ES-i

EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ACTIVITIES...............................................................1

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSIS AND THE 

PRELIMINARY TECHNICAL SUPPORT DOCUMENT ................................................3

ES.3 KEY RESULTS OF THE ANALYSIS ...............................................................................4

ES.3.1 Market and Technology Assessment .............................................................................4

ES.3.2 Screening Analysis.........................................................................................................9

ES.3.3 Engineering Analysis...................................................................................................10

ES.3.3.1 Equipment Classes Analyzed................................................................. 10

ES.3.3.2 Contractor Price Assessment ................................................................. 10

ES.3.3.3 Price-Efficiency Tables and Baseline Prices for Mechanical Draft 

Commercial Packaged Boilers............................................................... 11

ES.3.3.4 Price-Efficiency Tables and Baseline Prices for Natural Draft 

Commercial Packaged Boilers............................................................... 13

ES.3.4 Markups Analysis ........................................................................................................15

ES.3.5 Energy Use Analysis....................................................................................................17

ES.3.6 Life-Cycle Cost and Payback Period Analysis............................................................20

ES.3.7 Shipments Analysis......................................................................................................25

ES.3.8 National Impact Analysis.............................................................................................26

ES.3.8.1 National Energy Savings........................................................................ 27

ES.3.8.2 Net Present Value of Consumer Benefits .............................................. 29

ES.3.9 Preliminary Manufacturer Impact Analysis.................................................................32

ES.4 ISSUES ON WHICH THE DEPARTMENT OF ENERGY SEEKS PUBLIC

COMMENT.......................................................................................................................33

LIST OF TABLES

Table ES.3.1 Existing energy conservation standards for commercial packaged boilers 

under 10 CFR 431.87...............................................................................................5

Table ES.3.2 New equipment classes along with their current baseline efficiencies....................6

Table ES.3.3 Price-efficiency table for small gas-fired mechanical draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity ...............11

Table ES.3.4 Price-efficiency table for large gas-fired mechanical draft hot water 

commercial packaged boilers at 3,000,000 Btu/h representative capacity ............11

Table ES.3.5 Price-efficiency table for small oil-fired mechanical draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity ...............12

Table ES.3.6 Price-efficiency table for large oil-fired mechanical draft hot water a 

commercial packaged boilers at 3,000,000 Btu/h representative capacity ............12

Table ES.3.7 Price-efficiency table for small gas-fired mechanical draft steam 

commercial packaged boilers at 800,000 Btu/h representative capacity ...............12

Table ES.3.8 Price-efficiency table for large gas-fired mechanical draft steam 

commercial packaged boilers at 3,000,000 Btu/h representative capacity ............13
ES-ii

Table ES.3.9 Price-efficiency table for small oil-fired mechanical draft steam a 

commercial packaged boilers at 800,000 Btu/h representative capacity ...............13

Table ES.3.10 Price-efficiency table for large oil-fired mechanical draft steam 

commercial packaged boilers at 3,000,000 Btu/h representative capacity ............13

Table ES.3.11 Price-efficiency table for small gas-fired natural draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity ...............13

Table ES.3.12 Price-efficiency table for large gas-fired natural draft hot water 

commercial packaged boilers at 3,000,000 Btu/h representative capacity ............14

Table ES.3.13 Price-efficiency table for small oil-fired natural draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity ...............14

Table ES.3.14 Price-efficiency table for large oil-fired natural draft hot water commercial 

packaged boilers at 3,000,000 Btu/h representative capacity................................14

Table ES.3.15 Price-efficiency table for small gas-fired natural draft steam commercial 

packaged boilers at 800,000 Btu/h representative capacity...................................14

Table ES.3.16 Price-efficiency table for large gas-fired natural draft steam commercial 

packaged boilers at 3,000,000 Btu/h representative capacity................................15

Table ES.3.17 Price-efficiency table for small oil-fired natural draft steam commercial 

packaged boilers at 800,000 Btu/h representative capacity...................................15

Table ES.3.18 Price-efficiency table for large oil-fired natural draft steam commercial 

packaged boilers at 3,000,000 Btu/h representative capacity................................15

Table ES.3.19 National Average Markups for Small Commercial Packaged Boilers ..................17

Table ES.3.20 National Average Markups for Large Commercial Packaged Boilers ..................17

Table ES.3.21 Average Annual Energy Consumption and Savings for Small Gas-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers................................19

Table ES.3.22 Average Annual Energy Consumption and Savings for Large Gas-Fired 

Natural Draft Steam Commercial Packaged Boilers .............................................19

Table ES.3.23 Average Annual Energy Consumption and Savings for Small Gas-Fired 

Natural Draft Hot Water Commercial Packaged Boilers.......................................19

Table ES.3.24 Average Annual Energy Consumption and Savings for Small Gas-Fired 

Mechanical Draft Steam Commercial Packaged Boilers.......................................20

Table ES.3.25 Average Annual Energy Consumption and Savings for Small Oil-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers................................20

Table ES.3.26 Average LCC and PBP Results by Efficiency Level for Small Gas-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers................................22

Table ES.3.27 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Gas-Fired Mechanical Draft Hot Water Commercial Packaged Boilers...............23

Table ES.3.28 Average LCC and PBP Results by Efficiency Level for Large Gas-Fired 

Natural Draft Steam Commercial Packaged Boilers .............................................23

Table ES.3.29 LCC Savings Relative to the Base Case Efficiency Distribution for Large 

Gas-Fired Natural Draft Steam Commercial Packaged Boilers ............................23

Table ES.3.30 Average LCC and PBP Results by Efficiency Level for Small Gas-Fired 

Natural Draft Hot Water Commercial Packaged Boilers.......................................23

Table ES.3.31 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Gas-Fired Natural Draft Hot Water Commercial Packaged ..................................24

Table ES.3.32 Average LCC and PBP Results by Efficiency Level for Small Gas-Fired 

Mechanical Draft Steam Commercial Packaged Boilers.......................................24
ES-iii

Table ES.3.33 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Gas-Fired Mechanical Draft Steam Commercial Packaged Boilers......................24

Table ES.3.34 Average LCC and PBP Results by Efficiency Level for Small Oil-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers................................25

Table ES.3.35 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Oil-Fired Mechanical Draft Hot Water Commercial Packaged Boilers................25

Table ES.3.36 Full-Fuel-Cycle National Energy Savings for Commercial Packaged 

Boilers (quads).......................................................................................................28

Table ES.3.37 Net Present Value, Discounted at 3 Percent for Commercial Packaged 

Boilers (billion 2013$)...........................................................................................30

Table ES.3.38 Net Present Value, Discounted at 7 Percent, for Commercial Packaged 

Boilers (billion 2013$)...........................................................................................31

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the Commercial Packaged Boilers 

Standards Rulemaking .............................................................................................2

Figure ES.3.1 Market share of mechanical draft commercial packaged boilers based on 

Air-conditioning, Heating and Refrigeration Institute database ..............................7

Figure ES.3.2 Market share of natural draft commercial packaged boilers based on Airconditioning, Heating and Refrigeration Institute database.....................................8

Figure ES.3.3 Forecasted Shipments for Commercial Packaged Boilers (Base Case).................26
ES-1

EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ACTIVITIES

Title III, Part C1 of the Energy Policy and Conservation Act of 1975 (EPCA), Pub. L. 94-

163 (42 U.S.C. 6311-6317, as codified), added by Pub. L. 95-619, Title IV, §441(a), sets forth a 

variety of provisions designed to improve energy efficiency, and it established the "Energy 

Conservation Program for Certain Industrial Equipment," a program covering certain 

commercial and industrial equipment (hereafter referred to as "covered equipment"), which 

includes the commercial packaged boilers (hereafter referred to as "CPB" or “boilers’) that are

the subject of this rulemaking.

2 Part A-1 specifically includes definitions (42 U.S.C. 6311), 

energy conservation standards (42 U.S.C. 6313), test procedures (42 U.S.C. 6314), labeling 

provisions (42 U.S.C. 6315), and the authority to require compliance information and 

certification reports from manufacturers of covered equipment (42 U.S.C. 6316). This program 

authorizes DOE to establish technologically feasible, economically justified energy conservation

regulations for certain products and equipment that would be likely to result in substantial 

national energy savings.

This Executive Summary presents the preliminary activities that the U.S. Department of 

Energy (DOE) conducted in consideration of amended energy conservation standards for 

commercial packaged boilers. The Executive Summary describes activities and reports key 

results from DOE’s preliminary analyses. Additionally, the Executive Summary delineates issues 

identified during the analyses about which DOE seeks comments, data, and other information

from interested parties. These issues are highlighted in the public meeting presentation and are 

further discussed in chapter 2 of the preliminary technical support document (TSD).

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the column, 

labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how the 

analyses fit into the process and how they relate to each other. Key inputs are the types of data 

and other information that the analyses require. Some key information is obtained from public 

databases; DOE collects other inputs from interested parties or persons having special knowledge 

and expertise. Key outputs are analytical results that feed directly into the standards-setting 

process. The issues on which DOE seeks comment from interested parties derive from the key 

results that are generated by the preliminary analyses. Arrows connecting analyses show the 

types of information that flow from one analysis to another.

