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 U.S. DEPARTMENT OF ENERGY 

 + + + + + 

 FRAMEWORK FOR RESIDENTIAL BOILERS 

 + + + + + 

 PUBLIC MEETING 

 + + + + + 

 WEDNESDAY 

 MARCH 13, 2013 

 + + + + + 

 The Public Meeting met in Room 8E089, 1000 Independence Avenue, S.W., 

Washington, D.C., at 9:47 a.m., Doug Brookman, 

Meeting Facilitator, presiding. 

PRESENT 

DOUG BROOKMAN, Meeting Facilitator, Public 

 Solutions, Inc. 

ASHLEY ARMSTRONG, Department of Energy 

JOHN CYMBALSKY, Department of Energy 

ERIC STAS, Department of Energy 
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ALSO PRESENT 

JOHN BUSSE, U.S. Boiler Company, Inc. 

ADAM DARLINGTON, Navigant Consulting 

ROSS DILLON, Lawrence Berkeley National 

 Laboratory 

JEFF KLEISS, Lochinvar, LLC 

ALEX LEKOV, Lawrence Berkeley National 

Laboratory 

JOANNA MAUER, Appliance Standards Awareness 

 Project 

CATHERINE RIVEST, Navigant Consulting 

HARVEY SACHS, American Council for an Energy 

 -Efficient Economy 

FRANK STANONIK, Air-Conditioning, Heating, and 

 Refrigeration Institute 

PHILLIP STEPHENS, Heat Transfer Products, Inc. 

MEG WALTNER, Natural Resources Defense Council 
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 TABLE OF CONTENTS 

Welcome, Introductions and Agenda Review 4 

Introduction, Opening Remarks from Interested 

 Parties, Regulatory History, and 

 Rulemaking Overview 5 

Determination of Scope and Test Procedures 16 

Market Assessment and Screening Analysis 30 

Technology Assessment 36 

Screening Analysis 44 

Engineering Analysis 49 

Markup Analysis and Energy Use Analysis 58 

Energy Use Analysis 58 

Life-cycle Costs and Payback Period 

 Analysis 81 

Shipments Analysis and National Impact 

 Analysis 99 

Consumer Subgroup Analysis 107 

Manufacturer Impact Analysis 109 

Emissions Analysis; Utility Impact 

 Analysis; Employment Impact 

 Analysis; Regulatory Impact Analysis 

 114 

Other Issues and Comments; Closing 

 Remarks 119 

Adjourn 
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1 P-R-O-C-E-E-D-I-N-G-S 

2 9:47 a.m. 

3 MR. BROOKMAN: So as we resume, 

4 this is a separate meeting that is -- this is 

5 a meeting that is a continuation, but we have 

6 a separate transcript. This will be like 

7 starting a new meeting. 

8 Good morning again and welcome to 

9 the U.S. Department of Energy's public meeting 

10 on Boilers and Energy Conservation Standards 

11 for Residential Boilers. Today is Wednesday, 

12 March 13, 2013 here in the Forrestal Building 

13 at the Department of Energy. 

14 My name is Doug Brookman from 

15 Public Solutions. We've already done 

16 introductions around the room. I think that 

17 you are the only one who didn't get a chance 

18 to introduce yourself. Do you want to say 

19 your name, please? 

20 MR. BUSSE: John Busse, U.S. 

21 Boiler Company. I was in the back at the 

22 time. 
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1 MR. BROOKMAN: Thanks. We're 

2 going to start off this morning with welcoming 

3 remarks and perhaps move straight into the 

4 content with John Cymbalsky. 

5 MR. CYMBALSKY: Sure. Thanks, 

6 Doug. Hi, I'm John Cymbalsky. As I mentioned 

7 earlier, I am the program manager for Codes 

8 and Standards and I'm doing double duty today. 

9 I'm also the acting product manager for 

10 Residential Boilers, a product I have very 

11 limited knowledge about, but actually had one 

12 in my house growing up in New York, so I do 

13 know a little bit about them. 

14 We're going to try to go quickly 

15 through some of these introductory slides 

16 because they were covered -- 

17 MR. SACHS: John, excuse me, was 

18 that a one-pipe steam boiler? 

19 (Laughter.) 

20 MR. CYMBALSKY: No, no, it wasn't. 

21 It was very, very warm though. Kept the 

22 house very warm. 
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1 Okay, so these are the 

2 housekeeping items. I don't think we need to 

3 go through these again, so I'm just going to 

4 skip right to the content. 

5 For those of you on the webcast, 

6 welcome, thank you for joining us via the web. 

7 Hopefully, the audio problems that we've been 

8 experiencing intermittently will have gone 

9 away for this part of the presentation. 

10 Again, written comments are always 

11 helpful to the Department. I know we all want 

12 to make oral statements as well, but if you 

13 can back that up with written comments, that 

14 will help us in drafting the next phase of the 

15 rule here. 

16 The purpose of this public meeting 

17 today is to present the framework document for 

18 residential boilers. We invite comments on 

19 all aspects of this framework document. And 

20 again, submit any data information in writing 

21 to the Department. 

22 Throughout the presentation, 
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1 you'll see these yellow comment boxes. At 

2 that time we will open the floor and request 

3 comment on the issues that we feel most 

4 important in the framework document. Deadline 

5 for submitting comments for the framework is 

6 March 28, 2013. 

7 At this time, I'll open the floor 

8 for any opening remarks on the boilers 

9 framework document. 

10 MR. BROOKMAN: Frank Stanonik. 

11 MR. STANONIK: Well, I'm not sure 

12 it's an opening remark as much as maybe a 

13 general question. The framework document, 

14 let's say, certainly follows a well15 established pattern that DOE has been using 

16 now for some years to do standard rulemakings. 

17 And we did have a residential boiler standard 

18 rulemaking that was finalized in 2007, 

19 subsequently changed because of legislation, 

20 but it was finalized in 2007. And without 

21 having the exact date, there was an analysis 

22 of residential boiler standards, let's say, 
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1 around 2004 or so. 

2 On the one hand, okay, that's 

3 eight, nine years later. But on the other 

4 hand, certain aspects of residential boilers 

5 are still there. So I guess my question is I 

6 understand the need to fully detail what the 

7 framework document with the analysis we'll 

8 look at, but the question is will DOE in doing 

9 this, will they, where appropriate, will they 

10 be using any of the information that was 

11 developed and considered back in previous 

12 ones? 

13 MR. CYMBALSKY: Sure. John 

14 Cymbalsky, DOE. Yes, we'll try to leverage as 

15 much as possible on past analyses. And as you 

16 mentioned, we're nine years past some of the 

17 work that's been done in the past. So to the 

18 extent we need to refresh any information, any 

19 data in the analysis, obviously we want the 

20 latest data that everybody has to make the 

21 analysis as current as possible. 

22 MR. STANONIK: Just to explain, 
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1 the reason it's important to us is because 

2 some of us actually still have those TSDs. In 

3 some cases, I'll remark by simply saying okay, 

4 you know, in the previous analysis you ruled 

5 out certain technologies and we may encourage 

6 you to do that again or whatever. 

7 MR. CYMBALSKY: Okay. 

8 MR. STANONIK: It's nice. We will 

9 refer to it where we can and where it's 

10 appropriate. Thank you. 

11 MR. CYMBALSKY: We'd appreciate 

12 that. Thank you, Frank. 

13 MR. BROOKMAN: Thanks, Frank. 

14 Yes, Harvey Sachs. 

15 MR. SACHS: Harvey Sachs, ACEEE. 

16 I guess I respect Frank's thoughts and the 

17 efforts to minimize the burden on DOE, but we 

18 have had a couple of reasonably significant 

19 developments in the boiler field since the 

20 last analysis was done. And I'd point out, 

21 too, one of them is we really need to 

22 understand what people have done to implement 
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1 the controls required by the legislation and 

2 their economic impact, both on the cost side 

3 for manufacturers and consumers and on the 

4 energy saving side. 

5 And the second thing is, I recall 

6 no prior rulemaking or technical support 

7 document that explicitly included comparison 

8 with technologies that might be widely used 

9 outside the United States and reduced to 

10 practice. And since that legislation, we've 

11 seen activity such as the mandatory use of 

12 condensing boilers at least in England and I 

13 think all of Great Britain and they're 

14 certainly widespread in other parts of 

15 northern Europe. And to ignore that 

16 manufacturing and use experience would be to 

17 deprive American consumers of some important 

18 work that's been done and may be relevant for 

19 our own rulemaking. Thank you. 

20 MR. BROOKMAN: Thank you. 

21 MR. SACHS: I'd love to hear 

22 comments from DOE in terms of the commitment 
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1 that the TSD will reflect a little bit of 

2 international analysis this time. Hint, hint. 

3 MR. CYMBALSKY: We love data. 

4 MR. SACHS: This is important. 

5 MS. ARMSTRONG: No, I know. I 

6 understand. 

7 MR. BROOKMAN: Thanks, Harvey. 

8 MR. CYMBALSKY: We love data from 

9 all over the world, Harvey. And certainly, we 

10 will look at any data that we can get our 

11 hands on, but obviously, anything that's 

12 unique to installation of boilers in the 

13 United States, will be dealt with in the rule 

14 as well. 

15 MR. BROOKMAN: So then we'll 

16 proceed with the content. 

17 MR. CYMBALSKY: Okay, regulatory 

18 history. Adam went through this slide in the 

19 earlier part of the presentation, so I won't 

20 spend too much time on it. EPCA 1975, NAECA 

21 1987, then EISA 2007 came along, set some 

22 requirements for boilers. This rulemaking is 
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1 in accordance with the six-year look back 

2 provisions of EISA, so that's why we've 

3 undertaken this rulemaking. 

4 EISA 2007 codified in the Federal 

5 Register in July of 2008, set the minimum 

6 efficiency standards as presented on this 

7 table. Several different product classes 

8 here, but you can see the AFUEs range from 80 

9 for gas steam, up to 84 for oil hot water, and 

10 then a couple of design requirements sprinkled 

11 in based on the product class. 

12 Now the rulemaking overview. 

13 Here's our schedule that we have for 

14 presenting today for the boilers rulemaking 

15 and so today, we're here at the framework 

16 presentation, March of 2013. Our next step 

17 will be a preliminary analysis, hopefully by 

18 the end of this year. And then after that we 

19 will put a Notice of Proposed Rulemaking out 

20 for comment, hopefully next summer of 2014. 

21 And then the Final Rule in the summer of 2015, 

22 and then the five years for compliance with 
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1 the new set of standards, so July 2020. 

2 MR. BROOKMAN: Harvey Sachs. 

3 MR. SACHS: Harvey Sachs, ACEEE. 

4 As we're reviewing the chart on Slide 12, a 

5 question for general counsel. Legislation, 

6 we've referred to overturned an opinion by OGC 

7 that DOE could not require both the 

8 prescriptive and a performance standard, that 

9 is things like no standing pilot is 

10 prescriptive plus an AFUE. 

11 Is that opinion allowing both 

12 prescriptive and performance parameters going 

13 to be taken as binding on DOE going forward? 

14 MR. BROOKMAN: Eric Stas. 

15 MR. STAS: Eric Stas, DOE. I 

16 assume you're talking about the latest AEMTCA 

17 legislation, amendments to EPCA and whatever 

18 is in the statute we will follow the statutory 

19 -- the new statutory mandates. 

20 MR. SACHS: Harvey Sachs, I wasn't 

21 particularly referring to it and I'm 

22 embarrassed to say I haven't read that, but I 
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1 appreciate the commitment. 

2 MR. BROOKMAN: Thank you. I see 

3 Frank Stanonik. 

4 MR. STANONIK: Yes, I'm sorry, 

5 Frank Stanonik. Eric, I'm going to need a 

6 plain English answer. I think what Harvey was 

7 referring to is that there was legislation -- 

8 I mean what we see here as far as the 

9 automatic means and no pilot was, in fact, 

10 mandated by Congress. As Harvey mentions, it 

11 includes a combination of performance and 

12 prescriptive. And my understanding of 

13 Harvey's question is will this rulemaking 

14 consider both performance and prescriptive 

15 improvement? Because the previous DOE 

16 position which we had experience with was that 

17 DOE was restrained in the case of residential 

18 products from establishing prescriptive 

19 requirements. 

20 MR. STAS: Eric Stas, DOE. I'm 

21 trying to remember what was in the most recent 

22 AEMTCA legislation and then EPCA. I think the 
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1 design requirement discussion what I was 

2 thinking of is regarding ASHRAE products. So 

3 I'm not so sure it directly addressed this 

4 issue on the residential side. But I think 

5 it's fair to say that where Congress has -- in 

6 past instances where Congress has set design 

7 requirements and DOE subsequently updated the 

8 energy efficiency side, that the statutory 

9 design requirements have been kept in place. 

10 MR. BROOKMAN: Meg. 

11 MS. WALTNER: To follow on on 

12 that, is the Department's opinion that you 

13 have the authority to set additional design 

14 requirements or would just the existing design 

15 requirements stay in place? If you don't have 

16 an answer for that, that's okay. 

17 MR. BROOKMAN: Eric Stas. 

18 MR. STAS: We'd love your comments 

19 on that. 

20 MR. SACHS: Harvey Sachs. This is 

21 a critical issue. It was first raised by GAMA 

22 early on in pointing out that there were a 
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1 number of significant ways to save substantial 

2 amounts of energy that were not and could not 

3 be reflected in the AFUE rating method. 

4 And that these attributes 

5 reflected as prescriptive requirements were 

6 potentially of great importance to the country 

7 in a number of ways, lessening the burden on 

8 manufacturers to invest in technology was one 

9 of those. And I think it would be important 

10 to everyone in the room and in fact, it's 

11 referred to in the document handed out today 

12 that we not close that opportunity because 

13 that's where a lot of the potential for energy 

14 savings is. 

15 MR. BROOKMAN: Okay, I think we've 

16 got it now. 

17 MR. SACHS: I'll put my hammer 

18 back in its holster. Thank you. 

19 MR. BROOKMAN: John Cymbalsky. 

20 MR. CYMBALSKY: So that brings us 

21 to the slide on the EPCA seven factors. So in 

22 each of our standards rulemakings we consider 
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1 the EPCA seven factors in our DOE analysis. 

2 And so I won't read through all of them, but 

3 you can see that over the course of the 

4 rulemaking, DOE will conduct a series of 

5 analyses to address the EPCA seven factors and 

6 these range from impacts on the environment to 

7 energy savings costs, manufacturer costs, 

8 consumer savings and the like. 

9 And with that, I'm going to turn 

10 it over to Adam for the test procedure and 

11 scope discussion. 

12 MR. DARLINGTON: All right, so 

13 hello again. Adam Darlington, Navigant 

14 Consulting. I guess I'll just quickly go over 

15 this slide. We touched on a lot of it earlier 

16 this morning. But basically to reiterate the 

17 federal test procedure at Appendix N is 

18 largely based on ASHRAE Standard 103-1993. 

19 ASHRAE Standard 103-1993 accounts for the 

20 active, standby, and off mode fossil fuel 

21 energy consumption, but does not account for 

22 the standby and off mode electrical 
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1 consumption and as I noted this morning, there 

2 were some updates within the past couple of 

3 years to adopt IEC 62301 standard for the 

4 electrical consumption. 

5 And then more recently on January 

6 4, 2013, DOE published a request for 

7 information seeking comments on all aspects of 

8 the test procedure and why this is important 

9 for the standards rulemaking is because our 

10 standards obviously use the efficiency metric 

11 that comes out of the test procedure. So when 

12 we're analyzing amended AFUE, obviously we're 

13 looking at what AFUE picks up. And so it's 

14 very important for us to sort of tie that in 

15 with the test procedure rulemaking. 

16 And then for -- most recently on 

17 February 4th, DOE published the NOPR which we 

18 just discussed this morning to fix the two 

19 equations. 

