Ms. Brenda Edwards,

U.S. Department of Energy, Building Technologies Office, Mailstop EE

– 2J,
Framework Document for Commercial Packaged Boilers, Docket No. EERE

– 2013

– BT

– STD

– 0030 and/or RIN 1904

– AD01, 1000 Independence Avenue SW. Washington, DC 20585

– 0121

Re: Response to Framework document docket number EERE

– 2013

– BT

– STD

– 0030 regulatory identifier number (RIN) 1904

– AD01

Dear Ms. Edwards,

HTP, Inc. is a manufacturer of Advanced Heating and Hot Water Systems based in East Freetown, Massachusetts. We welcome the opportunity to participate in the Framework sessions which will shape the future of the Commercial Packaged Boiler industry for the foreseeable future. In this document you will find HTP’s input for the questions identified in the provided document RIN: 1904-AD01.

Please note that HTP provided a response of “No comment provided” in response to several questions. We provided this response as we felt that A) HTP believes the requested information is of a confidential nature or could be used to determine confidential information, B) HTP operates in the high efficiency segment of the market and prefers to answer questions within our sphere of knowledge and experience, 3) Due to the numerous regulation related activities ongoing, we have not had sufficient time to research several topics in order to provide a significant response.

Our responses are presented below, following each of the items for which the Department requests input.

Item 2- 1 DOE welcomes comment on the proposed scope of coverage and on whether there are any additional types of commercial packaged boilers that should or should not be included in the scope of this rulemaking.

HTP considers the scope of Commercial Packaged Boilers to be adequate for the foreseeable future. HTP encourages the Department to further delineate their sub classification based upon size to reflect the findings in the recent ASRAC Working group meetings where, products ≥ 300,000 BTU/h and < 2,500,000 BTU/h are considered “Small”, ≥ 2,500,000 BTU/h and < 5,000,000 BTU/h are considered “Medium”, and products ≥ 5,000,000 BTU/h are considered “Large”.This delineation matches well with the current Departme nt’s explanation, and has the following

benefits: 1) The availability of laboratories and facilities to conduct testing of products was determined to have similar break points. Most laboratories could test up to 2,000,000 BTU/h, while few labs were able to test products above 5,000,000 BTU/h. 2) The difficulty of testing products to the current BTS-2000 apparently increases with the increasing input rate. It is foreseeable that a different Method of Test may be required at one of these higher breakpoints in the future. 3) The manufacturer’s cost of testing these products increases proportionally to the cost of the fuel consumed, as do the operational costs. However, the complexity of the installation also increases significantly as the size of the unit increases. As the installation complexity increases, the representative performance measured by a Method of Test becomes less accurate. Therefore, the Department has the opportunity to continue requiring only Combustion Efficiency above 5,000,000 BTU/h but to consider another metric between 2.5 and 5 million BTU/h.

Item 2- 2 DOE welcomes comments regarding the need to include electric commercial packaged boilers in this rulemaking.

HTP encourages the department to include electric products to this rule making and expects the greatest impact to be in the standby and off mode power consumption of these products.

Item 2- 3 DOE requests comment on pursuing standby mode and off mode energy conservation standards for commercial packaged boilers.

HTP encourages the Department to adopt the same IEC 62301 requirements as the Residential Boiler products report.

Item 2- 4 DOE welcomes comment as to whether there are any size-related issues with conducting testing under the DOE test procedure which the agency should consider addressing in its test procedure rulemaking. DOE is also interested in any comments regarding whether there is a capacity limit beyond which amended energy conservation standards would not be technologically feasible and economically justified..

HTP recognizes there are limitations with the current BTS-2000 Method of Test and is working
within the AHRI Boiler Technical Committee to first understand the various issues manufacturers have and then to update this standard with respect to those issues.

As a part of this, HTP encourages the Department to further delineate their sub classification based upon size to reflect the findings in the recent ASRAC Working group meetings where, products ≥ 300,000 BTU/h and < 2,500,000 BTU/h are considered “Small”, ≥ 2,500,000 BTU/h and < 5,000,000 BTU/h are considered “Medium”, and products ≥ 5,000,000 BTU/h are considered “Large”.

