Energy Conservation Program: Energy Conservation Standards for Fans and Blowers, 62038-62065 [2022-22141]
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62038
Proposed Rules
Federal Register
Vol. 87, No. 197
Thursday, October 13, 2022
This section of the FEDERAL REGISTER
contains notices to the public of the proposed
issuance of rules and regulations. The
purpose of these notices is to give interested
persons an opportunity to participate in the
rule making prior to the adoption of the final
rules.
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE–2022–BT–STD–0002]
RIN 1904–AF40
Energy Conservation Program: Energy
Conservation Standards for Fans and
Blowers
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notification of data availability
(‘‘NODA’’).
AGENCY:
On February 8, 2022, the U.S.
Department of Energy (‘‘DOE’’)
published a request for information
regarding energy conservation standards
for fans and blowers. In this NODA,
DOE is publishing preliminary inputs
and methodology for its technology,
screening, engineering, shipments,
markups, life cycle cost, and energy use
analysis for air circulating fans. Air
circulating fans are a subcategory of
fans; however, air circulating fans were
not included in the Appliance
Standards and Rulemaking Federal
Advisory (‘‘ASRAC’’) negotiations
undertaken in 2015 (see Docket No.
EERE–2013–BT–STD–0006). The
purpose of this NODA is to provide
stakeholders with the opportunity to
review and provide comment on DOE’s
preliminary technical and economic
evaluation of air circulating fans, prior
to DOE’s publication of a notice of
proposed rulemaking for all fans and
blowers. The analysis presented in this
NODA is consistent with the air
circulating fans scope and definitions
that DOE proposed in the July 25, 2022,
test procedure notice of proposed
rulemaking (‘‘NOPR’’) for fans and
blowers (‘‘July 2022 TP NOPR’’). DOE
requests comments, data, and
information regarding its analysis.
DATES: Written comments and
information will be accepted on or
before November 28, 2022.
ADDRESSES: Interested persons are
encouraged to submit comments using
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SUMMARY:
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the Federal eRulemaking Portal at
www.regulations.gov, under docket
number EERE–2022–BT–STD–0002.
Follow the instructions for submitting
comments. Alternatively, interested
persons may submit comments,
identified by docket number EERE–
2022–BT–STD–0002, by any of the
following methods:
Email: FansAndBlowers
2022STD0002@ee.doe.gov. Include the
docket number EERE–2022–BT–STD–
0002 in the subject line of the message.
Postal Mail: Appliance and
Equipment Standards Program, U.S.
Department of Energy, Building
Technologies Office, Mailstop EE–5B,
1000 Independence Avenue SW,
Washington, DC 20585–0121.
Telephone: (202) 287–1445. If possible,
please submit all items on a compact
disc (‘‘CD’’), in which case it is not
necessary to include printed copies.
Hand Delivery/Courier: Appliance
and Equipment Standards Program, U.S.
Department of Energy, Building
Technologies Office, 950 L’Enfant Plaza
SW, 6th Floor, Washington, DC 20024.
Telephone: (202) 287–1445. If possible,
please submit all items on a CD, in
which case it is not necessary to include
printed copies.
No telefacsimiles (‘‘faxes’’) will be
accepted. For detailed instructions on
submitting comments and additional
information on this process, see section
IV of this document.
Docket: The docket for this activity,
which includes Federal Register
notices, comments, public meeting
transcripts, and other supporting
documents/materials, is available for
review at www.regulations.gov. All
documents in the docket are listed in
the www.regulations.gov index.
However, some documents listed in the
index, such as those containing
information that is exempt from public
disclosure, may not be publicly
available.
The docket web page can be found at
www.regulations.gov/docket/EERE–
2022–BT–STD–0002. The docket web
page contains instructions on how to
access all documents, including public
comments in the docket. See section
III.A of this document for information
on how to submit comments through
www.regulations.gov.
Mr.
Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and
FOR FURTHER INFORMATION CONTACT:
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Renewable Energy, Building
Technologies, EE–5B, 1000
Independence Avenue SW, Washington,
DC 20585–0121. Telephone: (202) 586–
9870. Email:
ApplianceStandardsQuestions@
ee.doe.gov.
Mr. Matthew Schneider, U.S.
Department of Energy, Office of the
General Counsel, GC–33, 1000
Independence Avenue SW, Washington,
DC 20585–0121. Telephone: (240) 597–
6265. Email: matthew.schneider@
hq.doe.gov.
For further information on how to
submit a comment, or review other
public comments and the docket,
contact the Appliance and Equipment
Standards Program staff at (202) 287–
1445 or by email:
ApplianceStandardsQuestions@
ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority
B. Deviation From Appendix A
C. Background
II. Summary of the Analyses Performed by
DOE
A. Scope
B. Technology Options
C. Screening Analysis
D. Engineering Analysis
1. Methodology
a. Metric
b. Air Circulating Fan Performance Data
2. Equipment Classes and Representative
Sizes
a. Equipment Classes
b. Representative Sizes
3. Efficiency Model
a. BESS Combined Database
b. Baseline Fan Efficiencies
c. Improving Efficiency With More
Efficient Motors
d. Improving Efficiency Through
Aerodynamic Redesign
e. Results for a 24-Inch, 0.5 hp
Representative Unit
4. Cost Model
a. Cost Model Structure and Process
b. Cost Model Assumptions
c. Determination of Air Circulating Fan
MPC
5. Manufacturer Selling Price
E. Markups Analysis
F. Energy Use Analysis
1. Fans With Input Power Less Than 125
W
a. Sample of Consumers
b. Operating Hours
2. Fans With Input Power Greater Than or
Equal to 125 W
a. Sample of Consumers
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b. Operating Hours
G. Life Cycle Cost and Payback Period
Analyses
1. Equipment Price
2. Installation, Repair and Maintenance
Costs
3. Energy Prices
4. Lifetime
5. Discount Rates
6. Efficiency Distribution in the No-New
Standards Case
H. National Impact Analysis
1. Base Year Shipments
2. Shipments Projections
3. Equipment Efficiency Trends
III. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
IV. Approval of the Office of the Secretary
Introduction
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A. Authority
The Energy Policy and Conservation
Act, as amended (EPCA),1 authorizes
DOE to regulate the energy efficiency of
a number of consumer products and
certain industrial equipment. (42 U.S.C.
6291–6317) Title III, Part C 1 of EPCA,
added by Public Law 95–619, Title IV,
section 441(a) (42 U.S.C. 6311–6317 as
codified), established the Energy
Conservation Program for Certain
Industrial Equipment, which sets forth a
variety of provisions designed to
improve energy efficiency.
EPCA specifies a list of equipment
that constitutes covered equipment
(hereafter referred to as ‘‘covered
equipment’’).2 EPCA also provides that
‘‘covered equipment’’ includes any
other type of industrial equipment for
which the Secretary of Energy
(‘‘Secretary’’) determines inclusion is
necessary to carry out the purpose of
Part A–1. (42 U.S.C. 6311(1)(L), 6312(b))
EPCA specifies the types of industrial
equipment that can be classified as
covered in addition to the equipment
enumerated in 42 U.S.C. 6311(1) This
industrial equipment includes fans and
blowers. (42 U.S.C. 6311(2)(B)(ii) and
(iii)) Additionally, industrial equipment
must be of a type that consumes, or is
designed to consume, energy in
operation; is distributed in commerce
1 For editorial reasons, upon codification in the
U.S. Code, Part C was redesignated Part A–1 and
hereafter referred to as Part A–1.
2 ‘‘Covered equipment’’ means one of the
following types of industrial equipment: Electric
motors and pumps; small commercial package air
conditioning and heating equipment; large
commercial package air conditioning and heating
equipment; very large commercial package air
conditioning and heating equipment; commercial
refrigerators, freezers, and refrigerator-freezers;
automatic commercial ice makers; walk-in coolers
and walk-in freezers; commercial clothes washers;
packaged terminal air-conditioners and packaged
terminal heat pumps; warm air furnaces and
packaged boilers; and storage water heaters,
instantaneous water heaters, and unfired hot water
storage tanks. (42 U.S.C. 6311(1)(A)–(K))
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for industrial or commercial use4; and is
not a covered product as defined in 42
U.S.C. 6291(a)(2) other than a
component of a covered product with
respect to which there is in effect a
determination under 42 U.S.C. 6312(c).
(42 U.S.C. 6311(2)(A)) On August 19,
2021, DOE published a final
determination that the inclusion of fans
and blowers as covered equipment was
necessary to carry out the purpose of
Part A–1 and classified fans and blowers
as covered equipment. 86 FR 46579,
46588. Air circulating fans are a class of
fans and blowers.
The energy conservation program
under EPCA consists essentially of four
parts: (1) testing, (2) labeling, (3) energy
conservation standards, and (4)
certification and enforcement
procedures. Relevant provisions of
EPCA include definitions (42 U.S.C.
6311), test procedures (42 U.S.C. 6314),
labeling provisions (42 U.S.C. 6315),
energy conservation standards (42
U.S.C. 6313), and the authority to
require information and reports from
manufacturers. (42 U.S.C. 6316, 42
U.S.C. 6296)
Federal energy efficiency
requirements for covered equipment
established under EPCA generally
supersede state laws and regulations
concerning energy conservation testing,
labeling, and standards. (42 U.S.C.
6316(a) and (b); 42 U.S.C. 6297) DOE
may, however, grant waivers of federal
preemption for particular state laws or
regulations, in accordance with the
procedures and other provisions of
EPCA. (42 U.S.C. 6316(b)(2)(D))
In proposing new standards, DOE
must evaluate a proposal against the
criteria detailed in 42 U.S.C. 6295(o),
discussed further in section I.C of this
document, and follow the rulemaking
procedures set out in 42 U.S.C. 6295(p).
(42 U.S.C. 6316(a))
DOE is publishing this NODA to
collect data and information to inform
its decision consistent with its
obligations under EPCA.
B. Deviation From Appendix A
In accordance with Section 3(a) of
appendix A to subpart C of 10 CFR part
430, DOE notes that it is deviating from
that appendix’s provision requiring a
75-day comment period for all preNOPR standards documents. (Section
6(d)(2) of appendix A to subpart C of 10
CFR part 430) DOE is instead providing
a 45-day comment period which DOE
believes is appropriate given the
substantial stakeholder engagement to
date, as discussed in section I.C of this
document. The request for information
on air circulating fans published on
February 8, 2022, provided early notice
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to interested parties that the Department
was interested in evaluating potential
energy savings for this equipment. 87
FR 7048. Further, a 45-day comment
period will allow DOE to review
comments received in response to this
NODA and use it to inform the analysis
of equipment considered in evaluating
potential energy conservation standards.
C. Background
On June 28, 2011, DOE published a
notice of proposed coverage
determination proposing that fans,
blowers, and fume hoods would qualify
as covered equipment under EPCA. 76
FR 37678. DOE noted that there were no
statutory definitions for ‘‘fan,’’
‘‘blower,’’ or ‘‘fume hood,’’ and
presented definitions for consideration.
76 FR 37678, 37679. DOE subsequently
published a framework document on
February 1, 2013, detailing the
analytical approach for developing
potential energy conservation standards
for commercial and industrial fans and
blowers should the Secretary classify
such equipment as covered equipment
(‘‘Framework Document’’). 78 FR 7306.
In the Framework Document, DOE
determined that it lacked authority to
establish energy conservation standards
for fume hoods because fume hoods are
not listed as a type of equipment for
which DOE could establish standards.
(Docket EERE–2013–BT–STD–0006, No.
1 at p. 15) DOE acknowledged that the
fan, which provides ventilation for the
fume hood, consumes the largest
portion of energy within the fume hood
system, and that DOE planned to cover
all commercial and industrial fan types,
which included fans used to ventilate
fume hoods. Id.
On December 10, 2014, DOE
published a NODA presenting an
analysis estimating the economic
impacts and energy savings from
potential energy conservation standards
for certain fans and blowers. This
analysis did not include air circulating
fans. 79 FR 73246.
On April 1, 2015, DOE published a
notice of intent to establish an
Appliance Standards and Rulemaking
Federal Advisory Committee (ASRAC)
Working Group for fans (hereafter
referred to as the ‘‘Working Group’’). 80
FR 17359.
The Working Group 3 commenced
negotiations at an open meeting on May
3 The Working Group was comprised of
representatives from AAON, Inc.; AcoustiFLO LLC;
AGS Consulting LLC; Air Movement and Control
Association (AMCA); Air Conditioning, Heating,
and Refrigeration Institute (AHRI), Appliance
Standards Awareness Project (ASAP); Berner
International Corp; Buffalo Air Handling Company;
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18, 2015 and held 16 meetings and three
webinars to discuss scope, metrics, test
procedures, and standard levels for fans
and blowers.4 The Working Group
concluded its negotiations on
September 3, 2015, and, by consensus
vote,5 approved a term sheet containing
27 recommendations related to scope,
test procedure and energy conservation
standards (‘‘term sheet’’). (See Docket
No. EERE–2013–BT–STD–0006, No.
179) ASRAC approved the term sheet on
September 24, 2015. (Docket No. EERE–
2013–BT–NOC–0005; Public Meeting
Transcript, No. 58, at p. 29) The
Working Group term sheet
recommended the exclusion of air
circulating fans. (See Docket No. EERE–
2013–BT–STD–0006, No. 179,
Recommendation #2 at p. 2) On
November 1, 2016, DOE published a
third notification of data availability
(‘‘November 2016 NODA’’) that
presented a revised analysis for fans and
blowers other than air circulating fans,
consistent with the scope and metric
recommendations of the term sheet. 81
FR 75742.
On January 10, 2020, DOE received a
petition from the Air Movement and
Control Association, International
(‘‘AMCA’’), Air Conditioning
Contractors of America, and Sheet Metal
& Air Conditioning Contractors of
America requesting that DOE establish a
test procedure for certain categories of
fans based on an upcoming industry test
method, AMCA Standard 214, ‘‘Test
Procedure for Calculating Fan Energy
Index (FEI) for Commercial and
Industrial Fans and Blowers’’ DOE
published a notice of petition for
rulemaking and request for public
comment (‘‘April 2020 Notice of
Petition for Rulemaking’’). 85 FR 22677
(Apr. 23, 2020). AMCA, Air
Conditioning Contractors of America,
and Sheet Metal & Air Conditioning
Contractors have since withdrawn their
petition (EERE–2011–BT–DET–0045–
00012, at p. 1)
In conjunction with this notice of
petition for rulemaking, on May 10,
2021, DOE published a request for
information requesting comments on a
potential fan or blower definition. 86 FR
24752. On August 19, 2021, DOE
published in the Federal Register a final
coverage determination classifying fans
and blowers as covered equipment. 86
FR 46579.
On October 1, 2021, DOE published a
request for information pertaining to test
procedures for fans and blowers
(‘‘October 2021 TP RFI’’). 86 FR 54412.
As part of the October 2021 TP RFI,
DOE discussed the potential scope and
definitions for air circulating fans. 86 FR
54412, 54414–54415. DOE is
considering including air circulating
fans in its analysis of potential energy
conservation standards for fans and
blowers. As noted previously, air
circulating fans were not included in
the scope of the term sheet and were not
previously analyzed by the Department.
DOE published a separate request for
information on February 8, 2022, to seek
input to aid in the development of the
technical and economic analyses
regarding whether standards for air
circulating fans may be warranted
(hereinafter referred to as the ‘‘ECS
RFI’’). 87 FR 7048. DOE received
comments in response to the ECS RFI
from the interested parties listed in
Table I–1.
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TABLE I–1—LIST OF COMMENTERS WITH WRITTEN SUBMISSIONS IN RESPONSE TO THE ECS RFI
Comment No.
in the Docket
Commenter(s)
Reference in this NODA
Air Movement and Control Association ....................................
Appliance Standards Awareness Project, American Council
for an Energy Efficient Economy, Natural Resources Defense Council, and Northwest Energy Efficiency Alliance.
California Investor-Owned Utilities ............................................
ebm-papst Inc. ..........................................................................
Robert Akscyn ...........................................................................
Rube´n Guerra ...........................................................................
AMCA ......................................
Joint Commenters ...................
9,10
6
CA IOUs ..................................
ebm-papst ...............................
Akscyn ....................................
Guerra .....................................
7
8
2
3
Commenter type
Trade Association.
Efficiency Organizations.
Utility.
Manufacturer.
Individual.
Individual.
A parenthetical reference at the end of
a comment quotation or paraphrase
provides the location of the item in the
public record.6 Comments received from
the two individuals listed in Table I–1
are not discussed further in because
they were either not relevant to the RFI
or provide procedural
recommendations.7 8
Some of the comments received in
response to the ECS RFI were related to
the fans and blower test procedure. DOE
published a proposed test procedure for
fans and blowers on July 25, 2022 (‘‘July
2022 TP NOPR’’) in which it addressed
the ECS RFI comments related to test
procedure issues, including those
related to definitions, scope of the test
procedure, and metrics. 87 FR 44194.
To date, DOE has not proposed energy
conservation standards for fans and
Carnes Company; Daikin/Goodman; ebm-papst;
Greenheck; Morrison Products; Natural Resources
Defense Council; Newcomb & Boyd; Northwest
Energy Efficiency Alliance; CA IOUs; Regal Beloit
Corporation; Rheem Manufacturing Company;
Smiley Engineering LLC representing Ingersoll
Rand/Trane; SPX Cooling Technologies/CTI; The
New York Blower Company; Twin City Companies,
Ltd; U.S. Department of Energy; and United
Technologies/Carrier.
4 Details of the negotiation sessions can be found
in the public meeting transcripts that are posted to
the docket for the energy conservation standard
rulemaking at: www.regulations.gov/
docket?D=EERE–2013–BT–STD–0006.
5 At the beginning of the negotiated rulemaking
process, the Working Group defined that before any
vote could occur, the Working Group must establish
a quorum of at least 20 of the 25 members and
defined consensus as an agreement with less than
four negative votes. Twenty voting members of the
Working Group were present for this vote. Two
members (Air Conditioning, Heating, and
Refrigeration Institute and Ingersoll Rand/Trane)
voted no.
6 The parenthetical reference provides a reference
for information located in the docket of DOE’s
rulemaking to develop energy conservation
standards for fans and blowers. (Docket No. EERE–
2022–BT–STD–0002, which is maintained at
www.regulations.gov) The references are arranged
as follows: (commenter name, comment docket ID
number, page of that document).
7 A comment from R. Guerra stated that they own
a residential ceiling fan that produces its own
energy (Guerra, No. 3 at p. 1). DOE notes that the
fans evaluated in this rulemaking exclude both
ceiling fans and furnace fans.
8 R. Akscyn recommended that DOE provide a
short RFI summary so stakeholders do not have to
review such lengthy documents and that DOE
consider presenting the variables included in its
analyses in terms of dimensional parameters.
(Akscyn, No. 2 at pp. 1–3) DOE appreciates these
suggestions. With respect to the structure and
length of RFIs, DOE notes that it has certain legal
obligations which it must fulfill for every document
that is published. In most documents, DOE includes
summaries and headings to aid stakeholder review.
Additionally, DOE notes that the purpose of an RFI
is to collect data and information. The purpose of
this document is to present DOE’s analyses to
support potential energy conservation standards for
fans and blowers.
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blowers, including air circulating fans.
This NODA presents DOE’s planned
inputs and preliminary analysis to
inform the development of potential
energy conservation standards for air
circulating fans. As previously
discussed, DOE previously published
and received public comment on three
NODAs for fans and blowers, excluding
air circulating fans. DOE plans to rely
on the existing analysis from the
Working Group for fans and blowers
other than air circulating fans. This
NODA focuses exclusively on air
circulating fans and is intended to
support DOE as it completes a notice of
proposed rulemaking analysis for all
fans and blowers, including air
circulating fans. While the discussion in
this NODA is specific to air circulating
fans, DOE welcomes additional
comments and data on fans and blowers
other than air circulating fans relevant
to its analysis of any potential energy
conservation standards for all fans and
blowers. In addition, DOE may consider
conducting a separate rulemaking
specific to air circulating fans instead of
including air circulating fans as part of
the fans and blowers rulemaking.
II. Summary of the Analyses Performed
by DOE
This NODA focuses exclusively on air
circulating fans and is intended to
support DOE as it completes the notice
of proposed rulemaking analysis for all
fans and blowers, including air
62041
circulating fans. This NODA discusses
the following for air circulating fans: (1)
scope; (2) technology options; (3)
engineering analysis; (4) markups
analysis; (5) energy use analysis; (6) life
cycle cost (‘‘LCC’’) and payback period
(‘‘PBP’’) analyses; and (7) national
impacts analysis. The items listed in
Table II–1 provide an overview of the
information about which DOE is
requesting feedback. A supplemental
spreadsheet documenting the
assumptions and approach to the
engineering analysis is included in the
docket and accessible via the equipment
rulemaking website. (See https://
www1.eere.energy.gov/buildings/
appliance_standards/standards.aspx?
productid=51&action=viewlive)
TABLE II–1—OVERVIEW OF DATA PRESENTED IN THIS NODA
Analysis
Data presented
Scope .......................................................................................
Scope of equipment considered in the analysis of any potential energy conservation standards and related definitions.
More efficient motors.
Improved aerodynamic design (inclusive of blade shape and material selection).
Representative sizes.
Determination of baseline fan efficiency.
Determination of efficiency levels by applying different technology options.
Estimates for manufacturer production cost and manufacturer conversion cost at
each efficiency level.
Manufacturer markup.
Distribution channels.
Fraction of sales going through each channel.
Distribution channel markups and sales tax.
Average operating hours per day.
Distribution of operating hours.
Fraction of time spent in each mode (i.e., speed setting).
Review of repair, installation, and repair practices and costs.
Energy prices.
Lifetimes of air circulating fans.
Discount rates.
Review of available data to determine efficiency distributions.
Base year shipments.
Shipments growth rates and information related to shipments projections.
Information related to efficiency trends.
Technology Options .................................................................
Engineering Analysis ................................................................
Markups Analysis .....................................................................
Energy Use Analysis ................................................................
Life Cycle Costs and Payback Period Analysis .......................
National Impact Analysis ..........................................................
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A. Scope
As stated previously, the July 2022 TP
NOPR discussed potential scope and
definitions for air circulating fans,
which include unhoused air circulating
fan heads and housed air circulating fan
heads. 87 FR 44194. In the July 2022 TP
NOPR, DOE proposed that the test
procedure would be applicable to all air
circulating fans and proposed to define
an air circulating fan as a fan that has
no provision for connection to ducting
or separation of the fan inlet from its
outlet using a pressure boundary,
operates against zero external static
pressure loss, and is not a jet fan. 87 FR
44194, 44215.
DOE is considering including all air
circulating fans in its analysis of
potential energy conservation standards
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for fans and blowers. This includes
unhoused air circulating fan head and
housed air circulating fan head, for
which DOE proposed definitions as part
of the July 2022 TP NOPR (87 FR 44194,
44216).
In the July 2022 TP NOPR, DOE also
provided definitions for subsets of
housed air circulating fan heads,
specifically air circulating axial panel
fans, box fans, cylindrical air circulating
fans, and housed centrifugal air
circulating fans. 87 FR 44194, 44216.
DOE notes that the definitions used in
this NODA are aligned with the
proposed definitions in the July 2022 TP
NOPR, which in turn were derived from
definitions proposed by the AMCA. In
response to the ECS RFI, AMCA
provided additional comments to the
docket on July 7, 2022, summarizing
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definitions to terms under consideration
by the committee revising the ANSI/
AMCA 230–15 standard, ‘‘Laboratory
Methods of Testing Air Circulating Fans
for Rating and Certification’’ (‘‘AMCA
230–15’’). (AMCA, No. 10, p. 1) AMCA’s
comments focused on definitions for
different categories of air circulating
fans and provided context for how air
circulating fans might be grouped.
(AMCA, No. 10, pp. 1–10) DOE will
further address the scope and
definitions of air circulating fan
categories in the test procedure
rulemaking and plans to consider
AMCA’s comments as part of the test
procedure rulemaking.
DOE also notes that in response to the
ECS RFI, the Joint Commenters
expressed their support for establishing
energy conservation standards for air
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circulating fans, including air
circulating fan heads, box fans,
personnel coolers, and table fans. (Joint
Commenters, No. 6 at p. 1) Additionally,
the Joint Commenters agreed that, based
on the definition fans and blowers, air
circulating fan heads, box fans,
personnel coolers, and table fans are
within the scope of the fans and blowers
equipment category. Id. Additionally,
ebm-papst supported the inclusion of
air circulating fans in the DOE test
procedure and energy conservation
standards for fans and blowers. (ebmpapst, No. 8 at p. 2) During the public
meeting held for the July 2022 TP
NOPR, AMCA commented that they
believed it would be best to separate air
circulating fans into a separate
rulemaking from fans and blowers.
(Public Meeting Transcript, EERE–
2021–BT–TP–0021, No. 18 at pp. 12, 27,
43–44) Morrison Products supported
AMCA’s position that air circulating
fans should be considered in a separate
rulemaking. (Public Meeting Transcript,
No. 18 at pp. 91–92) DOE has reviewed
existing regulatory definitions and
market materials and believes that air
circulating fans fall within the
definition of fans and blowers. DOE will
review stakeholder comments and may
consider a separate rulemaking for air
circulating fans.
B. Technology Options
In the ECS RFI, DOE presented
improved aerodynamic design, blade
shape, more efficient motors, material
selection, and variable-speed drives as
potential technology options for air
circulating fans and requested comment
on: (1) how the specific technologies
would impact air circulating fan
efficiency; (2) whether the technologies
listed apply equally to different
categories of air circulating fans; (3) the
impact of curved blades and airfoil
blades on air circulating fan efficiency;
(4) the impact of blade materials on fan
efficiency; and (5) the percentage of air
circulating fans sold with a motor and
with variable-speed drive. 87 FR 7048,
7052.
In response, the Joint Commenters
urged DOE to consider more efficient
motors and more efficient blade designs
in its analysis because of their energy
savings potential. (Joint Commenters,
No. 6 at p. 2) Specifically, they stated
that alternating current (‘‘AC’’) directdrive motors offer better efficiency than
belt drives and that direct current
(‘‘DC’’) motors are more efficient than
AC motors. Id. They added that more
advanced blade designs, such as airfoil
blades, can improve the efficiency of a
fan relative to traditional singlethickness blades. Id. emb-papst
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commented that to improve fan
efficiency, inlet cones or bells and outlet
vanes are occasionally included on air
circulating fan housings and that
winglets and rings are sometimes used
on impellers. (ebm-papst, No. 8 at p. 3)
Additionally, ebm-papst stated that the
most efficient air circulating fans on the
market (maximum available technology
or ‘‘max-tech’’) often include the
following features: an electronically
commutated motor (‘‘ECM’’), injectionmolded axial impellers, and outlet guide
vanes. (ebm-papst, No. 8 at p. 4) Finally,
ebm-papst commented that they are
unaware of any air circulating fans that
are sold without a motor. (ebm-papst,
No. 8 at p. 3)
During manufacturer interviews,9
many manufacturers stated that they
would switch to more efficient motors
before redesigning the housing and
impeller (i.e., the blade assembly), since
fan redesign results in significant
conversion costs. However, improving
the overall fan aerodynamics with the
addition of attachments, such as inlet
cones or outlet vanes might be done
before moving to higher efficiency and
more costly motors.
DOE is not aware of any circulating
fans that were distributed in commerce
without an electric motor. Based on
review of the Bioenvironmental and
Structural System Laboratory (‘‘BESS
Labs’’) database and air circulating fan
teardowns, most motors paired with air
circulating fans are not currently in the
scope of DOE energy conservation
standards (because they are split-phase
(‘‘SP’’) motors and permanent split
capacitor (‘‘PSC’’) motors).10 As such,
DOE expects that, in many cases, fan
manufacturers are using lower
efficiency motors. Therefore, in this
NODA, DOE’s analysis focuses
primarily on improving air circulating
fan efficiency through the use of more
efficient motors, as described in more
detail in section II.D.3.c. DOE also
evaluates the efficiency gains and
relative costs associated with fan
aerodynamic redesign. Notably, DOE is
9 DOE conducted manufacturer interviews
specific to air circulating fans from May 24 to May
31, 2022, to gather information for its analyses
presented in this NODA. Four manufacturers opted
to participate in these interviews.
10 SP and PSC motors are types of single-phase
motors that are not currently included in the scope
of electric motors at 10 CFR 431.25 because only
polyphase motors are included in this scope. SP
and PSC motors are not currently included in the
scope of small electric motors at 10 CFR 431.441
because they do not meet the statutory definition
of ‘‘small electric motor’’ as defined at 10 CFR
431.442. In March 2022, DOE published a
preliminary analysis for the ongoing energy
conservation standards rulemaking for electric
motors that included SP and PSC motors in its
analysis. 87 FR 11650.
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conducting a separate energy
conservation rulemaking for electric
motors in which it is considering
standards for certain single-speed SP
electric motors, single-speed shaded
pole electric motors, and single-speed
PSC motors. (See Docket No. EERE–
2020–BT–STD–0007) The Department
will consider any outcome of the
electric motors rulemaking when
conducting its analysis of potential
energy conservation standards for air
circulating fans.
Issue 1: DOE requests comment on its
assumption that most motors paired
with air circulating fans are lower
efficiency induction motors that are not
currently regulated by DOE.
Additionally, DOE requests data on the
percentage of air circulating fans that
include a SP, PSC, shaded pole, or
electronically commuted motors.
C. Screening Analysis
DOE uses the following five screening
criteria to determine which technology
options are suitable for further
consideration in an energy conservation
standards rulemaking: (1) Technological
feasibility; (2) Practicability to
manufacturer, install, and service; (3)
Impacts on product utility or product
availability; (4) Adverse impacts on
health or safety; and (5) Unique
pathway proprietary technologies. 10
CFR part 430, subpart C, appendix A,
sections 6(b)(3) and 7(b). If DOE
determines that a technology, or a
combination of technologies, fails to
meet one or more of the listed five
criteria, it will be excluded from further
consideration in the engineering
analysis.
DOE did not conduct a screening
analysis for this NODA and instead is
presenting analyses for more efficient
motors with efficiency and cost
estimates for aerodynamic redesign in
order to receive stakeholder feedback. In
future analysis to support this
rulemaking, DOE may screen out some
or all of the technologies discussed
based on one or more of the screening
criteria.
Issue 2: DOE requests comment on if
or how the five screening criteria may
impact the application of an
aerodynamic redesign (including
changes to housing, impeller and/or
blade design), more efficient motors, or
VSDs (‘‘variable-speed drives’’) as
design options in the current
rulemaking analysis.
D. Engineering Analysis
The purpose of the engineering
analysis is to determine the incremental
manufacturing cost associated with
producing products at higher efficiency
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levels. The primary considerations in
the engineering analysis are the
selection of efficiency levels to analyze
(i.e., the ‘‘efficiency analysis’’) and the
determination of product cost at each
efficiency level (i.e., the ‘‘cost
analysis’’).
DOE conducts the efficiency analysis
using either an efficiency-level
approach, a design option approach, or
a combination of both. Under the
efficiency-level approach, the efficiency
levels to be considered in the analysis
are determined based on the market
distribution of existing products (in
other words, observing the range of
efficiency and efficiency-level
‘‘clusters’’ that already exist on the
market). This approach typically starts
with compiling a comprehensive list of
products available on the market, such
as from DOE’s product certification
database. Next, the list of models is
ranked by efficiency level from lowest
to highest, and DOE typically creates a
scatter plot to visualize the distribution
of efficiency levels. From these rankings
and visual plots, efficiency levels can be
identified by examining clusters of
models around common efficiency
levels. The maximum efficiency level
currently available on the market can
also be identified.
Under the design option approach,
the efficiency levels to be considered in
the analysis are determined through
detailed engineering calculations and/or
computer simulations of the efficiency
improvements from implementing
specific design options that have been
identified in the technology assessment.
In an iterative fashion, design options
can also be identified during product
teardowns, described below. The design
option approach is typically used when
a comprehensive database of certified
models is unavailable (for example, if a
product is not yet regulated) and
therefore the efficiency-level approach
cannot be used.
In certain rulemakings, the efficiencylevel approach (based on actual
products on the market) will be
extended using the design option
approach to define ‘‘gap fill’’ levels
(levels that bridge large gaps between
other identified efficiency levels) and/or
to extrapolate to the ‘‘max-tech’’ level
(the level that DOE determines is the
maximum achievable efficiency level),
particularly in cases where the ‘‘maxtech’’ level exceeds the maximum
efficiency level currently available on
the market.
The cost analysis portion of the
engineering analysis is conducted using
one or a combination of cost
approaches. The selection of the cost
approach depends on a variety of factors
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such as the availability and reliability of
information on product features and
pricing, the physical characteristics of
the regulated product, and the
practicability of purchasing the product
on the market. DOE generally uses the
following cost approaches:
Physical teardown: Under this
approach, DOE physically dismantles a
commercially available product,
component-by-component, to develop a
detailed bill of materials (‘‘BOM’’) for
the product.
Catalog teardown: In lieu of
physically deconstructing a product,
DOE identifies each component using
available parts diagrams (available from
manufacturer websites or appliance
repair websites, for example) to develop
the BOM for the product.
Price surveys: If neither a physical nor
catalog teardown is feasible (for
example, for tightly integrated products
that are infeasible to disassemble and
for which parts diagrams are
unavailable), DOE conducts retail price
surveys by scanning retailer websites
and other marketing materials. This
approach must be coupled with
assumptions regarding distributor
markups and retailer markups in order
to estimate the actual manufacturing
cost of the product.
Manufacturer interviews: DOE may
conduct voluntary interviews with
manufacturers to gather confidential
information that can be used in its
analyses. This information can include
manufacturing costs, materials prices,
and markups that can be used in DOE’s
cost analysis.
The engineering analysis conducted
for this NODA used a design option
approach supplemented by an efficiency
level approach. The cost analysis relied
on physical and catalog tear downs, cost
analyses from other rulemakings, and
confidential information provided by
manufacturers.
1. Methodology
The engineering analysis presented in
this NODA is consistent with the scope,
definitions, and metric proposed in the
July 2022 TP NOPR for all fans
(including air circulating fans), except
where described below.
a. Metric
In the July 2022 TP NOPR, DOE
proposed to use the fan energy index
(‘‘FEI’’) or weighted average FEI (in the
case of multi-speed and variable-speed
air circulating fans) as the efficiency
metric for fans and blowers, including
air circulating fans. (87 FR 44194,
44237–44238) FEI is an index calculated
using the fan electrical input power at
a given operating point, divided by the
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electrical input power of a reference fan
at the same operating point. The FEI
allows for the evaluation of fan or
blower efficiency across a range of
operating conditions, captures the
performance of the motor, transmission,
or motor controllers (if present), and
enables differentiation of fans with
motors, transmissions, and motor
controller with different efficiencies. In
the July 2022 TP NOPR, DOE proposed
that the metric be determined as
follows: (1) for single-speed fans, FEI
would be evaluated at the single
available speed and corresponding duty
point; (2) for multi-speed fans and
variable-speed fans, a weighted average
FEI would be determined using a
weighted average of all speeds tested.
(87 FR 44194, 44238)
DOE notes that the BESS Labs
combined database does not provide
performance data for multiple speed
fans at all the test speeds proposed in
the July 2022 TP NOPR. Therefore, for
this NODA, DOE evaluated potential
efficiency improvements based only on
high-speed test data. Because fans are
typically less efficient at their maximum
speed, DOE expects that this
assumption provides a conservative
estimate of potential efficiency gains
relative to the baseline. In future
analysis, DOE expects to conduct its
analysis consistent with the approach
adopting in the forthcoming fans and
blower test procedure.
