October 1, 2013

Docket Number: EERE-2013-BT-STD-0030

PkgdBoilers2013STD0030@ee.doe.gov

Energy Conservation Standards

Framework for Commercial Packaged Boilers
2

Welcome and Introduction

• Introductions

• Role of the Facilitator

• Ground Rules

– Listen as an ally

– Focus on issues

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– One person speaks at a time (raise hand to be recognized; state your name for 

the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

• Agenda Review

• Opening Remarks

Title Slide, Boiler Photo Source: http://www.easco.com/mobile-temporary-boilers-rentals.html 
3

Morning Agenda

9:00 – 9:05 am Welcome

9:05 – 9:20 am Opening Remarks, Introductions, and Agenda Review

9:20 – 9:30 am Regulatory History

9:30 – 10:00 am Rulemaking Process Overview

10:00 – 10:15 am Break

10:15 – 11:00 am Scope and Test Procedure

11:00 – 11:30 am Market & Technology Assessment

11:30 – 11:50 am Screening Analysis, Engineering Analysis 

11:50 – 12:10 pm Markups and Energy Use Analyses

12:10 – 12:30 pm Life-Cycle Cost and Payback Period Analysis

12:30 – 1:30 pm Break for Lunch
4

Afternoon Agenda

1:30 – 1:50 pm Shipments Analysis and National Impact Analysis

1:50 – 2:10 pm Preliminary Manufacturer Impact Analysis

2:10 – 2:30 pm NOPR Analyses

2:30 – 3:00 pm Next Steps and Closing Remarks 
5

Public Meeting Agenda

Scope and Test Procedures

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
6

Listening Via the Webcast

• The U.S. Department of Energy (DOE) is broadcasting this meeting live 

over the internet. 

• DOE is providing the webcast to accommodate interested parties that are 

unable to attend the public meeting in person.

• The web broadcast allows interested parties to listen in, view the slides, 

and submit questions and comments.

• All interested parties are encouraged to submit written comments after 

the public meeting but before the close of the public comment period on 

October 18, 2013.
7

Purpose of the Public Meeting

• Present the Framework Document’s procedural and analytical approaches 

for evaluating potential amended energy conservation standards for 

commercial packaged boilers.

• Provide a forum for public discussion of rulemaking matters.

• Facilitate the rulemaking process.

• Encourage participants to submit data, information, summary statements, 

and written comments, including additional issues for discussion.
8

Request for Comment

Issue box numbering corresponds to the list of items published at the end of 

the Framework Document, available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/p

roductid/74

The deadline for submitting comments is October 18, 2013. 

While DOE invites comment on all aspects of the material presented in 

this document, several specific issues on which DOE seeks comment are 

set out in comment boxes like this one. DOE uses these comment boxes 

to highlight issues and to ask specific questions on the approaches DOE 

plans to follow to conduct the analyses required for this energy 

conservation standards rulemaking. Such requests for feedback are 

numbered sequentially throughout the document. 
9

Opening Remarks

Meeting participants are invited to provide opening 

remarks or statements at this time. 
10

Public Meeting Agenda

Scope and Test Procedures

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
11

Regulatory History

• The Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 

94-163)

– Established the Energy Conservation Program for Certain 

Commercial and Industrial Equipment

• The Energy Policy Act of 1992 (EPACT 1992), (Public Law 102−486) 

amended EPCA to add commercial packaged boilers as a type of 

covered equipment. (42 U.S.C. 6311(1)(J) and (11)(B)) 

• EPCA directs DOE to consider amending existing Federal energy 

conservation standards for commercial packaged boilers whenever 

the American Society of Heating, Refrigerating, and Air-Conditioning 

Engineers (ASHRAE) amends the efficiency levels in Standard 90.1. 

(42 U.S.C. 6313(a)(6)) 

• The Energy Independence and Security Act of 2007 (EISA 2007) 

(Public Law 110-140) and the American Energy Manufacturing 

Technical Corrections Act (AEMTCA) (Public Law 112-210) amended 

EPCA to require that every 6 years, the Secretary publish either:

• (I) a notice of the determination that standards for the product 

do not need to be amended; or

• (II) a notice of proposed rulemaking including new proposed 

standards (42 U.S.C. 6313(6)(C)(i))
12

Regulatory History

• DOE published a final rule in 2009 (74 FR 36312 (July 22, 2009)).

