### BY U.S. 

### MAIL AND EMAIL Mr. William T. Miller Partner Mccarter 

### & English, LLP 1015 151 h 

### Street, NW 12'h 

### Floor Washington, DC 20005 

## Department of Energy Washington, DC 20585



### Januaty 14, 2015

Re: Remand from

### APGA v DOE, CADC No. 11-1485

Dear Bud: DOEhas considered APGA'sNovember 14, 2014 letter, and while we regretthatAPGA did not believe its questions were answered at the November 7, 2014, public meeting, we disagree with the implication inyour letterthat DOEhas not fully complied with the settlement agreementin 

### AmericanPublic GasAssociation v. Department of Energy etal., No. 11-1485 (D. 

## C. Cir.filed Dec. 23, 2011), which required DOE "to make available to thepublicthe data gathered and analyzed bythe agencypriorto publicationofa proposed rule." We believethatthe data so gathered in connection withtheremanded furnace rule, and made publicly available by DOE pursuant to the settlement, is extensive andprovides ample opportunity for analysis priorto issuance ofthe proposed rule. As explained in the meeting announcementpublished in the 

### FederalRegister on October 30, 2014, the purpose ofthe publicmeeting was to provide an opportunity for DOEto explain in more detail the data included inthe three spreadsheets that were made publicly available on September 26, 2014, and to answer questions concerning the analytical tools operative inthose spreadsheets. 79 FR 64517. In accordance with that goal, DOEprovided a comprehensive fourhourtutorial onthe spreadsheets and responded to questions. Inparticular, DOEprovided detailed answers to all ofAPGA's questions to the extentthat they did not implicatepredecisional, deliberative matters with regard to the draft proposed rulemaking concerning nonweatherized and mobile home gas furnaces, whichremains underreviewwithin the Executive branch. As you know, Federal agency rulemaking is a deliberative process in which multiple

### Mr. William T. Miller January 14, 2015 Page2

stakeholders withinthe Executive branchmay conduct separate analyses ofthe issues being addressed in the rulemaking and form conclusions based onthese analyses. These analyses are conducted using a fixed set ofdata. Althoughthe data setremains fixed, the analyses and accompanying conclusions may change as the inter-agencyprocess proceeds. To ensure robust debate withinthe government, the process ofconducting and consideringthe analyses upon which an agency's ultimate policy decision is based is protected by a deliberativeprocess privilege. A proposed rule that is the product ofthis inter-agencyprocess is published in the Federal Register and the public is provided a period (usually between 30 and 60 days) in which to comment onthe data, the agency's approach to analyzing the data, and the policy choices made in the proposed rule. DOE does nottypically provide data supporting the policy decisions at issue in developing a proposed rule prior to issuing that proposed rule document. However, in accordance withthe Joint Statement supporting the settlement agreementinAPGA 

## v. DOE, 

### DOEmade "available to the public the data gathered and analyzed" indeveloping a draftproposed rule from DOEthat was submitted to and remains underreview at the Office ofManagement and Budget (OMB). (Joint Statement, pp. 7-8). The provision ofthese data at this stage ofrule development is unprecedented inDOE'spast rulemaking activities. DOE understands that the data that were provided were complicated and voluminous, as is typical ofmost appliance standards rulemakings. Therefore, to address APGA's concerns about its ability to understand and utilize the data provided, DOEhosted a public meeting, on November 7, 2014, to explainthe spreadsheets and the analytical tools underlying the spreadsheets ina comprehensive, step-by-step fashion and to answer questions that the public may havehad regarding the calculations DOE conducted inproducing the spreadsheets. When APGA submitted its questions priorto the meeting, at DOE's request, APGA was aware thatthe draft proposed rule was at OMB and thus was still undergoing the deliberativeprocess applicable to agency rulemaking. Therefore, APGA couldnot reasonably have expectedthatDOE would answer any questions that involved the ongoing deliberative interagencyprocess, and I was clear in my communicationto you, that DOE would not answer any such questions. APGA claimed in its November 14, 2014 letter that its questions did notdelve into the deliberative process since "we are not asking at this stage why DOE made certain choices." Yet, among the questions APGA provided in advance were several that involved the reasoning and the rationale behind DOE'sregulatory decision, which is a focus ofthe ongoing deliberative process and is thus privileged. Neve1theless, during the course ofthe publicmeeting, DOE addressed every questionAPGA submitted that directly pertained to the data and the analytical tools. APGA'sNovember 14, 2014 letter claimed that DOE'stutorial on its "opaque and complex" spreadsheets "effectively answered none of[their] questions," and characterized answers where DOE provided as much information as possible without breachingthe deliberative process privilege as "tantamount to no answer at all since the complete answer is required to permit further analysis." (APGANovember 14, 2014 letter, p.l) DOE disagrees. DOE systematically walked APGA's technical team through each ofthe spreadsheets, addressing bothpreviously

### Mr. William T. Miller January 14, 2015 Page3

submitted questions and questions asked at the meeting. Nevertheless, inthe spirit of cooperation, DOE is enclosing withthis letter written responses to those questions submitted by APGAthat can be andwere answered without waivingthe deliberative process privilege. Each answer provided in this document was discussed at the meeting. The answers inthe enclosure are numbered so as to correspond to each APGA question. We are asserting deliberative process privilege only to four out ofthe 29 questions submitted by APGA. APGA stated that "time is ofthe essence" withrespectto APGA's ability to participate in the rulemaking at issue. (APGANovember 14, 2014 Letter, p. 2). DOEwould like to make clear that APGA currentlyhas 

### allthe data that DOE used to develop the draft proposed rule currently underreview at OMB. These data are available in this rulemaking process at an earlierpoint thanin any other rulemaking issued by DOE. DOEwill publish, after OMB concludes its review, the proposed rule, onwhich APGA and all other interested parties will have 90 days to conm1ent-atime period that is 30 days longerthan most DOE rulemakings. Consequently, DOE anticipatesthat APGA, along with the rest ofthe interested public, will have ample opportunityto participate inthe related public meeting(s) and to ask DOE any and all pe11inent questions about the proposedrule. DOE also expects that APGAwill provide extensive comment onthat proposed rule. Consistent with its obligations underthe settlement agreement, and in an effortto be as f011hcoming as possible withthepublic, DOE has made its utmost effortto conduct a timely, open, and effective rulemaking process, and will continue to do so. We greatly appreciate APGA'spmiicipation inthis process and trust thatwe can c.ontinue ourmutual efforts to develop a robust and well-reasoned energy conservation standard applicable to non-weatherized gas furnaces and mobile home gas furnaces.

