Energy Conservation Program: Energy Conservation Standards for Walk-In Coolers and Freezers
Federal RegisterSep 5, 2023
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DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2017-BT-STD-0009]
RIN 1905-AD79
Energy Conservation Program: Energy Conservation Standards for Walk-In Coolers and Freezers
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking and announcement of public meeting.
SUMMARY:
The Energy Policy and Conservation Act, as amended (“EPCA”), prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including walk-in coolers and freezers (“walk-ins” or “WICFs”). EPCA also requires the U.S. Department of Energy (“DOE”) to periodically determine whether more-stringent, standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking (“NOPR”), DOE proposes amended energy conservation standards for walk-ins, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
DATES:
Comments:
DOE will accept comments, data, and information regarding this NOPR no later than November 6, 2023.
Meeting:
DOE will hold a public meeting via webinar on Wednesday, September 27, 2023, from 1:00 p.m. to 4:00 p.m. See section VII, “Public Participation,” for webinar registration information, participant instructions and information about the capabilities available to webinar participants.
Comments regarding the likely competitive impact of the proposed standard should be sent to the Department of Justice contact listed in the
ADDRESSES
section on or before October 5, 2023.
Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at
www.regulations.gov
under docket number EERE-2017-BT-STD-0009. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, identified by docket number EERE-2017-BT-STD-0009, by any of the following methods:
(1)
Email: WICF2017STD0009@ee.doe.gov.
Include the docket number EERE-2017-BT-STD-0009 in the subject line of the message.
(2)
Non-electronic submissions:
Please contact (202) 287-1445 for instructions if an electronic copy cannot be submitted.
No telefacsimiles (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on this process, see section VII of this document.
Docket:
The docket for this activity, which includes
Federal Register
notices, comments, and other supporting documents/materials, is available for review at
www.regulations.gov.
All documents in the docket are listed in the
www.regulations.gov
index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.
The docket web page can be found at
www.regulations.gov/docket/EERE-2017-BT-STD-0009.
The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section VII of this document for information on how to submit comments through
www.regulations.gov.
EPCA requires the Attorney General to provide DOE a written determination of whether the proposed standard is likely to lessen competition. The U.S. Department of Justice Antitrust Division invites input from market participants and other interested persons with views on the likely competitive impact of the proposed standard. Interested persons may contact the Division at
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 rulemaking.
FOR FURTHER INFORMATION CONTACT:
Mr. Troy Watson, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Email:
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
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Walk-Ins
C. Deviation From Process Rule
1. Public Comment Period
III. General Discussion
A. General Comments
B. Scope of Coverage
C. Test Procedure
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared To Increase in Price (LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Equipment
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Equipment Classes
a. Doors
b. Panels
c. Refrigeration Systems
2. Technology Options
a. Fully Assembled Walk-Ins
b. Doors and Panels
c. Refrigeration Systems
B. Screening Analysis
1. Screened Out Technologies
a. Fully Assembled Walk-Ins
b. Doors and Panels
c. Refrigeration Systems
2. Remaining Technologies
a. Doors and Panels
b. Refrigeration Systems
C. Engineering Analysis
1. Efficiency Analysis
a. Display Doors
b. Non-Display Doors
c. Panels
d. Dedicated Condensing Units and Single-Packaged Dedicated Systems
e. Unit Coolers
2. Cost Analysis
a. Teardown Analysis
b. Cost Estimation Method
c. Manufacturing Production Costs
d. Manufacturer Markup and Shipping Costs
3. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
1. Trial Standard Levels
2. Energy Use of Envelope Components
3. Energy Use of Refrigeration Systems
a. Fan Power
b. Nominal Daily Run Hours
4. Estimated Annual Energy Consumption
F. Life-Cycle Cost and Payback Period Analysis
1. Equipment Cost
2. Consumer Sample
3. Installation Cost
4. Annual Energy Consumption
5. Energy Prices
a. Future Electricity Prices
6. Maintenance and Repair Costs
7. Equipment Lifetimes
8. Discount Rates
9. Energy Efficiency Distribution in the No-New-Standards Case
10. Payback Period Analysis
G. Shipments Analysis
1. Price Elasticity
2. Shipments Results
H. National Impact Analysis
1. Product Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
1. High Warm Air-Infiltration Applications
2. Small Businesses
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Capital and Product Conversion Costs
d. Manufacturer Markup Scenarios
3. Manufacturer Interviews
a. Increasing Insulation Thickness
b. Reduced Anti-Sweat Heat
c. Refrigerant Regulation
4. Discussion of MIA Comments
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous Oxide
2. Monetization of Other Emissions Impacts
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Walk-Ins Standards
a. Doors
b. Panels
c. Refrigeration Systems
2. Annualized Benefits and Costs of the Proposed Standards
D. Reporting, Certification, and Sampling Plan
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866, 13563, and 14094
B. Review Under the Regulatory Flexibility Act
1. Description of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, Rule
3. Description on Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements Including Differences in Cost, if Any, for Different Groups of Small Entities
a. Doors
b. Panels
c. Refrigeration Systems
5. Duplication, Overlap, and Conflict With Other Rules and Regulations
6. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for Distribution
C. Conduct of the Webinar
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
The Energy Policy and Conservation Act, Public Law 94-163, as amended (“EPCA”),
1
authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part C of EPCA,
2
established the Energy Conservation Program for Certain Industrial Equipment. (42 U.S.C. 6311-6317) Such equipment includes walk-ins,
3
the subject of this rulemaking.
1
All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020), which reflect the last statutory amendments that impact Parts A and A-1 of EPCA.
2
For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.
3
Walk-in coolers and walk-in freezers are defined as an enclosed storage space, including but not limited to panels, doors, and refrigeration systems, refrigerated to temperatures, respectively, above, and at or below 32 degrees Fahrenheit that can be walked into, and has a total chilled storage area of less than 3,000 square feet; however, the terms do not include products designed and marketed exclusively for medical, scientific, or research purposes. 10 CFR 431.302.
Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later than 6 years after issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a notice of proposed rulemaking including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6316(a); 42 U.S.C. 6295(m))
In accordance with these and other statutory provisions discussed in this document, DOE analyzed the benefits and burdens of three trial standard levels (“TSLs”) for walk-ins. The TSLs and their associated benefits and burdens are discussed in detail in sections V.A through V.C of this document. As discussed in section V.C of this document, DOE has tentatively determined that TSL 2 represents the maximum improvement in energy efficiency that is technologically feasible and economically justified. The proposed standards for walk-in non-display doors, which are expressed in maximum daily energy consumption in kilowatt-hours per day (“kWh/day”), are shown in Table I.1. These proposed standards, if adopted, would apply to all non-display doors of walk-ins listed in Table I.1 manufactured in, or imported into, the United States starting on the date 3 years after the publication of the final rule for this proposed rulemaking.
Table I.1—Proposed Energy Conservation Standards for Walk-In Non-Display Doors
[TSL 2]
Equipment class
Display/non-display
Opening mechanism
Temperature
Maximum daily energy
consumption
(kWh/day) *
Non-Display
Manual
Medium
Low
0.01 × A
nd
+ 0.25
0.06 × A
nd
+ 1.32
Manual
Medium
Low
0.01 × A
nd
+ 0.39
0.05 × A
nd
+ 1.56
* A
nd
is the representative value of surface area of the non-display door as determined in accordance with the DOE test procedure at 10 CFR part 431, subpart R, appendix A and applicable sampling plans.
The proposed standards for walk-in refrigeration systems, which are expressed as annual walk-in energy factor 2 (“AWEF2”) in British thermal units per Watt-hour (“Btu/W-h”), are shown in Table I.2. These proposed standards, if adopted, would apply to all walk-in refrigeration systems listed in Table I.2 manufactured in, or imported into, the United States starting on the date 3 years after the publication of the final rule for this proposed rulemaking.
Table I.2—Proposed Energy Conservation Standards for Walk-In Refrigeration Systems
[TSL 2]
Equipment class
Minimum AWEF2
(Btu/W-h) *
Dedicated Condensing System—High, Indoor, Non-Ducted with a Net Capacity (q
net
) of:
<7,000 Btu/h
7.80E-04 × q
net
+ 2.20
≥7,000 Btu/h
7.66
Dedicated Condensing system—High, Outdoor, Non-Ducted with a Net Capacity (q
net
) of:
<7,000 Btu/h
1.02E-03 × q
net
+ 2.47
≥7,000 Btu/h
9.62
Dedicated Condensing system—High, Indoor, Ducted with a Net Capacity (q
net
) of:
<7,000 Btu/h
2.46E-04 × q
net
+ 1.55
≥7,000 Btu/h
3.27
Dedicated Condensing system—High, Outdoor, Ducted with a Net Capacity (q
net
) of:
<7,000 Btu/h
3.76E-04 × q
net
+ 1.78
≥7,000 Btu/h
4.41
Dedicated Condensing unit and Matched Refrigeration System—Medium, Indoor with a Net Capacity (q
net
) of:
<8,000 Btu/h
5.58
≥8,000 Btu/h and <25,000 Btu/h
3.00E-05 × q
net
+ 5.34
≥25,000 Btu/h
6.09
Dedicated Condensing unit and Matched Refrigeration System—Medium, Outdoor with a Net Capacity (q
net
) of:
<25,000 Btu/h
2.13E-05 × q
net
+ 7.15
≥25,000 Btu/h
7.68
Dedicated Condensing unit and Matched Refrigeration System—Low, Indoor with a Net Capacity (q
net
) of:
<25,000 Btu/h
2.50E-05 × q
net
+ 2.36
≥25,000 Btu/h and <54,000 Btu/h
1.72E-06 × q
net
+ 2.94
≥54,000 Btu/h
3.03
Dedicated Condensing unit and Matched Refrigeration System—Low, Outdoor with a Net Capacity (q
net
) of:
<9,000 Btu/h
9.83E-05 × q
net
+ 2.63
≥9,000 Btu/h and <25,000 Btu/h
3.06E-05 × q
net
+ 3.23
≥25,000 Btu/h and <75,000 Btu/h
4.96E-06 × q
net
+ 3.88
≥75,000 Btu/h
4.25
Single-Packaged Dedicated Condensing system—Medium, Indoor with a Net Capacity (q
net
) of:
<9,000 Btu/h
9.86E-05 × q
net
+ 4.91
≥9,000 Btu/h
5.8
Single-Packaged Dedicated Condensing system—Medium, Outdoor with a Net Capacity (q
net
) of:
<9,000 Btu/h
2.47E-04 × q
net
+ 4.89
≥9,000 Btu/h
7.11
Single-Packaged Dedicated Condensing system—Low, Indoor with a Net Capacity (q
net
) of:
<6,000 Btu/h
8.00E-05 × q
net
+ 1.8
≥6,000 Btu/h
2.28
Single-Packaged Dedicated Condensing system—Low, Outdoor with a Net Capacity (q
net
) of:
<6,000 Btu/h
1.63E-04 × q
net
+ 1.8
≥6,000 Btu/h
2.77
Unit Cooler—High Non-Ducted with a Net Capacity (q
net
) of:
<9,000 Btu/h
10.34
≥9,000 Btu/h and <25,000 Btu/h
3.83E-04 × q
net
+ 6.9
≥25,000 Btu/h
16.46
Unit Cooler—High Ducted with a Net Capacity (q
net
) of:
<9,000 Btu/h
6.93
≥9,000 Btu/h and <25,000 Btu/h
3.64E-04 × q
net
+ 3.66
≥25,000 Btu/h
12.76
Unit Cooler—Medium
9.65
Unit Cooler—Low
4.57
* q
net
is the representative value of net capacity in Btu/h as determined in accordance with the DOE test procedure at 10 CFR part 431, subpart R, appendix C1 and applicable sampling plans.
A. Benefits and Costs to Consumers
Table I.3 through Table I.5 present DOE's evaluation of the economic impacts of the proposed standards on consumers of walk-ins, as measured by the average life-cycle cost (“LCC”) savings and the simple payback period (“PBP”).
4
The average LCC savings are positive for all equipment classes, and the PBP is less than the average lifetime of walk-ins, which is estimated to be between 8 and 20 years (see section IV.F.10 of this document).
4
The average LCC savings refer to consumers that are affected by a standard and are measured relative to the efficiency distribution in the no-new-standards case, which depicts the market in the compliance year in the absence of new or amended standards (see section IV.F.9 of this document). The simple PBP, which is designed to compare specific efficiency levels, is measured relative to the baseline product (see section IV.F of this document).
5
All monetary values in this document are expressed in 2022 dollars.
Table I.3—Impacts of Proposed Energy Conservation Standards on Consumers of Walk-In Display and Non-Display Doors
[TSL 2]
5
Display/non-display
Opening mechanism
Temperature
Average
LCC savings
(2022$)
Simple
payback
period
(years)
Display
Manual
Low
Medium
Non-Display
Manual
Low
723
1.3
Medium
86
3.2
Motorized
Low
1,192
1.0
Medium
113
2.4
Table I.4—Impacts of Proposed Energy Conservation Standards on Consumers of Walk-In Panels
[TSL 2]
Equipment
Temperature
Average
LCC savings
(2022$)
Simple
payback
period
(years)
Structural
Low
Medium
Floor
Low
Table I.5—Impacts of Proposed Energy Conservation Standards on Consumers of Walk-in Refrigeration Systems
[TSL 2]
System
Temperature
Location
Average
LCC savings
(2022$)
Simple
payback
period
(years)
Dedicated Condensing Unit and Matched Refrigeration System
Low
Indoor
Outdoor
163
172
4.0
3.6
Medium
Indoor
Outdoor
567
136
3.4
2.6
Unit Cooler
Low
N/A
1,306
1.2
Medium
212
2.0
High
High, Ducted
237
0.7
Matched Refrigeration Systems and Single-Packaged Dedicated Systems
High, Non-Ducted
Indoor
Outdoor
124
126
1.3
2.9
High, Ducted
Indoor
Outdoor
296
305
1.7
3.4
Single-Packaged Dedicated Systems
Low
Indoor
Outdoor
180
3.8
Medium
Indoor
Outdoor
103
177
3.5
1.2
DOE's analysis of the impacts of the proposed standards on consumers is described in section IV.F of this document.
