Energy Conservation Program: Energy Conservation Standards for Fans and Blowers, 3714-3875 [2023-28976]
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3714
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Parts 429 and 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: Notice of proposed rulemaking
and announcement of public meeting.
AGENCY:
The Energy Policy and
Conservation Act, as amended
(‘‘EPCA’’), prescribes energy
conservation standards for various
consumer products and certain
commercial and industrial equipment,
including fans and blowers. EPCA also
requires the U.S. Department of Energy
(‘‘DOE’’) to periodically determine
whether more stringent standards would
be technologically feasible and
economically justified and would result
in significant energy savings. In this
notice of proposed rulemaking
(‘‘NOPR’’), DOE proposes energy
conservation standards for two
categories of fans and blowers: air
circulating fans (‘‘ACFs’’), and fans and
blowers that are not ACFs, referred to as
general fans and blowers (‘‘GFBs’’)
throughout this document. DOE also
announces a public meeting to receive
comment on these proposed standards
and associated analyses and results.
DATES: Comments: DOE will accept
comments, data, and information
regarding this NOPR no later than
March 19, 2024.
Meeting: DOE will hold a public
meeting on Wednesday, February 21,
2024, from 10 a.m. to 4 p.m., in
Washington, DC. This meeting will also
be broadcast as a webinar.
Comments regarding the likely
competitive impact of the proposed
standard should be sent to the
Department of Justice contact listed in
the ADDRESSES section on or before
February 20, 2024.
ADDRESSES: The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 6E–069, 1000
Independence Avenue SW, Washington,
DC 20585. See section VII of this
document, ‘‘Public Participation,’’ for
further details, including procedures for
attending the in-person meeting,
webinar registration information,
participant instructions, and
information about the capabilities
available to webinar participants.
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SUMMARY:
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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:
FansAndBlowers2022STD0002@
ee.doe.gov. Include docket number
EERE–2022–BT–STD–0002 in the
subject line of the message.
No telefacsimiles (‘‘faxes’’) will be
accepted. For detailed instructions on
submitting comments and additional
information on this process, see section
VII of this document.
Docket: The docket for this activity,
which includes Federal Register
notices, comments, 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,
not all documents listed in the index
may be publicly available, such as
information that is exempt from public
disclosure.
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 VII
of this document for information on
how to submit comments through
www.regulations.gov.
EPCA requires the Attorney General
to provide DOE a written determination
of whether the proposed standard is
likely to lessen competition. The U.S.
Department of Justice Antitrust Division
invites input from market participants
and other interested persons with views
on the likely competitive impact of the
proposed standard. Interested persons
may contact the Division at
energy.standards@usdoj.gov on or
before the date specified in the DATES
section. Please indicate in the ‘‘Subject’’
line of your email the title and Docket
Number of this proposed rulemaking.
FOR FURTHER INFORMATION CONTACT: Mr.
Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies Office, EE–5B, 1000
Independence Avenue SW, Washington,
DC 20585–0121. Telephone: (202) 586–
9870. Email:
ApplianceStandardsQuestions@
ee.doe.gov.
Ms. Amelia Whiting, U.S. Department
of Energy, Office of the General Counsel,
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GC–33, 1000 Independence Avenue SW,
Washington, DC 20585–0121.
Telephone: (202) 586–2588. Email:
Amelia.Whiting@hq.doe.gov.
For further information on how to
submit a comment, review other public
comments and the docket, or participate
in the public meeting, contact the
Appliance and Equipment Standards
Program staff at (202) 287–1445 or by
email: ApplianceStandardsQuestions@
ee.doe.gov.
DOE
maintains previously approved
incorporations by reference (AMCA
210–16, AMCA 214–21, and ISO
5801:2017) and incorporates by
reference the following material into
part 431:
IEC 61800–9–2:2023, Adjustable
speed electrical power drive systems
(PDS)—Part 9–2: Ecodesign for motor
systems—Energy efficiency
determination and classification,
Edition 2.0, 2023–10.
IEC TS 60034–30–2:2016, Rotating
electrical machines—Part 30–2:
Efficiency classes of variable speed AC
motors (IE-code), Edition 1.0, 2016–12.
IEC TS 60034–31:2021, Rotating
electrical machines—Part 31: Selection
of energy-efficient motors including
variable speed applications—
Application guidelines, Edition 2.0,
2021–03.
Copies of IEC 61800–9–2:2023, IEC TS
60034–30–2:2016 and IEC TS 60034–
31:2021 are available from the
International Electrotechnical
Committee (IEC), Central Office, 3, rue
de Varembe´, P.O. Box 131, CH–1211
GENEVA 20, Switzerland; + 41 22 919
02 11; webstore.iec.ch.
For a further discussion of these
standards, see section VI.M of this
document.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
1. General Fans and Blowers
2. Air Circulating Fans
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for
Fans and Blowers
C. Deviation From Process Rule
1. Framework Document
2. Public Comment Period
III. General Discussion
A. General Comments
B. Scope of Coverage
1. General Fans and Blowers
2. Air Circulating Fans
a. Ceiling Fan Distinction
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C. Test Procedure and Metric
1. General Fans and Blowers
a. General
b. Combined Motor and Motor Controller
Efficiency Calculation
2. Air Circulating Fans
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible
Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and
Consumers
b. Savings in Operating Costs Compared to
Increase in Price (LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of
Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related
Comments
A. Market and Technology Assessment
1. Equipment Classes
a. General Fans and Blowers
b. Air Circulating Fans
2. Scope of Analysis and Data Availability
a. General Fans and Blowers
b. Air Circulating Fans
3. Technology Options
B. Screening Analysis
C. Engineering Analysis
1. General Fans and Blowers
a. Baseline Efficiency
b. Selection of Efficiency Levels
c. Higher Efficiency Levels
d. Cost Analysis
2. Air Circulating Fans
a. Representative Units
b. Baseline Efficiency and Efficiency Level
1
c. Selection of Efficiency Levels
d. Cost Analysis
3. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
1. General Fans and Blowers
2. Air-Circulating fans
F. Life-Cycle Cost and Payback Period
Analyses
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Equipment Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the NoNew-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
1. General Fans and Blowers
2. Air Circulating Fans
H. National Impact Analysis
1. Equipment Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
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2. Government Regulatory Impact Model
and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Product and Capital Conversion Costs
d. Markup Scenarios
3. Manufacturer Interviews
4. Discussion of MIA Comments
K. Emissions Analysis
1. Air Quality Regulations Incorporated in
DOE’s Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas
Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous
Oxide
2. Monetization of Other Emissions
Impacts
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy
Savings
1. Economic Impacts on Individual
Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs
and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of
Products
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
8. Summary of Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs
Considered for Fans and Blowers
Standards
a. General Fans and Blowers
b. Air Circulating Fans
2. Annualized Benefits and Costs of the
Proposed Standards
a. General Fans and Blowers
b. Air Circulating Fans
D. Reporting, Certification, and Sampling
Plan
E. Representations and Enforcement
Provisions
1. Representations for General Fans and
Blowers
2. Enforcement Provisions for General Fans
and Blowers
a. Testing a Single Fan at Multiple Duty
Points
b. Testing Multiple Fans at One or Several
Duty Points
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866,
13563, and 14094
B. Review Under the Regulatory Flexibility
Act
1. Description of Reasons Why Action Is
Being Considered
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2. Objectives of, and Legal Basis for, Rule
3. Description on Estimated Number of
Small Entities Regulated
4. Description and Estimate of Compliance
Requirements Including Differences in
Cost, if Any, for Different Groups of
Small Entities
5. Duplication, Overlap, and Conflict With
Other Rules and Regulations
6. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction
Act
D. Review Under the National
Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates
Reform Act of 1995
H. Review Under the Treasury and General
Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General
Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
M. Description of Materials Incorporated
by Reference
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared
General Statements for Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
The Energy Policy and Conservation
Act, Public Law 94–163, 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 2 of EPCA
established the Energy Conservation
Program for Certain Industrial
Equipment. (42 U.S.C. 6311–6317) Such
equipment includes fans and blowers.