20 And so moving on, we'll get into 

21 the definitions and a little bit about the 

22 scope of coverage. So residential boilers are 
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1 defined in EPCA. EPCA does contain a 

2 definition. It's contained within the 

3 definition of residential furnace. Basically, 

4 the key points of this definition that's on 

5 the slide here are that there's single-phase 

6 electric products, sorry, they can only use 

7 single-phase electric current or single-phase 

8 current in conjunction with natural gas, 

9 propane, or home heating oil. And that they 

10 are limited to a heat input rate of less than 

11 300,000 BTU per hour. 

12 And the statute, I believe, 

13 specifically calls out that electric boilers 

14 and low-pressure steam or hot water boilers 

15 are considered a residential boiler and DOE 

16 has further defined these terms in 10 CFR 

17 430.2 in DOE's definition. And these 

18 definitions are here on the slide for you to 

19 review. 

20 And so these definitions basically 

21 define what will be covered in the rulemaking, 

22 DOE's scope of authority to cover residential 
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1 boilers. So DOE's plans to cover all 

2 residential boilers within the scope of those 

3 definitions on the previous slide and as the 

4 slide that John presented showed earlier, the 

5 amendments and Energy Independence and 

6 Security Act of 2007 included standards for 

7 six product classes of residential boilers. 

8 So the product classes are broken 

9 down based on the fuel type, whether it's gas10 fired, oil-fired, or electric. And the 

11 heating medium, whether it's hot water or 

12 steam. And so tentatively, DOE is proposing 

13 to continue to utilize those six product class 

14 designations and I would just note here that 

15 DOE in the framework tentatively has, based on 

16 a preliminary review, determined that the 

17 analysis of amended AFUE standards would focus 

18 on the gas and oil-fired products and not 

19 include the electric boilers, just because 

20 there's limited AFUE improvement potential for 

21 electric boilers. And again, that's based on 

22 a preliminary review. 
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1 And DOE would look at standby and off mode 

2 standards for all six of these product 

3 classes. 

4 And then the last bullet here on 

5 the slide talks about combination appliances 

6 and so DOE at this time doesn't have any kind 

7 of separate product class or separate 

8 designation for a combination appliance, but 

9 depending as this rulemaking progresses, as 

10 the test procedure rulemaking progresses, may 

11 consider specifically defining combination 

12 appliances. 

13 That brings us to a number of 

14 issues that we'd like comment on. And so the 

15 first issue here we're looking for comment on 

16 the scope generally, you know, what's been 

17 presented on the past couple of slides about 

18 the types of boilers that we're planning to 

19 include in this analysis. 

20 Item 2 here specifically seeks 

21 input about combination appliances. And then 

22 item 5-2 asks for comment about the proposed 
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1 product classes, whether there are any 

2 capacity of performance-related features that 

3 may necessitate the creation of a new product 

4 class. And the last item, 5-3, asks basically 

5 about, you know, maybe any of these product 

6 classes that are more niche products where 

7 shipment volumes may be sufficiently low that 

8 they wouldn't warrant more stringent standards 

9 or analysis. 

10 With that, I'll turn it over to 

11 Doug. 

12 MR. BROOKMAN: Harvey Sachs. 

13 MR. SACHS: Harvey Sachs, ACEEE. 

14 I could be wrong, but it seems to me that 

15 there is a regulatory gap for two emerging 

16 products. I don't know whether the Department 

17 wants to do more than take note about it. But 

18 it seems to me that both on the air source and 

19 the ground source heat pump sides, we have 

20 units that are air to refrigerant to water and 

21 ground to refrigerant, ground to water to 

22 refrigerant to water. So they're supporting 
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1 systems whose function is quite analogous to 

2 that supported by advanced boilers. 

3 I think that a ground source 

4 procedure is en route. The air source may be 

5 more difficult since that seems to becoming 

6 more as part of integrated appliances, but it 

7 would seem worthwhile for the Department to 

8 start thinking about how to develop standards 

9 that will provide consumers with information 

10 to compare expected energy use of those 

11 products with the products covered by this 

12 rulemaking. 

13 MR. BROOKMAN: Do you have any 

14 data on shipments on those products? 

15 MR. SACHS: This is Harvey Sachs 

16 again. This is why I stressed their status as 

17 emerging products. Certainly, the integrated 

18 variable refrigerant flow units are very small 

19 shipments in the U.S. We're seeing much more 

20 interest on the ground source side in products 

21 whose heat distribution product is water 

22 rather than air, particularly for sub-slab 
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1 just for slab-based and other radiant heating 

2 systems which are becoming important in the 

3 Northeast. And at that point it's directly 

4 competing with a condensing propane or natural 

5 gas boiler. So it is, I believe, relevant for 

6 the consideration of the Department where such 

7 products should be treated to minimize 

8 industry burden and maximize utility. I'm not 

9 sure -- I really can't, I think, advertise the 

10 efficiency descriptor for this product today. 

11 MR. BROOKMAN: Frank Stanonik. 

12 No? Sorry. 

13 MR. STANONIK: Nothing at this 

14 time. 

15 MR. BROOKMAN: You can see the 

16 comment box, comments on scope of coverage, 

17 combination appliances, proposed product 

18 classes, and niche products that may not be 

19 included. 

20 Frank Stanonik. 

21 MR. STANONIK: Frank Stanonik, 

22 AHRI. I do have one question. And it's just 
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1 because I'm sure I read it and I forgot. Are 

2 you asking here for comments about including 

3 combination appliances in this rulemaking and 

4 then we also have the test procedure 

5 rulemaking going on? Which one is going to be 

6 finished first, looking at the schedule at the 

7 moment? 

8 MR. BROOKMAN: Ashley. 

9 MS. ARMSTRONG: The test 

10 procedure. This is Ashley. 

11 MR. STANONIK: Okay, so -- 

12 MS. ARMSTRONG: The test procedure 

13 will come first. 

14 MR. STANONIK: My memory says -- 

15 MS. ARMSTRONG: This analysis 

16 would be based on any amendments in that 

17 rulemaking coming out. But yes, we are asking 

18 for not just variable refrigerant flow 

19 systems, but all combination appliances and 

20 their integration into this rule or otherwise. 

21 MR. STANONIK: Then we will 

22 address the question in test procedures. 
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1 MS. ARMSTRONG: This is Ashley, 

2 and that's fine. I think the RFI period has 

3 closed for the test procedure. That's 

4 correct, right? So I don't know if you 

5 addressed it previously, but it would be good 

6 to address it as part of this rule as well, 

7 even if you just echo a point to that. 

8 Thanks. 

9 MR. BROOKMAN: Phillip and then 

10 back to Jeff. Go ahead. 

11 MR. STEPHENS: Phillip Stephens. 

12 I would just like to go on the record that HTP 

13 encourages and supports the use of combination 

14 appliances. 

15 MR. BROOKMAN: And do you want to 

16 be more specific than that? 

17 MR. STEPHENS: Sure. 

18 Specifically, water heaters, heating medium, 

19 heat pump technology and the combination 

20 thereof solar thermal also. 

21 MR. BROOKMAN: Okay. Thank you. 

22 Jeff. 
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1 MR. KLEISS: Thank you. Jeff 

2 Kleiss, Lochinvar. In response sort of to 

3 what Harvey was saying, currently, we do have 

4 electric boilers that are categorized and the 

5 heat pumps would probably come into a similar 

6 situation where there is really not a good 

7 comparative AFUE measurement. And if we do 

8 move forward with that it needs to be 

9 something that takes into account the losses 

10 in power generation of generating the 

11 electrical power, transmitting the electrical 

12 power in order to make a more fair comparison 

13 for the actual cost of operation of the 

14 appliance if we move forward on that. 

15 Second thing related to the 

16 combination boilers, we would support the idea 

17 of them being created as possibly a unique 

18 class of products for consideration. But the 

19 way that things are currently written out in 

20 the proposed 

21 rulemaking document, we support DOE's approach 

22 of getting a federal test procedure that is 
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1 specific for those products before creating 

2 them as a unique class with special 

3 consideration. 

4 MR. BROOKMAN: Thank you. 

5 Phillip. 

6 MR. STEPHENS: Yes, Phillip 

7 Stephens. To further Jeff's comment, 

8 currently only the ASHRAE 124 that I'm aware 

9 of does support the combined AFUE. This does 

10 have limits. It is recognized and the 

11 Committee has recently slightly modified the 

12 scope to address some of these. But there are 

13 large gaps we recognize. 

14 I did a rotation as one of the 

15 board of director members for the SRCC and I 

16 can say quite honestly that the DOE has 

17 withdrawn a lot of the funding. It's been 

18 reorganized into a different stream basically. 

19 And the solar thermal industry is suffering 

20 because of it. And to have some other type of 

21 recognition for the solar thermal industry 

22 would be very welcome. 
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1 MR. BROOKMAN: Okay, thank you. 

2 I'm looking at the requests in the comment 

3 boxes. It seems like we've just touched 

4 lightly on scope of coverage. We've had a 

5 couple of comments on combination. What about 

6 the product classes and what about small or 

7 niche products? 

8 No additional comments? Harvey 

9 Sachs. 

10 MR. SACHS: Harvey Sachs. There 

11 does seem to be a little bit of ambiguity. I 

12 just want to try to clarify my intent to 

13 differentiate between call it inherently 

14 limited niche products. An example might be 

15 the small diameter high velocity air 

16 conditioners that the Department has treated 

17 versus emerging technologies which have the 

18 potential to be a significant component of the 

19 industry. And although their shipments may be 

20 small, it's worth thinking about rating 

21 methods that will not handicap their 

22 acceptance. And I think that's the gist of 
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1 what my colleagues in industry have been 

2 trying to emphasize as well. 

3 MR. BROOKMAN: Okay, Frank. 

4 MR. STANONIK: Frank Stanonik, 

5 AHRI. Yes, on this question of are there some 

6 product classes that maybe should not be 

7 analyzed, I think certainly leveraging the 

8 market for residential steam boilers by no 

9 means has grown and that certainly might be an 

10 area where there is no need to expend 

11 significant resources to analyze a product 

12 that is clearly a replacement product and not 

13 a significant segment of the market. 

14 MR. BROOKMAN: Thank you. Okay, 

15 final comments on this section? 

16 MR. DARLINGTON: And with that, 

17 I'm going to turn it over to Catherine. She's 

18 going to take you guys through the initial 

19 steps of the preliminary analysis. 

20 MS. RIVEST: Thank you, Adam. 

21 Again, I'm Catherine Rivest from Navigant 

22 Consulting and I'll be going over the steps of 
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1 the preliminary analysis. So I'll be going 

2 over the three upstream analyses that include 

3 the market and technology assessment, the 

4 screening analysis, and the engineering 

5 analysis which will culminate in the energy 

6 efficiency relationship that will feed into 

7 the rest of the analyses. 

8 I'll be starting off with the 

9 market and technology assessment where we try 

10 to describe the market as well as come up with 

11 measures that improve boiler efficiency. And 

12 DOE does this by identifying and 

13 characterizing manufacturers of residential 

14 boilers, as well as getting data on the 

15 historical shipments and the trends in the 

16 market. 

17 DOE also looks at regulatory and 

18 non-regulatory programs like Energy Star. And 

19 DOE looks at databases to try and see what the 

20 market saturation is of certain efficiency 

21 levels of boilers. And in the technology 

22 assessment, DOE identifies the technologies 
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1 that could improve efficiency. 

2 At this point, DOE casts a really 

3 wide net and tries to just find any technology 

4 regardless of the stages, whether it's in 

5 commercial products or in a prototype or in 

6 the research stage. So at this time I'll open 

7 up the floor to this comment, item 5-1, DOE 

8 welcomes data that would contribute to the 

9 market and technology assessment, including 

10 but not limited to national historical 

11 shipments, manufacturing costs, distribution 

12 channels and manufacturer market share. 

13 MR. BROOKMAN: Harvey Sachs. 

14 MR. SACHS: Was DOE represented or 

15 able to send one of its contractors to the ISH 

16 Conference and trade show this spring which is 

17 probably the world's largest center for the 

18 display of emerging technologies in this 

19 particular field of boilers? 

20 MR. BROOKMAN: Thank you. ISH? 

21 MR. CYMBALSKY: If you want to 

22 discuss international travel, so yeah, that's 
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1 a little difficult at the time. 

2 MR. SACHS: We would be pleased to 

3 provide letters of support for having DOE 

4 represented at next year's ISH and I suspect 

5 the manufacturers would as well. Correction, 

6 it's biannual. 

7 MR. BROOKMAN: Okay, that's good 

8 to know. 

9 Frank Stanonik. 

10 MR. STANONIK: Well, on this 

11 particular item clearly GAMA and AHRI has 

12 collected shipment statistics on residential 

13 boilers and at this point I can certainly say 

14 to the extent that our members will allow us, 

15 we will share that information with DOE and to 

16 whatever level of detail they are willing to 

17 help us give to you. 

18 MR. BROOKMAN: Thank you. 

19 MR. SACHS: Harvey Sachs again. 

20 I'm sorry, there's one more element in the 

21 analysis which will be important for oil-fired 

22 equipment. And that is -- I want to put into 
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1 the record the need to consider the work of 

2 Dr. Thomas Butcher at Brookhaven National Lab 

3 who has established to my satisfaction, at 

4 least, that corrosion and annual maintenance 

5 don't look like they're problems with boilers 

6 that are used only with ultra-low sulfur fuel. 

7 That's mandated now for over-the-road 

8 vehicles, diesel, and it's mandated by law for 

9 residential boilers in New York State. That 

10 change also opens up the door for some 

11 technology changes that will make it more 

12 feasible to do condensing oil and it will be 

13 very important for the technical support 

14 document to consider that as one pathway. I'm 

15 not sure how the economics work, but it should 

16 not be left on the cutting room floor. 

17 MR. CYMBALSKY: John Cymbalsky, 

18 DOE. Do you know if any other states, 

19 particularly in the Northeast, will adopt that 

20 standard for the low-sulfur fuel? 

21 MR. SACHS: I don't track that. 

22 David Lis from NEEP may or may not be on this 
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1 call and we can certainly check in with them 

2 and I'm happy to do that. 

3 MR. BROOKMAN: Thanks, Harvey. 

4 John. 

5 MR. BUSSE: John Busse, U.S. 

6 Boiler Company. I believe Massachusetts and 

7 Connecticut also had similar legislation. My 

8 understanding was they were sort of binding on 

9 one another. They all had to agree to similar 

10 standards so that the distribution channel 

11 would be maintained properly. 

12 MR. BROOKMAN: Thank you. Other -

13 - so Frank, you pretty much got the data that 

14 the Department is looking for here. Is that 

15 correct? 

16 MR. STANONIK: Well, just the 

17 first one. Historical shipments. 

18 MR. BROOKMAN: Hopeful comment. 

19 MR. STANONIK: We do not collect 

20 the manufacturing costs. We really aren't 

21 involved in distribution channels and I could 

22 probably give market share ones and then lose 
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1 my job. 

2 (Laughter.) 

3 That's not going to happen. 

4 MR. CYMBALSKY: You're not 

5 retiring any time soon? 

6 MR. BROOKMAN: Okay, we're moving 

7 on. 

8 MS. RIVEST: Okay, great. So 

9 moving on to the technology assessment. Here, 

10 we've listed the technology options that we've 

11 identified in the framework document. So many 

12 of these technologies were drawn from previous 

13 rulemakings. We've also listed technologies 

14 to improve the standby and off-mode power 

15 consumption and framework document describes 

16 these technologies in greater detail. 

17 So I'll open up the floor for 

18 comments on these technologies. 

