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Federal Register / Vol. 86, No. 110 / Thursday, June 10, 2021 / Proposed Rules standards on individual consumers, in order to determine whether amended standards would be economically justified, DOE typically uses the following two metrics:
The LCC is the total consumer expense of equipment over the life of that equipment, consisting of total installed cost manufacturer selling price, distribution chain mark-ups, sales tax, and installation costs plus operating costs expenses for energy use, maintenance, and repair. To compute the operating costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the equipment.
The PBP is the estimated amount of time in years it takes consumers to recover the increased purchase cost including installation of more-efficient equipment through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost at higher efficiency levels by the change in annual operating cost for the year that amended or new standards are assumed to take effect.
For any given efficiency level, DOE
typically measures the change in LCC
relative to the LCC in the no-newstandards case, which reflects the estimated efficiency distribution of equipment in the absence of new or amended energy conservation standards. In contrast, the PBP for a given efficiency level is measured relative to the baseline equipment.
1. Installation Costs Installation cost includes labor, overhead, and any miscellaneous materials and parts needed to install the equipment. In response to the August 2019 RFI, DOE received several comments related to installation issues associated with UFHWSTs with increased insulation thickness. BWC
and AHRI stated that increasing the size of UFHWSTs by increasing the thickness of required insulation will lead to difficulties getting tanks through doorways and to their final locations in existing mechanical rooms. BWC, No. 5
at p. 2 and AHRI, No. 6 at p. 2

AHRI commented that reducing the storage volume of the tank itself is not a practical option because the most critical design feature of UFHWSTs is their storage volume. AHRI, No. 6 at pp. 12 AHRI asserted that the predominant market for UFHWSTs are replacement installations, and again increased insulation would lead to difficulties with replacement because of space constraints in existing mechanical rooms. Additionally, BWC suggested that this could potentially necessitate the following changes: replacement of one UFHWST with two UFHWSTs, addition of mechanical rooms, or changes to system configurations. BWC, No. 5 at p. 2
Feedback from manufacturer interviews conducted under NDAs also suggests that manufacturers are very concerned that increases in overall UFHWST dimensions due to increased insulation thickness could require modifications to existing doorways or mechanical rooms, in order to be able to replace existing tanks with a single tank of similar volume, which would significantly increase installation costs.
In response to these comments from BWC and AHRI, DOE examined some of the potential installation costs i.e., widening doorways that lead to the mechanical room and expanding the mechanical room itself. To estimate the costs of expanding doorways in order to allow UFHWSTs to pass through, DOE
was able to examine the cost of door removal and reinstallation using data for exterior and interior door installations available in the RSMeans 2020
Estimating Handbook Online.13 DOE
examined the cost breakdown of installing new fire-rated doorways, both at 3 to 4-foot, and 6 to 7-foot width ranges, as well as interior passage doors at these same widths. For these doorway types, DOE did not use the entire installation values cited in the literature; rather, DOE only used the portions of the cost associated with the installation of existing frames and doors. DOE expects that comparable costs would be required to remove
existing doors in a manner where they could be reinstalled without the need for new equipment, so for this estimate, the doorway installation cost were doubled to reflect both removal and reinstallation. Under this scenario, DOE
found that door removal and reinstallation costs could potentially increase the cost of UFHWST
installation by between $280 and $1720
for every doorway requiring modification. DOE currently has no method of determining the average number of doorways that a UFHWST
would need to pass through during the course of installation which increases the potential range of installation costs.
For this NOPD, DOE was unable to find detailed data characterizing the costs of restructuring the mechanical room. However, DOE was able to examine other waterheating rulemakings with equipment with water storage characteristics where replacement installations could prove difficult. Specifically, DOE compared the magnitude of difference between the average, the 95th percentile, and maximum installation costs for the following baseline equipment as a proxy for potential customer impacts in extreme cases. DOE also does not currently have enough data indicating the percentage of UFHWST installations that could necessitate building modifications to get the UFHWST to its destination in the mechanical room, if tank dimensions were increased.
However, the results in Table IV.8, while illustrative, are not exhaustive, and they show that the potential range of increased costs is significant, particularly for commercial equipment where the range of potential installation costs can be greater than 50 percent than the average in some extreme cases. It is expected that these costs would often be unavoidable because building owners are likely unable to substitute these tanks with tanks of alternative dimensions or volumes to meet operational needs and fit in existing spaces.

TABLE IV.8MAGNITUDE OF POTENTIAL INCREASE IN INSTALLATION COSTS

khammond on DSKJM1Z7X2PROD with PROPOSALS

Installation cost $

Increase over mean %

Equipment 95thPercentile
Mean Commercial-Duty Gas Storage Water Heater 14
Residential-Duty Commercial Gas Storage Water Heater 15
Commercial Electric Storage Water Heater 16
13 RSMeans Data from Gordian 2020 Available at: https www.rsmeansonline.com/ Last Accessed: July 20, 2020. For details, please see the
VerDate Sep<11>2014

16:41 Jun 09, 2021

Jkt 253001

812
678
1,054

1,225
1,001
1,325

following records: B20301251800: Door, single, exterior fire door, A label, B20301252500: Door, double, exterior fire door, A label,
PO 00000

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Fmt 4702

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Maximum 2,432
2,088
1,773

95thPercentile
Maximum 51
48
26

199
208
68

C10201101600: Door, interior fire door, B20301251900: Door, double, aluminum, entrance, B20301251200: Door, single, aluminum, entrance.

E:FRFM10JNP1.SGM

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