DOE Proposed Determination of Coverage: Proposed Determination of 

Natural Draft Commercial Packaged Boilers as Covered Equipment

Docket Number EE-2013-BT-STD-0030 (Federal Register, August 13, 2013, 

pp. 49202-49207)

• DOE should promulgate the definition for “natural draft commercial packaged 

boiler” as proposed in the Proposed Determination of Coverage. Minimum 

efficiency standards coverage of these products without a formal definition is a 

clear deficiency in the formal standards process, especially since ASHRAE 

Standard 90.1, the origin of the minimum efficiency requirements, does not itself 

present a robust definition to cover these products.

• The large market presence of natural draft commercial packaged boilers, 

representing 41% of models among commercial packaged boilers overall and a 

DOE-estimated 36,000 units shipped annually, suggests the continued 

importance of separate rulemaking treatment of these products.

• DOE’s concerns relating to potential substitution effects from a lack of explicit 

coverage of natural draft commercial packaged boilers are justified, and these 

effects should be avoided. Maintaining differentiation of natural draft commercial 

packaged boilers is key to that end. Promulgation of efficiency standards for 

“commercial packaged boilers” (i.e., without differentiation of product class 

according to venting system type) would likely lead to elimination of natural draft 

commercial packaged boilers in pursuit of highest minimum efficiency levels and 

violate EPCA prohibitions against Federal minimum efficiency standards that 

would result in the unavailability in the U. S. of any covered equipment type “of 

performance characteristics (including reliability), features, sizes, capacities, and 

volumes that are substantially the same as those currently on the market (42 

U.S.C. 6295(o)(4)...”1

 With respect to differentiating aspects of natural draft 

commercial package boilers, venting system type is a key “feature” with respect 

to this EPCA language since venting systems are outside of the direct regulation 

of equipment efficiency standards and yet have significant importance in the 

costs of equipment installation and building design.

• Opportunities to advance technological approaches for higher efficiency natural 

draft commercial packaged boilers have not been pursued in recent years and 

need to be investigated. Since promulgation of minimum Federal requirements 

under EISA 2007, Federal activities to review design options for these products 

have not progressed. It is anticipated that technological solutions developed for 

 

1 “Energy Conservation Standards Rulemaking Framework Document for Commercial Packaged Boilers,” RIN: 

1904-AD01, U. S. Department of Energy, August 28, 2013.
other natural draft gas-fired equipment may have merit in maintaining proper 

venting in higher efficiency levels for natural draft commercial packaged boilers.

• Development of test procedures for natural draft commercial packaged boilers 

should be pursued in order to more comprehensively evaluate efficiency of these 

products and their efficiencies relative to completing products, including 

mechanical draft commercial packaged boilers. In particular, overall efficiency in 

terms of both fuel efficiency and electrical efficiency need to be considered for 

better representation of relative efficiencies. Furthermore, the proper 

representation of efficiency in terms of full fuel cycle efficiency for both primary 

fuels and grid electricity need to ultimately be considered. Robust test 

procedures and energy descriptors under those procedures represent best the 

starting point for that effort.

Sincerely,

Gary Heikkinen

Gary Heikkinen, PE

NW Natural

Portland, OR 97209