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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1

1.2 OVERVIEW OF STANDARDS FOR COMMERCIAL PACKAGED BOILERS........ 1-1

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-2

1.4 STRUCTURE OF THE DOCUMENT............................................................................ 1-5

LIST OF TABLES

Table 1.3.1 Rulemaking Analysis Stages................................................................................ 1-4
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This preliminary technical support document (preliminary TSD) is a stand-alone report 

that provides the technical analyses and results supporting the information presented in the 

preliminary notice of public meeting (NOPM) and executive summary for commercial packaged

boilers. This preliminary TSD reports on the preliminary activities and analyses conducted in the 

period preceding the notice of proposed rulemaking (NOPR) of this rulemaking.

1.2 OVERVIEW OF STANDARDS FOR COMMERCIAL PACKAGED BOILERS

The U.S. Department of Energy (DOE) is initiating this rulemaking to consider amending 

the energy conservation standards for commercial packaged boilers, as required under the 

Energy Policy and Conservation Act (EPCA), as amended. EPCA defines the term “packaged 

boiler” to mean “a boiler that is shipped complete with heating equipment, mechanical draft 

equipment, and automatic controls; usually shipped in one or more sections.” (42 U.S.C. 

6311(11)(B)) EPCA prescribed the initial minimum efficiency levels (in terms of combustion 

efficiency) both for gas-fired packaged boilers and oil-fired packaged boilers with rated 

maximum input capacities of 300,000 British thermal units (Btus) or more. (42 U.S.C. 

6313(a)(4)(C) and (D)) The minimum efficiency levels generally correspond to the levels set in 

the American Society of Heating, Refrigerating, and Air-Conditioning Engineers

(ASHRAE)/Illuminating Engineering Society (IES) Standard 90.1.a Further, EPCA provides that

if ASHRAE/IES Standard 90.1 is amended with respect to packaged boilers, then DOE shall 

consider amending the prescribed minimum efficiency levels. (42 U.S.C. 6313((a)(6)) In other 

words, when ASHRAE amends the efficiency levels for packaged boilers in Standard 90.1, DOE 

must adopt the new ASHRAE requirements unless clear and convincing evidence supports a 

determination that adoption of a more-stringent level would produce significant additional 

energy savings and would be technologically feasible and economically justified. (42 U.S.C. 

6313(a)(6))

In the event that ASHRAE does not act to amend Standard 90.1 (thereby triggering DOE 

to conduct an amended standards rulemaking), EPCA provides an alternative statutory 

mechanism for initiating such review. More specifically, EPCA requires that every six years, the 

Secretary of Energy (Secretary) shall consider amending the energy conservation standards for 

covered commercial equipment and shall publish either a notice of determination that those 

standards do not need to be amended, or a notice of proposed rulemaking for more-stringent 

energy efficiency standards. (42 U.S.C. 6313(a)(6)(C))

 

a For more information, see www.ashrae.org.
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In 2009, DOE acted in response to an ASHRAE trigger and published a final rule 

amending the energy conservation standards for commercial packaged boilers to correspond to 

the efficiency levels in the most recent ASHRAE Standard 90.1, which amended commercial 

packaged boiler efficiency levels (i.e., ASHRAE Standard 90.1-2007). 74 FR 36312 (July 22, 

2009).

In addition, EPCA prescribes test procedures for packaged boilers which are generally

accepted industry testing procedures or rating procedures developed or recognized by the AirConditioning, Heating and Refrigeration Instituteb (AHRI) or by ASHRAE, as referenced in 

ASHRAE/IES Standard 90.1. (42 U.S.C. 6314(a)(4)(A)) Furthermore, EPCA directs that if an 

industry test procedure or rating procedure for packaged boilers is amended, then DOE shall 

amend the test procedure as necessary for the equipment to be consistent with the amended 

industry procedure. (42 U.S.C. 6314(a)(4)(B)) In addition to requiring DOE to update its test 

method each time the relevant industry test procedure is modified, EPCA requires that DOE 

conduct an evaluation of its test procedure for each covered class of equipment at least once 

every seven years. (42 U.S.C. 6314(a)(1)(A)) DOE last reviewed its test procedures for 

commercial packaged boilers in a final rule published in the Federal Register on July 22, 2009

(77 FR 36312), so DOE must evaluate the test procedures for this equipment not later than July 

22, 2016. DOE is considering updating the test procedures for commercial packaged boilers in a 

separate proceeding that would occur in parallel with the energy conservation standards analysis 

outlined in this TSD. DOE aims to publish a final rule for the test procedure rulemaking prior to 

completing the energy conservation standards rulemaking. 

