Test Procedures and Energy Conservation Standar

Certain Equipment in ASHRAE Standard 90.1-20

Notice of Proposed Rulemaking (NOPR

Public Meeting 

Building Technologies Program

Office of Energy Efficiency and Renewable Energy

U.S. Department of Energy

April 7, 2009

http://www.eere.energy.gov/buildings/appliance_standards/commercial/ashrae_products_

EERE-2008-BT-STD-0013 COMMENT 11
 Purposes

• To present methodologies and characterize results for rulemaking analyses• To discuss specific issues related to each analysis;• To seek input from interested parties on methodologies, assumptions, data 

results from the analyses; and

• To describe the next steps.

Purpose of the Public Meeting

Introductio

EERE-2008-BT-STD-0013 COMMENT 11
Statutory Authority – Energy Policy and 

Conservation Act, as amended

 Addresses the requirements of 42 USC 6313(a)(6)(A)-(B).

 The Energy Policy and Conservation Act (EPCA) directs DOE to co

amending the existing Federal energy conservation standard for eequipment listed, each time ASHRAE Standard 90.1 is amended wto such equipment. 

 For each type of equipment, EPCA directs that if ASHRAE Standa

amended, DOE must review and adopt amended standards at the efficiency level in ASHRAE Standard 90.1, unless clear and convinevidence supports a determination that adoption of a more stringeefficiency level would:

• Produce significant additional energy savings;• Be technologically feasible; and• Be economically justified. (42 U.S.C. 6313(a)(6)(A)(ii))

Introductio

EERE-2008-BT-STD-0013 COMMENT 11
 Opening Remarks

• At this time, DOE welcomes opening remarks from interested parties on the 

certain ASHRAE Equipment.

 Comments from Participants

• Participants are invited to provide summary comments or statements;• Participants are invited to raise additional issues for discussion today; and• Participants are invited to submit comments during the NOPR comment per

open through June 3, 2009.

Opening Remarks and Comments from Interes

Parties on the Proposed Test Procedures an

Energy Conservation Standards 

Introductio

EERE-2008-BT-STD-0013 COMMENT 11
NOPR Analyses Flow Diagram

Determin

Engineering Analysis

Determination

of Scope

Life-Cycle Cost

and Payback 

Period Analysis

NOPR Final 

Rule

Effective

Date

NatioAnal

MarketAssessment 

Test Procedures 

EERE-2008-BT-STD-0013 COMMENT 11
Scope of Coverage Determination for the Rulem

 To determine the scope of coverage for ASHRAE Standard 90.1-2

equipment, DOE first reviewed all the changes made in ASHRAE S

90.1-2007.

 DOE identified any apparent changes to the efficiency levels of eq

covered by ASHRAE Standard 90.1-2007.

 DOE determined whether the apparent changes actually represen

increase in efficiency from existing Federal standards, thereby triDOE action.

Determin

EERE-2008-BT-STD-0013 COMMENT 11
Determin

ASHRAE Standard 90.1-2007 

Scope of Coverage Determination Summar

Equipment Class Preliminary Deter

Gas-fired Commercial Warm Air Furnaces No action required

Oil-fired Commercial Warm Air Furnaces No action required

Three-Phase Through-the-Wall Air-Cooled Air Conditioners and Heat Pumps

EISA 2007 specifiestandards.

Three-Phase, Small-Duct, High-Velocity Air-Cooled Air Conditioners and Heat Pumps

EISA 2007 specifiestandards.

Commercial Package Air-Cooled Air Conditioners with a Cooling Capacity at or above 760,000 Btu/h

DOE does not havto consider amend

Water-Cooled and Evaporatively-Cooled Commercial Package Air Conditioners and Heat Pumps with a Cooling Capacity at or above 

135,000 Btu/h and less than 240,000 Btu/h

No action required

Water-Cooled and Evaporatively-Cooled Commercial Package Air Conditioners and Heat Pumps with a Cooling Capacity at or above 240,000 Btu/h and less than 760,000 Btu/h

Further consider AStandard 90.1-200levels.