This proposed rule concerns two
categories of fans and blowers: air
circulating fans (‘‘ACFs’’), and fans and
blowers that are not ACFs, which are
referred to as general fans and blowers
(‘‘GFBs’’) throughout this document.
Pursuant to EPCA, any new or
amended energy conservation standard
must be designed to achieve the
maximum improvement in energy
efficiency that DOE determines is
technologically feasible and
economically justified. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(A))
Furthermore, the new or amended
standard must result in a significant
conservation of energy. (42 U.S.C.
1 All references to EPCA in this document refer
to the statute as amended through the Energy Act
of 2020, Public Law 116–260 (Dec. 27, 2020), which
reflect the last statutory amendments that impact
Parts A and A–1 of EPCA.
2 For editorial reasons, upon codification in the
U.S. Code, Part C was redesignated Part A–1.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
6316(a); 42 U.S.C. 6295(o)(3)(B)) EPCA
also provides that not later than 6 years
after issuance of any final rule
establishing or amending a standard,
DOE must publish either a notice of
determination that standards for the
product do not need to be amended, or
a notice of proposed rulemaking
including new proposed energy
conservation standards (proceeding to a
final rule, as appropriate). (42 U.S.C.
6316(a); 42 U.S.C. 6295(m))
In accordance with these and other
statutory provisions discussed in this
document, DOE analyzed the benefits
and burdens of six trial standard levels
(‘‘TSLs’’) for two categories of fans and
blowers: GFBs and ACFs. The TSLs and
their associated benefits and burdens
are discussed in detail in sections V.A
through V.C of this document. As
discussed in section V.C, DOE has
tentatively determined that TSL 4
represents the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified. The proposed
standards, which are expressed in terms
of a fan energy index (‘‘FEI’’) for GFBs,
are shown in Table I–1 through Table I–
3. The proposed standards, which are
expressed in terms of efficacy in cubic
feet per minute per watt (‘‘CFM/W’’) at
maximum speed for ACFs, are shown in
Table I–3. These proposed standards, if
adopted, would apply to all GFBs listed
in Table I–1 and Table I–2 and ACFs
listed in Table I–3 manufactured in, or
imported into, the United States starting
on the date 5 years after the publication
of the final rule for this rulemaking. For
GFBs, DOE proposes that every duty
point at which the basic model is
offered for sale would need to meet the
proposed energy conservation
standards. (See section III.C.1 of this
document).
BILLING CODE 6450–01–P
Tabl e I- 1 P ropose dE ner !!V Conservafion St an dar ds f or GFB s
Equipment Class
With or Without
Fan Energy Index
(FEI)*
Motor Controller
Axial Inline
Without
1.18 * A
Axial Panel
Without
1.48 * A
Axial Power Roof Ventilator
Without
0.85 * A
Centrifugal Housed
Without
1.31 * A
Centrifugal Unhoused
Without
1.35 * A
Centrifugal Inline
Without
1.28 * A
1.17*A
Radial Housed
Without
Centrifugal Power Roof Ventilator Without
1.00 * A
- Exhaust
Centrifugal Power Roof Ventilator Without
1.19 * A
- Supply
1.18*A*B
Axial Inline
With
1.48 *A* B
Axial Panel
With
0.85 * A* B
With
Axial Power Roof Ventilator
1.31*A*B
Centrifugal Housed
With
1.35 *A* B
Centrifugal Unhoused
With
1.28 * A* B
Centrifugal Inline
With
1.17*A*B
Radial Housed
With
1.00 * A* B
Centrifugal Power Roof Ventilator With
- Exhaust
1.19*A*B
Centrifugal Power Roof Ventilator With
- Supply
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*A is a constant representing an adjustment in FEI for motor hp, which can be found in Table 1-2. B is a
constant representing an adjustment in FEI for motor controllers, which can be found in Table 1-2
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3717
Table 1-2 Constants for GFB Proposed Ener2v Conservation Standards
Constant Condition
Value
Motor hp < I 00 hp
A
A= 1.00
Y/mtr,ZOZ3act
Motor hp 2: I 00 hp and :S 250 hp
A=
B
With Motor
Controller
FEPact of<
20 kW (26.8
hp)
FEPact of 2:
20 kW (26.8
hp)
B=
Y/mtr,Z014ref
FEPact-Credit
h
FEPact
; were:
Credit= 0.03
[SI]
X FEPact
+ 0.08
Credit= 0.03
1.341 rIPl
B = 0.966
X FEPact
+ 0.08 X
is the motor efficiency in accordance with table 8 at 10 CFR 431.25, l]m1r,2014 is the motor efficiency
in accordance with table 5 at 10 CFR 431.25, which DOE is proposing to adopt into 10 CFR 431.175, and
FEPact is determined according to the DOE test procedure in appendix A to subpart J of part 431.
l]m1r,2023
Table 1-3 Proposed Enerev Conservation Standards for ACFs
Equipment Class
.
Efficacy at Maximum Speed
(CFM/W)
12.2
17.3
21.5
NIA
Table I–4 and Table I–5 present DOE’s
evaluation of the economic impacts of
the proposed standards on consumers of
GFBs and ACFs, as measured by the
average life-cycle cost (‘‘LCC’’) savings
and the simple payback period
(‘‘PBP’’).3 The average LCC savings are
positive for all equipment classes, and
the PBP is less than the average lifetime
of the considered equipment, which is
estimated to be 16.0 years for GFBs and
6.3 years for ACFs (see section IV.F.6 of
this document).
3 The average LCC savings refer to consumers that
are affected by a standard and are measured relative
to the efficiency distribution in the no-newstandards case, which depicts the market in the
compliance year in the absence of new or amended
standards (see section IV.E.9 of this document). The
simple PBP, which is designed to compare specific
efficiency levels, is also measured relative to the no-
new-standards case (see section IV.C of this
document).
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A. Benefits and Costs to Consumers
EP19JA24.002
Axial ACFs; 12 inches :'.SD < 36 inches
Axial ACFs; 36 inches :'.SD < 48 inches
Axial ACFs; 48 inches :'.S D
Housed Centrifugal ACFs
•D: Diameter in inches
NIA: Not applicable; DOE is not proposing to set a standard for this equipment class.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table 1-4 Impacts of Proposed Energy Conservation Standards on Consumers of
GFBs
Average LCC Savings
Equipment Class
550
1,702
2,423
955
1,170
945
Simple Payback Period
Years
9.6
1.7
0.6
6.1
1.2
7.0
154
8.9
973
1.7
3,714
1.7
2022$
Axial Inline
Axial Panel
Centrifugal Housed
Centrifugal Inline
Centrifugal Unhoused
Axial Power Roof Ventilator
Centrifugal Power Roof
Ventilator - Exhaust
Centrifugal Power Roof
Ventilator - Supply
Radial Housed
Table 1-5 Impacts of Proposed Energy Conservation Standards on Consumers of
ACFs
Average LCC Savings
Axial ACFs; 12 inches :'.SD <
36inches
Axial ACFs; 36 inches :'.SD <
48inches
Axial ACFs; 48 inches :'.S D
Housed Centrifugal ACFs
•o: diameter in inches
NIA: Not applicable; DOE is not proposing to
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DOE’s analysis of the impacts of the
proposed standards on consumers is
described in section IV.F of this
document.