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors under 42 U.S.C. 6313(a)(6)(B)(ii):

1) the economic impact of the standard on the manufacturers and consumers of the affected 

products; 

2) the savings in operating costs throughout the estimated average life of the product 

compared to any increases in the initial cost or maintenance expense; 

3) the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

 

b EPCA refers to the Air-Conditioning, and Refrigeration Institute (ARI), which was renamed the Air-Conditioning, 

Heating, and Refrigeration Institute (AHRI) after ARI merged with the Gas Appliance Manufacturer’s Association 

(GAMA).
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4) any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; 

5) the impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant.

DOE considers participation by interested parties to be a very important part of the 

process for setting energy conservation standards. Through formal public notifications (i.e., 

Federal Register notices), DOE actively encourages the participation and interaction of all 

interested parties during the comment period in each stage of the rulemaking. Beginning with the 

framework document and during subsequent comment periods, interactions among interested 

parties provide a balanced discussion of the information that is required for the standards 

rulemaking.

Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6313(a)(6)(B)(i))

Any new or amended standard must be designed to achieve significant additional conservation of 

energy and be technologically feasible and economically justified. (42 U.S.C. 6313(a)(6)(A)) To 

determine whether economic justification exists, DOE must review comments on the proposal 

and determine that the benefits of the proposed standard exceed its burdens to the greatest extent 

practicable, weighing the seven factors listed above. (42 U.S.C. 6313(a)(6)(B)(ii))

After the publication of the framework document, the energy conservation standards 

rulemaking process typically involves three additional, formal public notices, which DOE 

publishes in the Federal Register. The first of the rulemaking notices is a NOPM, which is 

designed to publicly vet the models and tools used in the preliminary rulemaking and to facilitate 

public participation before the NOPR stage. The second notice is the NOPR, which presents a

discussion of comments received in response to the NOPM and the preliminary analyses and 

analytical tools; analyses of the impacts of potential amended energy conservation standards on 

consumers, manufacturers, and the Nation; DOE’s weighting of these impacts of amended 

energy conservation standards; and the proposed energy conservation standards for each product. 

The third notice is the final rule, which presents a discussion of the comments received in 

response to the NOPR; the revised analyses; DOE’s weighting of these impacts; the amended 

energy conservation standards DOE is adopting for each product; and the effective dates of the 

amended energy conservation standards.

In September 2013, DOE published a notice of public meeting and availability of the 

framework document. 78 FR 54197 (September 3, 2013). The framework document, Rulemaking 

Framework Document for Commercial Packaged Boilers, describes the procedural and 

analytical approaches DOE anticipated using to evaluate the amendment of existing energy 
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conservation standards for this equipment. This document is available at: 

http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-STD-0030-0002.

Subsequently, DOE held a public meeting on October 1, 2013 (“October 2013 public 

meeting”) to discuss procedural and analytical approaches to the rulemaking. In addition, DOE 

used the public meeting to inform and facilitate involvement of interested parties in the 

rulemaking process. The analytical framework presented at the public meeting described the 

different analyses, such as the engineering analysis and the consumer economic analyses (i.e., 

the life-cycle cost (LCC) and payback period (PBB) analyses), the methods proposed for 

conducting them, and the relationships among the various analyses.

Table 1.3.1 Rulemaking Analysis Stages

Preliminary Analyses NOPR Final Rule

Market and technology assessment Revised preliminary analyses Revised NOPR analyses

Screening analysis Consumer sub-group analysis

Engineering analysis Manufacturer impact analysis

Energy use analysis Utility impact analysis

Markups for equipment price 

determination

Emissions analysis/monetization

Life-cycle cost and payback period 

analysis

Employment impact analysis

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis

During the October 2013 public meeting, interested parties commented about numerous 

issues relating to each one of the analyses listed in Table 1.3.1. Comments from interested parties 

submitted during the framework document comment period elaborated on the issues raised 

during the public meeting. DOE attempted to address these issues during its preliminary analyses 

and summarized the comments and DOE’s responses in chapter 2 of the preliminary TSD.

As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the commercial packaged boilers considered in this rulemaking 

as part of the engineering analysis. DOE selected companies that represented production of all 

types of equipment, ranging from small to large manufacturers. DOE had four objectives for 

these interviews: (1) solicit manufacturer feedback on the draft inputs to the engineering 

analysis; (2) solicit feedback on topics related to the preliminary manufacturer impact analysis; 

(3) provide an opportunity, early in the rulemaking process, to express manufacturers’ concerns 

to DOE; and (4) foster cooperation between manufacturers and DOE.
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DOE incorporated the information gathered during the engineering interviews with 

manufacturers into its engineering analysis (chapter 5) and the preliminary manufacturer impact 

analysis (chapter 12). Following the publication of the preliminary analyses and the NOPM 

public meeting, DOE intends to hold additional meetings with manufacturers as part of the 

consultative process for the manufacturer impact analysis conducted during the NOPR phase of 

the rulemaking.

