeting on December 1, 2021, to discuss and receive comments on the preliminary TSD. The preliminary TSD that presented the methodology and results of the preliminary analysis is available at:

www.regulations.gov/document/EERE-2017-BT-STD-0003-0021.

Comments submitted in response to the RFI are available at

www.regulations.gov/document/EERE-2017-BT-STD-0003-0021/comment.

DOE received nine docket comments in response to the October 2021 Preliminary Analysis from the interested parties listed in Table II.2.

Table II.2—October 2021 Preliminary Analysis Written Comments

Organization(s)

Reference in this NOPR

Organization type

Association of Home Appliance Manufacturers

AHAM

Trade Organization.

Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, National Consumer Law Center (On behalf of its low-income clients)

Joint Advocates

Efficiency Organization.

California Investor-Owned Utilities

CA IOUs

Utility Supplier.

Shorey Consulting

Shorey

Consultant.

ComEd Energy Solutions Center, Northwest Energy Efficiency Alliance

ComEd and NEEA

Joint Commenters.

GE Appliances, a Haier company

GEA

Manufacturer.

Samsung Electronics America, Inc.

Samsung

Manufacturer.

Sub-Zero Group, Inc.

Sub-Zero

Manufacturer.

Whirlpool Corporation

Whirlpool

Manufacturer.

Anonymous

Individual.

A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.

The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop energy conservation standards for refrigerators, refrigerator-freezers, and freezers. (Docket No. EERE-2017-BT-STD-0003, which is maintained at

https://www.regulations.gov/document/EERE-2017-BT-STD-0003).

The references are arranged as follows: (commenter name, comment docket ID number, page of that document).

3. Test Procedure

EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with energy conservation standards and to quantify the efficiency of their product. DOE must finalize new or amended test procedures that impact measured energy use or efficiency at least 180 days prior to publication of a NOPR proposing new or amended energy conservation standards. (Section 8(d) of 10 CFR part 430, subpart C, appendix A (“Process Rule”))

DOE's current energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers are expressed in terms of annual energy use (“AEU”) in kilowatt-hours per year (“kWh/yr”) as measured by the current test procedures at appendix A and appendix B, as applicable. (10 CFR 430.32(a)) The current test procedure incorporates by reference the Association of Home Appliance Manufacturers (“AHAM”) industry test procedure updated in 2019, AHAM Standard HRF-1, “Energy and Internal Volume of Refrigerating Appliances,” (“HRF-1-2019”). 10 CFR 430.3(i)(4). The current test procedure was finalized in a final rule published on October 12, 2021 (“October 2021 TP Final Rule”). 86 FR 56790. The October 2021 TP Final Rule amended the test procedure by incorporating the latest industry test standard (HRF-1-2019). However, DOE did not adopt the change in icemaker energy use included in the 2019 revision of HRF-1. 86 FR 56793. While DOE had proposed to implement this change in the in the proposed test procedure rulemaking (84 FR 70842, 70848-70850 (December 23, 2019)), DOE indicated in the October 2021 TP Final Rule that it would not require the calculations until the compliance dates of any amended energy conservation standards for these products, which incorporated the amended automatic icemaker energy consumption. 86 FR 56793. DOE concluded that the test procedure would not alter the measured energy use of consumer refrigeration products.

Id.

The analysis presented in this NOPR is based on the test procedure as finalized in the October 2021 TP Final Rule, except for the calculation of the change in energy use attributed to icemaker energy use. The change in icemaker energy use is discussed further in section III.B of this document. DOE is proposing implementation of the revised icemaker energy use calculation in this NOPR. The value of the revised icemaker energy use and the plans to implement this change coincident with the date of future energy conservation standards were discussed at length and included in the most recent test procedure final rule, consistent with the Process Rule.

AS/NZ 4474.1:2007 is referenced in the amendatory text of this document but has already been approved for appendix A. No changes are proposed.

4. Off Mode and Standby Mode

Pursuant to the amendments contained in the Energy Independence and Security Act of 2007 (“EISA 2007”), Public Law 110-140, any final rule for new or amended energy conservation standards promulgated after July 1, 2010, is required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into a single standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE's current test procedures for consumer refrigerators, refrigerator-freezers, and freezers measure the energy use of these products during extended time periods that include periods when the compressor and other key components are cycled off. All of the energy these products use during the “off cycles” is already included in the measurements.

A given refrigeration product being tested could include auxiliary features that draw power in a standby or off mode. In such instances, the DOE test procedures generally instruct manufacturers to set certain auxiliary features to the lowest power position during testing.

See

section 5.5.2(e) of AHAM Standard HRF-1-2008. In this lowest power position, any standby or off mode energy use of such auxiliary features would be included in the energy measurement. As a result, DOE's current energy conservation standards, and any amended energy conservation standards would account for standby mode and off mode energy use in the AEU metric.

C. Deviation From Appendix A

In accordance with section 3(a) of 10 CFR part 430, subpart C, appendix A (“appendix A”), DOE notes that it is deviating from the provision in appendix A regarding the pre-NOPR stages for an energy conservation standards rulemaking. Section 6(a)(2) of appendix A states that if the Department determines it is appropriate to proceed with a rulemaking, the preliminary stages of a rulemaking to issue or amend an energy conservation standard that DOE will undertake will be a framework document and preliminary analysis, or an advance notice of proposed rulemaking. For the reasons that follow, DOE finds it necessary and appropriate to deviate from this step in appendix A and to instead publish this NOPR without conducting these preliminary stages. DOE finds that there would be little benefit in repeating the preliminary stages of this proposed rule. The earlier stages of a rulemaking are intended to introduce the various analyses DOE conducts during the rulemaking process, present preliminary results, and request initial feedback from interested parties to seek early input. As DOE is using similar analytical methods in this NOPR to previous amendments to the standard for refrigerators, refrigerator-freezers and freezers, publication of a framework document, preliminary analysis, or ANOPR would be largely redundant of previously published documents. Stakeholders have previously provided numerous rounds of input on these methodologies in the most recent rulemaking. However, as discussed in section IV of this NOPR, DOE has updated analytical inputs in its analyses where appropriate and welcomes submission of additional data, information, and comments.

Section 6(f)(2) of appendix A provides that the length of the public comment period for the NOPR will be at least 75 days. For this NOPR, DOE finds it necessary and appropriate to provide a 60-day comment period. As stated previously, the analytical methods used for this NOPR are similar to those used in previous rulemaking notices. Consequently, DOE has determined it is necessary and appropriate to provide a 60-day comment period, which the Department has determined provides sufficient time for interested parties to review the NOPR and develop comments.

III. General Discussion

DOE developed this proposal after considering oral and written comments, data, and information from interested parties that represent a variety of interests. The following discussion addresses issues raised by these commenters.

A. Product Classes and Scope of Coverage

When evaluating and establishing energy conservation standards, DOE divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justify differing standards. In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility of the feature to the consumer and other factors DOE determines are appropriate. (42 U.S.C. 6295(q))

When establishing the product classes, DOE is proposing to revise the class structure by eliminating the classes that add icemakers and through-the-door ice dispensers while maintaining the same AEU calculations. The product class discussion in section IV of this document explores this issue further.

B. Test Procedure

EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with energy conservation standards and to quantify the efficiency of their product. DOE's current energy conservation standards for refrigerators, refrigerator-freezers, and freezers are expressed in terms of AEU, expressed in kWh/year. (

See

10 CFR 430.32(a).)

AHAM stated it would have been preferable for DOE to conduct its analysis with the final test procedure that DOE published before the preliminary analysis and that will be used to demonstrate compliance with a possible amended standard and that, in this case, the revised test procedure does not change measured efficiency so much that they would expect that the entire analysis would need to be redone as a result of the new test procedure. (AHAM, Public Meeting Transcript, No. 30 at p. 1)

A notation in the form “AHAM, No. 31 at pp. 6-7” identifies a written comment: (1) Made by the Association of Home Appliance Manufacturers; (2) recorded in document number 27 that is filed in the docket of this test procedure rulemaking (Docket No. EERE-2014-BT-STD-0003) and available for review at

www.regulations.gov;

and (3) which appears on pages 6 and 7 of document number 31.

DOE responds that it conducted the preliminary analysis consistent with the test procedure currently used to demonstrate compliance with standards. Specifically, the icemaker energy use adder used in the preliminary analysis was 84 kWh/yr. For the NOPR analysis, DOE adopted the revised test procedure finalized in the October 2021 TP final rule (to be used to demonstrate compliance with a possible amended standard) which included a revised icemaker energy use adder of 28 kWh/yr, that is more closely aligned with AHAM's HRF-1-2019—which represents the industry standard. As discussed in the October 2021 TP final rule, DOE determined it would not require testing with the amended icemaking energy use adder until the compliance dates of the next amended energy conservation standards for refrigeration products. This NOPR proposes that product class representations made on or after the compliance date of revised standards would require use of the 28 kWh/year value.