In the July 2022 TP NOPR, DOE also
proposed FEI reference constants for
flow rate, pressure and the efficiency
target for air circulating fans. (87 FR
44194, 44230, 44232) Specifically, DOE
proposed a flow rate constant (Q0) of
3,201, and pressure constant (P0) of 0
and an efficiency target (h0) of 0.38. Id.
DOE utilized these proposed constants
in its calculations of reference FEI used
in the engineering analysis. In the
supplemental NODA spreadsheet
included in this docket, DOE also
provided performance in terms of cubic
feet per minute per watt (or CFM/W),
since the FEI metric is still relatively
new. (See Docket No. EERE–2022–BT–
STD–0002, No. 11)
b. Air Circulating Fan Performance Data
AMCA stated that no air circulating
fans are currently certified by AMCA.
(AMCA, No. 9 at p. 4) Additionally,
AMCA commented that air circulating
fan product literature may advertise fan
performance calculated using multiple
versions of the AMCA 230 standard
(e.g., AMCA 230–1999, AMCA 230–
2007, AMCA 230–2012, AMCA 230–
2015 without errata, and AMCA 230–15
with 2021 errata). They stated that all of
these versions, except for AMCA 230–15
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with 2021 errata, have at least one error
with respect to thrust, volumetric flow
rate, or input power. AMCA added that
this is an issue for the purchaser, either
because purchasers are not aware of
these errors or because manufacturers
are not required to state how air
circulating fan performance values were
obtained. (Id.) AMCA also provided a
table in their response to the ECS RFI
showing the corrections made between
each version of AMCA 230. (AMCA, No.
9 at p. 5, Table 1) The contents of this
table are reproduced below in Table II–
2.
TABLE II–2—SUMMARY OF ERRORS AND CORRECTIONS IN ANSI/AMCA STANDARD 230
Year
Thrust
Volumetric-flow-rate equation
Input power
No conversion for density.
to standard air
Incorrect—based on actual atmospheric density, but
calculation exaggerated by multiplication factor of
1.414 (√2).
Not calculated ................................................................
to standard air
Incorrect—uses converted thrust but actual air density
No conversion for density.
to standard air
Correct—uses converted thrust and standard air density.
Correct—uses converted thrust and standard air density.
No conversion for density.
1999 .....................................
No conversion for density
2007 .....................................
Conversion
density.
Conversion
density.
Conversion
density.
Conversion
density.
2012 .....................................
2015 .....................................
2015: 2021 erratum .............
to standard air
During interviews, manufacturers
stated that data collected by BESS Labs,
associated with the University of
Illinois-Champaign, is the best source
for air circulating fan data.11 BESS Labs
maintains a database of housed and
unhoused air circulating fan heads that
are used primarily in the agricultural
industry (i.e., poultry houses,
greenhouses, dairy barns). DOE notes
that these air circulating fans heads are
tested by BESS Labs according to AMCA
230–12. DOE used the BESS Labs test
data and applied conversion formulas to
calculate the performance data of the
fans according to AMCA 230–15 with
2021 errata. Details of these
performance calculations are available
in the supplementary spreadsheet
attached to this docket. (EERE–2022–
BT–STD–0002, No. 11)
DOE did not receive sufficient air
circulating fan performance data from
the ECS RFI stakeholder comment
responses or from manufacturers during
the interview process. Therefore, for this
No conversion for density.
Conversion to standard air
density.
analysis, DOE relied primarily on the
BESS Labs circulating fans database
(‘‘BESS Labs Database’’). The BESS Labs
Database categorizes circulating fans
into the following categories: basket,
box, panel, tube, tube with bell inlet,
vented tube, wire basket, and wire tube.
Based on the proposed definitions
discussed in section II.A, DOE mapped
the categories in the BESS Labs
Database as shown in Table II–3.
TABLE II–3—DOE CATEGORIZATION OF BESS LABS DATABASE CIRCULATING FAN CATEGORIES
July 2022 TP NOPR terminology
BESS labs database category
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Unhoused air circulating fan head ........................................................................................
Housed air circulating fan head
Box fan ...........................................................................................................................
Cylindrical air circulating fan ..........................................................................................
Air circulating axial panel fan .........................................................................................
Basket.
Box.
Tube, Tube with Bell Inlet, Vented Tube.
Panel.
For this initial analysis, DOE
evaluated unhoused air circulating fan
heads, box fans, and cylindrical air
circulating fans.12 DOE expects that the
technology options evaluated in its
analysis of these fans would be
applicable to air circulating axial panel
fans, especially improved motor
efficiency. DOE expects that it will
conduct additional analysis on air
circulating axial panel fans in a
subsequent part of this rulemaking.
DOE further notes that the BESS Lab
Database did not include any housed
centrifugal air circulating fans. DOE
expects that it will conduct additional
analysis on housed centrifugal air
circulating fans in a subsequent part of
this rulemaking. In addition, the BESS
Labs Database includes very few air
circulating fans with input power less
than 125 W. DOE expects that it will
conduct additional analysis on air
circulating fans with input power less
than 125 W in a subsequent part of this
rulemaking.
To further inform its analysis, DOE
completed testing and teardowns on a
small sample of housed and unhoused
air circulating fan heads.13 For this
analysis, DOE is assuming that the
combination of housed and unhoused
air circulating fan heads listed in the
BESS Labs Database and those
additional fans that DOE tested at BESS
Labs (‘‘BESS Labs Combined Database’’)
are representative of the air circulating
fan head market. However, the air
circulating axial panel fans in the BESS
Labs database were excluded from
DOE’s analysis and housed centrifugal
air circulating fans and air circulating
fans with input power less than 125 W
11 BESS Labs is a research, product-testing and
educational laboratory. BESS Labs provides
engineering data to air in the selection and design
of agricultural buildings and assists equipment
manufactures in developing better products. Test
reports for circulating fans are publicly available at
bess.illinois.edu/current.asp.
12 The BESS Labs Database classifies circulating
fans as basket, box, panel, tube, tube with bell inlet,
vented tube, wire basket, and wire tube fans. DOE
evaluated 58 box fans (housed circulating fan
heads) and 40 tube fans (housed air circulating fan
heads) and 102 basket fans (unhoused air
circulating fan heads) in the BESS Labs Database,
accessed on June 17, 2022.
13 DOE tested seven basket fans (unhoused air
circulating fan heads) and 11 tube fans (housed air
circulating fan heads) and two box fans (housed air
circulating fans heads) at BESS Labs. Where DOE
has relied on the test data from these fans in
addition to the BESS Labs Database, DOE has used
the term ‘‘BESS Labs Combined Database’’.
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were not represented in the BESS Labs
Combined Database.
Issue 3: DOE requests comment on its
assumption that the BESS Labs
Combined Database is representative of
the air circulating fan head market, with
the exception of housed centrifugal air
circulating fans and air circulating fans
with input power less than 125 W
which are not represented in the BESS
Labs Combined Database.
Issue 4: DOE requests additional
information for all categories of air
circulating fans, including:
manufacturer name, model number, fan
diameter, blade number, blade shape,
blade material, housing type, housing
material, spacing between the blade tip
and the housing, and housing depth
with associated performance data
obtained using AMCA 230–15 with
2021 errata (or sufficient information
that can be used to correct to AMCA
230–15 with 2021 errata). DOE
additionally requests the following
information on the motors sold within
each fan model: motor type (i.e., SP,
PSC, ECM, polyphase, etc.), type of
drive (i.e., direct or belt), motor
horsepower (‘‘hp’’), motor full-load
efficiency (if available), motor rotations
per minute, number of speeds, motor
electric requirements (i.e., volts, amps,
frequency, phase, AC/DC), and whether
a variable-speed drive is included with
the fan.
The minimum and maximum
diameter housed and unhoused air
circulating fan heads in the BESS Labs
Combined Database are 12 inches and
52 inches, respectively. Although DOE
did not evaluate fans smaller or larger
than these diameters in this NODA, in
the absence of additional data, DOE may
consider extrapolating BESS Labs data
to smaller and larger diameters using
fan affinity laws to the extent such
extrapolation is representative of the
performance of such fans.
Issue 5: DOE requests comment on the
potential of using fan affinity laws to
extrapolate BESS Labs performance data
to air circulating fan heads with
diameters less than 12 inches and
greater than 52 inches. Additionally,
DOE requests model characteristics and
performance data obtained using AMCA
230–15 plus 2021 errata (or sufficient
information than can be used to correct
to AMCA 230–15 plus 2021 errata) for
air circulating fans with diameters both
smaller than and larger than those listed
in the BESS Labs Database.
2. Equipment Classes and
Representative Sizes
In the ECS RFI, DOE requested
comment on whether it should consider
air circulating fan heads, personnel
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coolers, box fans, and table fans as
separate categories (i.e., equipment
classes) or whether some or all of these
four categories should be grouped
together when evaluating potential
energy conservation standards for air
circulating fan heads. 87 FR 7048, 7051.
DOE additionally requested whether
these four fan categories have unique
features or applications that might
warrant separate consideration in the
energy standards analysis. Id. Finally,
DOE requested comment on whether it
should consider separate equipment
classes for air circulating fan heads
based on diameter, operating speed,
efficiency, or utility. Id.
The Joint Commenters stated that
portable blowers may require an
equipment class separate from air
circulating fans because they provide a
unique application (i.e., drying floors),
have centrifugal rather than axial
construction, and are relatively low in
efficiency. (Joint Commenters, No. 6 at
p. 2) In the July 2022 TP NOPR, DOE
proposed a definition for ‘‘housed
centrifugal air circulating fan’’, which it
believes is the same fan type that the
Joint Commenters describe as a portable
blower. 87 FR 44194, 44216. As
discussed in section II.D.2.a, however,
DOE has not yet finalized equipment
classes for air circulating fans. DOE is
requesting additional information and
data on the utility of different fan
categories to further inform its analysis.
AMCA commented that air circulating
fan heads, box fans, personnel coolers,
and table fans all provide directional
airflow. (AMCA, No. 9 at p. 2) ebmpapst indicated that designing an air
circulating fan for high outlet velocity
may be an impediment to achieving
greater fan efficiency. (ebm-papst, No. 8
at p. 3) DOE interprets this comment to
mean that the utility of an air circulating
fan (i.e., a fan designed for high outlet
velocity vs. more diffuse flow) may
impact its efficiency.
a. Equipment Classes
When evaluating and establishing
energy efficiency standards, DOE often
divides covered equipment into separate
classes by the type of energy used,
equipment capacity, or some other
performance-related features that justify
differing standards. In deciding whether
a performance-related feature justifies a
different standard, DOE generally
considers such factors as the utility of
the feature to the consumer and other
factors DOE determines are appropriate.
(42 U.S.C. 6295(q) and 6316(a))
DOE has not yet identified equipment
classes for air circulating fans, but is
considering the following performance-
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related features that may justify separate
equipment classes:
(1) Presence or absence of a safety
guard;
(2) Presence or absence of housing;
(3) Housing design (i.e., box, panel,
cylindrical, bladeless, thermal, etc.);
(4) Blade type (axial, centrifugal);
(5) Drive type (belt, direct);
(6) Number of discrete speed settings
(single-speed, two-speed, three-speed,
etc.);
(7) Power requirements (input power,
phase, voltage, etc.); and
(8) Air velocity or throw.
For the purposes of this NODA, DOE
grouped all air circulating fans analyzed
into a single equipment class.
Issue 6: DOE requests comment on
whether, and if so how, each of the
following performance-related features
may impact utility of air circulating
fans: presence or absence of a safety
guard, presence or absence of housing,
housing design, blade type, drive type,
number of discrete speed settings,
power requirements, and air velocity or
throw. DOE requests additional
feedback and data or information on
other air circulating fan features that
may impact utility for the end user and
might form the basis for classification.
Issue 7: DOE requests comment with
supporting data on whether the
following performance-related features
provide substantially different utility, or
are expected to have a significant
impact on efficiency because of how
they are used: (1) housed vs. unhoused
air circulating fan heads; (2) directdriven vs. belt-driven air circulating fan
heads; and (3) single-phase vs.
polyphase air circulating fan heads.
DOE also requests information on any
additional features that may impact air
circulating fan head utility.
b. Representative Sizes
The minimum and maximum
diameters reported in the BESS Labs
Database for housed and unhoused air
circulating fan heads are 12 inches and
52 inches, respectively. DOE notes that
diameter has been used to define
representative units for ceiling fans and
for previous analyses conducted on fans
and blowers that are not air circulating
fans.14 Therefore, DOE developed a
diameter histogram using the BESS Labs
Combined Database to determine
14 On November 1, 2016, DOE published a
notification of data availability (‘‘November 2016
NODA’’) that presented an analysis for fans and
blowers other than air circulating fans. 81 FR
75742. The engineering analysis evaluated
manufacturer production cost as a function of
efficiency level for 10-inch, 20-inch and 30-inch
diameter fans and blowers that are not air
circulating fans. See www.regulations.gov/
document/EERE–2013–BT–STD–0006–0189.
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representative diameters for analysis.
Based on this distribution, DOE chose
the following representative diameters
for its analysis in this NODA: 12 inches,
20 inches, 24 inches, 36 inches and 50
inches. More details on the diameter
distribution can be found in the
supplementary spreadsheet included in
the docket. (See Docket No. EERE–
2022–BT–STD–0002, No. 11)
Issue 8: DOE requests comment on
whether the diameters chosen for
representative units in this analysis (i.e.,
12 inches, 20 inches, 24 inches, 36
inches, and 50 inches) accurately
represent the diameters with the highest
sales volume available in the air
circulating fan market. DOE also
requests comment on whether diameter
is an appropriate representative metric
for air circulating fans.
For each representative diameter,
DOE used the most common motor shaft
output power value in the BESS Labs
Combined Database as the
representative motor hp. Table II–4
summarizes the motor hp associated
with each representative diameter in
DOE’s NODA analysis. More details on
the motor hp distribution can be found
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in the supplementary spreadsheet
included in the docket. (See Docket No.
EERE–2022–BT–STD–0002, No. 11)
inch representative unit. DOE’s analysis
for other representative units is
included in the supplemental
spreadsheet included in the docket. (See
TABLE II–4—REPRESENTATIVE DIAME- Docket No. EERE–2022–BT–STD–0002,
TERS AND ASSOCIATED REPRESENT- No. 11)
ATIVE MOTOR INPUT POWER USE IN 3. Efficiency Model
THIS ANALYSIS
Representative diameter
(inches)
12
20
24
36
50
The efficiency model is a key
analytical tool used to construct costefficiency curves. This model is used to
estimate efficiencies at different
efficiency levels using a design option
0.1
0.33 approach supplemented with a
0.5 performance approach.
Representative
motor input power
(hp)
....................................
....................................
....................................
....................................
....................................
0.5
1
Issue 9: DOE requests comment on
whether the motor hp it has associated
with each representative diameter (i.e.,
0.1 hp for 12 inches, 0.33 hp for 20
inches, 0.5 hp for 24 inches and 36
inches, and 1 hp for 50 inches)
appropriately represent the motor hp for
fans sold with those corresponding
diameters.
To simplify the discussion in this
NODA, the efficiency model and the
cost model are discussed using a 24-
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a. BESS Combined Database
DOE calculated FEI for all fans in the
BESS Labs Combined Database by
correcting the BESS data for air density,
consistent with AMCA 230–15 (with
2021 errata) and using the FEI equation
proposed in the July 2022 TP NOPR. 87
FR 44194, 44230, 44232. A plot of
average FEI as a function of
representative diameter and number of
representative units analyzed in the
BESS Labs Combined Database is shown
in Figure 1.
BILLING CODE 6450–01–P
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Average FEI by Representative Unit Diameters
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Number of
belt-driven
9
28
37
62
5
fans. DOE evaluated motor type, model,
and corresponding product literature for
the 20 fans in the BESS Labs Combined
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Grand
total
0
0
0
9
22
9
28
37
71
27
Database that DOE tested, in addition to
the 10 most efficient and least efficient
fans in the database. DOE found that
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Diameter
(inches)
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every fan evaluated as part of this
exercise used either a single-phase PSC
motor, a polyphase motor,15 or an ECM.
There was only one ECM fan in the
BESS Labs Combined Database. Details
of this analysis can be found in the
supplemental spreadsheet attached to
this docket. (See Docket No. EERE–
2022–BT–STD–0002, No. 11)
DOE also compared the FEI values of
fans that use single-phase and fans that
use polyphase motors in the BESS Labs
Combined Database and did not find a
significant difference between the two.
However, as discussed in a notice of
proposed rulemaking for dedicated
purpose pool pump motors published
on June 21, 2021, DOE has previously
found that polyphase motors are
generally more efficient than singlephase motors due to differences in their
construction. 87 FR 37122, 37136. For
both the efficiency and cost analyses
here, DOE opted to evaluate singlephase motor technologies only. Given
that polyphase motors are generally
more efficient than single-phase motors,
DOE believes this is a more conservative
approach. While DOE evaluated only
single-phase motor technologies, it
utilized the FEI data of both singlephase and polyphase motor fans in the
BESS Labs Combined Database when
determining FEI values. DOE did this
since this approach provided more FEI
data, and, despite the expectation that
polyphase motors are generally more
efficient than single-phase motors, there
was not a significant difference in FEI
between single-phase and polyphase
fans in the database.
Although the BESS Labs Combined
Database lists only PSC motors and one
ECM, DOE’s review of the air circulating
fan market indicated that SP motors are
also used in air circulating fans. In
general, SP motors are the least efficient,
ECMs are the most efficient, and PSC
motor efficiency falls between SP
motors and ECMs. The efficiency of
each motor type can be improved by
using higher quality steel and magnets,
or by using more magnetic material. For
this analysis, DOE assumed that the
least efficient fans on the market
(baseline) used SP motors and therefore
evaluated potential air circulating fan
efficiency improvements by replacing
an SP motor with a PSC motor (‘‘PSC
1’’), replacing a PSC 1 motor with a
more efficient PSC motor (‘‘PSC 2’’), and
replacing a PSC 2 motor with an ECM.
Issue 10: DOE requests comment on
its use of SP motors as the baseline for
air circulating fans. Additionally, DOE
seeks feedback on its choice of motor
technologies (SP motor to PSC 1 motor,
PSC 1 motor to PSC 2 motor, and PSC
2 motor to ECM) to estimate air
circulating fan efficiency increases from
one efficiency level to the next.
Additionally, DOE considered the
efficiency gains that might be obtained
from improving the aerodynamic design
of an air circulating fan. DOE’s analysis
of the BESS Labs Combined Database
did not indicate that any particular
aerodynamic features, including blade
design or housing/guard design, had a
significant impact on air circulating fan
efficiency. However, feedback received
during manufacturer interviews
indicated that blade design and
housing/guard design can impact fan
efficiency. For blade design,
manufacturers generally responded that
decreasing the number of fan blades,
optimizing the blade shape for
efficiency, and, for housed fans,
decreasing the clearance between the
blade tip and the housing can all
improve the efficiency of air circulating
fans. However, manufacturers added
that decreasing the blade tip clearance
can also increase the noise generated by
the fan. For unhoused air circulating
fans, manufacturers stated that
increasing the spacing between wire
guard wires and redesigning the motor
hub supports more efficient airflow. For
housed air circulating fans,
manufacturers discussed the potential
for improving fan efficiency by
adjusting the inlet and outlet geometries
to improve airflow.
Table II–6 summarizes the technology
options DOE analyzed for each
efficiency level.
TABLE II–6: TECHNOLOGY OPTIONS ASSOCIATED WITH EACH EFFICIENCY LEVEL
EL0 (baseline)
EL1
EL2
EL3
SP motor .........................................................
PSC 1
PSC 2
ECM
DOE discusses its analysis of baseline
efficiency and the efficiencies that it
used in its analysis for each EL in the
following sections.
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b. Baseline Fan Efficiencies
The baseline configuration represents
the lowest efficiency level commonly
available in the market. Because energy
conservation standards do not currently
exist for air circulating fans, DOE must
establish a baseline configuration using
available information, as opposed to an
existing energy conservation standard.
The baseline configuration defines the
energy consumption and associated cost
for the lowest efficiency fan analyzed in
each equipment class.
15 Single-phase motors have a single conductor
through which the alternating current input signal
is sent to the motor. Polyphase motors have
multiple conductors through which alternating
current input signals that are phase-shifted from
each other are sent to the motor.
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EL4
ECM and Aerodynamic redesign.
DOE assumed that baseline air
circulating fans use SP motors because
they are the least expensive type of air
circulating fan motor on the market. As
stated in the previous section, SP
motors are less efficient than other
electric motors available. Since DOE
does not have test data for air
circulating fans sold with a SP motor,
DOE defined EL1 as a fan in the BESS
Labs Combined Database with a PSC 1
motor. Using data from an electric
motors database compiled by the
Department (‘‘Motors Database’’), DOE
established the loss in efficiency by
replacing a PSC 1 motor (EL 1) with an
SP motor (EL 0 or baseline).
Data in the Motors Database include
information on motor topology (i.e.,
whether the motor is SP, PSC, or
another type), motor enclosure (i.e.,
whether the motor is enclosed 16 or not
or whether it is air-over 17 or not), motor
hp, and motor efficiency. DOE notes
that the motors in its Motors Database
are not currently subject to DOE
standards. Given that motor
manufacturers are not required to certify
motor performance values to DOE, it is
possible that the nominal efficiency
values presented in the catalog data are
not accurate. During its review of air
circulating fan motor literature, DOE
found that every fan for which the
motor enclosure type was divulged used
16 ‘‘Enclosed’’ motors are dust-tight, meaning that
they prevent the free exchange of air to the point
that particulates cannot enter the motor enclosure.
‘‘Open’’ motors allow the free exchange of air
through the motor enclosure via openings designed
for ventilation.
17 ‘‘Air-over’’ motors are used specifically for fans
and blowers, are placed in the pathway of the
airflow, and are cooled by the airflow.
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an air-over motor. Therefore, in this
analysis, DOE assumed that all motors
used for air circulating fans are air-over
motors, and it considered only data for
air-over SP motors and for air-over PSC
motors in the Motors Database. ECMs
were not included in the Motors
Database.
To determine the differences in
efficiency between SP motors and PSC
motors, DOE used SP motor and PSC
motor data from the motor database.
DOE calculated the average efficiencies
of SP motors and PSC motors for each
motor output value in the database, then
applied best fit curves to the average
efficiency values as a function of
horsepower. DOE used these equations
to estimate SP motor and PSC 1 motor
efficiencies and to calculate the
decrease in efficiency from PSC 1
motors to SP motors for each
representative unit horsepower. Using
this approach, the efficiency decrease
for the 24-inch diameter fan, correlating
to the 0.5 hp unit, is 8.3 percent. Further
details of how the efficiency difference
between SP motors and PSC 1 motors
was determined and applied to the fan
FEI values can be found in Section
II.D.3.c of this NODA and the
supplementary spreadsheet attached to
this docket. (See Docket No. EERE–
2022–BT–STD–0002, No. 11)
Issue 11: DOE requests comment on
its assumption that motors used in air
circulating fans are exclusively air-over
motors. If this is not the case, DOE
requests information on the other types
of motors that are sold with air
circulating fans and data on the
percentage of air circulating fans that
are sold with motors other than air-over
motors. Additionally, DOE requests
information on whether or not the type
of motor supplied with an air
circulating fan is a function of air
circulating fan category (e.g., unhoused
air circulating fan head, box fan,
cylindrical air circulating fan, etc.).
To determine FEI values at EL 1, DOE
established a separate FEI value at EL1
for fans less than 20 inches in diameter
and for fans greater than or equal to 20
inches in diameter, consistent with the
average FEI values shown in Figure 1,
where FEI increases significantly below
a diameter of 20 inches. Using the BESS
Labs Combined Database, DOE defined
EL1 as the 5th percentile of FEI values
calculated for the 12-inch representative
unit (FEI = 1.70) and the 5th percentile
of FEI values calculated for all
representative units with diameters at or
above 20 inches (FEI = 0.79). The 5th
percentile was chosen to conservatively
capture the efficiencies of the least
efficient air circulating fans in the
database, which DOE assumed also used
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the least efficient PSC 1 motors, while
excluding potential outliers with very
low FEI values. Further details of this
analysis can be found in the
supplementary spreadsheet attached to
this docket. (See Docket No. EERE–
2022–BT–STD–0002, No. 11) Since DOE
estimated SP motors to be 8.3 percent
less efficient than PSC 1 motors for the
24-inch, 0.5 hp representative unit, DOE
defined the baseline (EL 0) for this
representative unit at FEI = 0.73. FEI
values calculated for the 24-inch
representative unit are shown in Table
II–7 at the end of this section. Further
details of this analysis can be found in
the supplementary spreadsheet attached
to this docket (see Docket No. EERE–
2022–BT–STD–0002, No. 11).
Issue 12: DOE requests feedback on
whether catalog performance data on SP
motors and PSC motors is generally
representative of the performance of the
SP and PSC motors included with air
circulating fans.
Issue 13: DOE requests feedback on
the methodology used to determine the
baseline efficiency values for the
representative units, including its
method of first establishing the EL1
efficiency and then determining the
baseline efficiency by reducing the EL1
efficiency by the difference in efficiency
between a PSC motor and a SP motor.
Additionally, DOE requests data on the
expected average improvement in air
circulating fan efficiency when a SP
motor is replaced by a PSC 1 motor.
c. Improving Efficiency With More
Efficient Motors
This section describes how DOE
estimated improvements in air
circulating fan efficiency by using more
efficient motors.
When substituting a more efficient
motor for a less efficient motor, DOE
assumed that the duty point of the fan
(i.e., the fan’s airflow and pressure)
remained the same, and that the only
change in motor performance was a
decrease in input power. Factors such as
motor speed and inrush current were
assumed to remain constant with the
change in motor. This assumption
enabled DOE to assume that a percent
change in FEI is equal to a percent
change in motor efficiency using the
equations defined in ANSI/AMCA
Standard 214–21, ‘‘Test Procedure for
Calculating Fan Energy Index (FEI) for
Commercial and Industrial Fans and
Blowers.’’ This aligns with the July 2022
TP NOPR approach for calculating FEI.
87 FR 44194, 44230, 44232. A
description of how DOE derived this
relationship is provided in the
supplementary spreadsheet attached to
this docket. (See Docket No. EERE–
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2022–BT–STD–0002, No. 11)
Throughout the remainder of this
NODA, DOE will therefore discuss
efficiency increases in terms of FEI and
not in terms of motor efficiency
increases. In the future, DOE may
consider performing this analysis in
terms of motor losses and shaft power,
consistent with other rulemakings. See
the ceiling fans preliminary analysis
published February 9, 2022 (‘‘Ceiling
Fan Preliminary Analysis’’). 87 FR 7758.
See also the electric motors preliminary
analysis published March 2, 2022
(‘‘Electric Motors Preliminary
Analysis’’). 87 FR 11650.
Issue 14: DOE requests feedback on its
assumption that airflow, pressure, and
motor performance (for example, speed
and inrush current) remain constant
when replacing a less efficient motor
with a more efficient motor in an air
circulating fan. If airflow, pressure, or
motor performance are not maintained
when using a more efficient motor, DOE
requests feedback and data on how it
should conduct this analysis.
To determine the PSC 2 motor
efficiencies, DOE again used PSC motor
data from the motor database. Rather
than fitting a curve to the average PSC
motor efficiency values at each motor
output power value, as it did for the
PSC 1 motor curve, DOE instead fit a
curve to the 95th percentile PSC motor
efficiency values. The 95th percentile
was chosen so that the efficiency values
for PSC 2 motors were close to the
maximum possible PSC motor
efficiencies. DOE then used this curve to
estimate PSC 2 motor efficiencies for the
representative unit motor output power
values.
For the representative units in this
NODA that used 0.5 hp motors,
replacing a 0.5 hp PSC 1 motor with a
0.5 hp PSC 2 motor increases the air
circulating fan FEI by 11.2 percent. The
resulting FEI for the 24-inch, 0.5 hp
representative unit with a PSC 2 motor
is therefore 0.88. (See Table II–7 at the
end of this section) The supplementary
spreadsheet attached to this docket
provides more details on how efficiency
increases from PSC 1 motors to PSC 2
motors were determined. (See Docket
No. EERE–2022–BT–STD–0002, No. 11)
Issue 15: DOE requests feedback on
whether the efficiency gains shown in
the supplementary spreadsheet are
realistic efficiency gains when replacing
a lower efficiency PSC motor (i.e., PSC
1 motor) with a higher efficiency PSC
motor (i.e., PSC 2 motor). If these
assumptions are not realistic, DOE
requests data demonstrating air
circulating fan motor efficiency as a
function of hp, as well as data for motor
hp as a function of fan diameter.
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To evaluate the efficiency increase
when changing to an ECM, DOE used a
2018 pool pump motor database
containing information on ECMs that
was compiled by DOE in support of its
dedicated purpose pool pump
rulemaking (‘‘DPPP Motor Database’’).
Most motors in the DPPP Motor
Database were 1 hp and higher;
therefore, DOE fit a curve to the ECM
data at each motor hp and used this
curve to extrapolate the data and
estimate motor efficiencies at fractional
hp for ECMs. The resulting ECM
efficiency for the 24-inch, 0.5 hp
representative unit is 83.2 percent, an
efficiency increase of 23.9 percent from
a PSC 1 motor to an ECM and a FEI of
0.98 at EL 3 (see Table II–7 at the end
of this section). Further details of this
analysis can be found in the
supplementary spreadsheet attached to
this docket. (See Docket No. EERE–
2022–BT–STD–0002, No. 11)
Issue 16: DOE requests feedback on its
use of dedicated purpose pool pump
motors as a source for comparing PSC
motor and ECM efficiency.
Additionally, DOE requests information
on whether motors used for this purpose
are comparable to air circulating fan
motors. DOE further requests feedback
on whether the efficiency increases from
PSC 1 motors to ECM that DOE presents
are realistic. If dedicated purpose pool
pump motors are not representative of
air circulating fans motors, or DOE’s
estimated efficiency increases are not
realistic, DOE requests data on the
difference between PSC 1 motor
efficiency and ECM efficiency and the
difference between PSC 2 motor
efficiency and ECM efficiency for air
circulating fans. DOE also requests
comment on its use of extrapolation of
these data to obtain efficiency values at
fractional hp.
d. Improving Efficiency Through
Aerodynamic Redesign
This section describes how DOE
evaluated increasing the energy
efficiency of air circulating fans by
improving fan component aerodynamic
design.
While EL3 assumes that air
circulating fan efficiency is increased
through the use of an ECM, EL4
evaluates the efficiency impact from
adding an ECM and improving the
aerodynamic design of the fan. This
‘‘max-tech’’ level represents the highest
efficiency available on the market. The
fans in the BESS Labs Combined
Database used almost exclusively PSC
motors, so DOE assumed that the
maximum efficiencies in the database
corresponded to the use of a PSC 2
motor with a highly efficient
aerodynamic design. Presumably, the
maximum efficiencies achieved by a fan
with a PSC motor and no aerodynamic
redesign would be captured by the FEI
values determined for EL 2 for each
representative unit. The efficiency gain
due to improvements in aerodynamic
design can therefore be quantified by
determining the difference between the
maximum FEI values in the database
and the efficiency levels determined for
EL 2. DOE used the maximum FEI
values in the BESS Labs Combined
Database for each representative unit to
develop a curve for the PSC 2 plus
aerodynamic redesign FEI values as a
function of diameter. The resulting FEI
value for the 24-inch, 0.5 hp
representative unit is 1.89. DOE then
determined the percent increase from
the EL 2 FEI values to the FEI values
determined from the curve fit to
establish the increase in efficiency due
to aerodynamic redesign for each
representative unit. This percent
increase for the 24-inch, 0.5 hp
representative unit was 114.39 percent.
DOE then applied the percent increases
in FEI due to aerodynamic redesign to
the EL 3 FEI values to determine the EL
4 FEI values. The resulting EL 4 FEI
value for the 24-inch, 0.5 hp
representative unit was 2.10. Further
details of this analysis can be found in
the supplementary spreadsheet attached
to this docket. (See Docket No. EERE–
2022–BT–STD–0002, No. 11)
Issue 17: DOE requests feedback on
the FEI values that it determined and its
approach for estimating FEI values for
an air circulating fan that includes both
an ECM and improved aerodynamic
design.
e. Results for a 24-inch, 0.5 hp
Representative Unit
FEI values calculated for each
efficiency level for the 24-inch, 0.5 hp
representative unit are shown in Table
II–7 . Information on the FEI values
calculated for other representative units
can be found in the supplementary
spreadsheet attached to this docket. (See
Docket No. EERE–2022–BT–STD–0002,
No. 11)
TABLE II–7—FEI VALUES FOR 24-INCH, 0.5 hp REPRESENTATIVE UNIT
EL0 (baseline)
EL1
EL2
EL3
EL4
0.73 .....................................
0.79
0.88
0.98
2.10
khammond on DSKJM1Z7X2PROD with PROPOSALS
4. Cost Model
The cost model is a key analytical tool
used to construct cost-efficiency curves.
This model is used to estimate
manufacturing production costs at
various efficiency levels using a design
option approach.
a. Cost Model Structure and Process
This section describes the process by
which the cost model converts the
physical information in each product’s
BOM into manufacturing cost estimates.
The cost model is based on production
activities and divides factory costs into
materials, labor, depreciation, and
overhead. The material costs include
both raw materials and purchased part
costs. The labor costs include
fabrication, assembly, and indirect and
overhead (burdened) labor rates. The
depreciation costs include
manufacturing equipment depreciation,
tooling depreciation, and building
depreciation. The overhead costs
include indirect process costs, utilities,
equipment and building maintenance,
and rework. DOE lists the cost inputs of
these categories in Table II–8.
TABLE II–8—COST MODEL CATEGORIES AND DESCRIPTIONS
Major category
Subcategory
Description
Material Costs .............................................................
Direct .............................................
Raw materials (e.g., coils of sheet metal) and purchased parts (e.g., fan motors, compressors).
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62051
TABLE II–8—COST MODEL CATEGORIES AND DESCRIPTIONS—Continued
Major category
Manufacturing Labor ...................................................
Subcategory
Description
Indirect ...........................................
Material used during manufacturing (e.g., welding
rods, die oil, release media).
Part/unit assembly on manufacturing line.
Conversion of raw material into parts ready for assembly.
Fraction of overall labor not associated directly with
product manufacturing (e.g., forklift drivers, quality
control).
Fraction of indirect labor that is paid a higher wage.
Straight line depreciation over expected life.
Cost is allocated on a per-use basis or obsolescence, whichever is shorter.
A fixed fraction of all material costs meant to cover
electricity and other utility costs.
Based on installed equipment and tooling investment.
A fixed fraction based on total unit costs.
Assembly .......................................
Fabrication .....................................
Indirect ...........................................
Depreciation ................................................................
Supervisory ....................................
Equipment, Conveyor, Building .....
Tooling ...........................................
Other Overhead ..........................................................
Utilities ...........................................
Maintenance ..................................
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Property Tax and Insurance ..........
To determine material costs, DOE
followed one of two different paths,
depending on whether a subassembly
was purchased (outsourced) or
produced in-house. For purchased parts,
DOE gathered price quotations from
major suppliers at different production
volumes. For parts produced in-house,
DOE reconstructed manufacturing
processes for each part using modeling
software based on internal expertise. For
the raw materials being converted to
ready-to-assemble parts, DOE estimated
manufacturing process parameters
(manufacturing equipment use and time
for each item, the required initial
material quantity, scrap, etc.) to
determine the value of each component.
Using this process, DOE was able to
assign manufacturing labor time,
equipment utilization, and other
important factors to each subassembly
for each unit considered in this analysis.