B. Impact on Manufacturers
6
6
All monetary values in this document are expressed in 2022 dollars unless otherwise noted.
The industry net present value (“INPV”) is the sum of the discounted cash flows to the industry from the base year through the end of the analysis period (2023-2056). Using a real discount rate of 9.4 percent for doors, 10.5 percent for panels, and 10.2 percent for refrigeration systems, DOE estimates that the INPV for manufacturers of walk-in display doors, non-display doors, panels, and refrigeration systems in the case without amended standards is $278.0 million, $536.7 million, $875.2 million, and $490.1 million, respectively. Under the proposed standards, all walk-in display door equipment classes remain at the baseline efficiency level. As a result, there are no changes to INPV and no conversion costs for display door manufacturers. Under the proposed standards, the change in INPV for non-display door manufacturers is estimated to range from −4.8 percent to −2.6 percent, which is approximately −$25.5 million to −$14.2 million. Under the proposed standards, all walk-in panel equipment classes remain at the baseline efficiency level. As a result, there are no changes to INPV and no conversion costs for panel manufacturers. Under the proposed standards, the change in INPV for refrigeration system manufacturers is estimated to range from −9.8 percent to −7.7 percent, which is approximately −$47.8 million to −$37.9 million. In order to bring equipment into compliance with amended standards, it is estimated that the walk-in non-display door and refrigeration system industries would incur total conversion costs of $28.9 million and $60.1 million, respectively.
DOE's analysis of the impacts of the proposed standards on manufacturers is described in section IV.J of this document. The analytic results of the manufacturer impact analysis (“MIA”) are presented in section V.B.2 of this document.
C. National Benefits and Costs
DOE's analyses indicate that the proposed energy conservation standards for walk-ins would save a significant amount of energy. Relative to the case without amended standards, the lifetime energy savings for walk-ins purchased in the 30-year period that begins in the anticipated year of compliance with the amended standards (2027-2056) amount to 1.51 quadrillion British thermal units (“Btu”), or quads.
7
This represents a savings of 6 percent relative to the energy use of these products in the case without amended standards (referred to as the “no-new-standards case”).
7
The quantity refers to full-fuel-cycle (“FFC”) energy savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and, thus, presents a more complete picture of the impacts of energy efficiency standards. For more information on the FFC metric, see section IV.H.2 of this document.
The cumulative net present value (“NPV”) of total consumer benefits of the proposed standards for walk-ins ranges from $1.45 billion (at a 7-percent discount rate) to $3.66 billion (at a 3-percent discount rate). This NPV expresses the estimated total value of future operating-cost savings minus the estimated increased product costs and installation costs for walk-ins purchased in 2027-2056.
In addition, the proposed standards for walk-ins are projected to yield significant environmental benefits. DOE estimates that the proposed standards would result in cumulative emission reductions (over the same period as for energy savings) of 28.5 million metric tons (“Mt”)
8
of carbon dioxide (“CO
2
”), 8.8 thousand tons of sulfur dioxide (“SO
2
”), 52.9 thousand tons of nitrogen oxides (“NO
X
”), 237.4 thousand tons of methane (“CH
4
”), 0.3 thousand tons of nitrous oxide (“N
2
O”), and 0.1 tons of mercury (“Hg”).
9
8
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
are presented in short tons.
9
DOE calculated emissions reductions relative to the no-new-standards-case, which reflects key assumptions in the
Annual Energy Outlook 2023
(
“AEO2023”
).
AEO2023
reflects, to the extent possible, laws and regulations adopted through mid-November 2022, including the Inflation Reduction Act. See section IV.K of this document for further discussion of
AEO2023
assumptions that effect air pollutant emissions.
DOE estimates the value of climate benefits from a reduction in greenhouse gases (GHG) using four different estimates of the social cost of CO
2
(“SC-CO
2
”), the social cost of methane (“SC-CH
4
”), and the social cost of nitrous oxide (“SC-N
2
O”). Together these represent the social cost of GHG (“SC-GHG”). DOE used interim SC-GHG values (in terms of benefit per ton of GHG avoided) developed by an Interagency Working Group on the Social Cost of Greenhouse Gases (“IWG”).
10
The derivation of these values is discussed in section IV.L of this document. For presentational purposes, the climate benefits associated with the average SC-GHG at a 3-percent discount rate are estimated to be $1.6 billion. DOE does not have a single central SC-GHG point estimate and it emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates.
10
To monetize the benefits of reducing GHG emissions this analysis uses the interim estimates presented in the Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 published in February 2021 by the IWG. (“February 2021 SC-GHG TSD”).
www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.
DOE estimated the monetary health benefits of SO
2
and NO
X
emissions reductions using benefit-per-ton estimates from the Environmental Protection Agency,
11
as discussed in
section IV.L of this document. DOE estimated the present value of the health benefits would be $1.3 billion using a 7-percent discount rate, and $3.2 billion using a 3-percent discount rate.
12
DOE is currently only monetizing health benefits from changes in ambient fine particulate matter (PM
2.5
) concentrations from two precursors (SO
2
and NO
X
), and from changes in ambient ozone from one precursor (for NO
X
), but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions.
11
U.S. EPA. Estimating the Benefit per Ton of Reducing Directly Emitted PM
2.5
, PM
2.5
Precursors and Ozone Precursors from 21 Sectors. Available at
www.epa.gov/benmap/estimating-benefit-ton-reducing-pm25-precursors-21-sectors.
12
DOE estimates the economic value of these emissions reductions resulting from the considered TSLs for the purpose of complying with the requirements of Executive Order 12866.
Table I.6 summarizes the monetized benefits and costs expected to result from the proposed standards for walk-ins. There are other important unquantified effects, including certain unquantified climate benefits, unquantified public health benefits from the reduction of toxic air pollutants and other emissions, unquantified energy security benefits, and distributional effects, among others.
Table I.6—Summary of Monetized Benefits and Costs of Proposed Energy Conservation Standards for Walk-Ins
[TSL 2]
Billion 2022$
3% discount rate
Consumer Operating Cost Savings
4.7
Climate Benefits *
1.6
Health Benefits **
3.2
Total Benefits †
9.5
Consumer Incremental Product Costs ‡
1.3
Net Benefits
8.2
Change in Producer Cashflow (INPV ‡‡)
(0.07) − (0.05)
7% discount rate
Consumer Operating Cost Savings
2.2
Climate Benefits * (3% discount rate)
1.6
Health Benefits **
1.3
Total Benefits †
5.1
Consumer Incremental Product Costs ‡
0.7
Net Benefits
4.4
Change in Producer Cashflow (INPV ‡‡)
(0.07) − (0.05)
Note:
This table presents the costs and benefits associated with walk-in coolers and freezers shipped in 2027-2056. These results include consumer, climate, and health benefits that accrue after 2056 from the walk-in coolers and freezers shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO
2
), methane (SC-CH
4
), and nitrous oxide (SC-N
2
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; however, DOE emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the
Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NO
X
and SO
2
. DOE is currently only monetizing (for SO
2
and NO
X
) PM
2.5
precursor health benefits and (for NO
X
) 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 3-percent discount rate.
‡ Costs include incremental equipment costs as well as installation costs.
‡‡ Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis as discussed in detail. See sections IV.F and IV.H of this document. DOE's NIA includes all impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the manufacturer to manufacture the equipment and ending with the increase in price experienced by the consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present value of all changes in industry cash flow, including changes in production costs, capital expenditures, and manufacturer profit margins. Change in INPV is calculated using the industry weighted average cost of capital values of 9.4 percent for walk-in non-display doors and 10.2 percent for walk-in refrigeration systems that are estimated in the MIA (see chapter 12 of the NOPR TSD for a complete description of the industry weighted average cost of capital). For walk-ins, those values are −$73 million to −$52 million. DOE accounts for that range of likely impacts in analyzing whether a TSL is economically justified. See section V.C of this document. DOE is presenting the range of impacts to the INPV under two markup scenarios: the Preservation of Gross Margin scenario, which is the manufacturer markup scenario used in the calculation of Consumer Operating Cost Savings in this table, and the Preservation of Operating Profit Markup scenario, where DOE assumed manufacturers would not be able to increase per-unit operating profit in proportion to increases in manufacturer production costs. DOE includes the range of estimated INPV in the above table, drawing on the MIA explained further in section IV.J of this document, to provide additional context for assessing the estimated impacts of this proposal to society, including potential changes in production and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. If DOE were to include the INPV into the net benefit calculation for this proposed rule, the net benefits would range from $8.13 billion to $8.15 billion at 3-percent discount rate and would range from $4.33 billion to $4.35 billion at 7-percent discount rate. Parentheses ( ) indicate negative values. DOE seeks comment on this approach.
The benefits and costs of the proposed standards can also be expressed in terms of annualized values. The monetary values for the total annualized net benefits are (1) the reduced consumer operating costs, minus (2) the increase in product purchase prices and installation costs, plus (3) the value of climate and health benefits of emission reductions, all annualized.
13
13
To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2023, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE calculated a present value associated with each year's shipments in the year in which the shipments occur (
e.g.,
2030), and then discounted the present value from each year to 2023. Using the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in the compliance year, that yields the same present value.
The national operating cost savings are domestic private U.S. consumer monetary savings that occur as a result of purchasing the covered products and are measured for the lifetime of walk-ins shipped in 2027-2056. The benefits associated with reduced emissions achieved as a result of the proposed standards are also calculated based on the lifetime of walk-ins shipped in 2027-2056. Total benefits for both the 3-percent and 7-percent cases are presented using the average GHG social costs with 3-percent discount rate. Estimates of SC-GHG values are presented for all four discount rates in section IV.L of this document.
Table I.7 presents the total estimated monetized benefits and costs associated with the proposed standard, expressed in terms of annualized values. The results under the primary estimate are as follows.
Using a 7-percent discount rate for consumer benefits and costs and health benefits from reduced NOx and SO
2
emissions, and the 3-percent discount rate case for climate benefits from reduced GHG emissions, the estimated cost of the standards proposed in this rule is $70.7 million per year in increased equipment costs, while the estimated annual benefits are $214.1 million in reduced equipment operating costs, $90.4 million in climate benefits, and $132.2 million in health benefits. In this case the net benefit would amount to $366.0 million per year.
Using a 3-percent discount rate for all benefits and costs, the estimated cost of the proposed standards is $72.4 million per year in increased equipment costs, while the estimated annual benefits are $260.0 million in reduced operating costs, $90.4 million in climate benefits, and $177.7 million in health benefits. In this case, the net benefit would amount to $455.7 million per year.
Table I.7—Annualized Benefits and Costs of Proposed Energy Conservation Standards for Walk-ins
[TSL 2]
Million 2022$/year
Primary
estimate
Low-net-benefits estimate
High-net-benefits estimate
3% discount rate
Consumer Operating Cost Savings
260.0
265.3
264.9
Climate Benefits *
90.4
92.6
90.0
Health Benefits **
177.7
182.1
177.0
Total Monetized Benefits †
528.1
540.0
531.9
Consumer Incremental Product Costs ‡
72.4
102.6
64.7
Monetized Net Benefits
455.7
437.4
467.2
Change in Producer Cashflow (INPV‡‡)
(7.6) − (5.4)
(7.6) − (5.4)
(7.6) − (5.4)
7% discount rate
Consumer Operating Cost Savings
214.1
218.8
218.3
Climate Benefits * (3% discount rate)
90.4
92.6
90.0
Health Benefits **
132.2
135.3
131.7
Total Monetized Benefits †
436.7
446.7
440.0
Consumer Incremental Product Costs ‡
70.7
95.4
64.1
Monetized Net Benefits
366.0
351.2
376.0
Change in Producer Cashflow (INPV ‡‡)
(7.6) − (5.4)
(7.6) − (5.4)
(7.6) − (5.4)
Note:
This table presents the costs and benefits associated with walk-ins shipped in 2027-2056. These results include consumer, climate, and health benefits that accrue after 2056 from the products shipped in 2027-2056. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the AEO2023 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition, incremental equipment costs reflect a medium decline rate in the Primary Estimate, a low decline rate in the Low Net Benefits Estimate, and a high decline rate in the High Net Benefits Estimate. The methods used to derive projected price trends are explained in sections IV.F.1 and IV.H.3 of this document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this document). For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the
Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NO
X
and SO
2
. DOE is currently only monetizing (for SO
2
and NO
X
) PM
2.5
precursor health benefits and (for NO
X
) 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 benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate.
‡ Costs include incremental equipment costs as well as installation costs.
‡‡ Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis as discussed in detail below. See sections IV.F and IV.H of this document. DOE's NIA includes all impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the manufacturer to manufacture the product and ending with the increase in price experienced by the consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present value of all changes in industry cash flow, including changes in production costs, capital expenditures, and manufacturer profit margins. The annualized change in INPV is calculated using the industry weighted average cost of capital values of 9.4 percent for walk-in non-display doors and 10.2 percent for walk-in refrigeration systems that are estimated in the MIA (see chapter 12 of the NOPR TSD for a complete description of the industry weighted average cost of capital). For walk-ins, those values are −$7.6 million to −$5.4 million. DOE accounts for that range of likely impacts in analyzing whether a TSL is economically justified. See section V.C of this document. DOE is presenting the range of impacts to the INPV under two markup scenarios: the Preservation of Gross Margin scenario, which is the manufacturer markup scenario used in the calculation of Consumer Operating Cost Savings in this table, and the Preservation of Operating Profit Markup scenario, where DOE assumed manufacturers would not be able to increase per-unit operating profit in proportion to increases in manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the above table, drawing on the MIA explained further in section IV.J of this document, to provide additional context for assessing the estimated impacts of this proposal to society, including potential changes in production and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. If DOE were to include the INPV into the annualized net benefit calculation for this proposed rule, the annualized net benefits would range from $448.1 million to $450.3 million at 3-percent discount rate and would range from $358.4 million to $360.6 million at 7-percent discount rate. Parentheses ( ) indicate negative values. DOE seeks comment on this approach.
DOE's analysis of the national impacts of the proposed standards is described in sections IV.H, IV.K and IV.L of this document.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. Specifically, with regards to technological feasibility, equipment achieving these standard levels are already commercially available for all equipment classes covered by this proposal. As for economic justification, DOE's analysis shows that the benefits of the proposed standard exceed, to a great extent, the burdens of the proposed standards.
