1 | Energy Efficiency and Renewable Energy eere.energy.gov

[INSERT PICTURE(S) OF PRODUCT(S)]

[INSERT PICTURE(S) OF PRODUCT(S)]

Energy Conservation Standards: 

Preliminary Analysis for

Commercial Packaged Boilers

December 9, 2014

James Raba

Department of Energy

Building Technologies Office

EERE-2013-BT-STD-0030

PkgdBoilers2013STD0030@ee.

doe.gov
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• “Norms”

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of 

this meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar 

conversations.

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.
3

Purpose of the Public Meeting

• To present methodologies and characterize results for 

analyses to date.

• To discuss specific issues related to each analysis

• To seek input from attendees on methodologies, 

assumptions and data sources.

• To describe upcoming analyses and next steps
4

Agenda

9:00 am – 9:15 am Welcome; Introductions and Agenda Review 

9:15 am – 9:45 am Purpose of Public Meeting; Opening Statements; Comment Submission 

Instructions; and Regulatory Authority and Rulemaking Overview 

9:45 am – 10:15 am Market and Technology Assessment and Screening Analysis

10:15 am – 10:45 am Engineering Analysis

10:45 am – 11:00 am Break

11:00 am – 12:00 pm Markups; Energy Use Characterization and LCC and Payback Period Analysis

12:00 pm– 1:00 pm Lunch (on your own)

1:00 pm – 1:30 pm LCC and Payback Period Analysis (cont.)

1:30 pm – 2:15 pm National Impact Analysis

2:15 pm – 2:30 pm Break

2:30 pm – 2:45 pm Preliminary Manufacturer Impact Analysis

2:45 pm – 3:15 pm Next Steps

3:15 pm – 3:30 pm Closing Remarks from Interested Parties and Adjournment
5

Housekeeping Items – Listening Via the Webcast

• The Department of Energy is broadcasting this public 

meeting “live” over the Internet for interested parties who 

are unable to attend in person.

• All interested parties are encouraged to submit written 

comments after the public meeting.
6

Opening Remarks

Meeting participants are invited to provide 

opening remarks or statements at this time.
7

Issue boxes correspond to the list of issues published at the end 

of the Executive Summary chapter of the Preliminary Technical 

Support Document, available at:

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BTSTD-0030

The deadline for submitting comments is January 20, 2015.

Issues for Discussion

Issue Box: DOE welcomes comments, data, and 

information concerning its proposed analyses for 

amended energy conservation standards for 

commercial packaged boilers. 

Whether invited by an issue box or not, comments 

are welcome on any part of DOE’s analysis.
8

How to Submit Comments

• In all correspondence, please include all of the following:

o Energy Conservation Standards for Commercial Packaged Boilers

o Docket Number: EERE-2013-BT-STD-0030

o Regulatory Identification Number (RIN): 1904-AD01

• Contact Information

Email: PkgdBoilers2013STD0030@ee.doe.gov

Postal Mail:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office

Mailstop EE-5B

1000 Independence Avenue, SW

Washington, DC 20585-0121

Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office

L’Enfant Plaza, SW, Suite 600 

Washington, DC 20024

Telephone: (202) 586-2945
9

Public Meeting Slides Topics

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
10

Regulatory Authority

• Energy Policy and Conservation Act (EPCA) of 1975 (P.L. 94-163)

– Established the Energy Conservation Program for Certain Industrial 

Equipment

• Energy Policy Act of 1992 (EPACT 1992), (P.L. 102−486) amended 

EPCA to add commercial packaged boilers as a type of covered 

equipment. (42 U.S.C. 6311(1)(J) and (11)(B)) 

• EPCA directs DOE to consider amending existing Federal energy 

conservation standards for commercial packaged boilers whenever 

the American Society of Heating, Refrigerating, and AirConditioning Engineers (ASHRAE) amends the efficiency levels in 

Standard 90.1. (42 U.S.C. 6313(a)(6))

• Energy Independence and Security Act of 2007 (EISA 2007) (P.L. 110-140) and the 

American Energy Manufacturing Technical Corrections Act (AEMTCA) (P.L. 112-210) 

amended EPCA to require that every 6 years, the Secretary publish either:

– A notice of the determination that standards for the product do not need to be amended; or

– A notice of proposed rulemaking including new proposed standards (42 U.S.C. 6313(6)(C)(i))

• DOE last published a final rule for CPB in 2009 (74 FR 36312 (July 22, 2009)).
11

Rulemaking Overview – Definitions

• EPCA defines “packaged boiler” as:

– “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)) 

• DOE further defines “commercial packaged boiler” in 10 CFR 431.82 

as: 

– “Commercial packaged boiler” means a type of packaged low pressure boiler that 

is industrial equipment with a capacity, (rated maximum input) of 300,000 Btu/h or 

more which, to any significant extent, is distributed in commerce: (1) For heating or 

space conditioning applications in buildings; or (2) For service water heating in 

buildings but does not meet the definition of a ‘hot water supply boiler’ in [part 

431].

– “Packaged low pressure boiler” is defined as “a packaged boiler that is: (1) A steam 

boiler designed to operate at or below a steam pressure of 15 psig [pounds per 

square inch gauge]; or (2) A hot water boiler designed to operate at or below a 

water pressure of 160 psig and a temperature of 250 °F; or (3) A boiler that is 

designed to be capable of supplying either steam or hot water, and designed to 

operate under the conditions in paragraphs (1) and (2) of this definition.” (10 CFR 

431.82)
12

Rulemaking Overview – Current Energy Efficiency Standards

*Effective March 2, 2022, energy conservation standard will be 

increased to a Thermal Efficiency of 79%

Equipment type Subcategory Size category (input) Efficiency 

level Effective Date

Hot Water Commercial 

Packaged Boilers Gas-fired ≥300,000 Btu/h and ≤2,500,000 Btu/h 80.0% ET March 2, 2012

Hot Water Commercial 

Packaged Boilers Gas-fired >2,500,000 Btu/h 82.0% EC March 2, 2012

Hot Water Commercial 

Packaged Boilers Oil-fired ≥300,000 Btu/h and ≤2,500,000 Btu/h 82.0% ET March 2, 2012

Hot Water Commercial 

Packaged Boilers Oil-fired >2,500,000 Btu/h 84.0% Ec March 2, 2012

Steam Commercial 

Packaged Boilers

Gas-fired—all, 

except natural draft

≥300,000 Btu/h and 

≤2,500,000 Btu/h 79.0% ET March 2, 2012

Steam Commercial 

Packaged Boilers

Gas-fired—all, 

except natural draft >2,500,000 Btu/h 79.0% ET March 2, 2012

Steam Commercial 

Packaged Boilers

Gas-fired—natural 

draft

≥300,000 Btu/h and 

≤2,500,000 Btu/h 77.0% ET March 2, 2012*

Steam Commercial 

Packaged Boilers

Gas-fired—natural 

draft >2,500,000 Btu/h 77.0% ET March 2, 2012*

Steam Commercial 

Packaged Boilers Oil-fired ≥300,000 Btu/h and ≤2,500,000 Btu/h 81.0% ET March 2, 2012

Steam Commercial 

Packaged Boilers Oil-fired >2,500,000 Btu/h 81.0% ET March 2, 2012
13

Rulemaking Overview – Current Process

• DOE is considering revisions to the energy conservation standards for 

commercial packaged boilers under subpart E of 10 CFR Part 431. 

• Notice of Public Meeting and Availability of the Framework Document 

Published on September 3, 2013. 78 FR 54197.

– Framework Document public meeting was held October 1, 2013.

• Notice of Public Meeting and Availability of the Preliminary Technical 

Support Document published on November 20, 2014. 79 FR 69066.

– The standards preliminary analysis comment period ends January 20, 2015.

• Preliminary analysis based on the existing test procedure under subpart 

E of 10 CFR Part 431

– DOE is conducting a rulemaking to update the existing test procedures for 

commercial packaged boilers. 

• DOE is conducting a coverage determination for natural draft CPBs.

See http://www1.eere.energy.gov/buildings/appliance_standards/ 

product.aspx/productid/74 
14

Rulemaking Overview – Timeline

Milestone Date

Preliminary Analysis Publication November 20, 2014

Preliminary Analysis Public Meeting December 9, 2014

Comment Period Ends January 20, 2015

NOPR Publication (projected) July, 2015

Final Rule Publication (projected) July, 2016

2013 2014 2015 2016 2017 2018 2019 2020

Energy Conservation 

Standards Timeline
15

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

consider seven factors when setting energy conservation standards.