The last step was to convert the
information into dollar values. To
perform this task, DOE collected
information on such factors as labor
rates, tooling depreciation, and costs of
purchased raw materials. DOE assumed
values for these parameters using
internal expertise and confidential
information available to its contractors.
In sum, DOE assigned costs of labor,
materials, and overhead to each part,
whether purchased or produced inhouse. DOE then aggregated single-part
costs into major assemblies (e.g., for air
circulating fans this would include
packaging, housing, impeller, controls
and wiring, motor, guard, and mounting
gear) and summarized these costs in a
spreadsheet. All parameters related to
manufacture and assembly were then
aggregated to determine facility
requirements at various manufacturing
scales. The final cost obtained by the
cost model is the manufacturer
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production cost (‘‘MPC’’), representing
the total cost to the manufacturer of
producing the component.
b. Cost Model Assumptions
Assumptions about manufacturer
practices and cost structure play an
important role in estimating the MPC of
the products. DOE based assumptions
about the sourcing of parts and in-house
fabrication on industry experience,
information in trade publications, and
discussions with manufacturers. DOE
used assumptions regarding the
manufacturing process parameters, (e.g.,
equipment use, labor rates, tooling
depreciation, and cost of purchased raw
materials) to determine the value of
each component. The following sections
describe the cost model assumptions
related to material prices, purchased
parts and factory parameters.
Raw Material Prices
For parts fabricated in-house, the
prices of the underlying ‘‘raw’’ metals
(e.g., tube, sheet metal) are estimated on
the basis of 5-year averages to smooth
out spikes in demand. Other ‘‘raw’’
materials such as plastic resins,
insulation materials, etc. are estimated
on a current-market basis. The costs of
raw materials are based on manufacturer
interviews, quotes from suppliers, and
secondary research. Past results are
updated periodically and/or inflated to
present-day prices using indices from
resources such as MEPS International,18
PolymerUpdate,19 the U.S. geologic
18 More
information on MEPS International may
be found at: www.meps.co.uk/.
19 More information on PolymerUpdate may be
found at: www.polymerupdate.com.
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survey (‘‘USGS’’),20 and the Bureau of
Labor Statistics (‘‘BLS’’).21
Fabricated Parts and Purchased Parts
DOE characterized parts based on
whether manufacturers fabricated them
in-house or purchased them from
outside suppliers. For fabricated parts,
DOE estimated the price of intermediate
materials (e.g., tube, sheet metal) and
the cost of forming them into finished
parts. DOE estimated initial raw
material dimensions to account for
scrap. For scrap materials that are
recyclable, DOE assigned a scrap credit
that is a fraction of the base material
cost. Non-recyclable materials incur a
disposal cost for all scrap. For
purchased parts, DOE estimated the
purchase price for original equipment
manufacturers based on its confidential
parts database and industry expertise.
For the purpose of this analysis, DOE
assumed that all components of the fan
were purchased from outside suppliers.
This assumption was made because of
the relatively low volume of
manufacturing for air circulating fans
compared to other products, which
increases the likelihood that parts are
purchased rather than manufactured inhouse.
As previously stated, variability in the
costs of purchased parts can account for
large changes in the overall MPC values
calculated. Purchased part costs can
vary significantly based on the
quantities desired and the component
suppliers chosen. The purchased part
prices used in this study were typical
values based on estimated production
volume and other factors. However,
20 More information on the USGS metal price
statistics may be found at: www.usgs.gov/centers/
nmic/commondity-statistics-and-information.
21 More information on the BLS producer price
indices may be found at: www.bls.gov/ppi/.
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variability in these prices may exist on
a case-by-case basis.
Due to the great diversity of
manufacturing scale in the fans
industry, DOE estimates that the
purchased parts costs could vary
significantly by manufacturer. Some
parts like motors, and impellers may be
produced in-house by some
manufacturers and purchased by others,
changing likely overall system costs and
investment requirements.
Factory Parameters
Certain factory parameters, such as
fabrication rates, labor rates, and wages,
also affect the cost of each unit
produced. DOE factory parameter
assumptions were based on internal
expertise and may be updated based on
manufacturer feedback. Table II–9 lists
the factory parameter assumptions used
in the cost models. These assumptions
are generalized to represent typical
production and are not intended to
model a specific factory.
TABLE II–9—FACTORY PARAMETER ASSUMPTIONS FOR AIR CIRCULATING FANS
Parameter
Estimate
Actual Annual Production Volume .......................................................................................................................................................
Work Days Per Year (days) ................................................................................................................................................................
Fabrication Shifts Per Day (shifts) .......................................................................................................................................................
Assembly Shifts Per Day (shifts) .........................................................................................................................................................
Fabrication Labor Wages ($/hr) ...........................................................................................................................................................
Assembly Labor Wages ($/hr) .............................................................................................................................................................
Burdened Fabrication Labor Wage ($/hr) ............................................................................................................................................
Burdened Assembly Labor Wage ($/hr) ..............................................................................................................................................
Fabrication Worker Hours Per Year ....................................................................................................................................................
Assembly Worker Hours Per Year ......................................................................................................................................................
Supervisor Span (workers/supervisor) ................................................................................................................................................
Supervisor Wage Premium (over fabrication and assembly wage) ....................................................................................................
Fringe Benefits Ratio ...........................................................................................................................................................................
Indirect to Direct Labor Ratio ..............................................................................................................................................................
Length of Shift (hr) ...............................................................................................................................................................................
Worker Downtime ................................................................................................................................................................................
Actual units per day .............................................................................................................................................................................
Average Equipment Installation Cost (% of purchase price) ..............................................................................................................
Average Scrap Credit (relative to base material cost) ........................................................................................................................
Non-recyclable Trash Cost ($/lb) .........................................................................................................................................................
Issue 18: DOE requests comment on
its factory parameter assumptions for
typical air circulating fan production.
c. Determination of Air Circulating Fan
MPC
DOE conducted teardowns on four
housed and five unhoused air
circulating fan heads ranging in
diameter from 18 inches to 30 inches
and created a BOM for each fan. For this
NODA, DOE used the BOM for what
DOE considered to be a representative
baseline 24-inch unhoused fan without
a motor and one representative baseline
24-inch housed fan without a motor.
The baseline unhoused air circulating
fan material and production costs were
scaled to each of the unhoused
representative diameters (i.e., 12, 20, 36,
and 50 inches) by the ratio of the
representative diameters to 24 inches.
For housed air circulating fans, DOE
determined material and production
costs for the 24-inch housed fan, then
used the ratio between the 24-inch
25,000
250
1
1
16
16
24
24
250
250
25
30%
50%
33%
8
10%
100
10%
30%
$0
housed and unhoused costs to estimate
housed fan costs at each representative
diameter. DOE’s cost data for diameters
other than 24 inches is included in the
supplement spreadsheet included in the
docket. (See Docket No. EERE–2022–
BT–STD–0002, No. 11) Table II–10
summarizes the characteristics assumed
for 24-inch housed and unhoused
baseline fans. DOE assumed that these
fans were manufactured in China, and
that material and parts were also
sourced from China.
TABLE II–10—MATERIAL AND PRODUCTION CHARACTERISTICS FOR BASELINE 24-INCH HOUSED AND UNHOUSED AIR
CIRCULATING FAN
Unhoused
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Blade Type ......................................
Blade Shape ....................................
Blade Material .................................
Hub Material ....................................
Type of Housing ..............................
Housing Material .............................
Propeller ....................................................................
Rectangular ...............................................................
Galvanized Cold Rolled Steel (‘‘CRS’’) .....................
Aluminum CRS ..........................................................
Basket ........................................................................
CRS-Wire ...................................................................
Issue 19: DOE requests comment on
whether or not its baseline material
assumptions are representative of
baseline fans distributed into commerce.
If DOE’s baseline material assumptions
are not representative, DOE requests
information and data on materials
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Housed
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Propeller.
Rectangular.
Galvanized CRS.
Aluminum CRS.
Tube.
CRS-Wire and polypropylene.
typically used in the air circulating fans
currently on the market.
Housed and unhoused baseline 24inch air circulating fan cost estimates
are summarized in Table II–11.
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TABLE II–11—ESTIMATED MPCS FOR
AIR CIRCULATING FANS WITH NO
MOTORS
Fan cost
(no motor)
24-inch Unhoused ................
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used in the representative units
TABLE II–11—ESTIMATED MPCS FOR baseline fans with fractional motor hp
AIR CIRCULATING FANS WITH NO would be equipped with a SP motor. For evaluated for this analysis, DOE
each efficiency level analyzed (i.e., EL1, determined the equation of the best fit
MOTORS—Continued
Fan cost
(no motor)
24-inch Housed ....................
69.89
Issue 20: DOE requests comment on
its estimated base MPC for air
circulating fans with no motors at each
of the representative diameters
evaluated. (See supplemental
spreadsheet included in Docket No.
EERE–2022–BT–STD–0002, No. 11)
As discussed previously, DOE used a
design option approach to structure its
engineering analysis. DOE assumed that
EL2, and EL 3), DOE assumed that a
more efficient motor is substituted into
the same fan. At EL 4, DOE assumed the
most efficient motor was paired with
improved aerodynamic design of the
fan.
To estimate manufacturer costs for SP
motors, PSC motors, and ECMs, DOE
used motor costs from its internal parts
database and assumed a motor to fan
manufacturer markup of 1.37.22 DOE
did not have specific cost data for SP
motors, and therefore used costs for
shaded-pole motors as a proxy for SP
motor costs. See 2009 CR Report. To
estimate motor costs for the motor hp
line for hp as a function of motor cost
and calculated motor cost at 0.1, 0.33,
0.5, and 1 hp for SP motors, PSC motors
and ECMs.
DOE’s parts database does not
differentiate between motor efficiency.
DOE therefore estimated PSC 1 motor
cost using a best fit line for cost as a
function of hp. For PSC 2 motor costs,
DOE determined a best fit line identified
the 95th cost percentile for each
representative unit/motor hp, and then
determined the best fit line through
these points. Table II–12 summarizes
estimated motor costs for the 24-inch air
circulating fan at each EL evaluated.
TABLE II–12—ESTIMATED MOTOR COSTS AT EACH EL FOR 24-INCH DIAMETER AIR CIRCULATING FANS
Motor hp
EL0
EL1
EL2
EL3
0.5 .......................................
$26.05
$64.32
$79.78
$114.45
Issue 21: DOE requests comment on
whether replacing a given fan motor
with a more efficient fan motor will
result in similar efficiency and cost
impacts for housed and unhoused air
circulating fan heads.
Issue 22: DOE requests comment on
its estimated motor costs SP motors
(EL0), PSC motors (EL1), higher
efficiency PSC motors (EL2), and ESMs
(EL3) at each hp associated with the
representative diameters evaluated. (See
supplemental spreadsheet included in
Docket No. EERE–2022–BT–STD–0002,
No. 11)
Table II–13 summarizes the total
estimated cost of the fan assembly,
including the motor, for 24-inch
unhoused and housed fans.
TABLE II–13—TOTAL AIR CIRCULATING FAN COST FOR A 24-INCH HOUSED AND UNHOUSED FAN AT EL0, EL1, EL2, AND
EL3
Type
Motor hp
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Unhoused .............................................................................
Housed .................................................................................
EL 0
0.5
0.5
$52.12
95.94
EL 1
EL 2
$90.38
134.21
$105.84
149.67
EL 3
$140.51
184.34
Issue 23: DOE requests comment on
its estimated housed and unhoused air
circulating fan costs at each EL and for
each representative unit. (See
supplemental spreadsheet included in
Docket No. EERE–2022–BT–STD–0002,
No. 11)
As mentioned previously, DOE is
assuming that a max-tech air circulating
fan (i.e., EL4) would undergo
aerodynamic redesign and contain an
ECM. Aerodynamic redesign includes
modifications to a fan’s housing, blade/
impeller, and/or guard that would
include fan model redesign, reengineering, and upgraded/new tooling
equipment. These modifications result
in a one-time cost that is not captured
by MPC but may be represented by
capital conversion costs. DOE used the
conversion costs for axial cylindrical
housed fans, presented in the November
2016 NODA,23 as a proxy for estimating
air circulating fan conversion costs.
After adjusting for inflation, DOE
estimates an air circulating fan redesign
cost of $720,300 per fan. Additional
information on DOE’s assumptions and
analysis may be found in the
supplemental spreadsheet associated
with this docket (see Docket No. EERE–
2022–BT–STD–0002, No. 11).
22 A markup of 1.37 for motors at or below 5 hp
was used in the Electric Motors Preliminary
Analysis Technical Support Document (TSD) (see
section 5.4.8.4, Docket No. EERE–2020–BT–STD–
0007–0010 at regulations.gov).
23 See EERE–2013–BT–STD–0006–0189 at
regulations.gov.
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Issue 24: DOE requests comment on
and additional data to support its
estimated air circulating fan conversion
costs to undergo aerodynamic redesign.
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5. Manufacturer Selling Price
The manufacturer selling price
(‘‘MSP’’) is the price of the equipment
when it is sold by the manufacturer to
the first party in the distribution chain.
It includes all direct and indirect
production costs, other costs such as
research and development, and the
manufacturer’s profit.
When developing cost-efficiency
curves during its engineering analysis,
DOE typically uses MSP as a function of
efficiency. For simplicity, DOE is
presenting the results of its cost model
for this NODA in terms of MPC.
The MSP is expressed as the product
of the MPC and the manufacturer
markup. Based on information obtained
during interviews with manufacturers,
DOE is assuming that the average
manufacturer markup for a baseline fan
is 1.5.50 percent, meaning the MSP is
During interviews, manufacturers stated
that they expected to be able to maintain
their profit margin if DOE were to set
energy efficiency standards for air
circulating fans; therefore, DOE is
assuming that the average MSP in a
market with standards would also be
1.5.
Issue 25: DOE requests comment on
whether or not an average MSP of 1.5
is representative for the air circulating
fan market. If an average MSP of 1.5 is
not representative, DOE requests
information of what a more
representative MSP would be.
Additionally, DOE requests comment on
whether or not MSP for air circulating
fans will remain constant in the case of
new energy conservation standards. If
not, DOE seeks information on the
magnitude by which MSP might change
under potential energy efficiency
standards.
E. Markups Analysis
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The markups analysis develops
appropriate markups (e.g., retailer
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markups, distributor markups,
contractor markups) in the distribution
chain and sales taxes to convert MSP
estimates derived in the engineering
analysis to consumer prices, which are
then used in the LCC and PBP analysis.
At each step in the distribution channel,
companies mark up the price of the
product to cover business costs and
profit margin.
DOE developed baseline and
incremental markups for each actor in
the distribution chain. Baseline
markups are applied to the price of
products with baseline efficiency, while
incremental markups are applied to the
difference in price between baseline and
higher efficiency models (the
incremental cost increase). The
incremental markup is typically less
than the baseline markup and is
designed to maintain similar per-unit
operating profit before and after new or
amended standards.24
In the ECS RFI, DOE requested
information to help characterize
distribution channels for air circulating
fans. DOE also requested data on the
fraction of sales that go through these
channels. 87 FR 7048, 7054. DOE did
not receive any input on this topic.
DOE identified two distribution
channels for air circulating fans,
depending on the input power of the fan
at maximum speed. Air circulating fans
with input power less than 125 Watts
(W) are primarily used in residential
applications.25 Data from the
24 Because the projected price of standardscompliant products is typically higher than the
price of baseline products, using the same markup
for the incremental cost and the baseline cost would
result in higher per-unit operating profit. While
such an outcome is possible, DOE maintains that in
markets that are reasonably competitive it is
unlikely that standards would lead to a sustainable
increase in profitability in the long run.
25 DOE notes that distribution for residential use
does not preclude coverage as covered equipment,
so long as the equipment is of a type that is also
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Association of Home Appliance
Manufacturers (‘‘AHAM’’) indicate that
an majority of residential appliances are
sold through retail outlets.26 Because
DOE is not aware of any other
distribution channel that plays a
significant role for air circulating fans
with input power less than 125 W, DOE
estimates that such air circulating fans
are purchased by consumers from retail
outlets (including online retailers).
For air circulating fans with input
power greater than or equal to 125 W,
DOE estimates that the primary
distribution channel is that the
manufacturer sells the equipment to a
distributor, who in turn sells it to the
customer. DOE is also aware of another
direct sale channel for air circulating
fans greater than or equal to 125 W
where the manufacturer sells the
equipment directly to a customer
through their in-house distributor. In
addition, DOE considered additional
channels that included a contractor
based on input from manufacturer
interviews. Further, DOE estimated the
fraction of shipments of air circulating
fans with input power greater than or
equal to 125 W going through each
channel based on feedback from
manufacturer interviews. Information
from the manufacturer interviews also
indicated that some fraction of
shipments (10–15 percent) are sold to
consumers via an original equipment
manufacturer (‘‘OEM’’) and a
distributor. However, DOE is not aware
of any OEM equipment that would
incorporate an air circulating fan and
therefore did not consider this channel.
distributed in commerce for industrial and
commercial use.
26 Association of Home Appliance Manufacturers.
Fact Book 2009. 2009. AHAM: Washington, DC.
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Table II–14 summarizes the air
circulating fan distribution channels
identified by DOE.
TABLE II–14—DISTRIBUTION CHANNELS FOR AIR CIRCULATING FANS
Air circulating fan input power at maximum speed (W)
Less than 125 W ..........................................................
Greater than or equal to 125 W ...................................
To estimate average baseline and
incremental markups for each actor in
the distribution channels, DOE relied on
data from the 2017 Annual Retail Trade
Fraction of
shipments (%)
Distribution channel
Manufacturer
Manufacturer
Manufacturer
Manufacturer
Manufacturer
→
→
→
→
→
Retailer → Consumer ....................................................
Distributor → Consumer ................................................
Distributor → Contractor → Consumer .........................
In-house Distributor → Consumer ................................
In-house Distributor → Contractor → Consumer ..........
Survey,27 the 2017 Annual Wholesale
Trade Survey,28 and RS Means.29 In
addition to the markups, DOE obtained
state and local taxes from data provided
100
40
20
30
10
by the Sales Tax Clearinghouse.30 Table
II–15 and Table II–16 and show the
resulting baseline markups, incremental
markups, and sales tax.
TABLE II–15—DISTRIBUTION CHANNEL MARKUPS FOR AIR CIRCULATING FANS WITH INPUT POWER LESS THAN 125 W
Manufacturer → retailer →
consumer
(100% shipments)
Distribution channel
Baseline
Retailer .....................................................................................................................................................................
Sales Tax .................................................................................................................................................................
Overall Markup ........................................................................................................................................................
Incremental
1.486
1.073
1.594
1.238
1.073
1.328
TABLE II–16—DISTRIBUTION CHANNEL MARKUPS FOR AIR CIRCULATING FANS WITH INPUT POWER GREATER THAN OR
EQUAL TO 125 W
Manufacturer → distributor →
consumer
(40% shipments)
(In-house) Distributor ........
Contractor ..........................
Sales Tax ..........................
Overall Markup ..................
Manufacturer → distributor →
contractor → consumer
(20% shipments)
Base.*
Inc.*
Base.
1.412
........................
1.073
1.516
1.194
........................
1.073
1.281
1.412
1.100
1.073
1.667
Manufacturer → in-house distributor → consumer
(30% shipments)
Inc.
1.194
1.100
1.073
1.409
Base.
Inc.
1.412
........................
1.073
1.516
1.194
........................
1.073
1.281
Manufacturer → in-house distributor → contractor → consumer (10% shipments)
Base.
1.412
1.100
1.073
1.667
Inc.
1.194
1.100
1.073
1.409
* Base. = baseline, Inc. = Incremental.
Issue 26: DOE requests feedback and
information on the distribution
channels identified for air circulating
fans, and on any other distribution
channel that DOE should consider. DOE
also requests data on the fraction of
sales that go through these channels.
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F. Energy Use Analysis
The purpose of the energy use
analysis is to determine the annual
energy consumption of air circulating
fans at different efficiencies for a
representative sample of consumers,
and to assess the energy savings
potential of increased air circulating fan
efficiency. The energy use analysis
estimates the range of energy use of air
27 Available at www.census.gov/data/tables/2017/
econ/arts/annual-report.html; NAICS 443—
Electronics and Appliance Stores.
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circulating fans in the field (i.e., as they
are actually used by consumers). The
energy use analysis provides the basis
for other analyses DOE performs,
particularly assessments of the energy
savings and the savings in consumer
operating costs that could result from
adoption of amended or new standards.
In any future analysis, DOE may
consider calculating the energy use by
combining air circulating fan input
power consumption in each mode (e.g.,
high speed, medium speed, low speed)
from the engineering analysis with
operating hours spent in each mode. To
characterize variability and uncertainty,
the energy use is calculated for a
representative sample of air circulating
fan consumers. This method of analysis,
referred to as a Monte Carlo method, is
explained in more detail in section II.G
of this document. Results of the energy
use analysis for each representative air
circulating fan will be derived from a
sample of 10,000 consumers. DOE then
plans on using the range of energy use
results in the LCC and PBP analyses and
the average of the energy use results in
the National Impact Analysis (‘‘NIA’’)
analysis. This section presents DOE’s
approach to develop consumer samples
and the operating hour inputs that DOE
is considering using in any future
energy use analysis. For each consumer
in the sample, DOE will associate a
value of air circulating fan operating
28 Available at: www.census.gov/programssurveys/awts.html; NAICS 4238—Machinery,
equipment, and supplies merchant wholesalers.
29 RS Means Electrical Cost Data 2021. Available
at: www.rsmeans.com.
30 Sales Tax Clearinghouse Inc., State Sales Tax
Rates Along with Combined Average City and
County Rates (2022), available at https://thestc.com/
STrates.stm (last accessed June 6, 2022).
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hours drawn from a statistical
distribution as described in the
remainder of this section.
b. Operating Hours
1. Fans With Input Power Less Than 125
W
a. Sample of Consumers
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DOE is considering including only
residential applications in the energy
use analysis of air circulating fans with
input power below 125 W. Although
some of these air circulating fans are
used in commercial or industrial
settings, DOE believes that they
represent a very small portion of the
total market for such air circulating fans.
To develop a representative sample of
consumers, DOE is considering using
the Energy Information Administration
(‘‘EIA’’) 2020 Residential Energy
Consumption Survey (‘‘RECS’’) 31 to
choose a random sample of households
in which new air circulating fans could
be installed. RECS is a national survey
of housing units that collects statistical
information on the consumption of, and
expenditures for, energy in housing
units, along with data on energy-related
characteristics of the housing units and
occupants. RECS collects data on
thousands of housing units, and was
constructed by EIA to be a national
representation of the household
population in the United States.
Although RECS contains information on
operation for many appliances, it
contains no information on the
operation of air circulating fans within
each household. RECS reports only the
number of floor or window fans in the
household which is the category of
appliance closest to air circulating fans.
In creating the sample of RECS
households, DOE is planning on using
the subset of RECS records that met the
criterion that the household had at least
one ‘‘floor or window fan’’. DOE is
planning on choosing a sample of
10,000 households from RECS to
estimate annual energy use for air
circulating fans with input power less
than 125 W. Because RECS provides no
means of determining the subset of air
circulating fans in a given household,
DOE will use the same sample for all
equipment classes.
31 Department of Energy, Energy Information
Administration. 2020 Residential Energy
Consumption Survey (RECS). 2020. (Last accessed
July 6, 2022) www.eia.gov/consumption/residential/
data/2020/.
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In the ECS RFI, DOE requested
information to characterize the annual
operating hours of air circulating fans
and time spent in each operating mode,
if applicable, by sector of application,
and geographical region. 87 FR 7048,
7054. In response, ebm-papst
commented that the use of agricultural
fans, residential fans, commercial fans,
and basket fans used for distribution
transformers are all very different (ebmpapst, No. 8 at p. 4). ebm-papst did not
provide additional information to
characterize operating conditions. DOE
did not receive other comments on this
topic.
DOE reviewed existing studies on air
circulating fans used in residential
applications and found that these are
often studied in combination with
ceiling fans, indicating that they likely
operate similarly.32 In the absence of
existing data indicating the daily hours
of operation specific to air circulating
fans with input power less than 125 W,
DOE used the same annual operating
hours as developed for standard, hugger,
and very small diameter ceiling fans in
the Ceiling Fans Preliminary Analysis to
characterize the operating hours of air
circulating fans with input power less
than 125 W.33 The ceiling fan
preliminary analysis relied on a
distribution of operating hours, with an
average of 6.45 hours of operation per
day with 33 percent at high speed, 38
percent at medium speed, and 29
percent at low speed. DOE assumes this
is also representative of air circulating
fan usage with input power less than
125W and plans on applying this load
profile in any future energy use
calculation. DOE notes that some air
circulating fans may not have three
available speeds, in which case DOE
plans on adjusting the time spent in
each mode according to the fan’s speed
capability (e.g., assuming 100 percent of
operation at the one available speed for
single-speed air circulating fans).
32 Ecodesign Lot 10 Comfort Fans Study,
Preparatory Study on Environmental Performance
of Residential Room Conditioning Appliances (airco
and ventilation) Study on comfort fans—final report
October 2008, after SH comments www.eceee.org/
static/media/uploads/site-2/ecodesign/products/
airco-ventilation/finalreport-cf.zip.
33 See Section 7.3.2. of Chapter 7 of the ceiling
fan preliminary analysis Technical Support
Document, www.regulations.gov/document/EERE2021-BT-STD-0011-0015.
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2. Fans With Input Power Greater Than
or Equal to 125 W
a. Sample of Consumers
DOE is considering including only
commercial, industrial, and agricultural
applications in the energy use analysis
of air circulating fans with input power
greater than or equal to 125 W.
Although some air circulating fans with
input power greater than or equal to 125
W are used in residential applications,
DOE believes that they represent a very
small portion of the total market for
such fans. DOE plans on creating a
sample of 10,000 consumers for each
equipment class to represent the range
of air circulating fan energy use in the
commercial, industrial, and agricultural
sectors.
b. Operating Hours
As noted previously, DOE did not
receive any information related to the
operating hours of air circulating fans.
In the absence of data indicating the
daily hours of operation specific to air
circulating fans, DOE estimated that air
circulating fans with input power
greater than or equal to 125 W operate,
on average, 12 hours per day, consistent
with the hours of use estimated for
large-diameter ceiling fans in the Ceiling
Fan Preliminary Analysis.34 To
represent a range of possible operating
hours around this representative value,
DOE will be drawing 10,000 samples
from a uniform distribution between 6
hours per day and 18 hours per day
(assuming a uniform distribution of
operating hours due to the limited
availability of information).
In the July 2022 TP NOPR, the
efficiency metric is calculated assuming
that the performance at each of the five
tested speeds is weighted equally, as
there are not available data to suggest a
different distribution of time spent at
each speed. 87 FR 44194, 44238. For
this NODA, DOE assumed an equal
amount of time would be spent at each
speed, in alignment with the approach
in the July 2022 TP NOPR.
Table II–17 summarizes the inputs to
the energy use calculation identified by
DOE. For each consumer in the samples,
DOE will associate a value of air
circulating fan operating hours drawn
from a statistical distribution as
described in Table II–17.
34 See Section 7.4.2 of Chapter 7 of the Ceiling
Fan Preliminary Analysis Technical Support
Document, www.regulations.gov/document/EERE2021-BT-STD-0011-0015.
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62057
TABLE II–17—INPUTS TO THE ENERGY USE CALCULATION
Input to the energy use calculation
Air circulating fan with input power
at maximum speed less than
125 W
Air circulating fan with input power at maximum
speed greater than or equal to 125 W
Average Operating Hours per Day .............................
Statistical Distribution ..................................................
6.45 hours per day ........................
Based on Consumer Survey .........
Fraction of time spent in each mode ..........................
33% on high speed, 38% on medium speed, 29% on low speed.
12 hours per day.
Uniform Distribution between 6 hours per day and
18 hours per day.
Equal amount of time at each tested speed.
Issue 27: DOE seeks comment on the
estimated average number of operating
hours per year, distribution of operating
hours, and the estimated fraction of time
spent at each speed setting for air
circulating fans with input power less
than 125 W and those with input power
greater than or equal to 125 W. In
addition, if DOE should consider
different operating hours for specific
applications (e.g., air circulating fans
used in agricultural applications,
thermal mixing fans) DOE requests data
on how to best characterize operating
hours for these various applications.
G. Life Cycle Cost and Payback Period
Analyses
The effect of new or amended energy
conservation standards on individual
consumers usually involves a reduction
in operating cost and an increase in
purchase cost. DOE uses the following
two metrics to measure consumer
impacts:
• The LCC is the total consumer
expense of an appliance or product over
the life of that product, consisting of
total installed cost (manufacturer selling
price, distribution chain markups, sales
tax, and installation costs) plus
operating costs (expenses for energy use,
maintenance, and repair). To compute
the operating costs, DOE discounts
future operating costs to the time of
purchase and sums them over the
lifetime of the product.
• The PBP is the estimated amount of
time (in years) it takes consumers to
recover the increased purchase cost
(including installation) of a more
efficient product through lower
operating costs. DOE calculates the PBP
by dividing the change in purchase cost
at higher efficiency levels by the change
in annual operating cost for the year that
amended or new standards are assumed
to take effect.
For any given efficiency level, DOE
measures the change in LCC relative to
the LCC in the no-new-standards case,
which reflects the estimated efficiency
distribution of air circulating fans in the
absence of new energy conservation
standards. In contrast, the PBP for a
given efficiency level is measured
relative to the baseline product. For
each considered efficiency level in each
equipment class, DOE plans on
calculating the LCC and PBP for a
nationally representative sample of
consumers.
In addition, the computer model that
DOE plans on using to calculate the LCC
and PBP relies on a Monte Carlo
simulation to incorporate uncertainty
and variability into the analysis. The
Monte Carlo simulations randomly
sample input values from the
probability distributions and air
circulating fan consumer samples. The
model calculates the LCC and PBP for
equipment at each efficiency level for
10,000 consumers per simulation run.
The analytical results include a
distribution of 10,000 data points
showing the range of LCC savings for a
given efficiency level relative to the nonew-standards case efficiency
distribution. In performing an iteration
of the Monte Carlo simulation for a
given consumer, equipment efficiency is
chosen based on its probability. If the
chosen equipment efficiency is greater
than or equal to the efficiency of the
standard level under consideration, the
LCC and PBP calculation reveals that a
consumer is not impacted by the
standard level. By accounting for
consumers who already purchase more
efficient equipment, DOE avoids
overstating the potential benefits from
increasing equipment efficiency.
This section presents the approach
and data DOE used to derive inputs to
the LCC and PBP analysis not
previously described in this document.
All inputs to the LCC and PBP analyses
are summarized in Table II–18.
TABLE II–18—SUMMARY OF INPUTS AND METHODS FOR THE LCC AND PBP ANALYSIS
Inputs
Source/method
Equipment Cost ........................................................................
Will be derived by multiplying MSPs by distribution channel markups and sales
tax, as appropriate. DOE uses historical data to derive a constant price index
to project equipment costs.
Assumed installation costs do not vary by efficiency level.
Annual energy use: Based on the time spent in each model multiplied by the
input power in each mode.
Variability: Based on discrete and uniform probability distributions.
Electricity: Average and marginal prices based on Edison Electric Institute
(‘‘EEI’’) data for 2021.
Variability: Based on sector and geographical region.
Based on 2022 Annual Energy Outlook (‘‘AEO2022’’) price projections (or most
recent version available at the time of the analysis).
Assumed maintenance costs do not vary by efficiency level.
Assumed no repair costs for air circulating fans with input power less than 125
W.
Assumed one motor repair for air circulating fans with input power greater than
or equal to 125 W, with a lifetime that exceeds the average lifetime.
Installation Costs ......................................................................
Annual Energy Use ..................................................................
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Energy Prices ...........................................................................
Energy Price Trends ................................................................
Repair and Maintenance Costs ................................................
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TABLE II–18—SUMMARY OF INPUTS AND METHODS FOR THE LCC AND PBP ANALYSIS—Continued
Inputs
Source/method
Equipment Lifetime ...................................................................
Average: 10 years for air circulating fans with input power less than 125 W.
And 30 years for air circulating fans with input power greater than or equal to
125 W.
Variability: Based on Weibull distribution.
Residential: approach involves identifying all possible debt or asset classes that
might be used to purchase the considered appliances, or might be affected indirectly. Primary data source was the Federal Reserve Board’s Survey of Consumer Finances.
Commercial/Industrial/Agricultural: Calculated as the weighted average cost of
capital for entities purchasing pool pumps. Primary data source was
Damodaran Online.
5 years after publication of any final rule.
Discount Rates .........................................................................
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Compliance Date ......................................................................
Issue 28: DOE requests feedback on
the inputs and considered methods used
for the LCC and PBP analyses.
Similarly, DOE expects to rely on a
constant price trend for air circulating
fans.
1. Equipment Price
To calculate consumer equipment
costs, DOE multiplies the MSPs
developed in the engineering analysis
by the distribution channel markups
described previously (along with sales
taxes). As previously discussed, DOE
uses different distribution channel
markups for baseline equipment and
higher efficiency equipment, because
DOE applies an incremental markup to
the increase in MSP associated with
higher efficiency equipment.
To project equipment costs in the
projected compliance year, DOE plans
on developing an equipment price
trend. Because the motor is the most
costly component of the air circulating
fan, DOE believes that historic prices of
electric motors provide a reasonable
basis for considering trends in the price
of air circulating fans.
DOE is planning on obtaining
historical Producer Price Index (‘‘PPI’’)
data for integral hp motors and
generators manufacturing spanning the
time period from 1969 to 2021 and for
fractional hp motors and generators
manufacturing between 1967 and 2021
from the BLS.35 The PPI data reflect
nominal prices, adjusted for product
quality changes. An inflation-adjusted
(deflated) price index for fractional hp
motors and generators manufacturing
was calculated by dividing the PPI
series by the Gross Domestic Product
Chained Price Index. Previous DOE
analysis that relied on the same
approach and data sources resulted in a
constant price trend assumption to
project future electric motor prices.36
2. Installation, Repair and Maintenance
Costs
DOE reviewed available air
circulating fan installation,
maintenance, and repair cost
information.
For air circulating fans with input
power less than 125 W, which DOE is
assuming are primarily used in
residential applications, a previous
study focused on air circulating fans
used in residential settings estimated no
installation, repair, or maintenance
costs for these fans.37 DOE believes this
is a representative characterization of
these costs as these air circulating fans
are plug-in equipment that do not
require any maintenance and are
unlikely to be repaired due to the
relatively low equipment price.
For air circulating fans with input
power greater than 125 W, which DOE
assumes are primarily used in
commercial, industrial, and agricultural
applications, DOE did not find any
information supporting changes in
installation and maintenance costs as a
function of efficiency. Therefore,
because DOE expresses results in terms
of LCC savings, DOE is not planning to
account for installation costs in the LCC
(the difference in installation costs
between a baseline and more efficient
air circulating fan would be zero and
would have no impact on the calculated
LCC savings). In terms of repairs, DOE
has identified the motor replacement as
a potential repair. Depending on the
35 Series ID PCU3353123353123 and
PCU3353123353121 for integral and fractional hp
motors and generators manufacturing, respectively;
www.bls.gov/ppi/.
36 See Electric Motors Energy Conservation
Standards Preliminary Analysis Technical Support
Document, Chapter 8: Life Cycle Cost and Payback
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Period Analysis (p. 269). Available at:
www.regulations.gov/document/EERE-2020-BTSTD-0007-0010.
