BY U.S. MAIL AND EMAIL 

Mr. William T. Miller 

Partner 

Mccarter & English, LLP 

1015 151h 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: 

DOE has considered APGA's November 14, 2014 letter, and while we regret that APGA did not 

believe its questions were answered at the November 7, 2014, public meeting, we disagree with 

the implication in your letter that DOE has not fully complied with the settlement agreement in 

American Public Gas Association v. Department of Energy et al., No. 11-1485 (D. C. Cir. filed 

Dec. 23, 2011), which required DOE "to make available to the public the data gathered and 

analyzed by the agency prior to publication of a proposed rule." We believe that the data so 

gathered in connection with the remanded furnace rule, and made publicly available by DOE 

pursuant to the settlement, is extensive and provides ample opportunity for analysis prior to 

issuance of the proposed rule. 

As explained in the meeting announcement published in the Federal Register on October 30, 

2014, the purpose of the public meeting was to provide an opportunity for DOE to explain in 

more detail the data included in the three spreadsheets that were made publicly available on 

September 26, 2014, and to answer questions concerning the analytical tools operative in those 

spreadsheets. 79 FR 64517. In accordance with that goal, DOE provided a comprehensive fourhour tutorial on the spreadsheets and responded to questions. In particular, DOE provided 

detailed answers to all of APGA's questions to the extent that they did not implicate predecisional, deliberative matters with regard to the draft proposed rulemaking concerning nonweatherized and mobile home gas furnaces, which remains under review within 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 within the Executive branch may conduct separate analyses of the issues being 

addressed in the rulemaking and form conclusions based on these analyses. These analyses are 

conducted using a fixed set of data. Although the data set remains fixed, the analyses and 

accompanying conclusions may change as the inter-agency process proceeds. To ensure robust 

debate within the government, the process of conducting and considering the analyses upon 

which an agency's ultimate policy decision is based is protected by a deliberative process 

privilege. A proposed rule that is the product of this inter-agency process is published in the 

Federal Register and the public is provided a period (usually between 30 and 60 days) in which 

to comment on the data, the agency's approach to analyzing the data, and the policy choices 

made in the proposed rule. 

DOE does not typically provide data supporting the policy decisions at issue in developing a 

proposed rule prior to issuing that proposed rule document. However, in accordance with the 

Joint Statement supporting the settlement agreement in APGA v. DOE, DOE made "available to 

the public the data gathered and analyzed" in developing a draft proposed rule from DOE that 

was submitted to and remains under review at the Office of Management and Budget (OMB). 

(Joint Statement, pp. 7-8). The provision of these data at this stage of rule development is 

unprecedented in DOE's past rulemaking activities. 

DOE understands that the data that were provided were complicated and voluminous, as is 

typical of most appliance standards rulemakings. Therefore, to address APGA's concerns about 

its ability to understand and utilize the data provided, DOE hosted a public meeting, on 

November 7, 2014, to explain the spreadsheets and the analytical tools underlying the 

spreadsheets in a comprehensive, step-by-step fashion and to answer questions that the public 

may have had regarding the calculations DOE conducted in producing the spreadsheets. When 

APGA submitted its questions prior to the meeting, at DOE's request, APGA was aware that the 

draft proposed rule was at OMB and thus was still undergoing the deliberative process applicable 

to agency rulemaking. Therefore, APGA could not reasonably have expected that DOE would 

answer any questions that involved the ongoing deliberative interagency process, and I was clear 

in my communication to you, that DOE would not answer any such questions. APGA claimed in 

its November 14, 2014 letter that its questions did not delve 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's regulatory decision, which is a focus of the ongoing deliberative process and is thus 

privileged. Neve1theless, during the course of the public meeting, DOE addressed every 

question APGA submitted that directly pertained to the data and the analytical tools. 

APGA's November 14, 2014 letter claimed that DOE's tutorial on its "opaque and complex" 

spreadsheets "effectively answered none of [their] questions," and characterized answers where 

DOE provided as much information as possible without breaching the deliberative process 

privilege as "tantamount to no answer at all since the complete answer is required to permit 

further analysis." (APGA November 14, 2014 letter, p.l) DOE disagrees. DOE systematically 

walked APGA's technical team through each of the spreadsheets, addressing both previously 
Mr. William T. Miller 

January 14, 2015 

Page3 

submitted questions and questions asked at the meeting. Nevertheless, in the spirit of 

cooperation, DOE is enclosing with this letter written responses to those questions submitted by 

APGA that can be and were answered without waiving the deliberative process privilege. Each 

answer provided in this document was discussed at the meeting. The answers in the enclosure 

are numbered so as to correspond to each APGA question. We are asserting deliberative process 

privilege only to four out of the 29 questions submitted by APGA. 

