Small-scale (100 kW-5 MW) on-site distributed generation (DG) economically driven by combined heat and power (CHP) applications and, in some cases, reliability concerns will likely emerge as a common feature of commercial building energy systems in developed countries over the next two decades. In the U.S., private and public expectations for this technology are heavily influenced by forecasts published by the Energy Information Administration (EIA), most notably the Annual Energy Outlook (AEO). EIA's forecasts are typically made using the National Energy Modeling System (NEMS), which has a forecasting module that predicts the penetration of several possible commercial building DG technologies over the period 2005-2025. Annual penetration is forecast by estimating the payback period for each technology, for each of a limited number of representative building types, for each of nine regions. This process results in an AEO2004 forecast deployment of about a total 3 GW of DG electrical generating capacity by 2025, which is only 0.25% of total forecast U.S. capacity. Analyses conducted using both the AEO2003 and AEO2004 versions of NEMS changes the baseline costs and performance characteristics of DG to reflect a world without U.S. Department of Energy (DOE) research into several thermal DG technologies, which is then compared to a case with enhanced technology representative of the successful achievement of DOE research goals. The net difference in 2025 DG penetration is dramatic using the AEO2003 version of NEMS, but much smaller in the AEO2004 version. The significance and validity of these contradictory results are discussed, and possibilities for improving estimates of commercial U.S. DG potential are explored.