1 | Energy Efficiency and Renewable Energy 

Energy Conservation Standards:

Framework forCommercial Prerinse Spray Valves

September 30, 2014

John CymbalDepartment of EnerBuilding Technologie

EERE‐2014‐BT‐STD‐0

SprayValves2014std
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time

– Say your name for the record—there will be a complete 

of this meeting

– Be concise—share the “air‐time”

– Keep the focus here—cell phones on silent; limit sidebar

conversations

– Webinar participants turn phone on mute; “raise your h

recognized to speak
3

Morning Agenda9:00–9:05 am Welcome

9:05–9:30 am Agenda Review, Opening Remarks, Hous

Items

9:30–10:00 am Rulemaking Process Overview

10:00–10:30 am Authority and Definitions10:30–10:45 am Break

10:45–11:15 am Test Procedure and Test Metrics

11:15–11:45 am Market & Technology Assessment, Scree

Analysis

11:45–12:30 pm Engineering Analysis

12:30–1:30 pm Break for Lunch
4

Afternoon Agenda1:30–2:00 pm Markups and Energy and Water Use Ana

2:00–2:30 pm Life‐Cycle Cost and Payback Period Analy

2:30–2:45 pm Break

2:45–3:00 pm Shipments Analysis and National Impact 

3:00–3:15 pm Preliminary Manufacturer Impact Analys

3:15–3:30 pm NOPR Analyses

3:30–4:00 pm Other Issues and Comments

4:00 pm Closing Remarks
5

Opening Remarks

Meeting participants are invited to provide open

remarks or statements at this time.
6

Public Meeting Topics

1 Housekeeping Items2 Rulemaking Process Overview3 Authority & Definitions4 Test Procedure & Test Metrics5 Rulemaking Analyses6 Closing Remarks
7

Housekeeping Items – Listening Via the Webca• The Department is broadcasting this meeting live ov

Internet.

• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
8

Purpose of the Framework Document Public Mee

• Present the analytical approaches to be used to eval

energy conservation standards for commercial prerin

valves (CPSV)

• Inform interested parties of and facilitate the rulema

process

• Provide a forum for public discussion of rulemaking i• Encourage interested parties to submit data, informa

written comments

Housekeeping Items – Purpose of Meeting
9

Request for Comment

• The list of items requesting comment is in the Framework d

available at

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.a

Housekeeping Items – Request for Comment

Item #‐#: DOE solicits comment on a range of specific issuthroughout the Framework document.

• Throughout this presentation, these issues will be high

for discussion in comment boxes such as this.

• Item numbers correspond to those in the Framework

document.

• DOE welcomes comments concerning these specific iss

and any other issues related to this rulemaking.
10

Instructions for Submitting Comments

In all correspondence, please refer to the CPSV rulemaking by:

– Standards for Commercial Prerinse Spray Valves– Docket Number EERE‐2014‐BT‐STD‐0027

– Regulation Identification Number (RIN) 1904‐AD31

Email: SprayValves2014STD0027@ee.doe.govPostal: Courier:Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies PrograMailstop EE‐2J 950 L’Enfant Plaza SW, Suite 6

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes October 27, 2014

Housekeeping Items – Submitting Comments
11

Public Meeting Topics

1 Housekeeping Items2 Rulemaking Process Overview3 Authority & Definitions4 Test Procedure & Test Metrics5 Rulemaking Analyses6 Closing Remarks
12

Standards Development

• The Energy Policy and Conservation Act (EPCA) of 1975 established th

Conservation Program for Consumer Products Other Than Automobile

includes commercial prerinse spray valves (42 U.S.C. 6291(33))

• EPCA directs DOE to develop new or amended standards designed to 

maximum improvement in energy efficiency that is technologically fea

economically justified

• EPCA also requires that, not later than 6 years after the issuance of a f

establishing or amending a standard, DOE publish:

(A) A notice of proposed rulemaking proposing new standards; or

(B) A notice of determination that the existing standards do not need to be 

U.S.C. 6295(m)(1))

