October ’22 at-a-glance … energy

Comprehensive refrigeration survey to inform meeting with SBA Office of Advocacy

Our thanks to NAFEM-member companies that responded to the comprehensive commercial refrigeration equipment survey fielded by the Air-Conditioning, Heating and Refrigeration Institute (AHRI) in collaboration with NAFEM. The survey asked for supplemental information related to engineering design options and components used to meet U.S. Department of Energy (DOE) energy-efficiency standards. NAFEM and AHRI believe the proposed standards contain several errors that impact the agency’s requirement to ensure the proposed standards are technologically feasible, economically justified and will produce significant energy savings.

All responses will be kept confidential. The results are being compiled, aggregated, anonymized and submitted to the DOE and their subcontractor – Guidehouse. Additionally, they will be shared during an Oct. 28 virtual, roundtable meeting with the Small Business Administration (SBA) Office of Advocacy. The roundtable is an opportunity to share member concerns with DOE, hopefully the U.S. Environmental Protection Agency (EPA), and get the SBA’s continued engagement in these issues. As an independent voice for small- and medium-sized businesses within the federal government, the Small Business Association Office of Advocacy (SBAOA) has been a valued resource to NAFEM over the years.

DOE to publish final rule for test procedures for automatic commercial ice makers

DOE issued a pre-publication final rule amending the test procedures for automatic commercial ice makers. Changes required in the new rule will be mandatory 360 days after the rule is published in the Federal Register. The new rule establishes a relative humidity test condition; provides additional details regarding certain test conditions, settings, set-up requirements and calculations; includes a voluntary measurement of potable water use; clarifies certification and reporting requirements; and adds enforcement provisions. It also provides additional detail to the DOE procedure to improve the representativeness and repeatability of the current test procedure.

Here’s the status of other outstanding DOE actions:

NAFEM urges California Public Utilities Commission (CPUC) to maintain gas energy-efficiency rebates

NAFEM wrote to the California Public Utilities Commission (CPUC) expressing strong disagreement with its proposal to phase out natural gas energy-efficiency incentives. It said, “NAFEM looks forward to engaging with the CPUC on this issue to develop a plan that achieves the overarching goals without limiting consumer choice and running the risk of putting foodservice owners/operators out of business.”

A CPUC assessment found that “a significant percentage of funding for gas energy efficiency goes to measures that are not cost-effective and, by far, the largest categories of measures that are non-cost effective are appliances.” As a result, CPUC prepared an action plan for consideration that would start phasing out gas energy-efficiency rebate incentives over the next 10 years if a similar electric measure is reasonably commercially available and can demonstrate a reduction in greenhouse gas emissions.

While the effort is primarily focused on residential water heating and space heating appliances, it also includes energy-efficiency rebates for commercial appliances.

ENERGY STAR^® opens award application nomination process

The application portal is open for the 2023 ENERGY STAR awards for organizations that have made outstanding contributions to protecting the environment through superior energy achievements. Applications are due Nov. 16.

Reminder to register with State Appliance Standards Database to avoid financial penalties

When Massachusetts issues final energy efficiency standards before Jan. 1, 2023 for a variety of commercial food service equipment it will be the 9^th state, plus Washington, D.C., to require that manufacturers register with the Northeast Energy Efficiency Partnerships’ (NEEP) State Appliance Standards Database (SASD). Massachusetts is currently developing final standards for commercial hot-food holding cabinets, ovens, dishwashers, fryers and steam cookers. Comments were due Aug. 30.

In addition to Massachusetts, Colorado, Hawaii, Maine, Nevada, Oregon, Rhode Island, Vermont, Washington and Washington D.C. require SASD registration and may issue financial penalties for products not meeting minimum efficiency levels sold within their borders. The SASD was created by NEEP to make compliance with state standards easier for the industry.

California also requires manufacturers to certify the performance of some products sold in the state via the California Energy Commission (CEC)’s  Modernized Appliance Efficiency Database System (MAEDbs). Details on these Title 20 appliance efficiency regulations are here. In the past, several members had questions about the accuracy of the data in the database. NAFEM learned that it is the responsibility of each manufacturer to ensure that their products are listed correctly. The California Energy Commission does not update the database with information from ENERGY STAR^® or other sources.