– Adopted energy conservation standards that correspond to the levels in 

ASHRAE Standard 90.1-2007. These standards are codified at 10 CFR 431.87(b).

Boiler Type Subtype Size category (input, BTU/H) Efficiency 

Level

Hot Water Gas-fired 300,000 - 2,500,000 80.0% ET

Hot Water Gas-fired > 2,500,000 82.0% EC

Hot Water Oil-fired 300,000 - 2,500,000 82.0% ET

Hot Water Oil-fired > 2,500,000 84.0% EC

Steam Gas-fired—all, except natural draft 300,000 - 2,500,000 79.0% ET

Steam Gas-fired—all, except natural draft > 2,500,000 79.0% ET

Steam Gas-fired—natural draft 300,000 - 2,500,000 77.0% ET

*

Steam Gas-fired—natural draft > 2,500,000 77.0% ET

*

Steam Oil-fired 300,000 - 2,500,000 81.0% ET

Steam Oil-fired > 2,500,000 81.0% ET

ET – Thermal efficiency, EC – Combustion efficiency

* Efficiency level will increase to 79.0% ET on March 2, 2022

Table 1. Commercial Packaged Boiler Equipment Minimum Efficiency Standards – Effective Date: March 2, 2012
13

Public Meeting Agenda

Scope and Test Procedures 

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
14

• TP and ECS rulemakings are separate processes but have integrated 

timelines.

• The TP rulemaking timeline duration is about 1.5 years from start to finish.

• The ECS rulemaking timeline duration is about 3 years from start to finish.

• For additional information on the rulemaking process go to:

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

Energy Conservation 

Standards (ECS)

Test Procedure (TP) NOPR Final 

Rule

Test Procedure and Standard Rulemakings Timelines

Framework

Document Preliminary 

Analysis

NOPR Final

Rule

Rulemaking Overview
15

EPCA Factors

• 42 U.S.C. 6313(a)(6)(B)(ii) directs DOE to consider seven factors when 

setting energy conservation standards.

EPCA Factors DOE Analysis

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the product Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary of Energy 

considers relevant

Environmental Assessment

Utility Impact Analysis

Employment Impact Analysis

Table 2. EPCA Factors and Associated Rulemaking Analyses
16

Framework Document

• Provides an overview of the rulemaking process and encourages early 

participation from interested parties.

• Invites comments on proposed approach and issues.

• Accompanying Federal Register Notice of Public Meeting (NOPM) – 78 FR 54197 

(Sept. 3, 2013).

– Gives notice of the public meeting and availability of the Framework 

Document being discussed today.

– Encourages interested parties to submit comments.

ECS Rulemaking Stages: Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule

Today
17

Preliminary Analysis Document

ECS Rulemaking Stages: Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule

• Preliminary Analyses:

• Federal Register Notice and Public Meeting 

(NOPM) – Planned July, 2014.

− Gives notice of the public meeting and 

availability of the Preliminary Technical 

Support Document (TSD).

− Encourages interested parties to submit 

comments.

− Design options to increase 

efficiency (engineering analysis).

− Manufacturer-to-user markups

− Energy use

− Consumer life-cycle cost (LCC) 

and payback period (PBP)

− Shipments

− National impacts (including national energy 

savings (NES) and consumer net present 

value (NPV)

− Preliminary analysis of manufacturer impacts

− Discussion of comments received in response 

to the Framework Document 
18

Notice of Proposed Rulemaking (NOPR) Document

• Discussion of comments received in response to Preliminary Analysis TSD.

• Analysis of the impacts of potential standards on consumers, manufacturers, and 

the Nation and weighting of these impacts.

• Any proposed standard levels for public comment.

• Federal Register publication of the NOPR – Planned July, 2015.

– Gives notice of DOE’s proposal, availability of the revised NOPR TSD, and the 

public meeting. 

– Encourages interested parties to submit comments.