This delineation matches well with the current Department’s explanation, and has the following
benefits:1) The availability of laboratories and facilities to conduct testing of products was

determined to have similar break points. Most laboratories could test up to 2,000,000 BTU/h, while few labs were able to test products above 5,000,000 BTU/h. 2) The difficulty of testing products to the current BTS-2000 apparently increases with the increasing input rate and heating medium. It is foreseeable that a different Method of Test may be required at one of these higher breakpoints in the future. 3) The manufacturer’s cost of testing these products increases proportionally to the cost of the fuel consumed, as do the operational costs. However, the complexity of the installation also increases significantly as the size of the unit increases. As the installation complexity increases, the representative performance measured by a Method of Test becomes less accurate. Therefore, with this delineation, the Department has the opportunity to continue requiring only Combustion Efficiency above 5,000,000 BTU/h but to consider another metric
b etween 2.5 and 5 million BTU/h. Alternatively and pending the Department’s findings in this area, it may be understandable that products above 5 million BTU/h may not be feasible to test, while combustion efficiency may be the only economical options for those products between 2,500,000 and 5,000,000 BTU/h.

Item 3- 1 DOE welcomes comment on all aspects of the current DOE test procedure for commercial packaged boilers and on whether the test procedure is in need of updates or

revisions. HTP recognizes there are limitations with the current BTS-2000 Method of Test and is working
within the AHRI Boiler Technical Committee to first understand the various issues manufacturers have and then to update this standard with respect to those issues.

HTP recognizes the input from several third party bodies which request additional data in order to better understand the variable loading efficiency of Commercial Boilers with respect to modulating firing rate and varying delta T’s. While HTP supports higher efficiency products and buildings, it is HTP’s position that any regulation requiring manufacturers to provide sufficient testing to satisfy these third parties would be overly burdensome to manufacturers and would in fact slow product development, product innovation, and hence adoption of higher overall efficiencies. HTP recommends the Department maintain the current course of action by: 1) requiring a single data point to meet efficiency requirements, 2) allowing the market to decide the amount of additional testing manufacturers will provide.

Item 3- 2 DOE requests feedback on issues or problems with the current test procedure that may make it burdensome or infeasible for manufacturers to conduct testing on some or all models of commercial packaged boilers. Specifically, DOE requests comment whether the operating pressures required by BTS-2000 are not achievable for any commercial packaged boilers within the scope of this rulemaking.

HTP agrees that there are several issues within the current BTS-2000 which require attention. Due to the importance of these issues, Phillip W. Stephens has volunteered to Chair a working group within the AHRI Boiler Technical Committee to update this standard.

HTP supports field verification for only the combustion efficiency metric due to variation in installations and difficulty in maintaining adequate test conditions for any significant duration. It is noted that a tolerance must be provided for combustion efficiency to allow tuning for ignitions depending upon local installation venting and environmental conditions.HTP also supports the use of the thermocouple grids shown in Figure 9 of the BTS-2000 with the

following modifications:
Round Vents

1. A 5 thermocouple grid is sufficient for diameters 2 inches and smaller.

2. The 9 thermocouple grid is sufficient for diameters larger than 2 inches and including 6
inches.

3. The 17 thermocouple grid is sufficient for diameters larger than 6 inches. Rectangular Vents

a. Rectangular vents should use the thermocouple locations identified in Diagram 1 of Figure 2 of the ASHRAE 103-1993 standard.

HTP does not recommend the specification of excess air requirements within the standard as this depends upon the technology employed in the combustion system and would inherently
limit future innovation.

HTP’s concerns are that several operating conditions are either not specified or are excessively unrealistic for products in this category:

 The 180°F outlet water temperature requirement. New installations often incorporate lower temperature heating requirements.

 The 100°F temperature difference (Delta T) requirement for condensing boilers. This temperature difference is not seen in installations of condensing boilers and seldom seen in the replacement market.

 Up to a 145°F Delta T for non-condensing boilers. This temperature difference is not
seen in installations.

 Standard laboratory conditions are not specified.

 It is HTP’s understanding, based upon communication with other manufacturers during AHRI and ASRAC WG meetings that the issues with operating pressure are predominately related to the steam pressure required during the test.

Item 3- 3 DOE requests feedback on testing conditions within the current test procedure that may need to be refined to ensure fair comparison of efficiencies across commercial packaged
boiler models.