Rulemaking Process Overview
13

• EPCA directs DOE to consider seven factors for analysis whe

technologically feasible and economically justifiable standar

Rulemaking Process Overview

EPCA Factor DOE Analysis

1. Economic impact on customers and 

manufacturers

• Life-cycle Cost (LCC) An• Manufacturer Impact Ana

2. Lifetime operating cost savings • LCC Analysis3. Total projected energy and water 

savings • National Impact Analysis 

4. Impact on utility or performance • Engineering Analysis • Screening Analysis5. Impact of any lessening of competition • MIA6. Need for national energy conservation • NIA7. Other factors the Secretary considers 

relevant

• Emissions Analysis• Utility Impact Analysis• Employment Impact Ana
14

Test Procedure and Standard Rulemakings Timel

Rulemaking Process Overview

Framework

Document

Preliminary

Analysis NOPR 

Final

Rule NOPR

Energy Conservation

Standard (ECS)

Test Procedure (TP)

(if applicable)

• ECS and TP rulemakings are separate processes but sometimes have int

timelines

• The expected ECS rulemaking timeline duration for CPSV is about 2 yea

• The expected TP rulemaking timeline duration for CPSV is about 1.5 yea

• For additional information on the rulemaking process go to:

http://www1.eere.energy.gov/buildings/appliance_standards/standards_dev_and
15

Framework Document

• Accompanying Federal Register notice of public meeting (NOPM

- Gives notice of the public meeting, availability of the Framew

document being discussed today, and encourages interested 

submit comments

- The Framework was posted September 8, 2014 on DOE’s web

http://www1.eere.energy.gov/buildings/appliance_standards

aspx?ruleid=100.

- The NOPM was published September 11, 2014 (79 FR 54213)

• Provides an overview of the rulemaking process and encourage

participation from interested parties

• Invites comments on resources and data sources

• Invites comments on proposed approach issues

Rulemaking Process Overview

Framework

Document

Preliminary

Analysis NOPR Final Rule
16

Preliminary Analysis

Rulemaking Process Overview

Framework

Document

Preliminary

Analysis NOPR Final Rule

• Accompanying Federal Register NOPM

- Gives notice of the public meeting, availability of the p

technical support document (TSD), provides discussion 

comments received in response to the Framework docu

encourages interested parties to submit comments

• Analysis

– Design options to increase efficiency

(engineering analysis)

– Manufacturer‐to‐user markups

– Energy and water use– Customer LCC and payback period

(PBP)

– Shipments– National impacts, including 

energy savings (NES), natio

savings, and customer net 

(NPV)

– Preliminary analysis of ma

impacts
17

Notice of Proposed Rulemaking (NOPR)

Rulemaking Process Overview

Framework

Document

Preliminary

Analysis NOPR Final Rule

• Federal Register Publication

- Gives notice of the public meeting, availability of the re

and encourages interested parties to submit comments

- Provides discussion of comments received in response t

preliminary analysis TSD

- Presents any proposed standard levels for public comm

• Analyses

– Customer Subgroup– Manufacturer Impact

– Employment Impact– Utility Impact– Emissions and Monetization– Regulatory Impact
18

Final Rule

Rulemaking Process Overview

Framework

Document

Preliminary

Analysis NOPR Final Rule

• Federal Register Publication

- Announces availability of the final TSD

- Provides discussion of all written and verbal comments 

response to the proposed standard

- Presents the standard levels DOE is adopting

- Establishes the compliance date for adopted standards

• Final TSD

- Presents the revised analysis of the impacts of standard

the weight of those impacts on the final rule
19

Rulemaking Schedule

Rulemaking Process Overview

2014 2015 2016 

Framework Document

Public Meeting

September 2014

Preliminary Analysis

Public Meeting

Planned Spring 2015

NOPR Public Meeting

Planned Fall 2015

P

Con

Fina

Plan
20

Public Meeting Topics

1 Housekeeping Items2 Rulemaking Process Overview3 Authority & Definitions4 Test Procedure & Test Metrics5 Rulemaking Analyses6 Closing Remarks
21

Authority and Background—Overview

• Title III of EPCA sets forth a variety of provisions designe

improve the energy efficiency of various products and eq

• Part B of Title III provides for the “Energy Conservation P

Consumer Products Other Than Automobiles” (42 U.S.C. 

