2010-01-26 Comment expressing concern over DOE’s testing requirements and enforcement

There are three approaches to ensuring energy efficiency in walk ins, the first two options; test the unit as a whole, or allow manufactures to use AED methods. DOE is proposing to separately test the two main pieces of walk-ins because of variations in the. The methods of testing walk-ins originally used were predicated on the assumption that an entire walk-in unit is manufactured by a single manufacturer. The problem is, the envelope is usually manufactured separately from the refrigeration unit, so testing them as a whole likely does not give a good idea of the overall energy efficiency of a single seller of walk ins. There would seem to be variations within single manufacturers of the final product because of inconsistencies in the parts, not the whole. Having separate tests for each component should be a more efficient and accurate way to ensure consistent energy efficiency. It would allow the people who manufacturer the separate parts to test their own components. These component manufacturers would be more likely to have access to the resources to conduct the tests and the knowledge of the production process used so that they could adequately adjust their methods based on the tests. That being said, DOE still needs to adopt and enforce these standards for testing, and I have some problems with The overall approach seems to be a vast improvement on the original process, but until I see the actual DOE testing requirements, I'll continue to be skeptical. Additionally, the definitions of envelope and refrigeration system are a bit too inclusive. While I understand the appeal of making them mutually exclusive. Requiring tests of the entire outer portion (including all pieces) seems excessive. It seems to me that the envelope could be defined a bit more narrowly so as to avoid some unnecessary testing.