19 MR. BROOKMAN: Yes, Jeff. 

20 MR. KLEISS: Jeff Kleiss, 

21 Lochinvar. While I have some hope and support 

22 the idea of off cycle loss regulation on the 
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1 standby mode regulation, I think that DOE 

2 needs to consider that within the current AFUE 

3 calculation, the jacket losses for the boiler 

4 are not considered in the calculation. The 

5 reason for that is that boilers are installed 

6 inside of houses, almost exclusively. So any 

7 residual heat that is shed by the appliance is 

8 considered to be useful heat within the 

9 envelope of the building. And that's why this 

10 jacket-loss factor applied, zero within the 

11 AFUE calculation, is used here. 

12 Standby mode losses, any kind of 

13 electric power consumption is going to end up 

14 being converted into heat which is going to be 

15 a similar, not truly a loss, but it's going to 

16 be heat that's going to be released into the 

17 environment. Now an off-mode loss certainly 

18 could happen while you're in a cooling mode 

19 for a home. But standby loss during heating 

20 season really should not be considered as a 

21 loss. And so that's one factor that I think 

22 should be considered in this. 
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1 The second thing is that with the 

2 power consumption that's being used for these 

3 heating appliances, the electrical power 

4 consumption is a very, very small factor for 

5 the appliances. And I'll be providing some 

6 written comments that have an example. Right 

7 now, I can just say that what I calculated as 

8 an average is probably .15 percent of the 

9 power. 

10 MR. BROOKMAN: Point 15. 

11 MR. KLEISS: Point 15. Just in my 

12 general calculation. And the third point here 

13 is that some of the technology that's 

14 suggested here certainly would add costs to 

15 the appliance and in addition to that has the 

16 potential to create additional maintenance 

17 problems. In particular, switching the power 

18 mode off to the blower motors that consume 

19 power in the standby mode, the primary 

20 manufacturer of those blowers that are used in 

21 the U.S. has recommended against that that it 

22 could damage the blower. 
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1 Now we might be saving a very 

2 small electrical power consumption that's 

3 actually adding heat to the envelope and as a 

4 result, damaging a rather expensive component 

5 that's going to require a qualified technician 

6 to do a replacement on it. So there's -- the 

7 standby electrical power consumption is 

8 something that I strongly encourage DOE to 

9 remove from the table for boilers. 

10 MR. BROOKMAN: Frank. 

11 MR. STANONIK: Well, I can't pass 

12 this one up. This is an example, I guess, of 

13 my initial comment about using analysis from 

14 the past. Again, technology options that 

15 you're listing, pulse combustion, granted, 

16 it's a unique technology, but its end result 

17 is simply to create a condensing appliance. 

18 In terms of looking at let's just say the 

19 option of creating a condensing appliance, I 

20 don't think DOE needs, as they go forward here 

21 to continue to consider pulse combustion as a 

22 unique technology out there. 
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1 Granted, again, I agree. It's a 

2 unique technology. I just don't think in 

3 terms of where products have evolved it needs 

4 to be considered as a separate unique -- if it 

5 evolved and DOE is going to push things 

6 towards condensing, then you know, I can't 

7 envision DOE is going to say we're going to 

8 create a condensing rule where everything has 

9 to be pulse combustion. They're going to 

10 create a condensing rule where everything has 

11 to -- how will you get there? So I just think 

12 that one, you know, my own opinion, should 

13 just be removed from the list. It's just not 

14 -- maybe whenever it was developed years ago 

15 was worth consideration, but today, I don't 

16 think that's the case. 

17 MR. BROOKMAN: Speak up, Frank. 

18 MR. STANONIK: We thought that 

19 last one -- 

20 MR. BROOKMAN: You're not on. 

21 Thank you. 

22 MR. STEPHENS: Thank you, Phillip 
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1 Stephens. We'd like to go on record 

2 supporting the previous comments from 

3 Lochinvar and AHRI and also noting that the 

4 section, the current section in the ASHRAE 103 

5 test method to prove the draft, the tracer gas 

6 method, is horribly written and very difficult 

7 to understand and to implement. You are by 

8 default inducing a vacuum, as you're trying to 

9 measure for carbon monoxide and you're 

10 inducing a flow by injecting carbon monoxide 

11 into the system. It's a very difficult test. 

12 MR. BROOKMAN: John, you want to 

13 comment here? 

14 MR. BUSSE: John Busse. No 

15 additional comments other than we do support 

16 the previous comments from Jeff and -- 

17 MR. BROOKMAN: Harvey Sachs. 

18 MR. SACHS: Harvey Sachs, ACEEE. 

19 The standby and off-mode criteria or 

20 parameters are prescribed in EISA, as I 

21 recall, but it's a legislative requirement. 

22 The question, given the relatively small 
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1 amounts of energy asserted by Jeff and Phillip 

2 is whether the Department would consider 

3 default values that are representative as 

4 being acceptable in lieu of testing. 

5 MR. BROOKMAN: Thank you. Final 

6 comments on this section? 

7 MR. SACHS: So what's the 

8 question, whether they would consider? 

9 MS. ARMSTRONG: This is Ashley 

10 from the Department. I don't think we have a 

11 definitive answer to that. I think we could 

12 always consider default by use to reduce test 

13 burden. We would need data on what a 

14 representative default value would be or 

15 different default values for different models, 

16 characteristics of standby and off, etcetera. 

17 But yes. 

18 MR. SACHS: For the record, I 

19 think we would be willing to work with 

20 industry in supporting that if a rational 

21 program would be less burdensome than testing 

22 each product, could be arranged. 
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1 MR. BROOKMAN: Thank you. 

2 MR. SACHS: That's not a promise, 

3 but we're certainly all ears. 

4 MR. BROOKMAN: John. 

5 MR. BUSSE: John Busse. A little 

6 bit off the cuff here, having run some of the 

7 electrical standby loss tests a year ago, it 

8 is from our standpoint it was an extremely 

9 burdensome process. It requires much more 

10 precision than anything else as far as the 

11 boiler test procedure and as Jeff noted, it is 

12 a very small percentage of the actual energy 

13 consumption. 

14 The equipment, I believe, was 

15 expensive, and it just -- in some cases we 

16 could not get a valid result because it was 

17 measuring things in terms of the electrical 

18 supply that we had no control over and in many 

19 cases we had tests that were not valid. They 

20 did not meet the electrical test standard. So 

21 again, it was significantly more burdensome 

22 than running an AFUE test where you're 
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1 measuring fuel and water quantities. 

2 MR. BROOKMAN: Thank you. 

3 MS. RIVEST: Great, so we'll move 

4 on to the screening analysis. So the purpose 

5 of the screening analysis is to rule out 

6 technologies -- I'm sorry, the purpose of the 

7 screening analysis is to focus the analysis on 

8 technologies that are viable. So the four 

9 screening criteria that DOE uses are 

10 technological feasibility. So a technology is 

11 considered feasible if it's been demonstrated 

12 in a working prototype or in a commercial 

13 product. 

14 DOE also looks at practicability 

15 to manufacture, install, and service. So if 

16 the technology can be produced, can be mass 

17 produced and installed and serviced to a great 

18 enough extent to meet the market demands, then 

19 it would be considered practicable to install, 

20 to manufacture, install and service. 

21 DOE also looks at adverse effects 

22 on product utility and adverse effects on 
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1 health and safety. 

2 Opening up the floor to comment, 

3 for item 6-1, of any of the technologies 

4 listed in the previous slide, are there any 

5 that should be screened out because of the 

6 criteria mentioned on this slide? And if so, 

7 which criteria apply? 

8 MR. BROOKMAN: Harvey Sachs. 

9 MR. SACHS: Harvey Sachs, ACEEE. 

10 With respect to technological feasibility and 

11 considering the globalization of supply 

12 chains, it would seem pretty obvious that 

13 anything that is available commercially and 

14 from say two or more manufacturers in the 

15 global market would be considered 

16 technologically feasible. And therefore, 

17 there is a burden on DOE to look at what's 

18 available in the global market as that which 

19 is required to demonstrate that something is 

20 not technologically feasible. 

21 MS. RIVEST: Thank you. 

22 MR. BROOKMAN: Jeff. 
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1 MR. KLEISS: Jeff Kleiss, 

2 Lochinvar. Per my previous comments, in terms 

3 of boilers with the BPM motors, the controller 

4 relay models, that would have an adverse 

5 effect on the product utility. 

6 MS. RIVEST: Thank you. 

7 MR. BROOKMAN: Additional comments 

8 on these screening factors? John. 

9 MR. BUSSE: John Busse. In the 

10 case of pulse combustion, I think that should 

11 probably be screened out. The first boiler 

12 that I'm aware of came out in 1963 out of 

13 Canada, Green Steel Hydronics. They built 450 

14 of them. And discontinued. Other 

15 manufacturers have used pulse and some of them 

16 have dropped it, if not all of them. 

17 The technology has been there. 

18 It's been analyzed by several people and it's 

19 really not being used at this point. So I 

20 would not spend any time on that. 

21 MR. BROOKMAN: Why is it not being 

22 used? 
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1 MR. BUSSE: I don't know the 

2 factors involved with that. One manufacturer, 

3 I heard third or fourth party, there was a 

4 reliability issue with both the heat exchanger 

5 and other things. Generally, they are noisier 

6 because they have a 60-cycle hum associated 

7 with them. That was the normal operating 

8 frequency. And so issues such as that. And 

9 in some cases, it just did not fit into the 

10 true manufacturing scheme of the company 

11 because they were more complicated to 

12 manufacture as a heat exchanger. 

13 MR. BROOKMAN: Jim, did you have -

14 - that covers it? Okay. Frank Stanonik. 

15 MR. STANONIK: I've been mulling -

16 - Frank Stanonik, AHRI. I've been mulling 

17 Harvey's comment a little bit and looking at 

18 what, let's say, DOE has to do in doing this 

19 analysis. I guess I just would put some 

20 caution on the concept of looking at what's 

21 available internationally. Certainly, there 

22 is some validity to saying that some 
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1 technology that may be employed in some other 

2 country in the world is technically feasible, 

3 obviously, if it is being employed, it is. 

4 But that of itself, I think, 

5 doesn't necessarily mean it needs to be 

6 considered in the analysis. Markets are 

7 unique and I'm not talking about relative to 

8 the sale of things, but in terms of the 

9 distribution, the support, if you will, the 

10 installation, all of the things that go into 

11 making sure that the consumer gets a properly 

12 installed and properly operating equipment. 

13 And in some cases, it may be a factor that a 

14 technology that may be popular wherever and 

15 again, clearly would be technically feasible, 

16 comes with -- would come with a whole host of 

17 problems because there would be no familiarity 

18 with it in the United States. 

19 And so I understand what Harvey is 

20 saying, but I'm certainly not -- I don't think 

21 DOE should necessarily just look at every 

22 technology that's being used some place and 
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1 say well, we have to consider these. There 

2 are other factors. 

3 And the other point is that, in 

4 fact, in several products that are in the U.S. 

5 market, the manufacturers already are 

6 embracing or incorporating technologies that 

7 have been developed in other parts of the 

8 world. And so I guess I'm going to go out on 

9 a limb a little bit and say if DOE focuses on 

10 technologies of products that are in the 

11 market in the U.S., they in fact, will to some 

12 degree actually look at foreign technologies. 

13 MR. BROOKMAN: Okay. Thank you. 

14 MS. RIVEST: Okay, great. So 

15 next, we'll move on to engineering analysis. 

16 So the purpose of the engineering analysis is 

17 to determine the relationship between 

18 efficiency level and manufacturers' selling 

19 price. So DOE will determine the cost 

20 efficiency relationship by eliminating -- I'm 

21 sorry, by estimating the increase in 

22 manufacturers' selling price with technology 
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1 changes that increase the efficiency of the 

2 boilers relative to a baseline model. 

3 So the relationship between price 

4 and efficiency feeds into further analyze 

5 including the life-cycle cost analysis, the 

6 manufacturer impact analysis, and the 

7 employment impact analysis. DOE will develop 

8 separate engineering analysis for each product 

9 class considered in this rulemaking and DOE 

10 intends to use boiler tear-downs and 

11 efficiency tests to develop cost efficiency 

12 relationships for the boilers analyzed. 

13 So as I previously mentioned, DOE 

14 proposes to perform the engineering analysis 

15 by testing and tearing down commercially16 available products. This graphic gives an 

17 idea of the process DOE plans to use to go 

18 through and develop the cost efficiency curves 

19 so it would be in the product. To begin the 

20 process, DOE will identify baseline models for 

21 each product analyzed which will serve as a 

22 reference point against which DOE can measure 
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1 changes resulting from energy efficiency 

2 improvements. 

3 The baseline model lists the most 

4 common, least efficient product that just 

5 meets the current energy conservation 

6 standard. So after the baseline models are 

7 described and defined, DOE will select 

8 efficiency levels between the baseline and the 

9 max-tech, based on the information obtained in 

10 the market and technology assessment. 

11 And then DOE will generate a bill 

12 of materials by disassembling each boiler 

13 across various manufacturers spanning the 

14 range of efficiency levels. And finally, DOE 

15 will develop a cost model to convert the bill 

16 of materials into manufacturer costs. 

17 So we have a list of questions 

18 here. Item 7-1, seeks input regarding the 

19 range of efficiency levels and any key 

20 efficiency levels that should be examined as 

21 part of the analysis for each product class. 

22 And for Item 7-2 is regarding the 
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1 appropriate max-tech for each product class 

2 for residential boilers. 

3 Item 7-3 seeks input on the 

4 representative capacity and other 

5 representative characteristics for each 

6 residential boiler product class. 

7 And finally, Item 7-4, DOE seeks 

8 input on characteristics which might require 

9 multiple representative products within a 

10 single product class. 

11 MR. BROOKMAN: Harvey Sachs. 

12 MR. SACHS: This is not a new 

13 issue and DOE has, in part -- Harvey Sachs, 

14 ACEEE. In part, has attempted to address it 

15 downstream in the life-cycle cost analysis. 

16 But referring back to the figure on the left 

17 of Slide 27 and all the mechanisms -- Slide 

18 27. 

19 MS. RIVEST: This is not 27? 

20 Okay. 

21 MR. SACHS: There's pretty good 

22 literature now that these static analyses do 
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1 not reflect what happens in the general case 

2 when DOE adopts new standards, that 

3 manufacturers are concerned with performance 

4 to meet the standards, and have shown 

5 themselves to be extremely creative in finding 

6 ways to reduce costs and this is why we get 

7 into the shift type scenario considerations. 

8 This is a static view and is not a dynamic 

9 view that reflects the historical pattern of 

10 responses to standards. And somehow, DOE has 

11 got to figure this out. 

12 Now there may be less of an effect 

13 for relatively low-volume boilers than there 

14 is for large-volume air conditioners and heat 

15 pumps where there have been major investments 

16 in revitalizing the manufacturing process. 

17 But I guess on some level I'm just tired of 

18 staring at a diagram that we all know does not 

19 reflect what happens in the actual world of 

20 manufacturing and marketing products. End of 

21 rant. 

22 MS. RIVEST: Thank you. 
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1 MR. BROOKMAN: John, comments 

2 here. 

3 MR. BUSSE: Yes, John Busse. In 

4 terms of the engineering analysis or final 

5 analysis, what about installed cost and 

6 maintenance cost? Where does that fit into 

7 the equations because they are very -- they 

8 can be dramatically different based on the 

9 efficiency range of the product. 

10 MS. RIVEST: So go ahead -- 

11 MS. ARMSTRONG: They will be added 

12 -- so we characterize them as part of the 

13 life-cycle cost analysis. This is just the 

14 cost all the way through the manufacturer 

15 selling the product and then distribution 

16 chain and subsequent installation and/or 

17 maintenance or repair over the life of the 

18 product will be added as part of the next. 

19 And I think Ross is going to talk about that. 

20 MR. BROOKMAN: Frank. 

21 MR. STANONIK: With regard to -- 

22 Frank Stanonik, AHRI. With regard to item 7-
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1 1, and again, this is another one of these 

2 issues that is let's say constant whenever 

3 we're looking at rulemaking on combustion 

4 equipment. There's been significant 

5 discussions that clearly establish that you 

6 have a certain ceiling when you're dealing 

7 with products that are non-condensing and then 

8 when you get to condensing you enter a 

9 different range of efficiency levels. I would 

10 just encourage DOE and I will certainly go 

11 back and look at our records to use -- again, 

12 leverage the information that existed before 

13 that in terms of residential boilers there is 

14 a practical limit on how far you can take the 

15 efficiency of a non-condensing boiler. And 

16 there's a certain zone where the industry 

17 really for a variety of reasons mostly related 

18 to safety, unwilling to enter even though 

19 again it could be technically done. So 

20 there's this gap and then you jump to 

21 condensing. 