The California IOUs stated the existing test procedures in appendices A and B do a poor job predicting efficiency at ambient conditions below 90 °F and that they would benefit significantly by including an additional ambient test condition to properly inform consumers about what products work well in a real-world use cycle. From their testing, the California IOUs stated that not testing at both 90 °F and 60 °F leaves a significant gap in representative performance evaluation of an average use cycle based on the significant unit-to-unit variation and rank order impact changes shown by the DOE and CA IOU product testing. They therefore asked DOE to reconsider their conclusion in the October 2021 Test Procedure Final Rule to not require testing at two ambient conditions, per IEC 62552, in the DOE consumer refrigeration test procedure. (California IOUs, No. 33, pp. 6-9)

ComEd and NEEA agreed with the sentiment from California IOUs that testing should require a set of lower ambient temperatures along with the 90-degree temperature mark and recommended that DOE consider adopting the IEC Refrigerator Test Procedure, which their analysis suggests will permit more representative energy values to be calculated than the current DOE test procedure of user interactions with refrigerators. Along with Samsung, they also recommended that DOE collect more field data on refrigerator energy use to understand how to improve the representativeness of the test procedure. (ComEd Energy Solutions Center & Northwest Energy Efficiency Alliance, No. 37, pp. 9-10; Samsung, No. 32, p. 3)

In another comment, ComEd and NEEA cited average usage of models in ambient temperatures lower than 90 degrees and cited how requiring a lower test point would create an incentive for manufacturers to focus on the broad range of ambient temperatures. (ComEd Energy Solutions Center & Northwest Energy Efficiency Alliance, No. 37, pp. 2-4) ComEd and NEEA also pointed to energy savings that could result from testing products at a lower ambient temperature. (ComEd Energy Solutions Center & Northwest Energy Efficiency Alliance, No. 37, pp. 4-7)

DOE responds that it has already finalized the test procedure without requiring additional lower ambient testing based both on data provided by a manufacturer and on its own test data, which indicated that the current test procedure conducted in a 90 °F ambient temperature does not underestimate the benefit of variable-speed technology. 86 FR 56790, 56790-56825 (October 12, 2021) DOE appreciates the additional data, which DOE will consider when considering revisions to the test procedure as required by the 7-year lookback provision. (42 U.S.C. 6314(a)(1)(A))

ComEd and NEEA further recommended that DOE adopt an optional method of testing for ice makers and undertake further testing and analysis. They stated they also believe that considerable variation exists in the efficiency of the ice making process itself and that the test method should include a way to quantify this aspect. They strongly urged DOE to reword the test method regarding the setup of ice makers to specify the base method as one in which the appliance makes ice and deactivates the icemaking process itself when the ice bucket is full (or an equivalent set of actions to achieve this) to reduce circumvention. (ComEd Energy Solutions Center & Northwest Energy Efficiency Alliance, No. 37, pp. 8-9)

In response, DOE notes that it has considered the test burden associated with measurement of the energy use associated with icemaking (rather than using the fixed icemaking energy use adder) as part of the most recent concluded test procedure rulemaking. DOE concluded that the benefits of a direct measurement of icemaking energy use would not outweigh the additional test burden associated with making the measurement, due in part to the updated understanding that the magnitude of ice usage is significantly less than initially thought. 84 FR 70842, 70848-70849 (December 23, 2019). DOE did not adopt an icemaking energy use test, either mandatory or optional, in the recently concluded test procedure rulemaking cycle and has finalized the test procedure on that basis. 86 FR 56790 (October 12, 2021). Regarding the potential for circumvention by making the icemaker inoperative during the test, DOE notes that the wording of section 5.5.2(j) of HRF-1-2019, which is incorporated by reference by the DOE test procedure, has clear instructions that only the harvesting of ice shall be interrupted when an icemaker is made inoperative during an energy test and that the inoperative state should simulate the state when the icemaker senses that the bin is filled. Any tests that reduce the power of additional components when the icemaker is inoperative during an energy test would be invalid. DOE believes that these requirements are sufficiently clear and that it would not be justified to impose the additional burden of connecting a water supply to a test unit to allow the ice bin to be filled and the bin sensor to make the icemaker inoperative.

C. Technological Feasibility

1. General

In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the proposed rule. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available products or in working prototypes to be technologically feasible. Sections 6(b)(3)(i) and 7(b)(1) of appendix A to 10 CFR part 430, subpart C.

After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) practicability to manufacture, install, and service; (2) adverse impacts on product utility or availability; (3) adverse impacts on health or safety, and (4) unique-pathway proprietary technologies. Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of the Process Rule. Section IV.B of this document discusses the results of the screening analysis for refrigerators, refrigerator-freezers, and freezers, particularly the designs DOE considered, those it screened out, and those that are the basis for the standards considered in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the NOPR TSD.

2. Maximum Technologically Feasible Levels

When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for refrigerators, refrigerator-freezers, and freezers, using the design parameters for the most efficient products available on the market or in working prototypes. The max-tech levels that DOE determined for this proposed rulemaking are described in section IV.C.1.e of this proposed rule and in chapter 5 of the NOPR TSD.

D. Energy Savings

1. Determination of Savings

For each trial standard level (“TSL”), DOE projected energy savings from application of the TSL to refrigerators, refrigerator-freezers, and freezers purchased in the 30-year period that begins in the year of compliance with the proposed standards (2027-2056).

The savings are measured over the entire lifetime of refrigerators, refrigerator-freezers, and freezers purchased in the previous 30-year

period. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-new-standards case. The no-new-standards case represents a projection of energy consumption that reflects how the market for a product would likely evolve in the absence of amended energy conservation standards.

Each TSL is composed of specific efficiency levels for each product class. The TSLs considered for this NOPR are described in section V.A of this document. DOE conducted a sensitivity analysis that considers impacts for products shipped in a 9-year period.

DOE used its national impact analysis (“NIA”) spreadsheet model to estimate national energy savings (“NES”) from potential amended or new standards for refrigerators, refrigerator-freezers, and freezers. 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 NES in terms of primary energy savings, which is the savings in the energy that is used to generate and transmit the site electricity. DOE also calculates NES in terms of FFC energy savings. The FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (

i.e.,

coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards.

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.

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 a covered product, DOE must determine that such action would result in significant energy savings. (42 U.S.C. 6295(o)(3)(B))

The significance of energy savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking.

Certain covered products and equipment may have most of their energy consumption occur during periods of peak energy demand. The impacts of such products on the energy infrastructure can be more pronounced than products with relatively constant demand. However, residential refrigerators, freezers, and refrigerator-freezers have loads that are more consistent throughout the year. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis, taking into account the significance of cumulative FFC national energy savings, the cumulative FFC emissions reductions, and the need to confront the global climate crisis, among other factors. DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B).

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).

E. 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. 6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.

a. Economic Impact on Manufacturers and Consumers

In determining the impacts of a potential amended standard on manufacturers, DOE conducts an MIA, as discussed in section IV.J of this document. DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include (1) INPV, which values the industry on the basis of expected future cash flows, (2) cash flows by year, (3) changes in revenue and income, and (4) other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.

For individual consumers, measures of economic impact include the changes in LCC and PBP associated with new or amended standards. These measures are discussed further in the following section. For consumers in the aggregate, DOE also calculates the national net present value of the consumer costs and benefits expected to result from particular standards. DOE also evaluates the impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a standard.

b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)

EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered product 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 product that are likely to result from a standard. (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 a product (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. The LCC analysis requires a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and discount rates appropriate for consumers. To account for uncertainty and variability in specific inputs, such as product 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 a more efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost due to a more stringent standard by the change in annual operating cost for the year that standards are assumed to take effect.

For its LCC and PBP analysis, DOE assumes that consumers who follow existing purchase patterns will purchase the covered products in the first year of compliance with new or amended standards. Consumer response to higher costs associated with the rule may reduce sales below the levels that otherwise would have been expected in the absence of a new standard. 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. 6295(o)(2)(B)(i)(III)) As discussed in section III.D of this document, DOE uses the NIA spreadsheet models to project national energy savings.

d. Lessening of Utility or Performance of Products

In establishing product 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 products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards proposed in this document would not reduce the utility or performance of the products under consideration in this rulemaking.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed rule to the Attorney General with a request that the Department of Justice (“DOJ”) provide its determination on this issue. DOE will publish and respond to the Attorney General's determination in the final rule. DOE invites comment from the public regarding the competitive impacts that are likely to result from this proposed rule. In addition, stakeholders may also provide comments separately to DOJ regarding these potential impacts.

See

the

ADDRESSES

section for information to send comments to DOJ.

f. Need for National Energy Conservation

DOE also considers the need for national energy and water conservation in determining whether a new or amended standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from the proposed standards are likely to provide improvements to the security and reliability of the Nation's energy system. Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the Nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the Nation's needed power generation capacity, as discussed in section IV.M of this document.

DOE maintains that environmental and public health benefits associated with the more efficient use of energy are important to take into account when considering the need for national energy conservation. The proposed standards are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases (“GHGs”) associated with energy production and use. DOE conducts an emissions analysis to estimate how potential standards may affect these emissions, as discussed in section IV.K of this document; the estimated emissions impacts are reported in section V.B.6 of this document. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section 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. 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

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the standard 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. DOE's LCC and PBP analyses generate values used to calculate the effects that proposed energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the Nation, and the environment, as required under 42 U.S.C. 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.10 of this proposed rule.