APGA stated that "time is of the essence" with respect to APGA' s ability to participate in the 

rulemaking at issue. (APGA November 14, 2014 Letter, p. 2). DOE would like to make clear 

that APGA currently has all the data that DOE used to develop the draft proposed rule currently 

under review at OMB. These data are available in this rulemaking process at an earlier point 

than in any other rulemaking issued by DOE. DOE will publish, after OMB concludes its 

review, the proposed rule, on which APGA and all other interested parties will have 90 days to 

conm1ent-a time period that is 30 days longer than most DOE rulemakings. Consequently, 

DOE anticipates that APGA, along with the rest of the interested public, will have ample 

opportunity to participate in the related public meeting( s) and to ask DOE any and all pe11inent 

questions about the proposed rule. DOE also expects that APGA will provide extensive 

comment on that proposed rule. 

Consistent with its obligations under the settlement agreement, and in an effort to be as 

f011hcoming as possible with the public, DOE has made its utmost effort to conduct a timely, 

open, and effective rulemaking process, and will continue to do so. We greatly appreciate 

APGA's pmiicipation in this process and trust that we can c.ontinue our mutual 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 Energy Efficiency 

Attachment 

Attachment: 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 of fuel switching. 

a) What are the major reasons for the significant changes in LCC savings? 

DOE response: DOE used the same model in both 2011 and 2014, if the analysis is run without 

the potential for fuel switching. 1 Nearly all values of inputs changed for a variety of reasons. For 

example, the price of natural gas, one of the LCC spreadsheet inputs, was lower in the 2014 LCC 

spreadsheet than it was in the 2011 LCC spreadsheet. 

b) Why do consumer impacts for replacements in the south not sum to 100% in the 2014 LCC 

spreadsheet? 

DOE response: The reported values have been corrected in the latest LCC spreadsheet published 

in DOE's website. The correction has no impact on analysis results. 

c) The 2014 LCC spreadsheet predicts first year 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 for this significant 

discrepancy in top level results? 

DOE response: There are many inputs to both the DOE model and the AGA model. While fuel 

switching impacts the results cited in the question above, there are many other inputs and 

assumptions in the modeling that may yield different results. A user comparison of the LCC 

spreadsheet used in the 2011 final rule with the current LCC spreadsheet will divulge the changes 

and magnitude of those 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: 

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95%AFUE !lll 2014 Average LCC savings 

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Attachment: 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 for the significant increase in heating loads, especially in the 

South region? 

DOE response: DOE considers this question to seek deliberative 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 approximate percentage of total heating load in the southern region of the total national 

heating load for buildings selected for analysis can be estimated by multiplying buildings' LBNL 

modified weighting factors by their annual heating NG consumption provided in the RECS 2005 

database. In the 2011 LCC spreadsheet that numbers is 8.6%. It is relatively close to the 9.5% 

calculated for the same buildings with the RECS 2005 original weighing factors before they were 

modified by LBNL. This suggests that the ratio of building heating loads in the southern region to 

the rest of the country in the LBNL sample is similar to RECS 2005 weighting factors. 

A similar calculation in the 2014 LCC spreadsheet shows that this number is 17%, or almost 

double that of the 2011 version. It is also much larger than the 12.2% calculated with the RECS 

2009 original weighing factors demonstrating more aggressive modification of weighting factors 

in the southern region by LBNL in favor of increasing these loads. The processed/static weighting 

factor numbers in the 2014 LCC spreadsheet (in contrast to the 2011 version where factors are 

calculated in the spreadsheet) makes it impossible to evaluate the methodology used. 

What is the methodology that was used to adjust these weighting factors? 

DOE response: The weighting factors are adjusted to match historical shipment data by state. 

Total weight matches the 2021 projected shipments 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 of the large differential increase in the installed cost of a baseline 80% NWGF 

vs. the installed cost increase of condensing 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 

DOE response: DOE considers 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'Gf 92% $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/o 
Attachment: 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 of electric water heating equipment predicted by the model is 

higher than the cost of gas equipment. This is an unexpected result. For example, RSMeans 

costs for electric water heaters are lower than for comparable gas water heaters, as expected. 

What is the rationale for higher electric water heater costs? 

DOE response: When households with gas water heaters switch to electric, they incur a high 

installation cost to wire the water heater location for electric. 