Factor Analysis

Economic impact on consumers 

and manufacturers

Life-cycle cost analysis

Manufacturer impact analysis

Lifetime operating cost savings Life-cycle cost analysis

Total projected energy savings National impact analysis 

Impact on utility or performance Screening analysis

Engineering analysis

Impact of any lessening of competition Manufacturer impact analysis

Need for national energy conservation National impact analysis

Other factors the Secretary considers 

relevant

Environmental assessment;

Utility impact analysis;

Employment impact analysis

Rulemaking Overview - Analyses
16

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Steps for the Standards Rulemaking: Preliminary 

Activities and Analyses

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization

Rulemaking Overview – Preliminary Analysis
17

Public Meeting Slides Topics

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
18

Rulemaking Overview - Market & Technology Assessment 

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization

Steps for the Standards Rulemaking: Preliminary 

Activities and Analyses
19

M&TA – Purpose and Introduction

Commercial Packaged Boiler Equipment Classes†

Mechanical Draft Natural Draft

Small Gas-Fired Hot Water Small Gas-Fired Hot Water

Small Gas-Fired Steam Small Gas-Fired Steam

Small Oil-Fired Hot Water Small Oil-Fired Hot Water

Small Oil-Fired Steam Small Oil-Fired Steam 

Large Gas-Fired Hot Water Large Gas-Fired Hot Water

Large Gas-Fired Steam Large Gas-Fired Steam

Large Oil-Fired Hot Water Large Oil-Fired Hot Water

Large Oil-Fired Steam Large Oil-Fired Steam

† Small ≥300,000 Btu/hr and ≤2,500,000 Btu/hr and 

Large > 2,500,000 Btu/hr

Purpose:

• Define equipment classes

• Characterize the CPB 

industry

• Identify existing regulatory 

and voluntary energy 

efficiency programs

• Gather relevant market data

• Analyze market data 

• Identify technology options 

for improving efficiency
20

M&TA – Scope

• Covers all “packaged low pressure” boilers :

– Having input capacity greater than or equal to 300,000Btu/h;

– Fired using gas (natural gas or propane) or oil;

– Capable of producing hot water, steam or both; and

– That are mechanical draft or natural draft.

• Electric CPBs are not covered under the scope of this rulemaking.

– Efficiencies already approach 100%, so there is negligible energy saving 

potential.

• DOE is conducting a coverage determination to clarify its authority to 

regulate natural draft CPBs.

• Standby mode and off mode energy conservation standards are not 

included in the scope.

– Standby mode and off-mode energy use is only 0.02% of the total boiler 

annual energy use. 

• No upper limit of input capacity set for regulating CPBs.
21

M&TA – Sample of Market Performance Data 

• Small Gas-Fired Mechanical Draft Hot Water

 76

 80

 84

 88

 92

 96

 100

300 - 400400 - 500500 - 600600 - 700700 - 800800 - 900

900 - 1000

1000 - 11001100 - 12001200 - 13001300 - 14001400 - 15001500 - 16001600 - 17001700 - 18001800 - 19001900 - 20002000 - 21002100 - 22002200 - 23002300 - 24002400 - 2500

Average Thermal Efficiency [%]

Input Rating Category [kBtu/h]

Average Thermal Efficiency Based on Input Rating

Overall thermal efficiency Condensing Boilers

6%

6%

62%

23%

3%

Distribution of Boilers Based 

on Material of Primary Heat 

Exchanger

Aluminum

Cast Iron

Copper

Stainless

Steel

Steel

Total: 728

0

30

60

90

120

150

180

80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99

Number of Models

Thermal Efficiency [%]

Distribution of Boilers Based on Thermal Efficiency

Other Boilers Condensing Boilers Condensing and Modulating Boilers Modulating Boilers
22

M&TA – Technology Assessment

Gas Oil

Fan/ Blower 

(Forced Draft)

Valve

Air MD ND

Water

Cold Hot

Single stage or 

Modulating burners

Vent Damper

Inducer Fan

Heat Exchanger

- Multiple designs

- Single or multiple 

pass

- Different Materials

Convection and Radiation

Basic operation of 

Commercial Packaged 

Boilers

P

Oil Pump

Water 

pump

Atomizer
23

M&TA – Technology Assessment

Technology Options Considered to Improve Combustion and/or Thermal Efficiency

Jacket Insulation Optimization

Heat Exchanger Improvements: 

Condensing heat exchanger 

Increase in heat exchanger surface area 

Incorporation of heat exchanger surface features and internal features

Flat, wavy or louvered finned HX with or without staggered fin configuration

Burner Derating

Combustion Air Preheaters

Economizers

Blow-down Waste Heat Recovery

Premix Burner

Pulse Combustion

Low-Pressure, Air-Atomized Oil Burner

Integrated, High-Efficiency Steam Boilers
24

Market & Technology Assessment – Issues for Comment

Issue #2: DOE seeks comment on the appropriateness of its 

tentative decision to classify CPBs into 16 equipment classes.
25

Screening Analysis 

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Steps for the Standards Rulemaking: 

Preliminary Activities and Analyses

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization
26

Screening Analysis 

• Purpose:

Screen out technology options that DOE will not consider in the engineering 

analysis and downstream analyses for commercial packaged boilers.

• Approach

DOE evaluates each technology option based on the following criteria, as 

provided at 10 CFR Part 430, Subpart C, Appendix A, section 4(a)(4)(i)-(iv)

– Technological feasibility

– Practicability to manufacture, install, and service

– Adverse effects on equipment utility or availability 

– Adverse effects on health and safety

• DOE will not consider a technology further if it is a proprietary 

technology and uses a unique pathway to achieving a higher 

efficiency level
27

Screening Analysis – Summary of Results

• Heat exchanger improvement:

− Condensing and secondary heat 

exchanger

− Outside surface enhancement: 

Micro-fin, dimples and other 

surface enhancement

− Internal surface enhancement: 

Turbulators, corrugation, rifling, 

baffles

− Improvement in fin design: Wavy or 

louvered fin designs

• Premix burners

• Pulse combustion

• Low-pressure, air-atomized burner

Passed Screening Test

• Burner derating

Failed Screening Test

• Jacket insulation optimization

• Combustion air preheaters

• Economizers

• Integrated, high-efficiency steam 

boilers

• Blowdown waste heat recovery

Passed Test – But Not Considered*

*These technologies have negligible or no impact on thermal or combustion efficiency as measured by the 

current test procedure. Integrated high-efficiency steam boiler is a combination of several different technology 

options. This technology does not provide any new option other than what has already been identified.
28

Screening Analysis – Issues for Comment

Issue #3: DOE is interested in views about the technological and 

economic feasibility of the technology options which successfully 

passed the screening analysis.
29

Public Meeting Slides Topics

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
30

Engineering Analysis 

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Steps for the Standards Rulemaking: 

Preliminary Activities and Analyses

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization
31

Engineering Analysis – Introduction

• Purpose: Establish relationship between 

equipment price and increased efficiency.

• Results are not representative of a particular 

manufacturer, but instead represent an 

industry aggregate.

• Results will be used for other downstream 

analyses (e.g., LCC analysis, Payback period). 

• Sources of Information: 

– Product literature 

– Trade association databases 

– Manufacturer interviews 

– List prices from manufacturers and contractors

• Life-Cycle Cost and 

Payback Period Analysis

• National Impacts Analysis

• Shipments Analysis

• Manufacturer Impact 

Analysis

Downstream Analyses

Price Efficiency Curves

Manufacturer Selling 

Price [$]

Efficiency [%]
32

Engineering Analysis – Steps

Develop 

Baseline

• Define baseline efficiency for each equipment class

• Baselines defined based on existing energy 

conservation standards

Establish 

Efficiency Levels

• Identify efficiency levels between baseline and 

maximum (max-tech) efficiency levels

• Selected efficiency levels are most common on market 

and/or capture significant technologies

Calculate 

Incremental 

Prices

• Incremental prices for increased efficiency are 

calculated from equipment price information

• Statistical and regression modeling techniques are 

used to infer prices if not available and aggregate data

Generate Price 

Efficiency Curves

• Industry average representation of incremental change 

in equipment price for achieving higher efficiency 

levels
33

Engineering Analysis – Baseline Models

• Baseline efficiency levels chosen that correspond to existing 

energy conservation standards

• Common technologies in baseline models:

• Baseline Efficiencies:

80% ET

SGNDHW

82% EC

LGNDHW

82% ET

SONDHW

84% EC

LONDHW

77% ET

SGNDST

77% ET

LGNDST

81% ET

SONDST

81% ET

LONDST

80% ET

SGMDHW

82% EC

LGMDHW

82% ET

SOMDHW

84% EC

LOMDHW

79% ET

SGMDST

79% ET

LGMDST

81% ET

SOMDST

81% ET

LOMDST

Gas Valve – single stage Primary Heat Exchanger

Cast iron sectional, copper-fin tube, water 

Jacket Insulation tube, fire tube, carbon steel

Mechanical Draft Equipment Class Natural Draft Equipment Class

• ET: Thermal Efficiency and EC: Combustion Efficiency

• S: Small; L: Large

• G: Gas (Natural or Propane) ; O: Oil

• MD: Mechanical Draft; ND: Natural Draft;

• HW: Hot Water; ST: Steam
34

Engineering Analysis – Efficiency Levels

• Efficiency levels identified based on literature review, 

manufacturer interviews, and technology assessment

• Condensing efficiency levels considered for small and large 

mechanical draft hot water equipment classes

• “Max – Tech” efficiency levels – highest efficiency level that is 

commercially available

81%

82%

85%

SGNDHW

83%

84% 

LGNDHW

83%

85%

87%

SONDHW

85%

86%

LONDHW

79%

80%

SGNDST

79%

80%

81%

LGNDST

82%

83%

SONDST

82%

83%

85%

LONDST

Natural Draft Equipment Class

83%

85%

87%

92%

95%

98%

SGMDHW

84%

86%

94%

97%

LGMDHW

83%

84%

87%

98%

SOMDHW

86%

88%

97%

LOMDHW

80%

81%

83%

SGMDST

80%

83%

LGMDST

83%

84%

86%

SOMDST

83%

86%

LOMDST

Mechanical Draft Equipment Class

Condensing Efficiency Levels
35

Engineering Analysis – Data Collection

• DOE collected list prices from 

contractors and manufacturers.

• Prices reflect the level at which the 

manufacturer sells the equipment to 

the first customer.

• Prices were spread over a range of 

input capacities; however, analysis 

prices were calculated at a single 

input capacity.

• This is referred to as the 

“representative input capacity” and is 

used to define a single input rating 

that characterizes the entire 

equipment class.

Large 

(>2,500kBtu/h) 

Equipment Class

Small 

(300kBtu/h to 

2,500kBtu/h) 

Equipment Class

Representative Input Capacity

800kBtu/h 3,000kBtu/h

96%

4%

Comparison of Prices Received

Mechanical Draft Natural Draft
36

Engineering Analysis – Methodology 

• Based on the prices received, DOE has divided the 

methodology into 5 sections.

Methodologies Used

General Approach

Non-Condensing 

SGMDHW and LGMDHW

Non-Condensing 

SOMDHW and LOMDHW

SGMDST

SOMDST

LGMDST and LOMDST

Condensing SGMDHW and 

LGMDHW

Condensing SOMDHW and 

LOMDHW

All Natural Draft Equipment 

Classes
37

Engineering Analysis – General Approach Methodology

• Some low-efficiency boiler models had selling prices higher than high-efficiency 

models, possibly due to additional features that don’t contribute to efficiency

Step 1: Equipment Classes

Group boilers with prices 

into equipment classes

Step 2: Efficiency Levels 

Determine relevant 

efficiency levels

Step 3: Representative 

Capacity

Pick boilers at 

representative capacity, 

use regression if required

Step 4: Baseline Price

Determine or Calculate 

using regression, prices of 

boilers at baseline 

efficiency levels at the rep. 

capacity

Step 5: Incremental Price 

For each manuf. calculate 

incremental price 

Inc. price at XX eff. level 

= Price at XX – Baseline 

Price

Step 6: Price-Efficiency 

Curves

Take average of 

incremental prices from all 

manuf. for each eff. level 

Generate incremental price 

– efficiency relationship. 
38

Engineering Analysis – LGMDST and LOMDST 

Methodology

• DOE took ratio of incremental prices of LGMDHW and 

SGMDHW. 

• Using this ratio and SGMDST and SOMDST incremental 

prices, DOE calculated prices for LGMDST and LOMDST.

Efficiency 

Level (EL)

[%]

Incremental 

Price [$] 

LGMDHW (L)

Incremental 

Price [$] 

SGMDHW (S)

Ratio 

[S/L]

82% Baseline Efficiency

83% 2,075 612 0.3 

84% 4,343 1,271 0.3 

85% 6,822 1,981 0.3 

86% 9,533 2,745 0.3 

87% 12,496 3,568 0.3 

88% 15,736 4,454 0.3 

89% 19,277 5,408 0.3 

Efficiency 

Level (EL) [%]

Incremental 

Price [$] 

SGMDST (S’)

Average 

Ratio [S/L]

Incremental 

Price [$] 

LGMDST 

(S’/Avg.Ratio)

79% Baseline Efficiency

80% 1,060 0.3 3,534 

81% 2,243 0.3 7,475 

82% 3,560 0.3 11,866 

83% 5,025 0.3 16,750 

84% 6,653 0.3 22,176 

AAAAAA.RRRRRRRRRR =

∑ SS

LL

mm mm mmmmmm

=EELL11

NNNN NN NN oo
39

Engineering Analysis – Condensing SGMDHW and 

LGMDHW Methodology

• For small and large gas-fired hot water condensing boilers, DOE 

used the methodology similar to corresponding non-condensing 

models but with an added step. 

• DOE grouped condensing boiler prices based on material type

• Incremental price is calculated for each material type.

• Final price – efficiency curve is calculated by taking the average 

for incremental price for each efficiency level. 

Efficiency

Level [%]

A 

[$]

B 

[$]

C 

[$]

90% X1 Y1 Z1

91% X2 Y2 Z2

92% X3 Y3 Z3

93% X4 Y4 Z4

Efficiency

Level [%]

Mat 1. Mat 2.

90% P1=Avg.(X1,Y1) Z1

91% P2=Avg.(X2,Y2) Z2

92% P3=Avg.(X3,Y3) Z3

93% P4=Avg.(X4,Y4) Z4

Efficiency

Level [%]

Inc. Price

90% Avg. (P1-P1, Z1-Z1)

91% Avg. (P2-P1, Z2-Z1)

92% Avg. (P3-P1, Z3-Z1)

93% Avg. (P4-P1, Z4-Z1)
40

Engineering Analysis – Condensing SOMDHW and 

LOMDHW Methodology 

Thermal Efficiency [%]

Incremental Price [$]

SNC: Slope NC

SC: Slope C

Thermal Efficiency [%]

Incremental Price [$]

S2: Slope C

S1: Slope NC

AAAAAA. SSSS SS .RRRRRRRRRR SS = SSNNNN

SS

SS22 =

SS11

SS

• DOE did not have sufficient price data for oil-fired 

condensing boiler models in SOMDHW and LOMDHW 

equipment classes.

• As a result, DOE inferred prices for condensing efficiency 

levels based on other equipment classes.

• DOE used the ratio of slope of the incremental price –

efficiency curve of non-condensing and condensing 

efficiency levels of gas-fired equipment class.
41

Engineering Analysis – Natural Draft Equipment 

Classes Methodology 

• DOE did not receive sufficient price data for natural draft equipment 

classes

• DOE compared price data for similar mechanical and natural draft systems 

to estimate the price of removing mechanical draft components from a 

boiler and replacing them with natural draft components (“price 

differential”).

• This price differential is subtracted from mechanical draft boiler prices of 

appropriate equipment class to derive natural draft prices.

• Natural draft boiler incremental classes are calculated by subtracting the 

price of higher-efficiency boilers from baseline in each equipment class.

Mechanical Draft Assembly 

(Inducer assembly, Sensors, 

Flue Collector , Vent 

Connector etc.)

Natural Draft Assembly 

(Vent damper, Draft 

hood, Sensors etc.)

Price 

Differential

Natural draft prices Mechanical draft 

prices

Price 

Differential
42

Engineering Analysis – Summary of Methodology 

To summarize the methodologies adopted:

• Methodology was chosen based on factors such as availability of 

prices, number of manufacturers, and type of equipment class etc.

• If DOE is not able to calculate incremental prices directly from 

available price data, other statistical methods are used.