22 So there's two ranges, I think 
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1 that need to be looked at. I would just 

2 encourage DOE to look at -- at least start 

3 from where we've been before. 

4 MR. BROOKMAN: Ashley Armstrong. 

5 MS. ARMSTRONG: So this is Ashley 

6 from DOE. Frank, I think it's correct to say 

7 we typically do start from where we left off. 

8 In this case though I have a specific 

9 question for you. And I guess I wonder -- I 

10 realize that there's a safety range and I'm 

11 wondering what that landscape or how that 

12 landscape may change given the test procedure 

13 meeting and the shift from this morning. So I 

14 encourage you to address that as part of your 

15 comments, when we are now going to see, you 

16 know, that middle level condensing or at least 

17 some of that falls down a little bit. 

18 MR. BROOKMAN: Okay. Several 

19 questions here in the comment boxes. Please 

20 take a peek. Additional comments on these? 

21 Jeff? 

22 MR. KLEISS: Jeff Kleiss, 
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1 Lochinvar. In response to Item 7-2, DOE seeks 

2 comment on appropriate maximum technologically 

3 feasible efficiency levels for residential 

4 boilers. We would encourage the DOE while 

5 considering max-tech levels that as much as 

6 possible they look at proven technologies, 

7 things that we have been working to move into 

8 condensing boilers. There's a variety of 

9 different types of combustion. And there are 

10 a number of technologies that have failed. 

11 And would want to make sure that something 

12 that truly will be feasible in the long run 

13 and not create an unsustainable product would 

14 be what would be considered. 

15 MR. BROOKMAN: Okay. 

16 MR. KLEISS: Second item, Item 7-

17 4, unless I need to stop for a response? 

18 MR. BROOKMAN: No. 

19 MR. KLEISS: Okay, just some of 

20 the DOE seeks input on characteristics which 

21 may require multiple representative products 

22 within a single product class. Some of the 
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1 characteristics that would be I think suitable 

2 to consider would be heat exchanger material 

3 of construction. And I'll provide -- through 

4 AHRI, we'll provide written comments on these. 

5 But stainless steel, copper, aluminum, cast 

6 iron, all those different materials bring with 

7 them certain limitations and advantages. And 

8 then different types of heat exchange 

9 construction, be it single piece, mechanically 

10 assembled, welded. But those will be provided 

11 in written comment. 

12 MR. BROOKMAN: Thank you. 

13 Additional comments? 

14 MS. RIVEST: Great, then I'll pass 

15 it off to Ross and he'll go over the markup 

16 analysis. 

17 MR. DILLON: Good morning, Ross 

18 Dillon. And I'm from Lawrence Berkeley 

19 National Laboratory. 

20 Next, we'll be talking about the 

21 markups and energy use analysis which feed 

22 into the life-cycle cost and payback period 
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1 analysis that will be discussed in greater 

2 detail later on. 

3 The markups analysis intends to 

4 characterize how products are distributed from 

5 the manufacturer to the consumer and to 

6 determine the prices paid by consumers for 

7 baseline and higher efficiency products. 

8 Markups analysis approach consists 

9 of identifying and characterizing the 

10 distribution channels and applying an 

11 estimated markup price for each step. For 

12 residential boilers, two distribution channels 

13 have been identified, as you can see on the 

14 board. One for replacements, number one; and 

15 one for new construction, diagram 2. 

16 These diagrams describe how most 

17 residential boilers pass from the 

18 manufacturers to the consumers. For the first 

19 distribution channel, you'll see that -- 

20 sorry, for the first distribution channel, 

21 you'll see that replacement distribution 

22 channel, the manufacturer generally sells 
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1 equipment to the wholesaler and then, in turn, 

2 sells it to the mechanical contractor and then 

3 on to the end consumer, the end user. The 

4 second distribution channel for new 

5 construction adds in the general constructor. 

6 On to the comments, DOE seeks 

7 input on future residential boiler retail 

8 pricing. 

9 MR. BROOKMAN: No comments at this 

10 time. Understandable. 

11 MR. DILLON: The next section 

12 that we'll be reviewing is the energy use 

13 analysis. The outputs of this analysis will 

14 be applied to analyses that we'll discuss 

15 later on in the presentation. 

16 The energy use analysis is used to 

17 determine the annual energy consumption of 

18 residential boilers for representative U.S. 

19 homes. The annual energy consumption will be 

20 estimated at specified energy efficiency 

21 levels across a range of climate zones. The 

22 approach for the energy use analysis involves 
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1 deriving a distribution of boiler operating 

2 hours for the household sample using the RECS 

3 2009 survey by Section and Census Division. 

4 To support the development of this 

5 analysis, DOE intends to utilize EIA's RECS 

6 database for the majority of the data needs 

7 supplemented where necessary by available 

8 information. 

9 DOE welcomes comments 9-1 through 

10 9-8. 9-1, DOE requests input regarding the 

11 use of RECS data for determining energy 

12 consumption of boilers. 9-2, DOE seeks input 

13 regarding what fraction of boilers in multiple 

14 housing units are considered commercial. 9-3, 

15 DOE seeks historical shipment-weighted boiler 

16 efficiency data between 2003 and 2011. 

17 MR. BROOKMAN: Let's just pause 

18 there for now. Frank. 

19 MR. STANONIK: Frank Stanonik, 

20 AHRI. On 9-2, we've had some discussion on it 

21 and we're puzzled as to why that matters in 

22 this analysis. If it's a large boiler that's 
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1 not covered by this rulemaking, what 

2 significance does that question have? We 

3 couldn't figure it out. 

4 So you have a multi-housing unit 

5 that has an essential boiler system and it has 

6 a boiler that's not a residential boiler, so 

7 why the question? We just couldn't understand 

8 it. 

9 MR. BROOKMAN: John Cymbalsky. 

10 MR. CYMBALSKY: I'll take a stab. 

11 My past employment at EIA, I think what 

12 they're getting at here is that some of the 

13 data may actually include these large boilers 

14 that are servicing the multi-family market and 

15 so the energy used characteristics from the 

16 number they'd get out of RECS would be based 

17 on a shared big boiler for say two multi18 family households. 

19 MR. STANONIK: I don't have a 

20 working knowledge of RECS. So it might be 

21 something that needs to be filtered out of the 

22 RECS statement. 
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1 MR. CYMBALSKY: I have a question. 

2 MR. BROOKMAN: Yes, John 

3 Cymbalsky. 

4 MR. CYMBALSKY: This is maybe for 

5 the manufacturers. So would propane versus 

6 natural gas impact the AFUE for a boiler or 

7 would they be rated roughly the same? We have 

8 had questions from manufacturers. 

9 MR. BROOKMAN: Jeff? 

10 MR. KLEISS: Jeff Kleiss with 

11 Lochinvar. We generally test just with 

12 natural gas and report with the same number 

13 for natural gas and LP. You can get a 

14 slightly different -- AFUE, you get a slightly 

15 higher with LP. But to be conservative, we 

16 typically report one number and that's also 

17 the most prevalent as far as what's sold, so 

18 natural gas. 

19 MR. BROOKMAN: It's quite close? 

20 MR. KLEISS: Relatively. 

21 MR. CYMBALSKY: Would the quality 

22 of the -- maybe quality is not the right word, 
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1 but chemical makeup of the LP can maybe be a 

2 little different from place to place? 

3 MR. BROOKMAN: Frank? 

4 MR. STANONIK: Well, yes, not just 

5 for boilers, but in general any gas-fired 

6 product if you fire with propane, because of 

7 the chemical nature of the propane, in test 

8 procedures we use today, most of them will 

9 show a little better performance. But as Jeff 

10 was saying, well, first of all, the -- I'm not 

11 sure of all of the test procedures, but again, 

12 the case of the water heater test procedure, 

13 if your input rating using propane is within 

14 ten percent of the input rating using natural 

15 gas, you can just use your test result from 

16 natural gas. 

17 And so the other part of it is 

18 that, rough numbers, one out of every ten gas19 fired appliances is propane. And so with all 

20 of the costs that come with testing 

21 certification and everything else, it just 

22 makes a lot more sense to just simply use the 
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1 option that's allowed and just rate it based 

2 on your natural gas test. The change isn't 

3 worth that -- isn't worth what would come with 

4 it to separately support that rating. 

5 MR. CYMBALSKY: I'm not suggesting 

6 you do that. I guess I'm looking to see if 

7 there was a hard and fast rule that natural 

8 gas would always have the lower rating than 

9 propane. And if that's the case, I'm 

10 perfectly happy with that. 

11 MR. BROOKMAN: Frank, please. 

12 MR. STANONIK: Frank Stanonik, 

13 AHRI. I would say that our experience 

14 certainly supports that. I've never seen, 

15 let's say, the theoretical analysis that would 

16 actually say like a geometrical proof, if you 

17 will, but clearly the experience is that is 

18 what you see. 

19 MR. BROOKMAN: And Frank, what 

20 about 9-3, historical shipment-weighted boiler 

21 efficiency data. Does AHRI have that stuff? 

22 MR. STANONIK: In 9-3, I think -- 
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1 it could be developed, but again, that's a 

2 situation where we will have to discuss with 

3 our members and determine whether they're 

4 willing to help us generate that information. 

5 It does have some confidentiality questions 

6 and issues that would need to be addressed 

7 before I could definitely tell whether we 

8 could give it to you or not. 

9 MR. BROOKMAN: Okay. Jeff, do you 

10 have a comment here? Nothing additional. 

11 Okay. 

12 MR. SACHS: Well -- 

13 MR. BROOKMAN: I missed you, 

14 Harvey. Sorry, go ahead. 

15 MR. SACHS: You missed Alex. 

16 MR. BROOKMAN: Alex, please come 

17 to the -- find a microphone. 

18 MR. LEKOV: Alex Lekov, Lawrence 

19 Berkeley National Laboratory. Just to add 

20 that the Department in the past was always 

21 willing to sign nondisclosure agreement if the 

22 industry is willing to provide any data 
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1 including this type of data. 

2 And historically, GAMA in 2003 

3 provided this data. So we have it for the 

4 period of 2003. Thank you. 

5 MR. BROOKMAN: Thank you. Harvey. 

6 MR. SACHS: Harvey Sachs, ACEEE. 

7 Frank, this is really directed to you, but 

8 it's in a sense that it might be helpful to 

9 DOE and the rest of us. I think I understand 

10 the natural gas versus propane stoichiometry. 

11 And my sense has been that's about the limit 

12 of my chemistry. My sense has been that we 

13 generally just change the orifice size to sell 

14 the product as propane instead of natural gas. 

15 If that's the case then it would seem to me 

16 that it would a good idea to allow the ratings 

17 to be converted by the stoic and the capacity 

18 and it just might be helpful to explain the 

19 differences generally seen in the propane 

20 versus product varieties in your written 

21 comments. 

22 MR. BROOKMAN: Frank. 
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1 MR. STANONIK: Frank Stanonik, 

2 AHRI. Harvey, you certainly are correct in 

3 terms of, let's say, setting up the appliance 

4 to burn propane. Obviously, the fuel on a 

5 volume basis has more than twice the energy of 

6 natural gas and so you simply, not simply, you 

7 change the orifice, but then you also have to 

8 adjust the pressure so that you're effectively 

9 getting the same energy delivery. 

10 I think the only issue with your 

11 suggestion that maybe one could just say 

12 mathematically convert or have some adjusted 

13 mathematical conversion, the only issue I 

14 would see there is that, as I mentioned, the 

15 test procedures allow that if your input 

16 rating is within X percent of your natural 

17 gas. So there's some leeway there and that 

18 would have -- that had some influence on it. 

19 And it's not always the case that the propane 

20 version will have the exact same input rating 

21 as natural gas. So I see that as really the 

22 only complication to what you are suggesting. 
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1 MR. BROOKMAN: Ross, walk us 

2 through 9-4 through 9-8. 

3 MR. DILLON: So we're going to 

4 continue on with the energy use analysis 

5 request for comments. 9-4, DOE seeks input on 

6 data sources for annual energy consumption. 

7 9-5, DOE requests input on what fraction a 

8 boiler market consists of combination boilers, 

9 space heating and water heating capabilities. 

10 9-6, DOE seeks input on the fraction of 

11 residential boilers that are used in 

12 combination of hydronic air handlers. 9-7, 

13 DOE seeks input on the fraction of residential 

14 boilers that are used in commercial 

15 applications. 9-8, DOE seeks comment on the 

16 rebound effect that may be associated with 

17 more efficient residential boilers. 

18 MR. BROOKMAN: Jeff. 

19 MR. KLEISS: Jeff Kleiss, 

20 Lochinvar. In regards to Item 9-5, DOE seeks 

21 stakeholder input on what fractions of oil22 fired and gas-fired hot water boilers are used 
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1 for space heating and domestic hot water 

2 purposes. Now I am drawing an inference that 

3 part of the purpose of gathering this data is 

4 considering the standby energy loss or the 

5 heating of hot water during hot heating season 

6 and how that could affect efficiency or losses 

7 that are associated with the product. 

8 To that end, I think it's very 

9 important that DOE segregate the data they 

10 collect on any boilers that are providing for 

11 hot water heating based on the type of boiler 

12 that's generating that hot water. It would be 

13 a very different thing as far as the standby 

14 energy loss that would be involved with a 

15 boiler that is circulating water to an 

16 indirect fired hot water storage tank versus a 

17 combination boiler that's a low-mass boiler 

18 and has a small plate and frame heat exchanger 

19 installed in it versus a large high-mass 

20 boiler that has a copper coil installed in a 

21 water way that then has to be -- the entire 

22 boiler has to be maintained at a higher 
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1 temperature. You have very different standby 

2 loss characteristics for those three products. 

3 So as you're collecting that data I would 

4 suggest that you differentiate between those 

5 three classes. 

6 MR. BROOKMAN: Thank you. Frank. 

7 MR. STANONIK: Frank Stanonik, 

8 AHRI. I actually have a little different 

9 question. As Jeff mentioned, there, in fact, 

10 are several ways to provide -- using a boiler 

11 to provide combined space heating and water 

12 heating. I just wondered if DOE had any 

13 particular set up in mind and as an example I 

14 think the first thing that comes to most 

15 people's mind is you've got the boiler and 

16 then you have what we call indirect water 

17 heater where you're simply circulating the 

18 boiler water through a coil in this separate 

19 tank that heats your domestic water. 

20 I guess the question was did DOE 

21 have a particular arrangement in mind or in 

22 fact, as Jeff mentioned, were they looking for 
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1 or intending to look at all of these varieties 

2 of how you do this multi-function approach. 

3 MR. DILLON: So during this phase 

4 of the analysis in the framework stage, we're 

5 still trying to assess the market and assess 

6 the technology. So that will come, defining 

7 that product or what that looks like will come 

8 at a later stage. 

9 MR. BROOKMAN: Thank you. Yes, 

10 Phillip. 

11 MR. STEPHENS: Phillip Stephens. 

12 We see this as a growing or an emerging 

13 market. We believe very strongly that this 

14 could become quite substantial. We have -- 

15 several manufacturers have volume water heater 

16 options, BWH options or some other 

17 nomenclature for their boiler products, so 

18 that a boiler can provide domestic hot water. 

19 Our company also has an inverse 

20 product, a storage tank water heater with a 

21 heat pack on it that also provides domestic 

22 heat. We said it's very probable. 
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1 MR. DILLON: Thank you. 

2 MR. BROOKMAN: Okay, thank you. 

3 You can see the request for comment, all five 

4 of those items. Yes, Frank. 

5 MR. STANONIK: Just a difference 

6 item here. Item 9-6, Frank Stanonik, AHRI. 

7 Item 9-6, again, that was one which caused us 

8 a little head scratching only in the sense of 

9 kind of why DOE was asking the question. 

10 We're just not really aware that boilers use -

11 - maybe I guess the question is what was DOE 

12 intending or what were they meaning by 

13 hydronic air handlers? We don't really see 

14 that as a significant part of the residential 

15 market. 