Using a 7-percent discount rate for consumer benefits and costs and NOx and SO
2
reduction benefits, and a 3-percent discount rate case for GHG social costs, the estimated cost of the proposed standards for walk-ins is $70.7 million per year in increased equipment costs, while the estimated annual benefits are $214.1 million in reduced equipment operating costs, $90.4 million in climate benefits and $132.2 million in health benefits. The net benefit amounts to $366.0 million per year.
The significance of the savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking.
14
For example, some covered products and equipment have substantial energy consumption occur during periods of peak energy demand. The impacts of these products on the energy infrastructure can be more pronounced than products with relatively constant demand. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis.
14
Procedures, Interpretations, and Policies for Consideration in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment, 86 FR 70892, 70901 (Dec. 13, 2021).
As previously mentioned, the standards are projected to result in estimated national energy savings of 1.55 quad FFC for walk-in doors, panels and refrigeration systems shipped between 2027 and 2056, the equivalent of the primary annual energy use of 42.7 million homes, or 1.4 million homes per year of the analysis. In addition, they are projected to reduce CO
2
emissions by 28.5 Mt for walk-in doors, panels and refrigeration systems shipped between 2027 and 2056.
15
Based on these findings, DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B). A more detailed discussion of the basis for these tentative conclusions is contained in the remainder of this document and the accompanying technical support document (“TSD”).
15
These results include benefits to consumers which accrue after 2056 from the equipment shipped in 2027-2056.
DOE also considered more-stringent energy efficiency levels as potential standards, and is still considering them in this rulemaking. However, DOE has tentatively concluded that the potential burdens of the more-stringent energy efficiency levels would outweigh the projected benefits.
Based on consideration of the public comments DOE receives in response to this document and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy efficiency levels presented in this document that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority underlying this proposed rule, as well as some of the relevant historical background related to the establishment of standards for walk-ins.
A. Authority
EPCA authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment.
Title III, Part C of EPCA, added by Public Law 95-619, Title IV, section 441(a) (42 U.S.C. 6311-6317, as codified), established the Energy Conservation Program for Certain Industrial Equipment, which sets forth a variety of provisions designed to improve energy efficiency. This equipment includes walk-ins, the subject of this document. (42 U.S.C. 6311(1)(G)) EPCA prescribed initial standards for these products. (42 U.S.C. 6313(f)) EPCA specifically prescribed that no later than January 1, 2020, the Secretary shall publish a final rule to determine if the standards should be amended. (42 U.S.C. 6313(f)(5)) EPCA further provides that, not later than 6 years after the issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a NOPR including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1)).
The energy conservation program under EPCA consists essentially of four parts: (1) testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA include definitions (42 U.S.C. 6311), test procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315), energy conservation standards (42
U.S.C. 6313), and the authority to require information and reports from manufacturers (42 U.S.C. 6316; 42 U.S.C. 6296).
Federal energy efficiency requirements for covered equipment established under EPCA generally supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6316(a) and (b); 42 U.S.C. 6297) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions set forth under EPCA. (See 42 U.S.C. 6316(a) (applying the preemption waiver provisions of 42 U.S.C. 6297))
Subject to certain criteria and conditions, DOE is required to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of each covered equipment during a representative average use cycle and that are not unduly burdensome to conduct. (42 U.S.C. 6314(a)(2)) Manufacturers of covered equipment must use the Federal test procedures as the basis for: (1) certifying to DOE that their equipment complies with the applicable energy conservation standards adopted pursuant to EPCA (42 U.S.C. 6316(a); 42 U.S.C. 6295(s)), and (2) making representations about the efficiency of that equipment (42 U.S.C. 6314(d)). Similarly, DOE must use these test procedures to determine whether the equipment complies with relevant standards promulgated under EPCA. (42 U.S.C. 6316(a); 42 U.S.C. 6295(s)) The DOE test procedures for walk-ins appear at title 10 of the Code of Federal Regulations (“CFR”) part 431, subpart R, appendices A, B, C, and C1.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered equipment, including walk-ins. Any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that the Secretary of Energy determines is technologically feasible and economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3))
Moreover, DOE may not prescribe a standard: (1) for certain products, including walk-ins, if no test procedure has been established for the product, or (2) if DOE determines by rule that the standard is not technologically feasible or economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:
(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;
(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (“Secretary”) considers relevant.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States in any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an energy conservation standard for a covered product that has two or more subcategories. DOE must specify a different standard level for a type or class of product that has the same function or intended use, if DOE determines that products within such group: (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q)(2))
B. Background
1. Current Standards
The current energy conservation standards for walk-ins are set forth in DOE's regulations at 10 CFR 431.306. The current energy conservation standards for walk-in doors are in terms of maximum daily energy consumption, which is measured in kWh/day (see Table II.1). The current energy conservation standards for walk-in panels are in terms of R-value, which is measured in h-ft
2
-°F/Btu (see Table II.2). The current energy conservation standards for refrigeration systems are in terms of AWEF, which is measured in Btu/W-h (see Table II.3).
Table II.1—Federal Energy Conservation Standards for Walk-in Coolers and Walk-In Freezer Doors
Equipment class
Equations for maximum daily energy consumption
(kWh/day)
Display door, medium-temperature
0.04 × A
dd
+ 0.41.
Display door, low-temperature
0.15 × A
dd
+ 0.29.
Passage door, medium-temperature
0.05 × A
nd
+ 1.7.
Passage door, low-temperature
0.14 × A
nd
+ 4.8.
Freight door, medium-temperature
0.04 × A
nd
+ 1.9.
Freight door, low-temperature
0.12 × A
nd
+ 5.6.
A
dd
or A
nd
= surface area of the display door or non-display door, respectively, expressed in ft
2
, as determined in appendix A to subpart R of 10 CFR part 431.
Table II.2—Federal Energy Conservation Standards for Walk-In Coolers and Walk-In Freezer Panels
Equipment class
Minimum
R-value
(h-ft
2
-°F/Btu)
Wall or ceiling panels, medium-temperature
25
Wall or ceiling panels, low-temperature
32
Floor panels, low-temperature
28
Table II.3—Federal Energy Conservation Standards for Walk-In Coolers and Walk-In Freezer Refrigeration Systems
Equipment class
Minimum AWEF
(Btu/W-h)
Dedicated condensing system, medium-temperature, indoor
5.61.
Dedicated condensing system, medium-temperature, outdoor
7.60.
Dedicated condensing system, low-temperature, indoor with a net capacity (q
net
) of <6,500 British thermal units per hour (“Btu/h”)
9.091 × 10
5
× q
net
+ 1.81.
Dedicated condensing system, low-temperature, indoor with a net capacity (q
net
) of ≥6,500 Btu/h
2.40.
Dedicated condensing system, low-temperature, outdoor with a net capacity (q
net
) of <6,500 Btu/h
6.522 × 10
−5
× q
net
+ 2.73.
Dedicated condensing system, low-temperature, outdoor with a net capacity (q
net
) of ≥6,500 Btu/h
3.15.
Unit cooler, medium-temperature
9.00.
Unit cooler, low-temperature, indoor with a net capacity (q
net
) of <15,500 Btu/h
1.575 × 10
−5
× q
net
+ 3.91.
Unit cooler, low-temperature, indoor with a net capacity (q
net
) of ≥15,500 Btu/h
4.15.
Where q
net
is net capacity as determined in accordance with 10 CFR 431.304 and certified in accordance with 10 CFR part 429
2. History of Standards Rulemaking for Walk-Ins
In a final rule published on June 3, 2014 (“June 2014 Final Rule”), DOE prescribed the energy conservation standards for walk-in doors, panels, and refrigeration systems manufactured on and after June 5, 2017. 79 FR 32050. After publication of the June 2014 Final Rule, the Air-Conditioning, Heating and Refrigeration Institute (“AHRI”) and Lennox International, Inc. (“Lennox”), a manufacturer of walk-in refrigeration systems, filed petitions for review of DOE's final rule and DOE's subsequent denial of a petition for reconsideration of the rule (79 FR 59090 (October 1, 2014)) with the United States Court of Appeals for the Fifth Circuit.
Lennox Int'l
v.
Dep't of Energy,
Case No. 14-60535 (5th Cir.). A settlement agreement was reached among the parties under which the Fifth Circuit vacated energy conservation standards for six of the refrigeration system equipment classes—the two standards applicable to multiplex condensing refrigeration systems (subsequently re-named as “unit coolers”) operating at medium and low-temperatures and the four standards applicable to dedicated condensing refrigeration systems operating at low-temperatures.
16
After the Fifth Circuit issued its order, DOE established a Working Group to negotiate energy conservation standards to replace the six vacated standards. 80 FR 46521 (August 5, 2015). The Working Group assembled its recommendations into a Term Sheet (see Docket EERE-2015-BT-STD-0016-0056) that was presented to, and approved by, the Appliance Standards and Rulemaking Federal Advisory Committee on December 18, 2015. (EERE-2015-BT-STD-0016-0055 at p. 11)
16
The 13 other standards established in the June 2014 Final Rule (
i.e.,
the four standards applicable to dedicated condensing refrigeration systems operating at medium temperatures; the three standards applicable to panels; and the six standards applicable to doors) were not vacated. The compliance date for the remaining standards was on or after June 5, 2017.
In a final rule published on July 10, 2017 (“July 2017 Final Rule”), DOE adopted energy conservation standards for the six classes of walk-in refrigeration systems were vacated—specifically, unit coolers and low-temperature dedicated condensing systems. 82 FR 31808. The rule required compliance with the six new standards on and after July 10, 2020.
To evaluate whether to propose amendments to the energy conservation standards for walk-ins, DOE issued a request for information (“RFI”) in the
Federal Register
on July 16, 2021 (“July 2021 RFI”). 86 FR 37687. In the July 2021 RFI, DOE sought data, information, and comment pertaining to walk-ins. 86 FR 37687, 37689.
DOE subsequently announced the availability of the preliminary analysis it had conducted for the purpose of evaluating the need for amending the current energy conservation standards for walk-ins in the
Federal Register
on June 30, 2022, (“June 2022 Preliminary Analysis”). The analysis was set forth in the Department's accompanying preliminary TSD. DOE held a public meeting via webinar to discuss and receive comment on the June 2022 Preliminary Analysis on July 22, 2022. The meeting covered the analytical framework, models, and tools that DOE
used to evaluate potential standards; the results of the preliminary analyses performed by DOE; the potential energy conservation standard levels derived from those analyses; and other relevant issues.
In response to the publication of the July 2021 RFI, DOE received comments from interested parties. The July 2021 RFI comments were addressed in chapter 2 of the June 2022 Preliminary Analysis TSD.
DOE received comments in response to the June 2022 Preliminary Analysis from the interested parties listed in Table II.4 of this document.
17
AHRI submitted two comment documents to the docket. The first document in the docket includes AHRI's comments for traditional walk-in manufacturers (
i.e.,
medium- and low-temperature walk-in components). The associated file name in the docket is: AHRI Comments WICF NOPR EERE-2017-BT-STD-0009. These comments are referenced in this document as “AHRI” comments.
18
AHRI submitted two comment documents to the docket. The second document in the docket includes AHRI's comments supporting wine cellar manufacturers (
i.e.,
high-temperature walk-in refrigeration systems). The associated file name in the docket is: Comments WICF NOPR EERE-2017-BT-STD-0009 Wine. These comments are referenced in this document as “AHRI-Wine” comments.
Table II.4—June 2022 Preliminary Analysis Written Comments
Commenter(s)
Abbreviation
Comment No. in the docket
Commenter type
Air-Conditioning, Heating, and Refrigeration Institute
AHRI
17
39
Trade Association.
Air-Conditioning, Heating, and Refrigeration Institute
AHRI-Wine
18
39
Trade Association.
Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, Natural Resources Defense Council, Northwest Energy Efficiency Alliance
Efficiency Advocates
37
Efficiency Organizations.
Heat Transfer Products Group, LLC
HTPG
35
Manufacturer.
Hussmann Corporation
Hussmann—Door
33
Manufacturer.
Hussmann Corporation
Hussmann—Refrigeration
38
Manufacturer.
KeepRite Refrigeration, Inc
KeepRite
41
Manufacturer.
Lennox International Inc
Lennox
36
Manufacturer.
North American Association of Food Equipment
NAFEM
42
Trade Association.
Rob Brooks
Brooks
34
Individual.
A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.
19
To the extent that interested parties have provided written comments that are substantively consistent with any oral comments provided during the July 22, 2022, public meeting, DOE cites the written comments throughout this document. Any oral comments provided during the webinar that are not substantively addressed by written comments are summarized and cited separately throughout this document.
19
The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop energy conservation standards for walk-ins. (Docket NO. EERE-2017-BT-STD-0009, which is maintained at
www.regulations.gov
). The references are arranged as follows: (commenter name, comment docket ID number, page of that document).
C. Deviation From Process Rule
In accordance with section 3(a) of 10 CFR part 430, subpart C, appendix A (“Process Rule”), DOE notes that it is deviating from the provision in the Process Rule regarding the pre-NOPR and NOPR stages for an energy conservation standard rulemaking by not publishing a framework document and providing a public comment period less than 75 days. Framework Document
Section 6(a)(2) of the Process Rule states that if DOE determines it is appropriate to proceed with a rulemaking, the preliminary stages of a rulemaking to issue or amend an energy conservation standard that DOE will undertake will be a framework document and preliminary analysis, or an advance notice of proposed rulemaking. While DOE published a preliminary analysis for this rulemaking (
see
87 FR 39008), DOE did not publish a framework document in conjunction with the preliminary analysis. DOE notes, however, that chapter 2 of the preliminary TSD that accompanied the preliminary analysis—entitled
Analytical Framework, Comments from Interested Parties, and DOE Responses
—describes the general analytical framework that DOE uses in evaluating and developing potential amended energy conservation standards.
20
As such, publication of a separate framework document would be largely redundant of previously published documents.
20
The preliminary technical support document is available at
www.regulations.gov/document/EERE-2017-BT-STD-0009-0024
.
