{"id":284889,"date":"2023-10-24T20:18:40","date_gmt":"2023-10-24T18:18:40","guid":{"rendered":"https:\/\/climatescience.press\/?p=284889"},"modified":"2023-10-24T20:18:44","modified_gmt":"2023-10-24T18:18:44","slug":"review-of-proposed-minimum-efficiency-standards-for-consumer-boilers","status":"publish","type":"post","link":"https:\/\/climatescience.press\/?p=284889","title":{"rendered":"Review of Proposed Minimum Efficiency Standards for \u201cConsumer Boilers\u201d"},"content":{"rendered":"\n
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Double exposure graphic of business people working over wind turbine farm and green renewable energy worker interface. Concept of sustainability development by alternative energy.<\/figcaption><\/figure>\n\n\n\n

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Many governments have made promises to reduce greenhouse gas emissions by replacing fossil fuels with solar and wind generated electricity and to electrify the economy. <\/em><\/strong><\/p>\n\n\n\n

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From\u00a0Master Resource<\/a><\/p>\n\n\n\n

By\u00a0<\/em>Mark Krebs<\/a><\/p>\n\n\n\n

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\u201cDOE\u2019s recent appliance efficiency \u2018determinations\u2019 are doing more harm than good for consumers and defy objectivity and transparency processes required by the Code of Federal Regulations (the Process Rule)\u2026.  Accordingly, this program should be dismantled as DOE has once again proven itself to be unworthy of objectively and transparently serving the best interests of American consumers.\u201d<\/p>\n<\/blockquote>\n\n\n\n

This post updates my September 19th analysis<\/a> to examine just-filed comments in opposition to the U.S. Department of Energy\u2019s hell-bent strategy of mandating less choice and higher costs for consumers in return for specious benefits.<\/p>\n\n\n\n

Background<\/strong><\/p>\n\n\n\n

On August 13, 2023, DOE\u2019s Office of Energy Efficiency and Renewable Energy (EERE) posted a Notice of Proposed Rulemaking for \u201cconsumer\u201d boilers<\/a>.  The comment period ended on October 13th<\/sup>, 2023.  This NOPR, if finalized, would ban common gas-fired hot water boilers by requiring an AFUE (Annual Fuel Utilization Efficiency) of 95%.<\/p>\n\n\n\n

According to Energy.gov<\/a>, a high-efficiency heating system has an AFUE rating of 90% to 98.5%. Such premium efficiencies come at a premium cost, especially in the replacement market where most of these  dependable and long-lasting non-condensing boiler technologies are common.<\/p>\n\n\n\n

My Comments<\/strong><\/p>\n\n\n\n

I have been documenting EERE\u2019s misdeeds for more than a decade in scores of filings publicly available through regulation.gov. Additionally, I have disclosed scores of articles further documenting these misdeeds for the past decade that are publicly available through my archives at MasterResource<\/a>. <\/p>\n\n\n\n

The reason for these inclusions is not for EERE; but for the benefit of elected and appointed lawmakers who may intervene in cleaning up the mess that the enabling legislation, the Energy Conservation and Policy Act (EPCA), created (unwittingly or otherwise) that increasingly harm ordinary consumers.<\/p>\n\n\n\n

In addition to the added purchase expenses of high-end condensing furnaces, all such homes would require costly new boiler exhaust systems and cause potential problems for any non-condensing heating systems \u201cstranded\u201d on the existing non-condensing exhaust systems (i.e., typical gas-storage water heaters). <\/p>\n\n\n\n

Condensing technologies are also much more complicated, requiring additional maintenance and repair costs that can easily wipe out EERE\u2019s claimed savings from reduced gas bills. Basically, high-end boilers are computer controlled. One failed motherboard component means a replacement. If such a failure occurs out-of-warranty, the fix is a new motherboard that can exceed the life-cycle savings estimated by EERE in this docket, savings of about $350 per year on average. Condensing boiler heat exchangers also don\u2019t last nearly as long. <\/p>\n\n\n\n

Some manufacturers claim that condensing boiler heat exchanges will only last 10 years, as opposed to the 27+ years claimed by EERE.  Additionally, EERE\u2019s meager $350 savings are highly inflated (by about 70%) due to  claimed Social Cost of Carbon (SCC) reductions and nebulous \u201chealth benefits,\u201d both of which are highly contested by independent science.  At least arguably, EPCA never intended for these concocted benefits to be included, let alone given greater weight than reduced consumer utility costs.<\/p>\n\n\n\n

Given these one-sided factors (and more discussed below), EERE claims a highly dubious 2.7-year simple payback.  It should also be noted that DOE has never based its \u201cdeterminations\u201d upon any semblance of actual installation histories.  Instead, EERE relies on a variety of biased analytical apparatchik<\/a> that defy (by design) independent verification largely through biased forecasts with results averaged into oblivion.<\/p>\n\n\n\n

Even more audacious is the fact that EERE is repeating the same manipulative Monte Carlo<\/a> \u201crandom assignment\u201d methodologies that DOE was recently admonished for using by the United States Court of Appeals for the District of Columbia Circuit where the Court remanded<\/a> DOE\u2019s final rule for commercial boilers.  By once again repeating this severe analytical cheat documented within the Court\u2019s order, it further indicates DOE\u2019s ongoing contempt for analytical objectivity and transparency that (at least arguably) shows contempt for the Court\u2019s ruling.[1]<\/a> <\/strong>The essence of this \u201crandom assignment\u201d cheat is this:<\/p>\n\n\n\n

 \u2013 that base case purchasing decisions are never influenced by the economics of potential investments in Standards-Compliant products regardless of the economic stakes involved\u2013 is indefensible<\/em>.[2]<\/strong><\/a><\/strong><\/p>\n\n\n\n

DOE\u2019s recent appliance efficiency \u201cdeterminations\u201d are doing more harm than good for consumers and defy objectivity and transparency processes required by the Code of Federal Regulations at 10 CFR 430 Appendix A to Subpart C (a.k.a., the \u201cProcess Rule\u201d).  But it\u2019s a massive win for EERE\u2019s radical \u201celectrify everything\u201d cult, their well-funded minions and the \u201cadministrative state\u201d they collectively serve.<\/p>\n\n\n\n

Accordingly, this program should be dismantled as DOE has once again proven itself to be unworthy of objectively and transparently serving the best interests of American consumers.<\/p>\n\n\n\n

Comments filed in opposition to EERE\u2019s NOPR for \u201cconsumer\u201d boilers posted after October 13 deadline:<\/p>\n\n\n\n