16 I guess my question was to kind of 

17 make sure we're talking about the same thing, 

18 I guess, is what were they -- how are they 

19 describing hydronic air handler? 

20 MR. BROOKMAN: Alex Lekov. 

21 MR. LEKOV: Alex Lekov, Lawrence 

22 Berkeley National Laboratory. So this request 
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1 for comment is primarily to help with economic 

2 analysis where we are trying to assess the 

3 actual energy used by the boiler for different 

4 applications. So hydronic air handlers is one 

5 of those applications. Maybe the difference 

6 comes as a result of the written temperature 

7 associated with this, with different 

8 application resulting in different energy use. 

9 MR. STANONIK: I guess, Alex, what 

10 I'm asking this hydronic air handler, what is 

11 this product, in the mind of the analyzers, 

12 what does this product look like? If we're 

13 talking about a water heater heating space, 

14 okay, I know that's a very common system. You 

15 take the water from the water heater, run it 

16 in the coil in an air handler and you 

17 basically have space heating. 

18 Are you talking about that version 

19 of a product where the water is coming from a 

20 boiler or are you talking about a product in 

21 some cases -- well, it's there. I don't know 

22 how much it's a player in the market, but 
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1 something that used to be called a kickspace 

2 heater or something where again, you're taking 

3 boiler water to this unit that transfers the 

4 heat to air, but it's different than a 

5 baseboard, right? 

6 So I guess my question again, so 

7 we can respond to the question, we need to 

8 understand what are you envisioning? What 

9 does this hydronic air handler look like? 

10 MR. BROOKMAN: Alex, please. 

11 MR. LEKOV: Alex Lekov, Lawrence 

12 Berkeley National Laboratory. The product 

13 there -- there are quite a few products out 

14 there that receive hot water from different 

15 sources. So in this case, the boiler is meant 

16 to represent an energy source. So similarly 

17 like in some cases, the water is provided by a 

18 water heater. That's it. 

19 MR. BROOKMAN: Okay, John. 

20 MR. CYMBALSKY: I have a question 

21 for Phillip. 

22 MR. BROOKMAN: John Cymbalsky. 
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1 MR. CYMBALSKY: The water heater 

2 that you mentioned that provided heat, what 

3 gallon capacity do you generally supply those 

4 in? 

5 MR. STEPHENS: If memory serves, 

6 that one is 55, 60, and 80. 

7 MR. CYMBALSKY: Thank you. 

8 MR. BROOKMAN: John, please. 

9 MR. BUSSE: John Busse. I do 

10 recall in the past and possibly still present 

11 in the current time that there have been 

12 products offered by manufacturers that 

13 supplemented their boiler with a coil that fit 

14 into a ductwork so you could retrofit to a 

15 furnace, but then you could also add an 

16 indirect water heater or you could add a 

17 hydronic loop. So you could actually have 

18 three different heating modes going off of one 

19 boiler. And at the end, this was all part of 

20 manufacturers' literature at the time. 

21 MR. BROOKMAN: Thank you. Okay. 

22 Move that microphone closer to you, please. 
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1 Thank you. You're next, Phillip. 

2 MR. STEPHENS: Phillip Stephens. 

3 With respect to 9-6, there again, we see this 

4 increasing. 

5 MR. BROOKMAN: Thank you. I'm 

6 trying to make sure we hit all of these. What 

7 fractional of residential boiler is used in 

8 commercial applications? Do we have a guess 

9 on that? 

10 Jeff, it looks like you have a 

11 guess. No. 

12 You guys don't know? Frank? 

13 MR. STANONIK: Again, this was one 

14 of these things where at least in our 

15 preliminary discussions were not -- we're just 

16 not sure it really is significant to the 

17 analysis, in the sense that okay, if you have 

18 a residential boiler that's being used in a 

19 commercial application, and granted, we're 

20 assuming there's been some thought to provide 

21 a proper application, okay? Then, in fact, 

22 you've got a commercial application that at 
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1 least to some degree is essentially a 

2 residential load or similar to a residential 

3 load. Again, let's assume we're talking about 

4 a fairly large-size boiler, 250,000 BTU input. 

5 Well, if you had a house that needed a boiler 

6 that operated at 250,000 BTUs per hour, and 

7 that product ended up in a commercial 

8 installation, again, there's a legitimate 

9 presumption that says well that happened 

10 because the load of that commercial 

11 application was to some degree similar to what 

12 the house's was. 

13 If that's all true, then what 

14 difference does it make whether it ended up in 

15 the house or in a small commercial 

16 establishment, relative to the efficiency. 

17 MR. BROOKMAN: John Cymbalsky. 

18 MR. CYMBALSKY: So I think what we 

19 might be getting at here is that -- let's just 

20 say it went into a small commercial 

21 establishment, like a barber shop or 

22 something, so the hours of use, I think, over 
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1 the year would be very different and so when 

2 we were to do an economic analysis of 

3 efficiency improvements, you'd have over the 

4 course of a year, even though it's the same 

5 exact boiler, they'd use it for less hours 

6 maybe in a barber shop that's only open 9 to 

7 5, where a house would be heating more hours. 

8 MR. STANONIK: The occupancy 

9 factor. 

10 MR. CYMBALSKY: Exactly. So I 

11 think that's part of it here. 

12 MR. BROOKMAN: Harvey Sachs. 

13 MR. SACHS: Harvey Sachs, ACEEE. 

14 I'm hearing some ambiguity. I read this 

15 question very differently from the way Frank 

16 seems to have read it, that the application 

17 I'm most familiar with is actually using a 

18 train of condensing residential boilers as the 

19 heating source for multi-family apartment 

20 complex. That would be quite likely a 

21 commercial application in the ASHRAE 90.1 

22 sense of its number of stories, but at least 
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1 during the '70s when commercial condensing 

2 appliances were not as common, and residential 

3 ones were less expensive than getting the same 

4 capacity with a smaller number of commercial 

5 appliances, it was quite a fad to do that. I 

6 have no idea if it's continued. I have no 

7 idea if it's widespread, but there certainly 

8 are multi-family organizations and people with 

9 experience in places. 

10 FHA is likely to have somebody who 

11 has a sense of what they've been doing in 

12 their own properties. But that was the 

13 application I was understanding from this -- 

14 from the phrasing you used. And I think it's 

15 very different from what Frank was thinking 

16 about. 

17 MR. BROOKMAN: And also rebound 

18 effects. Thoughts on rebound effect? 

19 MR. SACHS: Harvey Sachs, ACEEE. 

20 Our Department of Theology is preparing a 

21 response. 

22 (Laughter.) 
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1 MR. BROOKMAN: Frank. 

2 MR. STANONIK: Frank Stanonik, 

3 AHRI. We did talk about this one and again, 

4 just thinking in previous rulemakings, our 

5 position is we acknowledge, there is some 

6 rebound effect, but unfortunately, we've not 

7 really seen definitive studies that can give 

8 you a solid number. And at this point, we're 

9 not -- whatever number DOE has used for past 

10 analyses, I would say at the moment is as good 

11 as any. We just haven't seen anything to add 

12 to that general knowledge of that particular 

13 phenomenon. 

14 MR. BROOKMAN: Okay. 

15 MR. STANONIK: But it exists, we 

16 know that. 

17 MR. BROOKMAN: Okay, thank you. 

18 Now we're moving on. 

19 MR. DILLON: Thank you for your 

20 input. Next we'll be discussing the life21 cycle and payback period analysis which will 

22 further be referred to as the LCC and PBP. 
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1 These analyses will allow DOE to 

2 evaluate the net effect in terms of purchase 

3 and operating costs that in an amended energy 

4 conservation standard would have on the 

5 consumers of residential boilers. This 

6 economic analysis is from the consumer's 

7 perspective and the results represent the 

8 difference between the baseline and standard 

9 cases. 

10 As for the methodology, the LCC is 

11 equivalent to the customer price plus the sum 

12 of the annual operating costs over the 

13 analysis period, the baseline lifetime divided 

14 by the average operating hours, then 

15 discounted to a particular base year. 

16 This analysis is conducted using a 

17 Monte Carlo simulation that models the 

18 uncertainty and the variability of the inputs 

19 by characterizing the inputs by probability 

20 distributions. This model will be implemented 

21 using Microsoft Excel combined with Crystal 

22 Ball add-in. 
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1 Inputs required by the LCC and PBP 

2 consist of a variety of inputs, some of which 

3 have been covered in previous sections such as 

4 equipment costs, markups, annual energy 

5 consumption. However, there are additional 

6 inputs required that have not been discussed 

7 which consist of electricity prices, 

8 maintenance and repair costs, installation 

9 costs, product lifetimes and discount rates. 

10 The following comments will 

11 request primarily input on data as mentioned 

12 in the past discussion. DOE requests 

13 comments, 10-1 through 10-8. 

14 Let's start with 10-1. DOE 

15 requests input on the use of the Monte Carlo 

16 simulation and probability distribution 

17 approach for conducting the LCC and PBP. 

18 MR. BROOKMAN: Any comments on 

19 that one? No comments? 

20 MR. KLEISS: It's kind of a -- the 

21 Monte Carlo simulation, it's beyond the scope 

22 of anything that I've been exposed to. I 
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1 don't have any objection to it, but I really 

2 don't have any knowledge of the process. 

3 MR. BROOKMAN: Okay, John? Same 

4 thing, okay. Moving on. 

5 MR. DILLON: Additional comments 

6 for the life-cycle costs and payback analysis, 

7 10-2, DOE requests data that will help 

8 characterize the current mix of boiler 

9 efficiencies in the market. 10-3, DOE seeks 

10 input on the planned approach for estimating 

11 future energy prices. 10-4, DOE requests 

12 input on the maintenance and repair cost 

13 approach. 10-5, DOE seeks input on the 

14 proposed installation cost approach. 10-6, 

15 DOE welcomes comment on product lifetimes for 

16 residential boilers. 10-7, DOE seeks input on 

17 its planned approach for estimating discount 

18 rates for residential consumers. 10-8, DOE 

19 seeks comment on the distribution of energy 

20 efficiencies for boilers in the absence of an 

21 amended energy conservation standard. 

22 MR. BROOKMAN: Let's just take 
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1 these one at a time. 

2 Jeff? 

3 MR. KLEISS: Jeff Kleiss, 

4 Lochinvar. And this relates to 10-4, 10-5, 

5 and 10-6 to some degree. We agree with Frank 

6 Stanonik's and AHRI's suggestion that DOE use 

7 past work on this as a resource for this 

8 information. But in the case of these three 

9 inputs in particular, I think it's important 

10 that they look at more recent history because 

11 as the high efficiency boiler market has 

12 matured, I'm sure that there have been some 

13 cost savings. There's been some efficiencies 

14 of scale that have come about and that you may 

15 see some decline in in costs of high16 efficiency appliances and possibly some 

17 increases of lower-efficiency products. 

18 Also, the characteristic that was 

19 written in here within the document that's 

20 behind this, there were some assumptions that 

21 there would be more higher costs, more 

22 specialized equipment that would be used on 
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1 some high-efficiency products. 

2 Well, there are certainly 

3 manufacturers that create some distinctive 

4 parts for even lower-efficiency appliances. 

5 So that that not be taken as a rule, but 

6 rather they actually evaluate the data for 

7 what it is and look at more recent history. 

8 Also, related to that, for the 

9 longevity when doing the calculations, again, 

10 please look at the more recent data because 

11 there have been changes in products, a 

12 maturing of installation, maturing of water 

13 treatment chemicals and things of that sort 

14 that might help to provide longer lifetimes 

15 for condensing appliances. And similarly, 

16 there have been changes in water quality that 

17 have negatively affected some steam boilers 

18 which have historically had extremely long 

19 lifespans. You might see some shorter 

20 lifespans if you look at more recently 

21 historical data. So again, I just encourage 

22 you to use the most current data on this. 
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1 MR. BROOKMAN: Phillip. 

2 MR. STEPHENS: Phillip Stephens. 

3 We agree and support in addition to those 

4 comments we would like to include a note that 

5 recent improvements and technology for 

6 retrofits including PEX piping for water 

7 connections and flexible polypropylene venting 

8 for high-efficiency appliances have allowed 

9 the retrofits to be more common in older 

10 installations. 

11 And as far as item 10-4, input on 

12 maintenance and repair costs, simply put, most 

13 homeowners do not maintain their equipment 

14 sufficiently to have a significant improvement 

15 in the life. 

16 MR. BROOKMAN: John Cymbalsky. 

17 MR. CYMBALSKY: For the piping you 

18 were just mentioning, was that specifically to 

19 replacing a non-condensing with a condensing 

20 boiler or were you getting -- is that what you 

21 were getting at there? 

22 MR. STEPHENS: Yes. 
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1 MR. CYMBALSKY: If you could 

2 provide data on those costs, we would be 

3 extremely happy with that. Thank you. 

4 MR. STEPHENS: Yes, sir. 

5 MR. BROOKMAN: And I note 

6 following Jeff's comments on 10-4 through 10-

7 6, can we -- can you say now even though most 

8 homeowners don't maintain boilers, frequency 

9 and cost of maintenance or major repair 

10 issues, can you provide information about that 

11 now? Phillip, I'm looking at you. 

12 MR. STEPHENS: That would take 

13 some digging up. I will look into that. 

14 MR. BROOKMAN: Okay, thank you. 

15 Frank, your thoughts? Go ahead. 

16 MR. STANONIK: Not on that 

17 question. 

18 MR. BROOKMAN: Yes, go ahead. 

19 MR. STANONIK: Frank Stanonik, 

20 AHRI. Okay, a couple of things because we are 

21 talking about residential boilers, I mean 

22 first of all, it needs to be recognized that 
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1 unlike with warm-air furnaces, the residential 

2 boiler market is significantly more 

3 replacement market. There are new 

4 installations going on, no question, and a lot 

5 of those are related to increased popularity 

6 of radiant heating and things of that nature. 

7 But in terms of the numbers, the numbers -- 

8 it's clearly indicative that residential 

9 boiler market is driven by the replacement 

10 market. 

11 And there's also, let's say, a 

12 significant regionality to the boiler market 

13 in the U.S. There's a heavy concentration and 

14 then pockets. But that being -- that's the 

15 situation. And so certainly for recent years, 

16 and hopefully we will be able to show you the 

17 data, there has been an increase in the 

18 percentage of condensing boilers that are 

19 being sold in the United States. And again, 

20 most of those are going into residential 

21 replacements. 

22 The point of this -- well, this 
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1 long diatribe here perhaps is that when DOE 

2 looks at the installation costs and 

3 particularly the installation costs where 

4 you're going to be pulling out a non5 condensing/condensing product, for this 

6 product, I think it will be more important to 

7 recognize that because this has been going on 

8 for boilers now for at least ten years in 

9 terms of these -- pulling out the -- the 

10 availability of condensing products, many -- 

11 most of those replacements have probably been 

12 the easy ones. Because if it became too 

13 expensive, the consumer just wouldn't do it, 

14 if they weren't forced to. 

15 And so when DOE looks at okay, in 

16 terms of the effect of whatever regulation, 

17 whatever standard it's going to impose, it's 

18 important that they realize, okay, there's 

19 already been a number of households that made 

20 the switch. The remaining population of 

21 houses that might make the switch is whatever 

22 it's going to be. But the percentage of those 
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1 that would have a potentially difficult 

2 installation which would require maybe some 

3 rework of the site, if you will, is going to 

4 be higher than if you just looked at all 

5 existing boiler installations because again, 

6 some of the people have made the change and 

7 those that have in most cases did it because 

8 it wasn't a major disruption. 

9 MR. BROOKMAN: Harvey Sachs. 

10 MR. SACHS: Harvey Sachs, ACEEE. 

11 A couple of observations. One of them is in 

12 terms of setting the minimum standards. 

13 Jeff's comments are echoing in my mind. Are 

14 there technologies extant that cannot support 

15 condensing applications, metallurgy or 

16 whatever? 