1. Public Comment Period
Section 6(f)(2) of the Process Rule specifies that the length of the public comment period for a NOPR will be not less than 75 calendar days. For this NOPR, DOE is instead providing a 60-day comment period, consistent with EPCA requirements. 42 U.S.C. 6316(a); 42 U.S.C. 6295(p). DOE is opting to deviate from the 75-day comment period because stakeholders have already been afforded multiple opportunities to provide comments on this proposed rulemaking.
As noted previously, DOE requested comment in the July 2021 RFI on the analysis conducted in support of the last energy conservation standard rulemaking for walk-ins and provided a 30-day comment period. In its June 2022 Preliminary Analysis and TSD, DOE's analysis remained largely the same as the analysis conducted in support of the previous energy conservation standards rulemaking for walk-ins. DOE requested comment in the June 2022 Preliminary Analysis TSD on the analysis conducted in support of this current rulemaking. Given that this analysis remained largely the same as the June 2022 Preliminary Analysis, and in light of the 60-day comment period DOE has already provided with its June 2022 Preliminary Analysis, DOE has determined that a 60-day comment period is appropriate for this NOPR and that it will provide interested parties with a meaningful opportunity to comment on the proposed rule.
III. General Discussion
DOE developed this proposal after considering oral and written comments, data, and information from interested parties that represent a variety of interests. The following discussion addresses issues raised by these commenters.
A. General Comments
This section summarizes general comments received from interested parties regarding rulemaking timing and process.
The Efficiency Advocates commented that they encourage DOE to consider evaluating potential standards for refrigeration shipping containers. (Efficiency Advocates, No. 37 at pp. 5-6) As discussed in the test procedure final rule that was published on May 4, 2023 (“May 2023 TP Final Rule”), DOE has not evaluated refrigerated shipping containers to determine if current walk-in test procedures would produce test results that reflect energy efficiency, energy use, or estimated operating costs during a representative average use cycle, without being unduly burdensome to conduct. 88 FR 28780, 28787. Therefore, DOE has determined that refrigerated shipping containers are not currently subject to the DOE test procedure or energy conservation standards for WICFs. DOE may consider whether test procedures and energy conservation standards should be applied to refrigerated shipping containers in a future rulemaking.
AHRI-Wine commented that wine cellar manufacturers seek clarification on whether the June 2022 Preliminary Analysis would change AWEF standards for high-temperature walk-in refrigeration systems. (AHRI-Wine, No. 39 at p. 5) DOE notes that there are currently no standards for high-temperature units. DOE did analyze high-temperature units in the June 2022 Preliminary Analysis. In this NOPR, DOE is proposing an energy conservation standard for high-temperature units in section I.
AHRI-Wine urged DOE to increase in future analysis the box load multiplier of 0.5 that was proposed in the April 2022 test procedure because many wine cellar applications are high-end homes with little traffic into and out of the cellar. (AHRI-Wine, No. 39 at p. 3) DOE notes that the box load multiplier is part of the walk-in test procedure and not the energy conservation standards. The May 2023 TP Final Rule adopted the box load multiplier of 0.5 and therefore, the NOPR engineering analysis for high-temperature units used this value.
AHRI-Wine recommended that DOE conduct interviews with more wine cellar manufacturers to get a better representation of the wine cellar market. (AHRI, No. 39 at p. 5) DOE notes that it invited several wine cellar manufacturers to participate in interviews, which informed this rulemaking. DOE further notes that it welcomes comments, data, and information regarding this proposed rule from all interested parties.
The Efficiency Advocates suggested that DOE consider setting standards for refrigeration systems as a function of capacity since larger capacity units are generally able to reach higher efficiency levels. (Efficiency Advocates, No. 37 at pp. 2-3) Furthermore, the Efficiency Advocates cited the disparity in the LCC to support setting standards as a function of capacity.
Id.
DOE evaluated the economics of each efficiency level for each representative unit. This analysis indicated that more stringent standards were generally economically justified for larger units and, therefore, DOE proposed standards that reflected this. As seen in section I, DOE is proposing standards as a function of capacity for most refrigeration system equipment classes.
Lennox commented that several items were non-functional in the June 2022 preliminary engineering analysis worksheet. (Lennox, No. 36 at p. 9) DOE notes that a new engineering spreadsheet has been updated to reflect the updated analysis for this NOPR and the items identified by Lennox have been resolved in this version of the engineering sheet.
21
Additionally, DOE has reviewed the non-functional items identified in Lennox's comment and found that none impacted the results of the engineering analysis.
21
The new refrigeration systems engineering sheet can be found at
www.regulations.gov/docket/EERE-2017-BT-STD-0009
.
NAFEM stated that it endorses and reiterates all comments made by AHRI. (NAFEM, No. 42 at p. 2) DOE notes that throughout this document, reference to comments made by AHRI are therefore understood to be representative of the viewpoints of NAFEM as well. NAFEM also commented that it hopes DOE will follow the Process Rule.
Id.
In section II.C of this document, DOE discusses certain minor deviations from the Process Rule as well as the justification for such deviations. Aside from these minor deviations, DOE has developed this NOPR in accordance with the Process Rule.
B. Scope of Coverage
This NOPR covers “walk-in coolers and walk-in freezers” defined as an enclosed storage space, including but not limited to panels, doors, and refrigeration systems, refrigerated to temperatures, respectively, above, and at or below 32 degrees Fahrenheit that can be walked into, and has a total chilled storage area of less than 3,000 square feet; however, the terms do not include products designed and marketed exclusively for medical, scientific, or research purposes. 10 CFR 431.302. Rather than establishing standards for complete walk-in systems, DOE has established standards for the principal components that make up a walk-in (
i.e.,
doors, panels, and refrigeration systems).
A “door” means an assembly installed in an opening on an interior or exterior wall that is used to allow access or close off the opening and that is movable in a sliding, pivoting, hinged, or revolving manner of movement. For walk-in coolers and walk-in freezers, a door includes the frame (including mullions), the door leaf or multiple leaves (including glass) within the frame, and any other elements that form the assembly or part of its connection to the wall.
Id.
A “panel” means a construction component that is not a door and is used to construct the envelope of the walk-in, (
i.e.,
elements that separate the interior refrigerated environment of the walk-in from the exterior).
Id.
A “refrigeration system” means the mechanism (including all controls and other components integral to the system's operation) used to create the refrigerated environment in the interior of a walk-in cooler or walk-in freezer, consisting of:
(1) A dedicated condensing refrigeration system (as defined in 10 CFR 431.302); or
(2) A unit cooler.
The scope of coverage and equipment classes for this NOPR are discussed in further detail in section IV.A.1 of this document.
C. Test Procedure
EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6314(a)) Manufacturers of covered equipment must use these test procedures to certify to DOE that their equipment complies with energy conservation standards and to quantify the efficiency of their equipment. DOE's current energy conservation standards for walk-in doors are expressed in terms of maximum daily energy consumption, DOE's current energy conservation standards for walk-in panels are expressed in terms of R-value, and DOE's current energy conservation standards for walk-in refrigeration systems are expressed in terms of AWEF. (See 10 CFR part 431, subpart R, appendices A, B, C, and C1.)
On April 21, 2022, DOE published a test procedure NOPR (“April 2022 TP NOPR”) and on May 4, 2023, DOE published the May 2023 TP Final Rule.
87 FR 23920; 88 FR 28780 In the June 2022 Preliminary Analysis, DOE used the test procedure proposed in the April 2022 TP NOPR to evaluate the efficiency of walk-in components. In this NOPR analysis, DOE used the test procedure adopted in the May 2023 TP Final Rule to evaluate the efficiency of walk-in components. From this point forward the May 2023 TP Final Rule will be the “current test procedure”.
In the May 2023 TP Final Rule, DOE established a new appendix, appendix C1 to subpart R (“appendix C1”), and a new energy metric, AWEF2, for refrigeration systems. (
See
10 CFR part 431, subpart R, appendix C1.) The engineering analysis results and the proposed energy conservation standards for refrigeration systems are presented as AWEF2 values. Manufacturers would be required to begin using appendix C1 as of the compliance date of an energy conservation standards promulgated as a result of this rulemaking.
D. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the equipment that are the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available equipment or in working prototypes to be technologically feasible. 10 CFR 431.4; 10 CFR part 430, subpart C, appendix A, sections 6(b)(3)(i) and 7(b)(1) of the Process Rule.
After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) practicability to manufacture, install, and service; (2) adverse impacts on equipment utility or availability; (3) adverse impacts on health or safety, and (4) unique-pathway proprietary technologies. 10 CFR 431.4; Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of the Process Rule. Section IV.B of this document discusses the results of the screening analysis for walk-in doors, panels, and refrigeration systems, particularly the designs DOE considered, those it screened out, and those that are the basis for the standards considered in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a new or amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such equipment. (42 U.S.C. 6316(a); 42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for walk-in doors, panels, and refrigeration systems, using the design parameters for the most efficient equipment available on the market or in working prototypes. The max-tech levels that DOE determined for this rulemaking are described in section IV.C.1 of this proposed rule and in chapter 5 of the NOPR TSD.
E. Energy Savings
1. Determination of Savings
For each trial standard level (“TSL”), DOE projected energy savings from application of the TSL to walk-in doors, panels, and refrigeration systems purchased in the 30-year period that begins in the year of compliance with the proposed standards (2027-2056).
22
The savings are measured over the entire lifetime of walk-in doors, panels, and refrigeration systems purchased in the previous 30-year period. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-new-standards case. The no-new-standards case represents a projection of energy consumption that reflects how the market for the equipment would likely evolve in the absence of amended energy conservation standards.
22
Each TSL is composed of specific efficiency levels for each equipment class. The TSLs considered for this NOPR are described in section V.A of this document. DOE conducted a sensitivity analysis that considers impacts for products shipped in a 9-year period.
DOE used its national impact analysis (“NIA”) spreadsheet model to estimate national energy savings (“NES”) from potential amended or new standards for walk-in doors, panels, and refrigeration systems. The NIA spreadsheet model (described in section IV.H of this document) calculates energy savings in terms of site energy, which is the energy directly consumed by products at the locations where they are used. For electricity, DOE reports national energy savings in terms of primary energy savings, which is the savings in the energy that is used to generate and transmit the site electricity. DOE also calculates NES in terms of FFC energy savings. The FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards.
23
DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered products or equipment. For more information on FFC energy savings, see section IV.H.2 of this document.
23
The FFC metric is discussed in DOE's statement of policy and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as amended at 77 FR 49701 (Aug. 17, 2012).
2. Significance of Savings
To adopt any new or amended standards for covered equipment, DOE must determine that such action would result in significant energy savings. (42 U.S.C. 6295(o)(3)(B))
The significance of energy savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking.
24
For example, some covered equipment have most of their energy consumption occur during periods of peak energy demand. The impacts of this equipment on the energy infrastructure can be more pronounced than equipment with relatively constant demand. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis, taking into account the significance of cumulative FFC national energy savings, the cumulative FFC emissions reductions, and the need to confront the global climate crisis, among other factors. DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(B).
24
The numeric threshold for determining the significance of energy savings established in a final rule published on February 14, 2020 (85 FR 8626, 8670), was subsequently eliminated in a final rule published on December 13, 2021 (86 FR 70892).
As stated, the standard levels proposed in this document are projected to result in national energy savings of 1.55 quads, the equivalent of the primary annual energy use of 42.7 million homes. Based on the amount of FFC savings, the corresponding reduction in emissions, and the need to confront the global climate crisis, DOE
has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(B).
F. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential new or amended standard on manufacturers, DOE conducts an MIA, as discussed in section IV.J of this document. DOE first uses an annual cash flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include (1) INPV, which values the industry on the basis of expected future cash flows, (2) cash flows by year, (3) changes in revenue and income, and (4) other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the changes in LCC and PBP associated with new or amended standards. These measures are discussed further in the following section. For consumers in the aggregate, DOE also calculates the national net present value of the consumer costs and benefits expected to result from particular standards. DOE also evaluates the impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered equipment in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the covered equipment that are likely to result from a standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase price of equipment (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the equipment. The LCC analysis requires a variety of inputs, such as equipment prices, equipment energy consumption, energy prices, maintenance and repair costs, equipment lifetime, and discount rates appropriate for consumers. To account for uncertainty and variability in specific inputs, such as equipment lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value.
The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of more-efficient equipment through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost due to a more-stringent standard by the change in annual operating cost for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will purchase the covered equipment in the first year of compliance with new or amended standards. The LCC savings for the considered efficiency levels are calculated relative to the case that reflects projected market trends in the absence of new or amended standards. DOE's LCC and PBP analysis is discussed in further detail in section IV.F of this document.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section III.E of this document, DOE uses its NIA model to project national energy savings.
d. Lessening of Utility or Performance of Equipment
In establishing equipment classes and in evaluating design options and the impact of potential standard levels, DOE evaluates potential standards that would not lessen the utility or performance of the considered equipment. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards proposed in this document would not reduce the utility or performance of the equipment under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a proposed standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed rule to the Attorney General with a request that the Department of Justice (“DOJ”) provide its determination on this issue. DOE will publish and respond to the Attorney General's determination in the final rule. DOE invites comment from the public regarding the competitive impacts that are likely to result from this proposed rule. In addition, stakeholders may also provide comments separately to DOJ regarding these potential impacts. See the
ADDRESSES
section for information to send comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water conservation in determining whether a new or amended standard is economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from the proposed standards are likely to provide improvements to the security and reliability of the Nation's energy system. Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the Nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the Nation's needed power generation
capacity, as discussed in section IV.M of this document.
DOE maintains that environmental and public health benefits associated with the more efficient use of energy are important to take into account when considering the need for national energy conservation. The proposed standards are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases (“GHGs”) associated with energy production and use. DOE conducts an emissions analysis to estimate how potential standards may affect these emissions, as discussed in section IV.K of this document; the estimated emissions impacts are reported in section V.B.6 of this document. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section V.C.1 of this document.
g. Other Factors
In determining whether an energy conservation standard is economically justified, DOE may consider any other factors that the Secretary deems to be relevant (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent DOE identifies any relevant information regarding economic justification that does not fit into the other categories described previously, DOE could consider such information under “other factors.”