## ~**.---"'D'""a-m~· e,-,.C~ohen**  

### Assistant General Counsel

for Legislation, Regulation, and EnergyEfficiency

AttachmentAttachment: DOE Response to APGA Questions January 14, 2015 Questions below are regarding the spreadsheet EERE-2014-BT-STD-0031-002 unless otherwise noted. 1) The 2011 LCC spreadsheet predicted lower LCC savings, especially for replacements in the south region and for the highest efficiency {98%) condensing furnace cases, compared to the 2014 LCC spreadsheet even though the 2011 LCC spreadsheet did not Include the potential offuel switching. a) What are the major reasons for the significant changes in LCC savings? 

### DOEresponse: DOE used the same modelin both 2011 and2014, ifthe analysis is run without thepotential forfuel switching. 1 

### Nearly all values of inputs changed for avariety ofreasons. For example, theprice of naturalgas, one ofthe LCCspreadsheetinputs, was lowerin the 2014 LCC spreadsheet than it was in the 2011 LCCspreadsheet. b) Why do consumer impacts for replacements in the south not sum to 100% in the 2014 LCC spreadsheet? 

### DOEresponse: The reported values have been correctedin the latest LCCspreadsheetpublished in DOE's website. The correction has no impacton analysis results. c) The 2014 LCC spreadsheet predicts firstyear operations cost savings averaging between $54 and $88 depending on the mandated efficiency level while the fuel switching impact analysis model provided by AGA and dated 7 /11/2014 predicts a first year cost increase of$62 even though both consider fuel switching impacts. What are potential reasons forthis significant discrepancy in top level results? 

### DOEresponse: There are many inputs to both the DOEmodeland theAGA model. Whilefuel switching impacts the results citedin the question above, there are manyotherinputs and assumptions in the modeling thatmayyielddifferent results. A usercomparison ofthe LCC spreadsheet usedin the 2011final rule with the currentLCCspreadsheetwilldivulge the changes andmagnitude ofthose changes.

1 To run the simulation without switching, select "0 11 under "user options11 in the "Summary" tab.Attachment: DOE Response to APGA Questions January 14, 2015

2011 2014 Baseline Baseline lCCand 2011% LCC LCCand 2014% LCC 2011 Net 2011 No 2011 Net efficiency Average savings Average savings Consumer Consumer Consumer LCCsavings LCC Cost Impact Benefit 2013$ savings 80%AFUE 12,310 $12,560 National

- All 90%AFUE 94 0.8% $231 1.8% 25.2% 52.4% 22.4% Installations 92%AFUE 148 1.2% $301 2.4% 26.0% 41.8% 32.2% 95% AFUE 223 1.8% $379 3.0% 36.2% 16.9% 46.9% 98% AFUE 

### so 0.4% $424 3.4% 64.2% 0.5% 35.4%

- 80%AFUE 14,609 $15,379 North-All 90%AFUE 168 1.2% $209 1.4% 10.0% 71.4% 18.6% Installations 92%AFUE 233 1.6% $281 1.8% 10.9% 56.5% 32.6% 95%AFUE 351 2.4% $374 2.4% 22.8% 22.9% 54.3% 98% AFUE 215 1.5% $456 3.0% 58.7% 0.6% 40.7%

- 80%AFUE 8,882 $9,383 South-All 90%AFUE (14) -0.2% $256 2.7% 47.9% 24.1% 28.0% Installations 92%AFUE 21 0.2% $323 3.4% 48.4% 19.9% 31.7% 95%AFUE 30 0.3% $384 4.1% 56.1% 8.0% 35.9% 98%AFUE 11971 -2.2% $389 4.1% 72.3% 0,2% 27.4%

- 80% AFUE 11,978 $12,059 National
- 90% AFUE (12) -0.1% $109 0.9% 31.3% 52.1% 16.6% Replacements

## :~=**~:~:** 43 0.4% $176 1.5% 31.6% 41.6% 26.8% 121 1.0% $253 2.1% 41.2% 16.8% 42.0% 98%AFUE (29) -0.2% $302 2.5% 67.1% 0.4% 32.5%

- 80%AFUE 14,308 $14,924 North: 90% AFUE 98 0.7% $111 0.7% 12.6% 71.8% 15.6% Replacements 923 AFUE 164 1.1% $179 1.2% 13.2% 57.0% 29.8% 95%AFUE 285 2.0% $260 1.7% 25.0% 22.8% 52.2% 98%AFUE 172 1.2% $351 2.4% 00.0% 0.5% 39.4%

- 80%AFUE 8,561 $8,931 South
- 90% AFUE (173) -2.0% $106 1,2% 58.8% 23.2% 18.0% Replacements 923 AFUE (135) -1.6% $172 1.9% 58.7% 19.0% 22.3% 95% AFUE (120) -1.4% $246 2.8% 65.0% 7.9% 27.1% 98%AFUE (323) -3.8% $249 2.8% n.5% 0.2% 22.3%

- 80%AFUE 13,311 $13,405 National- 90%AFUE 416 3.1% $589 4.4% 6.9% 53.3% 39.8%

New 92% AFUE 466 3.5% $657 4.9% 8.9% 42.4% 48.7% Construction 95% AFUE 529 4.0% $727 5.4% 20.9% 17.4% 61.7% 98%AFUE 287 2.2% $744 5.6% 55.3% 0.7% 44.0%

- 80%AFUE 15,493 $15,882 North- New 90%AFUE 372 2.4% $486 3.1% 2.4% 70.2% 27.5% Construction 92% AFUE 438 2.8% $557 3.5% 4.2% 55.0% 40.8% 95% AFUE 545 3.5% $662 4.2% 16.2% 23.2% 60.6% 98% AFUE 342 2.2% $685 4.3% 54.8% 0.9% 44.4%

- 80%AFUE 9,891 $10,479 South- New 90%AFUE 484 4.9% $709 6.8% 13.9% 26.9% 59.2% Construction 92%AFUE 510 5.2% $776 7.4% 16.3% 22.8% 60.9% 95% AFUE 503 5.1% $804 7.7% 28.2% 8.4% 63.4% 98%AFUE 200 2.0% $814 7.8% 56.2% 0.4% 43.4% 2014Net 2014 No 2014 Net Consumer Consumer Consumer Cost Impact Benefit