B. Impact on Manufacturers
The industry net present value
(‘‘INPV’’) is the sum of the discounted
cash flows to the industry from the base
year through the end of the analysis
period (2024–2059). Using a real
discount rate of 11.4 percent, DOE
estimates that the INPV for
manufacturers of fans and blowers in
the case without new standards is $649
million in 2022 dollars for ACFs and
$4,935 million in 2022 dollars for GFBs.
Under the proposed standards, the
change in INPV is estimated to range
from ¥10.9 percent to less than 0.1
percent for ACFs, which represents a
change in INPV of approximately ¥$71
million to less than $0.1 million, and
from ¥9.2 percent to less than 0.1
percent for GFBs, which represents a
change in INPV of approximately
¥$455 million to $1 million. In order to
bring products into compliance with
new standards, it is estimated that the
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2022$
Simple Payback Period
Years
327
0.5
478
0.2
668
NIA
0.1
NIA
set a standard for this equipment class.
industry would incur total conversion
costs of $118 million for ACFs and $770
million for GFBs.
DOE’s analysis of the impacts of the
proposed standards on manufacturers is
described in section IV.J of this
document. The analytic results of the
manufacturer impact analysis (‘‘MIA’’)
are presented in section V.B.2 of this
document.
C. National Benefits and Costs 4
This section presents the combined
results for GFBs and ACFs. Specific
results for GFBs and ACFs are also
discussed in sections I.C.1 and I.C.2 of
this document, respectively.
DOE’s analyses indicate that the
proposed energy conservation standards
for GFBs and ACFs would save a
significant amount of energy. Relative to
the case without new standards, the
lifetime energy savings for GFBs and
ACFs purchased in the 30-year period
that begins in the anticipated first full
year of compliance with the new
standards (2030–2059) amount to 18.3
4 All monetary values in this document are
expressed in 2022 dollars.
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quadrillion British thermal units
(‘‘Btu’’), or quads.5
The cumulative net present value
(‘‘NPV’’) of total consumer benefits of
the proposed standards for GFBs and
ACFs ranges from $19.0 billion (at a 7
percent discount rate) to $49.5 billion
(at a 3 percent discount rate). This NPV
expresses the estimated total value of
future operating cost savings minus the
estimated increased equipment and
installation costs for GFBs and ACFs
purchased in 2030–2059.
In addition, the proposed standards
for GFBs and ACFs are projected to
yield significant environmental benefits.
DOE estimates that the proposed
standards would result in cumulative
emission reductions (over the same
period as for energy savings) of 317.9
5 The quantity refers to full-fuel-cycle (‘‘FFC’’)
energy savings. FFC energy savings includes the
energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas,
petroleum fuels), and, thus, presents a more
complete picture of the impacts of energy efficiency
standards. For more information on the FFC metric,
see section IV.G.1 of this document.
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Equipment Class
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
million metric tons (‘‘Mt’’) 6 of carbon
dioxide (‘‘CO2’’), 92.7 thousand tons of
sulfur dioxide (‘‘SO2’’), 598.9 thousand
tons of nitrogen oxides (‘‘NOX’’), 2,760.5
thousand tons of methane (‘‘CH4’’), 2.9
thousand tons of nitrous oxide (‘‘N2O’’),
and 0.6 tons of mercury (‘‘Hg’’).7
DOE estimates the value of climate
benefits from a reduction in greenhouse
gases (‘‘GHG’’) using four different
estimates of the social cost of CO2 (‘‘SC–
CO2’’), the social cost of methane (‘‘SC–
CH4’’), and the social cost of nitrous
oxide (‘‘SC–N2O’’). Together these
represent the social cost of GHG (‘‘SC–
GHG’’). DOE used interim SC–GHG
values developed by an Interagency
Working Group on the Social Cost of
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6 A metric ton is equivalent to 1.1 short tons.
Results for emissions other than CO2 are presented
in short tons.
7 DOE calculated emissions reductions relative to
the no-new-standards case, which reflects key
assumptions in the Annual Energy Outlook 2023
(‘‘AEO2023’’). AEO2023 represents current Federal
and State legislation and final implementation of
regulations as of the time of its preparation. See
section IV.J of this document for further discussion
of AEO2023 assumptions that affect air pollutant
emissions.
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Greenhouse Gases (‘‘IWG’’).8 The
derivation of these values is discussed
in section IV.L of this document. For
presentational purposes, the climate
benefits associated with the average SC–
GHG at a 3 percent discount rate are
estimated to be $16.3 billion. DOE does
not have a single central SC–GHG point
estimate and it emphasizes the
importance and value of considering the
benefits calculated using all four sets of
SC–GHG estimates.
DOE estimated the monetary health
benefits of SO2 and NOX emissions
reductions using benefit per ton
estimates from the scientific literature,
as discussed in section IV.L of this
document. DOE did not monetize the
reduction in mercury emissions because
the quantity is very small. DOE
8 To monetize the benefits of reducing GHG
emissions, this analysis uses the interim estimates
presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990,
published in February 2021 by the IWG (‘‘February
2021 SC–GHG TSD’’). www.whitehouse.gov/wpcontent/uploads/2021/02/
TechnicalSupportDocument_
SocialCostofCarbonMethaneNitrousOxide.pdf.
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3719
estimated the present value of the health
benefits would be $11.4 billion using a
7 percent discount rate, and $31.6
billion using a 3 percent discount rate.9
DOE is currently only monetizing (for
SO2 and NOX) PM2.5 precursor health
benefits and (for NOX) ozone precursor
health benefits, but will continue to
assess the ability to monetize other
effects such as health benefits from
reductions in direct PM2.5 emissions.
Table I–6 summarizes the monetized
benefits and costs expected to result
from the proposed standards for GFBs
and ACFs. There are other important
unquantified effects, including certain
unquantified climate benefits,
unquantified public health benefits from
the reduction of toxic air pollutants and
other emissions, unquantified energy
security benefits, and distributional
effects, among others.
BILLING CODE 6450–01–P
9 DOE estimates the economic value of these
emissions reductions resulting from the considered
trial standards levels (‘‘TSLs’’) for the purpose of
complying with the requirements of Executive
Order 12866.
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3720
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table 1-6 Present Value of Monetized Benefits and Costs of Proposed Energy
Conservation Standards for GFBs and ACFs (TSL 4)
Billion $2022
3% discount rate
Consumer Operating Cost Savings
55.8
Climate Benefits*
16.3
Health Benefits**
31.6
Total Monetized Benefitst
103.7
Consumer Incremental Equipment
Costs!
6.3
Net Monetized Benefits
97.4
Change in Producer Cashflow
(INPV:1:t)
(0.5) - 0
7% discount rate
Consumer Operating Cost Savings
22.2
Climate Benefits* (3% discount rate)
16.3
Health Benefits**
11.4
Total Monetized Benefitst
49.8
Consumer Incremental Equipment
Costs:;:
3.2
Net Monetized Benefits
46.6
(0.5) - 0
Note: This table presents the costs and benefits associated with GFBs and ACFs shipped in 2030-2059.
These results include consumer, climate, and health benefits that accrue after 2059 from the products
shipped in 2030-2059.
* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO2),
methane (SC-C~), and nitrous oxide (SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent
discount rates; 95th percentile at 3 percent discount rate) (see section IV.L of this document). Together
these represent the global SC-GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3-percent discount rate are shown, but DOE does not have a
single central SC-GHG point estimate. To monetize the benefits of reducing GHG emissions, this analysis
uses the interim estimates presented in the Technical Support Document: Social Cost of Carbon, A/ethane,
and Nitrous Oxide Interim Estimates Under Executive Order 13990, published in February 2021 by the
IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for S~ and NOx) PM2s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2_5 emissions. See section IV.L of this document for more details.
t Total and net benefits include those consumer, climate, and health benefits that can be quantified and
moncti7.cd. For presentation pmposcs, total and net benefits for both the 3 percent and 7 percent cases arc
presented using the average SC-GHG with a 3 percent discount rate, but DOE does not have a single
central SC-GHG point estimate. DOE emphasizes the importance and value of considering the benefits
calculated using all four sets of SC-GHG estimates.
l Costs include incremental equipment costs as well as installation costs.
tt Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.Hof this document. DOE's NIA includes all
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3721
The benefits and costs of the proposed
standards can also be expressed in terms
of annualized values. The monetary
values for the total annualized net
benefits are (1) the reduced consumer
operating costs, minus (2) the increase
in product purchase prices and
installation costs, plus (3) the monetized
value of climate and health benefits of
emission reductions, all annualized.10
The national operating cost savings
are domestic private U.S. consumer
monetary savings that occur as a result
of purchasing the covered products and
are measured for the lifetime of GFBs
and ACFs shipped in 2030–2059. The
benefits associated with reduced
emissions achieved as a result of the
proposed standards are also calculated
based on the lifetime of GFBs and ACFs
shipped in 2030–2059. Total benefits for
both the 3 percent and 7 percent cases
are presented using the average GHG
social costs with a 3-percent discount
rate.11 Estimates of total benefits are
presented for all four SC–GHG discount
rates in section V.B.6 of this document.
Table I–7 presents the total estimated
monetized benefits and costs associated
with the proposed standard, expressed
in terms of annualized values. The
results under the primary estimate are
as follows.
Using a 7 percent discount rate for
consumer benefits and costs and health
benefits from reduced NOX and SO2
emissions, and the 3 percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
cost of the standards proposed in this
rule is $360 million per year in
increased equipment costs, while the
estimated annual benefits are $2,506
million in reduced equipment operating
costs, $963 million in monetized
climate benefits, and $1,285 million in
monetized health benefits. In this case,
the monetized net benefit would
amount to $4,394 million per year.
Using a 3 percent discount rate for all
benefits and costs, the estimated cost of
the proposed standards is $374 million
per year in increased equipment costs,
while the estimated annual benefits are
$3,302 million in reduced operating
costs, $963 million in monetized
climate benefits, and $1,869 million in
monetized health benefits. In this case,
the monetized net benefit would
amount to $5,760 million per year.
10 To convert the time-series of costs and benefits
into annualized values, DOE calculated a present
value in 2024, the year used for discounting the
NPV of total consumer costs and savings. For the
benefits, DOE calculated a present value associated
with each year’s shipments in the year in which the
shipments occur (e.g., 2030), and then discounted
the present value from each year to 2024. Using the
present value, DOE then calculated the fixed annual
payment over a 30-year period, starting in the
compliance year, that yields the same present value.
11 As discussed in section IV.L.1 of this
document, DOE agrees with the IWG that using
consumption-based discount rates e.g., 3 percent) is
appropriate when discounting the value of climate
impacts. Combining climate effects discounted at an
appropriate consumption-based discount rate with
other costs and benefits discounted at a capitalbased rate (i.e., 7 percent) is reasonable because of
the different nature of the types of benefits being
measured.
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impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
manufacturer to manufacture the equipment and ending with the increase in price experienced by the
consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA).
See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions
based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces
a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present
value of all changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. Change in INPV is calculated using the industry weighted average cost of
capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD for a complete
description of the industry weighted average cost of capital). For GFB & ACF, those values are -$526
million and $1 million. DOE accounts for that range of likely impacts in analyzing whether a TSL is
economically justified. See section V. C of this document. DOE is presenting the range of impacts to the
INPV under two markup scenarios: the Conversion Cost Recovery scenario, which is the manufacturer
markup scenario where manufacturers increase their markups in response to changes in energy
conservation standards, and the Preservation of Operating Profit scenario, where DOE assumed
manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated INPV in the above table, drawing on
the MIA explained further in section IV.J of this document, to provide additional context for assessing the
estimated impacts of this rule to society, including potential changes in production and consumption, which
is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include the INPV into the net
benefit calculation for this proposed rule, the net benefits would range from $96.9 billion to $97.4 billion at
3-percent discount rate and would range from $46.1 billion to $46.6 billion at 7-percent discount rate.
Parentheses indicate negative values.
3722
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table I-7 Annualized Monetized Benefits and Costs of Proposed Energy
Conservation Standards for GFBs and ACFs (TSL 4)
Million 2022$/year
Low-NetBenefits
Estimate
High-NetBenefits
Estimate
3,302
3,074
3,521
Climate Benefits*
963
926
1,002
Health Benefits**
1,869
1,796
1,945
Total Benefitst
6,134
5,796
6,469
374
478
276
5,760
5,317
6,192
(62)- 0
(62) - 0
(62) - 0
2,506
2,346
2,658
963
926
1,002
Health Benefits**
1,285
1,240
1,330
Total Benefitst
4,754
4,513
4,991
360
441
280
4,394
4,072
4,710
(62)- 0
(62) - 0
(62) - 0
Primary
Estimate
3% discount rate
Consumer Operating Cost Savings
Consumer Incremental Equipment
Costs!
Net Benefits
Change in Producer Cashflow
(INPV:t:t)
7% discount rate
Consumer Operating Cost Savings
Climate Benefits* (3% discount rate)
Consumer Incremental Equipment
Costs!
Net Benefits
Note: This table presents the costs and benefits associated with GFBs and ACFs shipped in 2030-2059.
These results include consumer, climate, and health benefits that accrue after 2059 from the products
shipped in 2030-2059. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize
projections of energy prices from lheAEO2023 Reference case, Low Economic GrowU1 case, and High
Economic Growth case, respectively. In addition, incremental equipment costs reflect a constant rate in the
Primary Estimate, an increasing rate in the Low Net Benefits Estimate, and a declining rate in the High Net
Benefits Estimate for GFBs, and a low declining rate in the Primary Estimate, an increasing rate in the Low
Net Benefits Estimate, and a high declining rate in the High Net Benefits Estimate for ACFs. The methods
used to derive projected price trends are explained in sections IV.F.1 and IV.H.3 of this document. Note
that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3 percent discount rate are shown, but DOE does not have a single central SC-GHG point
estimate, and it emphasizes the importance and value of considering the benefits calculated using all four
sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the
interim estimates presented in the Technical Support Document: Social Cost of Carbon, }.!ethane, and
Nitrous Oxide Interim Estimates Under Eicecutive Order 13990, published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO 2 . DOE is currently only
monetizing (for SO2 and NOx) PM2.s precursor health benefits and (for NOx) owne precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2.s emissions. See section IV.L of this document for more details.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3723
t Total benefits for both the 3 percent and 7 percent cases are presented using the average SC-GHG with a
3 percent discount rate, but DOE does not have a single central SC-GHG point estimate.
t Costs include incremental equipment costs as well as installation costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.Hof this document. DOE's NIA includes all
impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
manufacturer to manufacture the equipment and ending with the increase in price experienced by the
consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA).
