1 | Energy Efficiency and Renewable Energy eere.energy.gov 

# Energy Conservation Standards: Framework for Commercial Prerinse Spray Valves

September 30, 2014 

# John Cymbalsky

Department of Energy Building Technologies Office
EERE

- 2014

- BT

- STD

- 0027 SprayValves2014std0027@ee.doe.gov2 

# 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 transcript 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 hand” to be recognized to speak3 

# Morning Agenda

9:00

– 9:05 am Welcome
9:05

– 9:30 am Agenda Review, Opening Remarks, Housekeeping Items
9:30

– 10:00 am Rulemaking Process Overview
10:00

– 10:30 am Authority and Definitions
10:30

– 10:45 am Break
10:45

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

– 11:45 am Market & Technology Assessment, Screening Analysis
11:45

– 12:30 pm Engineering Analysis
12:30

– 1:30 pm Break for Lunch4 

# Afternoon Agenda

1:30

– 2:00 pm Markups and Energy and Water Use Analyses
2:00

– 2:30 pm Life

- Cycle Cost and Payback Period Analysis
2:30

– 2:45 pm Break
2:45

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

– 3:15 pm Preliminary Manufacturer Impact Analysis
3:15

– 3:30 pm NOPR Analyses
3:30

– 4:00 pm Other Issues and Comments 4:00 pm Closing Remarks5 

# Opening Remarks

Meeting participants are invited to provide opening remarks or statements at this time.6 

# Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks7 

# Housekeeping Items

– Listening Via the Webcast

• The Department is broadcasting this meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view the slides.

• All stakeholders are encouraged to submit written comments after the public meeting.8 

## Purpose of the Framework Document Public Meeting

• Present the analytical approaches to be used to evaluate energy conservation standards for commercial prerinse spray valves (CPSV)

• Inform interested parties of and facilitate the rulemaking
process

• Provide a forum for public discussion of rulemaking issues

• Encourage interested parties to submit data, information, and written comments 

# Housekeeping Items

– Purpose of Meeting9 

## Request for Comment

• The list of items requesting comment is in the Framework document, available at http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=100 

# Housekeeping Items

– Request for Comment

Item #

- #: DOE solicits comment on a range of specific issues throughout the Framework document.

• Throughout this presentation, these issues will be highlighted for discussion in comment boxes such as this.

• Item numbers correspond to those in the Framework document.

• DOE welcomes comments concerning these specific issues 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.gov

Postal : Courier: Ms. Brenda Edwards Ms. Brenda Edwards U.S. Department of Energy U.S . Department of Energy Building Technologies Program, Building Technologies Program Mailstop EE

- 2J 950 L’Enfant Plaza SW, Suite 600 1000 Independence Avenue, SW Washington , DC 20024 Washington, DC 20585

- 0121 Tel : 202 586

- 2945



## Comment period closes October 27, 2014 

# Housekeeping Items

– Submitting Comments11 

# Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks12 

## Standards Development

• T he Energy Policy and Conservation Act (EPCA) of 1975 established the Energy Conservation Program for Consumer Products Other Than Automobiles, which includes commercial prerinse spray valves (42 U.S.C. 6291(33))

• EPCA directs DOE to develop new or amended standards designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified

• EPCA also requires that, not later than 6 years after the issuance of a final rule 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 amended. (42 U.S.C. 6295(m)(1)) 

# Rulemaking Process Overview13 

### • EPCA directs DOE to consider seven factors for analysis when setting technologically feasible and economically justifiable standards

. 

# Rulemaking Process Overview

EPCA Factor DOE Analysis

1. Economic impact on customers and manufacturers • Life

- cycle Cost (LCC) Analysis

• Manufacturer Impact Analysis (MIA)

2. Lifetime operating cost savings • LCC Analysis
3. Total projected energy and water savings • National Impact Analysis (NIA)

4. Impact on utility or performance • Engineering Analysis

• Screening Analysis

5. Impact of any lessening of competition • MIA

6. Need for national energy conservation • NIA

7. Other factors the Secretary considers relevant • Emissions Analysis

• Utility Impact Analysis

• Employment Impact Analysis14 

## Test Procedure and Standard Rulemakings Timelines 

# Rulemaking Process Overview

Framework Document Preliminary Analysis NOPR Final Rule

Final Rule NOPR 

### Energy Conservation Standard (ECS)

Test Procedure (TP) (if applicable)

• ECS and TP rulemakings are separate processes but sometimes have integrated timelines

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

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

• For additional information on the rulemaking process go to: http ://www1.eere.energy.gov/buildings/appliance_standards/standards_dev_and_revision.html15 

## Framework Document

• Accompanying Federal Register notice of public meeting (NOPM)

- Gives notice of the public meeting, availability of the Framework document being discussed today, and encourages interested parties to submit comments

- The Framework was posted September 8, 2014 on DOE’s website at http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking. aspx?ruleid=100

.

