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 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. 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 

between 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 

 Return 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 alternative 
standard 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. 
Bin Frequency % Cumulative %

500 50 20.0% 20.00%

1000 67 26.8% 46.80%

1500 43 17.2% 64.00%

2500 50 20.0% 84.00%

5000 35 14.0% 98.00%

More 5 2.0% 100.00%

93.0

94.0

95.0

96.0

97.0

98.0

99.0

100.0

0 1000 2000 3000 4000 5000 6000 7000

Thermal Efficiency (%)

1,000's BTU/hour

TE vs 1,000 BTU/h

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 than 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 respect 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/publicdatabase/) 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/watertube/forced draft/hot water and Boiler/steel/water-tube/natural draft/hot water. What is more 
concerning 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 Heating 

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 provided 
Item 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