R4 

LCC&PB Cale a Retell Price ( ($) Calcs'!$R$40 Retail Price (switching) Gas water He ate O 

R4 

LCC&PB Cale 1 Reta!1 Price ( ($) Calcs'!$R$41 Retail Price (swilch!ng) Gas water He ate 1 

R4 

LCC&PB Cale 2 Retall Price ( ($) Calcs't$RS42 Retail Price (switching) Gas water Heate 2 

R4 

LCC&PB Cale 3 Retail Price { ($) Calcs'!SR$43 Retail Price (switching) Gas water He ate 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) Electric Water He O 

R4 

LCC&PB Cale 6 Retail Price ( ($) Calcs'l$R$46 Retall Price (switching) Electric Water He 1 

R4 

LCC&PB Cale 7 Reta!I Price ( ($) Calcs'!$R$47 Retall Price {switching) Electric Water He 2 

R4 

LCC&PB Ca!e8 Retail Price ( ($) Calcs'l$R$48 Retail Price (switching) Electric Waler He 3 

R4 

LCC&PB Cale 9 Retail Price ( ($) Calcs'!$R$49 Retall Price (switching) Electric Water 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 (switching Gas Waler He ate 1 

$4 

LCC&PB Cale 2 Installation C($) Calcs'!$S$42 Installation Cost (switching Gas Waler Heale 2 

$4 

LCC&PB Cale 3 Installation C ($) Calcs'l$S$43 Installation Cost(swilchlngGas \rVaterHeate 3 

$4 

LCC&PB Cale 4 Installation C ($) Calcs'!SSS44 Installation Cost (switching Gas Waler He ate 4 

$4 

LCC&PB Cares Installation C(S) Calcs'!$S$45 Installation Cost (switching Electric 'Nater He O 

$4 

LCC&PB Cale 6 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 Electric Waler He 2 

$4 

LCC&PB cares Installation C ($) Calcs'l$S$48 Installation Cost (svlitching Electric 'Nater He 3 

$4 

LCC&PB Cale 9 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 of equipment 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 Deflators for Gross Domestic Product (Gross private domestic Investment 2013 vs. 2009) 

used is 1.04039. 

Source: http:(/www.bea.qov/notionol/pdf/dpqa.pdf 

Engineering Analysis Data 

13SEERCAC 

14SEERCAC 

14 Sa=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: CAC and t-P • 2011 Di'e<:I F11al Rule; B'\tt and GV\tt 2010 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 of fuel switching 

decisions? 

DOE response: DOE considers this question to seek deliberative process information. 

b) Why is a single time period used for all buildings and owners rather than 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 of payback periods for this decision. 

DOE response: 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? 

DOE response: This is the 3.5 year payback (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 first year operations cost of the switching option is lower than the first year 

operations cost of the high efficiency NWGF)? 

DOE response: A negative value occurs in this formula if the operating cost and total installed 

cost is lower for the switching option compared to the high efficiency NWGF. 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? 

DOE response: Switching only occurs when payback of the higher efficiency option compared to 

the switching option is greater than 3.5 years or a negative value occurs (in the case when the 

119 gal 

$107.00 
Attachment: DOE Response to APGA Questions 

January 14, 2015 

.. 

. e 

~ 

~ 

'* 

operating cost and total installed cost is lower for the switching option compared to the high 

efficiency NWGF). 

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 allow switching and also because some fuel switching 

options make economic sense even when considering a long time horizon. This switching 

behavior is entirely rational. A significant fraction of these switching events would be expected 

to occur in the absence of a DOE rule. Are these rational fuel switching cases included in an 

estimate of LCC savings due to a DOE rule change? 

DOE response: The user needs to re-run the Monte Carlo simulation to see the results change in 

the spreadsheet. 

e) The switching "payback period" is essentially the ratio of the first cost advantage of a 

switching option to the annual operation cost disadvantage of same 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 

of fuel switching. How does this inherent aspect of the Monte Carlo methodology work?? 

DOE response: Fuel switching is based on economics for each sampled household. The sampled 

households are randomly selected by the Monte Carlo approach. 

80% 

70% 

' ! 

60% :f 

Pc. 

" '• 50% 0 l> All Gas to Not all 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% 

'°" 

bl) 

c 60% 

:c ·i 

~ 

0 -

" bl) 

l'l 

c ""' 

" le 

" a. 0% 

-20% 

-40% 

Percentage of switching due to simultaneous first cost and first year operations savings -

replacement 

0 0 

0 0 • • 

• • i 

! 0 

' 0 • • • 

•• • • 0 • • • ! ,. 0 

(;El Q • ! f". 5 10 15 20 25 

i • 

payback period 

©All Gas to Not all Gas ®GWHtoEWH o Gas Heat to Electric Heat 

< 

First cost advantaqe ($) 11 b k f 't h" " c · · s - pay ac , or sw1 c mg 

O'>eration cost disadvantage(~'-) , t ~ -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 of different options in different home locations, sizes, and configurations, as 

30 
Attachment: DOE Response to APGA Questions 

January 14, 2015 

well as other factors that would impact consumer classes differently. Averages do not show the 

marginal affected consumers. 