Commercial Packaged Boilers Further consider A

Standard 90.1-200levels.

EERE-2008-BT-STD-0013 COMMENT 11
Commercial Packaged Boiler Backsliding Ana

 EPCA’s “anti-backsliding” clause mandates that the Secretary sh

prescribe any amended standard that either increases the maximallowable energy use or decreases the minimum required energy of covered equipment. (42 U.S.C. 6295(o)(1); 42 U.S.C. 6316(a)) 

 ASHRAE Standard 90.1-2007 changes the efficiency metric for eig

equipment classes of commercial packaged boilers from combusefficiency to thermal efficiency.

• Since there is no direct relationship or method of comparison for thermal an

efficiency, DOE developed an analytical approach to assist in determining thstringencies of the thermal efficiency levels specified in ASHRAE Standard 

compared to the Federal energy conservation standards specified in terms o

efficiency .

• In order to make the comparison between efficiency metrics, DOE analyzed 

relationship between thermal and combustion efficiency for the minimally co

equipment in DOE’s database. For each equipment class, DOE established difference between the two efficiency metrics.

Determin

EERE-2008-BT-STD-0013 COMMENT 11
Commercial Packaged Boiler Backsliding Ana

 DOE considered several additional factors in its backsliding analysi

• The accuracy and validity of the thermal efficiency ratings reported by manufac

equipment literature or in AHRI’s database.

• The benefits of switching to a thermal efficiency metric and requiring manufact

thermal efficiency for these eight equipment classes.

• The overall energy savings that would result from adopting the efficiency levels 

Standard 90.1-2007 compared to current Federal energy conservation standar

 Based on both its analytical approach and the additional factors con

DOE has tentatively concluded that the efficiency levels in ASHRAE 90.1-2007 represent an increase in efficiency as compared to the exenergy conservation standards.

 DOE performed a market analysis, economic analysis, and energy s

analysis for all of the identified commercial packaged boiler equipmto consider energy conservation standards at the ASHRAE Standard efficiency levels, as well as at levels more stringent than those founStandard 90.1-2007.

Determin

EERE-2008-BT-STD-0013 COMMENT 11
NOPR Analyses Flow Diagram

T

Engineering Analysis

Determination

of Scope

Life-Cycle Cost

and Payback 

Period Analysis

NOPR Final 

Rule

Effective

Date

NatioAnal

MarketAssessment 

Test Procedures 

EERE-2008-BT-STD-0013 COMMENT 11
Definition of Combustion and Thermal Efficienc

Commercial Packaged Boilers

(Issue #1)

 DOE is proposing changes to the definitions in the 10 CFR Part 431

concerning commercial packaged boilers, including:

• Add thermal efficiency definition to read: “Thermal efficiency for a commercia

boiler is determined using test procedures prescribed under §431.86 and is th

heat absorbed by the water or the water and steam to the higher heating valu

burned.”

• Amend combustion efficiency definition to read: “Combustion efficiency for a 

packaged boiler is determined using the test procedures prescribed under §4

equals to 100 percent minus percent flue loss (percent flue loss is based on i

energy).”

T

DOE seeks comment on its proposed definitions for 

“thermal efficiency” and “combustion efficiency” fo

commercial packaged boilers.

EERE-2008-BT-STD-0013 COMMENT 11
Test Procedures for Commercial Packaged Bo

 Summary of the proposed changes effective 180 days on or after the 

publication date:

• Updates to the test procedures for commercial packaged boilers in 10 CFR Pa

reference the most recent version of the Hydronics Institute (HI) Boiler Testing BTS-2000 (Rev06.07)).

– DOE’s changes do not include any substantive changes to the actual test methods cu

commercial packaged boilers.