37 Ecodesign Lot 10 Comfort Fans Study,
Preparatory Study on Environmental Performance
of Residential Room Conditioning Appliances (airco
and ventilation) Study on comfort fans—final report
October 2008, after SH comments (p. 44; p. 71–73)
www.eceee.org/static/media/uploads/site-2/
ecodesign/products/airco-ventilation/finalreportcf.zip.
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design options considered, DOE may
include different repair costs by EL to
reflect differences in motor replacement
costs. DOE did not find any information
related to motor repair frequency in air
circulating fans. For air circulating fans
greater than or equal to 125 W, DOE is
considering accounting for one motor
replacement for consumers that have an
air circulating fan with a sampled
lifetime exceeding the average lifetime.
Issue 29: DOE requests information on
its assumptions related to installation,
maintenance, and repair practices of air
circulating fans. Specifically, DOE
requests feedback and data on whether
installation, maintenance, and repair
costs of air circulating fans are expected
to be different at higher efficiency levels
in comparison to the baseline
installation, maintenance, and repair
costs. To the extent that these costs
differ, DOE seeks supporting data and
the reasons for those differences.
Issue 30: DOE requests information on
the repair frequency of air circulating
fans (i.e., how many repairs in a
lifetime) by category (i.e., unhoused air
circulating fan heads, air circulating
axial panel fan, box fan, cylindrical air
circulating fan, and housed centrifugal
air circulating fan) and on its approach
to consider a single repair for certain air
circulating fans with input power
greater than or equal to 125 W.
3. Energy Prices
DOE is planning on using average and
marginal electricity prices in 2021 for
each census division using data from
the EEI Typical Bills and Average Rates
reports 38 and the methodology
described in two Lawrence Berkeley
National Laboratory reports.39 40 DOE’s
38 Edison Electric Institute, EEI Typical Bills and
Average Rates Report (2021). Washington, DC.
39 Katie Coughlin and Berket Beraki, ‘‘NonResidential Electricity Prices: A Review of Data
Sources and Estimation Methods,’’ April 15, 2019,
doi.org/10.2172/1515782.
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methodology allows electricity prices to
vary by sector, region, and season. In the
analysis, variability in electricity prices
is chosen to be consistent with the way
the consumer economic and energy use
characteristics are defined in the LCC
62059
and PBP analyses. Table II–19 shows the
average and marginal prices for each
sector of application.
TABLE II–19—ELECTRICITY PRICES IN 2021
Average
price
2021$/kWh
Sector
Residential ...............................................................................................................................................................
Commercial (small) ..................................................................................................................................................
Commercial (large) ..................................................................................................................................................
Industrial ..................................................................................................................................................................
0.151
0.117
0.083
0.069
The equipment lifetime is the age at
which given equipment is retired from
service. DOE typically develops survival
probabilities using on a Weibull
function to characterize variability in
lifetimes. In preparation for this NODA,
DOE reviewed data available for air
circulating fan lifetime.
For air circulating fans with input
power less than 125 W, which are
primarily used in residential
applications, a previous study focused
on air circulating fans used in
residential settings estimated air
circulating fan lifetimes at 10 years on
average.41
For air circulating fans with input
power greater than or equal to 125 W,
DOE did not find data specific to such
fans and instead is considering an
average lifetime of 30 years across all
sectors, as used to characterize fan and
blower lifetimes in a previous DOE
analysis.42
In the calculation of LCC, DOE
applies discount rates appropriate to
consumers to estimate the present value
of future operating cost savings. DOE
estimated a distribution of discount
rates for air circulating fan consumers
based on the opportunity cost of
consumer funds.
DOE applies weighted average
discount rates calculated from consumer
debt and asset data, rather than marginal
or implicit discount rates.43 The LCC
analysis estimates net present value
over the lifetime of the equipment, so
the appropriate discount rate will reflect
the general opportunity cost of
household funds, taking this time scale
into account. Given the long time
horizon modeled in the LCC analysis,
the application of a marginal interest
rate associated with an initial source of
funds is inaccurate. Regardless of the
method of purchase, consumers are
expected to continue to rebalance their
debt and asset holdings over the LCC
analysis period, based on the
restrictions consumers face in their debt
payment requirements and the relative
size of the interest rates available on
debts and assets. DOE estimates the
aggregate impact of this rebalancing
using the historical distribution of debts
and assets.
To establish residential discount rates
for the LCC analysis, DOE identified all
relevant household debt or asset classes
in order to approximate a consumer’s
opportunity cost of funds related to
appliance energy cost savings. It
estimated the average percentage shares
of the various types of debt and equity
by household income group using data
from the Federal Reserve Board’s Survey
of Consumer Finances 44 (‘‘SCF’’) for
1995, 1998, 2001, 2004, 2007, 2010,
2013, 2016, and 2019. Using the SCF
and other sources, DOE developed a
distribution of rates for each type of
debt and asset by income group to
represent the rates that may apply in the
year in which amended standards
would take effect. In the LCC
calculation, to account for variation
among households, DOE will assign
each RECS household a specific
discount rate drawn the distributions for
the appropriate income group (RECS
provides household income data). The
average discount rate in 2021 across all
types of household debt and equity and
income groups, weighted by the shares
of each type, is 4.3 percent.
DOE applies weighted average
discount rates calculated from consumer
debt and asset data, rather than marginal
or implicit discount rates. DOE notes
that the LCC does not analyze the
appliance purchase decision, so the
implicit discount rate is not relevant in
this model. The LCC estimates net
present value over the lifetime of the
40 Katie Coughlin and Bereket Beraki,
‘‘Residential Electricity Prices: A Review of Data
Sources and Estimation Methods,’’ 2018.
41 Ecodesign Lot 10 Comfort Fans Study,
Preparatory Study on Environmental Performance
of Residential Room Conditioning Appliances (airco
and ventilation) Study on comfort fans—final report
October 2008, after SH comments (p. 44)
www.eceee.org/static/media/uploads/site-2/
ecodesign/products/airco-ventilation/finalreportcf.zip.
42 On November 1, 2016, DOE published a
notification of data availability (‘‘November 2016
NODA’’) that presented an analysis for fans and
blowers other than air circulating fans. 81 FR
75742. The lifetime assumptions and data source
supporting the life cycle cost calculation of the
November 2016 NODA are available online at
www.regulations.gov/document/EERE-2013-BTSTD-0006-0190 (see ‘‘Lifetime’’ worksheet). The
average lifetime estimate was based on input from
a subject matter expert John Murphy. ‘‘Commercial
and Industrial Fans Life-cycle Cost Informational
Interview.’’ Telephone interview. 13 May 2014.
43 The implicit discount rate is inferred from a
consumer purchase decision between two otherwise
identical goods with different first cost and
operating cost. It is the interest rate that equates the
increment of first cost to the difference in net
present value of lifetime operating cost,
incorporating the influence of several factors:
transaction costs; risk premiums and response to
uncertainty; time preferences; interest rates at
which a consumer is able to borrow or lend. The
implicit discount rate is not appropriate for the LCC
analysis because it reflects a range of factors that
influence consumer purchase decisions, rather than
the opportunity cost of the funds that are used in
purchases.
44 U.S. Board of Governors of the Federal Reserve
System. Survey of Consumer Finances. 1995, 1998,
2001, 2004, 2007, 2010, 2013, 2016, and 2019. (Last
accessed June 15, 2022) www.federalreserve.gov/
econresdata/scf/scfindex.htm.
To estimate electricity prices in future
years, DOE is planning on multiplying
the 2021 electricity prices by the sectorspecific forecasts of annual national
average price changes from EIA’s
Reference case in the AEO 2022. The
reference case is a business-as-usual
estimate, given known market,
demographic, and technological trends.
AEO2022 has an end year of 2050. DOE
assumes a flat rate of change in prices
from 2050. The values for the industrial
sector are used for the agricultural
sector as well.
4. Lifetime
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0.157
0.123
0.097
0.081
Marginal
price
2021$/kWh
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Issue 31: DOE requests comment on
the estimated average equipment
lifetimes for air circulating fans. DOE
also requests information related to
minimum and maximum equipment
lifetimes (in years or total mechanical
hours).
5. Discount Rates
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product, so the appropriate discount
rate will reflect the general opportunity
cost of household funds, taking this
time scale into account. Given the long
time horizon modeled in the LCC, the
application of a marginal interest rate
associated with an initial source of
funds is inaccurate. Regardless of the
method of purchase, consumers are
expected to continue to rebalance their
debt and asset holdings over the LCC
analysis period, based on the
restrictions consumers face in their debt
payment requirements and the relative
size of the interest rates available on
debts and assets. DOE estimates the
aggregate impact of this rebalancing
using the historical distribution of debts
and assets.
To establish commercial, industrial,
and agricultural discount rates, DOE
estimated the weighted average cost of
capital using data from Damodaran
Online.45 The weighted average cost of
capital is commonly used to estimate
the present value of cash flows to be
derived from a typical company project
or investment. Most companies use both
debt and equity capital to fund
investments, so their cost of capital is
the weighted average of the cost to the
firm of equity and debt financing. DOE
estimated the cost of equity using the
capital asset pricing model, which
assumes that the cost of equity for a
particular company is proportional to
the systematic risk faced by that
company. The average commercial,
industrial, and agricultural discount
rates in 2021 are 6.77 percent, 7.25
percent, and 7.15 percent respectively.
6. Efficiency Distribution in the No-New
Standards Case
To accurately estimate the share of
consumers that would be affected by a
potential energy conservation standard
at a particular efficiency level, DOE’s
LCC analysis considers the projected
distribution (market shares) of
equipment efficiencies in the no-newstandards case (i.e., the case without
new energy conservation standards) in
the anticipated compliance year of any
future energy conservations standards.
For air circulating fans with input
power less than 125 W, DOE did not
find any data regarding the distributions
of equipment efficiencies in the no-newstandards case. In the absence of any
data, DOE is conservatively considering
assuming all shipments are at the
baseline level (EL 0).
For air circulating fans with input
power greater than or equal to 125 W,
45 Damodaran Online, Data Page: Costs of Capital
by Industry Sector (2020). (Last accessed February
1, 2021) pages.stern.nyu.edu/∼adamodar/.
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DOE is planning on using the
distributions based on model counts at
each efficiency level analyzed from the
BESS Labs Database to develop 2021
distributions of equipment efficiencies
in the no-new-standards case. DOE
notes that the BESS Labs Database only
publishes performance at limited
operating points for a given model,
allowing DOE to calculate the FEI at a
single operating point (and not as a
weighted average). In the absence of
other data, DOE will use this as a proxy
for determining the weighted average
FEI of air circulating fans with variable
and multi-speed capability. In addition,
DOE will apply equipment efficiency
trends (see section II.H.3 of this
document) to project the efficiency
distribution for the no-new-standards
case in the compliance year.
Using the projected distribution of
efficiencies for air circulating fans, DOE
plans on randomly assigning an
equipment efficiency to each household
and commercial, industrial, or
agricultural consumer drawn from the
consumer samples. If a consumer is
assigned an equipment efficiency that is
greater than or equal to the efficiency
under consideration, the consumer
would not be affected by a standard at
that efficiency level.
Issue 32: DOE requests comment on
its approach to derive efficiency
distribution in the no-new standards
case for each air circulating fan category
and input regarding 2021 (or most
recent year available) equipment
efficiency distributions. Additionally,
DOE seeks data that would support
changes in efficiency distributions over
time in the no-new standards case. To
the extent any of the efficiency
distributions in the no-new standards
case differ by size or other consumer or
design characteristic, DOE requests
information to characterize these
variations.
H. National Impact Analysis
The NIA estimates the national energy
savings (‘‘NES’’) and the net present
value (‘‘NPV’’) of total consumer costs
and savings expected to result from new
standards at specific efficiency levels
(referred to as candidate standard
levels).46 DOE calculates the NES and
NPV for the potential standard levels
considered based on projections of
annual equipment shipments, along
with the annual energy consumption
and total installed cost data from the
energy use and LCC analyses. For the
present analysis, DOE projected the
energy savings, operating cost savings,
46 The
NIA accounts for impacts in the 50 states
and U.S. territories.
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equipment costs, and NPV of consumer
benefits over the lifetime of air
circulating fans sold over a 30-year
period starting in the compliance year.
DOE evaluates the impacts of new or
amended standards by comparing a case
without such standards with standards
case projections (‘‘no-new-standards
case’’). The no-new-standards case
characterizes energy use and consumer
costs for each equipment class in the
absence of new or amended energy
conservation standards. For this
projection, DOE considers historical
trends in efficiency and various forces
that are likely to affect the mix of
efficiencies over time. DOE compares
the no-new-standards case with
projections characterizing the market for
each equipment class if DOE adopted
new or amended standards at specific
energy efficiency levels for that class.
For each efficiency level, DOE considers
how a given standard would likely
affect the market shares of equipment
with efficiencies greater than the
standard.
The NIA calculations use typical
values (as opposed to probability
distributions) as inputs. Critical inputs
to this analysis include shipments
projections, estimated product lifetimes,
product installed costs and operating
costs, product annual energy
consumption, the base case efficiency
projection, and discount rates. In this
section, DOE discusses specific inputs
to the NIA, not previously discussed in
this document, for which it requests
comment and feedback.
1. Base Year Shipments
DOE develops shipments forecasts to
calculate the national impacts of
potential energy conservation standards
on energy consumption, NPV, and
future manufacturer cash flows. DOE
shipments projections are typically
based on available historical data
broken out by equipment class,
capacity, and efficiency. Current sales
estimates allow for a more accurate
model that captures recent trends in the
market.
For air circulating fans with input
power less than 125 W, DOE reviewed
shipments data from the Appliance
Magazine market research,47 which
provides 1981–1994 shipments
estimates of air circulating fans used in
residential settings and of ceiling fans.
On average during the period 1981–
1994, the data showed that shipments of
such air circulating fans represented 91
percent of ceiling fan shipments. DOE
47 Appliance Magazine market research,
Appliance Historical Statistical review, 1954–2012,
January 2014.
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assumed that this ratio is still
representative of the market in 2020 and
calculated shipments of air circulating
fans with input power less than 125 W
by multiplying the 2020 ceiling fan
shipments data published in a previous
DOE study 48 by 0.91, which resulted in
19.2 million units in 2020. DOE did not
find data to characterize shipments by
equipment classes in that input power
range.
For air circulating fans with input
power greater than or equal to 125 W,
DOE obtained 2021 shipments estimates
from manufacturer interviews for
unhoused air circulating fan heads and
cylindrical air circulating fans.49 DOE
then used model counts from the BESS
Labs Database to estimate market shares
by air circulating fan category. Table II–
20 shows the estimated market shares
by category based on model counts from
the BESS Labs Database. Based on this
data, DOE estimated that unhoused air
circulating fan headsand cylindrical air
circulating fans represent a combined 30
percent of the total market of air
circulating fans with input power
greater than or equal to 125 W. In
addition, DOE adjusted the market
shares of unhoused air circulating fan
heads (22 percent) and cylindrical air
62061
circulating fans (8 percent) from the
BESS Labs database to account for the
market shares from the shipments
estimates provided in manufacturer
interviews (i.e., 20 percent and 10
percent, respectively). DOE then used
unadjusted market shares by category as
presented in Table II–20 to calculate
shipments of air circulating fans for
which manufacturer interviews did not
provide estimates. The BESS Labs
Database does not include any housed
centrifugal air circulating fans. DOE did
not find any data to estimate the
shipments of housed centrifugal air
circulating fans.
TABLE II–20—AIR CIRCULATING FANS WITH INPUT POWER GREATER THAN OR EQUAL TO 125 W—MARKET SHARE BY
EQUIPMENT CLASS (EXCLUDING HOUSED CENTRIFUGAL AIR CIRCULATING FANS)
Market share
based on
model counts
(%)
Calculated
market share
(%) *
Estimated
2021
shipments
(units)
DOE terminology
BESS category
Unhoused Air Circulating Fan Head ...................................................
Box fan ................................................................................................
Air circulating axial panel fan ..............................................................
Cylindrical air circulating fan ...............................................................
Housed centrifugal air circulating fan ..................................................
Basket fan ..................
Box fan .......................
Panel fan ....................
Tube fan .....................
N/A .............................
22
11
59
8
N/A
20
11
59
10
N/A
494,950
275,018
1,475,098
255,100
N/A
Total .............................................................................................
....................................
100
100
2,500,167
* Adjusted market shares of Unhoused Air Circulating Fan Head and Cylindrical air circulating fan based on shipments estimates from manufacturer interviews.
Finally for air circulating fans with
input power greater than or equal to 125
W, based on information from
manufacturer interviews, DOE estimated
that while some fans are used in
commercial and industrial settings, the
majority of these fans are used in
agricultural applications. In the absence
of any quantitative data to characterize
the fraction of shipments by sector, DOE
assumed 75 percent of shipments are
used in agricultural settings,50 12.5
percent in commercial settings, and 12.5
percent in industrial applications.
khammond on DSKJM1Z7X2PROD with PROPOSALS
2. Shipments Projections
In response to the February 2022 ECS
RFI, ebm-papst suggested that the
growth of indoor horticulture, a need for
farm animal cooling due to climate
change, and a need for auxiliary cooling
on distribution transformers due to
electrification of climate change could
all be reasons for possible growth in the
air circulating fan market. (ebm-papst,
No. 8 at p. 4)
48 See Chapter 9 of the ceiling fan preliminary
analysis Technical Support Document
www.regulations.gov/document/EERE-2021-BTSTD-0011-0015.
49 Information from manufacturer interviews
indicated shipments estimates of 494,950 units of
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To project shipments of air circulating
fans with input power less than 125 W,
DOE is considering using an annual
growth rate of 5 percent based on the
Appliance Magazine market research
data,51 which provides 1981–1994
shipments estimates for air circulating
fans used in residential settings.
For air circulating fans with input
power greater than or equal to 125 W,
DOE estimates that shipments of such
fans follow similar trends as shipments
of large-diameter ceiling fans. Therefore,
DOE is considering projecting
shipments of air circulating fans with
input power greater than or equal to 125
W based on the growth rates projected
for shipments of large-diameter ceiling
fans.52 DOE notes that this corresponds
to a compound annual growth rate of 8.3
percent for the period 2020–2030.
DOE may consider alternative
approaches to project shipments
depending on stakeholder comment and
any additional data that may become
available.
Issue 33: DOE requests comment on
the estimated 2020 shipments of air
circulating fans for each market segment
considered (i.e., below 125 W, and at or
above 125 W) and seeks input on the
fraction of shipments by air circulating
fan category (i.e., unhoused air
circulating fan heads, air circulating
axial panel fan, box fan, cylindrical air
circulating fan, and housed centrifugal
air circulating fan). In addition, DOE
requests 2021 annual sales data (or the
most recent year available)—i.e.,
number of shipments—for air
circulating fans and annual historical
shipments data for 2016–2020 (or most
recent years available). If disaggregated
data of annual sales are not available for
different air circulating fan categories,
DOE requests more aggregated data of
annual sales as available.
Issue 34: DOE requests comment on
the estimated market share by sector.
DOE requests 2016–2021 data (or the
most recent years available) on the
fraction of shipments in the industrial,
commercial, and residential sectors for
unhoused air circulating fan heads and 255,100
units of cylindrical air circulating fans.
50 DOE assumed the mid-point between 50 and
100 percent of shipments (75 percent) go to
agriculture. Distributed the remaining shipments
equally across the commercial and industrial
sectors.
51 Appliance Magazine market research,
Appliance Historical Statistical review, 1954–2012,
January 2014.
52 See Chapter 9 of the ceiling fan preliminary
analysis Technical Support Document (TSD)
https://www.regulations.gov/document/EERE-2021BT-STD-0011-0015.
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air circulating fans. In each sector, DOE
requests 2016–2021 data (or the most
recent years available) on the fraction of
shipments that represent replacement
versus new installations.
Issue 35: DOE requests comments on
its approach to project shipments of air
circulating fans. DOE requests
information on the rate at which annual
sales (i.e., number of shipments) of air
circulating fans is expected to change in
the next 5–10 years. If possible, DOE
requests this information for each air
circulating fan category (i.e., unhoused
air circulating fan heads, air circulating
axial panel fan, box fan, cylindrical air
circulating fan, and housed centrifugal
air circulating fan). If disaggregated data
of annual sales are not available for each
air circulating fan category, DOE
requests more aggregated data of annual
sales.
3. Equipment Efficiency Trends
A key component of the NIA is the
trend in energy efficiency projected for
the no-new-standards case and each of
the standards cases over the entire 30year analysis period. To project the
trend in efficiency absent amended
standards for air circulating fans, DOE
did not find any historical equipment
efficiency data. Instead, in order to
incorporate any efficiency trends, DOE
may consider an approach that shifts a
fraction of the market share in the
single-speed levels (e.g., 1 percent) to
the variable-speed efficiency levels to
reflect the growing market share of
variable-speed air circulating fans. DOE
may consider alternative approaches to
project equipment efficiency depending
on stakeholder comment and any
additional data that may become
available.
For standards cases, DOE is
considering a ‘‘roll up’’ scenario to
establish the shipment-weighted
efficiency for the year that standards are
assumed to become effective. In this
scenario, the market share of products
in the no-new-standards case that do not
meet the standard under consideration
would ‘‘roll up’’ to meet the new
standard level, and the market share of
products above the standard would
remain unchanged. To project the trend
in efficiency in the various standard
case considered, DOE would then apply
the same shift towards variable-speed
efficiency levels as in the no-newstandard case for the standards cases.
Issue 36: DOE requests comments on
its approach to project equipment
efficiency for air circulating fans. DOE
requests data and information on any
trends in the fans market that could be
used to forecast expected trends in
market share by efficiency levels for air
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circulating fans. If disaggregated data
are not available for each air circulating
fan category, DOE requests more
aggregated data.
III. Public Participation
A. Submission of Comments
DOE will accept comments, data, and
information regarding this notification
of data availability no later than the date
provided in the DATES section at the
beginning of this document. Interested
parties may submit comments, data, and
other information using any of the
methods described in the ADDRESSES
section at the beginning of this
document.
Submitting comments via
www.regulations.gov. The
www.regulations.gov web page will
require you to provide your name and
contact information. Your contact
information will be viewable to DOE
Building Technologies staff only. Your
contact information will not be publicly
viewable except for your first and last
names, organization name (if any), and
submitter representative name (if any).
If your comment is not processed
properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment itself or in any
documents attached to your comment.
Any information that you do not want
to be publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Otherwise, persons viewing comments
will see only first and last names,
organization names, correspondence
containing comments, and any
documents submitted with the
comments.
Do not submit to www.regulations.gov
information for which disclosure is
restricted by statute, such as trade
secrets and commercial or financial
information (hereinafter referred to as
Confidential Business Information
(‘‘CBI’’)). Comments submitted through
www.regulations.gov cannot be claimed
as CBI. Comments received through the
website will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
DOE processes submissions made
through www.regulations.gov before
posting. Normally, comments will be
posted within a few days of being
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submitted. However, if large volumes of
comments are being processed
simultaneously, your comment may not
be viewable for up to several weeks.
Please keep the comment tracking
number that www.regulations.gov
provides after you have successfully
uploaded your comment.
Submitting comments via email, hand
delivery/courier, or postal mail.
Comments and documents submitted
via email, hand delivery/courier, or
postal mail also will be posted to
www.regulations.gov. If you do not want
your personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information in a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. If you
submit via postal mail or hand delivery/
courier, please provide all items on a
CD, if feasible, in which case it is not
necessary to submit printed copies. No
telefacsimiles (‘‘faxes’’) will be
accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, that are written in English, and
that are free from any defects or viruses.
Documents should not contain special
characters or any form of encryption
and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
Pursuant to 10 CFR 1004.11, any person
submitting information that he or she
believes to be confidential and exempt
by law from public disclosure should
submit via email two well-marked
copies: one copy of the document
marked ‘‘confidential’’ including all the
information believed to be confidential,
and one copy of the document marked
‘‘non-confidential’’ with the information
believed to be confidential deleted or
redacted. DOE will make its own
determination about the confidential
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status of the information and treat it
according to its determination.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
khammond on DSKJM1Z7X2PROD with PROPOSALS
B. Issues on Which DOE Seeks Comment
As indicated in the analyses
previously, DOE is seeking further
comment and/or data on certain issues.
For reference, these issues from the
above analyses include the following:
Issue 1: DOE requests comment on its
assumption that most motors paired
with air circulating fans are lower
efficiency induction motors that are not
currently regulated by DOE.
Additionally, DOE requests data on the
percentage of air circulating fans that
include a SP, PSC, shaded pole, or
electronically commuted motors.
Issue 2: DOE requests comment on if
or how the five screening criteria may
impact the application of an
aerodynamic redesign (including
changes to housing, impeller and/or
blade design), more efficient motors, or
VSDs (‘‘variable-speed drives’’) as
design options in the current
rulemaking analysis.
Issue 3: DOE requests comment on its
assumption that the BESS Labs
Combined Database is representative of
the air circulating fan head market, with
the exception of housed centrifugal air
circulating fans and air circulating fans
with input power less than 125 W
which are not represented in the BESS
Labs Combined Database.
Issue 4: DOE requests additional
information for all categories of air
circulating fans, including:
manufacturer name, model number, fan
diameter, blade number, blade shape,
blade material, housing type, housing
material, spacing between the blade tip
and the housing, and housing depth
with associated performance data
obtained using AMCA 230–15 with
2021 errata (or sufficient information
that can be used to correct to AMCA
230–15 with 2021 errata). DOE
additionally requests the following
information on the motors sold within
each fan model: motor type (i.e., SP,
PSC, ECM, polyphase, etc.), type of
drive (i.e., direct or belt), motor
horsepower (‘‘hp’’), motor full-load
efficiency (if available), motor rotations
per minute, number of speeds, motor
electric requirements (i.e., volts, amps,
frequency, phase, AC/DC), and whether
a variable-speed drive is included with
the fan.
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Issue 5: DOE requests comment on the
potential of using fan affinity laws to
extrapolate BESS Labs performance data
to air circulating fan heads with
diameters less than 12 inches and
greater than 52 inches. Additionally,
DOE requests model characteristics and
performance data obtained using AMCA
230–15 plus 2021 errata (or sufficient
information than can be used to correct
to AMCA 230–15 plus 2021 errata) for
air circulating fans with diameters both
smaller than and larger than those listed
in the BESS Labs Database.
Issue 6: DOE requests comment on
whether, and if so how, each of the
following performance-related features
may impact utility of air circulating
fans: presence or absence of a safety
guard, presence or absence of housing,
housing design, blade type, drive type,
number of discrete speed settings,
power requirements, and air velocity or
throw. DOE requests additional
feedback and data or information on
other air circulating fan features that
may impact utility for the end user and
might form the basis for classification.
Issue 7: DOE requests comment with
supporting data on whether the
following performance-related features
provide substantially different utility, or
are expected to have a significant
impact on efficiency because of how
they are used: (1) housed vs. unhoused
air circulating fan heads; (2) directdriven vs. belt-driven air circulating fan
heads; and (3) single-phase vs.
polyphase air circulating fan heads.
DOE also requests information on any
additional features that may impact air
circulating fan head utility.
Issue 8: DOE requests comment on
whether the diameters chosen for
representative units in this analysis (i.e.,
12 inches, 20 inches, 24 inches, 36
inches, and 50 inches) accurately
represent the diameters with the highest
sales volume available in the air
circulating fan market. DOE also
requests comment on whether diameter
is an appropriate representative metric
for air circulating fans.
Issue 9: DOE requests comment on
whether the motor hp it has associated
with each representative diameter (i.e.,
0.1 hp for 12 inches, 0.33 hp for 20
inches, 0.5 hp for 24 inches and 36
inches, and 1 hp for 50 inches)
appropriately represent the motor hp for
fans sold with those corresponding
diameters.
Issue 10: DOE requests comment on
its use of SP motors as the baseline for
air circulating fans. Additionally, DOE
seeks feedback on its choice of motor
technologies (SP motor to PSC 1 motor,
PSC 1 motor to PSC 2 motor, and PSC
2 motor to ECM) to estimate air
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62063
circulating fan efficiency increases from
one efficiency level to the next.
Issue 11: DOE requests comment on
its assumption that motors used in air
circulating fans are exclusively air-over
motors. If this is not the case, DOE
requests information on the other types
of motors that are sold with air
circulating fans and data on the
percentage of air circulating fans that
are sold with motors other than air-over
motors. Additionally, DOE requests
information on whether or not the type
of motor supplied with an air
circulating fan is a function of air
circulating fan category (e.g., unhoused
air circulating fan head, box fan,
cylindrical air circulating fan, etc.).
Issue 12: DOE requests feedback on
whether catalog performance data on SP
motors and PSC motors is generally
representative of the performance of the
SP and PSC motors included with air
circulating fans.
Issue 13: DOE requests feedback on
the methodology used to determine the
baseline efficiency values for the
representative units, including its
method of first establishing the EL1
efficiency and then determining the
baseline efficiency by reducing the EL1
efficiency by the difference in efficiency
between a PSC motor and a SP motor.
Additionally, DOE requests data on the
expected average improvement in air
circulating fan efficiency when a SP
motor is replaced by a PSC 1 motor.
Issue 14: DOE requests feedback on its
assumption that airflow, pressure, and
motor performance (for example, speed
and inrush current) remain constant
when replacing a less efficient motor
with a more efficient motor in an air
circulating fan. If airflow, pressure, or
motor performance are not maintained
when using a more efficient motor, DOE
requests feedback and data on how it
should conduct this analysis.
Issue 15: DOE requests feedback on
whether the efficiency gains shown in
the supplementary spreadsheet are
realistic efficiency gains when replacing
a lower efficiency PSC motor (i.e., PSC
1 motor) with a higher efficiency PSC
motor (i.e., PSC 2 motor). If these
assumptions are not realistic, DOE
requests data demonstrating air
circulating fan motor efficiency as a
function of hp, as well as data for motor
hp as a function of fan diameter.
Issue 16: DOE requests feedback on its
use of dedicated purpose pool pump
motors as a source for comparing PSC
motor and ECM efficiency.
Additionally, DOE requests information
on whether motors used for this purpose
are comparable to air circulating fan
motors. DOE further requests feedback
on whether the efficiency increases from
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PSC 1 motors to ECM that DOE presents
are realistic. If dedicated purpose pool
pump motors are not representative of
air circulating fans motors, or DOE’s
estimated efficiency increases are not
realistic, DOE requests data on the
difference between PSC 1 motor
efficiency and ECM efficiency and the
difference between PSC 2 motor
efficiency and ECM efficiency for air
circulating fans. DOE also requests
comment on its use of extrapolation of
these data to obtain efficiency values at
fractional hp.
Issue 17: DOE requests feedback on
the FEI values that it determined and its
approach for estimating FEI values for
an air circulating fan that includes both
an ECM and improved aerodynamic
design.
Issue 18: DOE requests comment on
its factory parameter assumptions for
typical air circulating fan production.
Issue 19: DOE requests comment on
whether or not its baseline material
assumptions are representative of
baseline fans distributed into commerce.
If DOE’s baseline material assumptions
are not representative, DOE requests
information and data on materials
typicaly used in the air circulating fans
currently on the market.
Issue 20: DOE requests comment on
its estimated base MPC for air
circulating fans with no motors at each
of the representative diameters
evaluated. (See supplemental
spreadsheet included in Docket No.
EERE–2022–BT–STD–0002, No. 11)
Issue 21: DOE requests comment on
whether replacing a given fan motor
with a more efficient fan motor will
result in similar efficiency and cost
impacts for housed and unhoused air
circulating fan heads.
Issue 22: DOE requests comment on
its estimated motor costs SP motors
(EL0), PSC motors (EL1), higher
efficiency PSC motors (EL2), and ESMs
(EL3) at each hp associated with the
representative diameters evaluated. (See
supplemental spreadsheet included in
Docket No. EERE–2022–BT–STD–0002,
No. 11)
Issue 23: DOE requests comment on
its estimated housed and unhoused air
circulating fan costs at each EL and for
each representative unit. (See
supplemental spreadsheet included in
Docket No. EERE–2022–BT–STD–0002,
No. 11)
Issue 24: DOE requests comment on
and additional data to support its
estimated air circulating fan conversion
costs to undergo aerodynamic redesign.
Issue 25: DOE requests comment on
whether or not an average MSP of 1.5
is representative for the air circulating
fan market. If an average MSP of 1.5 is
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not representative, DOE requests
information of what a more
representative MSP would be.
Additionally, DOE requests comment on
whether or not MSP for air circulating
fans will remain constant in the case of
new energy conservation standards. If
not, DOE seeks information on the
magnitude by which MSP might change
under potential energy efficiency
standards.
Issue 26: DOE requests feedback and
information on the distribution
channels identified for air circulating
fans, and on any other distribution
channel that DOE should consider. DOE
also requests data on the fraction of
sales that go through these channels.
Issue 27: DOE seeks comment on the
estimated average number of operating
hours per year, distribution of operating
hours, and the estimated fraction of time
spent at each speed setting for air
circulating fans with input power less
than 125 W and those with input ower
greater than or equal to 125 W. In
addition, if DOE should consider
different operating hours for specific
applications (e.g., air circulating fans
used in agricultural applications,
thermal mixing fans) DOE requests data
on how to best characterize operating
hours for these various applications.
Issue 28: DOE requests feedback on
the inputs and considered methods used
for the LCC and PBP analyses.
Issue 29: DOE requests information on
its assumptions related to installation,
maintenance, and repair practices of air
circulating fans. Specifically, DOE
requests feedback and data on whether
installation, maintenance, and repair
costs of air circulating fans are expected
to be different at higher efficiency levels
in comparison to the baseline
installation, maintenance, and repair
costs. To the extent that these costs
differ, DOE seeks supporting data and
the reasons for those differences.
Issue 30: DOE requests information on
the repair frequency of air circulating
fans (i.e., how many repairs in a
lifetime) by category (i.e., unhoused air
circulating fan heads, air circulating
axial panel fan, box fan, cylindrical air
circulating fan, and housed centrifugal
air circulating fan) and on its approach
to consider a single repair for certain air
circulating fans with input power
greater than or equal to 125 W.
Issue 31: DOE requests comment on
the estimated average equipment
lifetimes for air circulating fans. DOE
also requests information related to
minimum and maximum equipment
lifetimes (in years or total mechanical
hours).
Issue 32: DOE requests comment on
its approach to derive efficiency
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distribution in the no-new standards
case for each air circulating fan category
and input regarding 2021 (or most
recent year available) equipment
efficiency distributions. Additionally,
DOE seeks data that would support
changes in efficiency distributions over
time in the no-new standards case. To
the extent any of the efficiency
distributions in the no-new standards
case differ by size or other consumer or
design characteristic, DOE requests
information to characterize these
variations.
Issue 33: DOE requests comment on
the estimated 2020 shipments of air
circulating fans for each market segment
considered (i.e., below 125 W, and at or
above 125 W) and seeks input on the
fraction of shipments by air circulating
fan category (i.e., unhoused air
circulating fan heads, air circulating
axial panel fan, box fan, cylindrical air
circulating fan, and housed centrifugal
air circulating fan). In addition, DOE
requests 2021 annual sales data (or the
most recent year available)—i.e.,
number of shipments—for air
circulating fans and annual historical
shipments data for 2016–2020 (or most
recent years available). If disaggregated
data of annual sales are not available for
different air circulating fan categories,
DOE requests more aggregated data of
annual sales as available.
Issue 34: DOE requests comment on
the estimated market share by sector.
DOE requests 2016–2021 data (or the
most recent years available) on the
fraction of shipments in the industrial,
commercial, and residential sectors for
air circulating fans. In each sector, DOE
requests 2016–2021 data (or the most
recent years available) on the fraction of
shipments that represent replacement
versus new installations.