IV. Methodology and Discussion of Related Comments

This section addresses the analyses DOE has performed for this proposed rulemaking with regard to refrigerators, refrigerator-freezers, and freezers. Separate subsections address each component of DOE's analyses.

DOE used several analytical tools to estimate the impact of the standards proposed in this document. The first tool is a spreadsheet that calculates the LCC savings and PBP of potential amended or new energy conservation standards. The national impacts analysis uses a second spreadsheet set that provides shipments projections and calculates national energy savings and net present value of total consumer costs and savings expected to result from potential energy conservation standards. DOE uses the third spreadsheet tool, the Government Regulatory Impact Model (“GRIM”), to assess manufacturer impacts of potential standards. These three spreadsheet tools are available on the DOE website for this proposed rulemaking:

www.regulations.gov/docket/EERE-2017-BT-STD-0003.

Additionally, DOE used output from the latest version of the Energy Information Administration's (“EIA's”)

Annual Energy Outlook

(“

AEO”

), a widely known energy projection for the United States, for the emissions and utility impact analyses.

DOE received some comments that, rather than addressing specific aspects of the analysis, are general statements regarding the appropriateness of amending energy conservation standards and/or the efficiency levels that might be appropriate.

AHAM stated that the preliminary analysis relied heavily on the use of technologies that can affect reliability, longevity, and affordability of products. Accordingly, they claimed that DOE had placed too much emphasis on the implementation of variable-speed compressors later in the EL progression, and that DOE was overestimating the impact of vacuum insulated panels (“VIPs”) in reducing energy consumption. (AHAM, No. 31, pp. 8-11)

Sub-Zero fully supported and affirmed the comments that were submitted by AHAM, which emphasized that there are significant limitations to further energy regulation if products are to remain reliable, long-lived and affordable. Sub-Zero also stated that further increases in efficiency for the built-in

products they manufacture are not justified and will save minimal energy worldwide and pose a significant and unnecessary burden on manufacturers and noted that built-ins comprise only 1.3 percent of total U.S. refrigerator and freezer shipments according to AHAM 2019 shipment data. (Sub-Zero, No. 34, p. 1; Sub-Zero, No. 34, p. 2)

DOE defines a built-in consumer refrigeration product as one that is no more than 24 inches in depth, excluding doors, handles, and custom front panels; that is designed, intended, and marketed exclusively to be (1) Installed totally encased by cabinetry or panels that are attached during installation; (2) Securely fastened to adjacent cabinetry, walls or floor; (3) Equipped with unfinished sides that are not visible after installation; and (4) Equipped with an integral factory-finished face or built to accept a custom front panel (see 10 CFR 430.2).

AHAM and Sub-Zero comments suggesting that amending standards might reduce reliability and product life are addressed in section IV.F.6 of this document. AHAM's comments and those of other stakeholders regarding the impact of VIPs are discussed in section IV.A.2 of this document. In response to Sub-Zero regarding built-in products, DOE revised the analysis in the NOPR phase to more specifically address built-in classes—this is discussed in more detail in section IV.C.1.a of this document.

Samsung noted the freestanding top-mount product classes (3, 3A, and 3I) serves as a great example of increased energy savings given it has significant market share of 42 percent and it has the ability to adapt to a tightening of standards given the room for innovation with energy efficiency technologies compared to other freestanding products. They stated that improving on the EL for these classes can provide nearly double the energy savings. (Samsung, No. 32, p. 2)

When considering the information provided in the preliminary analysis TSD published in October 2021, DOE found that in 2020 top-mount refrigerator-freezers and classes for which they are a proxy (PC 1, 2, 3, 6) constituted 36.7% of the market, while bottom-mounts alone constituted 40.2 percent (PC 5, 5A). These data indicate that, in contrast to the Samsung claim, focusing on the bottom-mount product classes could actually lead to greater energy savings due to its larger market share. In any case, DOE agrees that increasing stringency for classes that have large market shares could be very effective in achieving national energy savings.

The California IOUs stated they generally support DOE analyzing the updated energy conservation standards levels for this equipment and the finding that there are significantly higher efficiency levels with positive net present value (NPV) for consumers. (California IOUs, No. 33, p. 1)

The California IOUs included two tables, which identified the highest EL that DOE presented in the preliminary analysis for which DOE found a positive NPV for freestanding and built-in product classes. Barring updates to the preliminary analysis that incorporate other comments, they asked that DOE adopt the efficiency level for each product class with the highest savings while still having a positive NPV. (California IOUs, No. 33, p. 5-6) DOE notes that EPCA requires consideration of seven factors when setting standard levels including total projected energy savings, among others (see the discussion in section III.E.1 of this document).

A. Market and Technology Assessment

DOE develops information in the market and technology assessment that provides an overall picture of the 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 proposed rule include (1) a determination of the scope of the rulemaking and product classes, (2) manufacturers and industry structure, (3) existing efficiency programs, (4) shipments information, (5) market and industry trends; and (6) technologies or design options that could improve the energy efficiency of consumer refrigerators, refrigerator-freezers, and freezers. The key findings of DOE's market assessment are summarized in the following sections. See chapter 3 of the NOPR TSD for further discussion of the market and technology assessment.

1. Scope of Coverage and Product Classes

In the October 2021 Preliminary Analysis, DOE identified two potential product class modifications, products with icemakers, and products with multiple doors or specialty doors. The following two subsections address these topics.

Product Classes With Automatic Icemakers

As discussed later in this section, DOE has identified an opportunity to simplify and consolidate the presentation of maximum allowable energy use for products within product classes that may or may not have an automatic icemaker, and in doing so DOE expects the product class representations to be more streamlined and simplified.

To represent the annual energy consumed by automatic icemakers in refrigerators, refrigerator-freezers, and freezers, DOE's test procedures specify a constant energy-use adder of 84 kWh/year (by use of a 0.23 kWh/day adder; see section 5.3(a)(i) of 10 CFR part 430, subpart B, appendix A and section 5.3.(a) of appendix B). With this constant adder, the standard levels for product classes with an automatic icemaker are equal to the standards of their counterparts without an icemaker plus the 84 kWh/year. Consistent with prior discussions in the test procedure rulemaking, this NOPR proposes to amend this equation such that for representations made on or after the compliance date of any potential new energy conservation standards, the adder to be used shall change from 84 kWh/yr to 28 kWh/yr. DOE determined as part of the October 2021 TP Final Rule that the revised adder would more accurately reflect energy use during a representative average use cycle. 86 FR 56811. However, DOE indicated that it would not adopt this change in the test procedure until the date of potential future energy conservation standard amendments.

Id.

at 86 FR 56793. Thus, this change is being proposed in this document, with an implementation date to coincide with the compliance date of the standards proposed in this document.

AHAM reiterated their support for merging product classes for products with and without automatic icemakers due to use of the icemaker adder rather than a measured value but stated DOE must ensure that the icemaking classes do not end up with a more stringent standard as a result. (AHAM, No. 31, pp. 6-7; AHAM, Public Meeting Transcript, No. 30, pp. 13-14)

DOE has concluded that because the standards for the product classes with and without automatic icemakers are effectively the same, except for the constant adder, there is an opportunity to express the maximum allowable energy use for both icemaking and non-icemaking classes in the same equation,

thus consolidating the presentation of classes and their energy conservation standards. The equation would, for those classes that may or may not have an icemaker, include a term equal to the icemaking energy use adder multiplied by a factor that is defined to equal 1 for products with icemakers and to equal zero for products without icemakers. This approach would consolidate the product class structure, and while products with and without ice makers would be represented by a single product class descriptor and maximum energy use equation, they would continue to have different maximum energy use values, due to the ice maker coefficient in the equations.

DOE requests comments on its proposal to consolidate the presentation of maximum allowable energy use for products of classes that may or may not have an automatic icemaker.

Special Door and Multi-Door Designs

In the October 2021 Preliminary Analysis, DOE considered certain refrigerators, refrigerator-freezers, and freezers available on the market that offer special door types that allow consumers to access or view the internal storage compartment without a typical door opening. Some products available on the market offer glass doors to allow a view inside the cabinet. Potential changes to product class structure to address changes to energy consumption as a result of these features were considered, and more information was requested from interested parties.

Door-in-door design is a relatively new setup offered in certain standard-size refrigerator-freezers. Typically, manufacturers add a second smaller door between the fresh food compartment's outer door and the inner cabinet. This design allows the consumer to access items loaded in the door shelves without opening an interior door that encloses the inner cabinet. Some door-in-door designs have an outer glass door, providing the user a transparent view of the inner cabinet. Some refrigerators, refrigerator-freezers, and freezers, available on the market also offer multi-door setups which deviate from the popular French-door design. Some designs include one or more “drawers” which can be pulled out of the main compartment and allow for more fresh food storage than more traditional designs. Other designs may include a “quadrant” design in which four doors are placed in a two-by-two configuration with two doors for the freezer compartment, and two for the fresh food.

