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.gov
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 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 speak
3

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 Lunch
4

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 Remarks
5

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 Remarks
7

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 Meeting
9

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 Comments
11

Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks
12

Standards Development

• The 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 Overview
13

• 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 Analysis
14

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.html
15

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

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 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 

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 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 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 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 rule
19

Rulemaking Schedule

Rulemaking Process Overview

2014 2015 2016 2019

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 2019
20

Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks
21

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 & Definitions
22

Scope of Coverage

• EPCA definition of Commercial Prerinse Spray Valve

- “A handheld device designed and marketed 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 & Definitions
23

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 Remarks
26

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 Metrics
27

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

- Cleanability 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 Remarks
29

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 

Analysis
30

• 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 & Technology
31

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 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, 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 patterns
34

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 & Technology
35

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 Options
36

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 

Analysis
38

• 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 Analysis
39

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 

Analysis
40

• Purpose: Determine 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 

Relationship

MSP

Water Use

Analyses Using Cost –

Efficiency Relationship
41

 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; identify the maximum technologically 

feasible (max-tech) level for each equipment class

 Develop efficiency levels that range from the baseline to maxtech

 The result of the engineering analysis will be a set of priceefficiency 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 Analysis
42

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 Analysis
43

Rulemaking Analyses: Engineering Analysis

Efficiency Levels

• DOE will identify the highest efficiency model in the market (maxtech) 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 patterns
44

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 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

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 

Analysis
46

• Purpose

– Assess the economic impacts of potential energy conservation 

standards on manufacturers

– Identify and estimate impacts on manufacturer subgroups that 

may be more adversely affected than the industry as a whole

– Examine 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 Analysis
47

Complete 

industry 

profile

Develop 

strawman 

GRIM

Develop 

interview 

guide

Conduct 

interviews & 

industrywide/ 

subgroup 

analyses

Assess direct 

employment, 

manufacturing 

capacity, and 

cumulative 

burden

Finalize

MIA 

results 

for 

NOPR

Phase 1 Phase 2 Phase 3

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 

Analysis
49

• 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 Analysis
50

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 Analysis
52

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 

Analysis
53

• 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 Analysis
54

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 

Analysis
56

• 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 Analysis
57

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 prices
58

• 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 Analysis
59

• 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 Analysis
60

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 

Analysis
62

• 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 Analysis
63

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 

Analysis
65

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 rates
66

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:

- Installed 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 Analyses
69

• 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 Analyses
71

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 Analyses
73

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 Analyses
75

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 (CO2)

• Sulfur dioxide (SO2) 

– SO2 emissions from affected electric generating units are subject to 

nationwide and regional emissions cap and trading programs

• Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern 

States and Washington, D.C.

• Methane (CH4)

• Nitrous oxide (N2O)

• 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 Analysis
77

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 

NOx 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 Analyses
79

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 nonregulatory alternative to a new or amended standard

– Some examples include:

– Tax Credits

– Rebate Programs

– Bulk Purchase Programs

– WaterSense
80

Public Meeting Topics

1 Housekeeping Items

2 Rulemaking Process Overview

3 Authority & Definitions

4 Test Procedure & Test Metrics

5 Rulemaking Analyses

6 Closing Remarks
81

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