 1

 For editorial reasons, upon codification in the United States Code (U.S.C.), Part C was re-designated Part A-1. 2 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act, Pub. L. 112-210 (December 18, 2012).
ES-2

Figure ES.1.1 Flow Diagram of Analyses for the Commercial Packaged Boilers

Standards Rulemaking 
ES-3

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSIS AND THE 

PRELIMINARY TECHNICAL SUPPORT DOCUMENT 

For the preliminary analysis stage, DOE publishes a notice of public meeting (NOPM) in 

the Federal Register, which announces the availability of the preliminary TSD, the date and 

place of the public meeting, and presentation materials that interested parties may review before 

the public meeting. In addition, the NOPM highlights the major analyses DOE developed in the 

preliminary analysis stage. The preliminary TSD describes each preliminary analysis step in 

detail, providing descriptions of inputs, sources, methodologies, and results. The following 

chapters of the preliminary TSD address the analyses performed for the preliminary analysis 

stage.

Chapter 1 - The introduction provides an overview of standards for CPBs and describes DOE’s 

process for setting energy conservation standards.

Chapter 2 - The analytical framework describes each preliminary analysis step, the comments 

received in response to the analytical approaches DOE described in the Framework 

Document, and DOE’s responses to those comments. 

Chapter 3 - The market and technology assessment (MTA) characterizes the relevant equipment

markets and technology options, including prototype designs.

Chapter 4 - The screening analysis reviews each technology option uncovered in the MTA to 

determine whether it is technologically feasible; is practicable to manufacture, 

install, and service; would adversely affect equipment utility or equipment

availability; or would have adverse impacts on health and safety.

Chapter 5 - The engineering analysis develops price-efficiency relationships that show a 

manufacturer’s selling price of achieving increased efficiency.

Chapter 6 - The markup analysis estimates commercial consumer equipment prices based on 

market structures, and the manufacturing costs developed in the engineering 

analysis.

Chapter 7 - The energy use analysis determines the annual energy consumption of the 

equipment under consideration.

Chapter 8 - The life-cycle cost (LCC) and payback period (PBP) analysis discusses the effects 

of standards on individual commercial consumers and users of the equipment and 

compares the LCC and PBP of equipment with and without higher efficiency 

standards.

Chapter 9 - The shipments analysis documents historic unit shipments and forecasts future 

shipments of equipment at potential energy conservation standard levels under 

consideration. 

Chapter 10 - The national impact analysis (NIA) assesses the cumulative national energy savings 

(NES) from potential standards and the net present value (NPV) of consumer costs 

and savings associated with standards at different efficiency levels.
ES-4

Chapter 11 - The consumer subgroup analysis evaluates the effects of potential energy 

conservation standards on subgroups of the population (e.g., small businesses).

Chapter 12 - The preliminary manufacturer impact analysis (MIA) assesses the potential impacts 

of energy conservation standards on manufacturers, such as effects on expenditures 

for capital conversion, marketing costs, shipments, and research and development 

costs.

The remaining chapters of the preliminary TSD describe the analyses to be performed for 

the notice of proposed rulemaking (NOPR) stage:

Chapter 13 - The emissions analysis examines the effects of potential energy conservation 

standards on various airborne emissions.

Chapter 14 - Monetization of emissions reductions quantifies the anticipated benefits from

potential energy conservation standards.

Chapter 15 - The utility impact analysis examines impacts of potential energy conservation 

standards on the generation capacity of electric utilities.

Chapter 16 - The employment impact analysis examines the effects of potential energy 

conservation standards on national employment.

Chapter 17 - A regulatory impact analysis examines the national impacts of non-regulatory 

alternatives to mandatory energy conservation standards.

ES.3 KEY RESULTS OF THE ANALYSIS 

The following sections describe analyses DOE performed for the preliminary analysis

stage and present the key results.

ES.3.1 Market and Technology Assessment

When initiating an analysis of potential energy conservation standards for commercial

equipment, DOE develops information for the equipment and characterizes the market and 

industry structure, evaluating both current and historical information. This activity is primarily 

based on a review of publicly-available information which can be obtained from a variety of 

sources, including manufacturers and trade associations. 

When evaluating and establishing energy conservation standards, DOE generally divides 

covered equipment into classes by the type of energy used or by capacity and/or other 

performance-related features that affect efficiency. Because the current definition of “packaged 

boiler” as defined in 42 USC 6311(11)(B) includes, the terms “shipped complete with heating 

equipment, mechanical draft equipment,” DOE is proposing to clarify its statutory authority 

under EPCA to cover natural draft boilers through a coverage determination. 78 FR 49202 

(August 13, 2013). Accordingly, DOE will maintain separate equipment classes for mechanical 

draft and natural draft CPBs, which will be used presuming that DOE moves to a final coverage 

determination. In addition, DOE has decided to differentiate between CPB equipment classes 
ES-5

based on three performance-related features: (1) size of boiler based on input ratings (small 

(≥300 kBtu/h to ≤2500 kBtu/h) or large (>2500 kBtu/h)), (2) fuel used (gas or oil), and (3) boiler 

output (hot water or steam). Thus, in all, 16 equipment classes were analyzed as part of this 

rulemaking effort. Different energy conservation standards may be applied to different 

equipment classes. 

Existing energy conservation standards, as set forth in subpart E of Title 10 of the Code 

of Federal Regulations, Part 431 (10 CFR Part 431), describe efficiency levels for 10 equipment 

classes. Both the small and large gas-fired steam boilers are currently divided based on draft 

type. Table ES.3.1 below describes the equipment classes established under existing standards. 

The efficiency levels under the existing standards were used as baseline efficiency levels for all 

subsequent analyses covered under the market and technology assessment chapter and the 

engineering analysis chapter.

Table ES.3.1 Existing energy conservation standards for commercial packaged boilers 

under 10 CFR 431.87

Equipment type Subcategory Size category (input) Efficiency level*

Hot Water 

Commercial Packaged 

Boilers

Gas-fired ≥300,000 Btu/h and 

≤2,500,000 Btu/h 80.0% ET

Hot Water 

Commercial Packaged 

Boilers

Gas-fired >2,500,000 Btu/h 82.0% EC

Hot Water 

Commercial Packaged 

Boilers

Oil-fired ≥300,000 Btu/h and 

≤2,500,000 Btu/h 82.0% ET

Hot Water 

Commercial Packaged 

Boilers

Oil-fired >2,500,000 Btu/h 84.0% EC

Steam Commercial 

Packaged Boilers

Gas-fired—all, 

except natural draft

≥300,000 Btu/h and 

≤2,500,000 Btu/h 79.0% ET

Steam Commercial 

Packaged Boilers

Gas-fired—all, 

except natural draft >2,500,000 Btu/h 79.0% ET

Steam Commercial 

Packaged Boilers

Gas-fired—natural 

draft

≥300,000 Btu/h and 

≤2,500,000 Btu/h 77.0% ET**

Steam Commercial 

Packaged Boilers

Gas-fired—natural 

draft >2,500,000 Btu/h 77.0% ET**

Steam Commercial 

Packaged Boilers Oil-fired ≥300,000 Btu/h and ≤2,500,000 Btu/h 81.0% ET

Steam Commercial 

Packaged Boilers Oil-fired >2,500,000 Btu/h 81.0% ET

* ET refers to “Thermal Efficiency,” and EC refers to “Combustion Efficiency.”

**On March 2, 2022 the minimum efficiency standard for small and large gas-fired natural draft steam commercial 

packaged boilers will be 79.0% ET.
ES-6

As noted above, on August 13, 2013, DOE published a notice of proposed determination 

(NOPD) in the Federal Register to confirm its authority to include natural draft commercial 

packaged boilers under its energy conservation standards rulemaking purview. 78 FR 49202. As 

part of this NOPD, DOE has sought feedback from interested parties about DOE’s authority to 

regulate such equipment. If the outcome of the NOPD is ultimately positive, DOE will create 

several new separate equipment classes for natural draft boilers having different energy 

conservation standards. The creation of these classes will add another 6 equipment classes to the 

existing ones described in Table ES.3.1. The rulemaking process conducted under this TSD 

considered all 16 CPB equipment classes for its analyses. Table ES.3.2 shows all 16 CPB 

equipment classes along with their baseline efficiencies. The baseline efficiencies correspond to 

existing energy conservation standards as set forth in 10 CFR 431.87.

Table ES.3.2 New equipment classes along with their current baseline efficiencies

Equipment 

Type Draft Type Fuel Type Size Category Abbreviation Efficiency Standard

Hot Water 

CPB

Natural 

Draft Gas-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SGNDHW 80% (ET)

Hot Water 

CPB

Natural 

Draft Gas-fired Large (>2,500,000 Btu/h) LGNDHW 82% (EC)

Hot Water 

CPB

Natural 

Draft Oil-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SONDHW 82% (ET)

Hot Water 

CPB

Natural 

Draft Oil-fired Large (>2,500,000 Btu/h) LONDHW 84% (EC)

Steam CPB Natural 

Draft Gas-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SGNDST 77% (ET)

Steam CPB Natural 

Draft Gas-fired Large (>2,500,000 Btu/h) LGNDST 77% (ET)

Steam CPB Natural 

Draft Oil-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SONDST 81% (ET)

Steam CPB Natural 

Draft Oil-fired Large (>2,500,000 Btu/h) LONDST 81% (ET)

Hot Water 

CPB

Mechanical 

Draft Gas-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SGMDHW 80%(ET)

Hot Water 

CPB

Mechanical 

Draft Gas-fired Large (>2,500,000 Btu/h) LGMDHW 82%(EC)

Hot Water 

CPB

Mechanical 

Draft Oil-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SOMDHW 82%(ET)

Hot Water 

CPB

Mechanical 

Draft Oil-fired Large (>2,500,000 Btu/h) LOMDHW 84%(EC)

Steam CPB Mechanical 

Draft Gas-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SGMDST 79%(ET)

Steam CPB Mechanical 

Draft Gas-fired Large (>2,500,000 Btu/h) LGMDST 79%(ET)

Steam CPB Mechanical 

Draft Oil-fired Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) SOMDST 81%(ET)

Steam CPB Mechanical 

Draft Oil-fired Large (>2,500,000 Btu/h) LOMDST 81%(ET)
ES-7

For the analyses, DOE reviewed available literature and interviewed manufacturers to 

develop an overall understanding of the CPB industry in the United States. Industry 

publications, including trade journals, literature from manufacturers, government agencies, and 

trade organizations provided the bulk of the information, including: (1) manufacturers and their 

market share; (2) equipment information; and (3) industry trends. DOE obtained much of the

information for the market assessment through the Air-conditioning, Heating and Refrigeration 

Institute’s (AHRI’s) certified directory of performance for commercial boilers.