See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions
based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces
a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present
value of all changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. The annualized change in INPV is calculated using the industry weighted
average cost of capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD
for a complete description of the industry weighted average cost of capital). For GFB & ACF, those values
are -$62 million and less than $0 .1 million. DOE accounts for that range of likely impacts in analyzing
whether a TSL is economically justified. See section V.C of this document. DOE is presenting the range of
impacts to the INPV under two markup scenarios: the Conversion Cost Recovery scenario, which is the
manufacturer marlmp scenario where manufacturers increase their markups in response to changes in
energy conservation standards, and the Preservation of Operating Profit Markup scenario, where DOE
assumed manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the
above table, drawing on the MIA explained further in section IV.J of this document, to provide additional
context for assessing the estimated impacts of this rule to society, including potential changes in production
and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include
the INPV into the annualized net benefit calculation for this proposed rule, the annualized net benefits
would range from $5,698 million to $5,760 million at 3-percent discount rate and would range from $4,332
million to $4,394 million at 7-percent discount rate. Parentheses indicate negative values.
12 The quantity refers to full-fuel-cycle (‘‘FFC’’)
energy savings. FFC energy savings includes the
energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas,
petroleum fuels), and, thus, presents a more
complete picture of the impacts of energy efficiency
standards. For more information on the FFC metric,
see section IV.G.1 of this document.
13 DOE calculated emissions reductions relative
to the no-new-standards case, which reflects key
assumptions in AEO 2023. AEO2023 represents
current Federal and State legislation and final
implementation of regulations as of the time of its
preparation. See section IV.J of this document for
further discussion of AEO2023 assumptions that
affect air pollutant emissions.
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Working Group on the Social Cost of
Greenhouse Gases (‘‘IWG’’).14 The
derivation of these values is discussed
in section IV.K of this document. For
presentational purposes, the climate
benefits associated with the average SC–
GHG at a 3 percent discount rate are
estimated to be $11.9 billion. DOE does
not have a single central SC–GHG point
estimate and it emphasizes the
importance and value of considering the
benefits calculated using all four sets of
SC–GHG estimates.
DOE estimated the monetary health
benefits of SO2 and NOX emissions
reductions using benefit per ton
estimates from the scientific literature,
as discussed in section IV.L of this
document. DOE did not monetize the
reduction in mercury emissions because
the quantity is very small. DOE
estimated the present value of the health
benefits would be $8.2 billion using a 7
percent discount rate, and $23.4 billion
14 To monetize the benefits of reducing GHG
emissions, this analysis uses the interim estimates
presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990,
published in February 2021 by the IWG (‘‘February
2021 SC–GHG TSD’’). www.whitehouse.gov/wpcontent/uploads/2021/02/TechnicalSupport
Document_SocialCostofCarbonMethaneNitrous
Oxide.pdf.
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1. General Fans and Blowers
DOE’s analyses indicate that the
proposed energy conservation standards
for GFBs would save a significant
amount of energy. Relative to the case
without new standards, the lifetime
energy savings for GFBs purchased in
the 30-year period that begins in the
anticipated first full year of compliance
with the new standards (2030–2059)
amount to 13.8 quadrillion British
thermal units (‘‘Btu’’), or quads.12 This
represents a savings of 11.4 percent
relative to the energy use of these
products in the case without standards
(referred to as the ‘‘no-new-standards
case’’).
The cumulative net present value
(‘‘NPV’’) of total consumer benefits of
the proposed standards for GFBs ranges
from $13.7 billion (at a 7 percent
discount rate) to $36.9 billion (at a 3
percent discount rate). This NPV
expresses the estimated total value of
future operating cost savings minus the
estimated increased equipment and
installation costs for GFBs purchased in
2030–2059.
In addition, the proposed standards
for GFBs are projected to yield
significant environmental benefits. DOE
estimates that the proposed standards
would result in cumulative emission
reductions (over the same period as for
energy savings) of 239.4 Mt of CO2, 73.1
thousand tons of SO2, 450.9 thousand
tons of NOX, 2,073.9 thousand tons of
CH4, 2.3 thousand tons of N2O, and 0.5
tons of Hg’’.13
DOE estimates the value of climate
benefits from a reduction in greenhouse
gases (‘‘GHG’’) using four different
estimates of the social cost of CO2 (‘‘SC–
CO2’’), the social cost of methane (‘‘SC–
CH4’’), and the social cost of nitrous
oxide (‘‘SC–N2O’’). Together these
represent the social cost of GHG (‘‘SC–
GHG’’). DOE used interim SC–GHG
values developed by an Interagency
DOE’s analysis of the national impacts
of the proposed standards is described
in sections IV.H, IV.K and IV.L of this
document.
3724
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
using a 3 percent discount rate.15 DOE
is currently only monetizing (for SO2
and NOX) PM2.5 precursor health
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15 DOE estimates the economic value of these
emissions reductions resulting from the considered
trial standards levels (‘‘TSLs’’) for the purpose of
complying with the requirements of Executive
Order 12866.
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benefits and (for NOX) ozone precursor
health benefits, but will continue to
assess the ability to monetize other
effects such as health benefits from
reductions in direct PM2.5 emissions.
Table I–8 summarizes the monetized
benefits and costs expected to result
from the proposed standards for GFBs.
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There are other important unquantified
effects, including certain unquantified
climate benefits, unquantified public
health benefits from the reduction of
toxic air pollutants and other emissions,
unquantified energy security benefits,
and distributional effects, among others.
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3725
Table 1-8 Present Value of Monetized Benefits and Costs of Proposed Energy
Conservation Standards for GFBs (TSL 4)
Billion $2022
3% discount rate
Consumer Operating Cost Savings
42.7
Climate Benefits*
11.9
Health Benefits**
23.4
Total Monetized Benefitst
78.0
Consumer Incremental Equipment Costsl
5.1
Net Monetized Benefits
72.2
(0.5)- 0.0
Change in Producer Cashflow (INPVU)
7% discount rate
Consumer Operating Cost Savings
16.6
Climate Benefits* (3% discount rate)
11.9
Health Benefits**
8.2
Total Monetized Benefitst
36.8
Consumer Incremental Equipment Costs;
2.9
Net Monetized Benefits
33.8
(0.5)- 0.0
Note: This table presents U1e costs and benefits associated wiU1 GFBs shipped in 2030-2059. These results
include consumer, climate, and health benefits that accrue after 2059 from the products shipped in
2030-2059.
* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO2),
methane (SC-CH4), and nitrous oxide (SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent
discount rates; 95th percentile at 3 percent discount rate) (see section IV.L of this document). Together
these represent the global SC-GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3-percent discount rate are shown, but DOE does not have a
single central SC-GHG point estimate. To monetize the benefits of reducing GHG emissions, this analysis
uses the interim estimates presented in the Technical Support Document: Social Cost ofCarbon, 11.1ethane,
and Nitrous Oxide Interim Estimates Under Executive Order 13990, published in February 2021 by the
IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2.s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2s emissions. See section IV.L_ofthis document for more details.
t Total and net benefits include those consumer, climate, and health benefits that can be quantified and
monetized. For presentation purposes. total and net benefits for both the 3 percent and 7 percent cases are
presented using the average SC-GHG with a 3 percent discount rate, but DOE does not have a single
central SC-GHG point estimate. DOE emphasizes the importance and value of considering the benefits
calculated using all four sets of SC-GHG estimates.
l Costs include incremental equipment costs as well as installation costs.
tt Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. Sec sections IV.F and IV.H oftlris document. DOE's NIA includes all
impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
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Change in Producer Cashflow (INPVU)
3726
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
The benefits and costs of the proposed
standards can also be expressed in terms
of annualized values. The monetary
values for the total annualized net
benefits are (1) the reduced consumer
operating costs, minus (2) the increase
in product purchase prices and
installation costs, plus (3) the monetized
value of climate and health benefits of
emission reductions, all annualized.16
The national operating cost savings
are domestic private U.S. consumer
monetary savings that occur as a result
of purchasing the covered products and
are measured for the lifetime of GFBs
shipped in 2030–2059. The benefits
associated with reduced emissions
achieved as a result of the proposed
standards are also calculated based on
the lifetime of GFBs shipped in 2030–
2059. Total benefits for both the 3
percent and 7 percent cases are
presented using the average GHG social
costs with a 3-percent discount rate.17
Estimates of total benefits are presented
for all four SC–GHG discount rates in
section V.B.6 of this document.