• Elimination of the reference to an obsolete alternative test procedure for steel b

PTC 4.1.

– The provision in 10 CFR Part 431 allowing for the use of ASME PTC 4.1 as an alterna

for steel commercial packaged boilers expired on October 23, 2006.

 Summary of the proposed changes effective on or after March 3, 201

• Requirements for commercial packaged boilers to be tested and rated for the e

(i.e. combustion or thermal efficiency) that is applicable based on the proposed for each equipment class using the HI BTS-2000 (Rev06.07) testing procedure

T

EERE-2008-BT-STD-0013 COMMENT 11
Test Procedures for Commercial Packaged Bo

 Dual output boilers (capable of producing either steam or hot wat

• DOE currently allows dual output boilers to be tested as steam boilers and r

steam and hot water modes.

• If the ASHRAE Standard 90.1-2007 efficiency levels are adopted as Federa

large steam boilers will be required to meet a thermal efficiency standard, wwater boilers would be required to meet a combustion efficiency standard. S

regardless of output type, will be required to meet a thermal efficiency stand

 DOE is proposing to allow small dual output boilers to be tested f

efficiency in steam mode only and rated for thermal efficiency in steam and hot water modes using the result of the thermal efficie

steam mode, or to be tested and rated for thermal efficiency sepaeach mode.

 DOE is proposing to allow manufacturers to rate large dual outpu

large steam boilers based on the result of the thermal efficiency tperformed in steam mode, and as large hot water boilers based oof the combustion efficiency test performed in steam mode. In adis proposing to allow dual output boilers to be tested and rated seeach output mode.

T

EERE-2008-BT-STD-0013 COMMENT 11
NOPR Analyses Flow Diagram

Mark

Engineering Analysis

Determination

of Scope

Life-Cycle Cost

and Payback 

Period Analysis

NOPR Final 

Rule

Effective

Date

NatioAnal

MarketAssessment 

Test Procedures 

EERE-2008-BT-STD-0013 COMMENT 11
 Market Assessment

• To characterize the commercial boiler markets to determine available equipme

manufacturers, and shipments.

Purpose

Mark

EERE-2008-BT-STD-0013 COMMENT 11
Equipment Classes

 DOE is proposing 10 equipment classes of commercial packaged 

differentiated by input capacity (i.e., small or large), fuel type (i.e., 

output (i.e., hot water or steam) and draft type (i.e., natural draft or 

 DOE is proposing the following 10 equipment classes, which are c

with those specified in ASHRAE Standard 90.1-2007:

• Small Gas Hot Water;• Small Gas Steam All Except Natural Draft;• Small Gas Steam Natural Draft;• Small Oil Hot Water;• Small Oil Steam;• Large Gas Hot Water;• Large Gas Steam All Except Natural Draft;• Large Gas Steam Natural Draft;• Large Oil Hot Water; and• Large Oil Steam.

Mark

EERE-2008-BT-STD-0013 COMMENT 11
Market Analysis

 Commercial Packaged Boilers Overall Market Characteristics

• Approximately 36,000 units covered by this rulemaking were shipped in 2007 (

data).

• DOE identified 46 brand names under which commercial packaged boilers are 

or marketed.

 Performance Data Sources

• DOE used the Institute of Boiler and Radiation Manufacturers’ (I=B=R) Ratings 

Baseboard Radiation, Finned Tube (Commercial) Radiation, and Indirect-Fired (January 2008 Edition) as the basis for its market analysis.

• DOE used information found in manufacturer catalogs to confirm information in 

Ratings Directory whenever possible. DOE also used information from manufadatasheets to identify efficiency ratings of commercial boilers that are not I=B=

Mark

EERE-2008-BT-STD-0013 COMMENT 11
 Dual output boilers are capable of operating in both hot water and s

The data provided in the I=B=R Directory lists efficiency ratings for output boilers. 

 The test procedure for dual output commercial packaged boilers req

that manufacturers test the steam mode, and allows them to rate the performance in both steam and hot water modes using the results omode test.