3 AHRI, one of 

the trade associations representing CPB manufacturers, provides a database of boiler models 

available on the market that includes information such as the name of manufacturer, input 

ratings, efficiency ratings, draft type, and fuel input, etc. DOE used this data as a starting point 

and supplemented it with data from manufacturer literature to create a complete database of 

CPBs. DOE categorized the boilers in its database into the 16 equipment classes and carried out 

its analyses on each equipment class. 

Figure ES.3.1 shows market share of mechanical draft CPB models available on the 

market by equipment class. Similarly, Figure ES.3.2 shows market share of natural draft CPBs

based on equipment classes. Chapter 3 of the preliminary TSD describes the market analysis and 

resulting information in further detail.

Figure ES.3.1 Market share of mechanical draft commercial 

packaged boilers based on Air-conditioning, Heating 

and Refrigeration Institute database

 3 AHRI directory for certified commercial boilers can be found at: 

https://www.ahridirectory.org/ahridirectory/pages/cblr/defaultSearch.aspx.

3% 7% 2%

8%

56%

7%

9%

8%

Commercial Packaged Boilers Market Share 

- Mechanical Draft 

SOMDHW

SOMDST

LOMDHW

LOMDST

SGMDHW

SGMDST

LGMDHW

LGMDST

Total: 1362 
ES-8

Figure ES.3.2 Market share of natural draft commercial packaged 

boilers based on Air-conditioning, Heating and 

Refrigeration Institute database

In addition to the market assessment, DOE also conducts a technology assessment to

review existing and past designs, along with prototype designs, to determine which technologies

provide ways to improve commercial package boiler efficiency. In consultation with interested 

parties, DOE develops a list of technologies to be considered as efficiency improvement options. 

In the current rulemaking, after reviewing comments from interested parties, DOE included the 

following technologies as part of the market and technology assessment. The list below consists 

of all possible options which were conceived. Several options were later screened out as part of 

DOE’s screening analysis which is discussed briefly in the next section and in detail in chapter 4,

Screening Analysis, of this preliminary TSD.4

1. Technology options to improve combustion and/or thermal efficiency

a. Jacket insulation optimization

b. Heat exchanger improvements (including condensing heat exchanger and external 

and internal tube surface enhancement)

c. Burner derating

d. Improved burner technology

e. Combustion air preheaters

f. Economizers

g. Integrated, high-efficiency steam boilers

h. Blowdown waste heat recovery

 4 As explained in Chapter 2, Analytical Framework, of this preliminary TSD, DOE has tentatively concluded that 

the proportion of standby mode and off mode energy consumption is de minimis, and therefore, DOE has tentatively 

decided not to address such modes further in this rulemaking. As a result, technology options that reduce standby 

mode and off mode energy consumption were not included in Chapter 3, Market and Technology Assessment, of 

this preliminary TSD. 

6% 5% 1%

10%

24%

35%

3%

16%

Commercial Packaged Boilers Market ShareNatural Draft 

SONDHW

SONDST

LONDHW

LONDST

SGNDHW

SGNDST

LGNDHW

LGNDST

Total: 989 
ES-9

2. Technology options to reduce seasonal boiler energy consumption

a. Modulating burners

b. Electronic ignition

c. Dampers

d. Temperature reset controls

e. Thermal post-purge controls

f. Delayed-action oil pump solenoid valve

DOE developed its list of technology options for CPBs based on a review of trade 

publications, technical papers, and manufacturer literature and through consultation with 

manufacturers of components and systems. Because existing equipment contain many 

technologies for improving equipment efficiency, equipment literature examination provided 

additional information. Detailed information regarding these technology options is included in 

chapter 3 of this preliminary TSD.

ES.3.2 Screening Analysis

DOE develops an initial list of options for enhancing efficiency of CPBs from the 

technologies that the technology assessment identified as feasible. DOE then conducts a 

screening analysis (see chapter 4, Screening Analysis, of this preliminary TSD) in which it 

examines, in consultation with interested parties, whether the identified technologies: (1) are 

technologically feasible; (2) are practicable to manufacture, install, and service; (3) have an 

adverse impact on equipment utility or availability; or (4) have adverse impacts on health and 

safety. If the technology option does not meet the first two criteria or if the technology option 

does meet the last two criteria, DOE will not consider that technology option further. In 

addition, DOE notes that the four screening criteria do not directly address the proprietary status 

of design options. DOE only considers efficiency levels achieved through the use of proprietary 

designs in the engineering analysis if they are not part of a unique path to achieve that efficiency 

level (i.e., if there are other non-proprietary technologies capable of achieving the same 

efficiency). Out of the list of technology options that passed the screening test, several options 

were removed from the final list, by DOE. This is because these options have a negligible

improvement on combustion or thermal efficiency of the CPB when it is tested using DOE’s test 

procedure. The following technology options are the remaining options that passed DOE’s 

screening analysis and are considered as potential technology options to increase

thermal/combustion efficiencies.

1. Addition of condensing or secondary heat exchanger

2. Increased primary heat exchanger surface area

3. Incorporation of heat exchanger surface features (such as dimples) and internal features 

(such as turbulators, corrugation, or rifling) with the purpose of inducing turbulent flow 

on either the flue-gas or water side of the heat exchanger

4. Introduction of baffles in the heat exchanger tubes which increase effective flow length 

(or surface area) and residence time of fluid inside the heat exchanger

5. Introduction of micro-fin heat exchanger tubes to enhance water-side boiling 

performance
ES-10

6. Replacing flat straight heat exchanger fins with wavy or louvered fins to improve fluegas side heat transfer performance. Staggering may also improve thermal as well as 

hydraulic performance.

7. Introduction of premix burners, pulse combustion and low pressure – air atomized oil 

burners as improved burner technology options.

For further details on the technology options which DOE considered but screened out 

(and the rationale for doing so), see chapter 4, Screening Analysis, of this preliminary TSD.

ES.3.3 Engineering Analysis

The engineering analysis establishes the relationship between the manufacturer selling 

price of CPBs and their efficiency. This relationship serves as the basis for calculating costs and 

benefits to consumers, manufacturers, and the Nation of modified equipment designs intended to 

improve energy efficiency. Chapter 5 describes the equipment classes DOE analyzed, the 

representative baseline units, the efficiency levels DOE considered, the methodology DOE used 

to determine the manufacturer selling price, and the price-efficiency results. 

ES.3.3.1 Equipment Classes Analyzed

The engineering analysis directly analyzed all 16 CPB equipment classes listed in Table 

ES.3.2. Based on its analysis, DOE generated price-efficiency curves for all classes. After a 

review of publicly-available equipment literature, manufacturer and contractor price lists, and 

discussions with manufacturers, DOE determined that the common technologies found in all

baseline CPB models include: (1) gas valve (single-stage, two-stage, or modulating); (2) ignition

(intermittent/electronic or standing pilot); and (3) heat exchanger (a sectional heat exchanger 

made from cast iron; a fin-tube heat exchanger made from copper; or a fire/water tube heat 

exchanger made from either aluminum or stainless steel). Of these, the heat exchanger is the 

most cost-intensive component of a CPB. Boiler models for which prices were obtained were 

divided into different equipment classes and within each equipment class were further divided

based on manufacturer and heat exchanger material. This served as a basis for grouping different 

manufacturers for the purpose of analyzing the incremental increase in equipment prices as 

efficiency increases. A detailed description of the analysis is explained in chapter 5, Engineering 

Analysis, of this preliminary TSD. 

The efficiency of boiler models for which prices were obtained from manufacturers and 

contractors was verified through examination of equipment literature and the AHRI database to 

improve consistency of analysis. Relevant mathematical and statistical techniques were used to 

calculate change in price for higher-efficiency models (i.e., “incremental price”), especially for 

efficiency levels for which price data were limited.

ES.3.3.2 Contractor Price Assessment

DOE calculated the increased incremental price to contractors for higher-efficiency 

equipment (with reference to the price of baseline-efficiency models) for all equipment classes. 
ES-11

For small boilers (having an input rating 300 kBtu/h – 2,500 kBtu/h), all prices were based on a 

reference capacity of 800 kBtu/h. Similarly, reference capacity for large boilers (having input 

rating >2,500 kBtu/h) was set at 3,000 kBtu/h. Based on the prices calculated at the reference 

capacity, price-efficiency curves are created to assess the variation of price with respect to 

efficiency. The incremental prices (for classes for which sufficient data were available) were 

calculated by taking an average of the prices of boiler models from various manufacturers. In 

some cases, especially for condensing boilers, models were categorized based on material of the 

heat exchanger. In this case, the incremental change in equipment price was calculated by taking 

an average of incremental prices for each material type. Trends that were observed in equipment 

classes with adequate data available and certain assumptions based on past industry experience 

and discussions with manufacturers were used to find incremental prices for efficiency levels for 

which limited price data were available. 