ECS Rulemaking Stages: Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule
19

Final Rule Publication

• Discussion of comments received in response to the NOPR.

– DOE will consider all written comments and oral input (e.g., public meeting 

transcript) when preparing the final rule 

• Revision of the analysis of the proposed standards and weighing of the impacts 

to arrive at the final rule.

• Determination and promulgation of the energy efficiency standard levels that 

DOE is adopting.

• Establish the “effective date” and “compliance date” for any new standards

• Federal Register publication of the Final Rule – Planned July, 2016.

ECS Rulemaking Stages: Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule
20

Notice of Proposed Rulemaking (NOPR) Document

• Discussion of comments received from the ECS Framework public meeting.

• Analysis of the current test procedure and the need for updates or revisions.

• Federal Register publication of the NOPR – Planned September, 2014.

- Gives notice of DOE’s proposal and the public meeting. 

- Encourages interested parties to submit comments.

Test Procedure Rulemaking Stages: Overview

TP NOPR TP Final Rule
21

Final Rule Publication

Test Procedure Rulemaking Stages: Overview

TP NOPR TP Final Rule

• Discussion of comments received in response to the NOPR.

– DOE will consider all written comments and oral input (e.g., public meeting 

transcript) when preparing the final rule. 

• Revision of the analysis of any proposed amendments or revisions to the test 

procedure.

• Determination and promulgation of amendments or revisions to the DOE test 

procedure.

• Establish the “effective date” for any amendments or revisions to the test 

procedure.

• Federal Register publication of the test procedure Final Rule – Planned July, 2015.
22

Commercial Packaged Boiler Rulemaking Schedules

2013 2014 2015 2016 2017 2018

Rulemaking Milestone Date

ECS Framework Document August 2013

ECS Availability of the Preliminary Analysis (projected) July 2014

TP Test Procedure Notice of Proposed Rulemaking (NOPR) (projected) Sep 2014

TP Test Procedure Final Rule (projected) July 2015

ECS Notice of Proposed Rulemaking (NOPR) (projected) July 2015

ECS Final Rule (projected) July 2016

ECS Compliance Date (projected) July 2019

2019

Table 3. Commercial Packaged Boiler ECS and TP Rulemaking Schedules

2020

Energy Conservation 

Standards Timeline

Test Procedure 

Timeline
23

Public Meeting Agenda

Scope and Test Procedures

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
24

Scope of Coverage

• DOE plans to maintain the scope of coverage as 

defined by its current regulations. 

• At this time, DOE is not considering standards for 

electric commercial packaged boilers.

• This rulemaking may consider establishing energy 

conservation standards for energy consumption 

of boilers operating in standby mode and off 

mode.

• DOE recently published a notice of proposed 

determination (NOPD) regarding coverage of 

natural draft commercial packaged boilers. 78 FR 

49202 (August 13, 2013). As explained in the 

NOPD, DOE is performing a coverage 

determination to explicitly clarify its statutory 

authority under EPCA to cover natural draft 

commercial packaged boilers, because explicit 

coverage of this equipment is necessary to carry 

out the purposes of part A-1 of EPCA, 42 U.S.C. 

6311 et seq. 

Photo Source: http://www.cyclotherm.com/commercial.html
25

Scope of Coverage

Item 2-1: DOE welcomes comments on the proposed scope of coverage and on 

whether there are any additional types of commercial packaged boilers that 

should or should not be included in the scope of this rulemaking.

Item 2-2: DOE welcomes comments regarding the need to and feasibility of 

including electric commercial packaged boilers in this rulemaking.

Item 2-3: DOE requests comments on pursuing standby mode and off mode 

energy conservation standards for commercial packaged boilers.

Item 2-4: DOE welcomes comments as to whether there are any size-related 

issues with conducting testing under the DOE test procedure which the agency 

should consider addressing in its test procedure rulemaking. DOE is also 

interested in any comments regarding whether there is a capacity limit beyond 

which amended energy conservation standards would not be technologically 

feasible and economically justified.
26

Test Procedure

• Current DOE Test Procedure for Commercial Packaged Boilers (10 CFR 

431.86)

– Based on the Hydronics Institute (HI) division of the Air-Conditioning, Heating, 

and Refrigeration Institute (AHRI) Standard BTS–2000 (Rev 06.07), Method to 

Determine Efficiency of Commercial Space Heating Boilers.