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



### • Provides an overview of the rulemaking process and encourages early 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 Rule16 

## 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 preliminary technical support document (TSD), provides discussion of comments received in response to the Framework document, and 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 national energy savings (NES), national water savings, and customer net present value (NPV)

– Preliminary analysis of manufacturer impacts17 

## 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 revised TSD, and encourages interested parties to submit comments

- Provides discussion of comments received in response to preliminary analysis TSD

- Presents any proposed standard levels for public comment



### • Analyses

– Customer Subgroup

– Manufacturer Impact

– Employment Impact

– Utility Impact

– Emissions and Monetization

– Regulatory Impact18 

## 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 received in 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 standards and of the weight of those impacts on the final rule19 

## Rulemaking Schedule 

# Rulemaking Process Overview

2014 2015 2016 20 19

Framework Document Public Meeting September 2014 Preliminary Analysis Public Meeting Planned Spring 2015 NOPR Public Meeting Planned Fall 2015 Proposed Energy Conservation Standard Final Rule Compliance Planned Summer 201920 

# Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks21 

## Authority and Background

— Overview

• Title III of EPCA sets forth a variety of provisions designed to improve the energy efficiency of various products and equipment

• Part B of Title III provides for the “Energy Conservation Program for Consumer Products Other Than Automobiles” (42 U.S.C. 6291

– 6309)

• The Energy Policy Act of 2005 (EPAct 2005) amended section 325 of EPCA, which now states that commercial prerinse spray valves manufactured on or after January 1, 2006 shall not have a flow rate of more than 1.6 gallons per minute (gpm) 

# Authority & Definitions22 

# Scope of Coverage

• EPCA definition of Commercial Prerinse Spray Valve

- “A handheld device designed and m arketed for use with commercial dishwashing and ware washing equipment that sprays water on dishes, flatware, and other food service items for the purpose of removing food residue before cleaning the items.” (10 CFR 431.262)

- DOE is considering modifications to the definition of commercial prerinse spray valve to clarify the scope of coverage, if needed 

# Authority & Definitions23 

## Authority to Modify Definition

• Under EPCA, the Secretary may modify the definition of “commercial prerinse spray valve” by rule

–

• ( i ) to include products

– (I) that are extensively used in conjunction with commercial dishwashing and ware washing equipment; (II) the application of standards to which would result in significant energy savings; and (III) the application of standards to which would meet the criteria specified in section 6295(o)(4) of 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 dishwashing and ware washing equipment; and ( III) the application of standards to which would not result in significant energy savings.

(42 U.S.C. 6291(33)(B)) 

# Authority & Definitions

Item 1

- 1: DOE requests comment on modifications to the definition of “commercial prerinse spray valve” that may clarify what equipment is covered.24 

## Prerinse Spray Valve Metric

• As part of this rulemaking DOE may consider adopting an alternative water consumption metric to replace the current flow rate (gpm) metric

• DOE will consider alternatives that will achieve energy and water savings, and preserve equipment utility

• Two possible metrics DOE could consider:

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

• A metric that directly correlates water use to the time taken to clean a dish, measured in gallons per dish 

# Authority & Definitions

Item 1

- 2: DOE requests comment on potential metrics other than flow rate that may be used to achieve greater water savings in commercial prerinse spray valves and if there is sufficient benefit to using an alternative metric to justify changing from the current flow rate metric.25 

# Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks26 

## Current Test Procedure

• EPCA specifies that the test procedure for measuring flow rate (gpm) for commercial prerinse spray valves shall be based on ASTM Standard F2324 “Standard Test Method for Pre

- Rinse Spray Valves” 42 U.S.C 6293(b)(14)

