CFA joined advocates in comments to DOE in response to the notice of webinar and availability of preliminary technical support document (TSD) for miscellaneous refrigeration products (MREFs). We encourage DOE to capture the improved full-load efficiency of variable-speed compressors. We are concerned that DOE is underestimating the potential savings from upgrading from a single-speed compressor to a variable speed compressor (VSC) by not accounting for the higher energy efficiency ratio (EER) values of variable-speed compressors. We urge DOE to ensure that the energy savings associated with the improved part-load performance of variable speed compressors are being appropriately captured for compact coolers.