6309)

• The Energy Policy Act of 2005 (EPAct 2005) amended sec

EPCA, which now states that commercial prerinse spray v

manufactured on or after January 1, 2006 shall not have 

of more than 1.6 gallons per minute (gpm)

Authority & Definitions
22

Scope of Coverage

• EPCA definition of Commercial Prerinse Spray 

- “A handheld device designed and marketed for use wit

commercial dishwashing and ware washing equipment 

water on dishes, flatware, and other food service items 

purpose of removing food residue before cleaning the 

(10 CFR 431.262)

- DOE is considering modifications to the definition of co

prerinse spray valve to clarify the scope of coverage, if 

Authority & Definitions
23

Authority to Modify Definition

• Under EPCA, the Secretary may modify the definition of “commercial 

spray valve” by rule –

• (i) to include products –

(I) that are extensively used in conjunction with commercial dishwashing and war

equipment;(II) the application of standards to which would result in significant energy saving(III) the application of standards to which would meet the criteria specified in sec

this title; and

• (ii) to exclude products –

(I) that are used for special food service applications;

(II) that are unlikely to be widely used in conjunction with commercial dishwashin

washing equipment; and

(III) the application of standards to which would not result in significant energy sa

(42 U.

Authority & Definitions

Item 1‐1: DOE requests comment on modifications to thedefinition of “commercial prerinse spray valve” that may c

what equipment is covered.
24

Prerinse Spray Valve Metric

• As part of this rulemaking DOE may consider adoptin

alternative water consumption metric to replace the flow rate (gpm) metric

• DOE will consider alternatives that will achieve ener

water savings, and preserve equipment utility

• Two possible metrics DOE could consider:

• A performance metric that accounts for both flow rate and spray 

• A metric that directly correlates water use to the time taken to cl

measured in gallons per dish

Authority & Definitions

Item 1‐2: DOE requests comment on potential metrics other rate that may be used to achieve greater water savings in co

prerinse spray valves and if there is sufficient benefit to using 

alternative metric to justify changing from the current flow r
25

Public Meeting Topics

1 Housekeeping Items2 Rulemaking Process Overview3 Authority & Definitions4 Test Procedure & Test Metrics5 Rulemaking Analyses6 Closing Remarks
26

Current Test Procedure

• EPCA specifies that the test procedure for measuring flow 

(gpm) for commercial prerinse spray valves shall be based 

Standard F2324 “Standard Test Method for Pre‐Rinse Spr

42 U.S.C 6293(b)(14)

• In October 2013, DOE published a final rule that incorpor

reference the test procedure specified in ASTM Standard 

(2009)

• Although ASTM Standard F2324‐03 (2009) includes a test f

qualitative cleanability test, the current DOE test procedur

incorporates testing methods for measuring flow rate

Test Procedure & Test Metrics
27

Potential Test Procedure Updates

• Since the publication of the 2013 test procedure, ASTM has iss

Standard F2324‐13 to reflect changes in the industry

• The primary change to the ASTM test procedure was to replace th

cleanability test with a spray force test

- Cleanability test evaluates the cleaning time of a standard din

measured in seconds per plate

- Spray force test measures the amount of force exerted by the 

water, measured in ounce‐force (ozf)

- These changes do not impact the energy/water use measure

DOE test procedure, but could be used as a way to establish Cequipment classes

Test Procedure & Test Metrics

Item 1‐3: DOE requests comment on the potential use of AS13 as the method of test for measuring the water consumpt

commercial prerinse spray valves.
28

Public Meeting Topics

1 Housekeeping Items2 Rulemaking Process Overview3 Authority & Definitions4 Test Procedure & Test Metrics5 Rulemaking Analyses6 Closing Remarks
29

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
30

• Purpose:

– Characterize the commercial prerinse spray valve 

and the technologies that improve efficiency

• Method:

– Identify and characterize manufacturers of comm

prerinse spray valves

– Estimate shipments and trends in the market– Identify technologies that could improve efficienc

Rulemaking Analyses: Market & Technology
31

Rulemaking Analyses: Market & Technology

Trade Groups

• Plumbing Manufacturers International (PMI) is the primary trad

organization that supports and has an interest in commercial pr

valves

• North American Association of Food Equipment Manufacturers 

a trade association of over 500 foodservice equipment manufac

is another organization that may be interested in commercial pr

spray valves

Retailers

• Prerinse spray valves are generally available to customers at:

‐ Brick‐and‐mortar retailers (mass market retailers, specia

club or warehouse stores)

‐ Internet sellers

‐ Showrooms

Item 3‐3: DOE seeks information regarding any other trade org

that represent the commercial prerinse spray valve industry
32

Rulemaking Analyses: Market & Technology

• 49 basic models were found

using the DOE Compliance

Certification Management

System (CCMS) database, the

EPA WaterSense® product

database, manufacturerwebsites, and Web searches

• Shows the estimated

percentages of basic models by

manufacturer in the U.S. marketfor commercial prerinse spray

valves

Manufacturers

Niagara

Conservation,

2%

Mueller

Streamline Co.,

4% 

Bricor Analy

Inc, 8%

Fisher

Manufacturing,

12%

Zurn Industries,

12%

T&S Brass, 16%

Component

Hardware

Group, 27%
33

Rulemaking Analyses: Market & Technology

Equipment Classes

• Pursuant to EPCA, DOE establishes different equipment classes 

type of energy used; (2) capacity of the product; or (3) any oth

performance‐related features that require different standard le

as features affecting customer utility (42 U.S.C. 6295(q))

• All commercial prerinse spray valves are currently included in a 

equipment class subject to a maximum flow rate of 1.6 gpm

• DOE will examine whether any of the following characteristics 

used for establishing equipment classes:

• Flow rate (gpm)

• Spray force (ozf)• Cleanability time (seconds/plate)

• Design of flow control insert

• Other equipment features that change functionality, e.g., spra
34

Item 3‐8: DOE requests input from interested parties about the de

characteristics and criteria that are being considered to create equ

classes. In particular, do other performance‐related features warra

separate standard levels?

Item 3‐9: DOE seeks comment on whether spray force or cleanabi

useful characteristics that could define the equipment classes of a 

spray valve.Item 3‐10: DOE requests comment on how ultra‐low flow spray va

from other spray valves in usage, functionality, features, and clean

Rulemaking Analyses: Market & Technology
35

Rulemaking Analyses: Market & Technology

• Addition of a flow control insert

• Smaller nozzle tip openings

• Incorporation of additional components, e.g., backflow preve

additional valves, or hoses

• Specially designed spray patterns, e.g.,

• Cone• Solid stream

• Triple solid stream

• Flat fan

• Shower

• DOE is considering the following technology options to i

the efficiency of commercial prerinse spray valves:

Technology Options
36

Rulemaking Analyses: Market & Technology

Spray pattern Description 

Cone Nozzle with hollow or solid cone spray, variety of

cone angles (“fan”)

Solid stream Nozzle with single solid jet stream

Triple solidstream

Nozzle with three spray holes, each with solid jet

streams (“triple action,” “tri‐tip”)

Flat Fan Nozzle producing flat, fan jet stream at various

angles (“knife‐like”)

Shower Spray face with multiple spray holes, resembles

a common showerhead (“rose spray”)

Item 3‐12: DOE seeks information on what technology options ar

to improve the performance of commercial prerinse spray valves
37

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
38

• Purpose:

─ Screen‐out technology options that DOE will not con

engineering analysis for commercial prerinse spray v

• Method:

─ DOE will evaluate each technology option based on t

following criteria:

• Technological feasibility• Practicability to manufacture, install, and service

• Adverse impacts on product utility or availability to cu

• Adverse impact on health and safety

─ The technology options that are not screened out w

adopted as design options in the engineering analys

Rulemaking Analyses: Screening Analysis
39

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
40

• Purpose: Determine the relationship between manufacturer s

(MSP) and efficiency

Overview

Rulemaking Analyses: Engineering Analysis

• Life-cycle Cost an

Payback Period

• National Impact 

Analysis

Cost – Efficiency 

Relationship

MSP

Water Use

Analyses Using Cos

Efficiency Relationsh
41

 Analyze all equipment classes

 The baseline efficiency level is 1.6 gpm based on t

standard

 For all equipment classes, identify the efficiency a

more efficient units based on design option mode

testing, and teardowns; identify the maximum tec

feasible (max‐tech) level for each equipment class

 Develop efficiency levels that range from the base

tech

 The result of the engineering analysis will be a set 

efficiency curves (MSP vs. efficiency) for each equ

Choose

Representative

Equipment Classes

and Sizes

Select Baseline

Efficiency Levels

Identify Higher

Efficiency

Units

Develop

Efficiency Levels for

Analysis

Determine Cost

Efficiency

Relationship

Rulemaking Analyses: Engineering Analysis
42

Baseline Models

• Baseline models are selected based on common feat

minimally compliant equipment efficiency

– baseline efficiency is 1.6 gpm at 60 pounds per square inch 

• If an efficiency metric other than gpm is selected, th

efficiency will be chosen to prevent backsliding

Item 5‐3: DOE seeks information regarding the specific tech

characteristics of baseline models.