• In October 2013 , DOE published a final rule that incorporated by reference the test procedure specified in ASTM Standard F2324

- 03 (2009)

• Although ASTM Standard F2324

- 03 (2009) includes a test for a qualitative cleanability test, the current DOE test procedure only incorporates testing methods for measuring flow rate 

# Test Procedure & Test Metrics27 

## Potential Test Procedure Updates

• Since the publication of the 2013 test procedure, ASTM has issued Standard F2324

- 13 to reflect changes in the industry

• The primary change to the ASTM test procedure was to replace the cleanability test with a spray force test

- C leanability test evaluates the cleaning time of a standard dinner plate, measured in seconds per plate

- Spray force test measures the amount of force exerted by the flow of water, measured in ounce

- force ( ozf )

- These changes do not impact the energy/water use measurement of the DOE test procedure, but could be used as a way to establish CPSV equipment classes 

# Test Procedure & Test Metrics

Item 1

- 3: DOE requests comment on the potential use of ASTM F2324

- 13 as the method of test for measuring the water consumption of commercial prerinse spray valves.28 

# Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks29 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis30 

## • Purpose:

– Characterize the commercial prerinse spray valve market and the technologies that improve efficiency



## • Method:

– Identify and characterize manufacturers of commercial prerinse spray valves

– Estimate shipments and trends in the market

– Identify technologies that could improve efficiency 

# Rulemaking Analyses: Market & Technology31 

# Rulemaking Analyses: Market & Technology
Trade Groups

• Plumbing Manufacturers International (PMI) is the primary trade organization that supports and has an interest in commercial prerinse spray valves

• North American Association of Food Equipment Manufacturers (NAFEM) is a trade association of over 500 foodservice equipment manufacturers and is another organization that may be interested in commercial prerinse spray valves 

## Retailers

• Prerinse spray valves are generally available to customers at:

- Brick

- and

- mortar retailers (mass market retailers, specialty stores, club or warehouse stores)

- Internet sellers

- Showrooms 

### Item 3

- 3: DOE seeks information regarding any other trade organizations that represent the commercial prerinse spray valve industry32 

# Rulemaking Analyses: Market & Technology

• 49 basic models were found using the DOE Compliance Certification Management System (CCMS) database, the EPA WaterSense ® product database, manufacturer websites, and Web searches

• Shows the estimated percentages of basic models by manufacturer in the U.S. market for commercial prerinse spray valves 

## Manufacturers

Niagara Conservation, 2% Mueller Streamline Co., 4% Chicago Faucet, 4%

Krowne Metal Corporation, 4%

BK Resources, 4%

Strahman Valves, Inc., 6% Bricor Analytical, 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 by: (1) type of energy used; (2) capacity of the product; or (3) any other performance

- related features that require different standard levels, such as features affecting customer utility (42 U.S.C. 6295(q))

• All commercial prerinse spray valves are currently included in a single equipment class subject to a maximum flow rate of 1.6 gpm

• DOE will examine whether any of the following characteristics could be 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. , spray patterns34 

### Item 3

- 8: DOE requests input from interested parties about the design characteristics and criteria that are being considered to create equipment classes. In particular, do other performance

- related features warrant separate standard levels?

Item 3

- 9: DOE seeks comment on whether spray force or cleanability are useful characteristics that could define the equipment classes of a prerinse spray valve.

Item 3

- 10: DOE requests comment on how ultra

- low flow spray valves differ from other spray valves in usage, functionality, features, and cleaning ability. 

# Rulemaking Analyses: Market & Technology35 

# Rulemaking Analyses: Market & Technology

• Addition of a flow control insert

• Smaller nozzle tip openings

• Incorporation of additional components, e.g. , backflow preventers, 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 improve the efficiency of commercial prerinse spray valves: 

## Technology Options36 

# Rulemaking Analyses: Market & Technology

Spray pattern Description Image
Cone Nozzle with hollow or solid cone spray, variety of cone angles (“fan”)

Solid stream Nozzle with single solid jet stream

Triple solid
stream 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 are available to improve the performance of commercial prerinse spray valves.37 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis38 

## • Purpose:

─ Screen

- out technology options that DOE will not consider in the engineering analysis for commercial prerinse spray valves



## • Method:

─ DOE will evaluate each technology option based on the following criteria:

• Technological feasibility

• Practicability to manufacture, install, and service

• Adverse impacts on product utility or availability to customers

• Adverse impact on health and safety



### ─ The technology options that are not screened out will be adopted as design options in the engineering analysis 

# Rulemaking Analyses: Screening Analysis39 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis40 

### • Purpose: D etermine the relationship between manufacturer selling price (MSP) and efficiency 

## Overview 

# Rulemaking Analyses: Engineering Analysis

• Life

- cycle Cost and Payback Period

• National Impact Analysis Cost

– Efficiency RelationshipMSP

Water Use Analyses Using Cost

– Efficiency Relationship41 

###  Analyze all equipment classes

 The baseline efficiency level is 1.6 gpm based on the existing standard

 For all equipment classes, identify the efficiency and cost of more efficient units based on design option modeling, product testing, and teardowns; i dentify the maximum technologically feasible (max

- tech) level for each equipment class

 Develop efficiency levels that range from the baseline to max

tech

 The result of the engineering analysis will be a set of price

efficiency curves (MSP vs. efficiency) for each equipment class 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 Analysis42 

## Baseline Models

• Baseline models are selected based on common features and minimally compliant equipment efficiency

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



## • If an efficiency metric other than gpm is selected, the baseline efficiency will be chosen to prevent backsliding

Item 5

- 3: DOE seeks information regarding the specific technological characteristics of baseline models. 

# Rulemaking Analyses: Engineering Analysis43 

# Rulemaking Analyses: Engineering Analysis

Efficiency Levels

• DOE will identify the highest efficiency model in the market (max

tech) for each class

• DOE will analyze the costs associated with implementing the screened

- in design options to improve spray valve efficiency from baseline efficiency to max

- tech

• Design options that DOE is tentatively considering include the addition of a flow control insert, smaller nozzle tip openings, incorporation of additional components, and specially designed spray patterns44 

## Cost

- Efficiency Relationship and Analysis

• DOE will develop a cost model that converts bills of materials (BOMs) for baseline models and the cost of design options for different efficiency levels into manufacturer production costs (MPCs )

─ Component costs will be determined using reverse engineering (product teardowns) and manufacturer feedback (engineering interviews )



### • Manufacturer selling price (MSP) is based on the manufacturing cost of prerinse spray valve hardware times the manufacturer markup

– The industry

- wide manufacturer markup will be determined based on publicly available financial sources ( e.g

. , SEC Form 10

- K) and manufacturer feedback 

# Rulemaking Analyses: Engineering Analysis

Manufacturer

Production Cost (MPC) Manufacturer Markups (Non

- Production Costs) 

# x =

• Direct material

• Direct labor

• Factory overhead

• Depreciation • Sales & marketing

• Research & development

• Interest

• Profit Manufacturer Selling Price (MSP)45 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis46 

## • Purpose

– A ssess the economic impacts of potential energy conservation standards on manufacturers

– I dentify and estimate impacts on manufacturer subgroups that may be more adversely affected than the industry as a whole

– E xamine the direct employment impacts, manufacturing capacity, and the cumulative regulatory impact on the manufacturing industry



## • Methodology

– 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 

## Rulemaking Analyses: Preliminary Manufacturer Impact Analysis47 Complete industry profile Develop strawman GRIM Develop interview guide Conduct interviews & industry

wide/ subgroup analyses Assess direct employment, manufacturing capacity, and cumulative burden Finalize MIA results for NOPR Phase 2 Phase 3 Phase 1



## Rulemaking Analyses: Preliminary Manufacturer Impact Analysis

Overview

Item 12

- 1: DOE seeks comment on the appropriate manufacturer subgroups, if any, for commercial prerinse spray valves that DOE should consider in a manufacturer subgroup analysis.48 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis49 

## • Purpose:

- Estimate actual user purchase prices from manufacturer selling prices of baseline and higher

- efficiency equipment designs



## • Method:

- Identify distribution channels and estimate share of each channel in the aggregate sales volume

- Estimate markup values for each level in the identified distribution channels 

# Rulemaking Analyses: Markups Analysis50 

# Rulemaking Analyses: Markups Analysis

Identified Distribution Channels

• Manufacturer  Final Customer

• Manufacturer  Authorized Distributor  Final Customer

• Manufacturer  Retail Merchant  Final Customer

Item 6

- 1: DOE seeks comment on the distribution channels and the share of industry shipments for each distribution channel as they apply to the range of commercial prerinse spray valves that are covered by this potential rule.51 