HTP proposes that all Commercial Boilers be tested to the following: Environmental Conditions (taken from ASHRAE 103)

 Temperature of 70

– 85°F with no more than a 5°F variation during any 15 minute segment of the test. It is noted that Table 1 currently lists both the Room Air and Test Air range of readings as 30-100°F.

 Relative Humidity not to exceed 80% during the test. This parameter is currently not specified in the BTS-2000.

Test Parameters

 Re turn water temperature of 80°F ±5°F

 Supply water temperature of 120°F ±5°F (nominal 40°F Delta T)

Item 3- 4 DOE welcomes comment on alternative industry test methods for determining the efficiency for commercial packaged boilers, particularly with regards to how an alternativestandard would improve or not improve upon the current test procedure based on BTS-2000,

and on the comparability of efficiency ratings determined using the alternative standards to
those from a BTS-2000 test.

HTP considers it important to discuss this topic with respect to the ranges of input identified previously.

For inputs up to and including 2,500,000 BTU/h Based upon discussions to date with various manufacturers at ASRAC and AHRI meetings, HTP is committed to updating the BTS-2000 standard.

For inputs greater than 2,500,000 BTU/h but less than 5,000,000 BTU/h HTP recommends maintaining harmonization of the efficiency metric and method of test to the extent possible and therefore is committed to updating the BTS-2000 standard for hot water boilers within this range of products. However, it is recognized that alternative technical standards may be more appropriate and available for steam boilers within this range of input. As HTP does not operate in the steam segment of the industry, we defer to other
manufacturer’s recommendations.

For inputs including and greater than 5,000,000 BTU/h Based upon discussions to date with various manufacturers at ASRAC and AHRI meetings, HTP supports requiring only combustion efficiency testing until systems level (entire building) efficiency methods are determined in the future.

Item 5- 1 DOE welcomes data that would contribute to the market assessment, including but not limited to information on national historical shipments, distribution channels, and manufacturer market shares of commercial packaged boilers.

No comments provided

Item 5- 2 DOE welcomes comment on the listed national trade associations for commercial packaged boilers. Specifically, are there trade associations not listed here that should be
included?

No comments provided

Item 5- 3 DOE welcomes comments on its considered equipment classes. Are there any other performance-related features that should be considered for commercial packaged boilers equipment classes?

As stated previously, HTP recommends the following delineation for sub categories of gas-fired hot water, gas-fired steam, oil-fired hot water, and oil-fired steam: “Small” For inputs from 300,000 BTU/h up to and including 2,500,000 BTU/h “Medium” For inputs greater than 2,500,000 BTU/h but less than 5,000,000 BTU/h “Large” For inputs including and greater than 5,000,000 BTU/h

HTP expects electric boilers, if requiring classification, to be classified by the range of kilowattage and the amperage required for operation with respect to building codes.Item 5- 4 DOE welcomes comments on the technologies identified, as well as any additional

technology options which have not been identified.

HTP provides the following supporting commentary:

 In addition to achieving higher efficiencies, pre-mixed combustion systems also result in significantly reduced emissions.

 De -rating a combustion system is equivalent to over-sizing a heat exchanger and has only limited application as the cost of the heat exchanger is significant in the over-all cost of the product.

 Pulse combustion has proven to be difficult in the field due to variation in venting
arrangements.

 For modulating boilers, additional technical distinction can be made with respect to the mixing of the fuel and air. This is accomplished through several technologies including simple venturies, swirl plates, and servo driven orifice valves. The choice of technology determines the maximum turn down ratio (high firing rate/low firing rate) possible and is a significant parameter in the overall efficiency as identified on page 28 of the
framework document.

Item 6- 1 Of the technologies listed in section 5.4, are there any that should be screened out based on the four screening criteria? If so, which criteria apply and why?

HTP considers the choice heat exchanger construction materials and venting methods to be a minor factor in the Department’s analysis and provide information for financial comparisons. HTP believes that, until significant innovation is achieved, only certain materials are advisable for products designed to achieve the higher efficiencies gained through capture of the latent heat available in the flue gas.

De -rating a combustion system is equivalent to over-sizing a heat exchanger and has only limited application as the cost of the heat exchanger is significant in the over-all cost of the product.

