DOE to review, possibly revise test procedures and energy-efficiency standards

Every five years, the DOE revisits test procedures and energy-efficiency standards for a variety of commercial foodservice equipment. In 2020, DOE is scheduled to review test procedures for automatic commercial ice makers (ACIM), commercial refrigeration equipment (CRE) and walk-in coolers/freezers (WIC/F). EPA also will determine whether to amend the current energy-efficiency standards for CRE and WIC/F. Review of the ACIM energy-efficiency standards is scheduled for 2021.

Tammy Helminski, NAFEM legal counsel, Barnes & Thornburg, is hopeful DOE will first finalize its proposed Process Rule (see story above) before undertaking this review. However, regardless of how DOE proceeds, now is the time for NAFEM members to begin to prepare.

“Although we’re not sure what direction the government is going to take, companies should begin preparing now. Education is key and preparing yourself and your company is critical,” said Charlie Hon, manager, sustainability and government affairs, True Manufacturing, O’Fallon, Mo. “We’re not sure if new product categories, like prep tables, will be added to DOE’s review, so my advice is to always be conservative and plan ahead.”

Stephen Schaefer, compliance engineer III, Hoshizaki America, Peachtree City, Ga., shared step-by-step guidelines to help NAFEM members begin to prepare:

1. Familiarize yourself with DOE’s Appliance and Equipment Standards Rulemakings and Notices website; sign up for email updates on your product categories.
2. Review the current standards and know how your products perform on DOE’s energy-efficiency curves.
3. Schedule time to review and comment when DOE requests information. Comments are usually due 30 days after a rule is proposed. Also, work with NAFEM so your perspective is reflected in its comments on behalf of the industry.
4. Attend meetings and rulemaking discussions to learn more and provide your perspective.
5. Be ready to provide data to validate whether DOE’s assumptions are technologically feasible and economically justified. This entails researching currently available motors, compressors and condensers for your products.

“If you want to dispute DOE’s data, you must be willing to provide your own, which can be protected as confidential business administration information,” Charlie added.

NAFEM continues to closely monitor DOE’s activity and alert members when it issues requests for information (RFIs) to begin these review processes.