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April 5, 2023

Industry Response to DOE Request for Information

Regarding Energy Upgrades


The US DOE, as part of the IRA, issued a Request for Information (RFI) for, in their words...

 

To collect information that will ultimately support states, territories, and Indian Tribes in creating Home Energy Rebate programs that effectively serve U.S. households with technology products and services that reduce energy bills, increase home comfort, improve indoor air quality, and reduce greenhouse gas emissions.

 

The RFI contained 60 questions for which parties could provide feedback. OMAs was part of a subcommittee assembled by NEFI to see where our industry could contribute. The subcommittee identified several questions that it felt were pertinent.

 

Additionally, OMA identified and pursued a section of particular interest. In Section H. Estimating and Measuring energy Savings, were several questions on measuring energy efficiency savings that also included methodology for measuring reducing GHGs. As the majority of .liquid fired heating systems do not match those of Nat Gas nor heat pumps when measured with AFUE, and there is no other standardized method of measuring efficiency, we intended to provide an answer that may be considered by the DOE.

 

Don Farrell and Roger Marran, along with Dr. Thomas Butcher, NORA Technical Director, got together to craft a credible response. NORA’s research shows that upgrading to a new, properly sized heating appliance can yield real savings not reflected in AFUE. Additionally, the inclusion of renewable, low carbon fuels can immediately and measurably reduce GHGs. The challenge was to show a method(s) that will be credible and effective.

 

After much discussion and evaluation (driven primarily by the technical knowledge of Roger Marran and Dr. Butcher) of the available data and methodologies that would be credible, the final wording reads as:

 

In a recent study, the National Oilheat Research Alliance (NORA) completed an evaluation of the energy, cost, and GHG emissions reductions associated with their equipment replacement rebate program. Recognizing that this equipment is dominated by combined heat and domestic hot water systems, the Annual Fuel Utilization Efficiency (AFUE) was not used to estimate fuel use reduction. Instead, prior work on combination systems and some basic system characteristics were used to estimate potential energy savings. This was validated through an examination of actual fuel use reduction in a subset of the 6,400 home sites included. The average savings were found to be 20%. It is therefore recommended that states adopt this fuel use reduction methodology to estimate savings that more accurately reflect field results than AFUE alone.

 

The NORA study Report on Equipment Upgrade Incentive Project December 2021 was cited.

 

As you can see from the full response this industry and the NPGA (it was agreed that crafting a joint response might ad “clout” to our document) that 17 questions from the DOE were addressed. The industry responses are too detailed to summarize here. You can download it below.


The NEFI Home Efficiency Subcommittee’s Members include David Foster of Wilcox Energy (chair), Kate Duffey of DE Duffey & Sons, Roger Marran of Energy Kinetics, Ian Lindsay of RW Beckett Corp., Rosemary Bartchak of Boyertown Furnace, Joe Uglietto of DES, David Chu of CEMA, Craig Snyder of BantamWessson (now Valiant Energy), and Don Farrell of OMA. Michael Ferrante, MEMA also participated and Dr. Butcher, NORA offered technical guidance.

DOE FRI
NEFI/Industry Response