17 But the other one is in response 

18 to Frank's comment that the easy ones have 

19 been done. We were involved, Meg and I, 

20 particular with the American Gas Association, 

21 a pretty extensive process last year looking 

22 at possible issues that would come from the 
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1 northern standard requiring condensing on 

2 furnaces. And particularly an examination in 

3 conjunction with PHCC and ACCA at what these 

4 installation issues might be and what the 

5 frequency might be of very hard problems. 

6 I found myself very encouraged 

7 that no one expected this to be a very high 

8 fraction and something which even if we got to 

9 a condensing standard for boilers would be 

10 feasible to handle with a -- call it a pre11 approved waiver process. 

12 So recognizing that there are 

13 going to be situations, some rowhouses have 

14 been named as a conspicuous example. I think 

15 that I'm encouraged by what's come out from 

16 Phillip, in particular, that we're seeing much 

17 wider use or beginning to see use of the 

18 flexible polypropylene venting systems that 

19 are much more adaptable, again from Europe. 

20 And we're seeing a lot of other things that do 

21 point toward Jeff's conclusion of potential 

22 for learning curves on installation as well. 
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1 Finally, while I've got the mic 

2 on, I believe that we'll find importantly that 

3 there's still a difference in the maintenance 

4 practices for the oil boiler market than for 

5 the gas boiler market. That the service 

6 providers for oil I'm quite certain will 

7 continue to strongly recommend the annual 

8 service to de-soot and check combustion 

9 efficiency, at least until they're very 

10 comfortable with the ultra-low sulfur 

11 regulations. 

12 MR. BROOKMAN: Thank you. Take a 

13 peek at the box here. Several of these have 

14 not been addressed yet. I don't think we have 

15 addressed estimating discount rates. We 

16 haven't talked about the current mix of boiler 

17 efficiencies. I know there are others as 

18 well. 

19 MR. KLEISS: Energy prices. 

20 MR. BROOKMAN: Yes, thank you. 

21 MR. SACHS: Harvey Sachs. Hasn't 

22 OMB taken the discount rate question out of 
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1 our hands? 

2 MR. CYMBALSKY: Yes, I don't think 

3 we need to talk about discount rates at this 

4 meeting. 

5 MR. BROOKMAN: Okay, Jeff. 

6 MR. KLEISS: Jeff Kleiss, 

7 Lochinvar. On Item 10-8, DOE seeks comments 

8 on the appropriate distribution of energy 

9 efficiencies for residential boilers in the 

10 absence of amended energy conservation 

11 standards. I can't say much to this other 

12 than our expectation and experience so far is 

13 that, when appliances are replaced, they are 

14 almost never replaced with appliances that are 

15 less efficient. So if anything, the attrition 

16 will be towards higher efficiency appliances. 

17 MR. BROOKMAN: Okay, thank you. 

18 Frank. 

19 MR. STANONIK: Simply because it 

20 was asked, in terms of DOE's handling of 

21 future energy prices, as far as our concerns, 

22 I'll say is that there's lots of news out 
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1 there and information about the change in US's 

2 natural gas supply. I guess I'm willing to 

3 defer to whatever information gets traded 

4 between DOE and AGA as to where they think 

5 future natural gas price projections are going 

6 to be. 

7 As far as oil, prices of oil, I 

8 guess I really haven't looked at that of late 

9 to see what projections exist for future 

10 prices. Although I've not heard any 

11 suggestions that those are going to drop 

12 appreciably. 

13 MR. CYMBALSKY: John Cymbalsky, 

14 DOE. So we'll typically or exclusively use 

15 the EIA projections in these models. 

16 Obviously, shale gas plays a big part in their 

17 projections and so -- and they update their 

18 forecasts annually. We'll pick up any changes 

19 in the market based on their work. 

20 MR. BROOKMAN: Harvey Sachs. 

21 MR. SACHS: Harvey Sachs. DOE has 

22 made enormous progress in doing its modeling 
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1 in many aspects of this proceeding. And it 

2 might not be too much to ask to think about 

3 changing the escalation rate implicit in the 

4 EIA forecast as an EIA base and a high cost to 

5 low cost. There's a fair amount of empirical 

6 evidence out there now that natural gas 

7 current prices do not reflect replacement 

8 costs even for shale gas and that the bubble 

9 may not last as long as expected. 

10 I don't know. I'm not in that 

11 business, but it seems that it would be 

12 beneficial to the process to change the 

13 escalation coefficient just to show what 

14 happens to your analyses as you're under way. 

15 It might not be good for my side. 

16 MR. BROOKMAN: Phillip. 

17 MR. STEPHENS: Phillip Stephens. 

18 As for Item 10-8, we see an opposite trend 

19 from what Lochinvar sees. We see the fact 

20 that especially in today's economy, people 

21 simply when they need a replacement, they will 

22 often go with the lowest-cost replacement. So 
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1 if it weren't for the energy conservation 

2 standards and requirements, the lower 

3 efficiency products which inherently cost less 

4 would become more popular and the country 

5 would use more energy. 

6 And on top of that, there's the 

7 added benefit of the incentive programs and 

8 the Energy Star programs which further give 

9 enforcement or encouragement to go with higher 

10 efficiencies. We strongly support higher 

11 efficiencies. 

12 MR. BROOKMAN: Does HTP serve a 

13 region of the country or -- 

14 MR. STEPHENS: We are nationwide, 

15 residential boilers, commercial boilers, water 

16 heaters also. 

17 MR. BROOKMAN: John. 

18 MR. CYMBALSKY: So could the 

19 manufacturers provide data on how their 

20 product offerings have become more Energy Star 

21 over time, is that something -- I think you 

22 would track how many you make that meet the 
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1 Energy Star designation. 

2 MR. STEPHENS: We only operate in 

3 the high-efficiency retail market, so we don't 

4 have a bias, but we may be able to draw some 

5 conclusions for the Energy Star. 

6 MR. CYMBALSKY: Okay, thank you. 

7 MR. BROOKMAN: Harvey. 

8 MR. SACHS: Harvey Sachs, ACEEE. 

9 John, I think that Energy Star is making an 

10 effort to track the fraction of the market 

11 that is being supplied with Energy Star across 

12 all its portfolio. 

13 MR. BROOKMAN: Jeff? 

14 MR. CYMBALSKY: Never have too 

15 much data over here, Harvey. 

16 MR. BROOKMAN: Jeff, please. 

17 MR. KLEISS: I recently did some -

18 - just going on the age of our directory of 

19 residential boilers and looked at the number 

20 of different products. Now this does not 

21 reflect sales of units, but the number of 

22 different products that are offered. And 
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1 there is a consistent shift towards higher2 efficiency products. I think that now as far 

3 as natural gas products, it was something like 

4 60-some odd percent of them qualified for the 

5 Energy Star as far as being 85 percent, and 

6 not quite as large a percentage of the oil 

7 boilers, but still a substantial amount. 

8 Energy Star program is currently 

9 reviewing raising those efficiency levels and 

10 sort of redrawing the lines so that it drives 

11 products towards higher efficiency level. 

12 MR. BROOKMAN: Phillip. 

13 MR. STEPHENS: I agree. We've 

14 done a similar analysis and from what we've 

15 seen, a lot of those higher-efficiency 

16 appliances are coming in as imports from 

17 countries that have higher efficiency 

18 requirements than the U.S. 

19 MR. BROOKMAN: Thank you. Okay. 

20 MR. DILLON: All right, we're 

21 going to switch over to the shipments 

22 analysis. The next two slides, we'll be 
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1 discussing the shipments analysis and the 

2 national impacts analysis. The shipments 

3 analysis outputs will be utilized during the 

4 NIA. 

5 The purpose of the shipments 

6 analysis is to project future shipments for 

7 the base case and standard case by product 

8 class beginning at the expected compliance 

9 year of the standard. These shipment 

10 projections will be used to calculate effects 

11 of an amended energy conservation standard on 

12 boiler shipments. 

13 The methodology for the analysis 

14 involves developing shipments projections 

15 based on an analysis of key market drivers for 

16 boilers. DOE may characterize the projected 

17 production of the shipments of boilers using 

18 economic and industry-related indicators. 

19 Shipments projections will be 

20 determined for both replacement and new 

21 construction cases. DOE intends to rely on 

22 publicly available data sources including 
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1 information provided by manufacturers, 

2 industry organizations, market reports and 

3 historical shipments data. 

4 DOE welcomes comments on items 11-

5 1 through 11-2. 

6 DOE seeks disaggregated historical 

7 shipment data based on the current product 

8 class and efficiency levels. 11-2, DOE seeks 

9 input on the potential impact that an amended 

10 standard would have on the residential boiler 

11 shipments. 

12 MR. BROOKMAN: Any comment on 

13 these? No comment at this time. 

14 MR. DILLON: Next up for 

15 discussion is the national impact analysis. 

16 The purpose of the national impact analysis is 

17 to determine the national energy savings and 

18 the national consumer economic impacts, the 

19 potential energy conservation standards for 

20 each product class in terms of net present 

21 value. The national impact analysis builds 

22 off outputs from several of the preceding 
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1 analyses. 

2 As for the methodology, DOE 

3 intends to calculate the annual equipment 

4 expenditures by multiplying the price per unit 

5 by projected shipments for the base case and 

6 standard cases. DOE also determines the 

7 national energy consumption by multiplying the 

8 unit energy consumption per boiler by 

9 projected shipments for the base cases and 

10 standard cases. 

11 DOE then determines the 

12 differences between the base case and standard 

13 case scenarios, resulting in the national 

14 annual energy savings and increased 

15 expenditures in dollars. The difference 

16 between energy savings and increased 

17 expenditures is a net savings or the net cost 

18 for each year. The net present value is 

19 calculated as the difference between the 

20 present value of operating cost savings and 

21 the present value of total installed costs. 

22 DOE seeks comment regarding the 
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1 distribution of boiler efficiencies in the 

2 absence of standards. 

3 No comments? 

4 MR. BROOKMAN: Yes, Jeff. 

5 MR. KLEISS: I couldn't pass up 

6 more than two in a row without comment. 

7 MR. BROOKMAN: Good. 

8 MR. KLEISS: In the document that 

9 DOE put out, it referred to the roll-up 

10 methodology for figuring this out. And I just 

11 want to sort of reiterate the point of 

12 considering installed cost while going through 

13 this roll-up. And if you do look at, say, the 

14 AHRI directory and sort of do the spread of 

15 the products that are offered, you will find 

16 that there is a gap in product that's offered. 

17 Very few products are in that range of 

18 efficiencies because you cross the boundary of 

19 condensing products. But the exhaust 

20 temperatures are high enough that the only way 

21 to vent it is with corrosion-resistant metal 

22 venting material which is much more expensive 
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1 than when you get to a higher level of 

2 condensing appliance where you then have cool 

3 enough flue gas temperatures that you can use 

4 polymer venting. Much lower installation 

5 costs comparatively. And it's that installed 

6 cost that creates this gap. So in the roll-up 

7 analysis, if you get to a point where you 

8 cross that threshold, just be aware that there 

9 is going to be a gap there, and that needs to 

10 be considered. 

11 MR. BROOKMAN: Thank you. You see 

12 the comment box. Additional thoughts on this? 

13 MR. DILLON: 12-1, DOE seeks 

14 comment on the appropriate assumptions to use 

15 regarding long-run changes in residential 

16 boiler energy efficiency independent of 

17 amending energy conservation standards. 

18 MR. BROOKMAN: No comment here? 

19 Yes, Frank. 

20 MR. STANONIK: Again, probably 

21 more of a question than a comment. And it's, 

22 in part, because I just don't remember how 
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1 this was addressed in previous rulemakings, 

2 but if DOE looks at the scenario of the 

3 absence -- or independent of amending energy 

4 conservation standards, does the analysis 

5 factor in the existence of incentive programs 

6 and the continued existence of those programs? 

7 MR. BROOKMAN: Phillip? 

8 MR. STEPHENS: Phillip Stephens. 

9 A question. Does the DOE analysis take into 

10 account the imports as well as domestic 

11 manufacturers or combine the market as one 

12 lump sum? 

13 MR. BROOKMAN: If there are no 

14 more additional comments to this box, we're 

15 going to move on. 

16 MR. DILLON: Is that it? I'm 

17 going to pass it over to -- 

18 MR. BROOKMAN: Phillip, yes, 

19 please. 

20 MR. STEPHENS: Phillip Stephens, 

21 just a follow-up question. Is it taken as a 

22 separate evaluation or as part of the entire 
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1 evaluation? Is there any way we can look at 

2 that as a separate? 

3 MR. CYMBALSKY: So where we do 

4 separate it out is in the manufacturing 

5 impact. We do look at the impact on domestic 

6 manufacturers separately on the standard, but 

7 as for doing the base line for the shipments, 

8 which is what I think we're asking for here on 

9 comment is we're just generally looking for 

10 the efficiency trend of the whole boiler 

11 market. We don't necessarily care if it's an 

12 import or domestically produced. 

13 What we're trying to do right is 

14 the math and the energy savings based on what 

15 would happen in the market without the 

16 standard there anyway. And so when you impose 

17 the standard, then you can do the math 

18 correctly to get the right national energy 

19 savings. 

20 MR. BROOKMAN: So moving on to 

21 NOPR analyses, the downstream analyses. 

22 MR. DILLON: I'm going to pass 
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1 this off to Alex Lekov. 

2 MR. LEKOV: So far we have been 

3 talking about the analysis that's related to 

4 the next phase of the rulemaking which is the 

5 preliminary analysis phase. During the next 

6 several slides, myself and Catherine will be 

7 talking about analysis that actually will 

8 start in the Notice of Proposed Rule phase 

9 which is down the line in 2014. 

10 So on this slide, you see the 

11 explanation about analysis related to 

12 developing consumer subgroups. So in addition 

13 to the main flow of consumers, the Department 

14 also analyzes the economic impacts of energy 

15 conservation standards on consumers, including 

16 subgroups who may be disproportionately 

17 impacted compared to the general population. 

18 The approach taken in this case is 

19 to utilize the primary life-cycle cost 

20 analysis tool by developing input specific to 

21 each of the consumer -- the considered 

22 consumer subgroups. And for this particular 
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1 analysis, the Department seeks input as to 

2 what consumer subgroups are appropriate to 

3 evaluate for residential boilers. 

4 MR. BROOKMAN: Consumer subgroups. 

5 Harvey. 

6 MR. SACHS: Harvey Sachs. Alex, 

7 I'm glad the Department is doing that. I only 

8 hope that the Department will be sensitive, 

9 not only to the nature of the potentially 

10 impacted groups, low-income, elderly, 

11 whatever, but to the geographic distribution 

12 of residential boiler sales that the 

13 population of low-income, Southeastern or 

14 Southwestern boiler users is probably a fairly 

15 small fraction of the population of boiler 

16 users. There are going to be geographic 

17 weighting factors that may not have been 

18 important in some of the product classes. 

19 MR. BROOKMAN: Thank you. 

20 Additional comments on this subgroup analysis? 

21 MR. LEKOV: So -- 

22 MR. BROOKMAN: Yes, hold on. 
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1 MR. STANONIK: I'm processing 

2 Harvey's comment there. And it's a good 

3 point. Just to reinforce, but also make sure 

4 that as we've mentioned, clearly the 

5 predominant, not exclusive, but predominant 

6 distribution of residential boilers in the 

7 U.S. tends to be in the Northeast and the 

8 region we're in. And so yes, I think you 

9 should look at -- at least consider the 

10 respective distribution of subgroups within 

11 that particular geographic area. It certainly 

12 would be different than the national average. 

13 MR. BROOKMAN: Yes, thank you. 

14 MR. LEKOV: Thank you. 

15 MS. RIVEST: I'll be going over 

16 the manufacturer impact analysis, and the 

17 purpose of the manufacturer impact analysis is 

18 threefold. It's to assess the impacts of 

19 amended standards on manufacturers as well as 

20 to identify subgroups that may be more 

21 severely impacted than the industry as a 

22 whole, and to examine the impact of cumulative 
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1 regulatory burden on manufacturers. 