– Updated in energy conservation standard Final Rule (74 FR 36312 (July 22, 

2009)).

– DOE believes that certain requirements of BTS-2000 may cause testing to be 

either difficult or unfeasible for manufacturers of certain commercial packaged 

boiler models.

• In the current rulemaking, DOE plans to analyze the alternative test procedures that 

are available and widely accepted within the industry.

• Efficiency Metric

– The majority of equipment classes are rated using steady-state thermal 

efficiency .

– Large (>2,500,000 Btu/h) hot water gas-fired and oil-fired commercial packaged 

boilers are rated using steady-state combustion efficiency.
27

Test Procedure

Item 3-1: DOE welcomes comments on all aspects of the current DOE test procedure for 

commercial packaged boilers and on whether the test procedure is in need of updates or 

revisions.

Item 3-2: DOE requests feedback on issues with the current test procedure that may 

make it burdensome or unfeasible for manufacturers to conduct testing on some or all 

models of commercial packaged boilers. Specifically, DOE requests comment whether 

the operating pressures required by BTS-2000 are not achievable for any commercial 

packaged boilers within the scope of this rulemaking.

Item 3-3: DOE requests feedback on testing conditions within the current test procedure 

that may need to be refined to ensure fair comparison of efficiencies across commercial 

packaged boiler models.

Item 3-4: DOE welcomes comments on alternative industry test methods for determining 

the efficiency for commercial packaged boilers, particularly with regards to how an 

alternative testing standard would improve or not improve upon the current test 

procedure based on BTS-2000, and on the comparability of efficiency ratings determined 

using the alternative standards to those from a BTS-2000 test.
28

Public Meeting Agenda

Scope and Test Procedures

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
29

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Markups 

Analysis
30

Market and Technology Assessment (M&TA)

Purpose

• Characterize the market, the commercial packaged boiler industry, and the 

measures to improve boiler efficiency.

Method

• Identify and characterize manufacturers of commercial packaged boilers;

• Estimate historical shipments and trends in the market;

• Identify regulatory and non-regulatory initiatives intended to improve the 

efficiency of the equipment covered under this rulemaking; 

• Characterize equipment currently available on the market; and

• Identify technologies that could improve efficiency.
31

M&TA: Equipment Classes

• DOE may divide covered equipment into equipment classes by: 

– (a) the type of energy used; 

– (b) the capacity of the equipment; and/or 

– (c) any other performance-related feature that justifies different standard levels. 

• At this time, DOE plans to maintain all commercial packaged boiler 

equipment classes.

– DOE may consider an electric commercial packaged boiler equipment class.

– In its August 13, 2013 notice of proposed determination (NOPD), DOE discusses 

natural draft boilers. DOE may consider a separate equipment category for 

natural draft commercial packaged boilers, which would include its own set of 

equipment classes. 
32

Market and Technology Assessment

Item 5-1: DOE welcomes data that would contribute to the market assessment, 

including but not limited to information on the national historical shipments, 

manufacturing costs, distribution channels, and manufacturer market share of 

commercial packaged boilers. 

Item 5-2: DOE welcomes information about organizations interested in the 

commercial packaged boilers rulemakings for energy efficiency standards and 

test procedures, including manufacturers, component manufacturers, 

assemblers, trade associations, utilities, inspectors, State agencies, energy 

efficiency advocates, and related organizations .

Item 5-3: DOE welcomes comment on its considered equipment classes. Are 

there any other performance-related features that should be considered for 

commercial packaged boilers equipment classes?
33

M&TA: Technology Options to Improve Efficiency

Item 5-4: DOE welcomes comments on the technologies identified, and any 

additional technology options which are not herein identified.