Additionally, the following opportunities have known reliability issues in the field:

 Pulse combustion has proven to be difficult in the field due to variation in venting arrangements and HTP currently considers this technology as not sufficiently robust for the market place.

 Air pre-heaters and economizers typically provide marginal improvement yet increase costs and would be anticipated to be employed on lower efficiency products in order to achieve slightly higher efficiencies should the minimum allowable efficiency be
increased.

 Hot-surface igniters are typically more fragile than other ignition types and are
therefore less common.

 Cast Iron field issues

Item 7- 1 DOE seeks input regarding the range of efficiency levels and any key efficiency levels that should be examined as part of its analysis.Currently approximately 18% of the Commercial Water Boilers listed on the AHRI directory have

a Thermal Efficiency of 94% or greater. While this percentage proves that high efficiency is both technically possible and that the market accepts these products, HTP is confident that efficiencies above 97% are within the capabilities of current technology and will become common place in the near future.

HTP encourages the department to review AHRI’s historical updates of their database to identify what efficiency levels new products are being released with to identify the trends manufacturers are following with respect to this question.

Item 7- 2 DOE seeks comment on the appropriate max-tech levels for commercial packaged
boilers.

HTP is currently developing a MaxTech prototype Commercial Boiler using currently available components and will maintain communication with the Department on our progress in this endeavor. Similarly, there are several products listed with efficiencies at or above 98% TE.

Item 7- 3 DOE seeks input on the representative capacity and other representative characteristics for each commercial packaged boiler equipment class.

As stated previously, HTP recommends the following delineation for sub categories of gas-fired hot water, gas-fired steam, oil-fired hot water, and oil-fired steam: “Small” For inputs from 300,000 BTU/h up to and including 2,500,000 BTU/h “Medium” For inputs greater than 2,500,000 BTU/h but less than 5,000,000 BTU/h “Large” For inputs including and greater t han 5,000,000 BTU/h

An inspection of data downloaded from the AHRI Commercial Boiler database with Water chosen as the heating medium, and based upon products with a Thermal Efficiency of 94% or
greater:

84% would be within the proposed “Small” category 14% would be within the proposed “Medium” category 2% would be in the proposed “Large” category.

It is noted that this information also provides supporting data for HTP’s previously noted position with respect to the appropriate Method of Test.

Further inspection of the data also indicates that the range of efficiencies possible has very little variation with respect to the input rate of boiler. This data indicates that products with a TE of 98% are available from the smaller sizes of boilers up through boilers operating at more than 4 million BTU’s/hr. The highest efficiency boiler currently listed in AHRI’s directory (99.1% TE) operates at 2.5 million BTU’s/hr.It is also noted that the existing products in 500,000 BTUH increments shown in the statistics

above indicates a very uniform distribution of models in each identified “bin.” Furthermore, there is a significant difference with respect to the cost of the boiler between a 501 kBTUH and a 999kBTUH boiler. For these reasons, HTP does not recommend the department using a representative capacity within each of these ranges.

Item 7- 4 DOE seeks input on characteristics which may require multiple representative equipment types within a single equipment class.

HTP interprets this question as “DOE seeks input on characteristics, such as fuel source, venting, and draft characteristics, which may require multiple representative equipment types within a single equipment class.” HTP considers the Department’s current breakdown with res pect to fuel sources to be adequate, but does not consider any delineation between venting, natural draft, or forced draft to be required.

Item 8- 1 DOE seeks interested party input on whether the distribution channels described above are appropriate for commercial packaged boilers.

No comments provided

Item 8- 2 DOE seeks input on the percentage of equipment being distributed through the different distribution channels, and whether the share of equipment through each channel varies based on equipment class or equipment capacity.

No comments provided

Item 8- 3 DOE welcomes suggestions and comments concerning its proposed approach to developing estimates of future commercial packaged boiler retail prices.

No comments provided

Item 8- 4 DOE seeks recent data to establish the markups for the parties involved with the distribution of the equipment.

No comments provided

Item 9- 1 DOE seeks input on the planned approach for determining the energy consumption of commercial packaged boilers in commercial buildings.