Equipment Class Type of Boiler Type of Analysis

SGMDHW

Non -

Condensing

“General approach” – group into equipment classes, calculate price at 

rep. capacity, calculate incremental prices, take average, generate price –

efficiency curve

Condensing

Similar to non-condensing analysis, 

additional step to group prices based on material type, 

calculate incremental price for each group, 

take average of incremental prices for each efficiency level.

LGMDHW

Non -

Condensing

General approach – group into equipment classes, calculate price at rep. 

capacity, calculate incremental prices, take average, generate price –

efficiency curve

Condensing

Similar to non-condensing analysis, 

additional step to group prices based on material type, 

calculate incremental price for each group, 

take average of incremental prices for each efficiency level.
43

Engineering Analysis – Summary of Methodology

Equipment

Class Type of Boiler Type of Analysis

SOMDHW Non-Condensing General approach – Similar to SGMDHW, non-condensing analysis

SOMDHW Condensing

Used slope ratio between condensing and non-condensing incremental 

prices of SGMDHW equipment class

Used this ratio to calculate condensing boiler incremental prices from 

SOMDHW non-condensing incremental prices

LOMDHW

Non-Condensing General approach – Similar to SGMDHW, non-condensing analysis

Condensing

Used slope ratio between condensing and non-condensing incremental 

prices of SGMDHW equipment class

Used this ratio to calculate condensing boiler incremental prices from 

LOMDHW non-condensing incremental prices

SGMDST Non-Condensing General approach – Similar to SGMDHW, non-condensing analysis

LGMDST Non-Condensing Used incremental price ratio between SGMDHW and LGMDHW to obtain 

relationship between SGMDST and LGMDST

SOMDST Non-Condensing General approach – Similar to SGMDHW, non-condensing analysis

LOMDST Non-Condensing Used incremental price ratio between SGMDHW and LGMDHW to obtain 

relationship between SOMDST and LOMDST

All natural draft 

equipment 

classes

N/A

Calculated price of replacing mechanical draft components with natural 

draft components in a boiler

Used this price differential to calculate natural draft prices by subtracting 

the differential from mechanical draft prices
44

Engineering Analysis – Sample Results

$0

$5,000

$10,000

$15,000

$20,000

79% 84% 89% 94% 99%

Incremental Prices [$]

Thermal Efficiency [%]

Small Gas - Fired Mechanical Draft Hot Water

Small Gas-fired Hot Water, ≥ 300,000 Btu/hr and ≤ 2,500,000 Btu/hr

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

77% 79% 81% 83% 85% 87%

Incremental Prices [$]

Thermal Efficiency [%]

Small Gas - Fired Natural Draft Hot Water

Small Gas-fired Hot Water, ≥ 300,000 Btu/hr and ≤ 2,500,000 Btu/hr

Product Class Efficiency Level Incremental Price Baseline Price

Small Gas-fired Mechanical draft Hot Water, 

≥ 300,000 Btu/hr and ≤ 2,500,000 Btu/hr

80% $0

$ 7,120 

83% $1,710

85% $3,078

87% $4,665

92% $6,819

95% $11,211

98% $15,604

Small Gas-fired Natural draft Hot Water, ≥ 

300,000 Btu/hr and ≤ 2,500,000 Btu/hr

80% $0

$ 3,799 81% $529

82% $1,307

85% $3,078
45

Engineering Analysis – Issues for Comment

Issue #4: DOE requests comment about the methodology used to 

calculate incremental prices for increased efficiency for each 

equipment class. 

DOE requests comment about the appropriateness of the 

incremental prices reported as part of the engineering analysis 

chapter. 

DOE requests additional price-related information, especially for 

natural draft boilers, which would further improve future analyses 

for this rulemaking. 
46

Public Meeting Slides Topics

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
47

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Steps for the Standards Rulemaking: 

Preliminary Activities and Analyses

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization
48

Markups Analysis

Purpose: The markups analysis is used to determine the cost to the commercial consumer 

of: (1) baseline equipment and of (2) more-efficient equipment purchased under new energy 

conservation standards.

Markups relate commercial consumer price to the manufacturer selling price (MSP), aka 

“cost of goods sold.” DOE calculated both baseline and incremental markups:

• Baseline markups relate baseline efficiency equipment MSP to direct business costs.

• Incremental markups relate the incremental change in commercial consumer price to 

the incremental change in MSP under new energy conservation standards (e.g., fixed 

costs such as overhead and labor do not scale up).

Distribution Channels: The markups depend on the type of distribution channels through 

which products move from manufacturers to consumers.

Markups were developed for the following market participants: Manufacturer, 

wholesaler, mechanical contractor, and general contractor.

Sales Taxes and Wholesaler and Contractor markups were developed for each of the 

geographical areas in the analysis.
49

Input Methodology

Distribution Channels Based on stakeholder input, markups were developed for the following 

markets: (1) Replacements and (2) New Construction. See next slide.

Manufacturer 

Markup

Determined in engineering analysis (Ch. 5), based on U.S. Security and 

Exchange Commission (SEC) 10-K reports from publicly-owned

commercial packaged boiler manufacturing companies.

Wholesaler Markup Based on firm income statements from the HARDI 2013 Profit Report.

Mechanical 

Contractor Markup

Based on ACCA 2005 Financial Analysis report and Plumbing and HVAC 

Contractors sector from the 2007 Economic Census.

General Contractor 

Markup

Based on Commercial Building Construction sector from the 2007 

Economic Census.

Sales Tax Based on 2014 Sales Tax Clearinghouse Data.

Markups Analysis 

Methodology for Commercial Packaged Boilers
50

Replacement

Distribution Channels for Commercial Packaged Boilers

Markups Analysis

Manufacturer

Wholesaler/

Manufacturer’s 

Representative

Mechanical 

Contractor

Commercial 

Consumer

Manufacturer

Wholesaler/

Manufacturer’s 

Representative

Mechanical 

Contractor

General 

Contractor

Commercial 

Consumer

Manufacturer National Account Commercial 

Consumer

Manufacturer National Account Commercial 

Consumer

New Construction
51

Total Markups by Equipment Class

Markups Analysis

Equipment Class Baseline 

Markup

Incremental 

Markup

Natural Draft Gas-Fired Hot Water Commercial Packaged Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 3.04 1.99

Natural Draft Gas-Fired Hot Water Commercial Packaged Boiler 

>2,500,000 Btu/hr 2.95 1.97

Natural Draft Oil-Fired Hot Water Commercial Packaged Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 3.24 2.04

Natural Draft Oil-Fired Hot Water Commercial Packaged Boiler 

>2,500,000 Btu/hr 2.99 1.96

Mechanical Draft Gas-Fired Hot Water Commercial Packaged 

Boiler ≥300,000 Btu/hr and ≤2,500,000 Btu/hr 3.35 2.07

Mechanical Draft Gas-Fired Hot Water Commercial Packaged 

Boiler >2,500,000 Btu/hr 3.31 2.05

Mechanical Draft Oil-Fired Hot Water Commercial Packaged 

Boiler ≥300,000 Btu/hr and ≤2,500,000 Btu/hr 3.54 2.14

Mechanical Draft Oil-Fired Hot Water Commercial Packaged 

Boiler >2,500,000 Btu/hr 3.16 2.00
52

Request for Comment

Markups Analysis

Issue #5: DOE seeks comments about whether the considered 

distribution channels are appropriate for commercial packaged 

boilers.

Issue #6: DOE seeks comments about the percentage of 

equipment being distributed through the different distribution 

channels, and whether the share of equipment through each 

channel varies based on equipment class or equipment capacity.

Issue #7: DOE requests comments about its proposed approach to 

developing estimates of future commercial packaged boiler retail 

prices.

Issue #8: DOE requests recent data to establish the markups and 

commercial consumer price for the parties involved with the 

distribution of the equipment.
53

Energy Use Characterization

Purpose: To determine the annual energy consumption of 

commercial packaged boilers and to assess the energy savings 

potential of increases in efficiency.

Annual energy consumption: site energy use associated with 

operating the equipment.