Table 5. Technology Options to Improve Combustion and/or Thermal Efficiency

Jacket Insulation Burner Derating

Condensing Boilers and Other Heat 

Exchanger Improvements

Combustion Air Preheaters

Improved Burner Technology Economizers 

Integrated, High-Efficiency Steam Boilers

Table 6. Technology Options to 

Reduce Standby/Off Mode Energy 

Consumption

Toroidal Transformer

Control Relay for Models with 

Brushless Permanent Magnet (BPM) 

Motors

Switching Mode Power Supply

Table 7. Technology Options to Reduce 

Seasonal Boiler Energy Consumption

Modulating Burners

Electronic Ignition

Dampers

Temperature Reset Controls

Thermal Post-Purge Controls

Delayed-Action Oil Pump Solenoid Valve
34

Screening Analysis

Purpose

• Screen out technology options that DOE will not consider in the engineering 

analysis and downstream analyses for commercial packaged boilers.

Approach

• DOE evaluates each technology option based on the following criteria, as provided 

at 10 CFR Part 430, Subpart C, Appendix A, sections 4(a)(4) and 5(b):

− Technological feasibility; 

− Practicability to manufacture, install, and service;

− Adverse effects on equipment utility or availability; and

− Adverse effects on health or safety.

Item 6-1: Of the technology options listed in section 5.4 of the Framework 

Document, which, if any, should be screened out based on the four screening 

criteria? If so, which criteria apply and why? 
35

Engineering Analysis

• A key factor in setting an energy conservation standard is the increased cost of a 

more-efficient equipment.

• The Engineering Analysis determines the relationship between cost and efficiency.

Rulemaking Analyses

• Life-Cycle Cost and Payback 

Period

• Manufacturer Impact Analysis 

• Employment Impact Analysis

Manufacturer Selling Price –

Efficiency Relationship

Manufacturer 

Selling Price

Efficiency Level
36

Engineering Analysis

Identify

Efficiency Levels

Perform Teardown 

Analysis

Develop

Manufacturer 

Production Cost

Define Baseline 

Models

 Define characteristics of models in each equipment class, 

which will serve as reference points to assess changes due to 

more-stringent standard levels.

 Identify more-efficient substitutes from a database of 

commercially-available boilers.

 Develop estimates of equipment cost for baseline boilers 

and boilers at higher efficiency levels.

 Develop cost-efficiency relationship from efficiency data and 

equipment cost estimates.
37

Engineering Analysis

Item 7-1: DOE seeks input about the range of efficiency levels and any 

key efficiency levels that it should examine as part of its analysis.

Item 7-2: DOE seeks comment about maximum technologically feasible 

(“max-tech”) efficiency levels applicable to each class of commercial 

packaged boiler.

Item 7-3: DOE seeks input on the representative capacity and other 

representative characteristics for each commercial packaged boiler 

equipment class. 

Item 7-4: DOE seeks input about design, construction, or performance 

characteristics which may require consideration of multiple 

representative units within a single equipment class.
38

Markups Analysis

Purpose

• Characterize the channels for how equipment is distributed from the manufacturer 

to the boiler end-user (i.e., the commercial consumer).

• Determine prices paid by end-users based on manufacturer selling prices for 

baseline and higher-efficiency equipment.

Method

• Identify distribution channels.

• Estimate the markups for each step of the distribution channel from manufacturer 

to end-user. 
39

Markups Analysis

Commercial Packaged Boiler Distribution Channels

Manufacturer Mechanical 

Contractor Wholesaler End User

Replacement Distribution Channel

Manufacturer

Mechanical 

Contractor

General 

Contractor

End 

User

New Construction Distribution Channel

Wholesaler

Manufacturer End User

National Account Distribution Channel

Manufacturer Wholesaler End User

Wholesaler Distribution Channel

A)

B)

C)

D)
40

Markups Analysis

Item 8-1: DOE seeks input about whether the distribution channels 

described on the previous slide are appropriate for commercial packaged 

boilers. 

Item 8-2: DOE seeks input about 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.

Item 8-3: DOE welcomes suggestions and comments concerning its 

proposed approach to developing estimates of future commercial 

packaged boiler retail prices. 

Item 8-4: DOE seeks recent data to establish the markups for the parties 

involved with the distribution of the equipment.
41

Energy Use Analysis

Purpose

• Develop annual energy use (AEU) for commercial packaged boilers to estimate the energysavings potential of amended energy conservation standards in the LCC and PBP analysis.

