COMMERCIAL PACKAGED BOILER ENERGY CONSERVATION STANDARD RULEMAKING

Docket Number EERE-2013-BT-STD-0030

RIN 1904-AD01

Item 14-1 Two subgroups to consider are those that primarily manufacturer their heat exchangers 

here in the states and those that primarily import the heat engines from outside the US. The impacts

upon each could be quite different. Other subgroups are water-tube and fire-tube products or perhaps 

the materials the boilers are constructed of would provide your subgroups-steel, stainless steel, cast 

iron, copper etc. 

Item 14-3 DOE 2012- all boiler manufacturers have recently gone through certifications of 

products to BTS-2000 for implementation January 1st, 2014. Any change in testing standard, which was 

just completed would require retesting, re-certification, and further costs associated with more testing. 

Item13.1 None anticipated

Item11-2 You should contact BRG Building Solutions, Larry Longo at 973 347-5300. They provide 

the industry breakdown and history that you are looking for.

Item 10-6 The material the boiler is constructed from, past performance of material, along with a 

products warranty should be used in determining equipment lifetimes. Steam should be separated from 

water and condensing boilers should be separated from non-condensing boilers. Some boilers last 30-

50 years with maintenance, some others will struggle achieving 10 years. 

Item 10-2 Low -minimum to 84%

Mid- 85-88%

High-89-93%

Max-94% plus

The above efficiencies are based on current test criteria which may or may never be 

achieved in an actual heating system. This rating can be extremely misleading as an ultra efficient boiler 

may actually achieve low to mid efficiency status in it’s real world application. Max and high efficiency 

condensing boilers achieve similar efficiency to mid efficiency non-condensing boilers in non-condensing 

applications requiring water temperatures above 130 degrees. 

Item 10-4 High efficiency boilers are very limited in being “repairable”, and any issue with a heat 

exchanger and it has to pulled and sent back to manufacturer for possible repair or more likely heads to 
the scrap yard. Steel, cast iron, and copper heat exchangers can be repaired in the field and boost 

expected lifetime of products.

Item 10-5 Any rule changing regarding use of chimneys will add costs 

Item 9-5 No, all boilers are not designed the same. Some will perform better or worse than 

others at higher or lower water temperatures

Item 5-4 pumps with ECM motors

Item 5-1 Contact BRG group as previously mentioned.

Item 2-4 Would prefer testing be limited to 2,500,000 BTU’s under DOE test procedure. 

The bodies conducting the tests at their own labs cannot go much higher than this number. 

Outfitting current labs with dissipation systems above this mark is a huge burden. If this 

number is not adopted a single unit from a boiler series should suffice to certify the line and is 

not required to be re-tested every year. This certification would be in effect until a change is 

made to the boiler series that would change the performance. Also based on current burner 

technology and range of achievable CO2’s, the performance of a boiler will not change from 

one manufacturer to another when adjusted for same CO2 levels. Based on this it is 

unnecessary to retest with each burner manufacturer.

On behalf of Burnham Holdings, Jim Schnorr and Chris Drew welcome the opportunity to meet 

personally and be interviewed. There are only a few manufacturers that provide boilers in the entire 

range you beseek input. We make all types of boilers, condensing and non-condensing, steel, stainless 

steel, cast iron, and copper.