2 And the method that DOE uses to do 

3 this includes analyzing industry cash flow and 

4 net present value through the use of the 

5 Government Regulatory Impact Model. And DOE 

6 also conducts interviews with manufacturers to 

7 refine the inputs of the GRIM model and to 

8 address any qualitative issues they may have. 

9 So I'll open the floor up for 

10 discussion. Item 14-1 seeks comments on the 

11 appropriate manufacturer subgroups should be 

12 considered. Item 14-2 welcomes comments on 

13 other existing regulations or pending 

14 regulations to consider in its examination of 

15 cumulative regulatory burden. And Item 14-3 

16 requests industry feedback on the names and 

17 the number of small business manufacturers. 

18 MR. BROOKMAN: Frank. 

19 MR. STANONIK: I was trying to see 

20 if I could find it quickly, again, since I 

21 don't have the command as to what DOE defines 

22 as a small business. 
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1 MS. RIVEST: I think for boilers, 

2 it's under 500 employees. 

3 MR. STANONIK: Under 500 

4 employees. Without knowing the exact numbers, 

5 first of all, again, the residential boiler 

6 market in the U.S. pales in comparison to 

7 residential warm air equipment. And there 

8 still are a significant number of 

9 manufacturers that do participate in that 

10 market. And many of those manufacturers also 

11 make commercial boilers, but I would venture 

12 that if you were to just look at the 

13 residential boiler market, many, if not all of 

14 them, may be considered small businesses. 

15 We'll try and help refine that, but I think a 

16 lot of the people in the boiler business, 

17 particularly if they're making residential 

18 boilers may end up being considered small 

19 businesses. 

20 And I would say even if they 

21 weren't, I think they still need certain 

22 considerations that would be consistent with 
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1 that, again, because it still is a relatively 

2 small market with a significant number of 

3 companies still participating. 

4 MR. BROOKMAN: Thank you. Jeff. 

5 MR. KLEISS: I would just say that 

6 with the manufacturer impact analysis and 

7 Government Regulatory Impact Model, it's not 

8 lost on us that the acronyms are MIA and GRIM. 

9 (Laughter.) 

10 That said, I would say on Item 14-

11 1 that it's certainly our position that 

12 evaluating or making decisions based on the 

13 manufacturing processes that are used doesn't 

14 really make sense to us. The decisions made 

15 should be based on the effect of the product. 

16 And if a manufacturer needs to adjust their 

17 processes in order to provide what's needed 

18 for the industry, then that would be our 

19 position. 

20 MR. BROOKMAN: Before you move on, 

21 Phillip, do you want to chime in here? 

22 MR. STEPHENS: Yes. From our 
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1 perspective, we are seeing consolidation in 

2 the industry. A lot of the smaller -- some of 

3 the smaller boiler manufacturers are being 

4 purchased by larger companies and I'm not sure 

5 how that classification holds whether when you 

6 look at the business, you look at the 

7 corporate entity or just the small business. 

8 But that will make a distinction. We are a 

9 small business relative to a lot of the other 

10 boiler manufacturers. 

11 MS. ARMSTRONG: So for our 

12 purposes, it would have to be 500 employees or 

13 less including parents and subsidiaries. 

14 MR. BROOKMAN: Jeff, back to you. 

15 MR. KLEISS: Commenting on the 

16 second item, Item 14-2, as far as the 

17 regulatory burden. DOE, EPA, FTC, the 

18 environmental requirements of REACH and RoHS19 2, the regulatory burden that's come out has 

20 been extraordinary, staggering for us. I 

21 appreciate DOE considering the regulatory 

22 burden and how it's impacting us and ask you 
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1 to be as gentle as possible. 

2 (Laughter.) 

3 MR. BROOKMAN: Phillip. 

4 MR. STEPHENS: We second. 

5 MR. BROOKMAN: Thank you. Do we 

6 have comment on 14-3, industry feedback on the 

7 number and names of small businesses? 

8 Frank, can you provide that 

9 information? 

10 MR. STANONIK: Yes, I mean I think 

11 we should be able to give some specific answer 

12 to that question, yes. 

13 MR. BROOKMAN: Okay, thank you. 

14 MS. RIVEST: Thank you, and I'll 

15 pass it back over to Alex. 

16 MR. LEKOV: Alex Lekov, Lawrence 

17 Berkeley National Laboratory. So as part of 

18 the NOPR phase, DOE is also mandated to report 

19 environmental effects of potential energy 

20 conservation standards. This is done both in 

21 terms of physical quantities and in terms of 

22 dollar values. So the physical quantities are 
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1 calculated using EIA's NEMS model, which 

2 reports effects related to emissions as listed 

3 here on the slide. 

4 The monetization, which reports 

5 essentially the dollar effect of the reduced 

6 emission is performed using values developed 

7 by interagency reviews, essentially, which 

8 represent the current social cost of carbon. 

9 For this analysis, DOE seeks input 

10 on the approach to conduct the physical 

11 emissions impacts, as well as on the approach 

12 to use for the estimating the momentary 

13 benefits. 

14 MR. BROOKMAN: Comments? Yes, 

15 Frank. 

16 MR. STANONIK: Again, Frank 

17 Stanonik, AHRI. More of a question. And in 

18 particular, looking at the framework document, 

19 in the discussion about the current estimates 

20 of the monetization of CO2 emissions, the 

21 information provided expressed in 2011 dollars 

22 is that the estimates, and I'm just going to 
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1 read them because of what they are. The 

2 estimates were $6.10, $25.04, $41, and $77.70. 

3 That's a range, a factor of 10. 

4 And so I think in order for us to 

5 try and work with DOE on this, I question what 

6 number do you use and how do you decide which 

7 of those? This is not a tightly packed range. 

8 It's almost like well, what did you have in 

9 your pocket today and that's going to be the 

10 price. I just don't -- it's hard for us to -- 

11 we're concerned this is a significant factor 

12 or could be a significant factor. And yet we 

13 still don't really have a good grasp of how 

14 you analyze that with that kind of a range of 

15 costs. 

16 MR. BROOKMAN: Thank you. 

17 MR. LEKOV: So DOE does not make 

18 an assessment of these values. DOE simply -- 

19 DOE's analyses report the results that will 

20 come as a result of applying this value to the 

21 physical quantities. 

22 MR. BROOKMAN: Frank. 
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1 MR. STANONIK: Okay, I understood 

2 your answer, Alex, but that doesn't help. 

3 That just says okay -- that's kind of like 

4 saying well, if you could get this much money 

5 in terms of the CO2 reduction, then this is 

6 what the effect would be. But in terms of all 

7 the other stuff that's done in this kind of 

8 analysis, I think the analysis is driven to 

9 try to come to some concrete conclusion or 

10 have some, as best as can be done, some real11 world information. And we get to this and 

12 it's like well, here's these numbers out here 

13 and we're just going to look at what the 

14 numbers mean. But it doesn't have that -- to 

15 me, it doesn't go to that next step and say 

16 okay, but for our analysis and if this is 

17 considered in this rulemaking, this would be 

18 the value of the CO2 emissions. There's no 

19 fixed number. It could be this, it could be 

20 that. Well, the cost of natural gas could be 

21 10 cents a therm and it could be $48 a therm. 

22 MR. BROOKMAN: John Cymbalsky. 
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1 MR. CYMBALSKY: So these values 

2 were given to us to use by OIRA and, you know, 

3 the range actually implies that there is a lot 

4 of uncertainty as to what this cost could be. 

5 And so I think it does add value 

6 to show the range because, in fact, nobody 

7 wants to actually pin the tail on the donkey 

8 here, right? 

9 And this relates since it's 

10 natural gas mostly we're talking about. I 

11 wouldn't suspect this would be a big economic 

12 part of the rule. So thankfully we're not 

13 burning a lot of coal in this rule, so I think 

14 we're okay. 

15 MR. BROOKMAN: You see the comment 

16 box. Additional thoughts. Boxes plural. 

17 Nothing additional. 

18 Alex? 

19 MR. LEKOV: So DOE also is 

20 mandated to an impact on overall effects on 

21 domestic energy supplies as a result of 

22 potential energy conservation standards. The 
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1 two uses for this purpose is, again, NEMS and 

2 outcome of this analysis is essentially 

3 projection of electricity generation and 

4 avoided capacity resulting from a potential 

5 change to the efficiency standard. 

6 So DOE welcomes input regarding 

7 the proposed approach to use NEMS to evaluate 

8 this type of analysis. 

9 MR. BROOKMAN: Comments on this 

10 approach? No comments. 

11 MR. LEKOV: In the NOPR, DOE will 

12 also assess the overall impact on the national 

13 employment from potential energy conservation 

14 standards. Those include both direct and 

15 indirect employment impacts. The direct 

16 impacts were already discussed as part of the 

17 MIA analysis. In this particular analysis 

18 here, the focus is on indirect impact and DOE 

19 plans to utilize a tool named ImSET, Impact of 

20 Sector Energy Technologies, to evaluate the 

21 indirect employment impacts. 

22 And here, the request for comment 
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1 is feedback on the proposed approach to 

2 perform the indirect employment analysis. 

3 MR. BROOKMAN: Comments on 

4 indirect employment? Yes, Jeff. 

5 MR. KLEISS: Jeff Kleiss, 

6 Lochinvar. In general, noncondensing products 

7 that are sold in the U.S. are by and large 

8 going to be domestically produced. There are 

9 a significant proportion of higher-efficiency 

10 condensing products that are in part or in 

11 whole imported, heat exchanger technologies 

12 have been brought in from Europe and other 

13 places. 

14 So even without a change in the 

15 number of boilers sold, it is reasonable to 

16 assume that there will be some manufacturing 

17 jobs lost as we shift to more condensing 

18 technologies. Beyond that, just the overall 

19 number of boilers sold, unless you eliminate a 

20 full product class of say noncondensing 

21 boilers which would then be a significant cost 

22 increase, I doubt that you're going to see 
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1 this ruling actually impact the number of 

2 boilers sold. That's primarily, it's a 

3 necessity. They're largely replacement units 

4 and it's going to be driven more based on 

5 rebate programs and weather. 

6 MR. BROOKMAN: Okay, thank you. 

7 Additional comments? I see none. 

8 MR. LEKOV: DOE is also mandated 

9 to investigate the national impacts of non10 regulatory alternatives compared to mandatory 

11 energy conservation standards. The tool used 

12 in this case is essentially the national 

13 impact analysis spreadsheet modified 

14 appropriately to reflect these types of 

15 policies, and the results after that are 

16 compared to the results of the mandatory 

17 efficiency standards. 

18 MR. BROOKMAN: Comments on the 

19 regulatory impact analysis? Okay, I see none. 

20 MR. LEKOV: Thank you. 

21 MR. BROOKMAN: Thank you. So as 

22 we noted first thing this morning, now is 
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1 another opportunity for anybody that wants to 

2 make closing remarks, issues that haven't been 

3 covered sufficiently, things you wish to bring 

4 to the floor as we move towards closure. 

5 Yes, Frank. 

6 MR. STANONIK: Frank Stanonik, 

7 AHRI. I just wanted to note that this is in 

8 the framework document that was provided. At 

9 the very bottom of page 3 and the top of page 

10 4, it does properly note that EPCA states that 

11 the Secretary may not establish an amended -- 

12 and I emphasis amended -- or new standard if 

13 such standard would not result in a 

14 significant conservation of energy or is not 

15 technologically feasible or economically 

16 justified. 

17 I am familiar in the legislation 

18 with certain criteria that apply if the 

19 Secretary was intending to develop standards 

20 for product not specifically listed in the 

21 legislation, but I just don't remember. Is 

22 there any particular defined value that 
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1 identifies whether it's significant 

2 conservation of energy or not that would apply 

3 to amended standards? No, okay. So we can talk 

4 about it, but it won't get us very far. 

5 MR. BROOKMAN: Okay. Jeff. 

6 MR. KLEISS: There was one other 

7 note that I had here that when we were in the 

8 Section 7 and talking about doing the tear9 down to do the evaluation of the manufacturing 

10 costs. There are certainly components that 

11 involve chemical treatment or some special 

12 processing that a tear-down evaluation would 

13 not necessarily reveal as far as possible 

14 costs for manufacturing. So I would just 

15 encourage the DOE while they're gathering that 

16 data to actually have some dialogue with the 

17 manufacturer that's engaged so that they can 

18 capture some of those costs. 

19 MR. BROOKMAN: Yes, thank you. 

20 Frank. Oh, excuse me, Harvey Sachs. 

21 MR. SACHS: Thanks for the 

22 compliment. This is Harvey Sachs, ACEEE. 
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1 Towards the question, we've already 

2 established that there are prescriptive 

3 features that might or might not impact the 

4 AFUE and there potentially are other features 

5 that might not affect AFUE determination, but 

6 could save substantial amounts of energy and 

7 it's not clear to me how DOE and FTC would 

8 proceed to allow manufacturers to profit by 

9 providing information to consumers on features 

10 that save energy but are not reflected in the 

11 AFUE test. This is potentially an important 

12 question. It ties directly to Frank's 

13 question. When we're doing an amended 

14 standard, do we calculate the energy savings 

15 of the prescriptive features or just the test 

16 cycle? 

17 MS. ARMSTRONG: This is Ashley 

18 from DOE. So I don't have a definitive 

19 answer. It's going to depend on the 

20 Department's position as to its authority 

21 about whether it can amend the dual 

22 descriptor, whether it has to amend a single 
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1 descriptor, and then the extent for which that 

2 carries through the analysis. So to the 

3 extent you have an opinion on that, we welcome 

4 your comments, obviously, to put that and 

5 bridge that as to what you believe it ought to 

6 do. 

7 MR. SACHS: Harvey Sachs again. 

8 Thank you, Ashley. I'm very modest about my 

9 potential to influence Office of General 

10 Counsel. 

11 MS. ARMSTRONG: Me, too. 

12 MR. SACHS: I'm very modest about 

13 my perception of my ability of General Counsel 

14 to understand the industry. With that zinger, 

15 I would like to thank the Department for this 

16 opportunity and the chance to explore some of 

17 these issues that are not quite as cut and 

18 dried as they might at first appear. And I 

19 guess I'll go lick my wounds and come back on 

20 Friday. 

21 MR. BROOKMAN: Frank Stanonik. 

22 MR. STANONIK: Frank Stanonik, 
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1 AHRI. Just one other question, at some point 

2 the analysis will include some interviews with 

3 manufacturers. Where in your schedule do you 

4 foresee that occurring? 

5 MS. ARMSTRONG: This is Ashley 

6 from DOE. Typically, it can happen either 

7 once or twice or multiple times in process. 

8 At the very least, we will do some type of 

9 engineering-type interviews where we go 

10 through our tear-down analysis and get the 

11 feedback on that. And then there will be some 

12 type of manufacturing interviews to deal with 

13 the cost to the industry, the changes in the 

14 capital that you have to deal with to try to 

15 provide inputs. 

16 As to exactly when, I mean, give 

17 us time. It's fair to say that it won't be in 

18 the next six months, but we would reach out 

19 well in advance and we can reach out to you as 

20 well as manufacturers. 

21 MR. STANONIK: Ashley, this is 

22 Frank. And I guess what I was thinking is 
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1 again, in Slide 14, you kind of showed us your 

2 schedule, so I guess I asked my question 

3 poorly. Do you think those interviews would 

4 occur before the preliminary analysis or 

5 after? 

6 MS. ARMSTRONG: So both. 

7 Typically, we do the engineering ones before 

8 and the MIA ones after. 

9 MR. STANONIK: Okay, so some time 

10 before. Okay. 

11 MR. BROOKMAN: Phillip. 

12 MR. STEPHENS: Phillip Stephens. 

13 I guess we're just going right around the room 

14 here. I would like to thank you for this 

15 opportunity. I would also like to encourage 

16 the Department of Energy to please continue to 

17 work with AHRI. They do provide a valuable 

18 service to all the manufacturers and we 

19 greatly appreciate everything they do. 

20 That being said, we recognize that 

21 we operate purely in the residential and 

22 commercial boiler industry, only the high-
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1 efficiency end, whereas AHRI is required to 

2 operate on a consensus agreement for the 

3 industry association. So our reviews on this 

4 are slightly different from AHRI's. We do 

5 support high efficiency in every market, the 

6 markets we compete in and the markets we do 

7 not. 