HTP considers the intended approach reasonable, but would like to note that the origin of the data presented in the cited references should also be considered in the analysis. For example, although the ASHRAE handbooks were recently updated, the hot water usage data presented in their sizing methods may not have been updated within the last ten or more years, depending upon which table is considered. Furthermore, the data presented in the tables has been often been collected on small sample sizes and does not accurately account for a cross section of the entire country. HTP strongly encourages the Department to fund research to update such
fundamental data references on a statistical basis.Item 9- 2 DOE seeks historical shipment-weighted commercial packaged boiler efficiency data or

shipment data by efficiency bins. DOE is primarily interested in obtaining this data during the last 10 years to capture the impact of the most current technologies on the boilers market.

HTP only operates within the high efficiency segments of this market, but defers to AHRI in order to provide the Department with a better understanding of the entire market and assure manufacturer’s confidential information is not shared in the public domain.

Item 9- 3 DOE seeks input on data sources that it can use to characterize the variability in annual energy consumption for commercial packaged boilers. DOE is particularly interested in field monitoring studies and data.

HTP has not been involved in commercial field studies to assist with this aspect of the request.

Item 9- 4 DOE requests comment on what other energy use by commercial packaged boilers should be included in the energy use analysis.

HTP recognizes there are two distinct ranges where the approach that the department is considering may be problematic. As with other product categories, the distinction between Commercial Water Heaters and Commercial Packaged Boilers is at best blurry at the lower input ranges; specifically below one million BTU/h, but more prevalent below 500,000 BTU/h. There will therefore be more uncertainty in this range of products.

For products with inputs above approximately 5 Million BTU/h, the dominate metric reported is combustion efficiency, with little data as to the Thermal Efficiency of the appliance. As the Thermal Efficiency should be lower than the Combustion Efficiency, HTP expects a statistical relationship between the two parameters to exist at higher inputs.

HTP does note that due to uncertainty in measurements and the effects of condensation, the Combustion Efficiency is sometimes measured to be lower than the Thermal Efficiency in higher efficiency products, as can be identified in the AHRI database.

Item 9- 5 DOE welcomes comment on whether the rated thermal efficiencies for all commercial packaged boiler equipment should be adjusted to reflect return-water conditions (previously done for condensing boilers only).

HTP encourages the department to apply such corrections across the entire product category and to recognize that all products are occasionally installed in buildings which will not allow the products to operate at their highest possible efficiencies.

Item 9- 6 DOE seeks input on what fractions of hot-water commercial packaged boilers are used both for space heating and hot water.

No comments provided

Item 9- 7 DOE seeks input on the fraction of commercial packaged boilers used in residential applications. Is this market large enough that DOE should take it into account?Boilers up to 400k are known to be installed in large scale residential applications. However,

HTP does not have any quantitative data to identify the number of such applications.

Item 9- 8 DOE seeks comments on the rebound effect that may be associated with moreefficient commercial packaged boilers.

HTP is not aware of a rebound affect in this market segment.

Item 10- 1 DOE seeks interested party input on its proposed approach of using probability distributions and Monte Carlo simulation to conduct the LCC and PBP analysis.

No comments provided

Item 10- 2 DOE requests data from interested parties to characterize the current mix of commercial packaged boiler efficiencies in the market.

No comments provided

Item 10- 3 DOE seeks input on the planned approach for estimating future energy prices.

No comments provided

Item 10- 4 DOE seeks interested party input on the maintenance and repair costs approach. Specifically, DOE requests comment on frequency and cost of maintenance, major repair issues, repair frequency, and repair costs for commercial packaged boilers that meet the minimum efficiency standards, as well as for higher-efficiency boilers.

No comments provided

Item 10- 5 DOE seeks interested party input on its proposed installation cost approach. Specifically, DOE requests data on the fractions of installations that would entail significant additional installation expenses.

No comments provided

Item 10- 6 DOE seeks comments on the methodology used to determine equipment lifetimes for commercial packaged boilers.

HTP is very concerned that sufficient current data is not available to accurately provide a Weibull distribution to each of the different heat exchanger constructions, fuel types, and different sizes of the products. At the least, the available data would not represent recent technologies in the industry. The inherent error (mathematical uncertainty) in this portion of the analysis would have significant implications on other aspects of the analysis.