AHAM commented that in its preliminary analysis DOE declined to adopt a separate product class or an energy use allowance for products with glass door or door-in-door type features. They stated that other jurisdictions have a constant multiplier used in the development of standards to account for the number of doors on a product, and there are separate product classes for glass door products in commercial refrigerators. (AHAM, No. 31, p. 7) GEA supported AHAM's position on multidoor products and suggested using gasket area as a basis for a multidoor multiplier. (GEA, No. 38, p. 3) Whirlpool also noted that there is justification for applying a multiplier for multidoor products. (Whirlpool, No. 35, pp. 8-10) Sub-Zero asked DOE to consider adding a product class for built-ins with specialty doors and urged DOE to define additional product classes for analyses and set separate standards levels for built-ins with specialty doors. (Sub-Zero, No. 34, p. 2)

DOE reviewed the prevalence of products with multiple or specialty doors and conducted analysis to assess the energy use impact of such design features. More detail regarding this assessment is provided in Chapters 3 and 5 of the NOPR TSD. As a result, DOE concluded that some allowance for multiple doors and specialty doors would be appropriate for classes where such features are offered. Specifically, DOE is proposing the following allowances for classes for which the specific features are relevant.

• Two percent energy use allowance for each externally-opening door in excess of the typical minimum for the class (

i.e.,

more than 2 doors for refrigerator-freezer classes 5 and 7, and more than 3 doors for class 5A). This would be applicable for current product classes 5, 5A, and 7, with a limits of six percent for product classes 5 and 7, representing a product with five doors (three in excess of the typical minimum), and four percent for product class 5A, also representing a product with five doors (in this case two in excess of the typical minimum). For the purposes of this provision, a drawer with an externally-exposed face would be considered an externally-opening door.

• Six percent total energy use allowance for a product with a door-in-door feature implemented in one or more of its doors. This would apply instead of any multiple-door allowance for product classes 5, 5A, and 7.

• Ten percent total energy use allowances for a product with a transparent door or doors. This would apply instead of any multiple-door or door-in-door allowance for product classes 3A, 5, 5A, 7, and 13A.

With this proposed approach, the maximum energy use allowance would be ten percent, for a glass door. However, if the standard level for any of the eligible classes is set at a level for which this allowance would represent backsliding,

i.e.,

allow such a product to have more energy use than the current standard (adjusted for the change in icemaker energy use adder), the allowance would be reduced to eliminate such backsliding. The proposal uses the number of doors in excess of the typical minimum number of doors, rather than using an adjustment based on gasket size, as suggested by GEA, in an attempt to maintain better simplicity of the adjustment and determination of the maximum allowable energy use. In response to Sub-Zero, DOE notes that this provision would apply to built-in classes as well as freestanding classes.

DOE requests comment on its proposal for establishing energy use allowances for multiple doors and/or specialty doors. Should such an energy use allowance structure be established, and, if so, are the proposed energy use allowance levels appropriate? If they are not appropriate, DOE requests input on what the energy use allowance values should be, with supporting data to demonstrate that the alternative levels suggested are justified.

DOE also considered whether any definitions would be required to clarify what products the door allowances would apply to. As described previously, the allowances for multiple doors would apply for externally-opening doors or drawers. DOE believes that these descriptions provide sufficient clarity such that additional definitions regarding multiple doors would not be required.

For transparent doors, DOE proposes to add a definition that aligns with the definition of display doors for walk-in coolers and freezers, which defines a display door as a door that either is designed for product display or has 75 percent or more of its surface area composed of glass or another transparent material. (

See

10 CFR 431.302). Specifically, DOE proposes to define transparent door as a door for which 75 percent or more of the surface area is glass or another transparent material.

For door-in-door features, DOE proposes to add a clarifying definition indicating that a door-in-door is a set of doors or an outer door and inner drawer for which (a) both doors (or both the door and the drawer) must be opened to provide access to the interior through a single opening, (b) gaskets for both doors (or both the door and the drawer)

are exposed to external ambient conditions on the outside around the full perimeter of the respective openings, and (c) the space between the two doors (or between the door and the drawer) achieves temperature levels consistent with the temperature requirements of the interior compartment to which the door-in-door provides access.

DOE requests comments on the proposed definitions to clarify transparent door and door-in-door features. If the proposed definitions are not appropriate, DOE requests comment on what specific changes should be made to the definitions, or what other definitions are necessary, so that they would appropriately describe the intended specialized doors.

2. Technology Options

In the preliminary market analysis and technology assessment, DOE identified 37 technology options that would be expected to improve the efficiency of refrigerators, refrigerator-freezers, and freezers, as measured by the DOE test procedure:

Table IV.1—Technology Options Identified in the Preliminary Analysis

Insulation:

1. Improved resistivity of insulation (insulation type).

2. Inert blowing fluid CO

3. Increased insulation thickness.

4. Gas-filled insulation panels.

5. Vacuum-insulated panels (“VIP”).

Gasket and Door Design:

6. Improved gaskets.

7. Double door gaskets.

8. Improved door face frame.

9. Reduced heat load for through-the-door (“TTD”) feature.

Anti-Sweat Heater:

10. Condenser hot gas (Refrigerant anti-sweat heating).

11. Electric anti-sweat heater sizing.

12. Electric heater controls.

Compressor:

13. Improved compressor efficiency.

14. Variable-speed compressors.

15. Linear compressors.

Evaporator:

16. Increased surface area.

17. Improved heat exchange.

Condenser:

18. Increased surface area.

19. Microchannel condenser.

20. Improved heat exchange.

21. Force convection condenser.

Defrost System:

22. Reduced energy for automatic defrost.

23. Adaptive defrost.

24. Condenser hot gas defrost.

Control System:

25. Electronic Temperature control.

26. Anti-Distribution control.

Other Technologies:

27. Fan and fan motor improvements.

28. Improved expansion valve.

29. Fluid control or solenoid off-cycle valve.

30. Alternative refrigerants.

31. Component location.

32. Phase change materials.

Alternative Refrigeration Cycles:

33. Ejector refrigerator.

34. Dual evaporator systems.

35. Two-stage system.

36. Dual-loop system.

37. Lorenz-Meutzner cycle.

Several commenters provided feedback on some of these technology options. These comments are summarized, along with DOE's responses.

Samsung agreed with the DOE's various technology options, specifically DOE's identification of variable-speed compressors and R-600a as means to improve energy efficiency. (Samsung, No. 32, pp. 2-3)

AHAM clarified that when considering “alternate refrigerants” as a technology option, DOE recognize that the use of R-600a should not be considered an option to account for a decrease in energy consumption if DOE's analysis accounts for a full transition from HFCs by January 1, 2023. AHAM also stated DOE's analysis regarding refrigerant for product classes 5, 5I, and 5A are flawed as the alternative refrigerants considered may not be accurate of the current or transitioning market. AHAM further stated the R-600a compressors only at ELs 3 and 4 is not reflective of the market; AHAM shipment data indicate a significant number of units are already using Isobutane (R-600a) refrigerant and/or variable-speed compressors to meet the current DOE standard or ENERGY STAR® levels. AHAM stated DOE needs to redo its analysis of product classes 5, 5I and 5A to incorporate market representative models and adjust the projected technology paths to account for options already in use. (AHAM, No. 31, pp. 4, 8-9)

In response, DOE reassessed its treatment of R-600a as a design option in the October 2021 Preliminary Analysis. It is DOE's understanding, confirmed through discussions with manufacturers, that following the removal of HFC-134a as a viable refrigerant for consumer refrigeration product in the U.S., manufacturers are primarily using R-600a as a replacement.

Hence, DOE assumed for its NOPR analysis that all consumer refrigeration products, even those at baseline efficiency levels, now use R-600a. DOE is aware that other alternative refrigerant choices are allowed to be used and further would not be banned by a recent EPA proposal restricting refrigerants.

However, based on all available information, DOE is not aware of any instances in which these alternatives are being considered by manufacturers as viable approaches for increases in efficiency in these products. 87 FR 76738, 76785 (December 15, 2022). Hence, refrigerant change has not been included as a technology option in this NOPR.

In a final rule published December 1, 2016, the Environmental Protection Agency (“EPA”), as part of its Significant New Alternatives Policy (“SNAP”) program covering ozone-depleting refrigerants and related substances, changed the status of HFC-134a, the refrigerant to “unacceptable” for consumer refrigeration products starting January 1, 2021. 81 FR 86778, 86893.

On December 15, 2022, EPA published a proposed rule restricting the use of refrigerants with GWP of 150 or greater. 87 FR 76738. Refrigerants including R-290, R-441A, R-600a, and HFC-152a meet this GWP requirement and are listed as acceptable under EPA's SNAP rules (see

https://www.epa.gov/snap/substitutes-household-refrigerators-and-freezers

Darren Rains stated that the current design of many homes, commercial, and industrial refrigeration units allow cooling fans to pull air directly over a unit's condenser coils, resulting in dust and debris clogging the coils. As a result of this Rains states that accumulation of dust, hair, and lint on the condenser coils lowers the unit's ability to dissipate heat. Rains suggests that all incoming airflow openings must be covered by filtering materials sufficient to keep out the vast majority of debris, lint, and hair away from the condenser coils, and that filtering materials be easy to remove, replace, and are resistant to cleaning with a vacuum. Rains also suggests that gaps underneath refrigeration units have closed cell foam to address suction of debris into the unit. (Rains, No. 27, pp. 1-2)

DOE responds that consumer refrigeration products are tested before installation in homes and therefore before there is the potential to clog the condenser coil. Hence, even though air filters and/or other protection of the coils from dust or other debris may provide an efficiency benefit during home use, they would not be expected to affect the measurement of efficiency in the DOE test procedure. This is a factor that AHAM could potentially consider in development of a future revision of the HRF-1 test standard, and is also a factor that DOE may consider in a future test procedure rulemaking.