## • Baseline, Incremental, and Overall Markups

- Baseline markups are cost multipliers that convert the MSP of equipment at the baseline efficiency level to customer purchase price

- Incremental markups are cost multipliers that convert the incremental increase/change in MSP for equipment at each higher

- efficiency level (compared to the MSP at baseline efficiency level) to corresponding incremental increases/changes in the customer purchase price

- Overall markups include the weighted

- average distribution channel markups, based on distribution channel market shares, and sales tax 

# Rulemaking Analyses: Markups Analysis52 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis53 

## • Purpose:

- Assess the annual energy and water use for all efficiency levels, for all equipment classes

- Provide the basis for unit energy and water costs, which are used in the life

- cycle cost analysis



## • Method:

- Wastewater discharge will be assumed to be 100% of water use

- Energy use will be estimated by calculating the energy required to raise the supply water temperature (by region) to the end

- use temperature, taking into account the heating efficiency of representative water heating equipment

- Daily data will be annualized by taking into account the number of operating days per year by equipment class 

# Rulemaking Analyses: Energy and Water Use Analysis54 

# Rulemaking Analyses: Energy and Water Use Analysis

Item 7

- 1: DOE requests input on operational patterns of commercial prerinse 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 operational water temperatures used in commercial prerinse spray valves for 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 rate for prerinse spray valves.55 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis56 

## • Purpose:

- Assess economic impacts of different efficiency levels on the customers of commercial prerinse spray valves



## • Method:

- Results are expressed in terms of LCC savings (LCC at baseline efficiency level compared to LCC at higher efficiency level)

- PBP , expressed in number of years, is calculated by dividing the incremental equipment first cost at a higher

- efficiency level by the corresponding annualized operating cost savings 

# Rulemaking Analyses: LCC and PBP Analysis57 

# Rulemaking Analyses: LCC and PBP Analysis

LCC Component Calculation Methodology Equipment Purchase Price Mark up MSP by the appropriate distribution channels and markup values

Installation Cost Includes labor and material costs to place the equipment into service

Maintenance Cost Incurred by the customer for preventative maintenance of the equipment

Repair Cost Repair or replace damaged or malfunctioning components of the equipment

Energy and Water Cost Paid by the customer for the energy and water used by hot
water

- using equipment

• Energy

– Use Energy Information Administration’s Annual Energy Outlook to estimate energy prices

• Water

– Use American Water Works Association Water Rate Survey to estimate current water and wastewater prices58 

## • Other Major Parameters in the LCC and PBP Analysis

• Discount Rates

- DOE will derive discount rates for different customers by estimating the weighted average cost of capital for different customers and business types that own and/or operate the equipment



### • Base Case Efficiency Distribution

- Base case efficiency distribution is the distribution of the market share of each efficiency level for all equipment classes in the absence of an amended DOE standard

- If market share data are not available by efficiency level, DOE may develop base case efficiency distributions based on available models and information from commercial prerinse spray valve manufacturers and experts



### • Equipment Lifetime

- The average and typical range of the equipment lifetime will be determined based on literature and industry inputs for each equipment class 

# Rulemaking Analyses: LCC and PBP Analysis59 

## • Approach: Monte Carlo Simulations

• The LCC analysis is carried out using Monte Carlo simulations

• For each of a large number of samples ( e.g ., 10,000), parameter values are chosen based on the probability of their occurrence; these values are then combined to calculate the LCC and PBP for that particular individual sample

• The LCC, LCC savings, and PBP are expressed in the form of mean or median values

• The LCC results are also presented in the form of estimated percentage of customers that benefit from, are adversely affected by, and/or are unaffected by amended standards 

# Rulemaking Analyses: LCC and PBP Analysis60 

# Rulemaking Analyses: LCC and PBP Analysis

Item 8

- 3: DOE seeks comment on sources of data for determining marginal water and wastewater rates and methods to break out water and wastewater rates across different pricing segments (such as regionally or by state).

Item 8

- 4: DOE seeks data sources and methods to determine future trends in water and wastewater rate escalations.