Rulemaking Analyses: Engineering Analysis
43

Rulemaking Analyses: Engineering Analysis

Efficiency Levels

• DOE will identify the highest efficiency model in the mark

tech) for each class

• DOE will analyze the costs associated with implementing 

screened‐in design options to improve spray valve efficie

baseline efficiency to max‐tech

• Design options that DOE is tentatively considering include 

addition of a flow control insert, smaller nozzle tip openin

incorporation of additional components, and specially de

spray patterns
44

Cost‐Efficiency Relationship and Analysis

• DOE will develop a cost model that converts bills of materials (

baseline models and the cost of design options for different eff

levels into manufacturer production costs (MPCs)

─ Component costs will be determined using reverse engineering (p

teardowns) and manufacturer feedback (engineering interviews)

• Manufacturer selling price (MSP) is based on the manufacturin

prerinse spray valve hardware times the manufacturer markup

– The industry‐wide manufacturer markup will be determined base

available financial sources (e.g., SEC Form 10‐K) and manufacture

Rulemaking Analyses: Engineering Analysis

Manufacturer

Production

Cost (MPC)

Manufacturer

Markups x

(Non‐Production Costs)

=

• Direct material• Direct labor• Factory overhead• Depreciation

• Sales & marketing

• Research &

development

• Interest• Profit

Manufacturer

Selling Price

(MSP)
45

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
46

• Purpose

– Assess the economic impacts of potential energy cons

standards on manufacturers

– Identify and estimate impacts on manufacturer subgro

may be more adversely affected than the industry as a 

– Examine the direct employment impacts, manufacturi

and the cumulative regulatory impact on the manufact

industry

• Methodology

– Analyze industry cash flow and industry net present va

use of the Government Regulatory Impact Model (GRI

– Interview manufacturers to refine inputs to the GRIM, 

subgroup analyses, and address qualitative issues

Rulemaking Analyses: Preliminary Manufacturer Impa
47

Completeindustryprofile

DevelopstrawmanGRIM

Developinterviewguide

Conduct

interviews &

industry‐

wide/

subgroup

analyses

Assess directemployment,manufacturingcapacity, andcumulativeburden

Phase 1 Phase 2 Phase 3

Rulemaking Analyses: Preliminary Manufacturer Impa

Overview

Item 12‐1: DOE seeks comment on the appropriate manufacture

subgroups, if any, for commercial prerinse spray valves that DOE 

consider in a manufacturer subgroup analysis.
48

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
49

• Purpose:

- Estimate actual user purchase prices from manufa

selling prices of baseline and higher‐efficiency equ

designs

• Method:

- Identify distribution channels and estimate share o

channel in the aggregate sales volume

- Estimate markup values for each level in the ident

distribution channels

Rulemaking Analyses: Markups Analysis
50

Rulemaking Analyses: Markups Analysis

Identified Distribution Channels

• Manufacturer  Final Customer

• Manufacturer  Authorized Distributor  Final Custo

• Manufacturer  Retail Merchant  Final Customer

Item 6‐1: DOE seeks comment on the distribution channels ashare of industry shipments for each distribution channel as t

apply to the range of commercial prerinse spray valves that a

covered by this potential rule.
51

• Baseline, Incremental, and Overall Markups

- Baseline markups are cost multipliers that convert the MSP 

equipment at the baseline efficiency level to customer purc

- Incremental markups are cost multipliers that convert the in

increase/change in MSP for equipment at each higher‐effici

(compared to the MSP at baseline efficiency level) to corres

incremental increases/changes in the customer purchase p

- Overall markups include the weighted‐average distribution 

markups, based on distribution channel market shares, and 

Rulemaking Analyses: Markups Analysis
52

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
53

• Purpose:

- Assess the annual energy and water use for all efficiency 

all equipment classes

- Provide the basis for unit energy and water costs, which 

the life‐cycle cost analysis

• Method:

- Wastewater discharge will be assumed to be 100% of w

- Energy use will be estimated by calculating the energy r

raise the supply water temperature (by region) to the en

temperature, taking into account the heating efficiency 

representative water heating equipment

- Daily data will be annualized by taking into account the 

operating days per year by equipment class

Rulemaking Analyses: Energy and Water Use A
54

Rulemaking Analyses: Energy and Water Use A

Item 7‐1: DOE requests input on operational patterns of comprerinse spray valves for different equipment classes and

applications that may impact water use.

Item 7‐2: DOE seeks recommendations on sources of data for

regional potable water supply temperatures and typical oper

water temperatures used in commercial prerinse spray valves 

different applications and equipment classes.

Item 7‐3: DOE seeks comments on the inclusion of associated

reduction in wastewater discharge as a result of lower flow ra

prerinse spray valves.
55

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
56

• Purpose:

- Assess economic impacts of different efficiency levels o

customers of commercial prerinse spray valves

• Method:

- Results are expressed in terms of LCC savings (LCC at ba

efficiency level compared to LCC at higher efficiency lev

- PBP, expressed in number of years, is calculated by divi

incremental equipment first cost at a higher‐efficiency corresponding annualized operating cost savings

Rulemaking Analyses: LCC and PBP Analysis
57

Rulemaking Analyses: LCC and PBP Analysis

LCC Component Calculation MethodologyEquipmentPurchase Price

Mark up MSP by the appropriate distribution cha

markup values

Installation Cost Includes labor and material costs to place the equ

service

Maintenance Cost Incurred by the customer for preventative mainte

equipment

Repair Cost Repair or replace damaged or malfunctioning com

the equipment

Energy and Water

Cost

Paid by the customer for the energy and water us

water‐using equipment• Energy – Use Energy Information Administratio

Energy Outlook to estimate energy prices

• Water – Use American Water Works Associatio

Survey to estimate current water and wastewa
58

• Other Major Parameters in the LCC and PBP Analysis

• Discount Rates

- DOE will derive discount rates for different customers by esti

weighted average cost of capital for different customers and 

types that own and/or operate the equipment

• Base Case Efficiency Distribution

- Base case efficiency distribution is the distribution of the mar

each efficiency level for all equipment classes in the absence amended DOE standard

- If market share data are not available by efficiency level, DOE 

develop base case efficiency distributions based on available 

information from commercial prerinse spray valve manufactu

experts

• Equipment Lifetime

- The average and typical range of the equipment lifetime will 

determined based on literature and industry inputs for each 

class

Rulemaking Analyses: LCC and PBP Analysis
59

• Approach: Monte Carlo Simulations

• The LCC analysis is carried out using Monte Carlo simu

• For each of a large number of samples (e.g., 10,000), 

values are chosen based on the probability of their oc

these values are then combined to calculate the LCC a

that particular individual sample

• The LCC, LCC savings, and PBP are expressed in the fo

mean or median values

• The LCC results are also presented in the form of estim

percentage of customers that benefit from, are adver

affected by, and/or are unaffected by amended stand

Rulemaking Analyses: LCC and PBP Analysis
60

Rulemaking Analyses: LCC and PBP Analysis

Item 8‐3: DOE seeks comment on sources of data for determmarginal water and wastewater rates and methods to break 

water and wastewater rates across different pricing segment

as regionally or by state).

Item 8‐4: DOE seeks data sources and methods to determine 

trends in water and wastewater rate escalations.

Item 8‐5: DOE invites comment on whether repair costs may 

for more‐efficient commercial prerinse spray valves.

Item 8‐6: DOE invites comment on whether commercial prer

spray valves are typically replaced upon failure or repaired.