The trends and price-efficiency curves are discussed in detail in chapter 5, Engineering 

Analysis, of this preliminary TSD. The sub-topics below describe preliminary results generated 

through the engineering analysis conducted by DOE. Incremental and baseline contractor prices

for each equipment class are shown in the tables below. 

ES.3.3.3 Price-Efficiency Tables and Baseline Prices for Mechanical Draft 

Commercial Packaged Boilers 

1. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Gas-fired Hot Water

Table ES.3.3 Price-efficiency table for small gas-fired mechanical draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity

Equipment 

Class

Efficiency Level

(Thermal) Change in Price Baseline Price

Small Gas-fired

Hot Water, ≥ 

300,000 Btu/h

and ≤ 2,500,000 

Btu/h

80% $0

$ 7,120

83% $1,710

85% $3,078

87% $4,665

92% $6,819

95% $11,211

98% $15,604

2. Large (>2,500,000 Btu/h) Gas-fired Hot Water

Table ES.3.4 Price-efficiency table for large gas-fired mechanical draft hot water 

commercial packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Combustion) Change in Price Baseline Price

Large Gas-fired 

Hot Water, 

>2,500,000 Btu/h

82% $0

84% $4,343 $ 22,256 

86% $9,533
ES-12

94% $31,784

97% $35,892

3. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Oil-fired Hot Water

Table ES.3.5 Price-efficiency table for small oil-fired mechanical draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity

Equipment

Class

Efficiency Level

(Thermal) Change in Price Baseline Price

Small Oil-fired

Hot Water, ≥ 

300,000 Btu/h

and ≤ 2,500,000 

Btu/h

82% $0

$ 8,806 

83% $814

84% $1,629

87% $4,073

98% $18,943

4. Large (>2,500,000 Btu/h) Oil-fired Hot Water

Table ES.3.6 Price-efficiency table for large oil-fired mechanical draft hot water a

commercial packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Combustion) Change in Price Baseline Price

Large Oil-fired 

Hot Water, 

>2,500,000 Btu/h

84% $0

$ 21,203 

86% $5,348

88% $8,459

97% $47,635

5. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Gas-fired Steam

Table ES.3.7 Price-efficiency table for small gas-fired mechanical draft steam 

commercial packaged boilers at 800,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Small Gas-fired 

Steam, ≥ 300,000 

Btu/h and ≤ 

2,500,000 Btu/h

79% $0

$ 8,136 

80% $1,060

81% $2,243

83% $5,025

6. Large (>2,500,000 Btu/h) Gas-fired Steam
ES-13

Table ES.3.8 Price-efficiency table for large gas-fired mechanical draft steam 

commercial packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Large Gas-fired 

Steam, >2,500,000 

Btu/h

79% $0

80% $3,534 $ 14,464 

83% $16,750

7. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Oil-fired Steam

Table ES.3.9 Price-efficiency table for small oil-fired mechanical draft steam a

commercial packaged boilers at 800,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Small Oil-fired 

Steam, ≥ 300,000 

Btu/h and ≤ 

2,500,000 Btu/h

81% $0

$ 8,607 

83% $2,204

84% $3,485

86% $6,461

8. Large (>2,500,000 Btu/h) Oil-fired Steam

Table ES.3.10 Price-efficiency table for large oil-fired mechanical draft steam 

commercial packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Large Oil-fired 

Steam, >2,500,000 

Btu/h

81% $0

83% $6,250 $ 13,355 

86% $18,316

ES.3.3.4 Price-Efficiency Tables and Baseline Prices for Natural Draft 

Commercial Packaged Boilers 

1. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Gas-fired Hot Water

Table ES.3.11 Price-efficiency table for small gas-fired natural draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity

Equipment Class Efficiency Level 

(Thermal) Change in Price Baseline Price

Small Gas-fired Hot 

Water, ≥ 300,000 

Btu/h and ≤ 

80% $0

81% $529 $ 3,799

82% $1,307
ES-14

2,500,000 Btu/h 85% $3,078

2. Large (>2,500,000 Btu/h) Gas-fired Hot Water

Table ES.3.12 Price-efficiency table for large gas-fired natural draft hot water 

commercial packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Combustion) Change in Price Baseline Price

Large Gas-fired Hot 

Water, >2,500,000 

Btu/h

82% $0

83% $2,075 $ 16,898 

84% $4,343

3. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Oil-fired Hot Water

Table ES.3.13 Price-efficiency table for small oil-fired natural draft hot water 

commercial packaged boilers at 800,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Small Oil-fired Hot 

Water, ≥ 300,000 

Btu/h and ≤ 

2,500,000 Btu/h

82% $0

$ 5,486 83% $395

85% $3,282

87% $3,654

4. Large (>2,500,000 Btu/h) Oil-fired Hot Water

Table ES.3.14 Price-efficiency table for large oil-fired natural draft hot water 

commercial packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Combustion) Change in Price Baseline Price

Large Oil-fired Hot 

Water, >2,500,000 

Btu/h

84% $0

85% $2,300 $ 15,845 

86% $4,138

5. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Gas-fired Steam

Table ES.3.15 Price-efficiency table for small gas-fired natural draft steam commercial 

packaged boilers at 800,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Small Gas-fired 

Steam, ≥ 300,000 

77% $0 $ 3,215 79% $1,601
ES-15

Btu/h and ≤ 

2,500,000 Btu/h 80% $2,661

6. Large (>2,500,000 Btu/h) Gas-fired Steam

Table ES.3.16 Price-efficiency table for large gas-fired natural draft steam commercial 

packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Large Gas-fired 

Steam, >2,500,000 

Btu/h

77% $0

$ 5,248 

79% $3,858

80% $7,392

81% $11,334

7. Small (≥300,000 Btu/h and ≤2,500,000 Btu/h) Oil-fired Steam

Table ES.3.17 Price-efficiency table for small oil-fired natural draft steam commercial 

packaged boilers at 800,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Small Oil-fired 

Steam, ≥ 300,000 

Btu/h and ≤ 

2,500,000 Btu/h

81% $0

82% $1,046 $ 5,286 

83% $2,204

8. Large (>2,500,000 Btu/h) Oil-fired Steam

Table ES.3.18 Price-efficiency table for large oil-fired natural draft steam commercial 

packaged boilers at 3,000,000 Btu/h representative capacity

Equipment Class Efficiency Level

(Thermal) Change in Price Baseline Price

Large Oil-fired 

Steam, >2,500,000 

Btu/h

81% $0

$ 7,998 82% $2,966

83% $6,250

85% $13,892

ES.3.4 Markups Analysis

The markups analysis develops appropriate markups in the distribution chain to convert 

the estimates of manufacturer cost derived in the engineering analysis to commercial consumer 

prices. For the two major equipment categories, small boilers (≥300,000 Btu/h and ≤2,500,000 

Btu/h) and large boilers (>2,500,000 Btu/h), covered in the analysis, DOE estimated that the 

majority of equipment is installed in commercial applications and that only a small fraction of 
ES-16

them is used in residential applications. Within each application, there are two primary types of 

markets describing the way most equipment pass from the manufacturer to the commercial 

consumer: one applying to commercial packaged boilers installed in replacement markets or by 

new owners, and the other applying to commercial packaged boilers that are installed in new 

construction. DOE considered three distinct categories of market participants for commercial 

packaged boiler distributions: (1) wholesaler (for small boilers) or manufacturer’s representative 

(for large boilers); (2) mechanical contractors (including dealers and installers); and (3) general 

contractors (including builders). In addition, DOE accounted for a fraction of large custom-built 

boilers that manufacturers sell directly to commercial consumers through a national accounts 

distribution channel.

For each type of actor in the distribution channel, DOE developed separate markups for 

baseline equipment (baseline markups) and for the cost increase associated with more-efficient 

equipment (incremental markups). DOE also added sales tax where appropriate. The overall 

markup for each distribution channel is the product of the appropriate markups, as well as the 

sales tax in the case of replacement applications. Table ES.3.19 and Table ES.3.20 summarize 

the markups developed for commercial packaged boilers.
ES-17

Table ES.3.19 National Average Markups for Small Commercial Packaged Boilers

Replacement New Construction

Baseline 

Markup

Incremental 

Markup

Baseline 

Markup

Incremental 

Markup

Manufacturer 1.41 1.41

Wholesaler 1.36 1.10 1.36 1.10

Mechanical Contractor 1.53 1.22 1.44 1.16

General Contractor 

(commercial/residential) - - 1.33/1.48 1.21/1.34

Sales Tax 1.07 - -

Overall Markup 

(commercial/ residential) 3.15 2.04 3.69/4.10 2.17/2.40

Table ES.3.20 National Average Markups for Large Commercial Packaged Boilers

Replacement New Construction

Baseline 

Markup

Incremental 

Markup

National 

Account: 

Baseline/ 

Incremental 

Markup

Baseline 

Markup

Incremental 

Markup

National 

Account: 

Baseline/ 

Incremental 

Markup

Manufacturer 1.41 1.41

Manufacturer’s 

Representative 1.36 1.10 1.36/1.10 1.36 1.10 1.36/1.10

Mechanical Contractor 1.53 1.22 - 1.44 1.16 -

General Contractor 

(commercial/residential) - - - 1.33/1.48 1.21/1.34 -

Sales Tax 1.07 - - 1.07

Overall Markup 

(commercial/ 

residential)

3.15 2.04 2.06/1.66 3.69/4.1

0 2.17/2.40 2.06/1.66

ES.3.5 Energy Use Analysis

The purpose of the energy use analysis is to determine the annual energy consumption of 

commercial packaged boilers in representative U.S. buildings and to assess the energy savings 

potential of increased boiler efficiency. DOE estimated the annual energy consumption of 

commercial packaged boilers at specified energy efficiency levels across a range of climate 

zones. The annual energy consumption includes the fuel use (oil or natural gas) by the boiler for 

space and water heating (if applicable), as well as the electricity use of auxiliary components, 

including the blower fan, igniter, and pumps.