 For the NOPR analysis, DOE assumed the efficiencies listed for dua

boilers were representative of the boilers being operated in the steabecause of the test procedure requirements for dual output boilers.

Dual Output Commercial Packaged Boile

(Issue #2)

DOE seeks information which would allow DOE to conve

steam ratings in the I=B=R Directory and manufacture

catalogs for dual output boilers to hot water ratings

Mark

EERE-2008-BT-STD-0013 COMMENT 11
NOPR Analyses Flow Diagram

Engin

Engineering Analysis

Determination

of Scope

Life-Cycle Cost

and Payback 

Period Analysis

NOPR Final 

Rule

Effective

Date

NatioAnal

MarketAssessment 

Test Procedures 

EERE-2008-BT-STD-0013 COMMENT 11
Downstream Ana

• Life-Cycle Cost and 

Period

• National Impacts An

Cost – Efficiency 

Relationship

Incremental 

Contractor Cost

Thermal Efficiency

 Characterize the relationship between contractor cost and efficien

(thermal efficiency or combustion efficiency).

Purpose of the Engineering Analysis

Engin

EERE-2008-BT-STD-0013 COMMENT 11
 Efficiency-Level Approach

• The efficiency level approach allows DOE to examine the relative costs of ach

increases in energy efficiency levels without regard to the particular design m

would use to achieve such efficiency increases. 

• The efficiency levels that DOE considered in the engineering analysis for eac

class are representative of commercial packaged boiler equipment available o

• DOE developed baseline cost and incremental costs based on discussions w

contractors.

 Representative Gross Output Capacities

• DOE focused the engineering analysis on the gross output capacities identifie

2000 Screening Analysis for EPACT-Covered Commercial Heating, VentilatinConditioning and Water-Heating Equipment

– For small equipment (i.e. gross output capacity is between 300 and 2,50

collected data for commercial packaged boilers with a gross output capakBtu/h, 800 kBtu/h, and 1,500 kBtu/h. 

– For large equipment, DOE collected data for commercial packaged boile

output capacity near 3,000 kBtu/h.

Engineering Analysis Method

Engin

EERE-2008-BT-STD-0013 COMMENT 11
 Data Collection

• DOE contacted mechanical contractors to obtain data for commercial packag

identified by their efficiency, gross output, type of output, type of fuel, and typsystem. 

• DOE collected data across a range of efficiencies for various manufacturers n

representative gross output capacities.

 Aggregating Data to Develop Cost-Efficiency Relationship

• DOE normalized the data for “small” commercial packaged boiler equipment 

output capacity.

• DOE aggregated the data for each of the ten equipment classes and fit a curv

characterized the cost-efficiency relationship.

• DOE subtracted the baseline cost (i.e. the cost of equipment at ASHRAE Sta

2007 levels) to normalize the cost data in order to identify the incremental cos

higher efficiency levels.

 Results

• A set of cost-efficiency results that represent the cost to increase the efficienc

average boiler in each equipment class. The results do not represent any sing

design, material, or manufacturer, but rather an average cost-efficiency relatio

all manufacturers and designs for the given equipment class.

Engineering Analysis Method

Engin

EERE-2008-BT-STD-0013 COMMENT 11
NOPR Analyses Flow Diagram

Life-Cycle Cost and Payback P

Engineering Analysis

Determination

of Scope

Life-Cycle Cost

and Payback 

Period Analysis

NOPR Final 

Rule

Effective

Date

NatioAnal

MarketAssessment 

Test Procedures 

EERE-2008-BT-STD-0013 COMMENT 11
Purpose of the Life-Cycle Cost and Paybac

Period Analysis

 To characterize the reduction in operational expenses, increases 

cost, and resultant customer life-cycle cost savings and payback higher efficiency commercial packaged boiler equipment. 