Methodology: The commercial packaged boiler annual energy use is 

equal to the sum of the energy used by the boiler for space heating, 

water heating, and any auxiliary electrical components:

EEnn nn UUUU = FF SSSS + FF WW + EE
54

Energy Use Characterization – Building Sample

Building Sample (CBECS and RECS) selection 

criteria:

• used a boiler as the main or secondary 

source of heat;

• used a heating fuel that is natural gas or 

fuel oil; and

• had a heating energy consumption greater 

than zero.
55

Space Heating Fuel Consumption

Energy Use Characterization
56

Space Heating Fuel Consumption

Energy Use Characterization

Annual Space Heating Fuel Consumption

Burner Operating Hours (BOH)

Building Heating Load (BHL)

AAAAAAAAAAAA FF FF UUUU = BBBBBB ∗ QQiiii

BBBBBB =

BBBBBB

QQiiii × TTTTrrrrrrrrrr, aa

BBBBBB = EE CCCCCCCCCC ∗ TTTT ee ee ∗ AAAAAA s ssss ∗ AAAAAAHHHHHH
57

• Conversion between combustion efficiency and 

thermal efficiency

– Based on AHRI model directory

• Thermal efficiency varies with:

– Return water temperature

– Cycling

– Part-load

• Calculate average impact for each climate zone based 

on weather

Energy Use Characterization

Thermal Efficiency Adjustments
58

Water Heating Energy Consumption

Energy Use Characterization

• For buildings using gas fuel for space heating and water heating, it was assumed 

that in 50% of these installations the boilers are also used for water heating.

Annual Water Heating Fuel Consumption

– AAAAAAAA AAAA AAAA FF FF FFFFWW accounts for the difference between TE and water 

heating (WH) efficiency

Water Heating Load

‒ QQYY ,WW is equal to the annual fuel consumption for water heating based on 

CBECS 2003 or RECS 2009 (kBtu/yr)

FF WW =

WW

TT − AAAAjjFF WW

WW = QQYYYY,WW × (TTTT ee− AAAA FF FF FF WW )
59

Electricity Consumption

Energy Use Characterization

Boiler Electricity Consumption accounts for the electricity use by circulating 

pump, draft inducer, igniter, and auxiliary equipment such as condensate pumps.

AdjBOH = adjustment factor that takes into account part-load operation (for 

condensing units only)

ElecPower = power of electrical components required during boiler 

operation, (kW)

ElecBOHWH = hours boiler provides water heating only

StdbyPower = total standby power of the equipment

StdbyHrs = standby hours, taking into account water heating operation during 

summer

EE

= BBBB SSSS × AAAA BBBB × EE EE EE + EE WW × EE EE EE

+SS SS × SS
60

Average Annual Energy Consumption

EL Design Option Fuel Use

MMBtu/yr

Electricity Use 

kWh/yr

Natural Draft Gas-Fired Hot Water Commercial Packaged Boiler ≥300,000 Btu/hr and ≤2,500,000 Btu/hr

0 80% TE - Baseline 830 342

1 81% TE 820 337

2 82% TE 810 333

3 85% TE - Max Tech 781 321

Natural Draft Gas-Fired Hot Water Commercial Packaged Boiler >2,500,000 Btu/hr

0 82% CE - Baseline 3826 886

1 83% CE 3772 873

2 84% CE - Max Tech 3719 861

Mechanical Draft Gas-Fired Hot Water Commercial Packaged Boiler ≥300,000 Btu/hr and ≤2,500,000 Btu/hr

0 80% TE - Baseline 939 746

1 83% TE 904 720

2 85% TE 882 704

3 87% TE 861 689

4 92% TE 824 990

5 95% TE 797 960

6 98% TE - Max Tech 772 931

Mechanical Draft Gas-Fired Hot Water Commercial Packaged Boiler >2,500,000 Btu/hr

0 82% CE - Baseline 3699 1306

1 84% CE 3596 1271

2 86% CE 3499 1238

3 94% CE 3182 1662

4 97% CE - Max Tech 3069 1605

Energy Use Characterization
61

Energy Use Characterization

Request for Comment

Issue #9: DOE seeks data on representative annual 

profiles of return water temperature, supply water 

temperature, and boiler percent loading.

Issue #10: DOE seeks data on what return water 

temperatures boilers are tested at under the test 

conditions prescribed by the DOE test procedure.

Issue #11: DOE seeks input on data sources that it 

can use to characterize the variability in annual 

energy consumption for commercial packaged 

boilers. DOE is particularly interested in field 

monitoring studies and data.
62

Energy Use Characterization

Request for Comment

Issue #12: DOE requests data about typical boiler sizing practices:

● How often are multiple boilers installed, instead of a single 

 boiler, to meet the building heating load?

● How are the number of boilers determined for a particular type 

 of building installation?

Issue #13: DOE seeks input about how boilers are controlled, 

particularly in multiple-boiler installations.

Issue #14: DOE seeks historical shipment-weighted commercial 

packaged boiler efficiency data and/or shipment data by efficiency 

bins. DOE is primarily interested in data during the last 10 years to 

capture the impact of the most current technologies on the boilers 

market.
63

Energy Use Characterization

Request for Comment

Issue #15: DOE requests input about the electricity 

use by commercial boilers that is in addition to the 

fuel energy use, and that should be included in the 

energy use analysis.

Issue #16: DOE seeks input on what fractions of hotwater commercial packaged boilers are used both for 

space heating and water heating.
64

Purpose: LCC analysis uses life-cycle cost (LCC) and payback period 

 (PBP) to determine the economic impact of boiler 

 standards on commercial consumers.

Methodology:

• Life-Cycle Cost (LCC) is used to determine total commercial 

consumer cost over the life of a product.

• Payback Period (PBP) determines the amount of time it takes 

consumers to recover the purchase price of more energyefficient equipment through reduced operating costs.

• The analysis uses the Crystal Ball® add-on for MS Excel to 

model the uncertainty and variability of inputs using Monte 

Carlo approach and probability distributions.

LCC and Payback Period Analyses 
65

Development of LCC and PBP Inputs

LCC and Payback Period Analyses

Engineering 

Analysis

Markups to 

Determine 

Product Price

Energy Use 

Characterization

Baseline 

Manufacturer Cost

Std-Level 

Manufacturer Cost

Manufacturer 

Markup

Distributer & 

Contractor 

Markups

Sales Tax

Energy 

Consumption

Marginal Energy

Prices

Consumer

Price

Installation

Cost

Total

Installed Cost

Annual

Energy Cost

Repair

Cost

Maintenance

Cost

Annual

Operating Expense

Lifetime

Discount

Rate

Energy Price Trend

Lifetime Operating

Expense

Payback

Period

Life-Cycle

Cost
66

LCC and Payback Period Analyses

Installation Costs

Installation Costs represent the labor and material costs 

necessary to install the appliance.

Key Components of installation cost model:

• Basic installation costs

• Venting 

• Condensate removal for condensing boilers

Sources:

• 2013 RS Means (Mechanical Cost Data) 

• Manufacturer literature

• Information from experts
67

Basic installation costs include:

• Placing and setting up boiler

• Connecting gas piping

• Connecting water piping

• Permit and removal/disposal fees

LCC and Payback Period Analyses

Basic Installation Costs
68

Boiler technology type

– Non-condensing: typically Category I venting

• Considerations: High-temperature flue gas, which heats the inside of the 

vent above the dew point to ensure that water vapor in the flue gas does 

not condense

• Replacements: Reline unlined chimney, resize existing vent, reuse existing 

vent, or replace vent

• Material: Type B (natural draft) or stainless steel (mechanical draft)

– Condensing: Category IV venting

• Considerations: Water vapor in flue condenses, so the flue must resist 

corrosion

• Replacements: Reuse existing stainless steel vent or replace vent

• Material: Plastic (≤ 6” diameter) or stainless steel (> 6” diameter)

• Combustion air direct vent

Cost factors: installation type, assumed existing venting material 

in replacement boiler installations, and new vent material

LCC and Payback Period Analyses

Venting
69

• Condensate pipe: Excess condensate must be deposited in a drain.

• Condensate pump: If a drain is not near the boiler, then the condensate 

must be pumped to a remote drain.

• Condensate neutralizer: Neutralizes condensate before pouring into drain.

• Additional electrical outlet: Some installations with a condensate pump 

also require an additional electricity outlet.

LCC and Payback Period Analyses

Condensing Boilers: Condensate Removal

Installation Cost 

Description Criteria Frequency of applying 

criteria

Pipe All installations 100%

Pump All installations 25%

Neutralizer All installations 12.5%

Electrical Outlet 

(additional) 

Fraction of installations requiring a 

pump

50%
70

LCC and Payback Period Analyses

Request for Comment

Issue #22: DOE seeks input on how often plastic 

versus stainless steel venting is installed for 

condensing boilers.

Issue #23: DOE seeks input on how often boilers 

have direct venting, for both condensing and noncondensing boilers.

Issue #24: DOE seeks input on the fraction of 

stainless steel venting in existing boiler installations 

by efficiency.