Item 8‐7: DOE seeks comment on appropriate commercial pr

spray valve lifetimes for the equipment under consideration, as data regarding correlation between hours of use and comm

prerinse spray valve lifetime.
61

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
62

• Purpose:

- Project future shipments by equipment class

• Method:

- DOE typically projects shipments for a 30‐year period 

with the expected compliance date of the standard

- DOE intends to collect historical shipment data for com

prerinse spray valves from trade organization surveys

- Future shipments will be calculated based on the histo

shipments data, retirement rates of equipment, and th

forecast of new commercial construction

- DOE may use different shipments projections in the st

and base case scenarios depending on the information 

Rulemaking Analyses: Shipments Analysis
63

Rulemaking Analyses: Shipments Analysis

Item 9‐1: DOE seeks comment on an appropriate shipmprojection methodology, including the selection of

appropriate economic drivers.

Item 9‐2: DOE requests historical shipments data for the

equipment discussed, including shipments for differing

equipment flow rates.Item 9‐3: DOE seeks comment on how an energy conse

standard for commercial prerinse spray valves might imshipments of the equipment.
64

Rulemaking Analyses

Market & Technology

ScreeningAnalysis

EngineeringAnalysis Markups Analysis

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Shipments Analysis

Framework

Document

Preliminary

Analysis NOPR Final Rule

Energy and Water Use Analysis
65

Rulemaking Analyses: National Impact Analysi

• Purpose:

– Determine the projected national impacts of an amended s

form of NES, national water savings and NPV

• Method:

– Develop annual series of national energy, water and econom

• Use LCC outputs to provide input about installed costs, energy u

use per unit

• Use the shipments model to estimate annual shipments and sto

– Aggregate the costs, energy use, and water use for all years 

period

– Report NES in primary and full‐fuel‐cycle (FFC) savings, NPV 

dollars, and national water and wastewater savings in billio

– Account for the time‐value of money though defined discou
66

Rulemaking Analyses: National Impact Analysi

• Inputs for calculating NES and National Water Savin

- Annual energy and water use at each efficiency level f

equipment classes

- Projected shipments- Equipment stock (based on historical and projected sh

- Site‐to‐source conversion factors: Multipliers used to 

energy used at the site to energy produced at the sou

• Inputs for calculating NPV:

- Installed and operating costs of all equipment for each 

analysis period

- Discount rates (3 percent and 7 percent)
67

Rulemaking Analyses: National Impact Analysi

Item 10‐1: DOE seeks comment on how the efficiency ocommercial prerinse spray valves would be likely to chathe future in the absence of standards.

Item 10‐2: DOE seeks comment on the likelihood of inc

commercial prerinse spray valve usage as a direct result 

improved equipment efficiency.
68

Rulemaking Analyses

Framework

Document

Preliminary

Analysis NOPR Final Rule

Manufacturer

Impact 

Analysis

Customer 

Subgroup 

Analysis

RevisePreliminary Analysis

Emission

Analysis 

Monetizat

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalysis

National

Impact

Analysis

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

NOPR Analyses
69

• Purpose:

– Analyze the economic impacts of standards on customer su

who may be disproportionately impacted compared with t

user population

• Examples include customers who use equipment less frequently, 

utility rates, and/or have higher discount rates than the typical cu

• Method:

– Change parameters within the LCC model to model the diff

between identified subgroups relative to the general popu

– The subgroup analysis results will be compared to the natio

results (from the LCC analysis) to determine the impact of s

on the identified subgroups

Rulemaking Analyses: Customer Subgroup Ana

Item 11‐1: DOE seeks comment on what, if any, user subgroushould be considered in evaluating potential standards for

commercial prerinse spray valves.
70

Rulemaking Analyses

Framework

Document

Preliminary

Analysis NOPR Final Rule

Manufacturer

Impact 

Analysis

Customer 

Subgroup 

Analysis

RevisePreliminary Analysis

Emission

Analysis 

Monetizat

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalysis

National

Impact

Analysis

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

NOPR Analyses
71

Rulemaking Analyses: Utility Impact Analysis• Purpose:

– Assess the overall impacts on domestic energy supplies tha

result from the imposition of standards

• Method:

– DOE plans to use factors derived from NEMS‐BT (a variant o

(National Energy Modeling System) developed and used by 

for their AEO report) as the basis of the utility impact analy

– Outputs of the utility impact analysis include projections of 

sales and prices, generation, and capacity in the base and s

cases

Item 13‐1: DOE seeks comment from interested parties abouproposed use of NEMS‐ BT to conduct the utility impact analy

