November ’22 at-a-glance … energy

SBA Advocacy hosts productive roundtable with NAFEM, DOE, EPA and others

A recent roundtable discussion with the Small Business Administration (SBA) Office of Advocacy (Advocacy) provided the industry with an opportunity to raise concerns about accuracy and data gaps identified during the recent notice and comment process for Commercial Refrigeration Equipment (CRE). In addition to the SBA Advocacy team and NAFEM members, the meeting was attended by the U.S. Department of Energy (DOE), U.S. Environmental Protection Agency (EPA), and those representing the Air-Conditioning, Heating and Refrigeration Institute (AHRI) and National Automatic Merchandising Association (NAMA).

In opening comments, NAFEM Vice President, Regulatory and Technical Affairs Charlie Souhrada, CFSP, shared that, “The recent notice and comment period presented a unique challenge for AHRI, NAMA and NAFEM members because, like the agencies, many of the small business members – and even the large ones, for that matter – aren’t blessed with endless resources. But these companies do have specific industry expertise to know what is technically feasible and economically justified, and they’re eager to work with the agencies and other stakeholders to bring about positive change.”

AHRI shared preliminary results from a recent survey showing that many design options proposed in the 2022 preliminary technical standards document are already in use to meet the current energy conservation standards, leaving very few feasible design options to meeting new standards. For example, refrigerants have not been developed specifically for CRE. Additionally, some equipment that has been designed around propane is subject to building code limitations banning flammable liquids in areas of egress.

“SBA Advocacy is charged with making sure federal agencies have properly considered the impacts of rules and regulations on small businesses,” said Jeff Longsworth, NAFEM legal counsel, Barnes & Thornburg. They are a formal part of the rulemaking process, but do not host roundtables on every topic. They have been a valued resource to NAFEM over the years and it was very important that they convened the industry with DOE and EPA to address continued standards development.”

DOE publishes final rule covering test procedures for automatic commercial ice makers

DOE issued a final rule amending the test procedures for automatic commercial ice makers that includes updates to the latest industry standards, test conditions, requirements, calculations and enforcement provisions. The requirements take effect Dec. 1 and changes are mandatory for equipment testing starting Oct. 27, 2023.


During the NAFEM Technical Liaison Committee (TLC) meeting in October, ENERGY STAR representatives who attended expressed interest in exploring some of the product category extensions NAFEM has suggested in the past. NAFEM will continue to work with ENERGY STAR to do so.