Issue #21: DOE requests data on the fractions of 

installations that would entail significant additional 

installation expenses.
71

LCC and Payback Period Analyses

Request for Comment

Issue #26: DOE seeks data on how often “common 

venting” occurs in multiple-boiler installations; and 

whether commercial water heaters are commonly 

vented with commercial boilers.

Issue #25: DOE seeks input on where boilers are 

typically located within different types of buildings 

and where the vents typically terminate. 

DOE is interested whether this changes by 

geographic region or boiler type.
72

Repair and Maintenance

LCC and Payback Period Analyses

• Maintenance Cost: Routine cost to the consumer of maintaining equipment.

• Maintenance Frequency: 

• Steam boilers and oil-fired boilers: based on RS Means

• Gas-fired hot water boilers: based on CBECS/RECS survey data

• Labor Hours/Cost: Based on 2013 RS Means Facility Repair and Maintenance

• Separate for steam vs hot water and small vs large.

• Material Cost: Based on 2013 RS Means. Condensate neutralizer for condensing boilers. 

• Assumes maintenance cost is the same within each equipment class. Assumes maintenance 

cost for condensing boilers is higher.

• Repair Cost: Cost of replacing or repairing components in the boiler that have failed.

• Labor Hours/Cost: Based on 2013 RS Means Facility Repair and Maintenance

• Material Cost: Based on engineering analysis and RS Means 

Component failure rate

Repair Description Mean Failure Year Repair Rate

Ignition, Controls 7.0 50%

Vent Damper or Power Vent Blower 15.0 35%

Heat Exchanger 20.0 17%
73

LCC and Payback Period Analyses

Request for Comment

Issue #19: DOE seeks input on how often boiler maintenance 

is performed by on-site staff versus external contractors, 

specifically for hot water boilers versus steam boilers and 

small boilers versus large boilers.

Issue #20: DOE seeks input as to how often, in the event of a 

heat exchanger failure, the heat exchanger alone is replaced 

versus the entire boiler being replaced. DOE is interested in 

knowing whether this varies with equipment class or varies 

with condensing versus non-condensing boilers.

Issue #18: DOE requests comment on frequency and cost of 

maintenance, major repair issues, repair frequency, and 

repair costs for commercial packaged boilers that meet the 

minimum efficiency standards, as well as for higherefficiency boilers.
74

Lifetime

LCC and Payback Period Analyses

• Definition: Age when the commercial boiler is retired from service.

• Methodology: Used published studies and typical appliance lifetime 

characteristics to calculate the distribution of lifetimes

• Lifetime assumed 24.8 years presented as a distribution (source references in 

Appendix 8-F)
75

LCC and Payback Period Analyses

Request for Comment

Issue #28: DOE seeks data to predict boiler lifetime, 

particularly for non-condensing versus condensing 

boilers.

Issue #27: DOE requests comments about the 

methodology used to determine equipment lifetimes 

for commercial packaged boilers.
76

Energy Prices

LCC and Payback Period Analyses

• Purpose: Develop average marginal monthly prices by geographical area. 

• Methodology: Most-current average annual energy prices by monthly price factors 

and marginal price factors. 

• 2012 average annual energy prices by geographical area based on:

‒ Electricity Prices: EIA’s 2013 Form 826 data

‒ Natural Gas: EIA’s 2013 Natural Gas Navigator monthly

‒ Oil: EIA’s 2012 State Energy Consumption, Price, and Expenditures 

Estimates (SEDS)

• Monthly energy price factors by geographical area based on:

‒ Electricity Prices: EIA’s 1993-2012 Form 826 monthly data

‒ Natural Gas: EIA’s 1993-2012 Natural Gas Navigator monthly data 

‒ Oil and LPG: EIA’s 2009 Short-Term Energy Outlook 1995-2009 historical data

• Marginal energy price factors for electricity and natural gas by geographic 

areas based on EIA data.
77

Energy Price Trends

LCC and Payback Period Analyses

Example: Projected Commercial National Natural Gas Price

• Methodology: 2012 average monthly marginal energy prices by geographical area 

multiplied to projected annual energy price trends for the corresponding Census 

Division

– 2019 - 2040 trends based on EIA’s AEO 2014 by Census Division

– After 2040 trends based on Federal Energy Management Program (FEMP) 

guidelines 

5.00

7.00

9.00

11.00

13.00

15.00

2010 2020 2030 2040

2012$/MMBtu
78

Discount Rates: Commercial

LCC and Payback Period Analyses

• Definition: Used to determine the present value of lifetime operating expenses when a 

piece of equipment is retired from service.

• Methodology: Calculated as the weighted average cost of capital (WACC), using the 

Capital Asset Pricing Model (CAPM) for different economic sectors.

• Primary data sources: Damodaran Online database of company debt and equity 

financing

Request for Comment 

Issue #29: DOE seeks comment about its planned 

approach for estimating discount rates for commercial 

consumers.
79

Base-Case Efficiency Distribution

LCC and Payback Period Analyses

Definition: Base-case product efficiency assignment reflects the projected 

market share of products at different efficiency levels.

• Not all consumers purchase products at the current minimum standard.

• LCC analysis recognizes that consumers already purchasing products at 

efficiencies greater than or equal to a prospective standard level are 

not impacted by the standard.

Methodology: Projected commercial boiler efficiency market share in 2019 for each 

product class based on the share of models in each product class from trends in the AHRI 

certification directory from 2007 to 2014.
80

Request for Comment

LCC and Payback Period Analyses

Issue #30: DOE requests data on the efficiency distribution and on the 

likelihood and degree of improvement in efficiency of commercial packaged 

boilers in the next 5 to 10 years, as a result of market forces or industry 

trends (in the absence of amended energy conservation standards).

Issue #17: DOE requests data to characterize the current distribution of 

commercial packaged boiler efficiencies in the market.
81

LCC and PBP Analysis Results

LCC and Payback Period Analyses

Example: Gas-Fired Small Hot Water Boilers, Mechanical Draft

Efficiency 

Level TE

Average Costs

2013$ LCC 

Savings 

($)

Payback 

Installed Cost years

($)

First Year’s 

Operating 

Cost

($)

Lifetime 

Operating 

Cost

($)

LCC

($)

0 80% 32,003 11,261 190,176 222,180 NA NA

1 83% 35,530 10,907 184,115 219,646 325 10.0

2 85% 38,353 10,685 180,326 218,680 579 11.0

3 87% 41,626 10,474 176,721 218,348 738 12.2

4 92% 45,983 10,161 171,255 217,239 1,333 12.7

5 95% 55,044 9,887 166,576 221,621 (1,612) 16.8

6 98% 64,104 9,631 162,202 226,307 (6,018) 19.7
82

Public Meeting Agenda

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
83

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Steps for the Standards Rulemaking: 

Preliminary Activities and Analyses

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization
84

• Shipments Analysis:

– Estimates commercial boiler shipments over 

analysis period.

• National Impact Analysis:

– Estimates the National Energy Savings (NES) and 

national economic impact on commercial boiler 

consumers (or the Net Present Value (NPV)) from 

commercial boiler energy conservation standards 

at different efficiency levels.

Purpose

National Impact Analysis
85

Approach

Shipments Analysis

Purpose: Forecast the commercial boilers that would be expected to be 

shipped between 2019 and 2048, both with and without amended energy 

conservation standards.

Methodology of Shipments Projections:

• New constructions: New building construction projections multiplied by 

new construction market saturations.

• Replacements: Equipment retirement functions (equipment lifetimes) 

applied to equipment stock. Equipment stock is generated with historical 

shipments. Demolished units are deducted from required replacements.

• New Owners: Existing buildings that acquire boilers for the first time. 

Includes consumers switching between boiler product classes. 

Accounted for impact of standards on shipments using price 

elasticities.
86

Shipments Model Inputs

Shipments Analysis

Input Definition/Source

Historical Annual 

Shipments

•Historical shipments of commercial packaged boilers in 2007 reported 

in the 2009 commercial packaged boiler final rule (used residential 

boiler shipments to extrapolate commercial boiler shipments)

•AHRI model data for commercial packaged boilers from 2007 to 2014

Retirement 

Function

Based on lifetime distribution

Shipments to New 

Construction

New construction market saturations multiplied by projected new 

buildings

• Saturations from CBECS 2003 and RECS 2009

•U.S. Census historical building starts data and EIA’s AEO 2014 

projections

New Owners and 

Product Switching

Product class switching based on trends in AHRI database

Price Elasticity Based on appliance shipments and household economic data during the 

period (1980-2002). See Appendix 9-A.
87

0.000

0.005

0.010

0.015

0.020

0.025

0.030

0.035

0.040

0.045

0.050

1960 1970 1980 1990 2000 2010 2020 2030 2040

Shipments (million)

LOMDST

SOMDST

LGMDST

SGMDST

LOMDHW

SOMDHW

LGMDHW

SGMDHW

LONDST

SONDST

LGNDST

SGNDST

LONDHW

SONDHW

LGNDHW

SGNDHW

Shipments Analysis

Historical and Projected Base Case Shipments by Equipment Class

Historical Projected
88

Shipments Analysis

Request for Comment

Issue #31: DOE requests input on the shipments 

projection methodology.