DOE developed an LCC spreadsheet that calculates the LCC and PBP at various energy 

efficiency levels. DOE also developed a national impact analysis spreadsheet that calculates the 

national energy savings (NES) and national net present values (NPVs) at various energy 

efficiency levels. This spreadsheet includes a model that forecasts the impacts of amended 

energy conservation standards at various levels on equipment shipments. All of these 

spreadsheets are available on the DOE website for commercial packaged boilers:

(http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/79).

1.4 STRUCTURE OF THE DOCUMENT

This preliminary TSD outlines the analytical approaches used in this rulemaking. The

TSD consists of seventeen chapters, including an environmental assessment and a regulatory 

impact analysis, and appendices. The first 12 chapters of the preliminary TSD address the 

analyses performed for the preliminary analysis stage. Chapters 13 through 17 describe the 

analyses to be performed for the NOPR stage.

Chapter 1 The introduction provides an overview of standards for CPBs and 

describes DOE’s process for setting energy conservation standards. 

Chapter 2 The analytical framework describes each preliminary analysis step, the 

comments received in response to the analytical approaches DOE 

described in the Framework Document, and DOE’s responses to those 

comments. 

Chapter 3 The market and technology assessment (MTA) characterizes the relevant 

equipment markets and technology options, including prototype designs. 

Chapter 4 The screening analysis reviews each technology option uncovered in the 

MTA to determine whether it is technologically feasible, practicable to 

manufacture, install, service; would adversely affect equipment utility or 

equipment availability, or would have adverse impacts on health and 

safety.

Chapter 5 The engineering analysis develops cost-efficiency relationships that 

show a manufacturer’s cost of achieving increased efficiency. 
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Chapter 6 The markups analysis estimates commercial consumer equipment prices 

based on market structures, and the manufacturing costs developed in 

the engineering analysis. 

Chapter 7 The energy use analysis determines the annual energy consumption of 

the equipment under consideration.

Chapter 8 The life-cycle cost and payback period analysis (PBP) discusses the 

effects of standards on individual commercial consumers and users of 

the equipment and compares the LCC and PBP of equipment with and 

without higher efficiency standards. 

Chapter 9 The shipments analysis documents historic unit shipments and forecasts 

future shipments of equipment at potential energy conservation standard 

levels under consideration

Chapter 10 The national impact analyses (NIA) assesses the cumulative national 

energy savings (NES) from potential standards and the net present 

values (NPV) of consumer costs and savings associated with standards 

at different efficiency levels. 

Chapter 11 The consumer subgroup analysis evaluates the effects of potential 

energy conservation standards of standards on subgroups of the 

population (e.g. small businesses) 

Chapter 12 The preliminary manufacturer impact analysis (MIA) assesses the 

potential impacts of energy conservation standards on manufacturers, 

such as effects on expenditures for capital conversion, marketing costs, 

shipments, and research and development costs. 

Chapter 13 The emissions analysis examines the effects of potential energy 

conservation standards on various airborne emissions. 

Chapter 14 Monetization of emission reduction quantifies the anticipated benefits 

from potential energy conservation standards.

Chapter 15 The utility impact analysis examines impacts of potential energy 

conservation standards on the generation capacity of electric utilities.

Chapter 16 The employment impact analysis examines the effects of potential 

energy conservation standards on national employment. 
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Chapter 17 The regulatory impact analysis examines the national impacts of nonregulatory alternatives to mandatory energy conservation standards. 

Appendix 6A Detailed Data for Equipment Price Markups

Appendix 7A Building Variables

Appendix 7B Determination of Boiler Energy Use in the Life-Cycle Cost Analysis

Appendix 7C Weather Station Data Mapping to RECS and CBECS Buildings

Appendix 8A User Instructions for Life-Cycle Cost Analysis Spreadsheet for 

Commercial Packaged Boilers

Appendix 8B Uncertainty and Variability in the Life-Cycle Cost Analysis

Appendix 8C Energy Price Calculations for Commercial Packaged Boilers

Appendix 8D Installation Cost Determination for Commercial Packaged Boilers

Appendix 8E Maintenance and Repair Cost Determination for Commercial Packaged 

Boilers

Appendix 8F Commercial Packaged Boiler Lifetime Determination

Appendix 8G Distributions Used for Discount Rates

Appendix 8H Base Case Distribution of Efficiency Levels

Appendix 9A Relative Price Elasticity of Demand for Appliances

Appendix 9B Additional Shipments Data for Commercial Packaged Boilers

Appendix 10A User Instructions National Impact Analysis Spreadsheet Model

Appendix 10B Full-Fuel-Cycle Multipliers