CFA joins advocates in comments to the Department of Energy on its notice of proposed rulemaking regarding test procedures for refrigerators.

The following recommendations are made in the comments:

• DOE should consider adopting the IEC (International Electrotechnical Commission) 62552:2015 test procedure for refrigerators and freezers to improve representativeness.
• DOE should maintain the existing approach of testing demand-response function communication modules in the as-shipped configuration and adopt a similar approach for other consumer-accessible features.
• DOE should maintain the existing approach of testing demand-response function communication modules in the as-shipped configuration and adopt a similar approach for other consumer-accessible features.