 Analysis Components

• Energy Analysis of Commercial Packaged Boiler Energy Consumption;• Markup Analysis Applied to Engineering Analysis Contractor Prices; and• Life-Cycle Cost and Payback Period Calculations.

Life-Cycle Cost and Payback P

EERE-2008-BT-STD-0013 COMMENT 11
 Life-Cycle Cost (LCC) equals customer installed price plus the su

annual operating costs discounted to a particular base year (2012case) in 2008$.

 Economic evaluation from the customer perspective. Results are expressed as LCC savings (baseline minus standard  Simple payback period (in years) is also calculated and reported i

analysis.

Life-Cycle Cost and Payback P

Life-Cycle Cost Analysis

Combine Changes 

in Costs 

Installed Cost

(Customer Price + Installation Cost)

Operating Costs

Convert to 

Present 

Value

EERE-2008-BT-STD-0013 COMMENT 11
Energy Analysis Method

 Energy Analysis

• Conducted using Full Load Equivalent Operating Hour (FLEOH) estimates f

Commercial Packaged Boiler used in Seven Building Types and 11 Climate DOE’s 2000 Screening Analysis (77 Market Sectors).*

• FLEOH is ratio of annual boiler heating load to boiler capacity.

 Market Segmentation

• States and Buildings within climate regions were assigned FLEOHs from ap

climate region.

 Annual Energy Consumption (in Million Btu/yr) is calculated as:

AEC = 0.001 x Boiler Capacity (kBtu/h) x FLEOH / EfficiencyseasonalEfficiencyseasonal = Thermal efficiency for non-condensing boilers

= Adjusted thermal efficiency for condensing boilers (to reflec

temperature assumptions during the course of the year)

Life-Cycle Cost and Payback P

E

*U.S. Department of Energy Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for ConsScreening Analysis for EPACT Covered Commercial HVAC and Water Heating Equipment Screening Analysis. April 200Note. These FLEOHs include impact of standby losses on energy use.

EERE-2008-BT-STD-0013 COMMENT 11
Markups to Determine Equipment Price

 Distribution Channel Markup Chain Assumptions (from contractor 

• New Construction: Mechanical Contractor -> General Contractor -> Customer • Replacements: Mechanical Contractor -> Customer (100%).

 Inputs

• Firm balance sheets data:

– Mechanical Contractors: U.S. Census Bureau Financial Data for Plumbin

Air-Conditioning Contractors, 2002 and Air Conditioning Contractors of Afinancial analysis data.

– General Contractors: U.S. Census Bureau Financial Data for Commercia

Institutional Building Construction Contractors.

• State Sales Tax Data• 33% to 67% split of equipment between new construction and replacement m

respectively.

 Outputs

• Weighted average baseline markups of 1.48 for replacement market and 1.77 

construction market (including sales tax). Average baseline markup of 1.56 ap

baseline contractor costs.

• Weighted average incremental markups of 1.20 replacement market and 1.29 

construction market (including sales tax). Average Incremental markup of 1.22 

incremental cost of higher efficiency equipment.

Life-Cycle Cost and Payback P

Markups to Determine E

EERE-2008-BT-STD-0013 COMMENT 11
Fuel Prices

 LCC analysis was based on state average commercial oil and nat

prices from EIA. 

 Fuel price adjustments by building type were developed using the 

average price in 2003 CBECS by building type to the reported comaverage price in CBECS.

 These adjustments were applied to the state-by-state average com

sector electricity prices calculated from EIA data for 2006 to obtastate electricity prices by business type. 

 These state-by-state prices by building type were projected for 20

beyond using EIA AEO 2008 national commercial fuel price trends commercial oil and natural gas fuels. For years beyond the EIA pr(2030-2042), fuel price trends were projected based on the averagin the period from 2020-2030.