Method

• Determine space heating and water heating over the range of applications, commercial 

building types, and climate zones for commercial packaged boiler equipment.

• Develop a relationship between commercial packaged boiler energy use and thermal 

efficiency to determine energy use, by efficiency level, for all equipment classes.

• Account for the electricity consumption of commercial packaged boiler components.

Item 9-1: DOE seeks input on the planned approach for determining the energy consumption of 

commercial packaged boilers in commercial buildings.

Item 9-2: DOE seeks historical shipment-weighted commercial packaged boiler efficiency data or 

shipment data by efficiency bins. DOE is primarily interested in obtaining these data during the 

last 10 years to capture the impact of the most current technologies on the boilers market.
42

Energy Use Analysis

Item 9-3: DOE seeks input about 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.

Item 9-4: DOE requests comment about what other energy use by commercial 

packaged boilers should be included in the energy use analysis.

Item 9-5: DOE welcomes comment about whether the rated thermal efficiencies 

for all commercial packaged boiler equipment should be adjusted to reflect 

return-water conditions (previously done for condensing boilers only).

Item 9-6: DOE seeks input about what fractions of hot-water commercial 

packaged boilers are used both for space heating and hot water.

Item 9-7: DOE seeks input about the fraction of commercial packaged boilers used 

in residential applications. Is this market large enough that DOE should take it into 

account?

Item 9-8: DOE seeks comment about the rebound effect that may be associated 

with more-efficient commercial packaged boilers. 
43

Life-Cycle Cost (LCC) & Payback Period (PBP) Analysis

Purpose

• Assess the LCC and PBP for users of commercial packaged boilers under the 

considered efficiency levels.

Method

• LCC equals user price plus the sum of installation cost and annual operating costs 

over the analysis period discounted to a particular base year.

• Analysis will model the uncertainty and variability of inputs using a Monte Carlo 

calculation method and probability distributions.

• Analysis will be implemented in MS Excel® spreadsheet combined with Crystal 

Ball.®

Item 10-1: DOE seeks input about its proposed LCC approach to using 

probability distributions and Monte Carlo simulation to conduct the LCC and 

PBP analysis. 
44

LCC & PBP Analysis Inputs

• Energy Prices 

– DOE intends to determine gas, oil, and electricity prices based on recent or 

current tariffs from a representative sample of utilities and EIA’s Annual Energy 

Outlook (AEO). 

• Installation, Maintenance, and Repair Costs

– DOE intends to develop installation, maintenance, and repair costs for its 

analysis using the most recent RS Means data available.

• Lifetime

– DOE plans to develop Weibull probability distributions to characterize 

commercial packaged boiler lifetime.

– DOE plans to use ASHRAE data, as well as review available literature and consult 

with industry experts to establish typical equipment lifetime. 

• Discount Rates

– DOE will derive the discount rates for boiler users by estimating the capital costs 

for companies that purchase commercial packaged boilers. 
45

LCC & PBP Analysis Flowchart

Baseline 

Manufacturer 

Cost Engineering 

Analysis Std-Level 

Manufacturer 

Cost

Manufacturer 

Markup

Markups to 

Determine 

Equipment 

Price

Distributer & 

Contractor 

Markups

Sales Tax

Energy Use 

Characterization

Energy 

Consumption

Energy

Prices

Consumer

Price

Installation

Cost

Total

Installed Cost

Annual

Energy Cost

Repair

Cost

Maintenance

Cost

Annual

Operating 

Expense

Lifetime

Discount

Rate

Energy Price 

Trend

Lifetime 

Operating

Expense

Payback

Period

Life-Cycle

Cost
46

Life-Cycle Cost and Payback Period Analysis

Item 10-2: DOE requests data to characterize the current mix of boiler 

efficiencies in the market. 

Item 10-3: DOE seeks input about the planned approach for estimating future 

energy prices. 

Item 10-4: DOE seeks input about the maintenance and repair costs 

approach. In particular, DOE requests comment about frequency and cost of 

maintenance, major repair issues, repair frequency and cost for boilers that 

just meet the minimum efficiency standards, as well as for high-efficiency 

boilers.