To determine the variation in field energy use by the commercial packaged boilers 

considered in this rulemaking, DOE developed a sample from the Energy Information 
ES-18

Administration’s (EIA) 2003 Commercial Building Energy Consumption Survey (CBECS).

5

 

CBECS is a national sample survey of commercial buildings that collects information on the 

vintage of the building, building square footage, fuels used, heating energy use, and other 

relevant information. For the residential building sample, DOE used EIA’s 2009 Residential 

Energy Consumption Survey (RECS) to establish a sample of residential buildings using 

commercial boilers for each boiler equipment class.6 The RECS data provide information on the 

consumption of and expenditures for energy in residential buildings along with data on energyrelated characteristics of the building and occupants.

To determine the energy consumption of commercial packaged boilers, DOE is using an 

adjusted thermal efficiency to account for the actual performance in the field.7 Starting with the 

rated thermal efficiency, DOE calculated adjustments to account for differences in efficiency 

related to part-load operation, return water temperature, and cycling losses. The adjustments are 

based on weather data and boiler efficiency information published in manufacturer literature. 

The adjusted thermal efficiency is proportional to annual heating energy consumption for 

national average operating conditions. There are four equipment classes (LGNDHW, LONDHW, 

LGMDHW, LOMDHW) for which the efficiency metric in the standard is combustion efficiency

instead of thermal efficiency.

8 For the purposes of the energy use analysis, for these product 

classes, DOE used data from the AHRI model database to represent the relationship between the

rated combustion efficiency and the thermal efficiency.

9

To estimate the annual energy consumption of commercial packaged boilers, DOE 

calculated the building heating load based on the CBECS and RECS estimates of the annual 

energy consumption of the boiler for each building. DOE then used the building heating load to 

determine the burner operating hours, to which the adjusted thermal efficiency was applied in 

order to calculate the annual fuel consumption and electricity consumption.

Table ES.3.21 through Table ES.3.24 shows the energy use results by efficiency level for

several key equipment classes, including small gas-fired mechanical draft hot water boilers 

(SGMDHW), large gas-fired natural draft steam boilers (LGNDST), small gas-fired natural draft 

hot water boilers (SGNDHW), small gas-fired mechanical draft steam boilers (SGMDST), and 

small oil-fired mechanical draft hot water boilers (SOMDHW). These equipment classes 

account for about 55-percent of commercial packaged boiler projected shipments in 2019, the 

 5 Energy Information Administration (EIA), 2003 Commercial Building Energy Consumption Survey (Available at: 

http://www.eia.gov/consumption/commercial/data/2003/). Since the 2003 survey, EIA conducted surveys in 2007 

and 2012. EIA determined that the CBECS 2007 did not yield valid statistical estimates of building counts, energy 

characteristics, consumption, and expenditures and, therefore, did not release the majority of the data tables and 

public use files. Data collection for the CBECS 2012 is still in progress, and the complete results have not yet been 

released.

6 Energy Information Administration (EIA), 2009 Residential Energy Consumption Survey (Available at:

http://www.eia.doe.gov/emeu/recs). 7 “Thermal efficiency” definition: the ratio of the heat absorbed by the water or the water and steam to the higher 

heating value in the fuel burned 10 CFR 431.82. 8 “Combustion efficiency” definition: 100% minus the flue losses due to: (1) Dry Flue Gas, (2) Incomplete 

Combustion, and (3) Moisture Formed by Combustion of Hydrogen. 10 CFR 431.82. 9 Air-Conditioning Heating and Refrigeration Institute, "AHRI Directory of Certified Product Performance for 

Commercial Boilers" (Available at: https://www.ahridirectory.org/ahridirectory/pages/cblr/defaultSearch.aspx) (Last 

accessed May 2014).
ES-19

first full year in which compliance would be required. Similar results for the remaining 

equipment classes are presented in chapter 7, Energy Use Analysis, of this preliminary TSD, 

along with details on the methods, data, and assumptions used for that analysis.

The savings in Table ES.3.21 through Table ES.3.24 do not account for potential changes 

in consumer operation of commercial packaged boilers if they purchase more-efficient 

equipment. There is no evidence that building managers who purchase higher-efficiency 

commercial packaged boilers significantly increase the frequency with which they operate the 

boiler. Therefore, DOE concluded that inclusion of such a rebound effect in its analysis is not 

warranted. 

Table ES.3.21 Average Annual Energy Consumption and Savings for Small Gas-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers

EL Thermal Efficiency (TE) Annual Energy 

Use

MMBtu

Energy Use 

Savings

MMBtu

Additional 

Electricity Use

kWh (MMBtu)

0 80% TE - Baseline 938.8 -- 746 (2.5)

1 83% TE 903.7 35.1 720 (2.5)

2 85% TE 881.8 57.0 704 (2.4)

3 87% TE 860.9 77.9 689 (2.3)

4 92% TE 824.5 114.3 990 (3.4)

5 95% TE 797.5 141.3 960 (3.3)

6 98% TE 772.2 166.5 931 (3.2)

Note: 1 kWh = 3412 Btu and 1 MMBtu = 1 million Btu.

Table ES.3.22 Average Annual Energy Consumption and Savings for Large Gas-Fired 

Natural Draft Steam Commercial Packaged Boilers 

EL Thermal Efficiency (TE) Annual Energy 

Use

MMBtu

Energy Use 

Savings

MMBtu

Additional 

Electricity Use

kWh (MMBtu)

0 77% TE - Baseline 4051.9 -- 1008 (3.4)

1 78% TE 3942.5 109.4 981 (3.3)

2 79% TE 3890.0 161.8 968 (3.3)

3 81% TE 3838.9 213.0 955 (3.3)

Table ES.3.23 Average Annual Energy Consumption and Savings for Small Gas-Fired 

Natural Draft Hot Water Commercial Packaged Boilers 

EL Thermal Efficiency (TE) Annual Energy 

Use

MMBtu

Energy Use 

Savings

MMBtu

Additional 

Electricity Use

kWh (MMBtu)

0 80% TE - Baseline 830.1 -- 342 (1.2)

1 81% TE 819.7 10.4 337 (1.2)

2 82% TE 809.5 20.6 333 (1.1)

3 85% TE 780.5 49.6 321 (1.1)
ES-20

Table ES.3.24 Average Annual Energy Consumption and Savings for Small Gas-Fired 

Mechanical Draft Steam Commercial Packaged Boilers

EL Thermal Efficiency (TE) Annual Energy 

Use

MMBtu

Energy Use 

Savings

MMBtu

Additional 

Electricity Use

kWh (MMBtu)

0 79% TE - Baseline 752.4 -- 673 (2.3)

1 80% TE 742.7 9.7 665 (2.3)

2 81% TE 733.3 19.1 657 (2.2)

3 83% TE 715.2 37.3 641 (2.2)

Table ES.3.25 Average Annual Energy Consumption and Savings for Small Oil-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers 

EL Thermal Efficiency (TE) Annual Energy 

Use

MMBtu

Energy Use 

Savings

MMBtu

Additional 

Electricity Use

kWh (MMBtu)

0 82% TE - Baseline 680.2 -- 686 (2.3)

1 83% TE 671.6 8.6 678 (2.3)

2 84% TE 663.1 17.1 670 (2.3)

3 87% TE 639.1 41.1 647 (2.2)

4 98% TE 573.8 106.4 858 (2.9)

ES.3.6 Life-Cycle Cost and Payback Period Analysis

New and amended energy conservation standards for equipment result in changes in 

commercial consumer operating expenses (usually a decrease) and changes in commercial 

consumer price (usually an increase). DOE analyzed the net effect of potential standards on 

commercial consumers by evaluating the LCC and PBP using the cost-efficiency relationships 

derived in the engineering analysis, as well as the energy use derived from the energy use 

analysis. DOE conducted the LCC and PBP analysis using values that reflect use of commercial 

packaged boilers in the field. 

DOE performed the LCC and PBP analysis using a spreadsheet model combined with a 

commercially-available software program used to conduct stochastic analysis using Monte Carlo 

simulation and probability distributions to account for uncertainty and variability among the 

input variables. Each Monte Carlo simulation consists of 10,000 LCC and PBP calculations. 

The model performs each calculation using input values that are either sampled from probability 

distributions and household samples or characterized with single point values. Inputs to the LCC 

calculation include the installed cost to the consumer, operating costs (primarily energy 

expenses), the lifetime of the appliance, and a discount rate. 

DOE used recent energy price data from EIA to determine average commercial prices of 

natural gas, fuel oil, and electricity in the nine CBECS Census Divisions and 30 RECS 

geographic areas. Appropriate prices were assigned to each sample building based on its 
ES-21

location. To estimate the future trends in energy prices, DOE used projections from EIA’s 

Annual Energy Outlook 2014 (AEO 2014).10

DOE modeled boiler lifetime using data from the ASHRAE Service Life Database and a 

literature review of research studies, and field data reports11 and a literature review of research 

studies, and field data reports.12 The data allowed DOE to develop an equipment survival 

function, which provides an average and median appliance lifetime. DOE assumed that the 

lifetime is the same for all commercial packaged boilers due to the lack of data showing 

otherwise.