Issue #32: DOE invites comments about the selection 

of appropriate economic drivers and sources of data 

for historical shipments and shipment-breakdowns 

by equipment class.

Issue #33: DOE seeks historical commercial 

packaged boiler shipments data, disaggregated by 

equipment class and efficiency level if available.

Issue #34: DOE seeks input on the potential impact of 

amended standards on commercial packaged boiler 

shipments.
89

National Impact Analysis

Purpose: Estimate the national impacts of energy conservation standards for 

commercial boilers shipped between 2019 and 2048

• National Energy Savings (NES): Primary energy savings

• Net Present Value (NPV): Difference between the present value of annual 

energy expenditures and the present value of annual equipment 

expenditures.

Methodology

• For each product class in each standards case:

1. Calculate per-unit cost increase and per-unit energy savings due to a 

standard.

2. Calculate number of units (stock) in use and energy savings each year 

from 2019 to 2048.

3. Combine the above to determine NES and NPV.
90

National Energy Savings

National Impact Analysis

Input Method/Assumptions

Annual Energy Consumption per 

Unit (UEC)

Derived per-unit annual energy consumption as a function of product 

efficiency from Energy Use Analysis for each equipment class.

Shipments Projected shipments for each equipment class under the base case and all 

standards cases.

Equipment Stock Determined the yearly stock using annual shipments and the lifetime for each 

equipment class.

National Annual Energy 

Consumption

Annual energy consumption is the product of the UEC and the equipment 

stock.

Rebound Effect No rebound effect was assumed in the analysis.

Site-to-Source Conversion Factor Used for converting site energy consumption into primary or source energy 

consumption (from EIA’s AEO 2014/NEMS).

Full Fuel Cycle Calculated FFC energy savings using a NEMS-based methodology (from EIA’s AEO 

2014/NEMS).

National Energy Savings: Difference in annual energy savings (UEC multiplied by 

equipment stock) between base case and each standards case and summed 

over the analysis period.
91

National Impact Analysis

Net Present Value

Input Method/Assumptions

Total Installed Cost Per Unit Function of product efficiency

Annual Per-unit Savings In 

Operation Cost

Includes costs for energy, repair, and maintenance.

Shipments Annual shipment of boilers by equipment classes

Equipment Stock Depends on shipments and lifetime

Total Annual Increases In 

Installed Cost

Increase attributable to standard, calculated by vintage

Total Annual Operating Cost Calculated by vintage 

Discount Factor Used 3% and 7% national discount rates to determine present value of future 

monetary values

• Net Present Value: Difference between the present value of energy cost 

savings and the present value of total installed cost increase.

• Present value of costs: Difference in installed cost between base case and each 

standards case discounted to the present and summed over the analysis period

• Present value of savings: Difference in operating cost savings between the base 

case and each standards case from 2019 to the time when the last unit is retired
92

• Efficiency Trend in 2019 (Assumed a “roll-up” scenario to establish the 

efficiency distribution):

– Product efficiencies in the base case that did not meet the standard 

under consideration would “roll up” to meet the new standard level.

– All efficiency shares in the base case that were above the standard 

under consideration would not be affected.

• Efficiency Trend After 2019:

– Condensing boilers are projected to increase linearly, based on trends 

in AHRI database by product class.

– Shares of condensing efficiency levels are kept within the same 

proportional relationships as in 2019.

– Shares of non-condensing efficiency levels are kept within the same 

proportional relationships as in 2019.

National Impact Analysis

Projected Efficiency Trends
93

National Impact Analysis

Projected Condensing Boiler Market Share Trends

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2019 2024 2029 2034 2039 2044 2049

Condensing market share

SGMDHW

LGMDHW

SOMDHW

LOMDHW
94

• DOE has published a Notice of Policy (NOP) stating its 

intention to incorporate full-fuel-cycle (FFC) metrics into the 

cost-benefit analysis. 76 FR 51281 (Aug. 18, 2011); 77 FR 

49701 (Aug. 17, 2012). 

• Methodology is based on the calculation of a FFC multiplier, 

or conversion factor, for each of the primary fuels used by the 

product.

• For this preliminary analysis, DOE calculated FFC energy 

savings using a NEMS-based methodology (described in 

appendix 10B).

• Primary NES and the FFC energy savings for the considered 

efficiency levels reported (see Ch.10).

Full-Fuel-Cycle Analysis

National Impact Analysis
95

National Impact Analysis

Primary National Energy Savings Results (quads)

Product Class Efficiency Levels

1 2 3 4 5 6

Natural Draft Gas-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.001 0.004 0.026 NA NA NA

Natural Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.010 0.023 NA NA NA NA

Natural Draft Oil-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.001 0.003 0.005 NA NA NA

Natural Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.005 0.012 NA NA NA NA

Mechanical Draft Gas-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.023 0.052 0.105 0.207 0.332 0.524

Mechanical Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.039 0.145 0.570 0.875 NA NA

Mechanical Draft Oil-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.006 0.017 0.059 0.201 NA NA

Mechanical Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.011 0.037 0.136 NA NA NA
96

National Impact Analysis

Full-Fuel-Cycle National Energy Savings Results (quads)

Product Class Efficiency Levels

1 2 3 4 5 6

Natural Draft Gas-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.001 0.005 0.029 NA NA NA

Natural Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.011 0.025 NA NA NA NA

Natural Draft Oil-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.001 0.004 0.006 NA NA NA

Natural Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.006 0.014 NA NA NA NA

Mechanical Draft Gas-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.025 0.058 0.117 0.230 0.370 0.583

Mechanical Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.044 0.161 0.634 0.975 NA NA

Mechanical Draft Oil-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.007 0.020 0.069 0.235 NA NA

Mechanical Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.013 0.044 0.159 NA NA NA
97

Discounted at 3% (billion 2013$)

National Impact Analysis

Net Present Value Results

Product Class 3% Efficiency Levels

1 2 3 4 5 6

Natural Draft Gas-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.004 0.011 0.072 NA NA NA 

Natural Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.036 0.079 NA NA NA NA 

Natural Draft Oil-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.009 0.025 0.054 NA NA NA 

Natural Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.057 0.144 NA NA NA NA 

Mechanical Draft Gas-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.047 0.088 0.129 0.203 (0.202) (0.908)

Mechanical Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.087 0.267 0.523 1.268 NA NA 

Mechanical Draft Oil-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.052 0.148 0.487 0.323 NA NA 

Mechanical Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.105 0.406 0.650 NA NA NA 
98

Discounted at 7% (billion 2013$)

National Impact Analysis

Net Present Value Results

Product Class 7% Efficiency Levels

1 2 3 4 5 6

Natural Draft Gas-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.001 0.003 0.019 NA NA NA 

Natural Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.014 0.030 NA NA NA NA 

Natural Draft Oil-Fired Hot Water Boiler ≥300,000 

Btu/hr and ≤2,500,000 Btu/hr 0.003 0.007 0.016 NA NA NA 

Natural Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.022 0.055 NA NA NA NA 

Mechanical Draft Gas-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.007 0.006 (0.016) (0.046) (0.358) (0.861)

Mechanical Draft Gas-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.017 0.034 (0.132) 0.035 NA NA 

Mechanical Draft Oil-Fired Hot Water Boiler 

≥300,000 Btu/hr and ≤2,500,000 Btu/hr 0.013 0.037 0.117 (0.315) NA NA 

Mechanical Draft Oil-Fired Hot Water Boiler 

>2,500,000 Btu/hr 0.031 0.131 0.025 NA NA NA 
99

Public Meeting Agenda

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
100

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Steps for the Standards Rulemaking: Preliminary 

Activities and Analyses

Shipments 

Analysis

Preliminary 

Manufacturer 

Impact Analysis

Life-Cycle

 Cost and 

 Payback

 Period

 Analyses

National 

Impact 

Analysis

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Markups to

 Determine 

 Product Price

Energy Use 

Characterization
101

Preliminary MIA

• Purpose

– The manufacturer impact analysis (MIA) identifies the impacts of 

energy conservation standards on manufacturers.