The Joint Commenters stated they believe DOE may be underestimating VIP performance by relying on outdated information and/or otherwise inappropriate assumptions. The Joint Commenters noted DOE did not provide ample explanation for the 50 percent degradation factor/scaling factor and urged DOE to investigate an appropriate, updated scaling factor informed by recent interviews with manufacturers rather than relying on the previous rulemaking. They also stated the energy savings from VIPs presented in the preliminary analysis appear to be notably smaller than those found in a 2018 study and therefore urged DOE to reevaluate its modeling to ensure that the energy savings from VIPs are appropriately being captured. (Joint Commenters, No. 36, pp. 3-4)

DOE notes that, while the use of VIPs has become more common, it is not yet a technology that is used in a majority of products. DOE found few VIPs in the products that it purchased, and reverse engineered using destructive teardowns. The use of VIPs is not advertised in manufacturer product literature; thus, it is difficult to conduct statistical analysis to correlate efficiency levels with use of the technology. Manufacturers have reported varied levels of success using the technology. The information that DOE has been able to obtain on this topic through manufacturer interviews is by no means exhaustive, but it doesn't suggest that energy use reduction associated with use of VIPs is significantly different than would be estimated by the approach derivative of the previous rulemaking that was adopted in the preliminary analysis. DOE has used this approach also for the NOPR analysis. The details of the VIP analysis are described further in Chapter 5 of the NOPR TSD.

Based on the comments received, DOE has not identified any new technologies to add to the list provided as part of the preliminary analysis, and has removed alternative refrigerants as a technology option, since it would already be used in products at any efficiency level.

For Product Class 11A, ASAP recognized that many of the most efficient models are powered coolers that have small, adjusted volumes. However, they encouraged DOE to investigate the design features present in these very high-efficiency models to determine if such design features are more broadly applicable to the product class. (ASAP, Public Meeting Transcript, No. 30, p. 22)

In response, DOE notes that several of the most efficient products certified under product class 11A are DC-input models marketed for use in cars or boats. For example, the Alpicool TS50 is rated as a 1.8 cuft model with energy use 40% less than the maximum allowable annual energy use for products in its class. Product information shows that it is intended for car or boat service, and thus, it cannot be considered representative of the market. (“Alpicool TS Series”, No. XXXX)

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:

10 CFR part 430, subpart C, appendix A, sections 6(b)(3) and 7(b).

(1)

Technological feasibility.

Technologies that are not incorporated in commercial products or in working prototypes will not be considered further.

(2)

Practicability to manufacture, install, and service.

If it is determined that mass production and reliable installation and servicing of a technology in commercial products 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 or product availability.

If it is determined that a technology would have a significant adverse impact on the utility of the product for significant subgroups of consumers or would result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not be considered further.

(4)

Adverse impacts on health or safety.

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 design option utilizes proprietary technology that represents a unique pathway to achieving a given efficiency level, that technology will not be considered further due to the potential for monopolistic concerns.

In summary, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the listed five criteria, it will be excluded from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed in the following sections.

The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (“screened out”) based on the screening criteria.

1. Screened-Out Technologies

In the October 2021 preliminary analysis, DOE screened out the technologies presented in Table IV.2 on the basis of technological feasibility, practicability to manufacture, install, and service, adverse impacts on utility or availability, adverse impacts on health and safety, and/or unique-pathway proprietary technologies.

AHAM stated DOE's analysis relies heavily on the use of variable-speed compressors (“VSCs”) to achieve efficiency gains, indicating that (a) for some product classes, achieving even EL1 would require the use of VSCs, (b) there is additional design work and related costs required to implement VSCs, and (c) there are potential concerns about harmonic and interference issues. (AHAM, No. 31, p. 10) GEA stated DOE's analysis of the potential use of VSCs to reach certain energy levels fails to account for several costs associated with the use of VSCs. (GEA, No. 38 at p. 10)

DOE notes that it is clear from AHAM's statements, review of product literature, and discussions with manufacturers, that VSCs are a common design option used in a large percentage of currently-shipped consumer refrigeration products, with around one third of the U.S. refrigerator market adapting to VSCs and increasing implementation. (Samsung, No. 32, pp. 2-3) Furthermore, while AHAM suggested that DOE consider harmonics and possible electric grid interference from VSCs, DOE is not aware of any issues related to VSCs and harmonics to date, nor any requirements in place at this time. DOE is aware that Natural Resources Canada (NRCan) has released a comprehensive energy efficiency guide regarding variable frequency drives for informative purposes, with discussion of harmonics.

DOE notes, however, that the stated primary focus of the NRCan publication is for 'off-the-shelf', low-voltage variable frequency drives typically used in conjunction

with AC, polyphase, and induction motors, which does not include drives for consumer refrigeration VSCs. Hence, because VSCs are currently implemented in a substantive number of products and DOE is not aware of harmonic interference at this time, DOE believes it is inappropriate to screen out this technology.

The NRCan publication regarding variable frequency drives can be found at

https://www.nrcan.gc.ca/sites/www.nrcan.gc.ca/files/energy/pdf/energystar/variable-frequency-drives-eng.pdf.

Table IV.2—Technologies Screened-Out in the Preliminary Analysis

Improved Gaskets, Double Gaskets, and Improved Door Face Frame.

Linear Compressors.

Fluid Control or Solenoid Off-Cycle Valves.

Improved Evaporator Heat Exchange.

Improved Condenser Heat Exchange.

Forced Convection Condenser.

Condenser Hot Gas Defrost.

Compressor Location at Top.

Evaporator Fan Motor Location Outside Cabinet.

Air Distribution Control.

Phase Change Materials.

Lorenz-Meutzner Cycle.

Dual-Loop Systems.

Two-Stage System.

Ejector Refrigerator.

Improved VIPs.

Inert Blowing Fluid CO

2. Remaining Technologies

Through a review of each technology, DOE concluded in the preliminary analysis that all of the other identified technologies listed in section IV.A.2 of this document met all five screening criteria to be examined further as design options in DOE's NOPR analysis. In summary, DOE did not screen out the following technology options:

Table IV.3—Technologies Remaining in the Preliminary Analysis

Insulation:

1. Improved resistivity of insulation (insulation type).

2. Increased insulation thickness.

3. Gas-filled insulation panels.

4. Vacuum-insulated panels.

Gasket and Door Design:

5. Reduced heat load for TTD feature.

Anti-Sweat Heater:

6. Refrigerant anti-sweat heating.

7. Electric anti-sweat heater sizing.

8. Electric heater controls.

Compressor:

9. Improved compressor efficiency.

10. Variable-speed compressors.

Evaporator:

11. Improved expansion valve.

12. Increased surface area.

13. Dual evaporator systems.

Condenser:

14. Increased surface area.

15. Microchannel condenser.

Defrost System:

16. Reduced energy for automatic defrost.

17. Adaptive defrost.

Control System:

18. Electronic Temperature control.

Other Technologies:

19. Fan and fan motor improvements.

20. Alternative refrigerants.

DOE has 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 and do not result in adverse impacts on consumer utility, product availability, health, or safety, unique-pathway proprietary technologies). For additional details, see chapter 4 of the NOPR TSD.

DOE did not receive any comments specifically about screening technologies that have not already been mentioned previously. DOE's assessment of screening technologies has not changed for the NOPR analysis, and thus DOE has screened out that same group of technologies in the NOPR phase. Hence, the technologies remaining, that are considered as design options for the engineering analysis, are the same as those in the preliminary analysis, except for alternative refrigerants, which DOE has removed from the technology option list for the reasons mentioned in section IV.A.2 of this document.

C. Engineering Analysis

The purpose of the engineering analysis is to establish the relationship between the efficiency and cost of consumer refrigerators, refrigerator-freezers, and freezers. There are two elements to consider in the engineering analysis; the selection of efficiency levels to analyze (

i.e.,

the “efficiency analysis”) and the determination of product cost at each efficiency level (

i.e.,

the “cost analysis”). In determining the performance of higher-efficiency products, DOE considers technologies and design option combinations not eliminated by the screening analysis. For each product class, DOE estimates the baseline cost, as well as the incremental cost for the product at efficiency levels above the baseline. The output of the engineering analysis is a set of cost-efficiency “curves” that are used in downstream analyses (

i.e.,

the LCC and PBP analyses and the NIA).