100% 21% 47% 32% 100% 100% 19% 41% 39% 100% 100% 24% 23% 52% 100% 100% 41% 0% 59% 100%

100% 11% 67% 22% 100% 100% 10% 60% 30% 100% 100% 14% 40% 46% 100% 100% 38% 1% 61% 100%

100% 33% 24% 43% 100% 100% 30% 20% 50% 100% 100% 35% 5% 60% 100% 100% 44% 0% 56% 100%

100% 28% 46% 19% 92% 100% 25% 41% 26% 92% 100% 28% 26% 39% 93% 100% 45% 0% 59% 104%

100% 14% 67% 19% 100% 100% 12% 62% 26% 100% 100% 15% 46% 39% 100% 100% 40% 1% 59% 100%

100% 42% 22% 19% 83% 100% 38% 19% 26% 83% 100% 41% 5% 39% 86% 100% 50% 0% 59% 109%

100% 3% 49% 48% 100% 100% 3% 42% 55% 100% 100% 14% 15% 71% 100% 100% 29% 0% 71% 100%

100% 2% 65% 33% 100% 100% 2% 56% 42% 100% 100% 12% 24% 63% 100% 100% 33% 1% 67% 100%

100% 5% 30% 65% 100% 100% 5% 24% 71% 100% 100% 15% 4% 81% 100% 100% 24% 0% 76% 100%

### Attachment: DOE Response to APGA Questions January 14,2015

900 all groups in order: 90%AFUE fill 2011 Average LCC savings 92%AFUE 95%AFUE !lll 2014Average LCC savings 700 98%AFUE

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## "' zAttachment: DOE Response to APGA Questions January 14, 2015 2) 2014 LCC analysis Sheet: Statistics and 2011 LCC Sheet: Forecast Cells a) The annual heating load in the 2014 LCC analysis using the RECS 2009 database is significantly higher, especially in the southern region, than the 2011 LCC analysis (based on the RECS 2005). What is the underlying rationale forthe significant increase in heating loads, especially in the South region? 

### DOEresponse: DOEconsiders this question to seekdeliberative process information.
DOE2014 DOE2014 DOE2011 DOE2011 2014/2011 (M\/Btu/year) #Buildings (MVBtu/year) #Buildings MVBtu% Heating Load
- NV\GF
- National 35.296 10,000 31.301 10,000 113% Heating Load
- NV\GF
- North 44.730 5,299 39.170 5,986 114% Heating Load
- NV\GF
- South 24.661 4,701 19.565 4,014 126% b) The LCC spreadsheet contains over 100 Crystal Ball Monte Carlo simulation-controlled variables. It also contains parametric assumptions that are not evident in the spreadsheet, for example: 

### The approximatepercentage oftotalheating loadin the southern region ofthe totalnational heating load forbuildings selected for analysis can be estimatedbymultiplying buildings'LBNL modifiedweightingfactors by theirannualheating NGconsumptionprovidedin the RECS2005 database. In the 2011 LCCspreadsheet thatnumbers is 8.6%. Itis relatively close to the 9.5% calculated for thesame buildings with the RECS2005 original weighingfactors before they were modifiedby LBNL. This suggests thatthe ratio of building heating loads in the southern region to the restofthe countryin the LBNLsample is similarto RECS2005 weightingfactors. Asimilarcalculation in the 2014 LCCspreadsheetshows that this numberis 17%, oralmost double thatofthe2011 version. It

### is also much largerthan the 12.2% calculatedwith the RECS 2009 original weighingfactors demonstrating more aggressive modification ofweightingfactors in the southern region byLBNL infavor of increasing these loads. Theprocessed/static weighting factor numbers in the2014 LCCspreadsheet(in contrast to the2011 version wherefactors are calculatedin the spreadsheet) makes itimpossible to evaluate the methodology used.
What is the methodologythat was used to adjust these weighting factors? 

### DOEresponse: The weightingfactors are adjusted to match historicalshipmentdata bystate. Total weightmatches the2021 projectedshipments in the NIA spreadsheet.

3) DOE 2011 Furnace LCC Sheet "Forecast Cells" Installed Price (HS to H12), 2009 Installed Price DOE 2014 Furnace LCC Sheet "Labels" (M36 to M40) DOE 2014 Furnace LCC Sheet "Forecast Cells" sum of non-switching retail price (03123 to 03127) and installation cost (03163 to 03167), 2013 Installed Price; What is the basis ofthe large differential increase in the installed cost ofa baseline 80% NWGF vs. the installed cost increase ofcondensing NWGFs in the 2014 LCC when compared with the 2011 LCC (in switching or non-switching configuration)?Attachment: DOE Response to APGA Questions January 

### 14, 2015
DOEresponse: DOEconsiders this question to seek deliberative process information. NoSwttchlng No Swttching No Switching South IXJE2014 IXJE2011 IXJE2011 2014/2011 2013 $ 2009 $ 2013$ 0 ..i. Change Retail Price NIJVGF 80% $1, 147.0 $831.2 $902.6 127.1% N'v'K3F90% $1,305.1 $1,035.0 $1,123.8 116.1% r-.tNGF 920/o $1,321.5 $1,096.6 $1, 190.8 111.0% M-VGF95% $1,449.6 $1,237.4 $1,343.7 107.9o/o M'VGF98% $1,644.9 $1,502.1 $1,631.0 100.9% Inst. Cost 

# I NWGF80% $847.0 $782.8 $850.1 99.6% N\fllGF 90% $1,038.1 $1,147.1 $1,245.5 83.3% r-M'Gf92% $1,038.1 $1,147.1 $1,245.5 83.3% NVVGF95o/o $1,038.1 $1,147.1 $1,245.5 83.3% f'.MIGF 98% $1,038.1 $1, 159.3 $1,258.8 82.5% Total Installed 

# I flM'GF 80% $1,994.0 $1,614.1 $1,752.7 113.8% NVVGF90% $2,343.2 $2,182.0 $2,369.4 98.9% r-.M'GF 92<'/o $2,359.5 $2,243.7 $2,436.3 96.8% N'NGF95% $2,487.6 $2,384.5 $2,589.2 96.1% MNGF98% $2,683.0 $2,661.3 $2,889.8 92.8% No 9.vttching No Swttching NoSWlching North OOE2014 OOE2011 OOE2011 201412011 2013$ 2009$ 2013$ o/o Olange Retall Price NWGF80% $1, 178.0 $876.5 $951.7 123.8% NWGF90% $1,345.7 $1,083.1 $1, 176.1 114.4% NWGF92% $1,361.4 $1,145.4 $1,243.8 109.5% NWGF95% $1,501.1 $1,294.1 $1,405.2 106.8% NWGF98% $1,690.7 $1,537.6 $1,669.6 101.3% Inst. Cost 