Item 8

- 5: DOE invites comment on whether repair costs may change for more

- efficient commercial prerinse spray valves

. Item 8

- 6: DOE invites comment on whether commercial prerinse spray valves are typically replaced upon failure or repaired.

Item 8

- 7: DOE seeks comment on appropriate commercial prerinse spray valve lifetimes for the equipment under consideration, as well as data regarding correlation between hours of use and commercial prerinse spray valve lifetime

.61 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis62 

## • Purpose:

- Project future shipments by equipment class



## • Method:

- DOE typically projects shipments for a 30

- year period beginning with the expected compliance date of the standard

- DOE intends to collect historical shipment data for commercial prerinse spray valves from trade organization surveys

- Future shipments will be calculated based on the historical shipments data, retirement rates of equipment, and the EIA’s AEO forecast of new commercial construction

- DOE may use different shipments projections in the standards case and base case scenarios depending on the information available 

# Rulemaking Analyses: Shipments Analysis63 

# Rulemaking Analyses: Shipments Analysis

Item 9

- 1: DOE seeks comment on an appropriate shipments projection 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 conservation standard for commercial prerinse spray valves might impact shipments of the equipment.64 

# Rulemaking Analyses

Market & Technology
Screening Analysis Engineering Analysis Markups Analysis

Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis Shipments Analysis National Impact Analysis Framework Document Preliminary Analysis NOPR Final Rule

Energy and Water Use Analysis65 

# Rulemaking Analyses: National Impact Analysis

• Purpose:

– Determine the projected national impacts of an amended standard, in the form of NES, national water savings and NPV



## • Method:

– Develop annual series of national energy, water and economic impacts

• Use LCC outputs to provide input about installed costs, energy use, and water use per unit

• Use the shipments model to estimate annual shipments and stock



### – Aggregate the costs, energy use, and water use for all years in the analysis period

– Report NES in primary and full

- fuel

- cycle (FFC) savings, NPV in billions of dollars, and national water and wastewater savings in billions of gallons

– Account for the time

- value of money though defined discount rates66 

# Rulemaking Analyses: National Impact Analysis

• Inputs for calculating NES and National Water Savings:

- Annual energy and water use at each efficiency level for all equipment classes

- Projected shipments

- Equipment stock (based on historical and projected shipments)

- Site

- to

- source conversion factors: Multipliers used to convert energy used at the site to energy produced at the source



## • Inputs for calculating NPV:

- I nstalled and operating costs of all equipment for each year of the analysis period

- Discount rates (3 percent and 7 percent)67 

# Rulemaking Analyses: National Impact Analysis

Item 10

- 1: DOE seeks comment on how the efficiency of commercial prerinse spray valves would be likely to change in the future in the absence of standards.

Item 10

- 2: DOE seeks comment on the likelihood of increased commercial prerinse spray valve usage as a direct result of improved equipment efficiency.68 

# Rulemaking Analyses

Framework Document Preliminary Analysis NOPR Final Rule

Manufacturer Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory Impact Analysis

Engineering Analysis Life

- Cycle Cost & Payback Period Analysis National Impact Analysis Employment Impact Analysis Utility Impact Analysis 

## NOPR Analyses69 

## • Purpose:

– Analyze the economic impacts of standards on customer subgroups who may be disproportionately impacted compared with the general user population

• Examples include customers who use equipment less frequently, pay lower utility rates, and/or have higher discount rates than the typical customer.



## • Method:

– Change parameters within the LCC model to model the differences between identified subgroups relative to the general population

– The subgroup analysis results will be compared to the national average results (from the LCC analysis) to determine the impact of standards on the identified subgroups 

# Rulemaking Analyses: Customer Subgroup Analysis

Item 11

- 1: DOE seeks comment on what, if any, user subgroups should 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 Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory Impact Analysis

Engineering Analysis Life

- Cycle Cost & Payback Period Analysis National Impact Analysis Employment Impact Analysis Utility Impact Analysis 

## NOPR Analyses71 

# Rulemaking Analyses: Utility Impact Analysis

• Purpose:

– Assess the overall impacts on domestic energy supplies that would result from the imposition of standards



## • Method:

– DOE plans to use factors derived from NEMS

- BT (a variant of the NEMS (National Energy Modeling System) developed and used by DOE/EIA for their AEO report) as the basis of the utility impact analysis