Item 10-5: DOE seeks interested party input about its proposed installation 

cost approach. Specifically, DOE requests data about the fractions of 

installations that would entail significant additional installation expenses. 
47

Life-Cycle Cost and Payback Period Analysis

Item 10-6: DOE requests comment about the methodology used to 

determine equipment lifetimes for commercial packaged boilers.

Item 10-7: DOE seeks input about its planned approach for estimating 

discount rates for commercial boiler users.

Item 10-8: DOE requests data about the boiler efficiency distribution and 

welcomes comment about 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).
48

Shipments Analysis

Purpose

• To project commercial packaged boiler shipments in the base case and standards 

cases in order to calculate the effects of amended energy conservation standards 

on energy savings and present value of savings, as well as future manufacturer 

cash flows.

Method

• DOE plans to project shipments of commercial packaged boilers by accounting for 

sales to the two primary market segments: (1) the replacement market and (2) the 

new construction market. 

• The shipments model relies on multiple data sources including:

− Manufacturers and industry organizations 

− Historical commercial packaged boiler shipments were provided in the 2009 

commercial packaged boilers final rule by GAMA/AHRI.

− National market reports 

− Publicly-available sources
49

Shipments Analysis

Item 11-1: DOE welcomes comment about the shipments projection 

methodology.

Item 11-2: DOE welcomes input on the selection of appropriate economic 

drivers and sources of data for historical shipments.

Item 11-3: DOE seeks historical commercial packaged boiler shipments 

data, disaggregated by equipment class and efficiency level if possible.

Item 11-4: DOE seeks input on the potential impact of amended standards 

on commercial packaged boiler shipments.
50

National Impact Analysis

Purpose

• To assess the aggregate effects at the national level of potential amended energy 

conservation standards for each equipment class, in terms of national energy 

savings (NES) and net present value (NPV).

Method

• DOE plans to apply a boiler efficiency distribution to the shipments projections to 

determine energy use in the base case and various standards cases. 

− DOE can use a “roll-up” or “shift” scenario to characterize the boiler efficiency 

distribution.

• DOE calculates annual NES by taking the difference in energy use between the 

base case and the standards cases. 

• DOE calculates NPV as the difference between the present value of operating cost 

savings and the present value of total installed costs for each of the standards 

cases. 
51

National Impact Analysis

Item 12-1: DOE seeks comment on appropriate assumptions to use for 

long-run changes in boiler efficiency independent of amended energy 

conservation standards. 

Item 12-2: DOE requests comment about whether to pursue a roll-up or 

shift approach.
52

Public Meeting Agenda

Scope and Test Procedures

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
53

Notice of Proposed Rulemaking (NOPR) Analyses

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

LCC 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date
54

LCC Consumer Subgroup Analysis

Purpose

• Analyze the economic impacts of amended energy conservation standards on 

subgroups of boiler end-users who are likely to be disproportionately impacted 

compared with the general population.

Method

• DOE plans to utilize the LCC spreadsheet model to analyze the LCC for subgroups by 

sampling inputs specific to that subgroup.

Item 13-1: DOE requests input about what consumer subgroups are appropriate to 

evaluate for commercial packaged boilers. 
55

Manufacturer Impact Analysis

Purpose

• To assess the potential impacts of amended standards on manufacturers.

• To identify and estimate impacts on manufacturer subgroups that may be more 

severely impacted than the industry as a whole. 

• To examine the impact of cumulative regulatory burden on the industry.

Method

• Analyze industry cash flow and industry net present value through use of the 

Government Regulatory Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop subgroup analyses, 

and address qualitative issues.

Item 14-1: DOE seeks comments about appropriate manufacturer subgroups, if any, that 

DOE should consider in a manufacturer subgroup analysis for commercial packaged boilers. 

Item 14-2: DOE welcomes data about the names and number of small manufacturers in the 

commercial packaged boilers industry. 

Item 14-3: DOE requests comments about what other existing regulations or pending 

regulations it should consider in its examination of cumulative regulatory burden.
56

Emissions Analysis

Purpose

• To report environmental impacts of amended energy conservation standards.