Life-Cycle Cost and Payback P

EERE-2008-BT-STD-0013 COMMENT 11
 Installation Costs

• Baseline Installation costs developed from Means Costworks Data for natur

and steam boilers as a function of equipment capacity. Oil-fired hot water a

assumed to be equivalent. 

• Additional installation costs adders introduced for boilers with higher combu

levels to account for non-corrosive venting and for condensate removal whe

For the replacement market adders also include labor costs to retrofit ventin

• Installation costs adjusted for each state using Means Costworks Data.

 Discount Rates

• Based on weighted average cost of capital for businesses from Damodaran 

(website).

• Aligned specific business type data with commercial buildings to get weight

of capital by building type.

 Equipment lifetime assumed to be 30 years. Baseline repair costs developed using MARS Facility Cost Databa

• Repair cost assumed to increase proportionally to first cost at higher efficien

use of more costly manufacturing components. 

 Maintenance Costs

• Based on RS Means Costworks Database, held constant with efficiency lev

Other LCC Inputs

Life-Cycle Cost and Payback P

EERE-2008-BT-STD-0013 COMMENT 11
Installation Cost

(Issue #3)

 For more-stringent efficiency levels, DOE estimated the cost for sta

venting based on an assumed 35-foot flue length and applied the ematerials cost to commercial packaged boilers going into the replamarket. 

 In addition, DOE assumed additional costs for control modification

efficiency boilers and for condensate removal for near condensing condensing boilers. 

 DOE recognized, however, that installation costs could potentially 

with higher efficiency commercial packaged boilers due primarily tconcerns with existing flues and chimney cases in the replacement 

 DOE did not have data to calibrate the extent to which additional co

apply.

Life-Cycle Cost and Payback P

DOE seeks comment and information on how installation 

could potentially increase with higher-efficiency comme

packaged boilers due primarily to venting concerns

EERE-2008-BT-STD-0013 COMMENT 11
LCC and Payback Period Results

 LCC results are expressed as national average LCC savings as w

terms of the distribution of LCC savings for higher standards comadoption of the baseline level (ASHRAE Standard 90.1-2007 efficielevels).

 Using data from the market assessment with regards to current s

DOE also developed estimates of the fraction of the market with nincrease, net LCC decrease, and no change in LCC.

 Payback Period (PBP) results are expressed in terms of national a

PBP as well as in terms of a distribution of PBP for the boiler mar

Life-Cycle Cost and Payback P

EERE-2008-BT-STD-0013 COMMENT 11
NOPR Analyses Flow Diagram

National I

Engineering Analysis

Determination

of Scope

Life-Cycle Cost

and Payback 

Period Analysis

NOPR Final 

Rule

Effective

Date

NatioAnal

MarketAssessment 

Test Procedures 

EERE-2008-BT-STD-0013 COMMENT 11
Purpose of the National Impact Analysis

 National Impact Analysis

• To estimate the National Energy Savings (NES) from adoption of commerci

boiler standards higher than the ASHRAE Standard 90.1-2007 efficiency lev

• To estimate the national economic impact on the nation (in terms of nationa

Present Value (NPV) from adoption of commercial packaged boiler standar

than the ASHRAE Standard 90.1-2007 efficiency levels.

 Analysis Components

• Shipment Analysis;• National Energy Savings Calculations; and• National Net Present Value Calculations.

National I

EERE-2008-BT-STD-0013 COMMENT 11
Shipment Analysis

National I

 Shipments Analysis – Purpose

• To estimate shipments of commercial packaged boilers over time.

 Methodology

• Disaggregated 2007 shipment data by equipment class.• Assumed saturation rate of boilers in new commercial construction is the sam• Assumed average boiler life of 30 years results in a replacement rate for stoc

years.

• Used 2007 estimate of commercial building growth to commercial building sto

2008 to estimate shipments going to new construction and replacement mark

• Future shipments going to new construction based on the ratio of AEO2008 c

construction growth (sf) in years 2012-2042 to 2007 growth (sf).