1. Efficiency Analysis

DOE typically uses one of two approaches to develop energy efficiency levels for the engineering analysis: (1) relying on observed efficiency levels in the market (

i.e.,

the efficiency-level approach), or (2) determining the incremental efficiency improvements associated with incorporating specific design options to a baseline model (

i.e.,

the design-option approach). Using the efficiency-level approach, the efficiency levels established for the analysis are determined based on the market distribution of existing products (in other words, based on the range of efficiencies and efficiency level “clusters” that already exist on the market). Using the design option approach, the efficiency levels established for the analysis are determined through detailed engineering calculations and/or computer simulations of the efficiency improvements from implementing specific design options that have been identified in the technology assessment. DOE may also rely on a combination of these two approaches. For example, the efficiency-level approach (based on actual products on the market) may be extended using the design option approach to “gap fill” levels (to bridge large gaps between other identified efficiency levels) and/or to extrapolate to the max-tech level (particularly in cases where the max-tech level exceeds the maximum efficiency level currently available on the market).

For the preliminary analysis, DOE used a combined efficiency-level and design-option approach. First, an efficiency-level approach was used to establish an analysis tied to existing products on the market. A design option approach was used to extend the analysis through “built-down” efficiency levels and “built-up” efficiency levels where there were gaps in the range of efficiencies of products that were reverse engineered. Products from the product classes 3, 5, 5A, 7, 9, 10, 11A, & 18 were tested and torn down to provide information to lay the groundwork for the analysis. Design option analysis techniques were used to extend the analysis to higher efficiency levels and to fill any efficiency level gaps. Due to limitations in acquiring models from every product class for testing, DOE did not acquire for test and teardown, nor construct analysis for, all product classes. DOE focused the analysis on products with the highest market share. Regarding built-in product classes, certification data collected in DOE's Compliance Certification Database (“CCD”) indicated that the

potential for efficiency improvement was comparable for built-in classes and their corresponding freestanding classes. (See Section 5.2.1 of the Preliminary Analysis TSD) Thus, DOE concluded that the freestanding classes could act as proxies for the built-in classes. Section 10.4 of the preliminary analysis TSD discusses use of the engineering analysis for the analyzed classes to represent the cost-efficiency relationship for the classes for which engineering analysis was not conducted.

AHAM raised two general comments regarding representativeness of the classes and products analyzed for the preliminary analysis. First, AHAM claimed that DOE used product classes as proxy for other classes which were not sufficiently representative—this comment primarily addressed built-in classes. (AHAM, No. 31, pp. 5-6) Second, AHAM asserted that DOE selected models for teardown that were not representative of the specific classes analyzed—this comment primarily addressed the increase in multi-door product configurations, mainly for product classes 5, 5I, and 5A. (AHAM, No. 31, p. 2) These general comments are discussed in detail below.

a. Built-In Products

AHAM agreed that, given the significant number of product classes, it is appropriate for DOE to evaluate some classes in detail and use that analysis as a proxy for other similar product classes. However, AHAM stated DOE consolidated its analysis too much. (AHAM, Public Meeting Transcript, No. 30, p. 7-8

) Specifically, AHAM stated freestanding product classes are not a proxy for built-in product classes and DOE should evaluate them separately. (AHAM, No. 31, 5-6) In addition to AHAM, GEA also objected to the use of freestanding products as analogues for built-in products in DOE's analysis and requested a separate analysis for built-in product classes. GEA stated built-in products are fundamentally different than freestanding products in that built-in products have different physical constraints as to size and shape, different configurations for their mechanical systems, and different markets and customer segments. Sub-Zero also noted that built-ins now utilize combinations of every practical energy saving design option identified by DOE and therefore urged DOE to seriously address the reality that a more stringent standard is not justified for some product classes, such as built-ins. (GEA, No. 38, p. 2; Sub-Zero, No. 34, p. 2)

A notation in the form “AHAM, Public Meeting Transcript, No. 30 at p. 3” identifies an oral comment that DOE received on December 1, 2021, during the public meeting, and was recorded in the public meeting transcript posted in the docket for this test procedure rulemaking (Docket No. EERE-2014-BT-STD-0003). This particular notation refers to a comment (1) made by the Association of Home Appliance Manufacturer during the public meeting; (2) recorded in document number 30, which is the public meeting transcript that is filed in the docket of this test procedure rulemaking; and (3) which appears on page 3 of document number 30.

On the other hand, the Joint Commenters stated they support DOE's approach of analyzing the same potential efficiency increases for built-in product classes as those for corresponding freestanding product classes. (Joint Commenters, No. 36, p. 5)

In response to these comments, DOE revised its analysis to address built-in products more directly. Specifically, DOE conducted additional analysis for class 5-BI, based on information from the 5-BI analysis conducted to support the September 2011 Final Rule, CCD and product literature data, and information provided by built-in product manufacturers during interviews. DOE has used the differences in the analyses between class 5 and 5-BI to approximate the differences between freestanding and built-in class pairs for other relevant built-in classes (

e.g.,

classes 3A, 7, and 9).

b. Representativeness of Reverse-Engineered and Analyzed Products

AHAM expressed concern that in some cases the features present in the teardown products were not representative of the market. (AHAM, Public Meeting Transcript, No. 30, pp. 7, 14-17) According to AHAM, DOE's analysis of product classes 5 and 5A in the preliminary analysis did not appear to be representative of the market in terms of volume, features, and number of doors; specifically, DOE's analysis focused on bottom-mount refrigerator/freezers with only two doors—one for the refrigerator and one for the freezer. AHAM stated it is unclear whether the analysis accounts for the differences between classes 5 and 5A and urged DOE to conduct further consultation with manufacturers in order to better account for these distinctions. (AHAM, No. 31, p. 2-3) Whirlpool agreed with these AHAM comments. (No. 35, pp. 2-3)

The California IOUs expressed similar concerns about whether all of the models selected to represent specific classes and efficiency levels were fully representative. They specifically pointed to the high cost of dual-evaporator systems, used in the DOE analysis for product classes 5A and 7 to reach EL2, as being non-representative. (California IOUs, Public Meeting Transcript, No. 30, p. 30) ASAP also noted that, when going from efficiency level 1 to 2 in the preliminary analysis, there is an incremental cost increase of more than $300 for Product Class 5A and more than $250 for Product Class 7 and that the technology options added at EL-2 are a higher-efficiency compressor and a single VIP for Product Class 5A and then dual evaporators in a single VIP for Product Class 7. ASAP requested an explanation of what is driving that incremental cost in both cases of going from EL-1 to EL-2. (ASAP, Public Meeting Transcript, No. 30, p. 27-28)

In response to these comments regarding the representativeness of the models analyzed, DOE investigated and came to similar conclusions. Thus, DOE revised the analysis for this NOPR such that (a) analyses for both product classes 5 and 5A are based on three-door designs, (b) the capacities of the product class 5 representative units are larger, (c) the capacities of the product class 5A units are smaller, and (d) the analyses for product classes 5A and 7 do not consider use of dual evaporators as a design option, remaining more consistent with a more representative single-evaporator design. DOE believes the analyses conducted for this NOPR are representative of the product classes in the market.

c. Baseline Efficiency/Energy Use

For each product/equipment class, DOE generally selects a baseline model as a reference point for each class, and measures changes resulting from potential energy conservation standards against the baseline. The baseline model in each product/equipment class represents the characteristics of a product/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.

For the preliminary analysis, DOE chose baseline efficiency levels represented by the current Federal energy conservation standards, expressed as maximum annual energy consumption as a function of the product's adjusted volume, with the exclusion of the automatic icemaker energy contribution for product classes that include this feature. The current standards incorporate allowance of a constant 84 kWh/yr icemaker adder for product classes with automatic icemakers, consistent with the current test procedure, which requires adding

this amount of annual energy use to the product's tested performance if the product has an automatic icemaker.

For the analysis in this NOPR, DOE adjusted the baseline energy usage levels for each class to account for the planned revision in the test procedure of the icemaker energy use adder to 28 kWh/year. From this baseline DOE conducted direct analyses for 9 product classes, with some classes including two representative adjusted volumes. In conducting these analyses, 13 baseline units were used in construction of cost curves, and had their characteristics determined in large part by purchased, tested, and reverse engineered tear-down models. Further information on the design characteristics of specific analyzed baseline models is summarized in the NOPR TSD.

d. Higher Efficiency Levels

AHAM commented that DOE should examine a gap-fill EL between the current DOE standard and the previously analyzed EL 1 for freestanding bottom-mount refrigerator-freezers (product classes 5, 5I, and 5A). Whirlpool agreed, but expanded on this, indicating that DOE should examine a gap-fill EL between the current DOE standard and the analyzed EL 1 for freestanding top-mount and side-by-side refrigerator-freezers (product classes 3, 3I, 4, 6, and 7). (AHAM, No. 31, p. 4; Whirlpool, No. 35, p. 4-5)

Whirlpool also noted that in the last refrigerator, refrigerator-freezer, and freezer energy conservation standards rulemaking, DOE considered (in the corresponding TSD) gap-fill efficiency levels between baseline and ESTAR Version 4.0 levels, which at the time were 20% more efficient than the DOE federal minimum for most product classes. Whirlpool stated DOE should analyze gap fill levels like those considered in the last rulemaking due to their own precedent and to at least consider them at this state and due to distinct technology options, product cost, and customer impacts of refrigerators, refrigerator-freezers, and freezers produced at these levels compared to refrigerators, refrigerator-freezers, and freezers at baseline and EL1. Whirlpool further stated it is extremely important that DOE consider these gap fill levels for the non-built-in top mount and side-by-side product classes. They stated the product costs needed to improve even a 5% gap fill level for those PCs will be substantially lower than their estimated costs of meeting EL1 and that savings would still be delivered to consumers, but at a much lower product cost increase, which would minimize the impact from amended standards to low-income consumers often from disadvantaged communities. (Whirlpool, No. 35, p. 4-8)

In interviews, manufacturers reiterated that gap-fill ELs should be evaluated, particularly for top-mount and side-by-side refrigerator-freezers.