Table I–9 presents the total estimated
monetized benefits and costs associated
with the proposed standard, expressed
in terms of annualized values. The
results under the primary estimate are
as follows.
Using a 7 percent discount rate for
consumer benefits and costs and health
benefits from reduced NOX and SO2
emissions, and the 3 percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
cost of the standards proposed in this
rule is $329 million per year in
increased equipment costs, while the
estimated annual benefits are $1,880
million in reduced equipment operating
costs, $703 million in monetized
climate benefits, and $932 million in
monetized health benefits. In this case,
the monetized net benefit would
amount to $3,185 million per year.
Using a 3 percent discount rate for all
benefits and costs, the estimated cost of
the proposed standards is $340 million
per year in increased equipment costs,
while the estimated annual benefits are
$2,524 million in reduced operating
costs, $703 million in monetized
climate benefits, and $1,384 million in
monetized health benefits. In this case,
the monetized net benefit would
amount to $4,271 million per year.
16 To convert the time-series of costs and benefits
into annualized values, DOE calculated a present
value in 2024, the year used for discounting the
NPV of total consumer costs and savings. For the
benefits, DOE calculated a present value associated
with each year’s shipments in the year in which the
shipments occur (e.g., 2030), and then discounted
the present value from each year to 2024. Using the
present value, DOE then calculated the fixed annual
payment over a 30-year period, starting in the
compliance year, that yields the same present value.
17 As discussed in section IV.L.1 of this
document, DOE agrees with the IWG that using
consumption-based discount rates e.g., 3 percent) is
appropriate when discounting the value of climate
impacts. Combining climate effects discounted at an
appropriate consumption-based discount rate with
other costs and benefits discounted at a capitalbased rate (i.e., 7 percent) is reasonable because of
the different nature of the types of benefits being
measured.
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manufacturer to manufacture the GFB and ending with the increase in price experienced by the consumer.
DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA). See section
IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions based on
assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces a range
of impacts, which is the rule's expected impact on the INPV. The change in INPVis the present value of all
changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. Change in INPV is calculated using the industry weighted average cost of
capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the final rule TSD for a
complete description of the industry weighted average cost of capital). For GFB, those values are -$455
million and $1 million. DOE accounts for that range of likely impacts in analyzing whether a TSL is
economically justified. See section V. C. DOE is presenting the range of impacts to the INPV under two
markup scenarios: the Conversion Cost Recovery scenario, which is the manufacturer markup scenario
where manufacturers increase their markups in response to changes in energy conservation standards, and
the Preservation of Operating Profit scenario, where DOE assumed manufacturers would not be able to
increase per-unit operating profit in proportion to increases in manufacturer production costs. DOE
includes the range of estimated INPV in the above table, drawing on the MIA explained further in section
IV.J of this document, to provide additional context for assessing the estimated impacts of this rule to
society, including potential changes in production and consumption, which is consistent with OMB's
Circular A-4 and E.O. 12866. If DOE were to include the INPV into the net benefit calculation for this
proposed rule, the net benefits would range from $71.7 billion to $72.2 billion at 3-percent discount rate
and would range from $33.3 billion to $33.8 billion at 7-percent discount rate. Parentheses indicate
negative values.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3727
Table 1-9 Annualized Monetized Benefits and Costs of Proposed Energy
Conservation Standards for GFBs (TSL 4)
Million 2022$/year
Low-NetBenefits
Estimate
High-NetBenefits
Estimate
2,524
2,321
2,724
Climate Benefits*
703
666
742
Health Benefits**
1,384
1,311
1,461
Total Benefitst
4,611
4,297
4,927
340
442
243
4,271
3,855
4,684
(53) - 0
(53) - 0
(53) - 0
1,880
1,739
2,017
Climate Benefits* (3% discount rate)
703
666
742
Health Benefits**
932
888
978
3,515
3,293
3,736
329
409
251
3,185
2,884
3,486
(53) - 0
(53) - 0
(53) - 0
Primary
Estimate
3% discount rate
Consumer Operating Cost Savings
Consumer Incremental Equipment
Costs!
Net Benefits
Change in Producer Cashflow
ONPV:t:t)
7% discount rate
Consumer Operating Cost Savings
Total Benefitst
Consumer Incremental Equipment
Costd
Net Benefits
Note: This table presents Ure costs and benefits associated with GFBs shipped in 2030-2059. These results
include consumer, climate, and health benefits that accrue after 2059 from the products shipped in
2030-2059. The Primacy, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy
prices from the AEO2023 Reference case, Low Economic Growth case, and High Economic Growth case,
respectively. In addition, incremental equipment costs reflect a constant rate in the Primacy Estimate, an
increasing rate in the Low Net Benefits Estimate, and a declining rate in the High Net Benefits Estimate.
The methods used to derive projected price trends are explained in sections IV.F.l and IV.H.3 of this
document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3 percent discount rate arc shown, but DOE docs not have a single central SC-GHG point
estimate, and it emphasizes the importance and value of considering the benefits calculated using all four
sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the
interim estimates presented in the Technical Support Document: Social Cost of Carbon, A1ethane, and
Nitrous Oxide Interim Estimates Under Executive Order 13990, published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2s precursor health benefits and (for NOx) owne precursor health
benefits, but will continue lo assess the ability to monetize 0U1er eITects such as health benefits from
reductions in direct PM2.s emissions. See section IV.L of this document for more details.
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Change in Producer Cashflow
ONPV:t:I:)
3728
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
t Total benefits for both the 3 percent and 7 percent cases are presented using the average SC-GHG with a
3 percent discount rate, but DOE does not have a single central SC-GHG point estimate.
t Costs include incremental equipment costs as well as installation costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.Hof this document. DOE's NIA includes all
impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
manufacturer to manufacture the equipment and ending with the increase in price experienced by the
consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA).
See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions
based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces
a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present
value of all changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. The annualized change in INPV is calculated using the industry weighted
average cost of capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD
for a complete description of the industry weighted average cost of capital). For GFB, those values are $53 million and less than $0.1 million. DOE accounts for that range of likely impacts in analyzing whether
a TSL is economically justified. See section V.C of this document. DOE is presenting the range of impacts
to the INPV under two markup scenarios: the Conversion Cost Recovery scenario, which is the
manufacturer marlmp scenario where manufacturers increase their markups in response to changes in
energy conservation standards, and the Preservation of Operating Profit Markup scenario, where DOE
assumed manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the
above table, drawing on the MIA explained further in section IV.J of this document, to provide additional
context for assessing the estimated impacts of this rule to society, including potential changes in production
and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include
the INPV into the annualized net benefit calculation for this proposed rule, the annualized net benefits
would range from $4,218 million to $4,271 million at 3-percent discount rate and would range from $3,132
million to $3,185 million at 7-percent discount rate. Parentheses indicate negative values.