2. Rebuttable Presumption
EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the equipment that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(iii)) DOE's LCC and PBP analyses generate values used to calculate the effects that proposed energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the Nation, and the environment, as required under 42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable presumption payback calculation is discussed in section V.B.1.c of this proposed rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this rulemaking with regard to walk-ins. Separate subsections address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the standards proposed in this document. The first tool is a spreadsheet that calculates the LCC savings and PBP of potential amended or new energy conservation standards. The national impacts analysis uses a second spreadsheet set that provides shipments projections and calculates national energy savings and net present value of total consumer costs and savings expected to result from potential energy conservation standards. DOE uses the third spreadsheet tool, the Government Regulatory Impact Model (“GRIM”), to assess manufacturer impacts of potential standards. These three spreadsheet tools are available on the DOE website for this proposed rulemaking:
www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=56&action=viewlive.
Additionally, DOE used output from the latest version of the Energy Information Administration's (“EIA's”)
Annual Energy Outlook
(“
AEO
”), a widely known energy projection for the United States, for the emissions and utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment that provides an overall picture of the market for the equipment concerned, including the purpose of the equipment, the industry structure, manufacturers, market characteristics, and technologies used in the equipment. This activity includes both quantitative and qualitative assessments, based primarily on publicly available information. The subjects addressed in the market and technology assessment for this rulemaking include (1) a determination of the scope of the rulemaking and equipment classes, (2) manufacturers and industry structure, (3) existing efficiency programs, (4) shipments information, (5) market and industry trends; and (6) technologies or design options that could improve the energy efficiency of walk-ins. The key findings of DOE's market assessment are summarized in the following sections. See chapter 3 of the NOPR TSD for further discussion of the market and technology assessment.
1. Equipment Classes
When evaluating and establishing energy conservation standards, DOE may establish separate standards for a group of covered equipment (
i.e.,
establish a separate equipment class) if DOE determines that separate standards are justified based on the type of energy used, or if DOE determines that equipment capacity or other performance-related feature justifies a different standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q)) In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility of the feature to the consumer and other factors DOE determines are appropriate. (
Id.
)
Rather than establishing standards for complete walk-in systems, DOE has established standards for each of the principal components that make up a walk-in (
i.e.,
doors, panels, and refrigeration systems).
a. Doors
DOE's existing standards for walk-in doors are based on six equipment classes, differentiated by temperature and whether they are display doors or non-display doors. DOE defines a display door as a door that is designed for product display or has 75 percent or more of its surface area composed of glass or another transparent material. 10 CFR 431.302. Non-display doors are all doors not considered display doors and are mainly used to allow people and products to be moved into and out of the walk-in. Non-display doors are further divided by whether they are passage or freight doors. DOE defines a freight door as a door that is not a display door and is equal to or larger than 4 feet wide and 8 feet tall. DOE defines passage doors as any doors that are not display doors or freights doors.
Id.
Display, passage, and freight doors are further divided based on walk-in temperature (
i.e.,
cooler or freezer). DOE currently defines separate energy conservation standards for the following walk-in door classes (10 CFR 431.306(c) and (d)):
• Display Door, Medium-temperature,
• Display Door, Low-temperature,
• Passage Door, Medium-temperature,
• Passage Door, Low-temperature,
• Freight Door, Medium-temperature, and
• Freight Door, Low-temperature.
In the June 2022 Preliminary Analysis, DOE combined passage and freight non-display door classes and
instead differentiated non-display doors by whether or not they have motorized door openers. DOE's initial research and analysis indicated that distinguishing non-display door classes by the presence or absence of a motorized door opener could be a more appropriate distinction of equipment classes rather than door size. As with its prior analysis, DOE also evaluated the motorized and non-motorized non-display door classes by temperature conditions: medium-temperature (
i.e.,
cooler) and low-temperature (
i.e.,
freezer).
In the June 2022 Preliminary Analysis, DOE also distinguished display door classes by the presence or absence of a motorized door opener. DOE analyzed medium- and low-temperature display doors without motorized door openers and medium-temperature display doors with motorized door openers. DOE has not identified any motorized display doors for low-temperature applications and therefore did not analyze such equipment in the June 2022 Preliminary Analysis. See section 3.1.2.1 of chapter 3 of the June 2022 preliminary analysis TSD.
DOE sought feedback on the equipment classes analyzed for walk-in doors in section ES.4.1 of the June 2022 Preliminary Analysis TSD. Hussmann-Doors commented that their request to have their Heavy Duty Door (“HDD”) and ABC Beer Cave (“ABC”) products classified as passage doors was not approved in 2017 and stated that there would be a cost benefit if their HDD and ABC product were to be classified as passage doors rather than display doors. Hussmann-Doors further elaborated that if these products were recognized as passage doors, they would not need to use expensive vacuum-insulated glass packs and could consider a more economical glass pack. (Hussmann-Doors, No. 33 at p. 2) In response, DOE notes that the display door definition references the physical characteristics of the door (
i.e.,
the percentage of surface area composed of glass or another transparent material) and is not contingent on door application. It is DOE's understanding that both Hussmann's HDD and ABC products are composed of at least 75 percent glass or another transparent material. Any door(s) that meets this criteria is considered a display door, even those not necessarily designed for product display.
The Efficiency Advocates agreed that non-display doors should be differentiated by manual or motorized opening mechanism (Efficiency Advocates, No. 37 at pp. 1-2).
Consistent with stakeholder feedback, DOE has tentatively concluded that it is more appropriate to distinguish non-display doors by whether or not they have a motorized door opener, rather than by size. Additionally, DOE has tentatively concluded that it is appropriate to distinguish display doors by whether or not they have a motorized door opener. DOE is proposing to establish the equipment classes listed in Table IV.1 for walk-in doors.
Table IV.1—Proposed Equipment Classes for Walk-In Doors
Display/non-display
Opening mechanism
Temperature
Class code
Display
Manual
Medium
DW.M.
Low
DW.L.
Motorized
Medium
DS.M.
Non-display
Manual
Medium
NM.M.
Low
NM.L.
Motorized
Medium
NO.M.
Low
NO.L.
DOE discusses representative units, baseline assumptions for representative unit efficiency, and design options analyzed at higher efficiency levels for walk-in display and non-display doors in sections IV.C.1.a and IV.C.1.b of this document, respectively. DOE notes that, consistent with its June 2022 Preliminary Analysis, it did not consider more efficient levels for the motorized display door class beyond the current maximum energy consumption (
i.e.,
baseline efficiency level) in this NOPR. In its review of the motorized display door market, DOE found that manufacturers are already implementing maximum technology design options, such as vacuum- insulated glass, to achieve the current maximum energy consumption standard since the motor consumes additional energy. DOE has not identified any energy-saving technology options for motorized display doors that were retained during the screening analysis, as discussed in sections IV.A.2.b and IV.B of this document. DOE received comments in response to the June 2022 Preliminary Analysis regarding efficiency of motorized (
i.e.,
sliding) display doors. These comments are addressed in section IV.C.1.a of this document.
b. Panels
DOE's existing standards for walk-in panels apply to three equipment classes that are differentiated by whether they are structural (also referred to as “wall or ceiling panels”) or floor panels. Structural panels are further separated by temperature condition (
i.e.,
cooler or freezer). DOE's analysis for the June 2014 Final Rule determined that, unlike walk-in freezers, the majority of walk-in coolers have concrete floors and no insulated floor panels. Thus, DOE did not adopt insulation R-value standards for walk-in cooler floors. 79 FR 32050, 32067. DOE's re-evaluation of the market for this rulemaking suggests that the walk-in cooler floor panel market has not changed substantially since the June 2014 Final Rule. Therefore, DOE has excluded walk-in cooler floor panels from this proposed rulemaking.
DOE currently defines separate energy conservation standards for the following walk-in panel classes (10 CFR 431.306(a)):
• Structural Panel, Medium-Temperature,
• Structural Panel, Low-Temperature, and
• Floor Panel, Low-Temperature.
DOE has not established standards for display panels because they make up a small percentage of the panel market; therefore, standards would not result in significant energy savings without incurring disproportionate costs. 79 FR 32050, 32067. In the June 2022 Preliminary Analysis, DOE maintained the current panel equipment classes. See section 3.1.2.2 of chapter 3 of the June 2022 preliminary analysis TSD. In section ES.4.1 of the June 2022 Preliminary Analysis TSD, DOE requested comment on the equipment classes used in this analysis. DOE received no comment regarding panel equipment classes in response to the June 2022 Preliminary Analysis. As such, DOE is proposing to maintain its
current equipment classes for walk-in panels. Table IV.2 summarizes the equipment classes for walk-in panels.
Table IV.2—Equipment Classes for Walk-In Panels
Component
Temperature
Class code
Structural Panel
Medium
PS.M.
Low
PS.L.
Floor Panel
Low
PF.L.
c. Refrigeration Systems
DOE's existing standards for walk-in refrigeration systems apply to nine equipment classes, differentiated by whether they are unit coolers or dedicated condensing systems and by temperature (
i.e.,
whether they are a cooler or freezer). A “dedicated condensing system” means a dedicated condensing unit, a single-packaged dedicated system, or a matched refrigeration system. (
See
10 CFR 431.302.) Dedicated condensing systems are further differentiated by their installation location (
i.e.,
indoor or outdoor). Low-temperature dedicated condensing systems and unit cooler equipment classes are further differentiated by net capacity. DOE currently defines separate energy conservation standards for the following walk-in refrigeration system classes (10 CFR 431.306(e)):
• Dedicated Condensing System, Medium-Temperature, Indoor,
• Dedicated Condensing System, Medium-Temperature, Outdoor,
• Dedicated Condensing System, Low-Temperature, Indoor, Net Capacity of less than 6,500 Btu/h,
• Dedicated Condensing System, Low-Temperature, Indoor, Net Capacity of greater than or equal to 6,500 Btu/h,
• Dedicated Condensing System, Low-Temperature, Outdoor, Net Capacity of less than 6,500 Btu/h,
• Dedicated Condensing System, Low-Temperature, Outdoor, Net Capacity of greater than or equal to 6,500 Btu/h,
• Unit Cooler, Medium-Temperature,
• Unit Cooler, Low-Temperature, Net Capacity of less than 15,500 Btu/h, and
• Unit Cooler, Low-Temperature, Net Capacity of greater than or equal to 15,500 Btu/h.
In the June 2022 Preliminary Analysis TSD, DOE noted that single-packaged dedicated systems, which are dedicated condensing systems with a combined condensing unit and unit cooler, were not evaluated separately from dedicated condensing units and matched refrigeration systems in the previous rulemaking. New test procedure provisions in appendix C1 require specific test methods for single-packaged dedicated systems that measure the inherent thermal losses of such systems. These thermal losses reduce the capacity and therefore the efficiency of single-packaged dedicated systems. For this reason, in the June Preliminary Analysis, DOE evaluated single-packaged dedicated systems separately from split dedicated condensing systems.
25
See
section 3.1.2.3 of chapter 3 of the June 2022 preliminary analysis TSD.
25
Split dedicated condensing systems or split systems refer to any dedicated condensing system that is made up of a unit cooler and a remote dedicated condensing unit. The systems are split because the unit cooler and dedicated condensing unit are not in the same package.
In the May 2023 TP Final Rule, DOE defined a high-temperature refrigeration system as a walk-in refrigeration system that is not designed to operate below 45 °F. 88 FR 28780, 28789. High-temperature units are generally smaller capacity than medium-temperature units and therefore contain small-capacity compressors, which DOE has found to be less efficient. Additionally, some high-temperature units are sold in ducted configurations. Ducting adds flexibility to installation location and removes refrigeration equipment from the refrigerated storage space. Ducts also increase energy consumption due to the higher external static pressure imposed on the system's fans. In the June 2022 Preliminary Analysis, DOE evaluated high-temperature units and ducted units as separate equipment classes. The equipment classes that DOE analyzed in the June 2022 Preliminary Analysis are summarized in Table IV.3.
Table IV.3—Walk-In Refrigeration System Equipment Classes Analyzed in the June 2022 Preliminary Analysis
System
Temperature
Location
Class code
Dedicated Condensing Unit
Medium-Temperature
Outdoor
Indoor
DC.M.O.
DC.M.I.
Low-Temperature
Outdoor
Indoor
DC.L.O.
DC.L.I.
Unit Cooler
High-Temperature
N/A
UC.H.
Medium-Temperature
UC.M.
Low-Temperature
UC.L.
Single-Packaged Dedicated System
High-Temperature (Non-ducted)
Outdoor
Indoor
SPU.H.O.
SPU.H.I.
High-Temperature (Ducted)
Outdoor
Indoor
SPU.H.O.D.
SPU.H.I.D.
Medium-Temperature
Outdoor
Indoor
SPU.M.O.
SPU.M.I.
Low-Temperature
Outdoor
Indoor
SPU.L.O.
SPU.L.I.
DOE requested comment on the equipment classes in section ES.4.1 of the Executive Summary of the June 2022 Preliminary Analysis TSD, repeated in Table IV.3. AHRI requested further clarification on DOE's reasoning for separating single-packaged dedicated systems and dedicated condensing systems. (AHRI, No. 39 at pp. 1-2) Hussmann-Refrigeration stated that it agrees with AHRI's inquiry. (Hussmann-Refrigeration, No. 38 at p. 2) HTPG commented that it disagrees with DOE separating single-packaged dedicated systems and dedicated condensing systems because a single-packaged dedicated system is essentially a matched pair and matched pairs have the same efficiency requirements as dedicated condensing systems. (HTPG, No. 35 at p. 3) Additionally, HTPG stated that if single-packaged dedicated systems are held to a lower standard than dedicated condensing systems and matched pairs, then consumers could purchase lower cost single-packaged dedicated systems at a lower efficiency level than dedicated condensing units and matched pairs.
Id.