# I NWGF80% $1,229.8 $1,024.4 $1, 112.3 110.6% NWGF90% $1,662.6 $1,390.8 $1,510.2 110.1% NWGF92% $1,662.6 $1,390.8 $1,510.2 110.1% NWGF95% $1,662.6 $1,390.8 $1,510.2 110.1% NWGF98% $1,662.6 $1,405.3 $1,525.9 109.0% Total Installed 

# I NWGF80% $2,407.7 $1,900.8 $2,004.0 116.7% NWGF90% $3,008.3 $2,473.9 $2,686.3 112.0% NWGF92% $3,024.0 $2,536.2 $2,753.9 109.8% NWGF95% $3, 163.7 $2,684.8 $2,915.4 108.5% NWGF98% $3,353.3 $2,942.8 $3, 195.5 104.9%

### Attachment: DOE 

### Response to APGA 

### Questions January 14, 2015

-- --- ------ - - No SW Itching No Switching No Switching 

### National DOE2014 DOE2011 DOE2011 2014/2011

---- -- ---- 2013$ 2009$ 2013$ % Olange Retail Price f\MIGF 80% $1,163.4 $858.3 $932.0 124.8% t#llGF90% $1,326.6 $1,063.8 $1,155.1 114.8% M'VGF92% $1,342.6 $1,125.8 $1,222.5 109.8% NNGF95% $1,476.9 $1,271.3 $1,380.5 107.0% IWVGF98% $1,669.2 $1,523.3 $1,654.1 100.9% Inst. Cost 

# I M'VGF80% $1,049.8 $927.4 $1,007.0 104.2% l'NVGF 90% $1,369.0 $1,292.9 $1,403.9 97.5% f#VGF92% $1,369.0 $1,292.9 $1,403.9 97.5% l'M'GF 95% $1,369.0 $1,292.9 $1,403.9 97.5% NNGF98% $1,369.0 $1,306.5 $1,418.7 96.5% Total Installed 

# I IWVGF80% $2,213.2 $1,785.7 $1,939.1 114.1o/o NiM3F90% $2,695.6 $2,356.7 $2,559.1 105.3% NNGF92% $2,711.6 $2,418.8 $2,626.4 103.2% l'NVGF 95% $2,845.9 $2,564.3 $2,784.4 102.2°/o IWVGF98% $3,038.2 $2,829.8 $3,072.8 98.9% S\viching No Switching No Switching 

### South DOE2014 DOE2011 DOE2011 2014/2011

---------------- 2013$ 2009$ 2013$ % Olange Retail Price NIM3F80% $1,147.0 $831.2 $902.6 127.1% N\!\GF90% $1,242.3 $1,035.0 $1,123.8 110.6% NIM3F 92%1 $1,256.9 $1,096.6 $1,190.8 105.6% NIM3F95% $1,359.2 $1,237.4 $1,343.7 101.2% IWVGF98% $1,493.2 $1,502.1 $1,631.0 91.6% Inst. Cost 

# I Nv'X3F 80% $847.0 $782.8 $850.1 99.6% f'Ni/GF 90% $1,032.9 $1,147.1 $1,245.5 82.9% NM3F92% $1,033.0 $1,147.1 $1,245.5 82.9o/o N\M3F95% $1,034.5 $1,147.1 $1,245.5 83.1% IWVGF98% $1,039.9 $1,159.3 $1,258.8 82.6% Total Installed 

# I M\X3F80% $1,994.0 $1,614.1 $1,752.7 113.So/o NIM3F90% $2,275.2 $2,182.0 $2,369.4 96.0% IWVGF92% $2,289.9 $2,243.7 $2,436.3 94.0% NVl/GF 95% $2,393.7 $2,384.5 $2,589.2 92.4% Nv'X3F98% $2,533.1 $2,661.3 $2,889.B 87.7o/oAttachment: DOE Response to APGA Questions January 14, 2015

SW iching No sw iching No Swiching North DOE2014 DOE2011 DOE2011 2013$ 2009$ 2013$ Ratall Price f'MGF809b $1,178.0 $876.5 $951.7 N\M3F90% $1,325.2 $1,083.1 $1,176.1 NV\UF 92% $1,340.9 $1,145.4 $1,243.8 f'MGF 9590 $1,471.5 $1,294.1 $1,405.2 NV\UF 98% $1,646.8 $1,537.6 $1,669.6 Inst.Cost 

# I N\AGF 8090 $1,229.8 $1,024.4 $1,112.3 f'MGf 90% $1,661.9 $1,390.8 $1,510.2 NV\UF 92% $1,662.1 $1,390.8 $1,510.2 NVIUF 95% $1,663.2 $1,390.8 $1,510.2 NV\UF 98% $1,666.0 $1,405.3 $1,525.9 Total Installed 

# I flMGF 809& $2,407.7 $1,900.8 $2,064.0 NV\UF 90% $2,987.0 $2,473.9 $2,686.3 NV\UF 92% $3,003.0 $2,536.2 $2,753.9 N\f!X3F 95% $3,134.7 $2,684.8 $2,915.4 NV\UF 98% $3,312.8 $2,942.8 $3,195.5 SWiching No Switching No &.v Itching National DOE2014 DOE2011 DOE2011 2013 $ 2009$ 2013$ Retail Price NWGF80% $1,163.4 $858.3 $932.0 M'/GF90% $1,286.2 $1,063.8 $1,155.1 M'/GF92% $1,301.4 $1,125.8 $1,222.5 M'/GF95% $1,418.7 $1,271.3 $1,380.5 NWGF98% $1,574.6 $1,523.3 $1,654.1 Inst. Cost 

# I NWGF80% $1,049.8 $927.4 $1,007.0 twi/GF 90o/o $1,366.2 $1,292.9 $1,403.9 NWGF92% $1,366.4 $1,292.9 $1,403.9 NWGF95% $1,367.6 $1,292.9 $1,403.9 NWGF98% $1,371.7 $1,306.5 $1,418.7 Total Installed 