Issue 35: DOE requests comments on
its approach to project shipments of air
circulating fans. DOE requests
information on the rate at which annual
sales (i.e., number of shipments) of air
circulating fans is expected to change in
the next 5–10 years. If possible, DOE
requests this information for each air
circulating fan category (i.e., unhoused
air circulating fan heads, air circulating
axial panel fan, box fan, cylindrical air
circulating fan, and housed centrifugal
air circulating fan). If disaggregated data
of annual sales are not available for each
air circulating fan category, DOE
requests more aggregated data of annual
sales.
Issue 36: DOE requests comments on
its approach to project equipment
efficiency for air circulating fans. DOE
requests data and information on any
trends in the fans market that could be
used to forecast expected trends in
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market share by efficiency levels for air
circulating fans. If disaggregated data
are not available for each air circulating
fan category, DOE requests more
aggregated data.
IV. Approval of the Office of the
Secretary
khammond on DSKJM1Z7X2PROD with PROPOSALS
The Secretary of Energy has approved
publication of this notification of the
availability of the preliminary technical
support document and request for
comment.
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Signing Authority
This document of the Department of
Energy was signed on October 5, 2022,
by Francisco Alejandro Moreno, Acting
Assistant Secretary for Energy Efficiency
and Renewable Energy, pursuant to
delegated authority from the Secretary
of Energy. That document with the
original signature and date is
maintained by DOE. For administrative
purposes only, and in compliance with
requirements of the Office of the Federal
Register, the undersigned DOE Federal
Register Liaison Officer has been
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authorized to sign and submit the
document in electronic format for
publication, as an official document of
the Department of Energy. This
administrative process in no way alters
the legal effect of this document upon
publication in the Federal Register.
Signed in Washington, DC, on October 6,
2022.
Treena V. Garrett,
Federal Register Liaison Officer, U.S.
Department of Energy.
[FR Doc. 2022–22141 Filed 10–12–22; 8:45 am]
BILLING CODE 6450–01–P
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Agencies
[Federal Register Volume 87, Number 197 (Thursday, October 13, 2022)]
[Proposed Rules]
[Pages 62038-62065]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-22141]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
Federal Register / Vol. 87, No. 197 / Thursday, October 13, 2022 /
Proposed Rules
[[Page 62038]]
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2022-BT-STD-0002]
RIN 1904-AF40
Energy Conservation Program: Energy Conservation Standards for
Fans and Blowers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notification of data availability (``NODA'').
-----------------------------------------------------------------------
SUMMARY: On February 8, 2022, the U.S. Department of Energy (``DOE'')
published a request for information regarding energy conservation
standards for fans and blowers. In this NODA, DOE is publishing
preliminary inputs and methodology for its technology, screening,
engineering, shipments, markups, life cycle cost, and energy use
analysis for air circulating fans. Air circulating fans are a
subcategory of fans; however, air circulating fans were not included in
the Appliance Standards and Rulemaking Federal Advisory (``ASRAC'')
negotiations undertaken in 2015 (see Docket No. EERE-2013-BT-STD-0006).
The purpose of this NODA is to provide stakeholders with the
opportunity to review and provide comment on DOE's preliminary
technical and economic evaluation of air circulating fans, prior to
DOE's publication of a notice of proposed rulemaking for all fans and
blowers. The analysis presented in this NODA is consistent with the air
circulating fans scope and definitions that DOE proposed in the July
25, 2022, test procedure notice of proposed rulemaking (``NOPR'') for
fans and blowers (``July 2022 TP NOPR''). DOE requests comments, data,
and information regarding its analysis.
DATES: Written comments and information will be accepted on or before
November 28, 2022.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at www.regulations.gov, under docket
number EERE-2022-BT-STD-0002. Follow the instructions for submitting
comments. Alternatively, interested persons may submit comments,
identified by docket number EERE-2022-BT-STD-0002, by any of the
following methods:
Email: [email protected]. Include the docket
number EERE-2022-BT-STD-0002 in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
Hand Delivery/Courier: Appliance and Equipment Standards Program,
U.S. Department of Energy, Building Technologies Office, 950 L'Enfant
Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202) 287-1445.
If possible, please submit all items on a CD, in which case it is not
necessary to include printed copies.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section IV of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, public meeting transcripts, and other
supporting documents/materials, is available for review at
www.regulations.gov. All documents in the docket are listed in the
www.regulations.gov index. However, some documents listed in the index,
such as those containing information that is exempt from public
disclosure, may not be publicly available.
The docket web page can be found at www.regulations.gov/docket/EERE-2022-BT-STD-0002. The docket web page contains instructions on how
to access all documents, including public comments in the docket. See
section III.A of this document for information on how to submit
comments through www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Mr. Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies, EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-
0121. Telephone: (202) 586-9870. Email:
[email protected].
Mr. Matthew Schneider, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (240) 597-6265. Email:
[email protected].
For further information on how to submit a comment, or review other
public comments and the docket, contact the Appliance and Equipment
Standards Program staff at (202) 287-1445 or by email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority
B. Deviation From Appendix A
C. Background
II. Summary of the Analyses Performed by DOE
A. Scope
B. Technology Options
C. Screening Analysis
D. Engineering Analysis
1. Methodology
a. Metric
b. Air Circulating Fan Performance Data
2. Equipment Classes and Representative Sizes
a. Equipment Classes
b. Representative Sizes
3. Efficiency Model
a. BESS Combined Database
b. Baseline Fan Efficiencies
c. Improving Efficiency With More Efficient Motors
d. Improving Efficiency Through Aerodynamic Redesign
e. Results for a 24-Inch, 0.5 hp Representative Unit
4. Cost Model
a. Cost Model Structure and Process
b. Cost Model Assumptions
c. Determination of Air Circulating Fan MPC
5. Manufacturer Selling Price
E. Markups Analysis
F. Energy Use Analysis
1. Fans With Input Power Less Than 125 W
a. Sample of Consumers
b. Operating Hours
2. Fans With Input Power Greater Than or Equal to 125 W
a. Sample of Consumers
[[Page 62039]]
b. Operating Hours
G. Life Cycle Cost and Payback Period Analyses
1. Equipment Price
2. Installation, Repair and Maintenance Costs
3. Energy Prices
4. Lifetime
5. Discount Rates
6. Efficiency Distribution in the No-New Standards Case
H. National Impact Analysis
1. Base Year Shipments
2. Shipments Projections
3. Equipment Efficiency Trends
III. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
IV. Approval of the Office of the Secretary
Introduction
A. Authority
The Energy Policy and Conservation Act, as amended (EPCA),\1\
authorizes DOE to regulate the energy efficiency of a number of
consumer products and certain industrial equipment. (42 U.S.C. 6291-
6317) Title III, Part C \1\ of EPCA, added by Public Law 95-619, Title
IV, section 441(a) (42 U.S.C. 6311-6317 as codified), established the
Energy Conservation Program for Certain Industrial Equipment, which
sets forth a variety of provisions designed to improve energy
efficiency.
---------------------------------------------------------------------------
\1\ For editorial reasons, upon codification in the U.S. Code,
Part C was redesignated Part A-1 and hereafter referred to as Part
A-1.
---------------------------------------------------------------------------
EPCA specifies a list of equipment that constitutes covered
equipment (hereafter referred to as ``covered equipment'').\2\ EPCA
also provides that ``covered equipment'' includes any other type of
industrial equipment for which the Secretary of Energy (``Secretary'')
determines inclusion is necessary to carry out the purpose of Part A-1.
(42 U.S.C. 6311(1)(L), 6312(b)) EPCA specifies the types of industrial
equipment that can be classified as covered in addition to the
equipment enumerated in 42 U.S.C. 6311(1) This industrial equipment
includes fans and blowers. (42 U.S.C. 6311(2)(B)(ii) and (iii))
Additionally, industrial equipment must be of a type that consumes, or
is designed to consume, energy in operation; is distributed in commerce
for industrial or commercial use\4\; and is not a covered product as
defined in 42 U.S.C. 6291(a)(2) other than a component of a covered
product with respect to which there is in effect a determination under
42 U.S.C. 6312(c). (42 U.S.C. 6311(2)(A)) On August 19, 2021, DOE
published a final determination that the inclusion of fans and blowers
as covered equipment was necessary to carry out the purpose of Part A-1
and classified fans and blowers as covered equipment. 86 FR 46579,
46588. Air circulating fans are a class of fans and blowers.
---------------------------------------------------------------------------
\2\ ``Covered equipment'' means one of the following types of
industrial equipment: Electric motors and pumps; small commercial
package air conditioning and heating equipment; large commercial
package air conditioning and heating equipment; very large
commercial package air conditioning and heating equipment;
commercial refrigerators, freezers, and refrigerator-freezers;
automatic commercial ice makers; walk-in coolers and walk-in
freezers; commercial clothes washers; packaged terminal air-
conditioners and packaged terminal heat pumps; warm air furnaces and
packaged boilers; and storage water heaters, instantaneous water
heaters, and unfired hot water storage tanks. (42 U.S.C. 6311(1)(A)-
(K))
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The energy conservation program under EPCA consists essentially of
four parts: (1) testing, (2) labeling, (3) energy conservation
standards, and (4) certification and enforcement procedures. Relevant
provisions of EPCA include definitions (42 U.S.C. 6311), test
procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315),
energy conservation standards (42 U.S.C. 6313), and the authority to
require information and reports from manufacturers. (42 U.S.C. 6316, 42
U.S.C. 6296)
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede state laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6316(a) and (b); 42 U.S.C. 6297) DOE may, however, grant waivers
of federal preemption for particular state laws or regulations, in
accordance with the procedures and other provisions of EPCA. (42 U.S.C.
6316(b)(2)(D))
In proposing new standards, DOE must evaluate a proposal against
the criteria detailed in 42 U.S.C. 6295(o), discussed further in
section I.C of this document, and follow the rulemaking procedures set
out in 42 U.S.C. 6295(p). (42 U.S.C. 6316(a))
DOE is publishing this NODA to collect data and information to
inform its decision consistent with its obligations under EPCA.
B. Deviation From Appendix A
In accordance with Section 3(a) of appendix A to subpart C of 10
CFR part 430, DOE notes that it is deviating from that appendix's
provision requiring a 75-day comment period for all pre-NOPR standards
documents. (Section 6(d)(2) of appendix A to subpart C of 10 CFR part
430) DOE is instead providing a 45-day comment period which DOE
believes is appropriate given the substantial stakeholder engagement to
date, as discussed in section I.C of this document. The request for
information on air circulating fans published on February 8, 2022,
provided early notice to interested parties that the Department was
interested in evaluating potential energy savings for this equipment.
87 FR 7048. Further, a 45-day comment period will allow DOE to review
comments received in response to this NODA and use it to inform the
analysis of equipment considered in evaluating potential energy
conservation standards.
C. Background
On June 28, 2011, DOE published a notice of proposed coverage
determination proposing that fans, blowers, and fume hoods would
qualify as covered equipment under EPCA. 76 FR 37678. DOE noted that
there were no statutory definitions for ``fan,'' ``blower,'' or ``fume
hood,'' and presented definitions for consideration. 76 FR 37678,
37679. DOE subsequently published a framework document on February 1,
2013, detailing the analytical approach for developing potential energy
conservation standards for commercial and industrial fans and blowers
should the Secretary classify such equipment as covered equipment
(``Framework Document''). 78 FR 7306. In the Framework Document, DOE
determined that it lacked authority to establish energy conservation
standards for fume hoods because fume hoods are not listed as a type of
equipment for which DOE could establish standards. (Docket EERE-2013-
BT-STD-0006, No. 1 at p. 15) DOE acknowledged that the fan, which
provides ventilation for the fume hood, consumes the largest portion of
energy within the fume hood system, and that DOE planned to cover all
commercial and industrial fan types, which included fans used to
ventilate fume hoods. Id.
On December 10, 2014, DOE published a NODA presenting an analysis
estimating the economic impacts and energy savings from potential
energy conservation standards for certain fans and blowers. This
analysis did not include air circulating fans. 79 FR 73246.
On April 1, 2015, DOE published a notice of intent to establish an
Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC)
Working Group for fans (hereafter referred to as the ``Working
Group''). 80 FR 17359.
The Working Group \3\ commenced negotiations at an open meeting on
May
[[Page 62040]]
18, 2015 and held 16 meetings and three webinars to discuss scope,
metrics, test procedures, and standard levels for fans and blowers.\4\
The Working Group concluded its negotiations on September 3, 2015, and,
by consensus vote,\5\ approved a term sheet containing 27
recommendations related to scope, test procedure and energy
conservation standards (``term sheet''). (See Docket No. EERE-2013-BT-
STD-0006, No. 179) ASRAC approved the term sheet on September 24, 2015.
(Docket No. EERE-2013-BT-NOC-0005; Public Meeting Transcript, No. 58,
at p. 29) The Working Group term sheet recommended the exclusion of air
circulating fans. (See Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #2 at p. 2) On November 1, 2016, DOE published a third
notification of data availability (``November 2016 NODA'') that
presented a revised analysis for fans and blowers other than air
circulating fans, consistent with the scope and metric recommendations
of the term sheet. 81 FR 75742.
---------------------------------------------------------------------------
\3\ The Working Group was comprised of representatives from
AAON, Inc.; AcoustiFLO LLC; AGS Consulting LLC; Air Movement and
Control Association (AMCA); Air Conditioning, Heating, and
Refrigeration Institute (AHRI), Appliance Standards Awareness
Project (ASAP); Berner International Corp; Buffalo Air Handling
Company; Carnes Company; Daikin/Goodman; ebm-papst; Greenheck;
Morrison Products; Natural Resources Defense Council; Newcomb &
Boyd; Northwest Energy Efficiency Alliance; CA IOUs; Regal Beloit
Corporation; Rheem Manufacturing Company; Smiley Engineering LLC
representing Ingersoll Rand/Trane; SPX Cooling Technologies/CTI; The
New York Blower Company; Twin City Companies, Ltd; U.S. Department
of Energy; and United Technologies/Carrier.
\4\ Details of the negotiation sessions can be found in the
public meeting transcripts that are posted to the docket for the
energy conservation standard rulemaking at: www.regulations.gov/docket?D=EERE-2013-BT-STD-0006.
\5\ At the beginning of the negotiated rulemaking process, the
Working Group defined that before any vote could occur, the Working
Group must establish a quorum of at least 20 of the 25 members and
defined consensus as an agreement with less than four negative
votes. Twenty voting members of the Working Group were present for
this vote. Two members (Air Conditioning, Heating, and Refrigeration
Institute and Ingersoll Rand/Trane) voted no.
---------------------------------------------------------------------------
On January 10, 2020, DOE received a petition from the Air Movement
and Control Association, International (``AMCA''), Air Conditioning
Contractors of America, and Sheet Metal & Air Conditioning Contractors
of America requesting that DOE establish a test procedure for certain
categories of fans based on an upcoming industry test method, AMCA
Standard 214, ``Test Procedure for Calculating Fan Energy Index (FEI)
for Commercial and Industrial Fans and Blowers'' DOE published a notice
of petition for rulemaking and request for public comment (``April 2020
Notice of Petition for Rulemaking''). 85 FR 22677 (Apr. 23, 2020).
AMCA, Air Conditioning Contractors of America, and Sheet Metal & Air
Conditioning Contractors have since withdrawn their petition (EERE-
2011-BT-DET-0045-00012, at p. 1)
In conjunction with this notice of petition for rulemaking, on May
10, 2021, DOE published a request for information requesting comments
on a potential fan or blower definition. 86 FR 24752. On August 19,
2021, DOE published in the Federal Register a final coverage
determination classifying fans and blowers as covered equipment. 86 FR
46579.
On October 1, 2021, DOE published a request for information
pertaining to test procedures for fans and blowers (``October 2021 TP
RFI''). 86 FR 54412. As part of the October 2021 TP RFI, DOE discussed
the potential scope and definitions for air circulating fans. 86 FR
54412, 54414-54415. DOE is considering including air circulating fans
in its analysis of potential energy conservation standards for fans and
blowers. As noted previously, air circulating fans were not included in
the scope of the term sheet and were not previously analyzed by the
Department. DOE published a separate request for information on
February 8, 2022, to seek input to aid in the development of the
technical and economic analyses regarding whether standards for air
circulating fans may be warranted (hereinafter referred to as the ``ECS
RFI''). 87 FR 7048. DOE received comments in response to the ECS RFI
from the interested parties listed in Table I-1.
Table I-1--List of Commenters With Written Submissions in Response to the ECS RFI
----------------------------------------------------------------------------------------------------------------
Comment No. in
Commenter(s) Reference in this NODA the Docket Commenter type
----------------------------------------------------------------------------------------------------------------
Air Movement and Control Association.... AMCA...................... 9,10 Trade Association.
Appliance Standards Awareness Project, Joint Commenters.......... 6 Efficiency Organizations.
American Council for an Energy
Efficient Economy, Natural Resources
Defense Council, and Northwest Energy
Efficiency Alliance.
California Investor-Owned Utilities..... CA IOUs................... 7 Utility.
ebm-papst Inc........................... ebm-papst................. 8 Manufacturer.
Robert Akscyn........................... Akscyn.................... 2 Individual.
Rub[eacute]n Guerra..................... Guerra.................... 3 Individual.
----------------------------------------------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\6\
Comments received from the two individuals listed in Table I-1 are not
discussed further in because they were either not relevant to the RFI
or provide procedural recommendations.\7\ \8\
---------------------------------------------------------------------------
\6\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for fans and blowers. (Docket No.
EERE-2022-BT-STD-0002, which is maintained at www.regulations.gov)
The references are arranged as follows: (commenter name, comment
docket ID number, page of that document).
\7\ A comment from R. Guerra stated that they own a residential
ceiling fan that produces its own energy (Guerra, No. 3 at p. 1).
DOE notes that the fans evaluated in this rulemaking exclude both
ceiling fans and furnace fans.
\8\ R. Akscyn recommended that DOE provide a short RFI summary
so stakeholders do not have to review such lengthy documents and
that DOE consider presenting the variables included in its analyses
in terms of dimensional parameters. (Akscyn, No. 2 at pp. 1-3) DOE
appreciates these suggestions. With respect to the structure and
length of RFIs, DOE notes that it has certain legal obligations
which it must fulfill for every document that is published. In most
documents, DOE includes summaries and headings to aid stakeholder
review. Additionally, DOE notes that the purpose of an RFI is to
collect data and information. The purpose of this document is to
present DOE's analyses to support potential energy conservation
standards for fans and blowers.
---------------------------------------------------------------------------
Some of the comments received in response to the ECS RFI were
related to the fans and blower test procedure. DOE published a proposed
test procedure for fans and blowers on July 25, 2022 (``July 2022 TP
NOPR'') in which it addressed the ECS RFI comments related to test
procedure issues, including those related to definitions, scope of the
test procedure, and metrics. 87 FR 44194.
To date, DOE has not proposed energy conservation standards for
fans and
[[Page 62041]]
blowers, including air circulating fans. This NODA presents DOE's
planned inputs and preliminary analysis to inform the development of
potential energy conservation standards for air circulating fans. As
previously discussed, DOE previously published and received public
comment on three NODAs for fans and blowers, excluding air circulating
fans. DOE plans to rely on the existing analysis from the Working Group
for fans and blowers other than air circulating fans. This NODA focuses
exclusively on air circulating fans and is intended to support DOE as
it completes a notice of proposed rulemaking analysis for all fans and
blowers, including air circulating fans. While the discussion in this
NODA is specific to air circulating fans, DOE welcomes additional
comments and data on fans and blowers other than air circulating fans
relevant to its analysis of any potential energy conservation standards
for all fans and blowers. In addition, DOE may consider conducting a
separate rulemaking specific to air circulating fans instead of
including air circulating fans as part of the fans and blowers
rulemaking.
II. Summary of the Analyses Performed by DOE
This NODA focuses exclusively on air circulating fans and is
intended to support DOE as it completes the notice of proposed
rulemaking analysis for all fans and blowers, including air circulating
fans. This NODA discusses the following for air circulating fans: (1)
scope; (2) technology options; (3) engineering analysis; (4) markups
analysis; (5) energy use analysis; (6) life cycle cost (``LCC'') and
payback period (``PBP'') analyses; and (7) national impacts analysis.
The items listed in Table II-1 provide an overview of the information
about which DOE is requesting feedback. A supplemental spreadsheet
documenting the assumptions and approach to the engineering analysis is
included in the docket and accessible via the equipment rulemaking
website. (See https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=51&action=viewlive)
Table II-1--Overview of Data Presented in This NODA
------------------------------------------------------------------------
Analysis Data presented
------------------------------------------------------------------------
Scope.................................. Scope of equipment considered
in the analysis of any
potential energy conservation
standards and related
definitions.
Technology Options..................... More efficient motors.
Improved aerodynamic design
(inclusive of blade shape and
material selection).
Engineering Analysis................... Representative sizes.
Determination of baseline fan
efficiency.
Determination of efficiency
levels by applying different
technology options.
Estimates for manufacturer
production cost and
manufacturer conversion cost
at each efficiency level.
Manufacturer markup.
Markups Analysis....................... Distribution channels.
Fraction of sales going through
each channel.
Distribution channel markups
and sales tax.
Energy Use Analysis.................... Average operating hours per
day.
Distribution of operating
hours.
Fraction of time spent in each
mode (i.e., speed setting).
Life Cycle Costs and Payback Period Review of repair, installation,
Analysis. and repair practices and
costs.
Energy prices.
Lifetimes of air circulating
fans.
Discount rates.
Review of available data to
determine efficiency
distributions.
National Impact Analysis............... Base year shipments.
Shipments growth rates and
information related to
shipments projections.
Information related to
efficiency trends.
------------------------------------------------------------------------
A. Scope
As stated previously, the July 2022 TP NOPR discussed potential
scope and definitions for air circulating fans, which include unhoused
air circulating fan heads and housed air circulating fan heads. 87 FR
44194. In the July 2022 TP NOPR, DOE proposed that the test procedure
would be applicable to all air circulating fans and proposed to define
an air circulating fan as a fan that has no provision for connection to
ducting or separation of the fan inlet from its outlet using a pressure
boundary, operates against zero external static pressure loss, and is
not a jet fan. 87 FR 44194, 44215.
DOE is considering including all air circulating fans in its
analysis of potential energy conservation standards for fans and
blowers. This includes unhoused air circulating fan head and housed air
circulating fan head, for which DOE proposed definitions as part of the
July 2022 TP NOPR (87 FR 44194, 44216).
In the July 2022 TP NOPR, DOE also provided definitions for subsets
of housed air circulating fan heads, specifically air circulating axial
panel fans, box fans, cylindrical air circulating fans, and housed
centrifugal air circulating fans. 87 FR 44194, 44216.
DOE notes that the definitions used in this NODA are aligned with
the proposed definitions in the July 2022 TP NOPR, which in turn were
derived from definitions proposed by the AMCA. In response to the ECS
RFI, AMCA provided additional comments to the docket on July 7, 2022,
summarizing definitions to terms under consideration by the committee
revising the ANSI/AMCA 230-15 standard, ``Laboratory Methods of Testing
Air Circulating Fans for Rating and Certification'' (``AMCA 230-15'').
(AMCA, No. 10, p. 1) AMCA's comments focused on definitions for
different categories of air circulating fans and provided context for
how air circulating fans might be grouped. (AMCA, No. 10, pp. 1-10) DOE
will further address the scope and definitions of air circulating fan
categories in the test procedure rulemaking and plans to consider
AMCA's comments as part of the test procedure rulemaking.
DOE also notes that in response to the ECS RFI, the Joint
Commenters expressed their support for establishing energy conservation
standards for air
[[Page 62042]]
circulating fans, including air circulating fan heads, box fans,
personnel coolers, and table fans. (Joint Commenters, No. 6 at p. 1)
Additionally, the Joint Commenters agreed that, based on the definition
fans and blowers, air circulating fan heads, box fans, personnel
coolers, and table fans are within the scope of the fans and blowers
equipment category. Id. Additionally, ebm-papst supported the inclusion
of air circulating fans in the DOE test procedure and energy
conservation standards for fans and blowers. (ebm-papst, No. 8 at p. 2)
During the public meeting held for the July 2022 TP NOPR, AMCA
commented that they believed it would be best to separate air
circulating fans into a separate rulemaking from fans and blowers.
(Public Meeting Transcript, EERE-2021-BT-TP-0021, No. 18 at pp. 12, 27,
43-44) Morrison Products supported AMCA's position that air circulating
fans should be considered in a separate rulemaking. (Public Meeting
Transcript, No. 18 at pp. 91-92) DOE has reviewed existing regulatory
definitions and market materials and believes that air circulating fans
fall within the definition of fans and blowers. DOE will review
stakeholder comments and may consider a separate rulemaking for air
circulating fans.
B. Technology Options
In the ECS RFI, DOE presented improved aerodynamic design, blade
shape, more efficient motors, material selection, and variable-speed
drives as potential technology options for air circulating fans and
requested comment on: (1) how the specific technologies would impact
air circulating fan efficiency; (2) whether the technologies listed
apply equally to different categories of air circulating fans; (3) the
impact of curved blades and airfoil blades on air circulating fan
efficiency; (4) the impact of blade materials on fan efficiency; and
(5) the percentage of air circulating fans sold with a motor and with
variable-speed drive. 87 FR 7048, 7052.
In response, the Joint Commenters urged DOE to consider more
efficient motors and more efficient blade designs in its analysis
because of their energy savings potential. (Joint Commenters, No. 6 at
p. 2) Specifically, they stated that alternating current (``AC'')
direct-drive motors offer better efficiency than belt drives and that
direct current (``DC'') motors are more efficient than AC motors. Id.
They added that more advanced blade designs, such as airfoil blades,
can improve the efficiency of a fan relative to traditional single-
thickness blades. Id. emb-papst commented that to improve fan
efficiency, inlet cones or bells and outlet vanes are occasionally
included on air circulating fan housings and that winglets and rings
are sometimes used on impellers. (ebm-papst, No. 8 at p. 3)
Additionally, ebm-papst stated that the most efficient air circulating
fans on the market (maximum available technology or ``max-tech'') often
include the following features: an electronically commutated motor
(``ECM''), injection-molded axial impellers, and outlet guide vanes.
(ebm-papst, No. 8 at p. 4) Finally, ebm-papst commented that they are
unaware of any air circulating fans that are sold without a motor.
(ebm-papst, No. 8 at p. 3)
During manufacturer interviews,\9\ many manufacturers stated that
they would switch to more efficient motors before redesigning the
housing and impeller (i.e., the blade assembly), since fan redesign
results in significant conversion costs. However, improving the overall
fan aerodynamics with the addition of attachments, such as inlet cones
or outlet vanes might be done before moving to higher efficiency and
more costly motors.
---------------------------------------------------------------------------
\9\ DOE conducted manufacturer interviews specific to air
circulating fans from May 24 to May 31, 2022, to gather information
for its analyses presented in this NODA. Four manufacturers opted to
participate in these interviews.
---------------------------------------------------------------------------
DOE is not aware of any circulating fans that were distributed in
commerce without an electric motor. Based on review of the
Bioenvironmental and Structural System Laboratory (``BESS Labs'')
database and air circulating fan teardowns, most motors paired with air
circulating fans are not currently in the scope of DOE energy
conservation standards (because they are split-phase (``SP'') motors
and permanent split capacitor (``PSC'') motors).\10\ As such, DOE
expects that, in many cases, fan manufacturers are using lower
efficiency motors. Therefore, in this NODA, DOE's analysis focuses
primarily on improving air circulating fan efficiency through the use
of more efficient motors, as described in more detail in section
II.D.3.c. DOE also evaluates the efficiency gains and relative costs
associated with fan aerodynamic redesign. Notably, DOE is conducting a
separate energy conservation rulemaking for electric motors in which it
is considering standards for certain single-speed SP electric motors,
single-speed shaded pole electric motors, and single-speed PSC motors.
(See Docket No. EERE-2020-BT-STD-0007) The Department will consider any
outcome of the electric motors rulemaking when conducting its analysis
of potential energy conservation standards for air circulating fans.
---------------------------------------------------------------------------
\10\ SP and PSC motors are types of single-phase motors that are
not currently included in the scope of electric motors at 10 CFR
431.25 because only polyphase motors are included in this scope. SP
and PSC motors are not currently included in the scope of small
electric motors at 10 CFR 431.441 because they do not meet the
statutory definition of ``small electric motor'' as defined at 10
CFR 431.442. In March 2022, DOE published a preliminary analysis for
the ongoing energy conservation standards rulemaking for electric
motors that included SP and PSC motors in its analysis. 87 FR 11650.
---------------------------------------------------------------------------
Issue 1: DOE requests comment on its assumption that most motors
paired with air circulating fans are lower efficiency induction motors
that are not currently regulated by DOE. Additionally, DOE requests
data on the percentage of air circulating fans that include a SP, PSC,
shaded pole, or electronically commuted motors.
C. Screening Analysis
DOE uses the following five screening criteria to determine which
technology options are suitable for further consideration in an energy
conservation standards rulemaking: (1) Technological feasibility; (2)
Practicability to manufacturer, install, and service; (3) Impacts on
product utility or product availability; (4) Adverse impacts on health
or safety; and (5) Unique pathway proprietary technologies. 10 CFR part
430, subpart C, appendix A, sections 6(b)(3) and 7(b). If DOE
determines that a technology, or a combination of technologies, fails
to meet one or more of the listed five criteria, it will be excluded
from further consideration in the engineering analysis.
DOE did not conduct a screening analysis for this NODA and instead
is presenting analyses for more efficient motors with efficiency and
cost estimates for aerodynamic redesign in order to receive stakeholder
feedback. In future analysis to support this rulemaking, DOE may screen
out some or all of the technologies discussed based on one or more of
the screening criteria.
Issue 2: DOE requests comment on if or how the five screening
criteria may impact the application of an aerodynamic redesign
(including changes to housing, impeller and/or blade design), more
efficient motors, or VSDs (``variable-speed drives'') as design options
in the current rulemaking analysis.
D. Engineering Analysis
The purpose of the engineering analysis is to determine the
incremental manufacturing cost associated with producing products at
higher efficiency
[[Page 62043]]
levels. The primary considerations in the engineering analysis are the
selection of efficiency levels to analyze (i.e., the ``efficiency
analysis'') and the determination of product cost at each efficiency
level (i.e., the ``cost analysis'').
DOE conducts the efficiency analysis using either an efficiency-
level approach, a design option approach, or a combination of both.
Under the efficiency-level approach, the efficiency levels to be
considered in the analysis are determined based on the market
distribution of existing products (in other words, observing the range
of efficiency and efficiency-level ``clusters'' that already exist on
the market). This approach typically starts with compiling a
comprehensive list of products available on the market, such as from
DOE's product certification database. Next, the list of models is
ranked by efficiency level from lowest to highest, and DOE typically
creates a scatter plot to visualize the distribution of efficiency
levels. From these rankings and visual plots, efficiency levels can be
identified by examining clusters of models around common efficiency
levels. The maximum efficiency level currently available on the market
can also be identified.
Under the design option approach, the efficiency levels to be
considered in the analysis are determined through detailed engineering
calculations and/or computer simulations of the efficiency improvements
from implementing specific design options that have been identified in
the technology assessment. In an iterative fashion, design options can
also be identified during product teardowns, described below. The
design option approach is typically used when a comprehensive database
of certified models is unavailable (for example, if a product is not
yet regulated) and therefore the efficiency-level approach cannot be
used.
In certain rulemakings, the efficiency-level approach (based on
actual products on the market) will be extended using the design option
approach to define ``gap fill'' levels (levels that bridge large gaps
between other identified efficiency levels) and/or to extrapolate to
the ``max-tech'' level (the level that DOE determines is the maximum
achievable efficiency level), particularly in cases where the ``max-
tech'' level exceeds the maximum efficiency level currently available
on the market.
The cost analysis portion of the engineering analysis is conducted
using one or a combination of cost approaches. The selection of the
cost approach depends on a variety of factors such as the availability
and reliability of information on product features and pricing, the
physical characteristics of the regulated product, and the
practicability of purchasing the product on the market. DOE generally
uses the following cost approaches:
Physical teardown: Under this approach, DOE physically dismantles a
commercially available product, component-by-component, to develop a
detailed bill of materials (``BOM'') for the product.
Catalog teardown: In lieu of physically deconstructing a product,
DOE identifies each component using available parts diagrams (available
from manufacturer websites or appliance repair websites, for example)
to develop the BOM for the product.
Price surveys: If neither a physical nor catalog teardown is
feasible (for example, for tightly integrated products that are
infeasible to disassemble and for which parts diagrams are
unavailable), DOE conducts retail price surveys by scanning retailer
websites and other marketing materials. This approach must be coupled
with assumptions regarding distributor markups and retailer markups in
order to estimate the actual manufacturing cost of the product.
Manufacturer interviews: DOE may conduct voluntary interviews with
manufacturers to gather confidential information that can be used in
its analyses. This information can include manufacturing costs,
materials prices, and markups that can be used in DOE's cost analysis.
The engineering analysis conducted for this NODA used a design
option approach supplemented by an efficiency level approach. The cost
analysis relied on physical and catalog tear downs, cost analyses from
other rulemakings, and confidential information provided by
manufacturers.
1. Methodology
The engineering analysis presented in this NODA is consistent with
the scope, definitions, and metric proposed in the July 2022 TP NOPR
for all fans (including air circulating fans), except where described
below.
a. Metric
In the July 2022 TP NOPR, DOE proposed to use the fan energy index
(``FEI'') or weighted average FEI (in the case of multi-speed and
variable-speed air circulating fans) as the efficiency metric for fans
and blowers, including air circulating fans. (87 FR 44194, 44237-44238)
FEI is an index calculated using the fan electrical input power at a
given operating point, divided by the electrical input power of a
reference fan at the same operating point. The FEI allows for the
evaluation of fan or blower efficiency across a range of operating
conditions, captures the performance of the motor, transmission, or
motor controllers (if present), and enables differentiation of fans
with motors, transmissions, and motor controller with different
efficiencies. In the July 2022 TP NOPR, DOE proposed that the metric be
determined as follows: (1) for single-speed fans, FEI would be
evaluated at the single available speed and corresponding duty point;
(2) for multi-speed fans and variable-speed fans, a weighted average
FEI would be determined using a weighted average of all speeds tested.
(87 FR 44194, 44238)
DOE notes that the BESS Labs combined database does not provide
performance data for multiple speed fans at all the test speeds
proposed in the July 2022 TP NOPR. Therefore, for this NODA, DOE
evaluated potential efficiency improvements based only on high-speed
test data. Because fans are typically less efficient at their maximum
speed, DOE expects that this assumption provides a conservative
estimate of potential efficiency gains relative to the baseline. In
future analysis, DOE expects to conduct its analysis consistent with
the approach adopting in the forthcoming fans and blower test
procedure.
In the July 2022 TP NOPR, DOE also proposed FEI reference constants
for flow rate, pressure and the efficiency target for air circulating
fans. (87 FR 44194, 44230, 44232) Specifically, DOE proposed a flow
rate constant (Q0) of 3,201, and pressure constant
(P0) of 0 and an efficiency target ([eta]0) of
0.38. Id. DOE utilized these proposed constants in its calculations of
reference FEI used in the engineering analysis. In the supplemental
NODA spreadsheet included in this docket, DOE also provided performance
in terms of cubic feet per minute per watt (or CFM/W), since the FEI
metric is still relatively new. (See Docket No. EERE-2022-BT-STD-0002,
No. 11)
b. Air Circulating Fan Performance Data
AMCA stated that no air circulating fans are currently certified by
AMCA. (AMCA, No. 9 at p. 4) Additionally, AMCA commented that air
circulating fan product literature may advertise fan performance
calculated using multiple versions of the AMCA 230 standard (e.g., AMCA
230-1999, AMCA 230-2007, AMCA 230-2012, AMCA 230-2015 without errata,
and AMCA 230-15 with 2021 errata). They stated that all of these
versions, except for AMCA 230-15
[[Page 62044]]
with 2021 errata, have at least one error with respect to thrust,
volumetric flow rate, or input power. AMCA added that this is an issue
for the purchaser, either because purchasers are not aware of these
errors or because manufacturers are not required to state how air
circulating fan performance values were obtained. (Id.) AMCA also
provided a table in their response to the ECS RFI showing the
corrections made between each version of AMCA 230. (AMCA, No. 9 at p.