Method

• In estimating physical reductions of emissions, DOE intends to use the emissions 

effects projected from the National Energy Modeling System (NEMS) – Building 

Technologies (BT) to conduct its analysis. 

• DOE plans to consider, to the extent feasible, reduction in power sector emissions 

of carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2), mercury (Hg), 

methane (CH4), nitrous oxide (N2O), and particulate matter (PM).

• DOE plans also to consider emissions impacts in fuel production activities 

(extracting, processing, and transporting fuels) for the fuels used in power plants.

• DOE plans to account for the emissions from boiler combustion at the building 

site.

Item 15-1: DOE seeks input about its approach to conduct the emissions analysis for 

the commercial packaged boiler equipment covered by this rulemaking. 
57

Monetizing CO2 and Other Emissions Reductions

Purpose

• To report monetary benefits from the reduced emissions of CO2 and NOX from 

amended energy conservation standards.

Method

• In estimating the monetary value of reduced emissions, DOE intends to use the 

most current social cost of carbon (SCC) values developed by interagency reviews.

• DOE multiplies the CO2 emissions reduction by the SCC value then discounts the 

values to calculate its present value.

• DOE estimates the potential monetary benefit of reduced NOX emissions based on 

environmental impact estimates found in the relevant scientific literature. These 

values are discounted to obtain a present value at 3% and 7% (in accordance with 

OMB guidance).

• Although it may not be possible to do so at this time, DOE plans to investigate 

valuation methods for avoided SO2, Hg, CH4, N2O, and PM emissions. 

Item 16-1: DOE requests comments about the approach it plans to use for 

estimating monetary benefits associated with emissions reductions. 
58

Utility Impact Analysis

Purpose

• Assess the overall effects on domestic energy supplies that would result from the 

adoption of amended energy conservation standards. 

Method

• DOE proposes to use the Energy Information Agency (EIA’s) NEMS-BT model, as the 

basis of the utility impact analysis.

• DOE plans to model the energy savings impacts from amended energy 

conservation standards using NEMS-BT to generate projections for the Annual 

Energy Outlook (AEO) Reference Case and additional cases.

• Outputs of the utility impact analysis include projections of electricity generation 

and avoided capacity resulting from a comparison of the base case and standards 

cases.

Item 17-1: DOE welcomes input about its proposed approach to conduct the utility 

impact analysis.
59

Employment Impact Analysis

Purpose

• Assess the overall effects on national employment from the adoption of amended 

energy conservation standards at various levels.

• Includes both direct and indirect employment impacts.

• Direct employment impacts are estimated in the manufacturer impact analysis.

• Indirect employment analysis estimates the impacts on the national economy that 

result from shifting user expenditures among goods and services (“substitution 

effect”) and changes in income and overall expenditure levels (“income effect”).

Method

• DOE intends to use the Impact of Sector Energy Technologies (ImSET) model for 

the evaluation of indirect employment impacts.

Item 18-1: DOE welcomes feedback about its proposed approach to assessing 

national employment impacts.
60

Regulatory Impact Analysis

Purpose

• To investigate the national effects of non-regulatory alternatives compared with 

mandatory energy conservation standards.

Method

• Modify NES spreadsheet model to consider non-regulatory scenarios.

• Estimate effects of non-regulatory scenarios based on experience with the 

considered policies.

• Output will include NES and NPV of the non-regulatory alternatives.
61

Public Meeting Agenda

Scope and Test Procedures

Preliminary Analyses

NOPR Analyses

4

5

6

2 Regulatory History

3 Rulemaking Overview

1 Introduction

7 Closing Remarks
62

Closing Remarks

Meeting participants are invited to provide closing 

remarks or statements at this time. 
63

How to Submit Written Comments

• In all correspondence, please refer to the commercial packaged boiler rulemaking 

by: 

− Commercial Packaged Boiler Energy Conservation Standard Rulemaking 

− Docket Number: EERE-2013-BT-STD-0030 

− Regulatory Identification Number (RIN): 1904-AD01

• Email: PkgdBoilers2013STD0030@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: (202) 586-2945

Comment period closes: October 18, 2013 — 11:59 PM EDT

http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/74