# l M'/GF80% $2,213.2 $1,785.7 $1,939.1 M'/GF90% $2,652.4 $2,356.7 $2,559.1 M'/GF92% $2,667.8 $2,418.8 $2,626.4 t#VGF95% $2,786.3 $2,564.3 $2,784.4 M'/GF98% $2,946.3 $2,829.8 $3,072.8 201412011 o/o O!ange

123.8°/o 112.7% 107.8% 104.?o/o 98.6%

110.60/o 110.0o/o 110.1o/o 110.1°/o 109.2°/o

116.70/o 111.2°/o 109.0°/o 107.6% 103.7o/o

2014/2011 % O!ange

124.8% 111.3% 106.5% 102.8% 95.2o/o

104.2% 97.3% 97.3o/o 97.4% 96.7%

114.1% 103.6% 101.6% 100.1% 95.9%Attachment: DOE Response to APGA Questions January 14, 2015 4) Sheet: Forecast Cells. Rows 3143-3152 and 3183-3192 The installation and retail cost ofelectric water heating equipment predicted bythe model is higherthan the cost ofgas equipment. This is an unexpected result. For example, RSMeans costs for electricwater heaters are lowerthan for comparable gas water heaters, as expected. What is the rationale for higher electricwater heatercosts? 

### DOEresponse: When households with gas waterheaters switch to electric, they incurahigh installation cost to wire the waterheaterlocationfor electric.

R4 LCC&PB Cale a Retell Price ( ($) Calcs'!$R$40 Retail Price (switching) Gas waterHeate O R4 LCC&PB Cale 1 Reta!1 Price ( ($) Calcs'!$R$41 Retail Price (swilch!ng) Gas waterHeate 1 R4 LCC&PB Cale2 Retall Price ( ($) Calcs't$RS42 Retail Price (switching) Gas waterHeate 2 R4 LCC&PB Cale 3 Retail Price { ($) Calcs'!SR$43 Retail Price (switching) Gas waterHeate 3 R4 LCC&PB Cale 4 Reta!I Price ( ($) Calcs'!$RS44 Retail Price (swllchfng) Gas WaterHeate 4 R4 LCC&PB Ca!e5 Retail Price ( ($) Calcs'!$R$45 Retail Price (switching) ElectricWater He O R4 LCC&PB Cale 6 Retail Price ( ($) Calcs'l$R$46 Retall Price (switching) ElectricWater He 1 R4 LCC&PB Cale7 Reta!I Price ( ($) Calcs'!$R$47 Retall Price {switching) ElectricWater He 2 R4 LCC&PB Ca!e8 Retail Price ( ($) Calcs'l$R$48 Retail Price (switching) ElectricWaler He 3 R4 LCC&PB Cale 9 Retail Price ( ($) Calcs'!$R$49 Retall Price (switching) ElectricWater He 4 $4 LCC&PB Cale 0 Installation C($) Calcs'!$S$40 Installation Cost(swilchlngGas WaterHeate O $4 LCC&PB Cale 1 Installation C($) Ca1cs'l$S$41 Installation Cost(switchingGas Waler Heate 1 $4 LCC&PB Cale2 Installation C($) Calcs'!$S$42 Installation Cost(switching Gas Waler Heale 2 $4 LCC&PB Cale3 Installation C ($) Calcs'l$S$43 Installation Cost(swilchlngGas \rVaterHeate 3 $4 LCC&PB Cale4 Installation C($) Calcs'!SSS44 Installation Cost(switchingGas Waler Heate 4 $4 LCC&PB Cares Installation C(S) Calcs'!$S$45 Installation Cost(switching Electric'NaterHe O $4 LCC&PB Cale6 Installation C($) Calcs'!$S$46 Installation Cost(switching Electric 'Nater He 1 $4 LCC&PB Cale7 Jnstallalion C($) Calcs'l$S$47 Installation Cost(switching ElectricWaler He 2 $4 LCC&PB cares Installation C ($) Calcs'l$S$48 Installation Cost(svlitching Electric 'Nater He 3 $4 LCC&PB Cale9 lnslal!alion C($) Calcs'l$S$49 Installation Cost(switching Electric 'Nater He 4**Reta~** priCes are rO"NS314J-3152

tnsta'lalion costs areraNs3183- 3192 

# "' 18
41 18
42 18
43 18
44 18
45 18
48 18
47 18
48 18 49 18 

# "' 19
41 19
42 19
43 19
44 19 45 19
48 19
47 19
48 19
49 19 Mean Median Min Max
6838 8319 680.0 616.6 48.6 3309.5 6839 8140 675.3 615.6 48.6 3309.5 6840 8138 674.8 615.2 48.6 3309.5 6841 8125 674.8 615.6 48.6 3309.5
6842 8079 674.3 615.2 48.6 3309.5 6833 0---
6834 179 844.8 696,7 459.6 3092.6 6835 181 871.3 696.7 459.6 3092.6 6836 194 884.8 696.7 459.6 3092.6 6837 240 907.1 692.2 459.6 3092.6 6456 8319 592.4 589.1 245.4 1155.2 6457 8140 592.6 589-1 245.4 1155.2 6458 8138 592.5 589.1 245.4 1155.2 6459 8125 592.4 589.1 245.4 1155.2 6460 8079 593.0 589.1 245.4 1155.2 6451 0

-- 8452 179 713.2 716.3 441.3 996.7 6453 181 716.3 719.6 441.3 996.7 6454 194 719.0 714.0 426.7 1260.8 6455 240 698.9 689.3 426.7 1260.8

The source ofequipment cost data in the 2014 LCC spreadsheet is "CAC and HP
- 2011 Direct Final Rule; EWH and GWH 2010 Heating Products Final Rule" (see "Equip Price" sheet Table located at Y27 and listed below).