2. Air Circulating Fans
DOE’s analyses indicate that the
proposed energy conservation standards
for ACFs would save a significant
amount of energy. Relative to the case
without new standards, the lifetime
energy savings for ACFs purchased in
the 30-year period that begins in the
anticipated first full year of compliance
with the new standards (2030–2059)
amount to 4.5 quadrillion British
thermal units (‘‘Btu’’), or quads.18 This
represents a savings of 37.3 percent
relative to the energy use of these
products in the case without standards
(referred to as the ‘‘no-new-standards
case’’).
The cumulative net present value
(‘‘NPV’’) of total consumer benefits of
the proposed standards for ACFs ranges
from $5.3 billion (at a 7 percent
discount rate) to $12.6 billion (at a 3
18 The quantity refers to full-fuel-cycle (‘‘FFC’’)
energy savings. FFC energy savings includes the
energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas,
petroleum fuels), and, thus, presents a more
complete picture of the impacts of energy efficiency
standards. For more information on the FFC metric,
see section IV.H.2 of this document.
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percent discount rate). This NPV
expresses the estimated total value of
future operating-cost savings minus the
estimated increased equipment costs for
ACFs purchased in 2030–2059.
In addition, the proposed standards
for ACFs are projected to yield
significant environmental benefits. DOE
estimates that the proposed standards
would result in cumulative emission
reductions (over the same period as for
energy savings) of 78.5 Mt 19 of CO2,
19.7 thousand tons of SO2, 148.0
thousand tons of NOX, 686.7 thousand
tons of CH4, 0.6 thousand tons of N2O,
and 0.1 tons of mercury Hg.20
DOE estimates the value of climate
benefits from a reduction in greenhouse
gases (GHG) using four different
estimates of the social cost of CO2 (‘‘SC–
CO2’’), the social cost of methane (‘‘SC–
CH4’’), and the social cost of nitrous
oxide (‘‘SC–N2O’’). Together these
represent the social cost of GHG (SC–
19 A metric ton is equivalent to 1.1 short tons.
Results for emissions other than CO2 are presented
in short tons.
20 DOE calculated emissions reductions relative
to the no-new-standards case, which reflects key
assumptions in AEO2023. AEO2023 represents
current Federal and State legislation and final
implementation of regulations as of the time of its
preparation. See section IV.K of this document for
further discussion of AEO2023 assumptions that
affect air pollutant emissions.
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GHG). DOE used interim SC–GHG
values developed by an Interagency
Working Group on the Social Cost of
Greenhouse Gases (IWG).21 The
derivation of these values is discussed
in section IV.L of this document. For
presentational purposes, the climate
benefits associated with the average SC–
GHG at a 3 percent discount rate are
estimated to be $4.4 billion. DOE does
not have a single central SC–GHG point
estimate and it emphasizes the
importance and value of considering the
benefits calculated using all four sets of
SC–GHG estimates.
DOE estimated the monetary health
benefits of SO2 and NOX emissions
reductions using benefit per ton
estimates from the scientific literature,
as discussed in section IV.L of this
document. DOE did not monetize the
reduction in mercury emissions because
the quantity is very small. DOE
estimated the present value of the health
benefits would be $3.1 billion using a 7percent discount rate, and $8.2 billion
using a 3-percent discount rate.22 DOE
21 To monetize the benefits of reducing GHG
emissions, this analysis uses the interim estimates
presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive order 13990,
published in February 2021 by the IWG.
22 DOE estimates the economic value of these
emissions reductions resulting from the considered
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DOE’s analysis of the national impacts
of the proposed standards is described
in sections IV.H, IV.K and IV.L of this
document.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
is currently only monetizing (for SO2
and NOX) PM2.5 precursor health
benefits and (for NOX) ozone precursor
health benefits, but will continue to
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TSLs for the purpose of complying with the
requirements of Executive Order 12866.
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assess the ability to monetize other
effects such as health benefits from
reductions in direct PM2.5 emissions.
Table I–10 summarizes the monetized
benefits and costs expected to result
from the proposed standards for ACFs.
There are other important unquantified
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3729
effects, including certain unquantified
climate benefits, unquantified public
health benefits from the reduction of
toxic air pollutants and other emissions,
unquantified energy security benefits,
and distributional effects, among others.
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3730
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table 1-10 Present Value of Monetized Benefits and Costs of Proposed Energy
Conservation Standards for ACFs (TSL 4)
Billion $2022
3% discount rate
Consumer Operating Cost
Savings
13.2
Climate Benefits*
4.4
Health Benefits**
8.2
Total Monetized Benefitst
25.8
Consumer Incremental
Eauinment Costs:
0.6
Net Monetized Benefits
25.2
Change in Producer
Cashflow (INPVtt)
(0.1) - 0
7% discount rate
Consumer Operating Cost
Savings
Climate Benefits* (3%
discount rate)
5.5
4.4
Health Benefits**
3.1
Total Monetized Benefitst
13.1
Consumer Incremental
Equipment Costs;
0.3
Net Monetized Benefits
12.8
Change in Producer
Cashflow (INPVtt)
(0.1) - 0
Note: This table presents the costs and benefits associated with ACFs shipped in 2030- 2059. These
results include consumer, climate, and health benefits that accrue after 2059 from the products shipped in
2030-2059.
* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO:!),
methane (SC-CH~), and nitrous oxide (SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent
discount rates; 95th percentile at 3 percent discount rate) (see section IV.L of this document). Together
these represent the global SC-GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the
importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To
monetize the benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM25 emissions. See section l V.L of this document for more details.
t Total and net benefits include those consumer, climate, and health benefits that can be quantified and
monetized. For presentation purposes, total and net benefits for both the 3 percent and 7 percent cases are
presented using the average SC-GHG with a 3 percent discount rate.
t Costs include incremental equipment costs.
tt Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.Hof this document. DOE's NIA includes all
impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
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Technical Support Document: Social Cost of Carbon, 11.1ethane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published inFebruazy 2021 by the IWG.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3731
The benefits and costs of the proposed
standards can also be expressed in terms
of annualized values. The monetary
values for the total annualized net
benefits are (1) the reduced consumer
operating costs, minus (2) the increase
in product purchase prices and
installation costs, plus (3) the monetized
value of climate and health benefits of
emission reductions, all annualized.23
The national operating cost savings
are domestic private U.S. consumer
monetary savings that occur as a result
of purchasing the covered products and
are measured for the lifetime of GFBs
shipped in 2030–2059. The benefits
associated with reduced emissions
achieved as a result of the proposed
standards are also calculated based on
the lifetime of GFBs shipped in 2030–
2059. Total benefits for both the 3
percent and 7 percent cases are
presented using the average GHG social
costs with 3 percent discount rate.24
Estimates of total benefits are presented
for all four SC–GHG discount rates in
section V.B.6 of this document.
Table I–11 presents the total
estimated monetized benefits and costs
associated with the proposed standard,
expressed in terms of annualized values.
The results under the primary estimate
are as follows.
Using a 7-percent discount rate for
consumer benefits and costs and health
benefits from reduced NOX and SO2
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
cost of the standards proposed in this
rule is $31 million per year in increased
equipment costs, while the estimated
annual benefits are $626 million in
reduced equipment operating costs,
$261 million in monetized climate
benefits, and $353 million in monetized
health benefits. In this case. The net
monetized benefit would amount to
$1,209 million per year.