• Future replacements based on replacements required for future stock based o

based survival function for commercial packaged boilers (30 yr average life).

• Distribution of vintages in existing stock based on long term steady-stat

survival function.

EERE-2008-BT-STD-0013 COMMENT 11
National Impact Analysis - Methodology

 National Energy Savings (NES) calculated for period from 2012 thro

30 year energy savings period from earliest possible standard effec

 National NPV calculated from 2012-2085, which covers life-cycle ins

operational expenses for all equipment shipments between 2012 an

 Both NES and NPV analysis take into account a two-year delay for D

standards more stringent than the efficiency levels in ASHRAE Stan2007.

• Amended energy conservation standards at the ASHRAE efficiency levels imp

2012.

• Amended energy conservation standards at more stringent efficiency levels tha

ASHRAE Standard 90.1-2007 implemented in 2014.

• Energy savings benefits for adopting the efficiency levels in ASHRAE Standard 

based on market assessment of average thermal efficiency of the fraction of bo

stock below ASHRAE efficiency level.

 Used national average customer prices, annual energy use, energy 

annual repair and maintenance expenditures from LCC analysis.

 Streams of energy use and total costs calculated over analysis time 

all costs (expenditures) discounted to the present.

National I

EERE-2008-BT-STD-0013 COMMENT 11
National Impact Analysis – Methodology Conti

 Analysis used a distribution of boilers shipments mapped to each of 

levels considered (i.e., those efficiency levels include a level below-AASHRAE level, and up to 4 higher efficiency levels) based on mappinassessment data for available boiler models to the analyzed efficienc

 Amended energy conservation standards assumed to “roll up” less-e

equipment to standard level, but not to affect projected shipments fohigher efficiency levels.

 Once an amended standard is in place, old equipment goes out of the 

according to base case efficiency mix. New equipment is sold and reaccording to the new efficiency mix.

 Fuel prices based on extrapolation of EIA data from AEO 2008 (2020-

National I

Example Distribution of Efficiencies for Small Gas-Fired Hot Water 

Equipment Class Energy Efficiency Level

Below 0 (Market 

Baseline)

~77.5% ET

Level 0 

(ASHRAE) 

80% ET

Level 1 

82% ET

Level 2 

84% ET

Level 3 

86% ET

Le

Small, Gas-Fired, Hot Water

8.9% 14.3% 29.3% 22.3% 7.7% 17

EERE-2008-BT-STD-0013 COMMENT 11
National Impact Analysis

(Issues #4 through #6)

National I

DOE seeks comment on the potential for a rebound effe

occur in the commercial packaged boiler industry. (Issu

DOE seeks comment on DOE’s assumption and the pote

significance of any overestimation of savings. In partic

DOE requests data that would allow it to better characte

the likely increases in packaged boiler efficiencies that w

occur over the 30-year analysis period absent amend

energy conservation standards. (Issue #5)

DOE seeks comment on the NES-forecasted base-ca

distribution of efficiencies and DOE’s prediction of ho

amended energy conservation standards affect the 

distribution of efficiencies in the standards case. (Issue 

EERE-2008-BT-STD-0013 COMMENT 11
National Impact Analysis – Results

 Cumulative NES savings (2012-2042) provided for establishing am

energy conservation standards at efficiency levels more stringent those in ASHRAE Standard 90.1-2007.

• NES based on the difference between the NES savings for adoption of the A

in 2012 and adoption of higher standard levels in 2014.

 Cumulative NPV savings (2012-2085) provided for establishing am

energy conservation standards at efficiency levels more stringent those in ASHRAE Standard 90.1-2007 using both 3-percent and 7-discount rates.

• NPV based on the difference between the NPV savings for adoption of the A

in 2012 and adoption of higher standard levels in 2014.

National I

EERE-2008-BT-STD-0013 COMMENT 11
 Closing Remarks

• At this time, DOE welcomes any additional remarks or questions from interes

the NOPR for certain ASHRAE Equipment.