DOE estimated all the installation costs associated with installing a boiler in a new

building unit or as a replacement for an existing boiler using RS Means 2011 Facilities 

Construction Cost Data,13 manufacturer literature, and information from expert consultants. This 

includes any additional costs, such as venting and piping modifications that would be required to 

install equipment at various efficiency levels.

DOE also considered expected maintenance and repair costs for the equipment covered in 

this rulemaking. DOE used the most recent RS Means Facilities Maintenance & Repair Cost 

Data14 to develop appropriate repair and maintenance costs for baseline units. DOE included

increased repair and maintenance costs for condensing equipment (thermal efficiency greater 

than 90 percent), accounting for regular replacement of condensate neutralizer and more 

expensive heat exchanger repair compared to lower-efficiency boilers.15

To estimate the share of commercial consumers that would be affected by a standard at a 

particular efficiency level, DOE projected the distribution (i.e., market shares) of equipment

efficiencies that commercial consumers may purchase under the base case (i.e., the case without 

amended energy efficiency standards). DOE based the base-case efficiency distribution on 

trends in the AHRI model database because it found very limited historical shipment data upon 

which to estimate either current shares or recent trends.16

Using the projected distribution of equipment efficiencies for each equipment class, DOE 

assigned a base-case-efficiency boiler to each sample building. If a building was assigned an 

equipment efficiency that is greater than or equal to the efficiency of the standard level under 

 10 See http://www.eia.gov/forecasts/aeo/. 11 Available at http://xp20.ashrae.org/publicdatabase/. 12 See appendix 8-F of the preliminary TSD for a list of the sources used in the literature review. 13 RS Means Company Inc., RS Means Mechanical Cost Data, 36st Annual Edition (2013) (Available at:

http://rsmeans.reedconstructiondata.com/) (Last accessed May 2014). 14 RS Means Company Inc., 2013 Facilities Maintenance & Repair Cost Data (2013) (Available at: 

http://rsmeans.reedconstructiondata.com/).(Last accessed May 2014). 15 “Replacement Cartridge for Condensate Neutralizing Kit,” The Home Depot (Available at: 

http://www.homedepot.com/p/Unbranded-Replacement-Cartridge-for-Condensation-Neutralizing-Kit-JM-2-

R/202809241?cm_mmc=shopping-_-googleads-_-pla-_-

202809241&skwcid&kwd=&ci_sku=202809241&ci_kw=&ci_gpa=pla&ci_src=17588969) (Last accessed June 27, 

2014).

16 Air-Conditioning Heating and Refrigeration Institute (2007-2014), "AHRI Directory of Certified Product 

Performance for Commercial Boilers" (Available at: 

https://www.ahridirectory.org/ahridirectory/pages/cblr/defaultSearch.aspx) (Last accessed May 2014).
ES-22

consideration, the LCC calculation would show that this building is not impacted by that 

standard level. 

Table ES.3.26 through Table ES.3.35 show key LCC and PBP results by efficiency level 

(EL) for several key equipment classes, including SGMDHW, LGNDST, SGNDHW, SGMDST, 

and SOMDHW. These equipment classes account for about 55-percent of commercial packaged 

boiler projected shipments in 2019, the first full year in which compliance with amended 

standards would be required. Similar results for the remaining equipment classes are presented 

in chapter 8, LCC and PBP Analysis, of this preliminary TSD, along with details on the methods, 

data, and assumptions used for that analysis. The average lifetime operating cost presented in 

the tables reflects discounting of future costs using the consumer discount rates developed for the 

LCC analysis. 

In the first of each pair of tables, the simple payback is measured relative to the baseline 

equipment in the compliance year and reflects the number of years it would take for the 

consumer to recover the increased costs of higher-efficiency equipment as a result of operating 

cost savings. The simple payback is calculated by dividing the incremental total installed cost 

increase by the difference in first year operating costs. In the second table, the LCC savings are 

measured relative to the base-case efficiency distribution in the compliance year. No impacts 

occur when the base-case efficiency for a specific consumer equals or exceeds the efficiency at a 

given trial standard level (TSL); a standard would have no effect because the equipment installed 

would be at or above that standard level without amended standards. Figures presented in 

chapter 8, LCC and PBP Analysis, of this preliminary TSD show the range of LCC savings and 

PBPs for all of the efficiency levels considered for all equipment classes. 

Table ES.3.26 Average LCC and PBP Results by Efficiency Level for Small Gas-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers 

Efficiency 

Level

TE Average Costs Simple 

Payback 

years

Average 

Lifetime 

years

2013$

Installed 

Cost

First Year’s 

Operating Cost

Lifetime 

Operating 

Cost

LCC

0 80% $32,003 $11,261 $190,176 $222,180 N/A 24.8

1 83% $35,530 $10,907 $184,115 $219,646 10.0 24.8

2 85% $38,353 $10,685 $180,326 $218,680 11.0 24.8

3 87% $41,626 $10,474 $176,721 $218,348 12.2 24.8

4 92% $45,983 $10,161 $171,255 $217,239 12.7 24.8

5 95% $55,044 $9,887 $166,576 $221,621 16.8 24.8

6 98% $64,104 $9,631 $162,202 $226,307 19.7 24.8

Note: The results for each TSL are calculated assuming that all consumers use equipment with that efficiency level. 

The PBP is measured relative to the baseline equipment. 
ES-23

Table ES.3.27 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Gas-Fired Mechanical Draft Hot Water Commercial Packaged Boilers

Efficiency 

Level

TE Life-Cycle Cost Savings

% of Consumers that Experience Net Cost Average Savings* 

2013$

0 80% 0% N/A

1 83% 5% $325

2 85% 13% $579

3 87% 28% $738

4 92% 31% $1,333

5 95% 51% ($1,612)

6 98% 78% ($6,018)

* The calculation includes buildings with zero LCC savings (no impact).

Parentheses indicate negative values.

Table ES.3.28 Average LCC and PBP Results by Efficiency Level for Large Gas-Fired 

Natural Draft Steam Commercial Packaged Boilers

Efficiency 

Level

TE Average Costs Simple 

Payback 

years

Average 

Lifetime 

years

2013$

Installed 

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 77% $33,212 $43,563 $715,670 $748,876 N/A 24.8

1 79% $40,816 $42,520 $698,333 $739,143 7.3 24.8

2 80% $47,781 $42,019 $690,011 $737,785 9.4 24.8

3 81% $55,550 $41,531 $681,908 $737,450 11.0 24.8

Note: The results for each TSL are calculated assuming that all consumers use equipment with that efficiency level. 

The PBP is measured relative to the baseline equipment. 

Table ES.3.29 LCC Savings Relative to the Base Case Efficiency Distribution for Large 

Gas-Fired Natural Draft Steam Commercial Packaged Boilers

Efficiency 

Level

TE Life-Cycle Cost Savings

% of Consumers that Experience Net Cost Average Savings* 

2013$

0 77% 0% N/A

1 79% 15% $4,378

2 80% 41% $5,478

3 81% 53% $5,811

* The calculation includes buildings with zero LCC savings (no impact).

Table ES.3.30 Average LCC and PBP Results by Efficiency Level for Small Gas-Fired 

Natural Draft Hot Water Commercial Packaged Boilers

Efficiency TE Average Costs Simple Average 
ES-24

Level 2013$ Payback 

years

Lifetime 

Installed years

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 80% $17,667 $10,108 $169,645 $187,315 N/A 24.8

1 81% $18,727 $10,003 $167,852 $186,582 10.1 24.8

2 82% $20,289 $9,900 $166,105 $186,397 12.6 24.8

3 85% $23,842 $9,608 $161,126 $184,970 12.3 24.8

Note: The results for each TSL are calculated assuming that all consumers use equipment with that efficiency level. 

The PBP is measured relative to the baseline equipment. 

Table ES.3.31 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Gas-Fired Natural Draft Hot Water Commercial Packaged 

Efficiency 

Level

TE Life-Cycle Cost Savings

% of Consumers that Experience Net Cost Average Savings* 

2013$

0 80% 0% N/A

1 81% 7% $116

2 82% 20% $172

3 85% 52% $1,546

* The calculation includes buildings with zero LCC savings (no impact).

Table ES.3.32 Average LCC and PBP Results by Efficiency Level for Small Gas-Fired 

Mechanical Draft Steam Commercial Packaged Boilers

Efficiency 

Level

TE Average Costs Simple 

Payback 

years

Average 

Lifetime 

years

2013$

Installed 

Cost

First Year’s 

Operating Cost

Lifetime 

Operating 

Cost

LCC

0 79% $33,196 $10,266 $170,602 $203,798 N/A 24.8

1 80% $35,311 $10,169 $168,926 $204,236 21.8 24.8

2 81% $37,669 $10,075 $167,294 $204,963 23.4 24.8

3 83% $43,220 $9,894 $164,154 $207,374 26.9 24.8

Note: The results for each TSL are calculated assuming that all consumers use equipment with that efficiency level. 

The PBP is measured relative to the baseline equipment. 

Table ES.3.33 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Gas-Fired Mechanical Draft Steam Commercial Packaged Boilers

Efficiency 

Level

TE Life-Cycle Cost Savings

% of Consumers that Experience Net Cost Average Savings* 

2013$

0 79% 0% N/A

1 80% 14% ($71)

2 81% 51% ($538)

3 83% 75% ($2,699)
ES-25

Parentheses indicate negative values.