### Attachment: DOE Response to APGA Questions January 14, 2015
Numbers from this table are first multiplied by local Total Distr./Const. Markup and Sales Tax than by Learning Curve Coeff. and by GDP Deflator. (See "Equip Price" sheet ADS to 12 and listed below) Implicit Price Deflatorsfor Gross Domestic Product (Gross private domestic Investment2013 vs. 2009) usedis 1.04039. Source: http:(/www.bea.qov/notionol/pdf/dpqa.pdf Engineering Analysis Data

13SEERCAC 14SEERCAC 14Sa=RHP (HP, Indoor lklit) 2-Ton $573.87 $633.96 $900.47 3-Ton $642.12 $705.76 $1,075.56 Mnfr. Production Cost{MPG)"

(2009$)
5-Ton $894.62 $984.85 $1,352.70 30 gal 40 gal 60 gal 68 gal 76/80 gal GWH- Default $172.00 $187.00 $200.00 $537.00 $565.00 GWH

- O:tra Low NOx $273.00 $290.00 $303.00 $631.00 $659.00 BYH $142.00 $159.00 $170.00 $569.00 $592.00 Source: CACand t-P• 2011 Di'e<:I F11al Rule; B'\ttand GV\tt2010 Heatilg Products FnaJ Rule 

### 5) Sheet: NWGF Switching. D48 and D49 119 gal

$655.00 2-Ton $16.02 $20.30 $25.45
30 gal $17.00 $20.00 $21.00 Shipping Cost Estimate (2009$)
3-Ton 5-Ton $20.51 $28.42 $24.83 $29.50 $30.54 $38.42 40gal 50gal 66 gal 76180 gal $20.00 540.00 $56.00 $61.00 $26.00 $54.00 $56.00 $61.00 $21.00 $56.00 $64.00 $87.00



### a) What is the rationale for choosing a single payback (3.5 years) as the basis offuel switching decisions? DOEresponse: DOE considers this question to seek deliberative process information. 

### b) Why is a single time period used for all buildings and owners ratherthan one dependent on discount rates, income, etc.? For example, there are discount rates in Sheet: Discount Rate. Rows 26-116 that could be used to create a distribution ofpayback periods forthis decision. DOEresponse: DOE considers this question to seek deliberative process information. 

### 6) Sheet: NWGF Switching. Column AG a) What is the decision making criteria for choosing which non-NWGF option is selected when fuel switching occurs? DOEresponse: This is the 3.5 yearpayback (which was discussed in detail at the public meeting). 

### b) Why are values negative and What happens in the formula when negative values occur(meaning the firstyear operations cost ofthe switching option is lowerthan the firstyear operations cost ofthe high efficiency NWGF)? DOEresponse: A negative value occurs in thisformula ifthe operating cost and totalinstalled costis lowerfor the switching option compared to the high efficiencyNWGF. Switching always occurs when there is o negative value in this formula. 

### c) Why does fuel switching remain high even at extreme payback times whether negative values are excluded or not? DOEresponse: Switching only occurs when payback ofthe higherefficiency option compared to the switching option is greater than 3.5years ora negative value occurs (in the case when the 119 gal
$107.00

### Attachment: DOE Response to APGA Questions January 14, 2015



# ..

. e

## ~**~** 

# '* operating costand total installedcostis lower for the switching option comparedto the high efficiencyNWGF).

d) Pushing the "payback period" up (changing D48&49 to high values) does not eliminate fuel switching. Even at 15 years it remains around 10

### %. In part this is because options that have a negative "payback period" will always allowswitching and also because some fuel switching options make economic sense even when considering a longtime horizon. This switching behavior is entirely rational. A significant fraction ofthese switching events would be expected to occur in the absence ofa DOE rule. Are these rational fuel switching cases included in an estimate of LCC savings due to a DOE rule change? 

### DOEresponse: The userneeds to re-run the Monte Carlo simulation to see the results change in the spreadsheet.

e) The switching "payback period" is essentially the ratio ofthe first cost advantage ofa switching option to the annual operation cost disadvantage ofsame option. Because this analysis is a Monte Carlo analysis this will tend to choose situations which are low operations cost disadvantage and/or high first cost advantage. This is likely to underestimate the true cost offuel switching. How does this inherent aspect ofthe Monte Carlo methodology work?? 

### DOEresponse: Fuelswitching is basedon economicsfor each sampledhousehold. The sampled households are randomlyselectedby the Monte Carlo approach.

80%

70% 

## ' ! 60% 

### :f Pc. 

# " '• 50% 0 l> All Gas to Notall Gas e GVVH to EWH a Gas Heat to Electrk Heat

40% 

## • 

# • ' 

## ' 30%**:,:.~** 

# • i 

### • 

## Fuel switching at long times 20% 

# • ! 

## is reduced by about half 

# " ' 

## • 

# • ! 10% ! 

## ' 

# • • s • G 3 $ 

## ' G 

# • • 

# • '**~** 

## § i i 0% 0 5 10 20 2 30

### Attachment: DOE Response to APGA Questions January 14, 2015

100% 

# '°"

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### :c 

# ·i

# -**~** 0 

## " bl) l'l 

# ""' c 

## " le 

# " 0% a.

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### Percentage ofswitching dueto simultaneousfirst cost and first year operations savings

- replacement

0 0 0 0 

# • • • 

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payback period

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## < First cost advantaqe ($) 11 

## b k f 't 

## h" "

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## s - pay ac ,or sw1 c mg O'>eration cost**disadvantage(~'-)** 

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### -year



### 7) Sheet: Overall Spreadsheet 

## When you start bringing the good:bad ratio down it is the overlapping tails of high first cost advantage and low operation cost disadvantage that will cross the threshold.

How are the negatively and positively impacted homes segmented? This includes north/south, and new construction/replacement segments. Included in the segmentation would be replacement costs ofdifferent options in different home locations, sizes, and configurations, as 30

### Attachment: DOE Response to APGA Questions January 14, 2015
well as otherfactors that would impact consumer classes differently. Averages do not showthe marginal affected consumers. DOEresponse: RECSprovides regional location byhousehold. DOE developeda method to designate which households can be consideredas newconstruction. 

### 8) Sheet: Summary Switching. Columns H and I Howwere the GTI survey numbers processed? DOE response: These numbers are not usedin the analysis and are notpart ofthe latest LCC spreadsheet.

