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 12th, 2013 

Submitted via e-mail to: PkgdBoilers2013STD0030@ee.doe.gov

References: 

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 differentiation of natural draft commercial packaged boilers is key to that end. 

Promulgation of efficiency standards for “commercial packaged boilers” (i.e., without 

differentiation of product class according to venting system type) would likely lead to 

elimination of natural draft commercial packaged boilers in pursuit of highest minimum 

efficiency levels. 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 procedures 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.