Date:    January 31, 2006

To:       Our Customers and Consultants

Re:       New California Energy Commission Appliance Efficiency Regulations

Background - California Public Resources Code Section 25402(c) has required the California Energy Commission to adopt standards for the energy efficiency of appliances whose use requires a significant amount of energy on a statewide basis.  Beginning in December 2004, the Energy Commission adopted numerous changes to the Appliance Efficiency Regulations that now include walk-in coolers and freezers.  Some of these changes have taken effect on January 1, 2006 for cold storage units installed in California.

It should be noted that the guiding principle of the Commission is that new and upgraded standards must be feasible and attainable and must not “result in any added total costs to the consumer over the designed life of the appliance”.  In other words, the energy cost saved through increased efficiency will offset the higher initial cost.

RMI has been working closely with the authors of the California Energy Commission’s Appliance Efficiency Regulations and with our primary material vendors in order to insure complete compliance of our walk-in cold storage units installed in California. 

Current Regulations – The Commission’s current regulations as they affect walk-ins are summarized in Table A-6 from page 110 of the most recent version of the California Appliance Efficiency Regulations and is reproduced here along with RMI’s compliance comments in the last column:

Table A-6:

Energy Design Standards for Walk-In Refrigerators and Walk-In Freezers

Envelope Definition - The walk-in “envelope” is defined on page 9 of the Commission’s Proposed Amendments to Appliance Efficiency Regulations (Express Terms) of the California Code of Regulations, Title 20: Sections 1601 – 1608, dated December 27, 2005 as follows:

“Envelope” of a walk-in refrigerator or walk-in freezer means the walls and ceiling of the walk-in refrigerator or walk-in freezer but not the doors or floors.

We have confirmed with the Commission that the interior dividing wall in a cooler/freezer combo box need not be R-36 and that standard 4” insulation is sufficient.  This concurs with our assumption that it is unnecessary to provide a 5” insulated wall between a freezer and cooler where the temperature differential is only about 40°F compared to a typical 80°F differential between a freezer and ambient.

R-36 Insulation for Freezers – In order to comply with this requirement, the exterior insulated walls and ceilings at all new walk-in freezers must be increased from the de facto industry standard of 4” to a minimum of 5”.  This is based on RMI’s highly efficient, exclusive formula polyurethane foam insulation that has been tested by independent laboratories to ASTM C5045 standards to meet the new efficiency requirement.

Designers need to be aware that additional room needs to be provided in their designs for freezer sections with 5” thick walls and ceilings.  The cost of providing 5” panels will quite obviously be higher than the standard 4” panels and additional costs will also be incurred in cooler/freezer combination units where a transition from 5” to 4” requires special corner and tee pieces.  On some smaller units, it may be appropriate to specify the thicker 5” panels for the entire unit rather than the freezer section alone.  In either case, the energy cost savings of operation should offset the higher cost of equipment acquisition.

Notes - There are a number of clarifications that should be mentioned for a complete understanding of the impact of these regulations.  These explanations are a result of several telephone interviews with Jim Holland who is the principal author of the regulations themselves.  If the reader requires further information, Mr. Holland can be reached by email through the Commission’s website at http://www.energy.ca.gov/.

1. Grand-Fathering Clause – Since the custom walk-in cold storage unit is unique in the way it is designed and configured and often involves long lead times, it’s compliance with the appliance regulations is subject to “grand fathering”.  Many projects due to install after the January 1, 2006 were designed prior to the rule’s effective date and do not have to be redesigned.  Any project that had “a reasonable amount of design work performed prior to the effective date” is therefore exempt from these rules.  Based on this, all projects quoted by RMI prior to January 1, 2006 will be made using 4” freezer walls and ceilings unless the customer wishes to pay to upgrade the freezer insulation.  All RMI cold storage units are already compliant with the remainder of the regulations.

2. Enforcement – There is no means in place at this time for any kind of enforcement of the appliance efficiency rules.

3. Testing and Certification – There is no provision for requiring testing or certification for walk-in cold storage units at this time.  It is possible that at a latter date, the Commission may perform a survey of field installations to determine the level of compliance and make appropriate recommendations at that time.

4. The R-Value Definition – The R-value requirement for the insulation envelope is not defined with respect to “initial” versus “aged” value.  Nor is the testing standard currently defined, although this may be corrected in the near future.  Meanwhile, it is therefore permitted to use the highest tested value obtained in any test in order to comply with the energy regulations.

5. Retrofitting Requirement - There is no provision for retrofitting existing walk-in appliances and they can continue to be serviced and repaired without the need to upgrade to current regulations.

RMI remains fully committed to providing our customers a leading edge product that fully complies with all State, Federal, NSF, and UL requirements.  Please direct any questions or comments to the undersigned.

Thank you again for your continued interest in RMI products and services.

Regards,

RMI – Refrigerator Manufacturers Inc.

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