Table ES.3.34 Average LCC and PBP Results by Efficiency Level for Small Oil-Fired 

Mechanical Draft Hot Water Commercial Packaged Boilers

Efficiency 

Level

TE Average Costs Simple 

Payback 

years

Average 

Lifetime 

years

2013$

Installed 

Cost

First Year’s 

Operating Cost

Lifetime 

Operating 

Cost

LCC

0 82% $38,850 $18,682 $327,718 $366,567 N/A 24.8

1 83% $40,555 $18,472 $323,957 $364,512 8.1 24.8

2 84% $42,260 $18,267 $320,291 $362,551 8.2 24.8

3 87% $47,376 $17,683 $309,823 $357,199 8.5 24.8

4 98% $79,076 $16,160 $282,186 $361,262 16.0 24.8

Note: The results for each TSL are calculated assuming that all consumers use equipment with that efficiency level. 

The PBP is measured relative to the baseline equipment. 

Table ES.3.35 LCC Savings Relative to the Base Case Efficiency Distribution for Small 

Oil-Fired Mechanical Draft Hot Water Commercial Packaged Boilers 

Efficiency 

Level

TE Life-Cycle Cost Savings

% of Consumers that Experience Net Cost Average Savings* 

2013$

0 82% 0% N/A

1 83% 11% $567

2 84% 21% $1,613

3 87% 27% $5,294

4 98% 58% $1,497

* The calculation includes buildings with zero LCC savings (no impact).

ES.3.7 Shipments Analysis

Shipment forecasts are needed to calculate the national impacts of standards on energy 

use, NPV, and future manufacturer cash flows. DOE estimated commercial packaged boiler 

shipments in three market segments: (1) replacements; (2) new construction; and (3) new owners 

in buildings that did not previously have a commercial packaged boiler.

To forecast boiler replacement shipments, DOE developed retirement functions for 

boilers from the lifetime estimates and applied them to the existing equipment in the building

stock. The existing stock of equipment is tracked by vintage and developed from historical 

shipments data. To forecast shipments to the new construction market, DOE utilized forecasted 

new building construction and historic saturation rates of various boiler equipment types in new 

buildings. DOE used AEO 2014 for forecasts of new construction. Boiler saturation rates in new 

buildings are provided by CBECS 2003 and RECS 2009.
ES-26

Figure ES.3.3 illustrates the projected base-case shipments by equipment class. 

DOE has determined that, consistent with economic theory and its past practice, it is 

reasonable to expect that standards that result in higher boiler prices will have some dampening 

effect on sales. To estimate the impact of the price increase for the considered efficiency levels, 

DOE used a relative price elasticity approach. This approach gives some weight to the operating 

cost savings from higher-efficiency equipment. The impact of higher boiler prices due to higher 

efficiency is expressed as a percentage drop in market share for each year during the analysis 

period. 

Figure ES.3.3 Forecasted Shipments for Commercial Packaged Boilers (Base 

Case)

ES.3.8 National Impact Analysis

The NIA estimates the following national impacts of potential efficiency levels for 

commercial packaged boilers: (1) national energy savings, (2) monetary value of the energy 

savings due to standards, (3) increased total installed costs of the considered equipment due to 

standards, and (4) the NPV of the difference between the value of energy savings and increased 

total installed costs. DOE prepared a spreadsheet model to forecast energy savings and national 

commercial consumer economic costs and savings resulting from new standards. In contrast to 

the LCC and PBP analysis which uses probability distributions for the inputs, the NIA uses 

average or typical values for inputs. 

A key component of DOE’s NIA is the energy efficiencies forecasted for the base case 

(without new standards) and each of the standards cases. To forecast the efficiency trend in the 

base case (i.e., no new standards for commercial packaged boilers), DOE derived a growth rate 

0.000

0.005

0.010

0.015

0.020

0.025

0.030

0.035

0.040

0.045

0.050

1960 1970 1980 1990 2000 2010 2020 2030 2040

Shipments (million)

LOMDST

SOMDST

LGMDST

SGMDST

LOMDHW

SOMDHW

LGMDHW

SGMDHW

LONDST

SONDST

LGNDST

SGNDST

LONDHW

SONDHW

LGNDHW

SGNDHW
ES-27

in the market share of different equipment classes by extrapolating the trend from 2007 to 2014

AHRI model data.

For the standards-case efficiency distributions, DOE used a “roll-up” scenario to establish 

the distribution of efficiencies for the year that compliance with amended standards is assumed 

to become required (i.e., 2019). DOE assumed that equipment efficiencies in the base case that 

did not meet the standard level under consideration would “roll up” to meet the new standard 

level in 2019. Market shares that were above a given standard level before 2019 would be 

unaffected.

Because DOE did not include the rebound effect in its analysis, the NES was not adjusted 

to account for the rebound effect.

Chapter 10, National Impact Analysis, of this preliminary TSD provides additional 

details on the NIA.

ES.3.8.1 National Energy Savings 

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without new efficiency standards) and under each candidate standard level (CSL). 

Cumulative energy savings are the sum of the annual NES, which DOE determined for 

2019−2048. 

DOE estimated energy consumption and savings based on site energy and converted the 

site energy values to primary (source) energy using factors that account for losses in transmission 

and distribution and in electricity generation. These site-to-source factors are derived from the 

National Energy Modeling System (NEMS). DOE also estimated full-fuel-cycle (FFC) energy 

savings for each EL. The full-fuel-cycle measure includes the energy consumed in extracting, 

processing, and transporting primary fuels. 

The NES results shown in Table ES.3.36 are shown as full-fuel-cycle energy savings in 

quadrillion Btu (quads). The primary energy savings are presented in chapter 10, National 

Impact Analysis, of this preliminary TSD.
ES-28

Table ES.3.36 Full-Fuel-Cycle National Energy Savings for Commercial 

Packaged Boilers (quads)

Equipment Class

Candidate Standard Level

1 2 3 4 5 6

Natural Draft Gas-Fired Hot Water 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.001 0.005 0.029 N/A N/A N/A

Natural Draft Gas-Fired Hot Water 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.011 0.025 N/A N/A N/A N/A

Natural Draft Oil-Fired Hot Water 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.001 0.004 0.006 N/A N/A N/A

Natural Draft Oil-Fired Hot Water 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.006 0.014 N/A N/A N/A N/A

Natural Draft Gas-Fired Steam 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.004 0.020 N/A N/A N/A N/A

Natural Draft Gas-Fired Steam 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.009 0.056 0.111 N/A N/A N/A

Natural Draft Oil-Fired Steam 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.001 0.002 N/A N/A N/A N/A

Natural Draft Oil-Fired Steam 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.006 0.017 0.051 N/A N/A N/A

Mechanical Draft Gas-Fired Hot Water 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.025 0.058 0.117 0.230 0.370 0.583

Mechanical Draft Gas-Fired Hot Water 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.044 0.161 0.634 0.975 N/A N/A

Mechanical Draft Oil-Fired Hot Water 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.007 0.020 0.069 0.235 N/A N/A

Mechanical Draft Oil-Fired Hot Water 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.013 0.044 0.159 N/A N/A N/A

Mechanical Draft Gas-Fired Steam 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.004 0.019 0.059 N/A N/A N/A

Mechanical Draft Gas-Fired Steam 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.011 0.110 N/A N/A N/A N/A

Mechanical Draft Oil-Fired Steam 

Commercial Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.018 0.041 0.091 N/A N/A N/A

Mechanical Draft Oil-Fired Steam 

Commercial Packaged Boiler >2,500,000 

Btu/h

0.041 0.139 N/A N/A N/A N/A

“N/A” means “not applicable.”
ES-29

ES.3.8.2 Net Present Value of Consumer Benefits

DOE calculated net monetary savings in each year as the difference between total savings 

in operating costs and increases in total equipment costs in the base case and standards cases. 

DOE calculated savings over the life of the equipment purchased in the forecast period. The 

NPV is the difference between the present value of operating cost savings and the present value 

of increased total installed costs. In accordance with guidance provided by the Office of 

Management and Budget (OMB) to Federal agencies on regulatory analysis, DOE used discount 

rates of 7-percent and 3-percent to discount future costs and savings to the present.17 The NPV 

results by equipment class are shown in Table ES.3.37 and Table ES.3.38. A negative NPV 

indicates that the costs of a standard at a given efficiency level exceed the savings.

 17 U.S. Office of Management and Budget, “Circular A-4: Regulatory Analysis” (Sept. 17, 2003) (Available at: 

http://www.whitehouse.gov/omb/circulars_a004_a-4/). 
ES-30

Table ES.3.37 Net Present Value, Discounted at 3 Percent for Commercial Packaged 

Boilers (billion 2013$)

Equipment Class

Candidate Standard Level

1 2 3 4 5 6

Natural Draft Gas-Fired Hot 

Water Commercial Packaged 

Boiler ≥300,000 Btu/h and 

≤2,500,000 Btu/h

0.004 0.011 0.072 N/A N/A N/A

Natural Draft Gas-Fired Hot 

Water Commercial Packaged 

Boiler >2,500,000 Btu/h

0.036 0.079 N/A N/A N/A N/A

Natural Draft Oil-Fired Hot 

Water Commercial Packaged 

Boiler ≥300,000 Btu/h and 

≤2,500,000 Btu/h

0.009 0.025 0.054 N/A N/A N/A

Natural Draft Oil-Fired Hot 

Water Commercial Packaged 

Boiler >2,500,000 Btu/h

0.057 0.144 N/A N/A N/A N/A

Natural Draft Gas-Fired Steam 

Commercial Packaged Boiler 

≥300,000 Btu/h and 

≤2,500,000 Btu/h

0.010 0.024 N/A N/A N/A N/A

Natural Draft Gas-Fired Steam 

Commercial Packaged Boiler 

>2,500,000 Btu/h

0.034 0.151 0.300 N/A N/A N/A

Natural Draft Oil-Fired Steam 

Commercial Packaged Boiler 

≥300,000 Btu/h and 

≤2,500,000 Btu/h

0.009 0.025 N/A N/A N/A N/A

Natural Draft Oil-Fired Steam 

Commercial Packaged Boiler 

>2,500,000 Btu/h

0.072 0.185 0.576 N/A N/A N/A

Mechanical Draft Gas-Fired 

Hot Water Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.047 0.088 0.129 0.203 (0.202) (0.908)