– Outputs of the utility impact analysis include projections of energy sales and prices, generation, and capacity in the base and standards

cases Item 13

- 1: DOE seeks comment from interested parties about its proposed use of NEMS

- BT to conduct the utility impact analysis.
Item 13

- 2: DOE seeks comment and information on potential methods and data sources that can be used to assess the impacts on water and wastewater utilities as a result of energy conservation standards for commercial prerinse spray valves.72 

# Rulemaking Analyses

Framework Document Preliminary Analysis NOPR Final Rule

Manufacturer Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory Impact Analysis

Engineering Analysis Life

- Cycle Cost & Payback Period Analysis National Impact Analysis Employment Impact Analysis Utility Impact Analysis 

## NOPR Analyses73 

# Rulemaking Analyses: Employment Impact Analysis

• Purpose:

– Assess the overall impact on national employment from the 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 expenditures among goods and services ( “substitution effect”) and changing equipment and energy costs (“income effect ”)



## • Method:

– DOE intends to use the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect employment impacts

Item 14

- 1: DOE seeks comments about its suggested approach for assessing national indirect employment impacts.74 

# Rulemaking Analyses

Framework Document Preliminary Analysis NOPR Final Rule

Manufacturer Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory Impact Analysis

Engineering Analysis Life

- Cycle Cost & Payback Period Analysis National Impact Analysis Employment Impact Analysis Utility Impact Analysis 

## NOPR Analyses75 

# Rulemaking Analysis: Emissions Analysis

• Purpose:

– Estimate environmental impacts from potential energy conservation standards for commercial prerinse spray valves including changes in FFC emissions



## • Method:

– DOE will base the emission factors on NEMS, supplemented by data from other sources; the following emissions are assessed:

• Carbon dioxide (CO 2 )

• Sulfur dioxide (SO 2 )

– SO 2 emissions from affected electric generating units are subject to nationwide and regional emissions cap and trading programs

• Nitrogen oxides (NO x )

– Clean Air Interstate Rule (CAIR) permanently caps NO x emissions in 28 eastern States and Washington, D.C.

• Methane (CH 4 )

• Nitrous o xide (N 2 O)

• Mercury (Hg)76 

### Item 15

- 1: DOE seeks comment about its approach to conduct the emissions analysis for the equipment that would be covered under this proposed rulemaking

.

Item 15

- 2: DOE seeks comment and information on potential methods and data sources that can be used to assess emissions reductions as a result of water savings

. 

# Rulemaking Analyses: Emissions Analysis77 

# Rulemaking Analyses: Monetization of Reduced Emissions

• DOE intends to use the most current Social Cost of Carbon (SCC) values developed by interagency reviews

– SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas emissions
, including, but not limited to, agricultural productivity loss, human health effects, property damage from rising sea level, and changes in the ecosystem



### • DOE will also estimate the potential monetary benefit of reduced NO x 

### emissions resulting from the considered standard levels

Item 16

- 1: DOE requests comment about the approach it plans to use for estimating monetary benefits associated with emissions reductions

.78 

# Rulemaking Analyses

Framework Document Preliminary Analysis NOPR Final Rule

Manufacturer Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory Impact Analysis

Engineering Analysis Life

- Cycle Cost & Payback Period Analysis National Impact Analysis Employment Impact Analysis Utility Impact Analysis 

## NOPR Analyses79 

# Rulemaking Analysis: Regulatory Impact Analysis

• Purpose:

– Explore the potential savings for non

- regulatory alternatives to new or amended energy efficiency standards



## • Method:

– Determine the energy and monetary savings impact of any non

regulatory alternative to a new or amended standard

– Some examples include:

– Tax Credits

– Rebate Programs

– Bulk Purchase Programs

– WaterSense80 

# Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks81 

## How to Submit Written Comments In all correspondence, please refer to the Commercial Prerinse Spray Valve 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.regulations.gov

Postal : Courier: Ms. Brenda Edwards Ms. Brenda Edwards U.S. Department of Energy U.S . Department of Energy Building Technologies Program, Building Technologies Program Mailstop EE

- 2J 950 L’Enfant Plaza SW, Suite 600 1000 Independence Avenue, SW Washington , DC 20024 Washington, DC 20585

- 0121 Tel : 202 586

- 2945



## Comment period closes October 27, 2014 

# Closing Remarks