### DOE Proposed Determination of Coverage: Proposed Determination of Natural Draft Commercial Packaged Boilers as Covered Equipment

Docket Number E E- 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

com mercial 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 pr oper 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