# DOE reported GTI results

....· Buikfers lnstaUatlon contractors

. North South North South

,---_-,·-, ,' 

### ... 

# . . Re Fbst Re Fl>st Re Fl>st Re Fl>st Low-eff gas Gas 12.7% • 0.0% 13.6% 0.0% 23.1% 0.0% 45.0%. 0.0% H·eff gas Gas 59.9% 61.7% 46.6% 59.2% 61.6% 78.0% 26.2% ' 58.0% BHP Gas 0.3% 8.4% 9.4% 6.1% 3.6% 7.0% 3.5% 12.4% 8 furnace Gas 0.0% 0.0% 0.6% 0.1% 0.9% 2.2%1 1.5% 1.6% Lo\v-eff gas 

### Bee 4.3% 0.0% 9.6% 0.0% 1.9% 0.0% 2.6% 0.0% H·effgas 

### Bee 18.2%. 24.8% 14.1%

. 26.9% 2.6% 4.0% 3.1% 6.5% BHP 

### Bee 1.8% 4.0% 5.4%1 6.8% 3.5% 4.5% 8.7% 10.6% 8 furnace 

### Bee 2.5% 0.6% 0.4% 0.5% 0.9% 1.7% 1.7% 1.5% Other . 0.3% 0.5o/o 0.3% 0.4% 1.8% 2.6% 7.6% 9.3% 

# GTI results

Builders Installation contractors

.. North South North South



### . .·.•.··.•·· ,.-
- __ -- .··· . 

# :.· · .. · Re Fl>st Re Fbst Re Fl>st Re Fl>st Low-eff gas Gas 16.3%. 0.0% 13.7% 0.0% 25.1% 0.0% 39.6%. 0.0% H·effgas Gas 65.8% ; 78.8% 54.7% 62.1% 58.0% 77.2% 30.3% 61.2% BHP • Gas 2.0% 3.2% 3.8% 9.8% 2.9% 6.6% 4.4% 10.9% B furnace Gas 0.1% 0.1% 1.1% 0.4% 0.9% 1.7% 1.5o/o 1.8% Lo\v-eff gas 

### Bee 1.6% 0.0% 5.7% 0.0% 2.2% 0.0% 2.7% 0.0% H-effgas 

### Bee 9.1% 12.3% 7.9% 13.7% 2.9% 4.8% 3.7°.i. 5.9% BHP 

### Bee 2.3% 3.5% 8.3% 9.2% 3.0% 4.0% 9.9% 11.7% 8 furnace 

### Bee 1.2% 0.4% 3.1% 2.7% 1.0% 1.4% 1.8% 1.7o/o other 1.6% 1.8% 1.7% 2.1% 4.0% 4.2% 6.1% 6.9%

### Attachment: DOE Response to APGA Questions January 14, 2015


### DOE GTI %SWltehlng Fraetiorl or N:>rrcondenslog t.Y,tJFSN ilchhg Fraction ofAU N1V3F SNttehhg Replacement AU Gas Gml Gas Fll'n AD Gas GY1H Gas Fan to to to to to 

# ,, census Oiv »:itAll Gas EVoH 

# """"' f'.bl.AUGas E'o\H 

# ""'""' all gas to gas water gas heat to not all gas heaterto 1 

# .... .... 

# . ... 

# . ... .... 

# . ... electricheat 2 2.7% 

# ... '-"' 21• 

### ,_

# .. ... electric 3 

# ..... ,_

# .. 8.5% 

# ..... ,_.,. 

# .... water 

# • 20.•v. 

# ..... 221% 20.4% M% 6.5% heater 

# • '°·"' 0.3% 21.5% 

# ...... 0.3% 11.5% 

## ' 24.7% 2.5% 29.4V. 24.7% 2.6>1 16.3% Replacement 6.8% 1.3% 7.0% 7 13.4% 2.0>I 15.3% 13

. .(% 20>1 14.6'4 

# • '-"' 2.0l< 7.4'1. 

## '-"' 2.0l< 4.-4% 

# • 37.00I> 5.4% 

# ...... 37.0¥. 5.4% 27.5% New 5.8% 2.2% 4.4% 10 

## '°·"' 02• 18.6'4 

# ..... 52'1. 14.7'l9 National 15.6% 

# ,

# ... 16.65S":f. 15.6% 2-8'1.. 9.0l\
Now A&Gas**G~H** Gas Furn to to to Census Div N>lAllGas E\IH Bee FIXn all gas to gaswater gas heat to electric heat 1 

## '-"" 

# ..... ......

# '~ notall gas heaterto 2 9.72% 8.3311>**13.7~** electric 3 13J•6Y. 

## '-"" 16.78% 

# • 25.00V. 22,,. 21.31% water 

## ' 13.44!1.**V~tV.** 14.41% heater 

# ' 17.91% 5.97% 16.67% 

### ' 7 

# ..... 

# =· 5.51% Replacement 20.7% 3.9% 21.3% 

# • 12.0$% 

# ..... 13.83% 

# • 

# .,,,. . 2222>1 

# "·""' New 27.4% 10.3% 21.0% 10**33.IJS~ 11.~**  

# """' -·------ ------\!> NaIlona\ 19.Wio 7.68% f9.S-4% 

### 9) Sheet: Bldg Sample and general methodology The buildings sampled are only those that use natural gas or LPG as a heat source and it is used as a primary or secondary source of heat. Are there any other criteria for selecting buildings to specifically select for buildings where an 80% NWGF would have been installed in the absence of a DOE rule mandating higher efficiencies? 

### DOEresponse: Thefraction of buildings where on 80% NWGFwouldhove been installedin the absence of higherefficiencystandards is determinedin the base case distribution worksheet. Thefraction varies by region andwhetheritis areplacement arnew construction installation. The specifichouseholdassignments ore done randomly. 10) Sheet: Summary Switching Switching statistics should be differentfor different efficiency levels; however, the spreadsheet shows only one set. Is it a composite, how it is calculated, and how do the statistics look in each group? It appears thatthis is supposed to be the content of M35
- R58 on the same sheet but these all contain #REF! ratherthan data. 

### DOEresponse: The reportedvalues have been correctedin the latestLCCspreadsheetpublished in DOE's website. The correction has no impacton analysis results. 11) Sheet: Summary Switching, National Summarytables Replacement AC18 and New Construction AC32 Why does the summary of national switching and no switching cases add to 11,129 cases when only 10,000 cases were analyzed? 

### DOEresponse: The reportedvalues hove been correctedin the latestLCCspreadsheetpublished in DOE's website. The correction has no impact on analysis results.