Item 13‐2: DOE seeks comment and information on potentia

methods and data sources that can be used to assess the imp

water and wastewater utilities as a result of energy conserva

standards for commercial prerinse spray valves.
72

Rulemaking Analyses

Framework

Document

Preliminary

Analysis NOPR Final Rule

Manufacturer

Impact 

Analysis

Customer 

Subgroup 

Analysis

RevisePreliminary Analysis

Emission

Analysis 

Monetizat

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalysis

National

Impact

Analysis

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

NOPR Analyses
73

Rulemaking Analyses: Employment Impact An• Purpose:

– Assess the overall impact on national employment from th

imposition of efficiency standards at differing levels

– Includes only indirect employment impacts

• Direct employment impacts are estimated in the MIA

• Indirect employment impacts result from shifting customer e

among goods and services ( “substitution effect”) and changi

equipment and energy costs (“income effect”)

• Method:

– DOE intends to use the ImSET (Impact of Sector Energy Tec

model for the evaluation of indirect employment impacts

Item 14‐1: DOE seeks comments about its suggested approacassessing national indirect employment impacts.
74

Rulemaking Analyses

Framework

Document

Preliminary

Analysis NOPR Final Rule

Manufacturer

Impact 

Analysis

Customer 

Subgroup 

Analysis

RevisePreliminary Analysis

Emission

Analysis 

Monetizat

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalysis

National

Impact

Analysis

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

NOPR Analyses
75

Rulemaking Analysis: Emissions Analysis• Purpose:

– Estimate environmental impacts from potential energy con

standards for commercial prerinse spray valves including ch

FFC emissions

• Method:

– DOE will base the emission factors on NEMS, supplemente

from other sources; the following emissions are assessed:

• Carbon dioxide (CO2)

• Sulfur dioxide (SO2)

– SO2 emissions from affected electric generating units are subjec

nationwide and regional emissions cap and trading programs

• Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emission

States and Washington, D.C.

• Methane (CH4)

• Nitrous oxide (N2O)

• Mercury (Hg)
76

Item 15‐1: DOE seeks comment about its approach to cthe emissions analysis for the equipment that would be

covered under this proposed rulemaking.

Item 15‐2: DOE seeks comment and information on pot

methods and data sources that can be used to assess

emissions reductions as a result of water savings.

Rulemaking Analyses: Emissions Analysis
77

Rulemaking Analyses: Monetization of Reduced Em

• DOE intends to use the most current Social Cost of Carbo

values developed by interagency reviews

– SCC is intended to be a monetary measure of the incremen

resulting from greenhouse gas emissions, including, but no

agricultural productivity loss, human health effects, proper

from rising sea level, and changes in the ecosystem

• DOE will also estimate the potential monetary benefit of 

NOx emissions resulting from the considered standard lev

Item 16‐1: DOE requests comment about the approach plans to use for estimating monetary benefits associate

emissions reductions.
78

Rulemaking Analyses

Framework

Document

Preliminary

Analysis NOPR Final Rule

Manufacturer

Impact 

Analysis

Customer 

Subgroup 

Analysis

RevisePreliminary Analysis

Emission

Analysis 

Monetizat

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalysis

National

Impact

Analysis

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

NOPR Analyses
79

Rulemaking Analysis: Regulatory Impact Analy• Purpose:

– Explore the potential savings for non‐regulatory altern

new or amended energy efficiency standards

• Method:

– Determine the energy and monetary savings impact o

regulatory alternative to a new or amended standard

– Some examples include:

– Tax Credits– Rebate Programs

– Bulk Purchase Programs

– WaterSense
80

Public Meeting Topics

1 Housekeeping Items2 Rulemaking Process Overview3 Authority & Definitions4 Test Procedure & Test Metrics5 Rulemaking Analyses6 Closing Remarks
81

How to Submit Written Comments

In all correspondence, please refer to the Commercial Prerinse Sp

rulemaking by:

– Framework Document for Commercial Prerinse Spray Valves

– Docket Number EERE‐2014‐BT‐STD‐0027

– Regulation Identification Number (RIN) 1904‐AD31

Email: SprayValves2014STD0027@ee.doe.gov or www.regulationsPostal: Courier:Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies PrograMailstop EE‐2J 950 L’Enfant Plaza SW, Suite 6

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes October 27, 2014

Closing Remarks