8 If there's any way we can provide 

9 further support on this for residential 

10 boilers, gas-fired, solar, thermal, heat pump 

11 technology, please feel free to contact me. 

12 MR. BROOKMAN: Thank you, Phillip. 

13 Additional final comments? Okay, then for my 

14 part, I'll say thank you for a very productive 

15 meeting. At the back of your packet, each one 

16 of you has an evaluation form, the last page, 

17 so please take a few minutes to -- one minute, 

18 probably, to figure that out and I'll turn it 

19 back to John Cymbalsky. 

20 MR. CYMBALSKY: Thanks, Doug. 

21 John Cymbalsky, DOE. Comment period closes 

22 March 28th, as you see on the slide. And on 
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1 behalf of the Department, I would like to 

2 thank everybody for attending and particularly 

3 the openness of this discussion. I thank the 

4 manufacturers, in particular. I think your 

5 candor here is very much appreciated by the 

6 Department. And again, this rule is only as 

7 good as the participation by all the 

8 stakeholders. So we really look forward to 

9 working with you on this rule and you'll 

10 probably be hearing from us very shortly. 

11 MR. STANONIK: I'm sorry, John. I 

12 just wanted to remind you, you do have the 

13 option to decide no amended, no change is 

14 necessary. 

15 (Laughter.) 

16 MR. CYMBALSKY: Did I say we were 

17 changing anything? 

18 MR. BROOKMAN: Frank Stanonik 

19 followed by John Cymbalsky. 

20 MR. CYMBALSKY: But again, thank 

21 you and we met the goal of finishing by lunch 

22 which for my stomach right now I can you is 
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1 very happy with that outcome. Thank you. 

2 (Whereupon, the above-entitled 

3 matter went off the record at 12:07 p.m.) 

4

5

6

7

8

9

10

11

12

13

14

15

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18

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A

ability 125:13

able 32:15 89:16

98:4 114:11

above-entitled

130:2

absence 84:20

94:10 103:2 105:3

ACCA 92:3

acceptable 42:4

acceptance 29:22

account 17:21 27:9

105:10

accounts 17:19

ACEEE 9:15 13:3

22:13 41:18 45:9

52:14 67:6 79:13

80:19 91:10 98:8

123:22

acknowledge 81:5

acronyms 112:8

Act 20:6

acting 5:9

active 17:20

activity 10:11

actual 27:13 43:12

53:19 74:3

Adam 2:2 11:18

17:10,13 30:20

adaptable 92:19

add 38:14 66:19

76:15,16 81:11

118:5

added 54:11,18

97:7

adding 39:3

addition 38:15 87:3

107:12

additional 15:13

29:8 38:16 41:15

46:7 56:20 58:13

66:10 83:5 84:5

104:12 105:14

108:20 118:16,17

121:7 128:13

address 17:5 25:22

26:6 28:12 52:14

56:14 110:8

addressed 15:3

26:5 66:6 93:14

93:15 105:1

adds 60:5

add-in 82:22

Adjourn 3:21

adjust 68:8 112:16

adjusted 68:12

adopt 18:3 34:19

adopts 53:2

advance 126:19

advanced 23:2

advantages 58:7

adverse 44:21,22

46:4

advertise 24:9

AEMTCA 13:16

14:22

affect 70:6 124:5

AFUE 13:10 16:3

18:12,13 20:17,20

27:7 28:9 37:2,11

43:22 63:6,14

124:4,5,11

AFUEs 12:8

AGA 95:4

age 98:18

Agenda 3:2

ago 40:14 43:7

agree 35:9 40:1

85:5 87:3 99:13

agreement 66:21

128:2

ahead 26:10 54:10

66:14 88:15,18

AHRI 24:22 30:5

33:11 41:3 47:16

54:22 58:4 61:20

65:13,21 68:2

71:8 73:6 81:3

88:20 103:14

115:17 122:7

126:1 127:17

128:1

AHRI's 85:6 128:4

air 22:18,20 23:4

23:22 29:15 53:14

69:12 73:13,19

74:4,10,16 75:4,9

111:7

Air-Conditioning

2:8

Alex 2:4 66:15,16

66:18 73:20,21

74:9 75:10,11

107:1 108:6

114:15,16 117:2

118:18

allow 33:14 67:16

68:15 82:1 124:8

allowed 65:1 87:8

allowing 13:11

alternatives 121:10

aluminum 58:5

ambiguity 29:11

79:14

amend 124:21,22

amended 18:12

20:17 82:3 84:21

94:10 100:11

101:9 109:19

122:11,12 123:3

124:13 129:13

amending 104:17

105:3

amendments 13:17

20:5 25:16

American 2:7

10:17 91:20

amount 96:5 99:7

amounts 16:2 42:1

124:6

analogous 23:1

analyses 8:15 17:5

31:2,7 52:22

60:14 81:10 82:1

96:14 102:1

106:21,21 116:19

analysis 3:6,8,9,10

3:10,11,12,13,14

3:15,16,17,17,18

3:18 7:21 8:7,19

8:21 9:4,20 11:2

12:17 17:1 20:17

21:19 22:9 25:15

30:19 31:1,4,5

33:21 39:13 44:4

44:5,7,7 47:19

48:6 49:15,16

50:5,6,7,8,14

51:21 52:15 54:4

54:5,13 58:16,21

59:1,3,8 60:13,13

60:16,22 61:5,22

65:15 69:4 72:4

74:2 77:17 79:2

81:21 82:6,13,16

84:6 99:14,22

100:1,2,3,6,13,15

101:15,16,21

104:7 105:4,9

107:3,5,7,11,20

108:1,20 109:16

109:17 112:6

115:9 117:8,8,16

119:2,8,17,17

120:2 121:13,19

125:2 126:2,10

127:4

analyze 30:11 50:4

116:14

analyzed 30:7

46:18 50:12,21

analyzers 74:11

analyzes 107:14

analyzing 18:12

110:3

and/or 54:16

annual 34:4 60:17

60:19 69:6 82:12

83:4 93:7 102:3

102:14

annually 95:18

answer 14:6 15:16

42:11 114:11

117:2 124:19

anybody 122:1

anyway 106:16

apartment 79:19

appear 125:18

Appendix 17:17

appliance 2:5 21:8

27:14 37:7 38:15

39:17,19 68:3

104:2

appliances 21:5,12

21:21 23:6 24:17

25:3,19 26:14

38:3,5 64:19 80:2

80:5 85:16 86:4

86:15 87:8 94:13

94:14,16 99:16

application 74:8

77:19,21,22 78:11

79:16,21 80:13

applications 69:15

74:4,5 77:8 91:15

applied 37:10

60:14

apply 45:7 122:18

123:2

applying 59:10

116:20

appreciably 95:12

appreciate 9:11

14:1 113:21

127:19

appreciated 129:5

approach 27:21

59:8 60:22 72:2

83:17 84:10,13,14

84:17 107:18

115:10,11 119:7

119:10 120:1

appropriate 8:9

9:10 52:1 57:2

94:8 104:14 108:2

110:11

appropriately

121:14

approved 92:11

area 30:10 109:11

Armstrong 1:14

11:5 25:9,12,15

26:1 42:9 54:11

56:4,5 113:11

124:17 125:11
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126:5 127:6

arranged 42:22

arrangement 71:21

Ashley 1:14 25:8

25:10 26:1 42:9

56:4,5 124:17

125:8 126:5,21

ASHRAE 15:2

17:18,19 28:8

41:4 79:21

asked 94:20 127:2

asking 25:2,17 73:9

74:10 106:8

asks 21:22 22:4

aspects 6:19 8:4

18:7 96:1

assembled 58:10

asserted 42:1

assess 72:5,5 74:2

109:18 119:12

assessment 3:6,7

31:3,9,22 32:9

36:9 51:10 116:18

associated 47:6

69:16 70:7 74:7

association 91:20

128:3

assume 13:16 78:3

120:16

assuming 77:20

assumptions 85:20

104:14

attempted 52:14

attending 129:2

attributes 16:4

attrition 94:15

audio 6:7

authority 15:13

19:22 124:20

automatic 14:9

availability 90:10

available 45:13,18

47:21 50:16 61:7

100:22

Avenue 1:10

average 38:8 82:14

109:12

avoided 119:4

aware 28:8 46:12

73:10 104:8

Awareness 2:5

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back 4:21 6:13 8:11

12:1 16:18 26:10

52:16 55:11

113:14 114:15

125:19 128:15,19

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barber 78:21 79:6

base 82:15 96:4

100:7 102:5,9,12

106:7

baseboard 75:5

based 12:11 17:18

20:9,15,21 25:16

51:9 54:8 62:16

65:1 70:11 95:19

100:15 101:7

106:14 112:12,15

121:4

baseline 50:2,20

51:3,6,8 59:7 82:8

82:13

basically 17:16

19:3,20 22:4

28:18 74:17

basis 68:5

becoming 23:5

24:2

beginning 92:17

100:8

behalf 129:1

believe 19:12 24:5

35:6 43:14 72:13

93:2 125:5

beneficial 96:12

benefit 97:7

benefits 115:13

Berkeley 2:3,4

58:18 66:19 73:22

75:12 114:17

best 117:10

better 64:9

beyond 83:21

120:18

biannual 33:6

bias 98:4

big 62:17 95:16

118:11

bill 51:11,15

binding 13:13 35:8

bit 5:13 11:1 18:21

29:11 43:6 47:17

49:9 56:17

blower 38:18,22

blowers 38:20

board 28:15 59:14

boiler 2:2 4:21 5:18

7:17,22 9:19

19:15 24:5 31:11

35:6 37:3 43:11

46:11 50:10 51:12

52:6 55:15 60:7

61:1,15,22 62:5,6

62:6,17 63:6

65:20 69:8 70:11

70:15,17,17,20,22

71:10,15,18 72:17

72:18 74:3,20

75:3,15 76:13,19

77:7,18 78:4,5

79:5 84:8 85:11

87:20 89:2,9,12

91:5 93:4,5,16

100:12 101:10

102:8 103:1

104:16 106:10

108:12,14,15

111:5,13,16 113:3

113:10 127:22

boilers 1:3 4:10,11

5:10 6:18 7:8 8:4

10:12 11:12,22

12:14 18:22 19:13

19:14 20:1,2,7,19

20:21 21:18 23:2

27:4,16 30:8

31:14,21 32:19

33:13 34:5,9 37:5

39:9 46:3 50:2,12

52:2 53:13 55:13

57:4,8 59:12,17

60:18 61:12,13

62:13 64:5 69:8

69:11,14,17,22

70:10 73:10 79:18

82:5 84:16,20

86:17 88:8,21

89:18 90:8 92:9

94:9 97:15,15

98:19 99:7 100:16

100:17 108:3

109:6 111:1,11,18

120:15,19,21

121:2 128:10

bottom 122:9

boundary 103:18

box 24:16 93:13

104:12 105:14

118:16

boxes 7:1 29:3

56:19 118:16

BPM 46:3

bridge 125:5

bring 58:6 122:3

brings 16:20 21:13

Britain 10:13

broken 20:8

Brookhaven 34:2

Brookman 1:10,13

4:3,14 5:1 7:10

9:13 10:20 11:7

11:15 13:2,14

14:2 15:10,17

16:15,19 22:12

23:13 24:11,15

25:8 26:9,15,21

28:4 29:1 30:3,14

32:13,20 33:7,18

35:3,12,18 36:6

36:19 38:10 39:10

40:17,20 41:12,17

42:5 43:1,4 44:2

45:8,22 46:7,21

47:13 49:13 52:11

54:1,20 56:4,18

57:15,18 58:12

60:9 61:17 62:9

63:2,9,19 64:3

65:11,19 66:9,13

66:16 67:5,22

69:1,18 71:6 72:9

73:2,20 75:10,19

75:22 76:8,21

77:5 78:17 79:12

80:17 81:1,14,17

83:18 84:3,22

87:1,16 88:5,14

88:18 91:9 93:12

93:20 94:5,17

95:20 96:16 97:12

97:17 98:7,13,16

99:12,19 101:12

103:4,7 104:11,18

105:7,13,18

106:20 108:4,19

108:22 109:13

110:18 112:4,20

113:14 114:3,5,13

115:14 116:16,22

117:22 118:15

119:9 120:3 121:6

121:18,21 123:5

123:19 125:21

127:11 128:12

129:18

brought 120:12

BTU 19:11 78:4

BTUs 78:6

bubble 96:8

building 4:12 37:9

builds 101:21

built 46:13

bullet 21:4

burden 9:17 16:7

24:8 42:13 45:17

110:1,15 113:17

113:19,22

burdensome 42:21

43:9,21

burn 68:4

burning 118:13

business 96:11
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110:17,22 111:16

113:6,7,9

businesses 111:14

111:19 114:7

Busse 2:2 4:20,20

35:5,5 41:14,14

43:5,5 46:9,9 47:1

54:3,3 76:9,9

Butcher 34:2

BWH 72:16

C

calculate 100:10

102:3 124:14

calculated 38:7

102:19 115:1

calculation 37:3,4

37:11 38:12

calculations 86:9

call 29:13 35:1

71:16 92:10

called 75:1

calls 19:13

Canada 46:13

candor 129:5

capabilities 69:9

capacity 22:2 52:4

67:17 76:3 80:4

119:4

capital 126:14

capture 123:18

carbon 41:9,10

115:8

care 106:11

Carlo 82:17 83:15

83:21

carries 125:2

case 14:17 40:16

46:10 53:1 56:8

64:12 65:9 67:15

68:19 75:15 85:8

100:7,7 102:5,12

102:13 107:18

121:12

cases 9:3 43:15,19

47:9 48:13 74:21

75:17 82:9 91:7

100:21 102:6,9,10

cash 110:3

cast 58:5

casts 32:2

categorized 27:4

Catherine 2:6

30:17,21 107:6

caused 73:7

caution 47:20

ceiling 55:6

Census 61:3

center 32:17

cents 117:21

certain 8:4 9:5

31:20 55:6,16

58:7 93:6 111:21

122:18

certainly 7:14

10:14 11:9 23:17

30:7,9 33:13 35:1

37:17 38:14 43:3

47:21 48:20 55:10

65:14 68:2 80:7

86:2 89:15 109:11

112:11 123:10

certification 64:21

CFR 19:16

chain 54:16

chains 45:12

chance 4:17 125:16

change 34:10 56:12

65:2 67:13 68:7

91:6 95:1 96:12

119:5 120:14

129:13

changed 7:19

changes 34:11 50:1

51:1 86:11,16

95:18 104:15

126:13

changing 96:3

129:17

channel 35:10

59:19,20,22 60:4

channels 32:12

35:21 59:10,12

characteristic

85:18

characteristics

42:16 52:5,8

57:20 58:1 62:15

71:2

characterize 54:12

59:4 84:8 100:16

characterizing

31:13 59:9 82:19

chart 13:4

check 35:1 93:8

chemical 64:1,7

123:11

chemicals 86:13

chemistry 67:12

chime 112:21

circulating 70:15

71:17

clarify 29:12

class 12:11 20:13

21:7 22:4 27:18

28:2 50:9 51:21

52:1,6,10 57:22

100:8 101:8,20

120:20

classes 12:7 20:7,8

21:3 22:1,6 24:18

29:6 30:6 71:5

108:18

classification 113:5

clear 124:7

clearly 30:12 33:11

48:15 55:5 65:17

89:8 109:4

climate 60:21

close 16:12 63:19

closed 26:3

closer 76:22

closes 128:21

closing 3:19 122:2

closure 122:4

coal 118:13

Codes 5:7

codified 12:4

coefficient 96:13

coil 70:20 71:18

74:16 76:13

colleagues 30:1

collect 35:19 70:10

collected 33:12

collecting 71:3

combination 14:11

21:5,8,11,21

24:17 25:3,19

26:13,19 27:16

29:5 69:8,12

70:17

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

150

Framework for Residential Boilers

US DOE

03-13-13

Washington, DC