Docket Number:

EE -2013- BT

- STD -0030

RIN 1904- AD01

Energy Conservation Program for Certain Commercial and Industrial Equipment: Proposed Determination of Natural Draft Commercial Packaged Boilers as Covered Equipment

Prepared by:

Laclede Gas Company

September 1 2 th , 2013

Submitted via e

- mail to: PkgdBoilers2013STD0030@ee.doe.gov

Reference s:

1. Federal Register / Vol. 78, No. 156 / Tuesday, August 13, 2013 / Proposed Rules [Page 49202]

2. Final rule: Energy Conservation Standards for Standby Mode and Off Mode for

Microwave Ovens

Docket No. EERE–2011– BT

– STD –0048, RIN 1904–AC07, 78 FR 36316 (June 17, 2013)About Laclede Gas

Laclede Gas Company (Laclede) is the largest subsidiary of the Laclede Group and serves about 630,000 residential, commercial and industrial customers in the city of St. Louis and ten other

counties in Eastern Missouri. Laclede also serves approximately 500,000 customers in 155

communities in western Missouri through the recent acquisition of Missouri Gas Energy (MGE); headquartered in Kansas City Missouri.

Laclede Comments

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 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 diffe rentiation 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

elimi nation of natural draft commercial packaged boilers in pursuit of highest minimum efficiency levels . In doing so, DOE would 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

In closing , the proper representation of efficiency should be in terms of full fuel cycle efficiency for both primary fuels and grid electricity. Robust test procedures and energy descriptors under those pro cedures best represent the starting point for that effort. 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 has significant importance in the costs of equipment installation and building design.

This concludes Laclede’s comments. Please direct any inquiries regarding these comments to:

Mark Krebs email: mkrebs@thelacledegroup.com
telephone: (314) 342-0714

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

1904

- AD01, U. S. Department of Energy, August 28, 2013.