 DOE specifically invites comment on:

• The proposed test procedure amendments for commercial packaged boilers;• The proposed energy conservation standard levels (i.e., the efficiency levels s

ASHRAE Standard 90.1-2007) for commercial packaged boilers; and

• The proposed energy conservation standard levels (i.e., the efficiency levels s

ASHRAE Standard 90.1-2007) for water-cooled and evaporatively-cooled com

package air conditioners and heat pumps with a cooling capacity at or above 

and less than 760,000 Btu/h.

Closing Remarks and Comments from Interes

Parties on the Proposed Test Procedures and E

Conservation Standards 

Proposed Standards and C

EERE-2008-BT-STD-0013 COMMENT 11
Proposed Standards and C

Equipment Type Subcategory Size Category 

(Input)

Efficiency LevelEffective Date: March 2, 2012

Hot Water Commercial Packaged Boilers

Gas-fired

≥ 300,000 Btu/h and ≤ 2,500,000 Btu/h 80% E

T 

Hot Water Commercial Packaged Boilers

Gas-fired > 2,500,000 Btu/h 82% E

C 

Hot Water Commercial Packaged Boilers

Oil-fired

≥3 00,000 Btu/h and ≤ 2,500,000 Btu/h 82% E

T 

Hot Water Commercial Packaged Boilers

Oil-fired > 2,500,000 Btu/h 84% E

C 

Steam Commercial Packaged Boilers

Gas-fired – all, except natural draft

≥ 300,000 Btu/h and ≤ 2,500,000 Btu/h 79% E

T 

Steam Commercial Packaged Boilers

Gas-fired – all, except natural draft

> 2,500,000 Btu/h 79% E

T 

Steam Commercial Packaged Boilers

Gas-fired – natural draft

≥ 300,000 Btu/h and ≤ 2,500,000 Btu/h 77% E

T 

Steam Commercial Packaged Boilers

Gas-fired – natural draft

> 2,500,000 Btu/h 77% E

T 

Steam Commercial Packaged Boilers

Oil-fired

≥ 300,000 Btu/h and ≤ 2,500,000 Btu/h 81% E

T 

Steam Commercial Packaged Boilers

Oil-fired > 2,500,000 Btu/h 81% E

T 

Proposed Amended Energy Conservation Standa

Commercial Packaged Boilers

*ET is thermal efficiency and EC is combustion efficiency.

EERE-2008-BT-STD-0013 COMMENT 11
Proposed Amended Energy Conservation Stand

for Water-Cooled and Evaporatively-Cooled 

Commercial Package Air-Conditioning and Hea

Equipment with a cooling capacity at or above 2

Btu/h and less than 760,000 Btu/h

Equipment Type Size Category Heating Section 

Type

Efficiency 

Water-cooled and evaporativelycooled commercial package air conditioners and heat pumps

≥ 240,000 Btu/h and 

≤

760,000 Btu/h Electric Resistance 

(or none) 11

Water-cooled and evaporativelycooled commercial packaged air conditioners and heat pumps

≥ 240,000 Btu/h and 

≤

760,000 Btu/h All other 10

*EER is energy efficiency ratio.

Proposed Standards and C

EERE-2008-BT-STD-0013 COMMENT 11
How to Submit Comments...

 Public Meeting – Oral comments will be captured in the transcript 

part of the public record.

 Written comments – NOPR comment period open until June 3, 200

Reference docket #: EERE-2008-BT-STD-0013 and/or RIN #: 1904–

Email: ASHRAE_90.1_rulemaking@ee.doe.govMail: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mail stop EE-2JNOPR for ASHRAE Standard 90.1 EquipmentEERE-2008-BT-STD-00131000 Independence Avenue, SW.Washington DC, 20585-0121

Courier: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, 6th FloorWashington, DC 20024

EERE-2008-BT-STD-0013 COMMENT 11