A brief examination of the ASHRAE database ( xp20. ashrae .org/publicdat abase/ ) searching for a System Type of “Heating” identified only two classes of boilers have sufficient numbers of replacement data to provide a resemblance to statistical accuracy; Boiler/steel/water

tube/forced draft/hot water and Boiler/steel/water

- tube/natural draft/hot water. What is moreconcerning is the fact that there are no recorded replacements of cast iron boilers in this

database.

A more in-depth review of the ASHRAE data is possible by downloading the dataset related to this query. Upon inspection, data integrity is questionable at best as one “Heat Exchanger/Vertical Bore” is listed as being removed sixteen years before it was installed. Additionally, no product has been installed or failed since 2004.

Review of the “Screening Analysis for EPACT Covered Commercial HVAC and Water Heati ng Equipment.” PNNL13232 by Pacific Northwest National Laboratory identified that the amount of water used in this analysis was based upon Handbook of HVAC Applications (ASHRAE 1995), Chapter 45, Table 7 which is based upon data generated by Werden and Spielvogel in an EEI sponsored research project from 1969. Significant changes to all aspects of building construction and appliance efficiencies have changed since that point in time.

HTP does not recommend the identified methodology. Furthermore, HTP recommends that the DOE fund research to update the hot water consumption in commercial buildings to improve future rulemaking analysis.

Item 10- 7 DOE seeks interested party input on its planned approach for estimating discount
rates for commercial customers.

No comments provided

Item 10- 8 DOE requests data on the efficiency distribution and welcomes comment on the likelihood and degree of improvement in efficiency of commercial packaged boilers in the next 5 to 10 years as a result of market forces or industry trends (in the absence of amended energy conservation standards).

HTP believes that while regulations establish the minimum allowable efficiency, and hence the lowest cost products; rebate programs serve to entice manufacturers to attain higher product efficiencies. Manufacturers understand that these rebate programs are only temporary incentives and must be periodically renewed. As federal and state budgets for incentives are debated each year, there is significant uncertainty in the rebate programs each year. Therefore, in the absence of amended energy conservation standards, further improvements in the efficiency of commercial packaged boilers are uncertain at best.

Without amended efficiency requirements, the likelihood of further improvements in the nation’s resource utilization is uncertain. Similarly, without regulation, the environmental impact of lower efficiency products will continue to be a significant contributor to pollution. For this reason, HTP supports the advancement of minimum efficiency requirements and more stringent limitations upon NOx emissions.

Item 11- 1 DOE welcomes comment on the shipments projection methodology.

No comments providedItem 11- 2 DOE invites comments regarding the selection of appropriate economic drivers and

sources of data for historical shipments and shipment breakdowns by equipment class.

No comments provided

Item 11- 3 DOE seeks historical commercial packaged boiler shipments data from interested parties, disaggregated by equipment class and efficiency level if possible.

No comments provided

Item 11- 4 DOE seeks input from interested parties on the potential impact of amended standards on commercial packaged boiler shipments.

HTP does not expect increases in minimum efficiencies to significantly impact shipments of Commercial Packaged Boilers.

Item 12- 1 DOE seeks comments on the appropriate assumptions to use regarding long-run changes in commercial packaged boiler energy efficiency independent of amended energy
conservation standards.

HTP recommends that the Department evaluate the two cases of “With Current Rebate Values” and “Without Rebates” to better understand the long term impacts of this decision.

Item 12- 2 DOE requests comment on whether it should pursue a roll-up or shift approach for the national impact analysis.

HTP expects that correction in the distribution of efficiencies would be a combination of these

two cases.

Item 13- 1 The Department requests input as to what consumer subgroups are appropriate to evaluate for commercial packaged boilers.

HTP supports the consideration of subgroups and recommends that the Department include the adaptation of LEED and Building Level Efficiency as a subgroup as this aspect of efficiency improvement continues to become more popular.

In conclusion, HTP supports the advancement of our country ’ s natural resource utilization through higher minimum efficiency requirements in the product classes related to this framework document. If you have any questions, or we can be of further service, please contact

me.

Sincerely, 

## Phillip W. Stephens, P.E.

Phillip W. Stephens, P.E. VP Engineering, HTP, Inc.

774-271-3158