5, Table 1) The contents of this table are reproduced below in Table
II-2.
Table II-2--Summary of Errors and Corrections in ANSI/AMCA Standard 230
----------------------------------------------------------------------------------------------------------------
Volumetric-flow-rate
Year Thrust equation Input power
----------------------------------------------------------------------------------------------------------------
1999............................... No conversion for Incorrect--based on actual No conversion for
density. atmospheric density, but density.
calculation exaggerated by
multiplication factor of
1.414 ([radic]2).
2007............................... Conversion to standard Not calculated............. No conversion for
air density. density.
2012............................... Conversion to standard Incorrect--uses converted No conversion for
air density. thrust but actual air density.
density.
2015............................... Conversion to standard Correct--uses converted No conversion for
air density. thrust and standard air density.
density.
2015: 2021 erratum................. Conversion to standard Correct--uses converted Conversion to standard
air density. thrust and standard air air density.
density.
----------------------------------------------------------------------------------------------------------------
During interviews, manufacturers stated that data collected by BESS
Labs, associated with the University of Illinois-Champaign, is the best
source for air circulating fan data.\11\ BESS Labs maintains a database
of housed and unhoused air circulating fan heads that are used
primarily in the agricultural industry (i.e., poultry houses,
greenhouses, dairy barns). DOE notes that these air circulating fans
heads are tested by BESS Labs according to AMCA 230-12. DOE used the
BESS Labs test data and applied conversion formulas to calculate the
performance data of the fans according to AMCA 230-15 with 2021 errata.
Details of these performance calculations are available in the
supplementary spreadsheet attached to this docket. (EERE-2022-BT-STD-
0002, No. 11)
---------------------------------------------------------------------------
\11\ BESS Labs is a research, product-testing and educational
laboratory. BESS Labs provides engineering data to air in the
selection and design of agricultural buildings and assists equipment
manufactures in developing better products. Test reports for
circulating fans are publicly available at bess.illinois.edu/current.asp.
---------------------------------------------------------------------------
DOE did not receive sufficient air circulating fan performance data
from the ECS RFI stakeholder comment responses or from manufacturers
during the interview process. Therefore, for this analysis, DOE relied
primarily on the BESS Labs circulating fans database (``BESS Labs
Database''). The BESS Labs Database categorizes circulating fans into
the following categories: basket, box, panel, tube, tube with bell
inlet, vented tube, wire basket, and wire tube.
Based on the proposed definitions discussed in section II.A, DOE
mapped the categories in the BESS Labs Database as shown in Table II-3.
Table II-3--DOE Categorization of BESS Labs Database Circulating Fan
Categories
------------------------------------------------------------------------
July 2022 TP NOPR terminology BESS labs database category
------------------------------------------------------------------------
Unhoused air circulating fan head......... Basket.
Housed air circulating fan head
Box fan............................... Box.
Cylindrical air circulating fan....... Tube, Tube with Bell Inlet,
Vented Tube.
Air circulating axial panel fan....... Panel.
------------------------------------------------------------------------
For this initial analysis, DOE evaluated unhoused air circulating
fan heads, box fans, and cylindrical air circulating fans.\12\ DOE
expects that the technology options evaluated in its analysis of these
fans would be applicable to air circulating axial panel fans,
especially improved motor efficiency. DOE expects that it will conduct
additional analysis on air circulating axial panel fans in a subsequent
part of this rulemaking.
---------------------------------------------------------------------------
\12\ The BESS Labs Database classifies circulating fans as
basket, box, panel, tube, tube with bell inlet, vented tube, wire
basket, and wire tube fans. DOE evaluated 58 box fans (housed
circulating fan heads) and 40 tube fans (housed air circulating fan
heads) and 102 basket fans (unhoused air circulating fan heads) in
the BESS Labs Database, accessed on June 17, 2022.
---------------------------------------------------------------------------
DOE further notes that the BESS Lab Database did not include any
housed centrifugal air circulating fans. DOE expects that it will
conduct additional analysis on housed centrifugal air circulating fans
in a subsequent part of this rulemaking. In addition, the BESS Labs
Database includes very few air circulating fans with input power less
than 125 W. DOE expects that it will conduct additional analysis on air
circulating fans with input power less than 125 W in a subsequent part
of this rulemaking.
To further inform its analysis, DOE completed testing and teardowns
on a small sample of housed and unhoused air circulating fan heads.\13\
For this analysis, DOE is assuming that the combination of housed and
unhoused air circulating fan heads listed in the BESS Labs Database and
those additional fans that DOE tested at BESS Labs (``BESS Labs
Combined Database'') are representative of the air circulating fan head
market. However, the air circulating axial panel fans in the BESS Labs
database were excluded from DOE's analysis and housed centrifugal air
circulating fans and air circulating fans with input power less than
125 W
[[Page 62045]]
were not represented in the BESS Labs Combined Database.
---------------------------------------------------------------------------
\13\ DOE tested seven basket fans (unhoused air circulating fan
heads) and 11 tube fans (housed air circulating fan heads) and two
box fans (housed air circulating fans heads) at BESS Labs. Where DOE
has relied on the test data from these fans in addition to the BESS
Labs Database, DOE has used the term ``BESS Labs Combined
Database''.
---------------------------------------------------------------------------
Issue 3: DOE requests comment on its assumption that the BESS Labs
Combined Database is representative of the air circulating fan head
market, with the exception of housed centrifugal air circulating fans
and air circulating fans with input power less than 125 W which are not
represented in the BESS Labs Combined Database.
Issue 4: DOE requests additional information for all categories of
air circulating fans, including: manufacturer name, model number, fan
diameter, blade number, blade shape, blade material, housing type,
housing material, spacing between the blade tip and the housing, and
housing depth with associated performance data obtained using AMCA 230-
15 with 2021 errata (or sufficient information that can be used to
correct to AMCA 230-15 with 2021 errata). DOE additionally requests the
following information on the motors sold within each fan model: motor
type (i.e., SP, PSC, ECM, polyphase, etc.), type of drive (i.e., direct
or belt), motor horsepower (``hp''), motor full-load efficiency (if
available), motor rotations per minute, number of speeds, motor
electric requirements (i.e., volts, amps, frequency, phase, AC/DC), and
whether a variable-speed drive is included with the fan.
The minimum and maximum diameter housed and unhoused air
circulating fan heads in the BESS Labs Combined Database are 12 inches
and 52 inches, respectively. Although DOE did not evaluate fans smaller
or larger than these diameters in this NODA, in the absence of
additional data, DOE may consider extrapolating BESS Labs data to
smaller and larger diameters using fan affinity laws to the extent such
extrapolation is representative of the performance of such fans.
Issue 5: DOE requests comment on the potential of using fan
affinity laws to extrapolate BESS Labs performance data to air
circulating fan heads with diameters less than 12 inches and greater
than 52 inches. Additionally, DOE requests model characteristics and
performance data obtained using AMCA 230-15 plus 2021 errata (or
sufficient information than can be used to correct to AMCA 230-15 plus
2021 errata) for air circulating fans with diameters both smaller than
and larger than those listed in the BESS Labs Database.
2. Equipment Classes and Representative Sizes
In the ECS RFI, DOE requested comment on whether it should consider
air circulating fan heads, personnel coolers, box fans, and table fans
as separate categories (i.e., equipment classes) or whether some or all
of these four categories should be grouped together when evaluating
potential energy conservation standards for air circulating fan heads.
87 FR 7048, 7051. DOE additionally requested whether these four fan
categories have unique features or applications that might warrant
separate consideration in the energy standards analysis. Id. Finally,
DOE requested comment on whether it should consider separate equipment
classes for air circulating fan heads based on diameter, operating
speed, efficiency, or utility. Id.
The Joint Commenters stated that portable blowers may require an
equipment class separate from air circulating fans because they provide
a unique application (i.e., drying floors), have centrifugal rather
than axial construction, and are relatively low in efficiency. (Joint
Commenters, No. 6 at p. 2) In the July 2022 TP NOPR, DOE proposed a
definition for ``housed centrifugal air circulating fan'', which it
believes is the same fan type that the Joint Commenters describe as a
portable blower. 87 FR 44194, 44216. As discussed in section II.D.2.a,
however, DOE has not yet finalized equipment classes for air
circulating fans. DOE is requesting additional information and data on
the utility of different fan categories to further inform its analysis.
AMCA commented that air circulating fan heads, box fans, personnel
coolers, and table fans all provide directional airflow. (AMCA, No. 9
at p. 2) ebm-papst indicated that designing an air circulating fan for
high outlet velocity may be an impediment to achieving greater fan
efficiency. (ebm-papst, No. 8 at p. 3) DOE interprets this comment to
mean that the utility of an air circulating fan (i.e., a fan designed
for high outlet velocity vs. more diffuse flow) may impact its
efficiency.
a. Equipment Classes
When evaluating and establishing energy efficiency standards, DOE
often divides covered equipment into separate classes by the type of
energy used, equipment capacity, or some other performance-related
features that justify differing standards. In deciding whether a
performance-related feature justifies a different standard, DOE
generally considers such factors as the utility of the feature to the
consumer and other factors DOE determines are appropriate. (42 U.S.C.
6295(q) and 6316(a))
DOE has not yet identified equipment classes for air circulating
fans, but is considering the following performance-related features
that may justify separate equipment classes:
(1) Presence or absence of a safety guard;
(2) Presence or absence of housing;
(3) Housing design (i.e., box, panel, cylindrical, bladeless,
thermal, etc.);
(4) Blade type (axial, centrifugal);
(5) Drive type (belt, direct);
(6) Number of discrete speed settings (single-speed, two-speed,
three-speed, etc.);
(7) Power requirements (input power, phase, voltage, etc.); and
(8) Air velocity or throw.
For the purposes of this NODA, DOE grouped all air circulating fans
analyzed into a single equipment class.
Issue 6: DOE requests comment on whether, and if so how, each of
the following performance-related features may impact utility of air
circulating fans: presence or absence of a safety guard, presence or
absence of housing, housing design, blade type, drive type, number of
discrete speed settings, power requirements, and air velocity or throw.
DOE requests additional feedback and data or information on other air
circulating fan features that may impact utility for the end user and
might form the basis for classification.
Issue 7: DOE requests comment with supporting data on whether the
following performance-related features provide substantially different
utility, or are expected to have a significant impact on efficiency
because of how they are used: (1) housed vs. unhoused air circulating
fan heads; (2) direct-driven vs. belt-driven air circulating fan heads;
and (3) single-phase vs. polyphase air circulating fan heads. DOE also
requests information on any additional features that may impact air
circulating fan head utility.
b. Representative Sizes
The minimum and maximum diameters reported in the BESS Labs
Database for housed and unhoused air circulating fan heads are 12
inches and 52 inches, respectively. DOE notes that diameter has been
used to define representative units for ceiling fans and for previous
analyses conducted on fans and blowers that are not air circulating
fans.\14\ Therefore, DOE developed a diameter histogram using the BESS
Labs Combined Database to determine
[[Page 62046]]
representative diameters for analysis. Based on this distribution, DOE
chose the following representative diameters for its analysis in this
NODA: 12 inches, 20 inches, 24 inches, 36 inches and 50 inches. More
details on the diameter distribution can be found in the supplementary
spreadsheet included in the docket. (See Docket No. EERE-2022-BT-STD-
0002, No. 11)
---------------------------------------------------------------------------
\14\ On November 1, 2016, DOE published a notification of data
availability (``November 2016 NODA'') that presented an analysis for
fans and blowers other than air circulating fans. 81 FR 75742. The
engineering analysis evaluated manufacturer production cost as a
function of efficiency level for 10-inch, 20-inch and 30-inch
diameter fans and blowers that are not air circulating fans. See
www.regulations.gov/document/EERE-2013-BT-STD-0006-0189.
---------------------------------------------------------------------------
Issue 8: DOE requests comment on whether the diameters chosen for
representative units in this analysis (i.e., 12 inches, 20 inches, 24
inches, 36 inches, and 50 inches) accurately represent the diameters
with the highest sales volume available in the air circulating fan
market. DOE also requests comment on whether diameter is an appropriate
representative metric for air circulating fans.
For each representative diameter, DOE used the most common motor
shaft output power value in the BESS Labs Combined Database as the
representative motor hp. Table II-4 summarizes the motor hp associated
with each representative diameter in DOE's NODA analysis. More details
on the motor hp distribution can be found in the supplementary
spreadsheet included in the docket. (See Docket No. EERE-2022-BT-STD-
0002, No. 11)
Table II-4--Representative Diameters and Associated Representative Motor
Input Power Use in This Analysis
------------------------------------------------------------------------
Representative
Representative diameter (inches) motor input power
(hp)
------------------------------------------------------------------------
12................................................... 0.1
20................................................... 0.33
24................................................... 0.5
36................................................... 0.5
50................................................... 1
------------------------------------------------------------------------
Issue 9: DOE requests comment on whether the motor hp it has
associated with each representative diameter (i.e., 0.1 hp for 12
inches, 0.33 hp for 20 inches, 0.5 hp for 24 inches and 36 inches, and
1 hp for 50 inches) appropriately represent the motor hp for fans sold
with those corresponding diameters.
To simplify the discussion in this NODA, the efficiency model and
the cost model are discussed using a 24-inch representative unit. DOE's
analysis for other representative units is included in the supplemental
spreadsheet included in the docket. (See Docket No. EERE-2022-BT-STD-
0002, No. 11)
3. Efficiency Model
The efficiency model is a key analytical tool used to construct
cost-efficiency curves. This model is used to estimate efficiencies at
different efficiency levels using a design option approach supplemented
with a performance approach.
a. BESS Combined Database
DOE calculated FEI for all fans in the BESS Labs Combined Database
by correcting the BESS data for air density, consistent with AMCA 230-
15 (with 2021 errata) and using the FEI equation proposed in the July
2022 TP NOPR. 87 FR 44194, 44230, 44232. A plot of average FEI as a
function of representative diameter and number of representative units
analyzed in the BESS Labs Combined Database is shown in Figure 1.
BILLING CODE 6450-01-P
[[Page 62047]]
[GRAPHIC] [TIFF OMITTED] TP13OC22.002
BILLING CODE 6450-01-C
As shown in Figure 1, FEI ranges from 0.39 to 2.74. A plot showing
FEI for all fans in the BESS Labs Combined Database as a function of
diameter can be found in the supplemental spreadsheet attached to this
docket. (See Docket No. EERE-2022-BT-STD-0002, No. 11) FEI has minimal
variance between 20-inch and 50-inch diameter fans; however, FEI
increases sharply at diameters less than 20 inches. DOE expects this is
because the reference fan used in the FEI calculation assumes a belt-
drive. Table II-5 shows the number of direct-drive and the number of
belt-drive air circulating fans in the BESS Labs Combined Database for
each representative diameter. Relative to DOE's representative
diameters, belt-driven fans are observed only at 36 inches and 50
inches. Only at 50 inches do belt-driven fans become more prevalent in
the BESS Labs Combined Database than direct-drive fans.
Table II-5--Distribution of Direct-Drive and Belt-Drive Fans in the BESS Labs Combined Database by Diameter
----------------------------------------------------------------------------------------------------------------
Diameter (inches) Number of direct-drive Number of belt-driven Grand total
----------------------------------------------------------------------------------------------------------------
12................................... 9 0 9
20................................... 28 0 28
24................................... 37 0 37
36................................... 62 9 71
50................................... 5 22 27
----------------------------------------------------------------------------------------------------------------
DOE also reviewed the BESS Labs Combined Database to understand the
types of motors sold with air circulating fans. DOE evaluated motor
type, model, and corresponding product literature for the 20 fans in
the BESS Labs Combined Database that DOE tested, in addition to the 10
most efficient and least efficient fans in the database. DOE found that
[[Page 62048]]
every fan evaluated as part of this exercise used either a single-phase
PSC motor, a polyphase motor,\15\ or an ECM. There was only one ECM fan
in the BESS Labs Combined Database. Details of this analysis can be
found in the supplemental spreadsheet attached to this docket. (See
Docket No. EERE-2022-BT-STD-0002, No. 11)
---------------------------------------------------------------------------
\15\ Single-phase motors have a single conductor through which
the alternating current input signal is sent to the motor. Polyphase
motors have multiple conductors through which alternating current
input signals that are phase-shifted from each other are sent to the
motor.
---------------------------------------------------------------------------
DOE also compared the FEI values of fans that use single-phase and
fans that use polyphase motors in the BESS Labs Combined Database and
did not find a significant difference between the two. However, as
discussed in a notice of proposed rulemaking for dedicated purpose pool
pump motors published on June 21, 2021, DOE has previously found that
polyphase motors are generally more efficient than single-phase motors
due to differences in their construction. 87 FR 37122, 37136. For both
the efficiency and cost analyses here, DOE opted to evaluate single-
phase motor technologies only. Given that polyphase motors are
generally more efficient than single-phase motors, DOE believes this is
a more conservative approach. While DOE evaluated only single-phase
motor technologies, it utilized the FEI data of both single-phase and
polyphase motor fans in the BESS Labs Combined Database when
determining FEI values. DOE did this since this approach provided more
FEI data, and, despite the expectation that polyphase motors are
generally more efficient than single-phase motors, there was not a
significant difference in FEI between single-phase and polyphase fans
in the database.
Although the BESS Labs Combined Database lists only PSC motors and
one ECM, DOE's review of the air circulating fan market indicated that
SP motors are also used in air circulating fans. In general, SP motors
are the least efficient, ECMs are the most efficient, and PSC motor
efficiency falls between SP motors and ECMs. The efficiency of each
motor type can be improved by using higher quality steel and magnets,
or by using more magnetic material. For this analysis, DOE assumed that
the least efficient fans on the market (baseline) used SP motors and
therefore evaluated potential air circulating fan efficiency
improvements by replacing an SP motor with a PSC motor (``PSC 1''),
replacing a PSC 1 motor with a more efficient PSC motor (``PSC 2''),
and replacing a PSC 2 motor with an ECM.
Issue 10: DOE requests comment on its use of SP motors as the
baseline for air circulating fans. Additionally, DOE seeks feedback on
its choice of motor technologies (SP motor to PSC 1 motor, PSC 1 motor
to PSC 2 motor, and PSC 2 motor to ECM) to estimate air circulating fan
efficiency increases from one efficiency level to the next.
Additionally, DOE considered the efficiency gains that might be
obtained from improving the aerodynamic design of an air circulating
fan. DOE's analysis of the BESS Labs Combined Database did not indicate
that any particular aerodynamic features, including blade design or
housing/guard design, had a significant impact on air circulating fan
efficiency. However, feedback received during manufacturer interviews
indicated that blade design and housing/guard design can impact fan
efficiency. For blade design, manufacturers generally responded that
decreasing the number of fan blades, optimizing the blade shape for
efficiency, and, for housed fans, decreasing the clearance between the
blade tip and the housing can all improve the efficiency of air
circulating fans. However, manufacturers added that decreasing the
blade tip clearance can also increase the noise generated by the fan.
For unhoused air circulating fans, manufacturers stated that increasing
the spacing between wire guard wires and redesigning the motor hub
supports more efficient airflow. For housed air circulating fans,
manufacturers discussed the potential for improving fan efficiency by
adjusting the inlet and outlet geometries to improve airflow.
Table II-6 summarizes the technology options DOE analyzed for each
efficiency level.
Table II-6: Technology Options Associated with Each Efficiency Level
----------------------------------------------------------------------------------------------------------------
EL0 (baseline) EL1 EL2 EL3 EL4
----------------------------------------------------------------------------------------------------------------
SP motor............................ PSC 1 PSC 2 ECM ECM and Aerodynamic
redesign.
----------------------------------------------------------------------------------------------------------------
DOE discusses its analysis of baseline efficiency and the
efficiencies that it used in its analysis for each EL in the following
sections.
b. Baseline Fan Efficiencies
The baseline configuration represents the lowest efficiency level
commonly available in the market. Because energy conservation standards
do not currently exist for air circulating fans, DOE must establish a
baseline configuration using available information, as opposed to an
existing energy conservation standard. The baseline configuration
defines the energy consumption and associated cost for the lowest
efficiency fan analyzed in each equipment class.
DOE assumed that baseline air circulating fans use SP motors
because they are the least expensive type of air circulating fan motor
on the market. As stated in the previous section, SP motors are less
efficient than other electric motors available. Since DOE does not have
test data for air circulating fans sold with a SP motor, DOE defined
EL1 as a fan in the BESS Labs Combined Database with a PSC 1 motor.
Using data from an electric motors database compiled by the Department
(``Motors Database''), DOE established the loss in efficiency by
replacing a PSC 1 motor (EL 1) with an SP motor (EL 0 or baseline).
Data in the Motors Database include information on motor topology
(i.e., whether the motor is SP, PSC, or another type), motor enclosure
(i.e., whether the motor is enclosed \16\ or not or whether it is air-
over \17\ or not), motor hp, and motor efficiency. DOE notes that the
motors in its Motors Database are not currently subject to DOE
standards. Given that motor manufacturers are not required to certify
motor performance values to DOE, it is possible that the nominal
efficiency values presented in the catalog data are not accurate.
During its review of air circulating fan motor literature, DOE found
that every fan for which the motor enclosure type was divulged used
[[Page 62049]]
an air-over motor. Therefore, in this analysis, DOE assumed that all
motors used for air circulating fans are air-over motors, and it
considered only data for air-over SP motors and for air-over PSC motors
in the Motors Database. ECMs were not included in the Motors Database.
---------------------------------------------------------------------------
\16\ ``Enclosed'' motors are dust-tight, meaning that they
prevent the free exchange of air to the point that particulates
cannot enter the motor enclosure. ``Open'' motors allow the free
exchange of air through the motor enclosure via openings designed
for ventilation.
\17\ ``Air-over'' motors are used specifically for fans and
blowers, are placed in the pathway of the airflow, and are cooled by
the airflow.
---------------------------------------------------------------------------
To determine the differences in efficiency between SP motors and
PSC motors, DOE used SP motor and PSC motor data from the motor
database. DOE calculated the average efficiencies of SP motors and PSC
motors for each motor output value in the database, then applied best
fit curves to the average efficiency values as a function of
horsepower. DOE used these equations to estimate SP motor and PSC 1
motor efficiencies and to calculate the decrease in efficiency from PSC
1 motors to SP motors for each representative unit horsepower. Using
this approach, the efficiency decrease for the 24-inch diameter fan,
correlating to the 0.5 hp unit, is 8.3 percent. Further details of how
the efficiency difference between SP motors and PSC 1 motors was
determined and applied to the fan FEI values can be found in Section
II.D.3.c of this NODA and the supplementary spreadsheet attached to
this docket. (See Docket No. EERE-2022-BT-STD-0002, No. 11)
Issue 11: DOE requests comment on its assumption that motors used
in air circulating fans are exclusively air-over motors. If this is not
the case, DOE requests information on the other types of motors that
are sold with air circulating fans and data on the percentage of air
circulating fans that are sold with motors other than air-over motors.
Additionally, DOE requests information on whether or not the type of
motor supplied with an air circulating fan is a function of air
circulating fan category (e.g., unhoused air circulating fan head, box
fan, cylindrical air circulating fan, etc.).
To determine FEI values at EL 1, DOE established a separate FEI
value at EL1 for fans less than 20 inches in diameter and for fans
greater than or equal to 20 inches in diameter, consistent with the
average FEI values shown in Figure 1, where FEI increases significantly
below a diameter of 20 inches. Using the BESS Labs Combined Database,
DOE defined EL1 as the 5th percentile of FEI values calculated for the
12-inch representative unit (FEI = 1.70) and the 5th percentile of FEI
values calculated for all representative units with diameters at or
above 20 inches (FEI = 0.79). The 5th percentile was chosen to
conservatively capture the efficiencies of the least efficient air
circulating fans in the database, which DOE assumed also used the least
efficient PSC 1 motors, while excluding potential outliers with very
low FEI values. Further details of this analysis can be found in the
supplementary spreadsheet attached to this docket. (See Docket No.
EERE-2022-BT-STD-0002, No. 11) Since DOE estimated SP motors to be 8.3
percent less efficient than PSC 1 motors for the 24-inch, 0.5 hp
representative unit, DOE defined the baseline (EL 0) for this
representative unit at FEI = 0.73. FEI values calculated for the 24-
inch representative unit are shown in Table II-7 at the end of this
section. Further details of this analysis can be found in the
supplementary spreadsheet attached to this docket (see Docket No. EERE-
2022-BT-STD-0002, No. 11).
Issue 12: DOE requests feedback on whether catalog performance data
on SP motors and PSC motors is generally representative of the
performance of the SP and PSC motors included with air circulating
fans.
Issue 13: DOE requests feedback on the methodology used to
determine the baseline efficiency values for the representative units,
including its method of first establishing the EL1 efficiency and then
determining the baseline efficiency by reducing the EL1 efficiency by
the difference in efficiency between a PSC motor and a SP motor.
Additionally, DOE requests data on the expected average improvement in
air circulating fan efficiency when a SP motor is replaced by a PSC 1
motor.
c. Improving Efficiency With More Efficient Motors
This section describes how DOE estimated improvements in air
circulating fan efficiency by using more efficient motors.
When substituting a more efficient motor for a less efficient
motor, DOE assumed that the duty point of the fan (i.e., the fan's
airflow and pressure) remained the same, and that the only change in
motor performance was a decrease in input power. Factors such as motor
speed and inrush current were assumed to remain constant with the
change in motor. This assumption enabled DOE to assume that a percent
change in FEI is equal to a percent change in motor efficiency using
the equations defined in ANSI/AMCA Standard 214-21, ``Test Procedure
for Calculating Fan Energy Index (FEI) for Commercial and Industrial
Fans and Blowers.'' This aligns with the July 2022 TP NOPR approach for
calculating FEI. 87 FR 44194, 44230, 44232. A description of how DOE
derived this relationship is provided in the supplementary spreadsheet
attached to this docket. (See Docket No. EERE-2022-BT-STD-0002, No. 11)
Throughout the remainder of this NODA, DOE will therefore discuss
efficiency increases in terms of FEI and not in terms of motor
efficiency increases. In the future, DOE may consider performing this
analysis in terms of motor losses and shaft power, consistent with
other rulemakings. See the ceiling fans preliminary analysis published
February 9, 2022 (``Ceiling Fan Preliminary Analysis''). 87 FR 7758.
See also the electric motors preliminary analysis published March 2,
2022 (``Electric Motors Preliminary Analysis''). 87 FR 11650.
Issue 14: DOE requests feedback on its assumption that airflow,
pressure, and motor performance (for example, speed and inrush current)
remain constant when replacing a less efficient motor with a more
efficient motor in an air circulating fan. If airflow, pressure, or
motor performance are not maintained when using a more efficient motor,
DOE requests feedback and data on how it should conduct this analysis.
To determine the PSC 2 motor efficiencies, DOE again used PSC motor
data from the motor database. Rather than fitting a curve to the
average PSC motor efficiency values at each motor output power value,
as it did for the PSC 1 motor curve, DOE instead fit a curve to the
95th percentile PSC motor efficiency values. The 95th percentile was
chosen so that the efficiency values for PSC 2 motors were close to the
maximum possible PSC motor efficiencies. DOE then used this curve to
estimate PSC 2 motor efficiencies for the representative unit motor
output power values.
For the representative units in this NODA that used 0.5 hp motors,
replacing a 0.5 hp PSC 1 motor with a 0.5 hp PSC 2 motor increases the
air circulating fan FEI by 11.2 percent. The resulting FEI for the 24-
inch, 0.5 hp representative unit with a PSC 2 motor is therefore 0.88.
(See Table II-7 at the end of this section) The supplementary
spreadsheet attached to this docket provides more details on how
efficiency increases from PSC 1 motors to PSC 2 motors were determined.
(See Docket No. EERE-2022-BT-STD-0002, No. 11)
Issue 15: DOE requests feedback on whether the efficiency gains
shown in the supplementary spreadsheet are realistic efficiency gains
when replacing a lower efficiency PSC motor (i.e., PSC 1 motor) with a
higher efficiency PSC motor (i.e., PSC 2 motor). If these assumptions
are not realistic, DOE requests data demonstrating air circulating fan
motor efficiency as a function of hp, as well as data for motor hp as a
function of fan diameter.
[[Page 62050]]
To evaluate the efficiency increase when changing to an ECM, DOE
used a 2018 pool pump motor database containing information on ECMs
that was compiled by DOE in support of its dedicated purpose pool pump
rulemaking (``DPPP Motor Database''). Most motors in the DPPP Motor
Database were 1 hp and higher; therefore, DOE fit a curve to the ECM
data at each motor hp and used this curve to extrapolate the data and
estimate motor efficiencies at fractional hp for ECMs. The resulting
ECM efficiency for the 24-inch, 0.5 hp representative unit is 83.2
percent, an efficiency increase of 23.9 percent from a PSC 1 motor to
an ECM and a FEI of 0.98 at EL 3 (see Table II-7 at the end of this
section). Further details of this analysis can be found in the
supplementary spreadsheet attached to this docket. (See Docket No.
EERE-2022-BT-STD-0002, No. 11)
Issue 16: DOE requests feedback on its use of dedicated purpose
pool pump motors as a source for comparing PSC motor and ECM
efficiency. Additionally, DOE requests information on whether motors
used for this purpose are comparable to air circulating fan motors. DOE
further requests feedback on whether the efficiency increases from PSC
1 motors to ECM that DOE presents are realistic. If dedicated purpose
pool pump motors are not representative of air circulating fans motors,
or DOE's estimated efficiency increases are not realistic, DOE requests
data on the difference between PSC 1 motor efficiency and ECM
efficiency and the difference between PSC 2 motor efficiency and ECM
efficiency for air circulating fans. DOE also requests comment on its
use of extrapolation of these data to obtain efficiency values at
fractional hp.
d. Improving Efficiency Through Aerodynamic Redesign
This section describes how DOE evaluated increasing the energy
efficiency of air circulating fans by improving fan component
aerodynamic design.
While EL3 assumes that air circulating fan efficiency is increased
through the use of an ECM, EL4 evaluates the efficiency impact from
adding an ECM and improving the aerodynamic design of the fan. This
``max-tech'' level represents the highest efficiency available on the
market. The fans in the BESS Labs Combined Database used almost
exclusively PSC motors, so DOE assumed that the maximum efficiencies in
the database corresponded to the use of a PSC 2 motor with a highly
efficient aerodynamic design. Presumably, the maximum efficiencies
achieved by a fan with a PSC motor and no aerodynamic redesign would be
captured by the FEI values determined for EL 2 for each representative
unit. The efficiency gain due to improvements in aerodynamic design can
therefore be quantified by determining the difference between the
maximum FEI values in the database and the efficiency levels determined
for EL 2. DOE used the maximum FEI values in the BESS Labs Combined
Database for each representative unit to develop a curve for the PSC 2
plus aerodynamic redesign FEI values as a function of diameter. The
resulting FEI value for the 24-inch, 0.5 hp representative unit is
1.89. DOE then determined the percent increase from the EL 2 FEI values
to the FEI values determined from the curve fit to establish the
increase in efficiency due to aerodynamic redesign for each
representative unit. This percent increase for the 24-inch, 0.5 hp
representative unit was 114.39 percent. DOE then applied the percent
increases in FEI due to aerodynamic redesign to the EL 3 FEI values to
determine the EL 4 FEI values. The resulting EL 4 FEI value for the 24-
inch, 0.5 hp representative unit was 2.10. Further details of this
analysis can be found in the supplementary spreadsheet attached to this
docket. (See Docket No. EERE-2022-BT-STD-0002, No. 11)
Issue 17: DOE requests feedback on the FEI values that it
determined and its approach for estimating FEI values for an air
circulating fan that includes both an ECM and improved aerodynamic
design.
e. Results for a 24-inch, 0.5 hp Representative Unit
FEI values calculated for each efficiency level for the 24-inch,
0.5 hp representative unit are shown in Table II-7 . Information on the
FEI values calculated for other representative units can be found in
the supplementary spreadsheet attached to this docket. (See Docket No.
EERE-2022-BT-STD-0002, No. 11)
Table II-7--FEI Values for 24-Inch, 0.5 hp Representative Unit
----------------------------------------------------------------------------------------------------------------
EL0 (baseline) EL1 EL2 EL3 EL4
----------------------------------------------------------------------------------------------------------------
0.73........................................ 0.79 0.88 0.98 2.10
----------------------------------------------------------------------------------------------------------------
4. Cost Model
The cost model is a key analytical tool used to construct cost-
efficiency curves. This model is used to estimate manufacturing
production costs at various efficiency levels using a design option
approach.
a. Cost Model Structure and Process
This section describes the process by which the cost model converts
the physical information in each product's BOM into manufacturing cost
estimates. The cost model is based on production activities and divides
factory costs into materials, labor, depreciation, and overhead. The
material costs include both raw materials and purchased part costs. The
labor costs include fabrication, assembly, and indirect and overhead
(burdened) labor rates. The depreciation costs include manufacturing
equipment depreciation, tooling depreciation, and building
depreciation. The overhead costs include indirect process costs,
utilities, equipment and building maintenance, and rework. DOE lists
the cost inputs of these categories in Table II-8.
Table II-8--Cost Model Categories and Descriptions
------------------------------------------------------------------------
Major category Subcategory Description
------------------------------------------------------------------------
Material Costs.................. Direct............ Raw materials
(e.g., coils of
sheet metal) and
purchased parts
(e.g., fan
motors,
compressors).
[[Page 62051]]
Indirect.......... Material used
during
manufacturing
(e.g., welding
rods, die oil,
release media).
Manufacturing Labor............. Assembly.......... Part/unit assembly
on manufacturing
line.
Fabrication....... Conversion of raw
material into
parts ready for
assembly.
Indirect.......... Fraction of
overall labor not
associated
directly with
product
manufacturing
(e.g., forklift
drivers, quality
control).
Supervisory....... Fraction of
indirect labor
that is paid a
higher wage.
Depreciation.................... Equipment, Straight line
Conveyor, depreciation over
Building. expected life.
Tooling........... Cost is allocated
on a per-use
basis or
obsolescence,
whichever is
shorter.
Other Overhead.................. Utilities......... A fixed fraction
of all material
costs meant to
cover electricity
and other utility
costs.
Maintenance....... Based on installed
equipment and
tooling
investment.
Property Tax and A fixed fraction
Insurance. based on total
unit costs.
------------------------------------------------------------------------
To determine material costs, DOE followed one of two different
paths, depending on whether a subassembly was purchased (outsourced) or
produced in-house. For purchased parts, DOE gathered price quotations
from major suppliers at different production volumes. For parts
produced in-house, DOE reconstructed manufacturing processes for each
part using modeling software based on internal expertise. For the raw
materials being converted to ready-to-assemble parts, DOE estimated
manufacturing process parameters (manufacturing equipment use and time
for each item, the required initial material quantity, scrap, etc.) to
determine the value of each component.