Mechanical Draft Gas-Fired 

Hot Water Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.087 0.267 0.523 1.268 N/A N/A

Mechanical Draft Oil-Fired 

Hot Water Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.052 0.148 0.487 0.323 N/A N/A

Mechanical Draft Oil-Fired 

Hot Water Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.105 0.406 0.650 N/A N/A N/A

Mechanical Draft Gas-Fired 

Steam Commercial Packaged 

Boiler ≥300,000 Btu/h and 

≤2,500,000 Btu/h

0.000 (0.009) (0.067) N/A N/A N/A

Mechanical Draft Gas-Fired 0.016 0.096 N/A N/A N/A N/A
ES-31

Steam Commercial Packaged 

Boiler >2,500,000 Btu/h

Mechanical Draft Oil-Fired 

Steam Commercial Packaged 

Boiler ≥300,000 Btu/h and 

≤2,500,000 Btu/h

0.137 0.296 0.591 N/A N/A N/A

Mechanical Draft Oil-Fired 

Steam Commercial Packaged 

Boiler >2,500,000 Btu/h

0.356 1.106 N/A N/A N/A N/A

“N/A” means “not applicable.”

Parentheses indicate negative values.

Table ES.3.38 Net Present Value, Discounted at 7 Percent, for Commercial Packaged 

Boilers (billion 2013$)

Equipment Class

Candidate Standard Level

1 2 3 4 5 6

Natural Draft Gas-Fired Hot 

Water Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.001 0.003 0.019 N/A N/A N/A

Natural Draft Gas-Fired Hot 

Water Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.014 0.030 N/A N/A N/A N/A

Natural Draft Oil-Fired Hot 

Water Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.003 0.007 0.016 N/A N/A N/A

Natural Draft Oil-Fired Hot 

Water Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.022 0.055 N/A N/A N/A N/A

Natural Draft Gas-Fired 

Steam Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.003 0.002 N/A N/A N/A N/A

Natural Draft Gas-Fired 

Steam Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.016 0.054 0.108 N/A N/A N/A

Natural Draft Oil-Fired 

Steam Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.003 0.010 N/A N/A N/A N/A

Natural Draft Oil-Fired 

Steam Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.028 0.072 0.229 N/A N/A N/A

Mechanical Draft Gas-Fired 

Hot Water Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.007 0.006 (0.016) (0.046) (0.358) (0.861)
ES-32

Mechanical Draft Gas-Fired 

Hot Water Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.017 0.034 (0.132) 0.035 N/A N/A

Mechanical Draft Oil-Fired 

Hot Water Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.013 0.037 0.117 (0.315) N/A N/A

Mechanical Draft Oil-Fired 

Hot Water Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.031 0.131 0.025 N/A N/A N/A

Mechanical Draft Gas-Fired 

Steam Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

(0.004) (0.022) (0.089) N/A N/A N/A

Mechanical Draft Gas-Fired 

Steam Commercial 

Packaged Boiler >2,500,000 

Btu/h

0.001 (0.024) N/A N/A N/A N/A

Mechanical Draft Oil-Fired 

Steam Commercial 

Packaged Boiler ≥300,000 

Btu/h and ≤2,500,000 Btu/h

0.038 0.076 0.131 N/A N/A N/A

Mechanical Draft Oil-Fired 

Steam Commercial

Packaged Boiler >2,500,000 

Btu/h

0.109 0.318 N/A N/A N/A N/A

“N/A” means “not applicable.”

Parentheses indicate negative values.

ES.3.9 Preliminary Manufacturer Impact Analysis

DOE acknowledges that amended energy conservation standards might lead to changes in 

manufacturing practices for manufacturers of commercial packaged boilers. DOE conducts a 

manufacturer impact analysis (MIA) to assess the potential impacts of amended standards on 

manufacturers. In this analysis, DOE examines the effects of potential standards on 

manufacturers’ capital investments, marketing costs, shipment volumes, employment levels, and 

research and development costs, among other factors. In the preliminary analysis, DOE 

identified potential impacts by conducting market research and interviewing manufacturers and 

other interested parties.

 

 During interviews for this preliminary MIA, manufacturers identified four major areas

of concern: (1) the testing burden associated with amended standards; (2) condensing boilers are 

not appropriate for many commercial applications; (3) not many American companies produce 

condensing heat exchangers; and (4) amended standards could reduce equipment durability and 

reliability. See chapter 12, Preliminary Manufacturer Impact Analysis, of this preliminary TSD 

for details.
ES-33

ES.4 ISSUES ON WHICH THE DEPARTMENT OF ENERGY SEEKS PUBLIC 

COMMENT 

DOE is interested in receiving comments on all aspects of this preliminary analysis. 

DOE especially invites comments or data to improve DOE’s analysis, including data or 

information that will respond to the following questions or concerns that were raised in response 

to the Framework Document and in preparation of the preliminary TSD.

1. DOE requests comment on its tentative decision not to set an upper input capacity limit 

for CPB.

2. DOE requests comment on the appropriateness of its tentative decision to classify CPBs 

into 16 equipment classes as described in Table ES.3.2. 

3. DOE seeks comment on CPB standby mode and off mode energy consumption and, in 

particular, data on the magnitude of energy consumed in the different operational modes. 

4. DOE is interested in views regarding the technological and economic feasibility of the 

technology options which successfully passed the screening analysis. In particular, DOE 

seeks information regarding technology options which can be applied to improve the 

efficiency of natural draft boilers. 

5. DOE requests comment on the methodology used to calculate incremental costs for 

increased efficiency for each equipment class. DOE would welcome comments from 

interested parties about the appropriateness of the incremental costs reported as part of 

the engineering analysis chapter. DOE would also welcome any additional price-related 

information, especially for natural draft boilers, which would further improve future 

analyses for this current rulemaking. 

6. DOE seeks input on whether the considered distribution channels are appropriate for 

commercial packaged boilers.

7. 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.

8. DOE welcomes suggestions and comments concerning its proposed approach to 

developing estimates of future commercial packaged boiler retail prices.

9. DOE seeks recent data to establish the markups and commercial consumer price for the 

parties involved with the distribution of this equipment.

10. DOE seeks data on representative annual profiles of return water temperature, supply 

water temperature, and boiler percent loading.

11. DOE seeks data on what return water temperatures boilers are tested at under the test 

conditions prescribed by the DOE test procedure.

12. 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.

13. DOE welcomes any data from interested parties about typical boiler sizing practices, 

including how often multiple boilers instead of a single boiler are installed to cover the 

building heating load, and how the number of boilers suitable for a specific installation is 

determined.
ES-34

14. DOE seeks input on how boilers are controlled, particularly in multiple-boiler 

installations.

15. DOE seeks historical shipment-weighted commercial packaged boiler efficiency data 

and/or shipment data by efficiency bins. DOE is primarily interested in data during the 

last 10 years in order to capture the impact of the most current technologies on the boilers 

market.

16. DOE requests input on ancillary energy use by commercial boilers (i.e., in addition to 

fuel energy use) that should be included in the energy use analysis.

17. DOE seeks input on what fractions of hot-water commercial packaged boilers are used 

both for space heating and hot water.

18. DOE requests data to characterize the current distribution of commercial packaged boiler 

efficiencies in the market.

19. 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.

20. DOE seeks input on how often boiler maintenance is performed by on-site staff versus 

external contractors, specifically for hot water boilers versus steam boilers and small 

boilers versus large boilers.

21. DOE seeks input as to how often, in the event of a heat exchanger failure, the heat 

exchanger alone is replaced versus the entire boiler being replaced. DOE is interested in 

knowing whether this varies with equipment class or varies with condensing versus noncondensing boilers.

22. DOE requests data on the fractions of installations that would entail significant additional 

installation expenses.

23. DOE seeks input on how often plastic versus stainless steel venting is installed for 

condensing boilers.

24. DOE seeks input on how often boilers have direct venting, for both condensing and noncondensing boilers.

25. DOE seeks input on the fraction of stainless steel venting in existing boiler installations

by efficiency.

26. DOE seeks input on where boilers are typically located within buildings and where the 

vents typically terminate. DOE is interested in whether such placements change by 

geographic region or boiler type. 

27. DOE seeks data on how often common venting occurs in multiple-boiler installations and 

whether commercial water heaters are commonly vented with commercial boilers.

28. DOE seeks comments on the methodology used to determine equipment lifetimes for 

commercial packaged boilers.

29. DOE welcomes any data to predict boiler lifetime, particularly for non-condensing versus 

condensing boilers.

30. DOE seeks input on its planned approach for estimating discount rates for commercial 

consumers.
ES-35

31. 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).

32. DOE welcomes input on the shipments projection methodology.

33. DOE invites comments regarding the selection of appropriate economic drivers and 

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

34. DOE seeks historical commercial packaged boiler shipments data, disaggregated by 

equipment class and efficiency level if available.

35. DOE seeks input on the potential impact of amended standards on commercial packaged 

boiler shipments.

36. 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.

37. DOE requests input as to what consumer subgroups are appropriate to evaluate for 

commercial packaged boilers.