The TSD contains preliminary analyses performed by DOE, the performance energy conservation standard levels that DOE could consider, and the energy savings that could result from implementing these standards. In its comments to DOE, AHRI noted serious deficiencies in the engineering analysis and in particular the cost-efficiency curves that AHRI said were derived based on false assumptions and incorrect cost figures.

AHRI offered to work with DOE to improve the analysis. AHRI further questioned DOE’s intention to regulate continuous ice-makers, as the preliminary energy savings from establishing energy conservation standards were found negligible.

Publication date: 05/07/2012