Using this process, DOE was able to assign manufacturing labor
time, equipment utilization, and other important factors to each
subassembly for each unit considered in this analysis. The last step
was to convert the information into dollar values. To perform this
task, DOE collected information on such factors as labor rates, tooling
depreciation, and costs of purchased raw materials. DOE assumed values
for these parameters using internal expertise and confidential
information available to its contractors.
In sum, DOE assigned costs of labor, materials, and overhead to
each part, whether purchased or produced in-house. DOE then aggregated
single-part costs into major assemblies (e.g., for air circulating fans
this would include packaging, housing, impeller, controls and wiring,
motor, guard, and mounting gear) and summarized these costs in a
spreadsheet. All parameters related to manufacture and assembly were
then aggregated to determine facility requirements at various
manufacturing scales. The final cost obtained by the cost model is the
manufacturer production cost (``MPC''), representing the total cost to
the manufacturer of producing the component.
b. Cost Model Assumptions
Assumptions about manufacturer practices and cost structure play an
important role in estimating the MPC of the products. DOE based
assumptions about the sourcing of parts and in-house fabrication on
industry experience, information in trade publications, and discussions
with manufacturers. DOE used assumptions regarding the manufacturing
process parameters, (e.g., equipment use, labor rates, tooling
depreciation, and cost of purchased raw materials) to determine the
value of each component. The following sections describe the cost model
assumptions related to material prices, purchased parts and factory
parameters.
Raw Material Prices
For parts fabricated in-house, the prices of the underlying ``raw''
metals (e.g., tube, sheet metal) are estimated on the basis of 5-year
averages to smooth out spikes in demand. Other ``raw'' materials such
as plastic resins, insulation materials, etc. are estimated on a
current-market basis. The costs of raw materials are based on
manufacturer interviews, quotes from suppliers, and secondary research.
Past results are updated periodically and/or inflated to present-day
prices using indices from resources such as MEPS International,\18\
PolymerUpdate,\19\ the U.S. geologic survey (``USGS''),\20\ and the
Bureau of Labor Statistics (``BLS'').\21\
---------------------------------------------------------------------------
\18\ More information on MEPS International may be found at:
www.meps.co.uk/.
\19\ More information on PolymerUpdate may be found at:
www.polymerupdate.com.
\20\ More information on the USGS metal price statistics may be
found at: www.usgs.gov/centers/nmic/commondity-statistics-and-information.
\21\ More information on the BLS producer price indices may be
found at: www.bls.gov/ppi/.
---------------------------------------------------------------------------
Fabricated Parts and Purchased Parts
DOE characterized parts based on whether manufacturers fabricated
them in-house or purchased them from outside suppliers. For fabricated
parts, DOE estimated the price of intermediate materials (e.g., tube,
sheet metal) and the cost of forming them into finished parts. DOE
estimated initial raw material dimensions to account for scrap. For
scrap materials that are recyclable, DOE assigned a scrap credit that
is a fraction of the base material cost. Non-recyclable materials incur
a disposal cost for all scrap. For purchased parts, DOE estimated the
purchase price for original equipment manufacturers based on its
confidential parts database and industry expertise. For the purpose of
this analysis, DOE assumed that all components of the fan were
purchased from outside suppliers. This assumption was made because of
the relatively low volume of manufacturing for air circulating fans
compared to other products, which increases the likelihood that parts
are purchased rather than manufactured in-house.
As previously stated, variability in the costs of purchased parts
can account for large changes in the overall MPC values calculated.
Purchased part costs can vary significantly based on the quantities
desired and the component suppliers chosen. The purchased part prices
used in this study were typical values based on estimated production
volume and other factors. However,
[[Page 62052]]
variability in these prices may exist on a case-by-case basis.
Due to the great diversity of manufacturing scale in the fans
industry, DOE estimates that the purchased parts costs could vary
significantly by manufacturer. Some parts like motors, and impellers
may be produced in-house by some manufacturers and purchased by others,
changing likely overall system costs and investment requirements.
Factory Parameters
Certain factory parameters, such as fabrication rates, labor rates,
and wages, also affect the cost of each unit produced. DOE factory
parameter assumptions were based on internal expertise and may be
updated based on manufacturer feedback. Table II-9 lists the factory
parameter assumptions used in the cost models. These assumptions are
generalized to represent typical production and are not intended to
model a specific factory.
Table II-9--Factory Parameter Assumptions for Air Circulating Fans
------------------------------------------------------------------------
Parameter Estimate
------------------------------------------------------------------------
Actual Annual Production Volume......................... 25,000
Work Days Per Year (days)............................... 250
Fabrication Shifts Per Day (shifts)..................... 1
Assembly Shifts Per Day (shifts)........................ 1
Fabrication Labor Wages ($/hr).......................... 16
Assembly Labor Wages ($/hr)............................. 16
Burdened Fabrication Labor Wage ($/hr).................. 24
Burdened Assembly Labor Wage ($/hr)..................... 24
Fabrication Worker Hours Per Year....................... 250
Assembly Worker Hours Per Year.......................... 250
Supervisor Span (workers/supervisor).................... 25
Supervisor Wage Premium (over fabrication and assembly 30%
wage)..................................................
Fringe Benefits Ratio................................... 50%
Indirect to Direct Labor Ratio.......................... 33%
Length of Shift (hr).................................... 8
Worker Downtime......................................... 10%
Actual units per day.................................... 100
Average Equipment Installation Cost (% of purchase 10%
price).................................................
Average Scrap Credit (relative to base material cost)... 30%
Non-recyclable Trash Cost ($/lb)........................ $0
------------------------------------------------------------------------
Issue 18: DOE requests comment on its factory parameter assumptions
for typical air circulating fan production.
c. Determination of Air Circulating Fan MPC
DOE conducted teardowns on four housed and five unhoused air
circulating fan heads ranging in diameter from 18 inches to 30 inches
and created a BOM for each fan. For this NODA, DOE used the BOM for
what DOE considered to be a representative baseline 24-inch unhoused
fan without a motor and one representative baseline 24-inch housed fan
without a motor. The baseline unhoused air circulating fan material and
production costs were scaled to each of the unhoused representative
diameters (i.e., 12, 20, 36, and 50 inches) by the ratio of the
representative diameters to 24 inches. For housed air circulating fans,
DOE determined material and production costs for the 24-inch housed
fan, then used the ratio between the 24-inch housed and unhoused costs
to estimate housed fan costs at each representative diameter. DOE's
cost data for diameters other than 24 inches is included in the
supplement spreadsheet included in the docket. (See Docket No. EERE-
2022-BT-STD-0002, No. 11) Table II-10 summarizes the characteristics
assumed for 24-inch housed and unhoused baseline fans. DOE assumed that
these fans were manufactured in China, and that material and parts were
also sourced from China.
Table II-10--Material and Production Characteristics for Baseline 24-
Inch Housed and Unhoused Air Circulating Fan
------------------------------------------------------------------------
Unhoused Housed
------------------------------------------------------------------------
Blade Type...................... Propeller......... Propeller.
Blade Shape..................... Rectangular....... Rectangular.
Blade Material.................. Galvanized Cold Galvanized CRS.
Rolled Steel
(``CRS'').
Hub Material.................... Aluminum CRS...... Aluminum CRS.
Type of Housing................. Basket............ Tube.
Housing Material................ CRS-Wire.......... CRS-Wire and
polypropylene.
------------------------------------------------------------------------
Issue 19: DOE requests comment on whether or not its baseline
material assumptions are representative of baseline fans distributed
into commerce. If DOE's baseline material assumptions are not
representative, DOE requests information and data on materials
typically used in the air circulating fans currently on the market.
Housed and unhoused baseline 24-inch air circulating fan cost
estimates are summarized in Table II-11.
Table II-11--Estimated MPCs for Air Circulating Fans With No Motors
------------------------------------------------------------------------
Fan cost (no
motor)
------------------------------------------------------------------------
24-inch Unhoused........................................ $26.06
[[Page 62053]]
24-inch Housed.......................................... 69.89
------------------------------------------------------------------------
Issue 20: DOE requests comment on its estimated base MPC for air
circulating fans with no motors at each of the representative diameters
evaluated. (See supplemental spreadsheet included in Docket No. EERE-
2022-BT-STD-0002, No. 11)
As discussed previously, DOE used a design option approach to
structure its engineering analysis. DOE assumed that baseline fans with
fractional motor hp would be equipped with a SP motor. For each
efficiency level analyzed (i.e., EL1, EL2, and EL 3), DOE assumed that
a more efficient motor is substituted into the same fan. At EL 4, DOE
assumed the most efficient motor was paired with improved aerodynamic
design of the fan.
To estimate manufacturer costs for SP motors, PSC motors, and ECMs,
DOE used motor costs from its internal parts database and assumed a
motor to fan manufacturer markup of 1.37.\22\ DOE did not have specific
cost data for SP motors, and therefore used costs for shaded-pole
motors as a proxy for SP motor costs. See 2009 CR Report. To estimate
motor costs for the motor hp used in the representative units evaluated
for this analysis, DOE determined the equation of the best fit line for
hp as a function of motor cost and calculated motor cost at 0.1, 0.33,
0.5, and 1 hp for SP motors, PSC motors and ECMs.
---------------------------------------------------------------------------
\22\ A markup of 1.37 for motors at or below 5 hp was used in
the Electric Motors Preliminary Analysis Technical Support Document
(TSD) (see section 5.4.8.4, Docket No. EERE-2020-BT-STD-0007-0010 at
regulations.gov).
---------------------------------------------------------------------------
DOE's parts database does not differentiate between motor
efficiency. DOE therefore estimated PSC 1 motor cost using a best fit
line for cost as a function of hp. For PSC 2 motor costs, DOE
determined a best fit line identified the 95th cost percentile for each
representative unit/motor hp, and then determined the best fit line
through these points. Table II-12 summarizes estimated motor costs for
the 24-inch air circulating fan at each EL evaluated.
Table II-12--Estimated Motor Costs at Each EL for 24-Inch Diameter Air Circulating Fans
----------------------------------------------------------------------------------------------------------------
Motor hp EL0 EL1 EL2 EL3
----------------------------------------------------------------------------------------------------------------
0.5......................................... $26.05 $64.32 $79.78 $114.45
----------------------------------------------------------------------------------------------------------------
Issue 21: DOE requests comment on whether replacing a given fan
motor with a more efficient fan motor will result in similar efficiency
and cost impacts for housed and unhoused air circulating fan heads.
Issue 22: DOE requests comment on its estimated motor costs SP
motors (EL0), PSC motors (EL1), higher efficiency PSC motors (EL2), and
ESMs (EL3) at each hp associated with the representative diameters
evaluated. (See supplemental spreadsheet included in Docket No. EERE-
2022-BT-STD-0002, No. 11)
Table II-13 summarizes the total estimated cost of the fan
assembly, including the motor, for 24-inch unhoused and housed fans.
Table II-13--Total Air Circulating Fan Cost for a 24-Inch Housed and Unhoused Fan at EL0, EL1, EL2, and EL3
----------------------------------------------------------------------------------------------------------------
Type Motor hp EL 0 EL 1 EL 2 EL 3
----------------------------------------------------------------------------------------------------------------
Unhoused........................ 0.5 $52.12 $90.38 $105.84 $140.51
Housed.......................... 0.5 95.94 134.21 149.67 184.34
----------------------------------------------------------------------------------------------------------------
Issue 23: DOE requests comment on its estimated housed and unhoused
air circulating fan costs at each EL and for each representative unit.
(See supplemental spreadsheet included in Docket No. EERE-2022-BT-STD-
0002, No. 11)
As mentioned previously, DOE is assuming that a max-tech air
circulating fan (i.e., EL4) would undergo aerodynamic redesign and
contain an ECM. Aerodynamic redesign includes modifications to a fan's
housing, blade/impeller, and/or guard that would include fan model
redesign, re-engineering, and upgraded/new tooling equipment. These
modifications result in a one-time cost that is not captured by MPC but
may be represented by capital conversion costs. DOE used the conversion
costs for axial cylindrical housed fans, presented in the November 2016
NODA,\23\ as a proxy for estimating air circulating fan conversion
costs. After adjusting for inflation, DOE estimates an air circulating
fan redesign cost of $720,300 per fan. Additional information on DOE's
assumptions and analysis may be found in the supplemental spreadsheet
associated with this docket (see Docket No. EERE-2022-BT-STD-0002, No.
11).
---------------------------------------------------------------------------
\23\ See EERE-2013-BT-STD-0006-0189 at regulations.gov.
---------------------------------------------------------------------------
Issue 24: DOE requests comment on and additional data to support
its estimated air circulating fan conversion costs to undergo
aerodynamic redesign.
[[Page 62054]]
5. Manufacturer Selling Price
The manufacturer selling price (``MSP'') is the price of the
equipment when it is sold by the manufacturer to the first party in the
distribution chain. It includes all direct and indirect production
costs, other costs such as research and development, and the
manufacturer's profit.
When developing cost-efficiency curves during its engineering
analysis, DOE typically uses MSP as a function of efficiency. For
simplicity, DOE is presenting the results of its cost model for this
NODA in terms of MPC.
The MSP is expressed as the product of the MPC and the manufacturer
markup. Based on information obtained during interviews with
manufacturers, DOE is assuming that the average manufacturer markup for
a baseline fan is 1.5.50 percent, meaning the MSP is During interviews,
manufacturers stated that they expected to be able to maintain their
profit margin if DOE were to set energy efficiency standards for air
circulating fans; therefore, DOE is assuming that the average MSP in a
market with standards would also be 1.5.
Issue 25: DOE requests comment on whether or not an average MSP of
1.5 is representative for the air circulating fan market. If an average
MSP of 1.5 is not representative, DOE requests information of what a
more representative MSP would be. Additionally, DOE requests comment on
whether or not MSP for air circulating fans will remain constant in the
case of new energy conservation standards. If not, DOE seeks
information on the magnitude by which MSP might change under potential
energy efficiency standards.
E. Markups Analysis
The markups analysis develops appropriate markups (e.g., retailer
markups, distributor markups, contractor markups) in the distribution
chain and sales taxes to convert MSP estimates derived in the
engineering analysis to consumer prices, which are then used in the LCC
and PBP analysis. At each step in the distribution channel, companies
mark up the price of the product to cover business costs and profit
margin.
DOE developed baseline and incremental markups for each actor in
the distribution chain. Baseline markups are applied to the price of
products with baseline efficiency, while incremental markups are
applied to the difference in price between baseline and higher
efficiency models (the incremental cost increase). The incremental
markup is typically less than the baseline markup and is designed to
maintain similar per-unit operating profit before and after new or
amended standards.\24\
---------------------------------------------------------------------------
\24\ Because the projected price of standards-compliant products
is typically higher than the price of baseline products, using the
same markup for the incremental cost and the baseline cost would
result in higher per-unit operating profit. While such an outcome is
possible, DOE maintains that in markets that are reasonably
competitive it is unlikely that standards would lead to a
sustainable increase in profitability in the long run.
---------------------------------------------------------------------------
In the ECS RFI, DOE requested information to help characterize
distribution channels for air circulating fans. DOE also requested data
on the fraction of sales that go through these channels. 87 FR 7048,
7054. DOE did not receive any input on this topic.
DOE identified two distribution channels for air circulating fans,
depending on the input power of the fan at maximum speed. Air
circulating fans with input power less than 125 Watts (W) are primarily
used in residential applications.\25\ Data from the Association of Home
Appliance Manufacturers (``AHAM'') indicate that an majority of
residential appliances are sold through retail outlets.\26\ Because DOE
is not aware of any other distribution channel that plays a significant
role for air circulating fans with input power less than 125 W, DOE
estimates that such air circulating fans are purchased by consumers
from retail outlets (including online retailers).
---------------------------------------------------------------------------
\25\ DOE notes that distribution for residential use does not
preclude coverage as covered equipment, so long as the equipment is
of a type that is also distributed in commerce for industrial and
commercial use.
\26\ Association of Home Appliance Manufacturers. Fact Book
2009. 2009. AHAM: Washington, DC.
---------------------------------------------------------------------------
For air circulating fans with input power greater than or equal to
125 W, DOE estimates that the primary distribution channel is that the
manufacturer sells the equipment to a distributor, who in turn sells it
to the customer. DOE is also aware of another direct sale channel for
air circulating fans greater than or equal to 125 W where the
manufacturer sells the equipment directly to a customer through their
in-house distributor. In addition, DOE considered additional channels
that included a contractor based on input from manufacturer interviews.
Further, DOE estimated the fraction of shipments of air circulating
fans with input power greater than or equal to 125 W going through each
channel based on feedback from manufacturer interviews. Information
from the manufacturer interviews also indicated that some fraction of
shipments (10-15 percent) are sold to consumers via an original
equipment manufacturer (``OEM'') and a distributor. However, DOE is not
aware of any OEM equipment that would incorporate an air circulating
fan and therefore did not consider this channel.
[[Page 62055]]
Table II-14 summarizes the air circulating fan distribution
channels identified by DOE.
Table II-14--Distribution Channels for Air Circulating Fans
------------------------------------------------------------------------
Air circulating fan input power Fraction of
at maximum speed (W) Distribution channel shipments (%)
------------------------------------------------------------------------
Less than 125 W................ Manufacturer [rarr] 100
Retailer [rarr]
Consumer.
Greater than or equal to 125 W. Manufacturer [rarr] 40
Distributor [rarr]
Consumer.
Manufacturer [rarr] 20
Distributor [rarr]
Contractor [rarr]
Consumer.
Manufacturer [rarr] In- 30
house Distributor
[rarr] Consumer.
Manufacturer [rarr] In- 10
house Distributor
[rarr] Contractor
[rarr] Consumer.
------------------------------------------------------------------------
To estimate average baseline and incremental markups for each actor
in the distribution channels, DOE relied on data from the 2017 Annual
Retail Trade Survey,\27\ the 2017 Annual Wholesale Trade Survey,\28\
and RS Means.\29\ In addition to the markups, DOE obtained state and
local taxes from data provided by the Sales Tax Clearinghouse.\30\
Table II-15 and Table II-16 and show the resulting baseline markups,
incremental markups, and sales tax.
---------------------------------------------------------------------------
\27\ Available at www.census.gov/data/tables/2017/econ/arts/annual-report.html; NAICS 443--Electronics and Appliance Stores.
\28\ Available at: www.census.gov/programs-surveys/awts.html;
NAICS 4238--Machinery, equipment, and supplies merchant wholesalers.
\29\ RS Means Electrical Cost Data 2021. Available at:
www.rsmeans.com.
\30\ Sales Tax Clearinghouse Inc., State Sales Tax Rates Along
with Combined Average City and County Rates (2022), available at
https://thestc.com/STrates.stm (last accessed June 6, 2022).
Table II-15--Distribution Channel Markups for Air Circulating Fans With
Input Power Less Than 125 W
------------------------------------------------------------------------
Manufacturer [rarr] retailer
[rarr] consumer (100%
Distribution channel shipments)
-------------------------------
Baseline Incremental
------------------------------------------------------------------------
Retailer................................ 1.486 1.238
Sales Tax............................... 1.073 1.073
Overall Markup.......................... 1.594 1.328
------------------------------------------------------------------------
Table II-16--Distribution Channel Markups for Air Circulating Fans With Input Power Greater Than or Equal to 125 W
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Manufacturer [rarr] Manufacturer [rarr] Manufacturer [rarr] in-house Manufacturer [rarr] in-house
distributor [rarr] consumer distributor [rarr] contractor distributor [rarr] consumer distributor [rarr] contractor
(40% shipments) [rarr] consumer (20% (30% shipments) [rarr] consumer (10%
-------------------------------- shipments) -------------------------------- shipments)
-------------------------------- -------------------------------
Base.* Inc.* Base. Inc. Base. Inc. Base. Inc.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
(In-house) Distributor.......................................... 1.412 1.194 1.412 1.194 1.412 1.194 1.412 1.194
Contractor...................................................... .............. .............. 1.100 1.100 .............. .............. 1.100 1.100
Sales Tax....................................................... 1.073 1.073 1.073 1.073 1.073 1.073 1.073 1.073
Overall Markup.................................................. 1.516 1.281 1.667 1.409 1.516 1.281 1.667 1.409
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* Base. = baseline, Inc. = Incremental.
Issue 26: DOE requests feedback and information on the distribution
channels identified for air circulating fans, and on any other
distribution channel that DOE should consider. DOE also requests data
on the fraction of sales that go through these channels.
F. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of air circulating fans at different efficiencies
for a representative sample of consumers, and to assess the energy
savings potential of increased air circulating fan efficiency. The
energy use analysis estimates the range of energy use of air
circulating fans in the field (i.e., as they are actually used by
consumers). The energy use analysis provides the basis for other
analyses DOE performs, particularly assessments of the energy savings
and the savings in consumer operating costs that could result from
adoption of amended or new standards.
In any future analysis, DOE may consider calculating the energy use
by combining air circulating fan input power consumption in each mode
(e.g., high speed, medium speed, low speed) from the engineering
analysis with operating hours spent in each mode. To characterize
variability and uncertainty, the energy use is calculated for a
representative sample of air circulating fan consumers. This method of
analysis, referred to as a Monte Carlo method, is explained in more
detail in section II.G of this document. Results of the energy use
analysis for each representative air circulating fan will be derived
from a sample of 10,000 consumers. DOE then plans on using the range of
energy use results in the LCC and PBP analyses and the average of the
energy use results in the National Impact Analysis (``NIA'') analysis.
This section presents DOE's approach to develop consumer samples and
the operating hour inputs that DOE is considering using in any future
energy use analysis. For each consumer in the sample, DOE will
associate a value of air circulating fan operating
[[Page 62056]]
hours drawn from a statistical distribution as described in the
remainder of this section.
1. Fans With Input Power Less Than 125 W
a. Sample of Consumers
DOE is considering including only residential applications in the
energy use analysis of air circulating fans with input power below 125
W. Although some of these air circulating fans are used in commercial
or industrial settings, DOE believes that they represent a very small
portion of the total market for such air circulating fans. To develop a
representative sample of consumers, DOE is considering using the Energy
Information Administration (``EIA'') 2020 Residential Energy
Consumption Survey (``RECS'') \31\ to choose a random sample of
households in which new air circulating fans could be installed. RECS
is a national survey of housing units that collects statistical
information on the consumption of, and expenditures for, energy in
housing units, along with data on energy-related characteristics of the
housing units and occupants. RECS collects data on thousands of housing
units, and was constructed by EIA to be a national representation of
the household population in the United States. Although RECS contains
information on operation for many appliances, it contains no
information on the operation of air circulating fans within each
household. RECS reports only the number of floor or window fans in the
household which is the category of appliance closest to air circulating
fans.
---------------------------------------------------------------------------
\31\ Department of Energy, Energy Information Administration.
2020 Residential Energy Consumption Survey (RECS). 2020. (Last
accessed July 6, 2022) www.eia.gov/consumption/residential/data/2020/.
---------------------------------------------------------------------------
In creating the sample of RECS households, DOE is planning on using
the subset of RECS records that met the criterion that the household
had at least one ``floor or window fan''. DOE is planning on choosing a
sample of 10,000 households from RECS to estimate annual energy use for
air circulating fans with input power less than 125 W. Because RECS
provides no means of determining the subset of air circulating fans in
a given household, DOE will use the same sample for all equipment
classes.
b. Operating Hours
In the ECS RFI, DOE requested information to characterize the
annual operating hours of air circulating fans and time spent in each
operating mode, if applicable, by sector of application, and
geographical region. 87 FR 7048, 7054. In response, ebm-papst commented
that the use of agricultural fans, residential fans, commercial fans,
and basket fans used for distribution transformers are all very
different (ebm-papst, No. 8 at p. 4). ebm-papst did not provide
additional information to characterize operating conditions. DOE did
not receive other comments on this topic.
DOE reviewed existing studies on air circulating fans used in
residential applications and found that these are often studied in
combination with ceiling fans, indicating that they likely operate
similarly.\32\ In the absence of existing data indicating the daily
hours of operation specific to air circulating fans with input power
less than 125 W, DOE used the same annual operating hours as developed
for standard, hugger, and very small diameter ceiling fans in the
Ceiling Fans Preliminary Analysis to characterize the operating hours
of air circulating fans with input power less than 125 W.\33\ The
ceiling fan preliminary analysis relied on a distribution of operating
hours, with an average of 6.45 hours of operation per day with 33
percent at high speed, 38 percent at medium speed, and 29 percent at
low speed. DOE assumes this is also representative of air circulating
fan usage with input power less than 125W and plans on applying this
load profile in any future energy use calculation. DOE notes that some
air circulating fans may not have three available speeds, in which case
DOE plans on adjusting the time spent in each mode according to the
fan's speed capability (e.g., assuming 100 percent of operation at the
one available speed for single-speed air circulating fans).
---------------------------------------------------------------------------
\32\ Ecodesign Lot 10 Comfort Fans Study, Preparatory Study on
Environmental Performance of Residential Room Conditioning
Appliances (airco and ventilation) Study on comfort fans--final
report October 2008, after SH comments www.eceee.org/static/media/uploads/site-2/ecodesign/products/airco-ventilation/finalreport-cf.zip.
\33\ See Section 7.3.2. of Chapter 7 of the ceiling fan
preliminary analysis Technical Support Document,
www.regulations.gov/document/EERE-2021-BT-STD-0011-0015.
---------------------------------------------------------------------------
2. Fans With Input Power Greater Than or Equal to 125 W
a. Sample of Consumers
DOE is considering including only commercial, industrial, and
agricultural applications in the energy use analysis of air circulating
fans with input power greater than or equal to 125 W. Although some air
circulating fans with input power greater than or equal to 125 W are
used in residential applications, DOE believes that they represent a
very small portion of the total market for such fans. DOE plans on
creating a sample of 10,000 consumers for each equipment class to
represent the range of air circulating fan energy use in the
commercial, industrial, and agricultural sectors.
b. Operating Hours
As noted previously, DOE did not receive any information related to
the operating hours of air circulating fans. In the absence of data
indicating the daily hours of operation specific to air circulating
fans, DOE estimated that air circulating fans with input power greater
than or equal to 125 W operate, on average, 12 hours per day,
consistent with the hours of use estimated for large-diameter ceiling
fans in the Ceiling Fan Preliminary Analysis.\34\ To represent a range
of possible operating hours around this representative value, DOE will
be drawing 10,000 samples from a uniform distribution between 6 hours
per day and 18 hours per day (assuming a uniform distribution of
operating hours due to the limited availability of information).
---------------------------------------------------------------------------
\34\ See Section 7.4.2 of Chapter 7 of the Ceiling Fan
Preliminary Analysis Technical Support Document,
www.regulations.gov/document/EERE-2021-BT-STD-0011-0015.
---------------------------------------------------------------------------
In the July 2022 TP NOPR, the efficiency metric is calculated
assuming that the performance at each of the five tested speeds is
weighted equally, as there are not available data to suggest a
different distribution of time spent at each speed. 87 FR 44194, 44238.
For this NODA, DOE assumed an equal amount of time would be spent at
each speed, in alignment with the approach in the July 2022 TP NOPR.
Table II-17 summarizes the inputs to the energy use calculation
identified by DOE. For each consumer in the samples, DOE will associate
a value of air circulating fan operating hours drawn from a statistical
distribution as described in Table II-17.
[[Page 62057]]
Table II-17--Inputs to the Energy Use Calculation
------------------------------------------------------------------------
Air circulating Air circulating
fan with input fan with input
Input to the energy use power at maximum power at maximum
calculation speed less than speed greater than
125 W or equal to 125 W
------------------------------------------------------------------------
Average Operating Hours per Day. 6.45 hours per day 12 hours per day.
Statistical Distribution........ Based on Consumer Uniform
Survey. Distribution
between 6 hours
per day and 18
hours per day.
Fraction of time spent in each 33% on high speed, Equal amount of
mode. 38% on medium time at each
speed, 29% on low tested speed.
speed.
------------------------------------------------------------------------
Issue 27: DOE seeks comment on the estimated average number of
operating hours per year, distribution of operating hours, and the
estimated fraction of time spent at each speed setting for air
circulating fans with input power less than 125 W and those with input
power greater than or equal to 125 W. In addition, if DOE should
consider different operating hours for specific applications (e.g., air
circulating fans used in agricultural applications, thermal mixing
fans) DOE requests data on how to best characterize operating hours for
these various applications.
G. Life Cycle Cost and Payback Period Analyses
The effect of new or amended energy conservation standards on
individual consumers usually involves a reduction in operating cost and
an increase in purchase cost. DOE uses the following two metrics to
measure consumer impacts:
The LCC is the total consumer expense of an appliance or
product over the life of that product, consisting of total installed
cost (manufacturer selling price, distribution chain markups, sales
tax, and installation costs) plus operating costs (expenses for energy
use, maintenance, and repair). To compute the operating costs, DOE
discounts future operating costs to the time of purchase and sums them
over the lifetime of the product.
The PBP is the estimated amount of time (in years) it
takes consumers to recover the increased purchase cost (including
installation) of a more efficient product through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
at higher efficiency levels by the change in annual operating cost for
the year that amended or new standards are assumed to take effect.
For any given efficiency level, DOE measures the change in LCC
relative to the LCC in the no-new-standards case, which reflects the
estimated efficiency distribution of air circulating fans in the
absence of new energy conservation standards. In contrast, the PBP for
a given efficiency level is measured relative to the baseline product.
For each considered efficiency level in each equipment class, DOE plans
on calculating the LCC and PBP for a nationally representative sample
of consumers.
In addition, the computer model that DOE plans on using to
calculate the LCC and PBP relies on a Monte Carlo simulation to
incorporate uncertainty and variability into the analysis. The Monte
Carlo simulations randomly sample input values from the probability
distributions and air circulating fan consumer samples. The model
calculates the LCC and PBP for equipment at each efficiency level for
10,000 consumers per simulation run. The analytical results include a
distribution of 10,000 data points showing the range of LCC savings for
a given efficiency level relative to the no-new-standards case
efficiency distribution. In performing an iteration of the Monte Carlo
simulation for a given consumer, equipment efficiency is chosen based
on its probability. If the chosen equipment efficiency is greater than
or equal to the efficiency of the standard level under consideration,
the LCC and PBP calculation reveals that a consumer is not impacted by
the standard level. By accounting for consumers who already purchase
more efficient equipment, DOE avoids overstating the potential benefits
from increasing equipment efficiency.
This section presents the approach and data DOE used to derive
inputs to the LCC and PBP analysis not previously described in this
document. All inputs to the LCC and PBP analyses are summarized in
Table II-18.
Table II-18--Summary of Inputs and Methods for the LCC and PBP Analysis
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Equipment Cost......................... Will be derived by multiplying
MSPs by distribution channel
markups and sales tax, as
appropriate. DOE uses
historical data to derive a
constant price index to
project equipment costs.
Installation Costs..................... Assumed installation costs do
not vary by efficiency level.
Annual Energy Use...................... Annual energy use: Based on the
time spent in each model
multiplied by the input power
in each mode.
Variability: Based on discrete
and uniform probability
distributions.
Energy Prices.......................... Electricity: Average and
marginal prices based on
Edison Electric Institute
(``EEI'') data for 2021.
Variability: Based on sector
and geographical region.
Energy Price Trends.................... Based on 2022 Annual Energy
Outlook (``AEO2022'') price
projections (or most recent
version available at the time
of the analysis).
Repair and Maintenance Costs........... Assumed maintenance costs do
not vary by efficiency level.
Assumed no repair costs for air
circulating fans with input
power less than 125 W.
Assumed one motor repair for
air circulating fans with
input power greater than or
equal to 125 W, with a
lifetime that exceeds the
average lifetime.
[[Page 62058]]
Equipment Lifetime..................... Average: 10 years for air
circulating fans with input
power less than 125 W.
And 30 years for air
circulating fans with input
power greater than or equal to
125 W.
Variability: Based on Weibull
distribution.
Discount Rates......................... Residential: approach involves
identifying all possible debt
or asset classes that might be
used to purchase the
considered appliances, or
might be affected indirectly.
Primary data source was the
Federal Reserve Board's Survey
of Consumer Finances.
Commercial/Industrial/
Agricultural: Calculated as
the weighted average cost of
capital for entities
purchasing pool pumps. Primary
data source was Damodaran
Online.
Compliance Date........................ 5 years after publication of
any final rule.
------------------------------------------------------------------------
Issue 28: DOE requests feedback on the inputs and considered
methods used for the LCC and PBP analyses.
1. Equipment Price
To calculate consumer equipment costs, DOE multiplies the MSPs
developed in the engineering analysis by the distribution channel
markups described previously (along with sales taxes). As previously
discussed, DOE uses different distribution channel markups for baseline
equipment and higher efficiency equipment, because DOE applies an
incremental markup to the increase in MSP associated with higher
efficiency equipment.
To project equipment costs in the projected compliance year, DOE
plans on developing an equipment price trend. Because the motor is the
most costly component of the air circulating fan, DOE believes that
historic prices of electric motors provide a reasonable basis for
considering trends in the price of air circulating fans.
DOE is planning on obtaining historical Producer Price Index
(``PPI'') data for integral hp motors and generators manufacturing
spanning the time period from 1969 to 2021 and for fractional hp motors
and generators manufacturing between 1967 and 2021 from the BLS.\35\
The PPI data reflect nominal prices, adjusted for product quality
changes. An inflation-adjusted (deflated) price index for fractional hp
motors and generators manufacturing was calculated by dividing the PPI
series by the Gross Domestic Product Chained Price Index. Previous DOE
analysis that relied on the same approach and data sources resulted in
a constant price trend assumption to project future electric motor
prices.\36\ Similarly, DOE expects to rely on a constant price trend
for air circulating fans.
---------------------------------------------------------------------------
\35\ Series ID PCU3353123353123 and PCU3353123353121 for
integral and fractional hp motors and generators manufacturing,
respectively; www.bls.gov/ppi/.
\36\ See Electric Motors Energy Conservation Standards
Preliminary Analysis Technical Support Document, Chapter 8: Life
Cycle Cost and Payback Period Analysis (p. 269). Available at:
www.regulations.gov/document/EERE-2020-BT-STD-0007-0010.
---------------------------------------------------------------------------
2. Installation, Repair and Maintenance Costs
DOE reviewed available air circulating fan installation,
maintenance, and repair cost information.
For air circulating fans with input power less than 125 W, which
DOE is assuming are primarily used in residential applications, a
previous study focused on air circulating fans used in residential
settings estimated no installation, repair, or maintenance costs for
these fans.\37\ DOE believes this is a representative characterization
of these costs as these air circulating fans are plug-in equipment that
do not require any maintenance and are unlikely to be repaired due to
the relatively low equipment price.
---------------------------------------------------------------------------
\37\ Ecodesign Lot 10 Comfort Fans Study, Preparatory Study on
Environmental Performance of Residential Room Conditioning
Appliances (airco and ventilation) Study on comfort fans--final
report October 2008, after SH comments (p. 44; p. 71-73)
www.eceee.org/static/media/uploads/site-2/ecodesign/products/airco-ventilation/finalreport-cf.zip.
---------------------------------------------------------------------------
For air circulating fans with input power greater than 125 W, which
DOE assumes are primarily used in commercial, industrial, and
agricultural applications, DOE did not find any information supporting
changes in installation and maintenance costs as a function of
efficiency. Therefore, because DOE expresses results in terms of LCC
savings, DOE is not planning to account for installation costs in the
LCC (the difference in installation costs between a baseline and more
efficient air circulating fan would be zero and would have no impact on
the calculated LCC savings). In terms of repairs, DOE has identified
the motor replacement as a potential repair. Depending on the design
options considered, DOE may include different repair costs by EL to
reflect differences in motor replacement costs. DOE did not find any
information related to motor repair frequency in air circulating fans.
