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Federal Register / Vol. 86, No. 110 / Thursday, June 10, 2021 / Proposed Rules
failures. UFHWSTs are relatively simple equipment when compared to storagetype water heaters that include heating elements or a fossil-fuel burner with a storage tank. The simplicity of UFHWSTs would limit the likelihood of mechanical failure as compared to a storage-type water heater, but they can still fail due to corrosive or sediment build-up. Electric storage water heaters that use electric resistance elements for heating are likewise relatively simple equipment, whereas gas-fired storage water heaters can be more complex, because they typically require an ignition system, burner, combustion fans in some cases, associated combustion controls, and flue gas venting system. The mechanical simplicity of electric storage water heaters lends itself to a failure mode related to the storage tank component of the water heating package, which would be expected to be analogous to the typical failure mode for an UFHWST.
For this analysis, DOE used the average lifetime for commercial electric storage water heaters i.e., 12 years as a proxy for UFHWST lifetime. In the TSD for
DOEs May 2016 CWH ECS NOPR 81
FR 34440, the average lifetime for commercial electric hot water storage tanks was estimated to be 12 years.
Based on this average lifetime, DOE
assumed an 8 percent per year replacement rate for UFHWSTs.
DOE requests comment on its assumption of a 12-year lifetime for UFHWSTs similar to commercial electric hot water storage tanks.
3. Shipments for New Construction To project shipments of UFHWSTs for new construction, DOE relied on the trends available from the AEO 2021.
DOE used the Commercial Floorspace and Macro Indicators Employment Manufacturing trends to project new construction for the commercial and industrial sectors, respectively.26 27 DOE
estimated a saturation rate for each equipment type using building and equipment stock values. The saturation rate was applied in each year, yielding shipments to new buildings.
DOE requests comment on its use of AEO 2021 trends as a scaler to project shipments to new construction.

4. Estimated Shipments Table IV.10 presents the estimated UFHWST shipments in selected years.

TABLE IV.10SHIPMENTS RESULTS
FOR UFHWSTS UNITS
Year 2025
2030
2040
2050
2060

Shipments

18,292
19,240
21,244
23,208
0

a. Distribution of Shipments by UFHWST Storage Volume Table IV.11 presents the estimated distribution of UFHWST shipments by the storage volume ranges specified in section IV.B.2 of this document. DOE
estimated these values through examination of capacity counts in existing trade literature and DOEs CCMS database. DOE assumes that this distribution is static and does not change over time.

TABLE IV.11DISTRIBUTION OF SHIPMENTS BY UFHWST STORAGE VOLUME GAL
Capacity Range
0 to 100
percent
101 to 250
percent
251 to 500
percent
501 to 1000
percent
1001 to 2000
percent
2001 to 5000
percent
>5000
percent
Market Share

3

11

23

26

20

16

1

DOE requests comment on its distribution of shipments by storage volume, and on its assumption that the distribution of shipments by storage volume does not change over time.

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5. Additional Sources of Uncertainty DOE recognizes that the market for UFHWSTs is a relatively highly customized and low-volume shipments market. DOEs review of publiclyavailable information indicates that annual shipments through 2030 will be below 20,000 units see the previous section for additional details.
Additionally, in response to the August 2019 RFI, BWC submitted a list of over 200 companies which it identified as UFHWST manufacturers, which underscores the low-volume nature of the UFHWST industry. BWC, No. 5 at p.2 DOE reviewed these companies and found many to be custom fabrication/
welding shops or producers of vessels for niche industry processes such as chemical mixing or fuel storage.
26 U.S. Energy Information Administration, Annual Energy Outlook 2021, Table 22, Commercial Sector Energy Consumption, Floorspace, Equipment Efficiency, and Distributed Generation Available at: https www.eia.gov/

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Although most of the manufacturers listed by BWC may theoretically be capable of manufacturing UFHWSTs, DOE did not find evidence that these businesses advertise or market UFHWSTs. However, DOE was able to confirm that some of the companies listed by BWC manufacture UFHWSTs, and DOE included these manufacturers in its list of UFHWST manufacturers. In total, DOE has identified 48 UFHWST
manufacturers, 37 of which are small domestic manufacturers.
Due to the niche nature of this marketplace, it is difficult to accurately predict how the market would respond to amended standards e.g. whether any manufacturers would face disproportionately high conversion costs, what changes may result to the distribution of tank sizes sold, if consumers would select different equipment to meet their water heating needs, or whether manufacturers might consolidate or exit the market. These uncertainties may substantially impact
the findings if DOE were to complete a full economic impact analysis of amended standards for UFHWSTs or estimate the cost-effectiveness of a more-stringent standard.

outlooks/aeo/data/browser id=32AEO2021&cases=ref2021&sourcekey=0.
27 U.S. Energy Information Administration, Annual Energy Outlook 2021, Table 23, Industrial
Sector Macroeconomic Indicators Available at:
https www.eia.gov/outlooks/aeo/data/browser//
?id=34- AEO2021&cases=ref2021&sourcekey=0.

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F. National Impact Analysis DOE conducted an NIA that assesses the NES in terms of total site energy savings that would be expected to result from new or amended standards at specific efficiency levels. DOE did not assess the net present value NPV of the total costs and benefits experienced by consumers as part of the NIA because of the lack of an LCC analysis as previously discussed. DOE calculates the NES for the potential standard levels considered based on projections of annual equipment shipments, along with the annual energy consumption from the energy use analysis. For the present analysis, DOE projected the site energy savings over the lifetime of UFHWSTs sold from 2025 through 2054.

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