The Efficiency Advocates encouraged DOE to ensure that efficiency standard levels for single-packaged dedicated systems are as stringent (
e.g.,
incorporate similar assumed design options) as efficiency standard levels for dedicated condensing units to prevent a shift in the market away from dedicated condensing units and towards single-packaged dedicated systems. (Efficiency Advocates, No. 37 at p. 5)
DOE clarifies that in Table IV.3, the dedicated condensing unit equipment class refers to all split systems. In general, DOE has separated packaged equipment from split systems as packaged equipment provides consumers with more options for space-constrained applications. But packaged refrigeration systems are inherently less efficient because manufacturers cannot employ the same technologies such as increased heat exchanger sizes without impacting the overall dimensions of the packaged system. In addition, packaged systems are constrained by their overall weight limitations of the equipment, which affects the technologies options that can be applied to the system. Packaged systems typically contain smaller heat exchangers and those heat exchangers have less faces for airflow to pass over impacting the overall heat transfer of the system. In addition, packaged systems have both the cold and hot sides connected within the packaged framework and the cold side is exposed to the outside, which increases the losses associated with the thermal loads. Overall, DOE has tentatively decided that packaged system and split system WICF refrigeration systems cannot be combined into the same product class because packaged systems provide consumers with more options for space-constrained applications and inherent differences in system design between packaged systems and split systems limit the efficiency of the former.
AHRI-Wine commented that it seeks clarification on where matched split systems are represented in Table 5.3.4 of the June 2022 Preliminary Analysis TSD, which lists the representative units chosen for the refrigeration system analysis. (AHRI-Wine, No. 39 at p. 2) Also, AHRI-Wine recommended adding high-temperature dedicated condensing [units] since leaving these out of the scope would be a competitive disadvantage for manufacturers that sell single-packaged dedicated systems and matched split systems.
Id.
Furthermore, AHRI-Wine commented that wine cellar manufacturers seek clarification on the classes that constitute matched split, ducted and non-ducted, and indoor and outdoor systems. (AHRI-Wine, No. 39 at p. 5)
DOE notes that it did not establish a test procedure for high-temperature dedicated condensing units tested alone in the May 2023 TP Final Rule; however, it did establish a test procedure for high-temperature matched refrigeration systems and single-packaged dedicated condensing systems. This decision is discussed in detail in the May 2023 TP Final Rule. 88 FR 28780, 28816-28817. As such, DOE did not analyze high-temperature dedicated condensing units in this NOPR analysis and therefore is not proposing to establish an equipment class for high-temperature dedicated condensing units. DOE is, however, proposing to establish an equipment class for both high-temperature matched refrigeration systems and high-temperature single-packaged dedicated condensing systems. For this NOPR, DOE evaluated high-temperature matched refrigeration systems and high-temperature single-packaged dedicated systems as a single equipment class since both are sold with a condenser and an evaporator that are matched for optimal performance. Furthermore, the temperature difference between the refrigerated and ambient spaces for high-temperature refrigeration systems is less than the temperature difference for medium- and low-temperature systems. Therefore, thermal losses have less impact for high-temperature systems. This means that the difference in performance between high-temperature matched refrigeration systems and high-temperature single-packaged dedicated systems is much less than the performance difference expected between medium- or low-temperature matched refrigeration systems and medium- or low-temperature single-packaged dedicated systems. Because of the expected similarity in performance, DOE has tentatively determined that a single class of equipment encompassing high-temperature matched refrigeration systems and single-packaged dedicated systems is appropriate. In its analysis of high-temperature refrigeration units, DOE focused on single-packaged dedicated systems since this is where most of the shipments are concentrated for the high-temperature market.
DOE is proposing to establish the following equipment classes for refrigeration systems, as presented in Table IV.4.
Table IV.4—Proposed Equipment Classes for Walk-In Refrigeration Systems
System
Temperature
Location
Class code
Dedicated Condensing Units and Matched Refrigeration Systems
Medium-Temperature
Outdoor
Indoor
DC.M.O.
DC.M.I.
Low-Temperature
Outdoor
Indoor
DC.L.O.
DC.L.I.
Unit Cooler
High-Temperature (Non-Ducted)
N/A
UC.H.
High-Temperature (Ducted)
UC.H.D.
Medium-Temperature
UC.M.
Low-Temperature
UC.L.
Matched Refrigeration Systems and Single-Packaged Dedicated Systems
High-Temperature (Non-ducted)
Outdoor
Indoor
SPU.H.O.
SPU.H.I.
High-Temperature (Ducted)
Outdoor
Indoor
SPU.H.O.D.
SPU.H.I.D.
Single-Packaged Dedicated Systems
Medium-Temperature
Outdoor
Indoor
SPU.M.O.
SPU.M.I.
Low-Temperature
Outdoor
Indoor
SPU.L.O.
SPU.L.I.
As discussed previously, the current DOE standards for walk-in refrigeration systems differentiate low-temperature dedicated condensing systems and unit coolers by net capacity. DOE understands that for split systems and single-packaged dedicated systems, lower capacity systems may have greater difficulty attaining higher efficiency levels than higher capacity systems since compressors for small-sized equipment are generally less efficient. Additionally, DOE has found through testing that lower capacity unit coolers tend to have reduced efficiency compared to higher capacity unit coolers. As discussed in section III.A of this document, DOE received comments on the June 2022 Preliminary Analysis suggesting that walk-in refrigeration system efficiency standards should vary with net capacity for walk-in refrigeration system equipment classes. In this NOPR, DOE evaluated multiple capacities in each equipment class to better ascertain the relationship between efficiency and net capacity. This is discussed in more detail in the Representative Units subsection of section IV.C.1.d of this document. In section I, DOE discusses the proposed standards for walk-in refrigeration systems.
2. Technology Options
DOE considered separate technology options for whole walk-ins, doors, and panels, and refrigeration systems.
a. Fully Assembled Walk-Ins
In the market analysis and technology assessment presented in Chapter 3 of the June 2022 preliminary analysis TSD, DOE identified seven technology options that would be expected to improve the efficiency of a fully assembled walk-in (
i.e.,
wall, ceiling and floor panels, door(s), and refrigeration system(s)) but would not apply specifically to any of the components analyzed in this rulemaking:
• Energy storage systems,
• Refrigeration system override,
• Automatic evaporator fan shut-off,
• Non-penetrative internal racks and shelving,
• Humidity sensors,
• Fiber optic natural lighting, and
• Heat reclaim valve.
DOE requested comment on the technology options in section ES.4.2 of the June 2022 Preliminary Analysis TSD. DOE received no comments on the technology options that might improve the efficiency of whole walk-ins. Therefore, DOE identified the same technology options for the NOPR analysis. DOE further discusses these technology options in chapter 3 of the NOPR TSD.
b. Doors and Panels
In the preliminary market analysis and technology assessment, DOE identified 15 technology options that would be expected to improve the efficiency of doors and/or panels, as measured by the DOE test procedure. These technology options are listed in Table IV.5.
Table IV.5—Summary of Door and Panel-Related Technology Options Analyzed in the June 2022 Preliminary Analysis
Technology options
Applicable component
Door gaskets
Doors.
Anti-sweat heater/freezer wire controls
Display and window glass system insulation performance
Non-electric, reduced, or no anti-sweat systems
Improved frame systems
Automatic door opening and closing systems
Occupancy sensors
High-efficiency lighting
Automatic insulation deployment systems
Display Doors.
Infiltration-reducing devices or systems (
e.g.,
air curtains, strip curtains, vestibule entryways, revolving doors)
Non-display Doors.
Insulation thickness and material
Non-display doors and panels.
Framing materials
Damage-sensing systems (
e.g.,
air and water infiltration sensors, heat flux sensors)
Panel interface systems
Panels.
In response to the June 2022 Preliminary Analysis, Hussmann-Doors stated that its sliding doors are designed to utilize insulation from the box/cooler wall to minimize door anti-sweat heat power. (Hussmann-Doors, No. 33 at p. 3) Per Hussmann-Doors' recommendation, DOE is considering this as a technology option for walk-in doors. The screening of this technology option is discussed further in section IV.B.1.a.
DOE is considering the same technology options for doors and panels in this NOPR that it considered in the June 2022 Preliminary Analysis, as well as the sliding doors referenced the comment from Hussmann-Doors.
c. Refrigeration Systems
In the preliminary market analysis and technology assessment, DOE identified 16 technology options that would be expected to improve the efficiency of refrigeration systems:
• Improved evaporator and condenser fan blades,
• Improved evaporator and condenser coils,
• Evaporator fan control,
• Ambient sub-cooling,
• Higher-efficiency fan motors,
• Higher-efficiency compressors,
• Variable-speed compressors,
• Liquid suction heat exchanger,
• Adaptive defrost,
• Hot gas defrost,
• Floating head pressure,
• Condenser fan control,
• Economizer cooling,
• Crank case heater controls,
• Single-package thermal insulation, and
• Oil management systems.
DOE requested comment on the technology options in section ES.4.2 of
the June 2022 Preliminary Analysis TSD. AHRI commented that there are many technology options on the market that may individually provide energy savings for refrigeration systems, however, these technologies would require significant modification to implement with current systems and once implemented, they may no longer provide significant energy savings, as they are contingent on other aspects of the system. (AHRI, No. 39 at p. 2)
DOE notes that it applies screening criteria to all potential technology options which is designed to eliminate technologies that are not suitable for further analysis as discussed in section IV.B and in Ch. 4 of the TSD. This includes analysis of the technological feasibility and practicability. DOE then conducts a full engineering analysis to weigh the costs and energy savings of each design option that remains after the screening analysis. The engineering analysis is discussed in section IV.C. This engineering analysis evaluates potential changes to other aspects of the system necessary to implement the option.
HTPG agreed that DOE has considered all the technology options available on the market for walk-in refrigeration systems that it is aware of. (HTPG, No. 35 at p. 4) AHRI-Wine commented that wine cellar manufacturers agree with the technologies that DOE has considered in its analysis. (AHRI-Wine, No. 39 at p. 2)
Based on comments received from stakeholders, DOE is considering the same technology options for walk-in refrigeration systems in this NOPR as were considered in the June 2022 Preliminary Analysis.
B. Screening Analysis
DOE uses the following five screening criteria to determine which technology options are suitable for further consideration in an energy conservation standards rulemaking:
1. Technological feasibility.
Technologies that are not incorporated in commercial equipment or in commercially viable, existing prototypes will not be considered further.
2. Practicability to manufacture, install, and service.
If it is determined that mass production of a technology in commercial equipment and reliable installation and servicing of the technology could not be achieved on the scale necessary to serve the relevant market at the time of the projected compliance date of the standard, then that technology will not be considered further.
3. Impacts on product utility.
If a technology is determined to have a significant adverse impact on the utility of the equipment to subgroups of consumers or result in the unavailability of any covered equipment type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as equipment generally available in the United States at the time, it will not be considered further.
4. Safety of technologies.
If it is determined that a technology would have significant adverse impacts on health or safety, it will not be considered further.
5. Unique-pathway proprietary technologies.
If a technology has proprietary protection and represents a unique pathway to achieving a given efficiency level, it will not be considered further, due to the potential for monopolistic concerns. 10 CFR 431.4; 10 CFR part 430, subpart C, appendix A, sections 6(c)(3) and 7(b).
In summary, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the listed five criteria, it will be excluded from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed in the following sections.
The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (“screened out”) based on the screening criteria.
1. Screened Out Technologies
a. Fully Assembled Walk-Ins
In the June 2022 Preliminary Analysis, DOE screened out the following technology options under the tentative assumption that they would not affect rated energy consumption of the walk-in components as measured by the DOE test procedure. While these technologies may improve the energy efficiency of a fully assembled walk-in installed in the field, DOE's current walk-in test procedures are component-specific (
i.e.,
DOE does not have a test procedure for determining energy use of a fully assembled walk-in):
• Energy storage systems,
• Refrigeration system override,
• Automatic evaporator fan shut-off,
• Non-penetrative internal racks and shelving,
• Humidity sensors, and
• Heat reclaim valves.
See
section 4.2.1 of the June 2022 Preliminary Analysis TSD.
Furthermore, in the June 2022 Preliminary Analysis, DOE screened out fiber optic natural lighting since it is not technologically feasible. DOE is not aware of any such systems currently manufactured and sold for walk-in operations.
DOE requested comment on the technologies that it had screened out in section ES.4.3 of the June 2022 Preliminary Analysis TSD. HTPG commented that it agrees that energy storage systems, refrigeration systems override, automatic evaporator fan shut-off, humidity sensors, and heat reclaim valves do not affect the rated energy consumption as measured under the walk-in test procedures. (HTPG, No. 359 at p. 4) Lennox supported DOE's conclusions and rationale for the screened out technologies. (Lennox, No. 36 at p. 3) AHRI-Wine stated that wine cellar manufacturers agree with the technologies screened in and out of the analysis. (AHRI-Wine, No. 39 at p. 2)
In its NOPR analysis, DOE has screened out all technology options for whole walk-ins for the same rationales as it did for the June 2022 Preliminary Analysis.
b. Doors and Panels
In the June 2022 Preliminary Analysis, DOE screened out the following technology options because any reduction in energy use would not be captured by the test procedure in appendix A to subpart R of 10 CFR part 431 (“appendix A”) and any increase in R-value would not be captured by the test procedure in appendix B to subpart R of 10 CFR part 431 (“appendix B”):
• Infiltration-reducing devices,
• Air and water infiltration sensors,
• Heat flux sensors, and
• Structural materials for panels.
Infiltration-reducing technologies could include door gaskets, automatic door opening and closing systems, air curtains, strip curtains, vestibule entryways, revolving doors, and panel interface systems. In the June 2022 Preliminary Analysis, DOE had tentatively determined that any potential energy savings from infiltration-reducing devices would not be captured because air infiltration is a characteristic of a fully assembled walk-in. The walk-in test procedures do not evaluate the energy use of the assembled walk-in box and instead evaluate the energy use of a single component (
i.e.,
door or panel); therefore, technologies that may improve energy efficiency of the full walk-in box were screened out.
Additionally, DOE preliminarily concluded that any potential energy savings from air and water infiltration sensors, heat flux sensors, and structural materials for panels would not be captured by either the appendix A or
appendix B test procedures. Air and water infiltration sensors and heat flux sensors are technology options that would most benefit the end user for monitoring the continuing performance of walk-in components; however, the potential degradation captured by these sensors over the lifetime of a walk-in are not reflected in the current test procedure. Additionally, changes to panel structural materials are not captured in the test procedure since the current walk-in panels test procedure provides a method for determining the R-value of the panel insulation only. In other words, the overall R-value of the panel, including structural materials, is not captured by the current test procedure. Therefore, such technologies were screened out.