• Phase 1

– DOE creates an industry profile to characterize the industry and 

identify important issues that require consideration.

• Phase 2

– DOE prepares an industry cash-flow model and an interview 

questionnaire to guide subsequent discussions.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards 

both quantitatively (using the Government Regulatory Impact Model) 

and qualitatively (impacts on competition, manufacturing capacity, 

direct employment, and regulatory burden).
102

Preliminary MIA: Key Issues

• Testing Burden

– Amended standards and an altered test procedure could require CPB 

manufacturers to retest all models, which could strain lab resources 

and result in added financial burden.

– Testing is costly and logistically challenging because of the large size of 

most equipment and the fact that many CPBs are custom 

manufactured. 

• Not Many American Companies Produce Condensing Heat 

Exchangers for Gas-Fired Hot Water Equipment

– Many companies in the US currently produce condensing equipment; 

however, most condensing heat exchangers are sourced from 

European or Asian companies.

– A standard level that necessitates condensing technology could 

require manufacturers to decide whether to continue to source heat 

exchangers, or develop their own production capacity, which could 

require investments in product development and new capital 

equipment.
103

Preliminary MIA: Key Issues

• Small Business Concerns

– DOE has preliminarily identified 21 small business CPB manufacturers.

– Small business manufacturers may have fewer resources (e.g., 

engineering, testing, capital) to adapt to amended standards, relative 

to larger competitors.
104

Issues for Comment

Issue #32: DOE considers the impacts on certain manufacturer 

subgroups that have different cost structures or operate within 

different regulatory frameworks in the NOPR stage. DOE 

requests feedback on subgroups to analyze and/or 

characteristics appropriate for subgroup analysis.

Issue #33: DOE requests comment about its identification of key 

issues, and requests data and information which would assist in 

evaluating the potential impact of energy efficiency standards on 

manufacturers.

Issue #31: DOE conducts a regulatory flexibility analysis that 

examines the impact on small entities and considers alternative 

ways of reducing negative impacts in the NOPR stage. DOE 

invites comments and information about small businesses that 

manufacture CPBs and should be consulted before the NOPR is 

published.
105

Public Meeting Agenda

Markups, Energy Use Characterization, LCC and Payback 

Period Analysis 4

3 Engineering Analysis

1 Introduction and Overview

2 Market and Technology Assessment and Screening 

Analysis

5 Shipments and National Impact Analysis

6 Preliminary Manufacturer Impact Analysis

7 Next Steps
106

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Next Steps in the Standards Rulemaking: NOPR

Revise 

Preliminary 

Analyses

Consumer 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Emissions 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Regulatory 

Impact 

Analysis
107

• Purpose:

– To develop a list of potential amended standard levels from which impacts are 

weighed and a proposed standard level is selected.

• Each trial standard level consists of a set of efficiency levels covering all product classes, 

and may vary between product classes.

• NOPR analyses assess impacts for trial standard levels (not efficiency levels for each 

product class).

• Method:

– Trial standard levels are assembled from the equipment classes and efficiency 

levels identified in the preliminary analyses.

• Trial standard levels cover a range of efficiencies and can include:

– Most energy efficient level (max-tech);

– Efficiency level with the lowest life-cycle cost;

– Efficiency level with a payback period of three years or less;

– Efficiency levels with noteworthy technologies; and

– Efficiency levels that fill in large gaps.

Trial Standard Levels

Selection of Trial Standard Levels

ISSUE 34: DOE requests feedback on the criteria it should use 

for basing the selection of Trial Standard Levels.
108

Revise 

Preliminary 

Analyses

Consumer 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Emissions 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Regulatory 

Impact 

Analysis

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Next Steps in the Standards Rulemaking: NOPR
109

• Purpose:

– Analyze the economic impacts of standards on commercial consumers, 

including subgroups who may be disproportionately impacted 

compared with the general user population.

• Method:

– Refine the LCC analysis to examine the impacts for defined subgroups.

Consumer Subgroup Analysis

Overview

ISSUE 35: DOE requests input as to which consumer 

subgroups, if any, it should consider when developing 

standards for commercial packaged boilers.
110

Framework

Document

Preliminary

Activities NOPR Final

Rule

Effective

Date

Next Steps in the Standards Rulemaking: NOPR

Revise 

Preliminary 

Analyses

Consumer 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Emissions 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Regulatory 

Impact 

Analysis
111

• Purpose:

– Estimate emissions impacts from amended energy conservation standards for 

commercial packaged boilers, including changes in full-fuel cycle (FFC) emissions. 

• Method:

– DOE will base the emission factors for FFC on EIA’s AEO, supplemented by data 

from other sources. 

– DOE estimates the reduction in power sector and site combustion emissions of 

carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2), mercury (Hg), 

methane (CH4) and nitrous oxide (N2O) from potential energy conservation 

standards for the considered equipment.

• Monetization:

– DOE considers the estimated monetary benefits likely to result from the reduced 

emissions of CO2 from the energy efficiency standards levels.

– To estimate benefits from CO2, DOE uses the Social Cost of Carbon values 

developed by an interagency process.

Emissions Impact Analysis

Overview
112

Emission Analysis and Emissions Monetization

Issue #36: DOE seeks input on its plans to use 

NEMS-BT to conduct the emissions analysis for 

the products covered by this rulemaking.

Issue #37: Are there any other emissions factors 

the DOE should consider in this rulemaking?

Issue #38: Are there other approaches to the 

emissions analysis that the DOE should consider?

Request for Comment
113

• Purpose: Assess the overall impacts on domestic energy supplies that 

would result from amended energy conservation standards.

• Method:

– Uses national energy savings results.

– Uses the Energy Information Administration’s National Energy 

Modeling System (NEMS) tailored for DOE’s Building Technologies 

Program (NEMS-BT).

• Output:

– Change in energy sales and price by region.

– Change in the mix of electricity generation.

– Change in new capacity construction.

Utility Impact Analysis

Overview

Issue #39: DOE seeks input on its plans to use 

NEMS-BT to conduct the utility impact analysis.
114

• Purpose: To report net jobs created or eliminated nationally as a 

consequence of amended energy conservation standards.

• Method:

– Uses the ImSET tool, a spreadsheet model of the U.S. economy that 

focuses on 188 sectors most relevant to building energy use.

– Changes in product and energy expenditures taken from the NIA.

– Estimates the national employment and income effects of energy 

saving appliances.

– Direct employment impacts taken from the MIA.

• Output: Change in employment by sector as a consequence of new 

standards.

Indirect Employment Impact Analysis

Overview

Issue #40: DOE requests comment about its 

planned approach for assessing national indirect 

employment impacts.
115

• Purpose:

– To investigate the national impacts due to non-regulatory alternatives compared 

with mandatory energy conservation standards.

– The non-regulatory alternatives that may be considered: 

• No new regulatory action; early replacement; prescriptive standards; 

consumer tax credits; manufacturer tax credits; consumer rebates; voluntary 

efficiency targets; bulk government procurement.

• Method:

– Modify NES spreadsheet model to consider non-regulatory scenarios.

– Non-regulatory scenarios increase overall appliance efficiency and are modeled 

by modifying the base-case efficiency trend.

– NPV calculated for non-regulatory alternatives in the same way as for the adopted 

standard.

– Each non-regulatory scenario will decrease national appliance operating costs and 

increase appliance equipment prices.

• Output:

– National Energy Savings and Net Present Value of the non-regulatory alternatives.

Regulatory Impact Analysis

Overview
116

Issue #41: In general, DOE requests any additional 

comments and invites questions from interested 

parties about the Department of Energy’s Commercial 

Packaged Boilers Energy Conservation Standards 

Rulemaking.

Final Comments and Questions
117

How to Submit Comments

• In all correspondence, please include all of the following:

o Energy Conservation Standards for Commercial Packaged Boilers

o Docket Number: EERE-2013-BT-STD-0030

o Regulatory Identification Number (RIN): 1904-AD01

• Contact Information

Email: PkgdBoilers2013STD0030@ee.doe.gov

Postal Mail:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office

Mailstop EE-5B

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Comment period ends January 20, 2015

Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office

L’Enfant Plaza, S.W., Suite 600 

Washington, DC 20024

Telephone: (202) 586-2945