In response, in this NOPR analysis DOE analyzed a 5% EL for product classes 3 and 7 (the top-mount refrigerators-freezers, and side-by-side refrigerator-freezers, respectively).

For the NOPR analysis, DOE analyzed up to five incremental efficiency levels beyond the baseline for each of the analyzed product classes. For products classes 3 and 7, this included an efficiency level roughly 5% more efficient than the current energy conservation standard. For other classes, the efficiency levels start at EL2, near 10% more efficiency than the current energy conservation standard, equivalent to the current ENERGY STAR® level for refrigerators, refrigerator-freezers, and freezers. For the NOPR analysis, DOE extended the efficiency levels in steps of close to 5% of the current energy conservation standard up to EL 4. Finally, EL 5 represents “max-tech”, using design option analysis to extend the analysis beyond EL 4 using all applicable design options, including max efficiency variable-speed compressors, and considerable use of VIPs.

For Product Classes 5A, 7, and 11A, ASAP, California IOUs, and Joint Commenters stated they found that there are models listed in DOE's Compliance Certification Database that are more efficient than DOE's max-tech levels. They further stated that DOE presented a figure in the PTSD that showed available models that are more efficient than the max-tech efficiency level for Product Class 7. They therefore encouraged DOE to reevaluate the max-tech efficiency levels for Product Classes 5A, 7, and 11A so that they represent true max-tech levels. (ASAP, Public Meeting Transcript, No. 30, p. 22; California IOUs, No. 30; pp. 24-26; Joint Commenters, No. 36, p. 1-2) As indicated in section IV.A.2, DOE notes that some of the most efficient products of product class 11A are DC-input products and thus not generally representative of the refrigerator market. As for product classes 5A and 7, the max-tech efficiency levels analyzed in this NOPR were 21.5% and 22%, respectively. These max-tech levels are consistent with the maximum available efficiency levels of representative products sold by major manufacturers with which DOE conducted interviews.

The Joint Commenters noted that the TSD states that the energy efficiency ratios (“EER”) for VSCs are typically consistent with those of the highest available efficiency single-speed compressors (“SSC”) at the same capacity but stated that low-capacity compressors (generally models less than

1/4

hp or 500 BTU/hr) would typically be present in compact product classes. They included a figure which showed, for both R-134a and R-600a compressors, the EER of a VSC can be 1 to 2 points higher than that of the most efficient SSC at the same capacity (<500 BTU/hr) and, therefore, DOE may be underestimating the savings from VSC for compact products by failing to capture the improved full-load efficiency in addition to the part-load savings. (Joint Commenters, No. 36, p. 4-5)

While published EER levels for VSCs may be much higher than published EERs for single-speed compressors in the capacity range suitable for compact products, DOE has not found many such products that use such compressors, and thus has little evidence that the suggested efficiency improvements could be guaranteed. DOE believes that its engineering analysis for compact products is representative of likely performance using VSCs.

The efficiency levels analyzed beyond the baseline are shown in Table IV.4.

Table IV.4—Incremental Efficiency Levels for Analyzed Products

[% Energy Use Less Than Baseline]

Product class

(AV, ft)

Standard-size refrigerator

(11.9)

(%)

(20.6)

(%)

5 **

(23.0)

(%)

5 **

(30.0)

(%)

5A **

(35.0)

(%)

5-BI **

(26.0)

(%)

(31.5)

(%)

Standard-size freezers

(29.3)

(%)

(26.0)

(%)

Compact refrigerators and freezers

11A

(1.7)

(%)

11A

(4.4)

(%)

(9.0)

(%)

(8.9)

(%)

EL 1 *

EL 2 *

9.5

EL 3

21.5

14.5

EL 4

EL 5

* ENERGY STAR® % level varies based on specific teardown units analyzed.

** Percentages are based on a 3-door configuration.

e. VIP Analysis and Max-Tech Levels

ASAP noted that a 2018 study

found that the installation of vacuum insulated panels (“VIPs”) in the rear cabinet wall reduced energy consumption by 5 percent and when VIPs were added to the doors, the total reduction was almost 12 percent. ASAP further noted that, with VIPs added to the side walls and top wall (where VIPs cover approximately half of the cabinet area), the total reduction energy consumption was about 20 percent. ASAP therefore stated DOE's conclusion of a 4 to 6 percent energy savings from the installation of VIPs covering half of the cabinet area seems lower than expected and questioned this discrepancy. California IOUs also reiterated energy savings from using VIPs was being undercounted. (ASAP, Public Meeting Transcript, No. 30, pp. 22-23; California IOUs, No. 33, pp. 2-3)

Thiessen, S., Knabben, F.T., Melo, C., & Gonçalves, J.M. (2018). A study on the effectiveness of applying vacuum insulation panels in domestic refrigerators.

International Journal of Refrigeration, 96,

p. 10-16.

https://doi.org/10.1016/j.ijrefrig.2018.09.006.

The California IOUs recommended that DOE increase the maximum ELs in the PTSD by reviewing design options for commercialized products that meet or exceed the max-tech levels. The California IOUs stated that it is likely that DOE is underestimating the energy savings that can be achieved at max-tech level because there is no indication that any of the products analyzed have VIPs, which is the additional design option for most product classes at max-tech. They therefore requested that DOE revise EL 3 and EL 4 to either incorporate additional design options or revise the energy savings attributed to the included design options if they are the only ones used in these commercialized products. (California IOUs, No. 33, p. 3-4)

ASAP requested specific information, particularly dimensions, of the single VIP referenced in table 5.5.1 of the preliminary analysis which shows the design options by efficiency level for each product class. ASAP also noted there is a reference to the VIPs covering half of the cabinet area and requested clarification on whether the full cabinet area is referring to all five sides being the top, bottom, two sides, and rear (excluding the doors) or if it was something else. (ASAP, Public Meeting Transcript, No. 30, pp. 15-17 & 21-22)

ASAP noted that DOE assumed a mid-panel thermal conductivity for the VIPs but then used a scaling factor of 50 percent to account for the actual versus expected performance of VIPs and requested clarification regarding what the 50 percent factor is capturing. (ASAP, Public Meeting Transcript, No. 30, p. 23)

On the other hand, AHAM stated DOE does not account for the limitations of VIPs and does not apply it as it would likely be used in actual products and, as a result, overestimates the use and impact of VIPs in its analysis. AHAM noted DOE's emphasis on VIPs appears to result from the teardown of a single unit, which is likely not representative of how VIPs are generally deployed on a larger scale. GEA stated DOE must also account for the technical limitations of VIPs including edge effects, which is particularly important when analyzing their use in smaller products. GEA also noted that DOE's analysis indicates manufactures will implement VIPs to achieve higher energy levels, but stated that many manufacturers, including GEA, already use VIPs to meet existing standards minimums and EL 1. (AHAM, No. 31, pp. 10-11; GEA, No. 38, p. 2)

In response to the ASAP and California IOUs comments regarding a study involving use of VIPs, DOE notes that the Department's analysis was generally consistent with the study in terms of how and where VIPs would be applied into the products. DOE further notes that its analysis also was consistent with information provided by manufacturers in interviews on VIP placement—specifically, that VIPs would primarily be used on the door(s), the walls, and the tops of cabinets, preferentially for the freezer compartments. In response to ASAP's question about the 50 percent factor, this was an adjustment that DOE used in the analysis leading up to the September 2011 Final Rule based on information regarding VIP experiences by manufacturers at that time. Based on discussions with manufacturers in the current rulemaking, it is not clear that success using VIPs in production settings has significantly increased. While the cited study provides some indication that VIPs can provide significant energy savings, DOE is now aware of evidence showing commercialized products are consistently achieving such levels of improvement.

Regarding table 5.5.1 of the preliminary analysis TSD and Product Classes 5A and 7, the California IOUs acknowledged that the breakdown for different ELs was determined by the units that were selected for a direct analysis that were purchased by DOE. The California IOUs requested clarification regarding whether there were other design options, like the dual evaporators, that were not necessarily used primarily to improve efficiency. They pointed to the transition to the R600A refrigerant in the new variable-speed compressor which has its own added costs at EL-3. (California IOUs, Public Meeting Transcript No. 30, p. 28-29)

The Joint Commenters stated DOE is significantly overestimating the incremental cost to meet intermediate efficiency levels for Product Classes 5A and 7 in the preliminary analysis. They stated that DOE included dual evaporators as a design option at EL2, but it is not reasonable to assume that dual evaporators would be employed to meet intermediate ELs (

i.e.,

EL2 and EL3) given their high cost if they became the minimum standard. (Joint Commenters, No. 36, p. 2-3)

In response, DOE notes that while dual evaporators were considered for product classes 5A and 7 in the preliminary analysis, DOE did not include dual evaporators in its engineering analysis for the NOPR, due to its high cost compared to efficiency gains.