For air circulating fans greater than or equal to 125 W, DOE is
considering accounting for one motor replacement for consumers that
have an air circulating fan with a sampled lifetime exceeding the
average lifetime.
Issue 29: DOE requests information on its assumptions related to
installation, maintenance, and repair practices of air circulating
fans. Specifically, DOE requests feedback and data on whether
installation, maintenance, and repair costs of air circulating fans are
expected to be different at higher efficiency levels in comparison to
the baseline installation, maintenance, and repair costs. To the extent
that these costs differ, DOE seeks supporting data and the reasons for
those differences.
Issue 30: DOE requests information on the repair frequency of air
circulating fans (i.e., how many repairs in a lifetime) by category
(i.e., unhoused air circulating fan heads, air circulating axial panel
fan, box fan, cylindrical air circulating fan, and housed centrifugal
air circulating fan) and on its approach to consider a single repair
for certain air circulating fans with input power greater than or equal
to 125 W.
3. Energy Prices
DOE is planning on using average and marginal electricity prices in
2021 for each census division using data from the EEI Typical Bills and
Average Rates reports \38\ and the methodology described in two
Lawrence Berkeley National Laboratory reports.\39\ \40\ DOE's
[[Page 62059]]
methodology allows electricity prices to vary by sector, region, and
season. In the analysis, variability in electricity prices is chosen to
be consistent with the way the consumer economic and energy use
characteristics are defined in the LCC and PBP analyses. Table II-19
shows the average and marginal prices for each sector of application.
---------------------------------------------------------------------------
\38\ Edison Electric Institute, EEI Typical Bills and Average
Rates Report (2021). Washington, DC.
\39\ Katie Coughlin and Berket Beraki, ``Non-Residential
Electricity Prices: A Review of Data Sources and Estimation
Methods,'' April 15, 2019, doi.org/10.2172/1515782.
\40\ Katie Coughlin and Bereket Beraki, ``Residential
Electricity Prices: A Review of Data Sources and Estimation
Methods,'' 2018.
Table II-19--Electricity Prices in 2021
------------------------------------------------------------------------
Average price Marginal price
Sector 2021$/kWh 2021$/kWh
------------------------------------------------------------------------
Residential............................. 0.157 0.151
Commercial (small)...................... 0.123 0.117
Commercial (large)...................... 0.097 0.083
Industrial.............................. 0.081 0.069
------------------------------------------------------------------------
To estimate electricity prices in future years, DOE is planning on
multiplying the 2021 electricity prices by the sector-specific
forecasts of annual national average price changes from EIA's Reference
case in the AEO 2022. The reference case is a business-as-usual
estimate, given known market, demographic, and technological trends.
AEO2022 has an end year of 2050. DOE assumes a flat rate of change in
prices from 2050. The values for the industrial sector are used for the
agricultural sector as well.
4. Lifetime
The equipment lifetime is the age at which given equipment is
retired from service. DOE typically develops survival probabilities
using on a Weibull function to characterize variability in lifetimes.
In preparation for this NODA, DOE reviewed data available for air
circulating fan lifetime.
For air circulating fans with input power less than 125 W, which
are primarily used in residential applications, a previous study
focused on air circulating fans used in residential settings estimated
air circulating fan lifetimes at 10 years on average.\41\
---------------------------------------------------------------------------
\41\ Ecodesign Lot 10 Comfort Fans Study, Preparatory Study on
Environmental Performance of Residential Room Conditioning
Appliances (airco and ventilation) Study on comfort fans--final
report October 2008, after SH comments (p. 44) www.eceee.org/static/media/uploads/site-2/ecodesign/products/airco-ventilation/finalreport-cf.zip.
---------------------------------------------------------------------------
For air circulating fans with input power greater than or equal to
125 W, DOE did not find data specific to such fans and instead is
considering an average lifetime of 30 years across all sectors, as used
to characterize fan and blower lifetimes in a previous DOE
analysis.\42\
---------------------------------------------------------------------------
\42\ On November 1, 2016, DOE published a notification of data
availability (``November 2016 NODA'') that presented an analysis for
fans and blowers other than air circulating fans. 81 FR 75742. The
lifetime assumptions and data source supporting the life cycle cost
calculation of the November 2016 NODA are available online at
www.regulations.gov/document/EERE-2013-BT-STD-0006-0190 (see
``Lifetime'' worksheet). The average lifetime estimate was based on
input from a subject matter expert John Murphy. ``Commercial and
Industrial Fans Life-cycle Cost Informational Interview.'' Telephone
interview. 13 May 2014.
---------------------------------------------------------------------------
Issue 31: DOE requests comment on the estimated average equipment
lifetimes for air circulating fans. DOE also requests information
related to minimum and maximum equipment lifetimes (in years or total
mechanical hours).
5. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
to consumers to estimate the present value of future operating cost
savings. DOE estimated a distribution of discount rates for air
circulating fan consumers based on the opportunity cost of consumer
funds.
DOE applies weighted average discount rates calculated from
consumer debt and asset data, rather than marginal or implicit discount
rates.\43\ The LCC analysis estimates net present value over the
lifetime of the equipment, so the appropriate discount rate will
reflect the general opportunity cost of household funds, taking this
time scale into account. Given the long time horizon modeled in the LCC
analysis, the application of a marginal interest rate associated with
an initial source of funds is inaccurate. Regardless of the method of
purchase, consumers are expected to continue to rebalance their debt
and asset holdings over the LCC analysis period, based on the
restrictions consumers face in their debt payment requirements and the
relative size of the interest rates available on debts and assets. DOE
estimates the aggregate impact of this rebalancing using the historical
distribution of debts and assets.
---------------------------------------------------------------------------
\43\ The implicit discount rate is inferred from a consumer
purchase decision between two otherwise identical goods with
different first cost and operating cost. It is the interest rate
that equates the increment of first cost to the difference in net
present value of lifetime operating cost, incorporating the
influence of several factors: transaction costs; risk premiums and
response to uncertainty; time preferences; interest rates at which a
consumer is able to borrow or lend. The implicit discount rate is
not appropriate for the LCC analysis because it reflects a range of
factors that influence consumer purchase decisions, rather than the
opportunity cost of the funds that are used in purchases.
---------------------------------------------------------------------------
To establish residential discount rates for the LCC analysis, DOE
identified all relevant household debt or asset classes in order to
approximate a consumer's opportunity cost of funds related to appliance
energy cost savings. It estimated the average percentage shares of the
various types of debt and equity by household income group using data
from the Federal Reserve Board's Survey of Consumer Finances \44\
(``SCF'') for 1995, 1998, 2001, 2004, 2007, 2010, 2013, 2016, and 2019.
Using the SCF and other sources, DOE developed a distribution of rates
for each type of debt and asset by income group to represent the rates
that may apply in the year in which amended standards would take
effect. In the LCC calculation, to account for variation among
households, DOE will assign each RECS household a specific discount
rate drawn the distributions for the appropriate income group (RECS
provides household income data). The average discount rate in 2021
across all types of household debt and equity and income groups,
weighted by the shares of each type, is 4.3 percent.
---------------------------------------------------------------------------
\44\ U.S. Board of Governors of the Federal Reserve System.
Survey of Consumer Finances. 1995, 1998, 2001, 2004, 2007, 2010,
2013, 2016, and 2019. (Last accessed June 15, 2022)
www.federalreserve.gov/econresdata/scf/scfindex.htm.
---------------------------------------------------------------------------
DOE applies weighted average discount rates calculated from
consumer debt and asset data, rather than marginal or implicit discount
rates. DOE notes that the LCC does not analyze the appliance purchase
decision, so the implicit discount rate is not relevant in this model.
The LCC estimates net present value over the lifetime of the
[[Page 62060]]
product, so the appropriate discount rate will reflect the general
opportunity cost of household funds, taking this time scale into
account. Given the long time horizon modeled in the LCC, the
application of a marginal interest rate associated with an initial
source of funds is inaccurate. Regardless of the method of purchase,
consumers are expected to continue to rebalance their debt and asset
holdings over the LCC analysis period, based on the restrictions
consumers face in their debt payment requirements and the relative size
of the interest rates available on debts and assets. DOE estimates the
aggregate impact of this rebalancing using the historical distribution
of debts and assets.
To establish commercial, industrial, and agricultural discount
rates, DOE estimated the weighted average cost of capital using data
from Damodaran Online.\45\ The weighted average cost of capital is
commonly used to estimate the present value of cash flows to be derived
from a typical company project or investment. Most companies use both
debt and equity capital to fund investments, so their cost of capital
is the weighted average of the cost to the firm of equity and debt
financing. DOE estimated the cost of equity using the capital asset
pricing model, which assumes that the cost of equity for a particular
company is proportional to the systematic risk faced by that company.
The average commercial, industrial, and agricultural discount rates in
2021 are 6.77 percent, 7.25 percent, and 7.15 percent respectively.
---------------------------------------------------------------------------
\45\ Damodaran Online, Data Page: Costs of Capital by Industry
Sector (2020). (Last accessed February 1, 2021) pages.stern.nyu.edu/
~adamodar/.
---------------------------------------------------------------------------
6. Efficiency Distribution in the No-New Standards Case
To accurately estimate the share of consumers that would be
affected by a potential energy conservation standard at a particular
efficiency level, DOE's LCC analysis considers the projected
distribution (market shares) of equipment efficiencies in the no-new-
standards case (i.e., the case without new energy conservation
standards) in the anticipated compliance year of any future energy
conservations standards.
For air circulating fans with input power less than 125 W, DOE did
not find any data regarding the distributions of equipment efficiencies
in the no-new-standards case. In the absence of any data, DOE is
conservatively considering assuming all shipments are at the baseline
level (EL 0).
For air circulating fans with input power greater than or equal to
125 W, DOE is planning on using the distributions based on model counts
at each efficiency level analyzed from the BESS Labs Database to
develop 2021 distributions of equipment efficiencies in the no-new-
standards case. DOE notes that the BESS Labs Database only publishes
performance at limited operating points for a given model, allowing DOE
to calculate the FEI at a single operating point (and not as a weighted
average). In the absence of other data, DOE will use this as a proxy
for determining the weighted average FEI of air circulating fans with
variable and multi-speed capability. In addition, DOE will apply
equipment efficiency trends (see section II.H.3 of this document) to
project the efficiency distribution for the no-new-standards case in
the compliance year.
Using the projected distribution of efficiencies for air
circulating fans, DOE plans on randomly assigning an equipment
efficiency to each household and commercial, industrial, or
agricultural consumer drawn from the consumer samples. If a consumer is
assigned an equipment efficiency that is greater than or equal to the
efficiency under consideration, the consumer would not be affected by a
standard at that efficiency level.
Issue 32: DOE requests comment on its approach to derive efficiency
distribution in the no-new standards case for each air circulating fan
category and input regarding 2021 (or most recent year available)
equipment efficiency distributions. Additionally, DOE seeks data that
would support changes in efficiency distributions over time in the no-
new standards case. To the extent any of the efficiency distributions
in the no-new standards case differ by size or other consumer or design
characteristic, DOE requests information to characterize these
variations.
H. National Impact Analysis
The NIA estimates the national energy savings (``NES'') and the net
present value (``NPV'') of total consumer costs and savings expected to
result from new standards at specific efficiency levels (referred to as
candidate standard levels).\46\ DOE calculates the NES and NPV for the
potential standard levels considered based on projections of annual
equipment shipments, along with the annual energy consumption and total
installed cost data from the energy use and LCC analyses. For the
present analysis, DOE projected the energy savings, operating cost
savings, equipment costs, and NPV of consumer benefits over the
lifetime of air circulating fans sold over a 30-year period starting in
the compliance year.
---------------------------------------------------------------------------
\46\ The NIA accounts for impacts in the 50 states and U.S.
territories.
---------------------------------------------------------------------------
DOE evaluates the impacts of new or amended standards by comparing
a case without such standards with standards case projections (``no-
new-standards case''). The no-new-standards case characterizes energy
use and consumer costs for each equipment class in the absence of new
or amended energy conservation standards. For this projection, DOE
considers historical trends in efficiency and various forces that are
likely to affect the mix of efficiencies over time. DOE compares the
no-new-standards case with projections characterizing the market for
each equipment class if DOE adopted new or amended standards at
specific energy efficiency levels for that class. For each efficiency
level, DOE considers how a given standard would likely affect the
market shares of equipment with efficiencies greater than the standard.
The NIA calculations use typical values (as opposed to probability
distributions) as inputs. Critical inputs to this analysis include
shipments projections, estimated product lifetimes, product installed
costs and operating costs, product annual energy consumption, the base
case efficiency projection, and discount rates. In this section, DOE
discusses specific inputs to the NIA, not previously discussed in this
document, for which it requests comment and feedback.
1. Base Year Shipments
DOE develops shipments forecasts to calculate the national impacts
of potential energy conservation standards on energy consumption, NPV,
and future manufacturer cash flows. DOE shipments projections are
typically based on available historical data broken out by equipment
class, capacity, and efficiency. Current sales estimates allow for a
more accurate model that captures recent trends in the market.
For air circulating fans with input power less than 125 W, DOE
reviewed shipments data from the Appliance Magazine market
research,\47\ which provides 1981-1994 shipments estimates of air
circulating fans used in residential settings and of ceiling fans. On
average during the period 1981-1994, the data showed that shipments of
such air circulating fans represented 91 percent of ceiling fan
shipments. DOE
[[Page 62061]]
assumed that this ratio is still representative of the market in 2020
and calculated shipments of air circulating fans with input power less
than 125 W by multiplying the 2020 ceiling fan shipments data published
in a previous DOE study \48\ by 0.91, which resulted in 19.2 million
units in 2020. DOE did not find data to characterize shipments by
equipment classes in that input power range.
---------------------------------------------------------------------------
\47\ Appliance Magazine market research, Appliance Historical
Statistical review, 1954-2012, January 2014.
\48\ See Chapter 9 of the ceiling fan preliminary analysis
Technical Support Document www.regulations.gov/document/EERE-2021-BT-STD-0011-0015.
---------------------------------------------------------------------------
For air circulating fans with input power greater than or equal to
125 W, DOE obtained 2021 shipments estimates from manufacturer
interviews for unhoused air circulating fan heads and cylindrical air
circulating fans.\49\ DOE then used model counts from the BESS Labs
Database to estimate market shares by air circulating fan category.
Table II-20 shows the estimated market shares by category based on
model counts from the BESS Labs Database. Based on this data, DOE
estimated that unhoused air circulating fan headsand cylindrical air
circulating fans represent a combined 30 percent of the total market of
air circulating fans with input power greater than or equal to 125 W.
In addition, DOE adjusted the market shares of unhoused air circulating
fan heads (22 percent) and cylindrical air circulating fans (8 percent)
from the BESS Labs database to account for the market shares from the
shipments estimates provided in manufacturer interviews (i.e., 20
percent and 10 percent, respectively). DOE then used unadjusted market
shares by category as presented in Table II-20 to calculate shipments
of air circulating fans for which manufacturer interviews did not
provide estimates. The BESS Labs Database does not include any housed
centrifugal air circulating fans. DOE did not find any data to estimate
the shipments of housed centrifugal air circulating fans.
---------------------------------------------------------------------------
\49\ Information from manufacturer interviews indicated
shipments estimates of 494,950 units of unhoused air circulating fan
heads and 255,100 units of cylindrical air circulating fans.
Table II-20--Air Circulating Fans With Input Power Greater Than or Equal to 125 W--Market Share by Equipment
Class (Excluding Housed Centrifugal Air Circulating Fans)
----------------------------------------------------------------------------------------------------------------
Market share Calculated Estimated 2021
DOE terminology BESS category based on model market share shipments
counts (%) (%) * (units)
----------------------------------------------------------------------------------------------------------------
Unhoused Air Circulating Fan Head..... Basket fan.............. 22 20 494,950
Box fan............................... Box fan................. 11 11 275,018
Air circulating axial panel fan....... Panel fan............... 59 59 1,475,098
Cylindrical air circulating fan....... Tube fan................ 8 10 255,100
Housed centrifugal air circulating fan N/A..................... N/A N/A N/A
-----------------------------------------------
Total............................. ........................ 100 100 2,500,167
----------------------------------------------------------------------------------------------------------------
* Adjusted market shares of Unhoused Air Circulating Fan Head and Cylindrical air circulating fan based on
shipments estimates from manufacturer interviews.
Finally for air circulating fans with input power greater than or
equal to 125 W, based on information from manufacturer interviews, DOE
estimated that while some fans are used in commercial and industrial
settings, the majority of these fans are used in agricultural
applications. In the absence of any quantitative data to characterize
the fraction of shipments by sector, DOE assumed 75 percent of
shipments are used in agricultural settings,\50\ 12.5 percent in
commercial settings, and 12.5 percent in industrial applications.
---------------------------------------------------------------------------
\50\ DOE assumed the mid-point between 50 and 100 percent of
shipments (75 percent) go to agriculture. Distributed the remaining
shipments equally across the commercial and industrial sectors.
---------------------------------------------------------------------------
2. Shipments Projections
In response to the February 2022 ECS RFI, ebm-papst suggested that
the growth of indoor horticulture, a need for farm animal cooling due
to climate change, and a need for auxiliary cooling on distribution
transformers due to electrification of climate change could all be
reasons for possible growth in the air circulating fan market. (ebm-
papst, No. 8 at p. 4)
To project shipments of air circulating fans with input power less
than 125 W, DOE is considering using an annual growth rate of 5 percent
based on the Appliance Magazine market research data,\51\ which
provides 1981-1994 shipments estimates for air circulating fans used in
residential settings.
---------------------------------------------------------------------------
\51\ Appliance Magazine market research, Appliance Historical
Statistical review, 1954-2012, January 2014.
---------------------------------------------------------------------------
For air circulating fans with input power greater than or equal to
125 W, DOE estimates that shipments of such fans follow similar trends
as shipments of large-diameter ceiling fans. Therefore, DOE is
considering projecting shipments of air circulating fans with input
power greater than or equal to 125 W based on the growth rates
projected for shipments of large-diameter ceiling fans.\52\ DOE notes
that this corresponds to a compound annual growth rate of 8.3 percent
for the period 2020-2030.
---------------------------------------------------------------------------
\52\ See Chapter 9 of the ceiling fan preliminary analysis
Technical Support Document (TSD) https://www.regulations.gov/document/EERE-2021-BT-STD-0011-0015.
---------------------------------------------------------------------------
DOE may consider alternative approaches to project shipments
depending on stakeholder comment and any additional data that may
become available.
Issue 33: DOE requests comment on the estimated 2020 shipments of
air circulating fans for each market segment considered (i.e., below
125 W, and at or above 125 W) and seeks input on the fraction of
shipments by air circulating fan category (i.e., unhoused air
circulating fan heads, air circulating axial panel fan, box fan,
cylindrical air circulating fan, and housed centrifugal air circulating
fan). In addition, DOE requests 2021 annual sales data (or the most
recent year available)--i.e., number of shipments--for air circulating
fans and annual historical shipments data for 2016-2020 (or most recent
years available). If disaggregated data of annual sales are not
available for different air circulating fan categories, DOE requests
more aggregated data of annual sales as available.
Issue 34: DOE requests comment on the estimated market share by
sector. DOE requests 2016-2021 data (or the most recent years
available) on the fraction of shipments in the industrial, commercial,
and residential sectors for
[[Page 62062]]
air circulating fans. In each sector, DOE requests 2016-2021 data (or
the most recent years available) on the fraction of shipments that
represent replacement versus new installations.
Issue 35: DOE requests comments on its approach to project
shipments of air circulating fans. DOE requests information on the rate
at which annual sales (i.e., number of shipments) of air circulating
fans is expected to change in the next 5-10 years. If possible, DOE
requests this information for each air circulating fan category (i.e.,
unhoused air circulating fan heads, air circulating axial panel fan,
box fan, cylindrical air circulating fan, and housed centrifugal air
circulating fan). If disaggregated data of annual sales are not
available for each air circulating fan category, DOE requests more
aggregated data of annual sales.
3. Equipment Efficiency Trends
A key component of the NIA is the trend in energy efficiency
projected for the no-new-standards case and each of the standards cases
over the entire 30-year analysis period. To project the trend in
efficiency absent amended standards for air circulating fans, DOE did
not find any historical equipment efficiency data. Instead, in order to
incorporate any efficiency trends, DOE may consider an approach that
shifts a fraction of the market share in the single-speed levels (e.g.,
1 percent) to the variable-speed efficiency levels to reflect the
growing market share of variable-speed air circulating fans. DOE may
consider alternative approaches to project equipment efficiency
depending on stakeholder comment and any additional data that may
become available.
For standards cases, DOE is considering a ``roll up'' scenario to
establish the shipment-weighted efficiency for the year that standards
are assumed to become effective. In this scenario, the market share of
products in the no-new-standards case that do not meet the standard
under consideration would ``roll up'' to meet the new standard level,
and the market share of products above the standard would remain
unchanged. To project the trend in efficiency in the various standard
case considered, DOE would then apply the same shift towards variable-
speed efficiency levels as in the no-new-standard case for the
standards cases.
Issue 36: DOE requests comments on its approach to project
equipment efficiency for air circulating fans. DOE requests data and
information on any trends in the fans market that could be used to
forecast expected trends in market share by efficiency levels for air
circulating fans. If disaggregated data are not available for each air
circulating fan category, DOE requests more aggregated data.
III. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding this
notification of data availability no later than the date provided in
the DATES section at the beginning of this document. Interested parties
may submit comments, data, and other information using any of the
methods described in the ADDRESSES section at the beginning of this
document.
Submitting comments via www.regulations.gov. The
www.regulations.gov web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (``CBI'')). Comments submitted
through www.regulations.gov cannot be claimed as CBI. Comments received
through the website will waive any CBI claims for the information
submitted. For information on submitting CBI, see the Confidential
Business Information section.
DOE processes submissions made through www.regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that www.regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or postal
mail. Comments and documents submitted via email, hand delivery/
courier, or postal mail also will be posted to www.regulations.gov. If
you do not want your personal contact information to be publicly
viewable, do not include it in your comment or any accompanying
documents. Instead, provide your contact information in a cover letter.
Include your first and last names, email address, telephone number, and
optional mailing address. The cover letter will not be publicly
viewable as long as it does not include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via postal mail
or hand delivery/courier, please provide all items on a CD, if
feasible, in which case it is not necessary to submit printed copies.
No telefacsimiles (``faxes'') will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free from
any defects or viruses. Documents should not contain special characters
or any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email two well-marked copies: one copy of the document marked
``confidential'' including all the information believed to be
confidential, and one copy of the document marked ``non-confidential''
with the information believed to be confidential deleted or redacted.
DOE will make its own determination about the confidential
[[Page 62063]]
status of the information and treat it according to its determination.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
B. Issues on Which DOE Seeks Comment
As indicated in the analyses previously, DOE is seeking further
comment and/or data on certain issues. For reference, these issues from
the above analyses include the following:
Issue 1: DOE requests comment on its assumption that most motors
paired with air circulating fans are lower efficiency induction motors
that are not currently regulated by DOE. Additionally, DOE requests
data on the percentage of air circulating fans that include a SP, PSC,
shaded pole, or electronically commuted motors.
Issue 2: DOE requests comment on if or how the five screening
criteria may impact the application of an aerodynamic redesign
(including changes to housing, impeller and/or blade design), more
efficient motors, or VSDs (``variable-speed drives'') as design options
in the current rulemaking analysis.
Issue 3: DOE requests comment on its assumption that the BESS Labs
Combined Database is representative of the air circulating fan head
market, with the exception of housed centrifugal air circulating fans
and air circulating fans with input power less than 125 W which are not
represented in the BESS Labs Combined Database.
Issue 4: DOE requests additional information for all categories of
air circulating fans, including: manufacturer name, model number, fan
diameter, blade number, blade shape, blade material, housing type,
housing material, spacing between the blade tip and the housing, and
housing depth with associated performance data obtained using AMCA 230-
15 with 2021 errata (or sufficient information that can be used to
correct to AMCA 230-15 with 2021 errata). DOE additionally requests the
following information on the motors sold within each fan model: motor
type (i.e., SP, PSC, ECM, polyphase, etc.), type of drive (i.e., direct
or belt), motor horsepower (``hp''), motor full-load efficiency (if
available), motor rotations per minute, number of speeds, motor
electric requirements (i.e., volts, amps, frequency, phase, AC/DC), and
whether a variable-speed drive is included with the fan.
Issue 5: DOE requests comment on the potential of using fan
affinity laws to extrapolate BESS Labs performance data to air
circulating fan heads with diameters less than 12 inches and greater
than 52 inches. Additionally, DOE requests model characteristics and
performance data obtained using AMCA 230-15 plus 2021 errata (or
sufficient information than can be used to correct to AMCA 230-15 plus
2021 errata) for air circulating fans with diameters both smaller than
and larger than those listed in the BESS Labs Database.
Issue 6: DOE requests comment on whether, and if so how, each of
the following performance-related features may impact utility of air
circulating fans: presence or absence of a safety guard, presence or
absence of housing, housing design, blade type, drive type, number of
discrete speed settings, power requirements, and air velocity or throw.
DOE requests additional feedback and data or information on other air
circulating fan features that may impact utility for the end user and
might form the basis for classification.
Issue 7: DOE requests comment with supporting data on whether the
following performance-related features provide substantially different
utility, or are expected to have a significant impact on efficiency
because of how they are used: (1) housed vs. unhoused air circulating
fan heads; (2) direct-driven vs. belt-driven air circulating fan heads;
and (3) single-phase vs. polyphase air circulating fan heads. DOE also
requests information on any additional features that may impact air
circulating fan head utility.
Issue 8: DOE requests comment on whether the diameters chosen for
representative units in this analysis (i.e., 12 inches, 20 inches, 24
inches, 36 inches, and 50 inches) accurately represent the diameters
with the highest sales volume available in the air circulating fan
market. DOE also requests comment on whether diameter is an appropriate
representative metric for air circulating fans.
Issue 9: DOE requests comment on whether the motor hp it has
associated with each representative diameter (i.e., 0.1 hp for 12
inches, 0.33 hp for 20 inches, 0.5 hp for 24 inches and 36 inches, and
1 hp for 50 inches) appropriately represent the motor hp for fans sold
with those corresponding diameters.
Issue 10: DOE requests comment on its use of SP motors as the
baseline for air circulating fans. Additionally, DOE seeks feedback on
its choice of motor technologies (SP motor to PSC 1 motor, PSC 1 motor
to PSC 2 motor, and PSC 2 motor to ECM) to estimate air circulating fan
efficiency increases from one efficiency level to the next.
Issue 11: DOE requests comment on its assumption that motors used
in air circulating fans are exclusively air-over motors. If this is not
the case, DOE requests information on the other types of motors that
are sold with air circulating fans and data on the percentage of air
circulating fans that are sold with motors other than air-over motors.
Additionally, DOE requests information on whether or not the type of
motor supplied with an air circulating fan is a function of air
circulating fan category (e.g., unhoused air circulating fan head, box
fan, cylindrical air circulating fan, etc.).
Issue 12: DOE requests feedback on whether catalog performance data
on SP motors and PSC motors is generally representative of the
performance of the SP and PSC motors included with air circulating
fans.
Issue 13: DOE requests feedback on the methodology used to
determine the baseline efficiency values for the representative units,
including its method of first establishing the EL1 efficiency and then
determining the baseline efficiency by reducing the EL1 efficiency by
the difference in efficiency between a PSC motor and a SP motor.
Additionally, DOE requests data on the expected average improvement in
air circulating fan efficiency when a SP motor is replaced by a PSC 1
motor.
Issue 14: DOE requests feedback on its assumption that airflow,
pressure, and motor performance (for example, speed and inrush current)
remain constant when replacing a less efficient motor with a more
efficient motor in an air circulating fan. If airflow, pressure, or
motor performance are not maintained when using a more efficient motor,
DOE requests feedback and data on how it should conduct this analysis.
Issue 15: DOE requests feedback on whether the efficiency gains
shown in the supplementary spreadsheet are realistic efficiency gains
when replacing a lower efficiency PSC motor (i.e., PSC 1 motor) with a
higher efficiency PSC motor (i.e., PSC 2 motor). If these assumptions
are not realistic, DOE requests data demonstrating air circulating fan
motor efficiency as a function of hp, as well as data for motor hp as a
function of fan diameter.
Issue 16: DOE requests feedback on its use of dedicated purpose
pool pump motors as a source for comparing PSC motor and ECM
efficiency. Additionally, DOE requests information on whether motors
used for this purpose are comparable to air circulating fan motors. DOE
further requests feedback on whether the efficiency increases from
[[Page 62064]]
PSC 1 motors to ECM that DOE presents are realistic. If dedicated
purpose pool pump motors are not representative of air circulating fans
motors, or DOE's estimated efficiency increases are not realistic, DOE
requests data on the difference between PSC 1 motor efficiency and ECM
efficiency and the difference between PSC 2 motor efficiency and ECM
efficiency for air circulating fans. DOE also requests comment on its
use of extrapolation of these data to obtain efficiency values at
fractional hp.
Issue 17: DOE requests feedback on the FEI values that it
determined and its approach for estimating FEI values for an air
circulating fan that includes both an ECM and improved aerodynamic
design.
Issue 18: DOE requests comment on its factory parameter assumptions
for typical air circulating fan production.
Issue 19: DOE requests comment on whether or not its baseline
material assumptions are representative of baseline fans distributed
into commerce. If DOE's baseline material assumptions are not
representative, DOE requests information and data on materials typicaly
used in the air circulating fans currently on the market.
Issue 20: DOE requests comment on its estimated base MPC for air
circulating fans with no motors at each of the representative diameters
evaluated. (See supplemental spreadsheet included in Docket No. EERE-
2022-BT-STD-0002, No. 11)
Issue 21: DOE requests comment on whether replacing a given fan
motor with a more efficient fan motor will result in similar efficiency
and cost impacts for housed and unhoused air circulating fan heads.
Issue 22: DOE requests comment on its estimated motor costs SP
motors (EL0), PSC motors (EL1), higher efficiency PSC motors (EL2), and
ESMs (EL3) at each hp associated with the representative diameters
evaluated. (See supplemental spreadsheet included in Docket No. EERE-
2022-BT-STD-0002, No. 11)
Issue 23: DOE requests comment on its estimated housed and unhoused
air circulating fan costs at each EL and for each representative unit.
(See supplemental spreadsheet included in Docket No. EERE-2022-BT-STD-
0002, No. 11)
Issue 24: DOE requests comment on and additional data to support
its estimated air circulating fan conversion costs to undergo
aerodynamic redesign.
Issue 25: DOE requests comment on whether or not an average MSP of
1.5 is representative for the air circulating fan market. If an average
MSP of 1.5 is not representative, DOE requests information of what a
more representative MSP would be. Additionally, DOE requests comment on
whether or not MSP for air circulating fans will remain constant in the
case of new energy conservation standards. If not, DOE seeks
information on the magnitude by which MSP might change under potential
energy efficiency standards.
Issue 26: DOE requests feedback and information on the distribution
channels identified for air circulating fans, and on any other
distribution channel that DOE should consider. DOE also requests data
on the fraction of sales that go through these channels.
Issue 27: DOE seeks comment on the estimated average number of
operating hours per year, distribution of operating hours, and the
estimated fraction of time spent at each speed setting for air
circulating fans with input power less than 125 W and those with input
ower greater than or equal to 125 W. In addition, if DOE should
consider different operating hours for specific applications (e.g., air
circulating fans used in agricultural applications, thermal mixing
fans) DOE requests data on how to best characterize operating hours for
these various applications.
Issue 28: DOE requests feedback on the inputs and considered
methods used for the LCC and PBP analyses.
Issue 29: DOE requests information on its assumptions related to
installation, maintenance, and repair practices of air circulating
fans. Specifically, DOE requests feedback and data on whether
installation, maintenance, and repair costs of air circulating fans are
expected to be different at higher efficiency levels in comparison to
the baseline installation, maintenance, and repair costs. To the extent
that these costs differ, DOE seeks supporting data and the reasons for
those differences.
Issue 30: DOE requests information on the repair frequency of air
circulating fans (i.e., how many repairs in a lifetime) by category
(i.e., unhoused air circulating fan heads, air circulating axial panel
fan, box fan, cylindrical air circulating fan, and housed centrifugal
air circulating fan) and on its approach to consider a single repair
for certain air circulating fans with input power greater than or equal
to 125 W.
Issue 31: DOE requests comment on the estimated average equipment
lifetimes for air circulating fans. DOE also requests information
related to minimum and maximum equipment lifetimes (in years or total
mechanical hours).
Issue 32: DOE requests comment on its approach to derive efficiency
distribution in the no-new standards case for each air circulating fan
category and input regarding 2021 (or most recent year available)
equipment efficiency distributions. Additionally, DOE seeks data that
would support changes in efficiency distributions over time in the no-
new standards case. To the extent any of the efficiency distributions
in the no-new standards case differ by size or other consumer or design
characteristic, DOE requests information to characterize these
variations.
Issue 33: DOE requests comment on the estimated 2020 shipments of
air circulating fans for each market segment considered (i.e., below
125 W, and at or above 125 W) and seeks input on the fraction of
shipments by air circulating fan category (i.e., unhoused air
circulating fan heads, air circulating axial panel fan, box fan,
cylindrical air circulating fan, and housed centrifugal air circulating
fan). In addition, DOE requests 2021 annual sales data (or the most
recent year available)--i.e., number of shipments--for air circulating
fans and annual historical shipments data for 2016-2020 (or most recent
years available). If disaggregated data of annual sales are not
available for different air circulating fan categories, DOE requests
more aggregated data of annual sales as available.
Issue 34: DOE requests comment on the estimated market share by
sector. DOE requests 2016-2021 data (or the most recent years
available) on the fraction of shipments in the industrial, commercial,
and residential sectors for air circulating fans. In each sector, DOE
requests 2016-2021 data (or the most recent years available) on the
fraction of shipments that represent replacement versus new
installations.
Issue 35: DOE requests comments on its approach to project
shipments of air circulating fans. DOE requests information on the rate
at which annual sales (i.e., number of shipments) of air circulating
fans is expected to change in the next 5-10 years. If possible, DOE
requests this information for each air circulating fan category (i.e.,
unhoused air circulating fan heads, air circulating axial panel fan,
box fan, cylindrical air circulating fan, and housed centrifugal air
circulating fan). If disaggregated data of annual sales are not
available for each air circulating fan category, DOE requests more
aggregated data of annual sales.
Issue 36: DOE requests comments on its approach to project
equipment efficiency for air circulating fans. DOE requests data and
information on any trends in the fans market that could be used to
forecast expected trends in
[[Page 62065]]
market share by efficiency levels for air circulating fans. If
disaggregated data are not available for each air circulating fan
category, DOE requests more aggregated data.
IV. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this
notification of the availability of the preliminary technical support
document and request for comment.
Signing Authority
This document of the Department of Energy was signed on October 5,
2022, by Francisco Alejandro Moreno, Acting Assistant Secretary for
Energy Efficiency and Renewable Energy, pursuant to delegated authority
from the Secretary of Energy. That document with the original signature
and date is maintained by DOE. For administrative purposes only, and in
compliance with requirements of the Office of the Federal Register, the
undersigned DOE Federal Register Liaison Officer has been authorized to
sign and submit the document in electronic format for publication, as
an official document of the Department of Energy. This administrative
process in no way alters the legal effect of this document upon
publication in the Federal Register.
Signed in Washington, DC, on October 6, 2022.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
[FR Doc. 2022-22141 Filed 10-12-22; 8:45 am]
BILLING CODE 6450-01-P