Furthermore, in the June 2022 Preliminary Analysis, DOE screened out the following technologies due to technological infeasibility since DOE was not able to find these technologies incorporated into either prototypes or commercially available walk-in doors or panels:
• Non-electric anti-sweat systems,
• Higher efficiency LEDs, and
• Automatic insulation deployment systems.
In the June 2022 Preliminary Analysis, DOE screened out panel and door insulation thicker than six inches because DOE received feedback during manufacturer interviews that it is not practicable to manufacture and install and it has adverse impacts on consumer utility.
See
section 4.3.2.4 of chapter 4 of the June 2022 Preliminary Analysis TSD. DOE preliminarily concluded that insulation thicker than six inches would be heavy, unwieldy, and would take up space that the consumer would otherwise use. Additionally, panels and non-display doors greater than six inches that use foam-in-place insulation would take an excessive amount of time to cure, impacting the practicability to manufacture, install, and service.
In section ES.4.1 of the June 2022 Preliminary Analysis, DOE requested comment on the technology options it had screened out for doors and panels. DOE received no comment on the screened out technologies for doors and panels. In this analysis, DOE is screening out the same technologies that it screened out in the June 2022 Preliminary Analysis, in addition to the eliminated anti-sweat heater system technology option.
Walk-in doors typically use anti-sweat heater wires to prevent (1) condensation from collecting on the glass, frame, or any other portion of the door, which can puddle and be hazardous to consumers, (2) glass from fogging, and (3) condensation that may lead to low-temperature doors freezing shut. The amount and rate of condensation on walk-in doors is dependent on the relative humidity surrounding the walk-in and the surface temperature of the door. To ensure the temperature of the door surface stays above the dew point of its surroundings, electric resistive heater wire is installed around the frame of the door. DOE recognizes that anti-sweat systems on doors may be necessary in high-humidity environments and DOE does not have sufficient evidence to demonstrate that anti-sweat heat can be removed from doors installed in all climate zones of the U.S. without having a potential negative impact on the safety and utility of the walk-in. Therefore, DOE is screening out eliminated anti-sweat heater systems in this NOPR on the basis of safety of technology.
Furthermore, DOE is screening out the technology option to utilize insulation from the box/cooler wall to minimize door anti-sweat heat power recommended by Hussmann-Doors in its comment and discussed in section IV.A.2.b of this document. DOE recognizes that an ideally designed walk-in box ensures that panel design could reduce door sweating; however, DOE notes that since its walk-in test procedures evaluate the performance of walk-in components separately, these design pairings are not captured by the test procedure and therefore cannot be used to analyze higher efficiency levels.
c. Refrigeration Systems
In the June 2022 Preliminary Analysis, DOE tentatively determined that adaptive defrost, hot gas defrost, oil management systems, and economizer cooling would not affect the measured AWEF2 value of walk-in refrigeration systems based on appendix C1. DOE requested comment on the screened out technologies in section ES.4.3 of the June 2022 Preliminary Analysis TSD.
HTPG commented that it agrees that oil management systems, adaptive defrost, hot gas defrost, and economizer cooling do not affect rated energy consumption as measured under the test procedures for refrigeration systems. (HTPG, No. 35 at p. 4)
DOE has tentatively determined that oil management systems, adaptive defrost, hot gas defrost, and economizer cooling would not affect the measured AWEF2 value of walk-in refrigeration systems when measured using appendix C1.
In the June 2022 Preliminary Analysis, DOE also screened out three-phase motors as a design option. In general, three-phase motors can save energy compared to single-phase motors, however, use of three-phase motors requires three-phase power. Not all businesses that use walk-ins are equipped with three-phase power, and therefore must use single-phase equipment. DOE therefore screened out this design option on the grounds of utility.
HTPG commented that it agrees with screening out three-phase motors as a technology option.
Id.
In this NOPR analysis, DOE is screening out three-phase motors based on utility.
In response to the June 2022 Preliminary Analysis, AHRI-Wine recommended that DOE consider how a 50-percent increase in condenser face area would increase the footprint of a single-packaged wine cooler system and how this increase in footprint would affect the market. (AHRI-Wine, No. 39 at p. 2) DOE received similar feedback during manufacturer interviews. DOE notes that high-temperature walk-ins are often installed in residential applications that have standard stud spacing in walls and standard joist spacing in floors and ceilings; therefore, these units may be designed to fit between these structural members for construction and aesthetic reasons. DOE has tentatively determined that consumers would lose the compact feature of high-temperature refrigeration systems if the evaporator or condenser heat exchangers underwent a considerable increase in size. Therefore, DOE is proposing to screen out improved evaporator and condenser coils for high-temperature refrigeration systems on the grounds of customer utility due to the additional heat exchanger size needed for this technology option.
The screened out technologies for fully assembled walk-ins and each component of walk-ins are discussed in more detail in chapter 4 of the accompanying TSD.
2. Remaining Technologies
Through a review of each technology, DOE tentatively concludes that none of the identified technologies for whole walk-ins, listed in section IV.A.2.a, met all five screening criteria to be examined further as design options in DOE's NOPR analysis.
a. Doors and Panels
Through a review of each technology, DOE tentatively concludes that all of the other identified technologies for doors and panels, listed in section IV.A.2.b of this document met all five screening criteria to be examined further as design options in DOE's NOPR analysis. In
summary, DOE did not screen out the following technology options:
• Glass system insulation performance for display doors,
• Occupancy sensors (lighting controls) for doors,
• Anti-sweat heater controls for doors,
• Improved frame systems and materials for non-display doors,
• Reduced anti-sweat heater systems for doors, and
• Increased insulation thicknesses up to 6 inches for non-display doors and panels.
In section ES.4.3 of the June 2022 Preliminary Analysis TSD, DOE requested comment on the screened in technologies. Hussmann-Doors stated that increased insulation thicknesses up to 6 inches for non-display doors and panels would help reduce insulation requirements on framing materials for door products and that increased wall thickness would offer additional insulation. (Hussmann-Doors, No. 33 at p. 3) DOE understands this comment to support increased insulation thicknesses up to 6 inches as a technology option for non-display doors and panels.
Additionally, Hussmann-Doors stated that the cost of applying controllers (
e.g.,
to control the on time of electrical components like lighting and anti-sweat heat) to door products is not economically justified by the resulting energy savings. However, Hussmann-Doors commented that it does use controllers on its products to be compliant with regulations. (Hussmann-Doors, No. 33 at p. 2) Hussmann-Doors also commented that it does not see a need for a change to the standard for doors based on the technology option of occupancy sensors.
Id.
DOE understands Hussmann-Doors comment to mean that it believes the energy consumption standard for doors should not change to reflect that occupancy sensors can reduce energy consumption. In response to these comments, DOE notes that it in addition to the screening analysis discussed above, it conducts a full engineering analysis to weigh the costs and energy savings of each potential design option. While DOE evaluates specific design options for the purposes of developing a representative cost-efficiency curve, manufacturers are not bound to implement the design options that DOE analyzes to meet a performance-based energy conservation standard. Manufacturers may employ any design option, whether DOE has evaluated it or not, so long as it meets the energy consumption standard based on the Federal test procedure. The engineering analysis is discussed further in section IV.C of this document.
DOE has initially determined that these technology options are technologically feasible because they are being used or have previously been used in commercially available equipment or working prototypes. DOE also finds that all of the remaining technology options meet the other screening criteria (
i.e.,
practicable to manufacture, install, and service and do not result in adverse impacts on consumer utility, product availability, health, or safety, unique-pathway proprietary technologies). For additional details, see chapter 4 of the NOPR TSD.
b. Refrigeration Systems
Through a review of each technology, DOE tentatively concludes that all the other identified technologies listed in section IV.A.2.c of this document met all five screening criteria to be examined further as design options in DOE's NOPR analysis. In summary, DOE did not screen out the following technology options for walk-in refrigeration systems:
• Hydrocarbon refrigerants,
• Higher efficiency compressors,
• Improved evaporator and condenser coil,
• Higher efficiency condenser fan motors,
• Improved condenser and evaporator fan blades,
• Ambient sub-cooling,
• Off-cycle evaporator fan control,
• Head pressure control,
• Variable-speed condenser fan control,
• Crankcase heater controls,
• Improved thermal insulation for single-packaged dedicated systems,
• Higher efficiency evaporator fan motors,
• On-cycle evaporator fan control, and
• Liquid suction heat exchanger.
In section ES.4.3 of the June 2022 Preliminary Analysis TSD, DOE requested comment on the screened in technologies. DOE received no comment on the screened in technologies for refrigeration systems.
DOE has initially determined that these technology options are technologically feasible because they are being used or have previously been used in commercially available products or working prototypes. DOE also finds that all the remaining technology options meet the other screening criteria (
i.e.,
practicable to manufacture, install, and service and do not result in adverse impacts on consumer utility, product availability, health, or safety, unique-pathway proprietary technologies). For additional details, see chapter 4 of the NOPR TSD
C. Engineering Analysis
The purpose of the engineering analysis is to establish the relationship between the efficiency and cost of each component of walk-ins (
e.g.,
doors, panels, and refrigeration systems). There are two elements to consider in the engineering analysis; the selection of efficiency levels to analyze (
i.e.,
the “efficiency analysis”) and the determination of product cost at each efficiency level (
i.e.,
the “cost analysis”). In determining the performance of higher-efficiency walk-ins, DOE considers technologies and design option combinations not eliminated by the screening analysis. For each walk-in component equipment class, DOE estimates the baseline cost, as well as the incremental cost for the walk-in component at efficiency levels above the baseline. The output of the engineering analysis is a set of cost-efficiency “curves” that are used in downstream analyses (
i.e.,
the LCC and PBP analyses and the NIA).
1. Efficiency Analysis
DOE typically uses one of two approaches to develop energy efficiency levels for the engineering analysis: (1) relying on observed efficiency levels in the market (
i.e.,
the efficiency-level approach), or (2) determining the incremental efficiency improvements associated with incorporating specific design options to a baseline model (
i.e.,
the design-option approach). Using the efficiency-level approach, the efficiency levels established for the analysis are determined based on the market distribution of existing products (in other words, based on the range of efficiencies and efficiency level “clusters” that already exist on the market). Using the design option approach, the efficiency levels established for the analysis are determined through detailed engineering calculations and/or computer simulations of the efficiency improvements from implementing specific design options that have been identified in the technology assessment. DOE may also rely on a combination of these two approaches. For example, the efficiency-level approach (based on actual products on the market) may be extended using the design option approach to “gap fill” levels (to bridge large gaps between other identified efficiency levels) and/or to extrapolate to the max-tech level (particularly in cases where the max-tech level exceeds the maximum efficiency level currently available on the market).
In this rulemaking, DOE relies on a design-option approach for doors, panels, dedicated condensing units, and single-packaged dedicated systems. DOE relies on both a design-option and an efficiency-level approach for unit coolers, depending on the equipment class. These approaches are discussed in the following sections.
a. Display Doors
Representative Units
As previously mentioned in section IV.A.1.a of this document, DOE evaluated equipment classes for display doors in the June 2022 Preliminary Analysis based on the presence or absence of a motor. In the June 2022 Preliminary Analysis, DOE analyzed three representative door sizes for manually opening display doors and two representative door sizes for motorized display doors. The representative units were based on the number of door openings within a common frame. Additionally, DOE based its representative door sizes on typical height and width of doors found in equipment product literature.
See
section 5.3.1 of chapter 5 of the June 2022 Preliminary Analysis TSD. DOE sought comment on the representative units selected in section ES.4.5 of the June 2022 Preliminary Analysis TSD.
In response, Hussmann-Doors commented that the representative door sizes used in the analysis are appropriate; however, Hussmann-Doors stated that it sells a sliding door that is larger than the representative units. (Hussmann-Doors, No. 33 at p. 3) DOE notes that the representative units it selects for analysis are intended to be representative of the display door industry as a whole and cannot capture every door available on the market. Additionally, DOE ultimately did not define representative units for motorized display doors in this NOPR since, as discussed in section IV.A.1.a of this document, DOE did not evaluate higher efficiency levels for these doors in its analysis. However, DOE may consider evaluating higher efficiency levels for motorized display doors in a future rulemaking, at which time it would determine representative units based on the market at that time.
DOE received no comments on the manually opening display door representative units; therefore, in this NOPR, DOE maintained the same manually opening display door representative units that were evaluated in the June 2022 Preliminary Analysis. Table IV.6 lists the display door classes and sizes that DOE analyzed in its engineering analysis for this NOPR, where the dimensions listed are consistent with the surface area that is used to determine the maximum daily energy consumption.
Table IV.6—Representative Units Analyzed for Display Doors
Opening mechanism
Temperature
Class code
Number of
door
openings
Dimensions
height ×
length, ft
Manual
Medium-temperature
DW.M
1
6.25 × 2.5
3
6.25 × 7.5
5
6.25 × 12.5
Low-temperature
DW.L
1
6.25 × 2.5
3
6.25 × 7.5
5
6.25 × 12.5
Baseline Efficiency, Design Options, and Higher Efficiency Levels
To determine the baseline efficiency of manually opening display doors in the June 2022 Preliminary Analysis, DOE relied on the current energy conservation standards and minimum prescriptive requirements for the glass pack of transparent reach-in doors at 10 CFR 431.306(b)(1)-(2). DOE's analysis suggested that manufacturers already implement high-efficiency frame designs to minimize thermal transmission; therefore, DOE included high-efficiency frame designs as a baseline design option for manually opening display doors in the June 2022 Preliminary Analysis.
In the June 2022 Preliminary Analysis, DOE evaluated the design options listed in Table IV.7 for manually opening display doors. As noted, design option DR1 includes baseline design options; additional design options are evaluated in DR2 (efficiency level 1) and DR3 (efficiency level 2).
Table IV.7—Design Options Evaluated in the June 2022 Preliminary Analysis and This NOPR Analysis for Display Doors
Efficiency level
Design option code
Description
Medium-temperature, manual
display doors
Low-temperature, manual
display doors
0 (Baseline)
DR1
2-pane glass with argon gas fill
3-pane glass with argon gas fill.
