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Federal Register / Vol. 86, No. 110 / Thursday, June 10, 2021 / Proposed Rules TABLE IV.8MAGNITUDE OF POTENTIAL INCREASE IN INSTALLATION COSTSContinued Installation cost $

Increase over mean %

Equipment 95thPercentile
Mean Consumer Gas-fired Storage Water 17
Consumer Electric Storage Water Heaters 18
Consumer Oil-fired Storage Water Heaters 19

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DOE recognizes that increasing installation costs can reduce, or even eliminate, the future economic consumer benefits from a potential new standard. Because of this, DOE
tentatively agrees with the commenters that installation costs for certain UFHWST customers could include the removal and reinstallation of exterior and interior doorways, and in some extreme cases, it could require the restructuring of existing mechanical rooms to fit the new replacement equipment if the dimensions of UFHWSTs are increased. Furthermore, DOE tentatively agrees with the commenters that a small increase in tank dimensions in a potential new standards case could potentially disproportionately increase the installation costs for a fraction of consumers of replacement equipment.
While the fraction of impacted consumers is uncertain, DOE is certain that there will be some consumers who will experience these higher installation costs. These higher installation costs for 14 U.S. Department of Energy, Energy Efficiency and Renewable Energy Office, Energy Conservation Standards for Commercial Water Heating Equipment, NOPR Analytical Spreadsheet:
Commercial Water Heater CWH Life Cycle Cost LCC and Payback Period Analysis April 20, 2016
Available at: https regulations.gov/document/
EERE-2014-BT-STD-0042-0013. See worksheet labelled: Forecast Cells.
15 Ibid.
16 Ibid.
17 U.S. Department of Energy, Energy Efficiency and Renewable Energy Office, Energy Efficiency Standards for Pool Heaters, Direct Heating Equipment and Water Heaters, 20100406 Final Rule Analytical Tools July 1, 2011 Available at:
https www.regulations.gov/document?D=EERE2006-STD-0129-0148. See: 20100326 Life Cycle Cost Electric Storage Water Heaters.xlsx.
18 U.S. Department of Energy, Energy Efficiency and Renewable Energy Office, Energy Efficiency Standards for Pool Heaters, Direct Heating Equipment and Water Heaters, 20100406 Final Rule Analytical Tools July 1, 2011 Available at:
https www.regulations.gov/document?D=EERE2006-STD-01290148. See: 20100326 Life Cycle Cost Gas-fired Storage Water Heaters.xlsx.
19 U.S. Department of Energy, Energy Efficiency and Renewable Energy Office, Energy Efficiency Standards for Pool Heaters, Direct Heating Equipment and Water Heaters, 20100406 Final Rule Analytical Tools July 1, 2011 Available at:
https www.regulations.gov/document?D=EERE2006-STD-01290148. See: 20100324 Life Cycle Cost Oil-fired Storage Water Heaters.xlsx.

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replacement equipment create uncertainty regarding the positive economic benefits for a potentially significant fraction of consumers from an amended standard for UFHWSTs.
DOE requests data and information which can be used to estimate installation costs of UFHWSTs with modified dimensions.
DOE requests information and data characterizing the types of buildings where installation difficulties are likely to occur and to lead to increased installation cost, as well as the frequency with which such installation problems may arise.
DOE requests information and data characterizing the average installation costs for UFHWSTs at all different storage volumes.
DOE requests information and data characterizing the circumstances that would drive the decision to potentially restructure an existing building spaces, including doorways and mechanical rooms, when installing a replacement UFHWST. For example, is the decision driven by a minimum building code requirement for door openings?
2. Annual Energy Consumption DOE typically determines the annual energy consumption for equipment at different efficiency levels. DOEs approach to determining the annual energy consumption of UFHWSTs is described in section IV.C of this document. In response to the August 2019 RFI, A.O. Smith suggested that any potential energy savings resulting from changes to insulation thickness would be small and significantly outweighed by the costs that would be borne by commercial customers and manufacturers. A.O. Smith, No. 8 at p. 2
As discussed in section V.A.1 of this document, DOE estimates that amended standards at the max-tech level would result in site energy savings i.e., realized at the source of hot water by either a water heater or hot water supply boiler of 0.017 quads over 30 years.
However, as discussed in section IV.C.1
of this document, even small adjustments to several critical inputs to the model could have a large impact on
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498
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40
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Maximum 276
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these results and could significantly alter the findings. For example, as explained previously, the inputs to the tank thermal loss model are primarily based on publicly-available data and information gathered during manufacturer interviews, but as discussed earlier, the results from this model underestimate losses as compared to those observed during testing of UFHWSTs that was previously done to evaluate the test procedure proposed for UFHWSTs in the May 2016 CWH TP NOPR. These uncertainties would propagate through the cost-benefit analyses and could potentially significantly reduce the energy savings from amended standards.
Therefore, DOE did not conduct an LCC
and PBP analysis for this NOPD.
E. Shipments Analysis DOE uses projections of annual equipment shipments to calculate the national impacts of potential amended or new energy conservation standards.
The shipments model takes an accounting approach in tracking market shares of each equipment class and the vintage of units in the stock. Stock accounting uses equipment shipments as inputs to estimate the age distribution of in-service equipment stocks for all years.
In response to the August 2019 RFI, AHRI stated that it would provide DOE
with 2018 shipments data for UFHWST.
AHRI, No. 6 at p.1 However, no data were received, so DOE developed its own shipments estimates based on available data.
To project shipments and equipment stocks for 2025 through the end of the 30-year analysis period 2054, DOE
used a stock accounting model. Future shipments are calculated based on projections in Annual Energy Outlook 2021 AEO 2021 see section IV.E.3 of this document for further details. The stock accounting model keeps track of shipments and calculates replacement shipments based on the expected service lifetime of UFHWSTs and a Weibull distribution that identifies a percentage of units still in existence from a prior year that will fail and need to be replaced in the current year.

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