The Joint Commenters stated that, since recent state laws and the American Innovation and Manufacturing (“AIM”) Act of 2020 have caused manufacturers to already transition to R-600a and since they expect a full transition to occur well before any amended DOE standards would take effect, DOE should not attribute conversion costs associated with the refrigerant transition to updated efficiency standards. (Joint Commenters, No. 36, p. 5-6) The California IOUs requested that Iso-Butane (R-600a) be included as a refrigerant design option for all products and be incorporated into efficiency levels with positive NPV for Product Classes 5A and 7, before other less cost-effective design options. (California IOUs, No. 33, p. 1-2)

DOE agrees that all manufacturers will have transitioned to R-600a by the time of the compliance date for any new energy conservation standards. Hence, the NOPR analysis assumes that all products will use R-600a at all efficiency levels.

2. Cost Analysis

The cost analysis portion of the engineering analysis is conducted using one or a combination of cost approaches. The selection of cost approach depends on a suite of factors, including the availability and reliability of public information, characteristics of the regulated product, the availability and timeliness of purchasing the

product on the market. The cost approaches are summarized as follows:

Physical teardowns:

Under this approach, DOE physically dismantles a commercially available product, component-by-component, to develop a detailed bill of materials for the product.

Catalog teardowns:

In lieu of physically deconstructing a product, 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 product.

Price surveys:

If neither a physical nor catalog teardown is feasible (for example, for tightly integrated products such as fluorescent lamps, which are infeasible to disassemble and for which parts diagrams are unavailable) or cost-prohibitive and otherwise impractical (

e.g.,

large commercial boilers), DOE conducts price surveys using publicly available pricing data published on major online retailer websites and/or by soliciting prices from distributors and other commercial channels.

In the present case, DOE conducted the analysis using a combination of physical teardowns, catalog teardowns, and price surveys. Where possible, physical teardowns were used to provide a baseline of technology options and pricing for a specific product class at a specific EL level. Then with technology option information, DOE estimated the cost of various design options including compressors, VIPs, and insulation, by extrapolating the costs from price surveys. With specific costs for technology options, DOE was then able to “build-up” or “build-down” from the various teardown models to finish the cost-efficiency curves. DOE used this approach primarily because it allowed the comparison of different technologies and design options.

3. Cost-Efficiency Results

The results of the engineering analysis are presented as cost-efficiency data for each of the efficiency levels for each of the product classes that were analyzed. DOE developed estimates of MPCs for each unit in the teardown sample, and also performed additional modeling based on representative teardown samples, to extend the analysis to cover the range of efficiency levels appropriate for a representative product. In this way, DOE estimated key design details for this range of efficiency levels. The manufacturer interviews provided input for these design details—DOE selected design options that were, to the extent possible, representative of manufacturer input regarding what design options would be required to attain specific efficiency levels for the analyzed product classes. DOE then calculated differential MPCs based on design option differences across the efficiency levels—using the calculated MPCs of the teardown units and the differential MPCs, DOE calculated MPCs for each considered efficiency level. The efficiency levels and design option progression for the analyzed standard-size refrigerator-freezers are presented in Table IV.5 and Table IV.6 of this document. The cells in the table list the design options that would be applied at each higher efficiency level as compared with the next-lower efficiency level. Similarly, the efficiency levels and design options for the other analyzed classes are presented in Table IV.7 of this document. The resulting MPCs for the analyzed classes across the considered efficiency levels are presented in Tables IV.8 and IV.9 of this document. See chapter 5 of the NOPR TSD for additional detail on the engineering analysis.

DOE seeks comment on the method for estimating manufacturing production costs and on the resulting cost-efficiency curves.

See section VII.E of this document for a list of issues on which DOE seeks comment.

Table IV.5—Efficiency Levels and Design Options for Analyzed Standard-Size Refrigerator-Freezers

Product class

(AV

)

EL1

EL2

EL3

EL4

EL5

3 (11.9)

EL Percent

10%

15%

20%

27%.

Design Options Added

Variable Defrost; Higher-EER Compressor

Higher-EER Compressor

Highest-EER Compressor

VIP side walls and doors

Variable-speed compressor system.

3 (21.0)

EL Percent

10%

15%

20%

28%.

Design Options Added

Higher-EER Compressor

Variable Defrost; Higher-EER Compressor

Variable-speed compressor system

40% of Max-tech VIP

VIP side walls and doors.

5 (23.0)

EL Percent

13%

18%

20%

Design Options Added

BLDC Evaporator Fan Motor; Variable-speed compressor system

Highest-EER Variable-speed Compressor

71% of Max-tech VIP

VIP side walls and doors

5 (30.0)

EL Percent

11%

15%

17%

Design Options Added

Efficiency levels were shifted such that the number of EL's matches that of the 23 AV analysis. MPCs were interpolated to these new EL numbers. See Table IV.6IV.6 for design options for the efficiency levels analyzed in the engineering analysis.

5-BI

(26.0)

EL Percent

13%

14%

Design Options Added

Variable-speed compressor system;

43% of Max-tech VIP

90% of Max-tech VIP

VIP side walls and doors

5A (35.0)

EL Percent

11%

16%

21.5%

Design Options Added

Variable-speed compressor system

Highest-EER Variable-speed Compressor; 42% of Max-tech VIP

VIP side walls and doors

7 (31.5)

EL Percent

9.5%

14.5%

19%

22%.

Design Options Added

Highest-EER Compressor

BLDC Evaporator Fan Motor; Variable-speed compressor system

38% of Max-tech VIP

Highest-EER Variable-speed Compressor; 75% of Max-tech VIP

VIP side walls and doors.

Notes:

Percent energy use less than baseline.

For three-door configuration.

Includes two-speed fan control.

The percentage of surface area of VIP as compared with the VIP surface area used in the maximum-technology design, for which VIP would be installed for full coverage of the side walls and doors.

Adjusted Volume in cubic feet.

Table IV.6—Product Class 5, 30 AV, 3-Door Design Options and Manufacturing Production Cost

Percent Energy use below Baseline

13%

17%.

Design Options Added

Highest-EER Compressor; BLDC Evaporator Fan Motor

Variable-speed compressor system;

50% of Max-tech VIP

VIP side walls and doors.

MPC

$748

$776

$809

$845.

Incremental MPC

$28

$62

$97.

Note:

This information is the initial engineering analysis output. LCC, PBP, and other downstream analyses used the EL's and MPC's in Table IV.8.

Table IV.7—Efficiency Levels and Design Options for Analyzed Standard-Size Freezers and Compact Refrigerators, Refrigerator-Freezers, and Freezers

Product class

(AV

)

EL1

EL2

EL3

EL4

9 (29.3)

EL Percent

10%

15%

20%

25%.

Design Options Added

Highest-EER Compressor; Switch to forced-convection condenser; BLDC fans

Highest-EER Variable-speed compressor system

38% of Max-tech VIP

VIP side walls and door.

10 (26.0)

EL Percent

10%

15%

20%

23%.

Design Options Added

Variable-speed compressor system

Wall thickness increase

Highest-EER Variable-speed Compressor

VIP door.

11A (1.7)

EL Percent

10%

15%

20%

32%.

Design Options Added

Wall thickness increase

Higher-EER Compressor

Higher-EER Compressor; VIP sides and door

Highest-EER Compressor.

11A (4.4)

EL Percent

10%

15%

20%

30%.

Design Options Added

Higher-EER Compressor

Wall thickness increase

Higher-EER Compressor

Variable Speed Compressor System;

VIP sides walls and door.

17 (9.0)

EL Percent

10%

15%

20%

Design Options Added

Highest-EER Variable Speed Compressor System;

Variable Defrost

50% of Max-tech VIP

VIP side walls and door panels.

18 (8.9)

EL Percent

10%

15%

20%

30%.

Design Options Added

Higher-EER Compressor; Variable Defrost

Wall thickness increase

Higher-EER Compressor; VIP door

Variable Speed Compressor System.

Notes:

Percent energy use less than baseline.

Includes two-speed fan control.

The percentage of surface area of VIP as compared with the VIP surface area used in the maximum-technology design, for which VIP would be installed for full coverage of the side walls and doors.

Adjusted Volume in cubic feet.

Table IV.8—Cost-Efficiency Curves for Standard-Size Refrigerator-Freezers

Product class

(AV

)

EL0

EL1

EL2

EL3

EL4

EL5

3 (11.9)

EL Percent

10%

15%

20%

27%

MPC

$419

$426

$427

$429

$478

$507

Incremental MPC

$7.14

$8.60

$10

$59

$88

3 (21.0)

EL Percent

10%

15%

20%

28%

MPC

$511

$513

$530

$554

$580

$618

Incremental MPC

$1.59

$19

$43

$69

$107

5 (23.0)

EL Percent

13%

18%

20%

MPC

$666

$691

$693

$736

$753

Incremental MPC

$25

$27

$70

$87

5 (30.0)

EL Percent

11%

15%

17%

MPC

$748

$773

$796

$827

$845

Incremental MPC

$26

$48

$79

$97

5-BI

(26.0)

EL Percent

10%

15%

16%

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