DOE response: RECS provides regional location by household. DOE developed a method to 

designate which households can be considered as new construction. 

8) Sheet: Summary Switching. Columns H and I 

How were the GTI survey numbers processed? 

DOE response: These numbers are not used in the analysis and are not part of the 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·eff gas 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·eff gas 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-eff gas 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:>rrcondens log t.Y,tJF SN ilchhg Fraction of AU N1V3F SN ttehhg 

Replacement AU Gas Gml Gas Fll'n AD Gas GY1H Gas Fan 

to to to to to ,, census Oiv »:it All Gas EVoH """"' f'.bl.AUGas E'o\H ""'""' 

all gas to gas water gas heat to 

not all gas heater to 1 .... .... . ... . ... .... . ... electric heat 

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 gas water gas heat to 

electric heat 1 '-"" ..... ...... '~ not all gas heater to 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.~ """' -·------ ------\!> 

Na Ilona\ 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? 

DOE response: The fraction of buildings where on 80% NWGF would hove been installed in the 

absence of higher efficiency standards is determined in the base case distribution worksheet. 

The fraction varies by region and whether it is a replacement ar new construction installation. 

The specific household assignments ore done randomly. 

10) Sheet: Summary Switching 

Switching statistics should be different for 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 that this is supposed to be the content of M35 - R58 on the same sheet but 

these all contain #REF! rather than data. 

DOE response: The reported values have been corrected in the latest LCC spreadsheet published 

in DOE's website. The correction has no impact on analysis results. 

11) Sheet: Summary Switching, National Summary tables 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? 

DOE response: The reported values hove been corrected in the latest LCC spreadsheet published 

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 allowing fuel switching Improves LCC savings compared to 

disallowing fuel switching If the '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 that fuel switching should be expected to reduce costs to consumers (e.g., in the South) as a 

result of the new minimum efficiency level? 

DOE response: Fuel switching is based on economics for each sampled household. Depending 

on the household economics the switching may or may not result in economic benefits. 

Simulation Results NATIONAL -10000 samples Fuel Switching Allowed AE02014- Reference Case 

Average LCC Results I 'eayt:!ack Result~ 

Installed Lifetime First Year 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 ! payback Re$ulfs /, 

Installed lifetime First Year LCC Simple LCC Not No Not Sfmple 

Level Descriptio Price Oper. Cost* Oper. Cost LCC Savings Savings Colt Impact' Benenf Average 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 per efficiency group in the 'Statistics' sheet different than 

the one listed in the 'Forecast Cells' sheet? 

DOE response: The reported values include switching, while forecast cells 03043 and 03052 are 

for NWGFs only and do not include households that switch to other equipment. 

14) Sheet: Energy Price, Table Marginal Energy Prices 

What is the source of the marginal electric and gas prices? Did the analysis incorporate any of 

the marginal gas price information provided by AGA based on its member survey? 

DOE response: Marginal electric and gas prices are based on EIA data. DOE considered AGA 

member survey data along with all the other data DOE has (such as RECS billing data and tariff 

data provided by AGA}. The full methodology will be explained in the NOPR TSO. 
Attachment: DOE Response to APGA Questions 

January 14, 2015 

15) Sheet: Equip Price. AC50 

What is the source of the factor of 1/3 that is multiplied by the cost differential (EF vs. NWGF)? 

DOE response: The M factor is the conversion factor between RS Means retail price and 

manufactured production cost. It corresponds to the overall markup used to convert 

manufacturers' cost to consumer price. 

16) Sheet: Base Case AFUE 

What is the source of the distributions of furnace efficiencies (new and replacement)? 

DOE response: It is based on manufacturer interviews, historical shipments data by efficiency, 

and number of models at each efficiency level. 

17) Sheet: Bldg Sample, E67, E61 

What is the source of the uniform distribution chosen for remaining lifetimes for cooling and 

water heating equipment? 

DOE response: The analysis assumes that the remaining lifetime will be from 1 year to the 

average lifetime {19 for CAC/HP or 12 years for WHs); this applies only to equipment that does 

not fail at the same time as the furnace. 

18) Sheet: Installation Cost, Columns E and F 

The source for the assumptions regarding venting options and conditioned vs. unconditioned 

space is given as "Consultant Report." Is this report available? 

DOE response: Consultant report is a part of Appendix 8-B of the 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 factor from columns AJ and AK. But the source of the 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? 

DOE response:· The latest LCC spreadsheet published in DOE's website has been corrected and 

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 New values (rows 

AA and AP)? 

DOE response: The reported values have been corrected in the latest LCC spreadsheet published 

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?? 

DOE response: Commercial buildings were included in the analysis.