1
DR2
3-pane glass with argon gas fill
3-pane glass with krypton gas fill.
2
DR3
2-pane vacuum-insulated glass
2-pane vacuum-insulated glass.
In response to the June 2022 Preliminary Analysis, Hussmann-Doors commented that vacuum-insulated glass on a sliding door affects the U-factor. DOE interprets this comment to suggest that vacuum-insulated glass could be used to reach higher efficiency levels for all display doors, including manually opening display doors. DOE notes that vacuum-insulated glass is the maximum technology option for manually opening display doors.
DOE received no other comments on the design options or efficiency levels for manually opening display doors. In this NOPR analysis, DOE maintained the same baseline efficiency level, design options, and higher efficiency levels that it evaluated in the June 2022 Preliminary Analysis.
b. Non-Display Doors
Representative Units
As previously mentioned in section IV.A.1.a of this document, DOE evaluated equipment classes for non-display doors based on the presence or absence of a motorized door opener in the June 2022 Preliminary Analysis. DOE analyzed three representative sizes for each class of non-display doors based on the representative sizes analyzed for both passage and freight doors in the June 2014 Final Rule and based on typical height and width of doors found in current equipment product literature.
See
section 5.3.1 of chapter 5 of the preliminary analysis TSD. DOE sought comment on the representative units selected in section ES.4.5 of the preliminary analysis TSD. DOE did not receive any stakeholder comments with respect to non-display door representative units.
In this NOPR analysis, DOE modified the non-display door representative sizes that it evaluated based on further review of product literature and interviews with manufacturers. Table IV.8 lists the non-display door classes and sizes that DOE analyzed in the engineering analysis for this NOPR.
Table IV.8—Representative Units Analyzed for Non-Display Doors
Opening mechanism
Temperature
Class code
Size
Dimensions,
height ×
length, in
Manual
Medium-temperature
NM.M
Small
84 × 38
Medium
90 × 40
Large
96 × 56
Low-temperature
NM.L
Small
84 × 38
Medium
90 × 40
Large
96 × 56
Motorized
Medium-temperature
NO.M
Small
100 × 66
Medium
118 × 90
Large
154 × 90
Low-temperature
NO.L
Small
100 × 66
Medium
118 × 90
Large
154 × 90
Baseline Efficiency, Design Options, and Higher Efficiency Levels
To determine non-display door baseline efficiency, DOE relied on the current energy conservation standards. For the June 2022 Preliminary Analysis, based on certifications in the private certification and compliance management system (“CCMS”) database and product literature, DOE assumed that baseline non-display doors had 3.5-inch-thick insulation for coolers and 4-inch-thick insulation for freezers, wood framing materials, anti-sweat heat with no controls, and lighting with no controls.
For the June 2022 Preliminary Analysis, DOE evaluated the design options listed in Table IV.9 for non-display doors. While DOE largely maintained these design options in its analysis for this NOPR, there were a few changes specific to their implementation, discussed in more detail below.
Table IV.9—Design Options Evaluated in the June 2022 Preliminary Analysis for Non-Display Doors
Design option code
Description
Occupancy sensors (lighting controls).
LNC
No lighting controls.
LCTRL
Lighting controls.
Anti-sweat heater wire controls.
ASHNC
No anti-sweat heater controls.
ASCTRL
Anti-sweat heater controls.
Improved frame systems and lower conductivity framing materials.
FR1
Baseline non-display door frame made of wood.
FR2
Improved non-display door frame made of insulation.
Decreased anti-sweat heater power.
ASH1
Baseline anti-sweat heater power.
ASH2
Reduced or eliminated anti-sweat heater power.
Increased Insulation Thickness.
TCK1
Baseline insulation thickness.
TCK2
Increased insulation thickness 1.
TCK3
Increased insulation thickness 2.
TCK4
Increased insulation thickness 3.
In the June 2022 Preliminary Analysis, DOE included lighting in baseline manually opening non-display doors. DOE's research at the time indicated that non-display doors sometimes include lighting and switches to operate that lighting. Therefore, DOE was able to use lighting controllers as a design option for the representative units it modeled. However, upon further review of the market, DOE found that lighting may or may not be included with non-display doors. Therefore, DOE removed lighting from its baseline representative units of manually opening non-display doors in this NOPR, thus removing the use of the lighting controller as a design option in its analysis of non-display doors.
In the June 2022 Preliminary Analysis, DOE combined improved non-display door framing systems and materials with reduced or eliminated anti-sweat heater power. In section ES.4.6 of the June 2022 Preliminary Analysis TSD, DOE requested comment on its assumptions that anti-sweat heater power can be reduced or eliminated by use of improved framing systems and materials. If anti-sweat heater power can be reduced through other means of design or technology options for doors, DOE sought specific data on the achievable reduction in anti-sweat heater power and the cost to implement. DOE received no comment on whether improving framing systems and materials could reduce anti-sweat heater or by how much anti-sweat heater power could potentially be reduced.
In this NOPR analysis, DOE decoupled improved frame systems and materials from the reduction in anti-sweat heater power and implemented these as separate design options. Additionally, in this NOPR analysis, rather than present a fixed value of anti-
sweat heater wire power in watts, DOE is presenting the amount of anti-sweat heater power in terms of rated power per linear foot, which can be converted into the total anti-sweat heater power per representative unit using door leaf dimensions. DOE recognizes that the total value of anti-sweat heater power will vary based on the size of the door leaf but that manufacturers generally use wire with the same rating of power per linear foot across doors of different sizes. DOE is presenting anti-sweat heat in terms of a rated power per linear foot and is soliciting feedback on the values used in this analysis.
In the June 2022 Preliminary Analysis, DOE had considered eliminated anti-sweat heater power as a design option for medium-temperature non-display doors, however, as discussed in section IV.B.1.b of this document, DOE is no longer considering elimination of anti-sweat heater systems as a design option since DOE does not have sufficient evidence to demonstrate that doors without anti-sweat heat could be installed in all climates or installation locations. Instead, DOE has tentatively concluded in this NOPR that cooler doors could reduce anti-sweat heater power. Based on certified information in DOE's private CCMS database, approximately 93 percent of models reported a rated anti-sweat heater power of less than or equal to 2 W/ft; therefore, DOE evaluated the energy savings and cost associated with reducing rated anti-sweat heater power from baseline levels to 2 W/ft.
For low-temperature non-display doors, in the June 2022 Preliminary Analysis, DOE determined reduced anti-sweat heater power values based on a line of best fit of anti-sweat heater power versus door area from the lower third of non-zero anti-sweat heater power values certified in DOE's private CCMS database.
See
section 5.7.1.4 of chapter 5 of the June 2022 Preliminary Analysis TSD. In this NOPR analysis, based on a combination of certified values in CCMS, rated anti-sweat heater power per linear foot of wire based on product literature, and information received during confidential interviews with manufacturers, DOE has tentatively concluded that freezer doors may be able to implement a reduced rated anti-sweat heater system power of 5 W/ft.
Table IV.10 shows the baseline and reduced anti-sweat heater wire power evaluated in this NOPR for each equipment class. The design options that DOE evaluated for non-display doors for the NOPR analysis are shown in Table IV.11.
Table IV.10—Anti-Sweat Heater Wire Power per Linear Foot Used in NOPR Analysis
Equipment class
Baseline
anti-sweat
heater wire
power rating
(W/ft)
Reduced
anti-sweat
heater wire
power rating
(W/ft)
Medium-Temperature, Manually-Opening Non-Display Doors
4
2
Low-Temperature, Manually-Opening Non-Display Doors
10
5
Medium-Temperature, Motorized Non-Display Doors
4
2
Low-Temperature, Motorized Non-Display Doors
9.5
5
Table IV.11—Design Options Evaluated in This NOPR Analysis for Non-Display Doors
Design option code
Description
Anti-sweat heater wire controls.
ASHNC
No anti-sweat heater controls.
ASCTRL
Anti-sweat heater controls.
Improved frame systems and lower conductivity framing materials.
FR1
Baseline non-display door framing made of wood.
FR2
Improved non-display door framing made of insulation.
Decreased anti-sweat heater power.
ASH1
Baseline anti-sweat heater power.
ASH2
Reduced anti-sweat heater power.
Increased Insulation Thickness.
TCK1
Baseline insulation thickness.
TCK2
Increased insulation thickness 1.
TCK3
Increased insulation thickness 2.
TCK4
Increased insulation thickness 3.
DOE seeks comment on the baseline and assumed reduction in anti-sweat heater wire power listed in Table IV.10. DOE specifically seeks feedback on whether the reduced anti-sweat heater wire power is acceptable for use in walk-in doors at all climates and installations throughout the U.S.
c. Panels
Representative Units
In the June 2022 Preliminary Analysis, DOE evaluated the same representative units for each panel equipment class that it evaluated for the June 2014 Final Rule.
See
section 5.3.2 of chapter 5 of the June 2022 Preliminary Analysis TSD. DOE requested comment on these panel representative units in section ES.4.5 of the June 2022 Preliminary Analysis TSD. DOE did not receive any comments regarding the representative units analyzed for panels. Therefore, DOE maintained the same representative units it evaluated in the June 2022 Preliminary Analysis for this NOPR analysis. Table IV.12 summarizes the representative units evaluated for walk-in panel equipment classes.
Table IV.12—Representative Units Analyzed for Panels in This NOPR
Equipment
Temperature
Equipment class code
Dimensions
height ×
length, ft
Structural
Medium
PS.M
8 × 1.5
8 × 4
9 × 5.5
Structural
Low
PS.L
8 × 1.5
8 × 4
9 × 5.5
Floor
PF.L
8 × 2
8 × 4
9 × 6
Baseline Efficiency, Design Options and Efficiency Levels
For panels, DOE evaluated increasing insulation thickness to obtain higher insulation R-values as calculated pursuant to appendix B of subpart R to 10 CFR 431. The thermal resistance of insulating materials increases approximately linearly with material thickness.
For determining the baseline efficiency level, DOE relied on the current R-value standards. Based on DOE's analysis of the market, 3.5 inches of foam insulation is generally used for baseline medium-temperature panels and low-temperature floor panels, while 4 inches of foam insulation is used in baseline low-temperature structural panels to meet the minimum R-value requirements specified in 10 CFR 431.306(a)(3)-(4).
In addition, DOE found that many panel manufacturers offer insulation in thicknesses of 4, 5, and 6 inches. DOE also observed that the majority (approximately 75 percent) of the market uses polyurethane insulation, with the remainder using extruded polystyrene (“XPS”), expanded polystyrene, and polyisocyanurate insulation in its walk-in panels. Therefore, DOE assessed the incremental increase in R-value for polyurethane insulation at 4, 5, and 6 inches as design options, with 6 inches being the max-tech design option.
d. Dedicated Condensing Units and Single-Packaged Dedicated Systems
Refrigerants Analyzed
In the June 2022 Preliminary Analysis, DOE assumed R-448A as a refrigerant for medium- and low-temperature dedicated condensing units and single-packaged dedicated systems. Based on the available compressor performance coefficients, and an examination of the refrigerant compositions, DOE tentatively concluded that R-448A and R-449A have nearly identical performance characteristics for walk-in applications and that AWEF2 standards would not be meaningfully changed if analysis was conducted using R-449A instead of R-448A. R-448A/R-449A was chosen because the walk-in industry is shifting to lower global warming potential (“GWP”) refrigerants. R-448A/R-449A have much lower GWP compared to R-404A—additionally R-448A/R-449A has a higher glide, which will tend to disadvantage dedicated condensing units when they are tested alone according to the DOE test procedure. In other words, R-448A/R-449A are the most conservative, lower GWP, widely available refrigeration options. For the June 2022 Preliminary Analysis, DOE used R-134A in its evaluation of high-temperature single-packaged dedicated units since this is the only refrigerant option currently offered for this equipment.
DOE requested comment on whether the refrigerants used are representative of the current and future walk-in market in section ES.4.8 of the June 2022 Preliminary Analysis TSD. In response to the June 2022 Preliminary Analysis, DOE received several comments on the refrigerants used in the analysis and on the need to consider lower GWP refrigerants.
HTPG agreed with DOE using R-448A and R-449A in its analysis of medium- and low-temperature dedicated condensing units, specifically the compressor coefficients and the reduction in mass flow rate. (HTPG, No. 35 at pp. 3, 6) AHRI agreed with DOE using R-448A and R-449A in its analysis, however, it recommended that A2L
26
or other refrigerants (
i.e.,
R-454A, R-454C, R-455A, R-744A) be considered in a future analysis. (AHRI, No. 39 at p. 3) Hussmann-Refrigeration stated that due to the Environmental Protection Agency (“EPA”) regulations,
27
changes to refrigerants are expected and further analysis of system performance may be required to determine the efficiency impact of the new refrigerants. (Hussmann-Refrigeration, No. 38 at p. 2) Hussmann-Refrigeration additionally commented that it agrees with the views of other AHRI members on the matter of the transition to A2L refrigerants and stated that R-448A and R-449A will not be available for future markets and are currently not available for new applications at a charge level greater than 50 pounds in California. (Hussmann-Refrigeration, No. 38 at p. 4) Lennox commented that R-448A and R-449A are not representative of the future market, which would likely consist of R-454A, R-454C, R-455A, and R-744. (Lennox, No. 36 at p. 5) Lennox also stated that R-744 (
i.e.,
CO
2
) could pose a significant challenge if it is required for transcritical operation.
28
Id.
Lennox recommended that DOE consider the technological feasibility, performance, and cost impacts of the transition to lower GWP refrigerants, specifically A2L and CO
2
refrigerants, when proposing energy conservation standards. (Lennox, No. 36 at pp. 1-3). HTPG also recommended that DOE consider the transition to low-GWP refrigerants in its analysis. (HTPG, No. 35 at p. 6)
26
A2L is a refrigerant classification from the American Society of Heating, Refrigeration, and Air-Conditioning Engineers (“ASHRAE”) Standard 34: “Designation and Safety Classification of Refrigerants”. The A2L class defines refrigerants that are nontoxic, but mildly flammable. Refrigerants in this classification include R-454A, R-454C, and R-455A.
27
See
“Phasedown of
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