### Attachment: DOE Response to APGA Questions January 14, 2015

12) Using the 2014 LCC spreadsheet and allowingfuel switching Improves LCC savings compared to disallowingfuel switching Ifthe 'payback' for switching decisions is long (15 years for sheet NWGF Switching cells D48 and D49 is shown below). The effect is even larger in the south. Does this mean thatfuel switching should be expected to reduce costs to consumers (e.g., in the South) as a result ofthe new minimum efficiency level? DOEresponse: Fuelswitching is based on economicsforeach sampledhousehold. Depending on the householdeconomics the switching mayormaynot result in economic benefits. Simulation Results NATIONAL -10000 samples Fuel Switching Allowed AE02014- Reference Case Average LCC Results I 'eayt:!ack**Result~** Installed Lifetime FirstYear LCC Simple LCC Not No Not S!mple Level ())scrlptlor Price Oper.**Cost~** Oper.Cost LCC Savings Savings Cost Impact, Benefl(Average Median PBP MVGF 0 Nl'\'3f80% $2,209 $10,369 $&14 $12,579 

# "' "' 

# "' 100% 

# "' MVGF 1 Nl'\'3f90% $2,644 $9,434 $590 $12,079 $227 $500 21% 48% 31% 16.6 10.6 8.1 MVGF 2 WVGF92% $2,660 $9,276 $580 $11,935 $292 $843 19% '42% 38% 13.0 8.0 7.1 MVGF 3 IWVGF95% $2,779 $9,039 $586 $11,818 $387 $760 24% 24% 52% 12.6 8.9 7.4 MVGF 4 Nl'\'3f98% $2,943 $8,821 $555 $11,764 $421 $815 41% 0% 59% 16.9 12.2 8.2 MHGF 0**~'H3F80%** $1,551 $10,913 $700 $12,463 

# "' "' 

# "' 100% 

# "' MHGF 1 t.t-+3F92% $1,722 $9,705 $822 $11,426 $895 $1,037 7% 26% 67% 5.4 1.9 2.2 MHGF 2 M-IGF95% $1,865 $9,461 $607 $11,326 $774 $1,137 13% 14% 73% 8.5 4.4 3.4 MHGF 3 M-G97% $1,980 $9,339 $599 $11,319 $782 $1,144 2!j% 0% 74% 12.5 6.7 4.2

Simulation Results NATIONAL -10000 samples Fuel Switching NOT Allowed AE02014- Reference Case Average LCC Results 

## ! paybackRe$ulfs /, Installed lifetime FirstYear LCC Simple LCC Not No Not Sfmple Level Descriptio Price Oper. Cost* Oper.Cost LCC Savings Savings Colt Impact' BenenfAverage Median PBP MVGF 0 Nl'\'3f80% $2,213 $10,347 $&15 $12,560 

# "' "' NA 100% 

# "' MVGF Nl'\<lf 00% $2,696 $9,437 $586 $12,133 $169 $427 22% 47% 31% j 18.6 12.0 8.5 MVGF 2 f'.NllGF92% $2,712 $9,271 $578 $11,982 $243 $578 20% 41% 39% 

### 1 14.5 8.8 7.5 MVGF 3 i'MGF95% $2,846 $9,028 $563 $11,874 $311 $687 25% 23% 52%'\ 14.1 9.7 7.7 MVGF 4 Nl'\'3f98% $3,038 $8,822 $550 $11,860 $324 $700 42% 0% 57% 

### i 18.2 13.1 8.7 MHGF 0 t.tt3F 80% $1,551 $10,885 $700 $12,436 

# "' "' 

# "' 100% 

# "' MHGF t.tiGF92% $1,721 $9,679 $822 $11,399 $701 $1,037 7% 26% 67% 5.7 1.7 2.2 MHGF 2 ,.t-IGF95% $1,864 $9,435 $607 $11,299 $780 $1,137 13% 14% 73% 8.8 4.4 3.3 MHGF 3 ,.'H3F97% $1,979 $9,313 $599 $11,292 $787 $1,144 25% 0% 75% 12.9 6.5 4.2 

### 13) Sheet: Statistics and Forecast Cells 03043 to 03052 Why is the national annual fuel usage perefficiency group in the 'Statistics' sheet differentthan the one listed in the 'Forecast Cells' sheet? DOE response: The reported values include switching, while forecast cells 03043 and03052 are for NWGFs onlyanddo notinclude households thatswitch to otherequipment. 

### 14) Sheet: Energy Price, Table Marginal Energy Prices What is the source ofthe marginal electric and gas prices? Did the analysis incorporate any of the marginal gas price information provided byAGA based on its membersurvey? DOE response: Marginalelectric andgas prices are basedon EIA data. DOEconsideredAGA membersurveydata along with all the otherdata DOEhas (such as RECS billing data and tariff data providedbyAGA}. The full methodology will be explainedin the NOPR TSO.

### Attachment: DOE Response to APGA Questions January 14, 2015 15) Sheet: Equip Price. AC50 What is the source ofthe factor of 1/3that is multiplied by the cost differential (EF vs. NWGF)? DOEresponse: The Mfactoris the conversion factorbetween RS Means retailprice and manufacturedproduction cost. Itcorresponds to the overallmarkup used to convert manufacturers'cost to consumerprice. 

### 16) Sheet: Base Case AFUE What is the source ofthe distributions offurnace efficiencies (newand replacement)? DOEresponse: Itis based on manufacturerinterviews, historicalshipments data by efficiency, andnumberofmodels at each efficiency level. 

### 17) Sheet: Bldg Sample, E67, E61 What is the source ofthe uniform distribution chosen for remaining lifetimes for cooling and water heating equipment? DOEresponse: The analysis assumes that the remaining lifetime will befrom 1 year to the average lifetime {19 for CAC/HP or 12 yearsfor WHs); this applies only to equipment that does notfail at the same time as the furnace. 

### 18) Sheet: Installation Cost, Columns Eand F The source forthe assumptions regarding venting options and conditioned vs. unconditioned space is given as "Consultant Report." Is this report available? DOEresponse: Consultant report is a part of Appendix8-B ofthe 2011 DFR TSO. 

### 19) Sheet NWGF Switching and LCC&PB Cales It appears that in NWGF Switching column AA, equipment age related discounting incorporates a present worth factorfrom columns 

### AJ and AK. Butthe source ofthe cost numbers is generated in the LCC&PB Cales sheet, where the same present worth factor is used to discount costs in cells 044 and 046. Is this double counting the present worth factor? DOEresponse:· The latest LCCspreadsheetpublishedin DOE's website has been correctedand the updated results reflect the correction. 

### 20) Summary Sheet a) Why are the National, North and South Region Installed Prices in "Summary" sheet (row K) different (smaller) than the calculated weighted average of Replacement and Newvalues (rows AA and AP)? DOEresponse: The reported values have been correctedin the latest LCCspreadsheetpublished in DOE's website. The correction has no impact on analysis results. 

### b) 2014 LCC CB 10,000 cases default simulation run includes 9,717 residential and 283 commercial buildings. Are the commercial buildings results included in the Simulation Results NATIONAL- 10000 samples tables in the "Summary" sheet?? DOEresponse: Commercialbuildings were included in the analysis.