Using a 3-percent discount rate for all
benefits and costs, the estimated cost of
the proposed standards is $34 million
per year in increased equipment costs,
while the estimated annual benefits are
$778 million in reduced operating costs,
$261 million in monetized climate
benefits, and $485 million in monetized
health benefits. In this case, the
monetized net benefit would amount to
$1,489 million per year.
23 To convert the time-series of costs and benefits
into annualized values, DOE calculated a present
value in 2022, the year used for discounting the
NPV of total consumer costs and savings. For the
benefits, DOE calculated a present value associated
with each year’s shipments in the year in which the
shipments occur (e.g., 2030), and then discounted
the present value from each year to 2022. Using the
present value, DOE then calculated the fixed annual
payment over a 30-year period, starting in the
compliance year, that yields the same present value.
24 As discussed in section IV.L.1 of this
document, DOE agrees with the IWG that using
consumption-based discount rates e.g., 3 percent) is
appropriate when discounting the value of climate
impacts. Combining climate effects discounted at an
appropriate consumption-based discount rate with
other costs and benefits discounted at a capitalbased rate (i.e., 7 percent) is reasonable because of
the different nature of the types of benefits being
measured.
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manufacturer to manufacture the equipment and ending with the increase in price experienced by the
consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA).
See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions
based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces
a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present
value of all changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. Change in INPV is calculated using the industry weighted average cost of
capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD for a complete
description of the industry weighted average cost of capital). For ACF, those values are -$71 million and
no change in INPV. DOE accounts for that range of likely impacts in analyzing whether a TSL is
economically justified. See section V.C. DOE is presenting the range of impacts to the INPV under two
markup scenarios: the Conversion Cost Recovery scenario, which is the manufacturer markup scenario
where manufacturers increase their markups in response to changes in energy conservation standards, and
the Preservation of Operating Profit scenario, where DOE assumed manufacturers would not be able to
increase per-unit operating profit in proportion to increases in manufacturer production costs. DOE
includes the range of estimated INPV in the above table, drawing on the MIA explained further in section
IV.J of this document, to provide additional context for assessing the estimated impacts of this rule to
society, including potential changes in production and consumption, which is consistent with 0MB' s
Circular A-4 and E.O. 12866. IfDOE were to include the INPV into the net benefit calculation for this
proposed rule, the net benefits would range from $25.1 billion to $25.2 billion at 3-percent discount rate
and would range from $12.7 billion to $12.8 billion at 7-percent discount rate. Parentheses indicate
negative values.
3732
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table 1-11 Annualized Monetized Benefits and Costs of Proposed Energy
Conservation Standards for ACFs (TSL 4)
Million 2022$/year
Primary
Estimate
Low-NetBenefits
Estimate
High-Net-Benefits
Estimate
3% discount rate
Consumer Operating Cost Savings
778
753
796
Climate Benefits*
261
261
261
Health Benefits**
485
485
485
Total Benefitst
1,523
1,498
1,542
34
36
33
Net Benefits
1,489
1,462
1,509
Change in Producer Cashflow
(INPV:t:t)
(8) - 0
(8) - 0
(8) - 0
Consumer Incremental Equipment
Costs:t
7% discount rate
Consumer Operating Cost Savings
626
607
641
Climate Benefits* (3% discount rate)
261
261
261
Health Benefits**
353
353
353
1,239
1,221
1,254
31
32
30
1,209
1,188
1,225
(8) - 0
(8) - 0
(8) - 0
Total Benefitst
Consumer Incremental Equipment
Costst
Net Benefits
Change in Producer Cashflow
(INPV:t:t)
Note: This table presents the costs and benefits associated with ACFs shipped in 2030-2059. These results
include consumer, climate, and health benefits that accrue after 2059 from the products shipped in
2030-2059. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy
prices from the AEO2023 Reference case, Low Economic Growth case, and High Economic Growth case,
respectively. In addition, incremental equipment costs reflect a low declining rate in the Primary Estimate,
an increasing rate in the Low Net Benefits Estimate, and a high declining rate in the High Net Benefits
Estimate. The methods used to derive projected price trends are explained in sections IV.F.1 and IV.HJ of
this document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3 percent discount rate are shown: however, DOE emphasizes the importance and value of
considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of
reducing GHG emissions, this analysis uses the interim estimates presented in the Technical Support
13990 published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO 2. DOE is currently only
monetizing (for SO 2 and NOx) PM25 precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2.5 emissions. See section IV.L of this document for more details.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3733
BILLING CODE 6450–01–C
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DOE’s analysis of the national impacts
of the proposed standards is described
in sections IV.H, IV.K and IV.L of this
document.
D. Conclusion
DOE has tentatively concluded that
the proposed standards represent the
maximum improvement in energy
efficiency that is technologically
feasible and economically justified, and
would result in the significant
conservation of energy. Specifically,
with regards to technological feasibility
products achieving these standard levels
are already commercially available for
all equipment classes covered by this
proposal. As for economic justification,
DOE’s analysis shows that the benefits
of the proposed standard exceed, to a
great extent, the burdens of the
proposed standards.
Using a 7-percent discount rate for
consumer benefits and costs and NOX
and SO2 reduction benefits, and a 3percent discount rate case for GHG
social costs, the estimated cost of the
proposed standards for GFBs is $329
million per year in increased GFB costs,
while the estimated annual benefits are
$1,880 million in reduced GFB
operating costs, $703 million in
monetized climate benefits and $932
million in monetized health benefits.
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The net monetized benefit amounts to
$3,185 million per year. DOE notes that
the net benefits are substantial even in
the absence of the climate benefits,25
and DOE would adopt the same
standards in the absence of such
benefits.
Using a 7-percent discount rate for
consumer benefits and costs and NOX
and SO2 reduction benefits, and a 3percent discount rate case for GHG
social costs, the estimated cost of the
proposed standards for ACFs is $31
million per year in increased ACF costs,
while the estimated annual benefits are
$626 million in reduced ACF operating
costs, $261 million in monetized
climate benefits and $353 million in
monetized health benefits. The net
monetized benefit amounts to $1,209
million per year.
The significance of energy savings
offered by a new or amended energy
conservation standard cannot be
determined without knowledge of the
specific circumstances surrounding a
given rulemaking.26 For example, some
covered products and equipment have
25 The information on climate benefits is provided
in compliance with Executive Order 12866.
26 Procedures, Interpretations, and Policies for
Consideration in New or Revised Energy
Conservation Standards and Test Procedures for
Consumer Products and Commercial/Industrial
Equipment, 86 FR 70892, 70901 (Dec. 13, 2021).
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substantial energy consumption occur
during periods of peak energy demand.
The impacts of these products on the
energy infrastructure can be more
pronounced than products with
relatively constant demand.
Accordingly, DOE evaluates the
significance of energy savings on a caseby-case basis.
As previously mentioned, the
proposed standards are projected to
result in estimated national energy
savings of 13.8 quad FFC for GFBs and
4.5 quads FFC for ACFs, the equivalent
of the primary annual energy use of 148
and 48 million homes, respectively. In
addition, they are projected to reduce
CO2 emissions by 239.4 Mt and 78.5 Mt,
for GFBs and ACFs, respectively. Based
on these findings, DOE has initially
determined the energy savings from the
proposed standard levels are
‘‘significant’’ within the meaning of 42
U.S.C. 6295(o)(3)(B). A more detailed
discussion of the basis for these
tentative conclusions is contained in the
remainder of this document and the
NOPR TSD.
DOE also considered more-stringent
energy efficiency levels as potential
standards, and is still considering them
in this rulemaking. However, DOE has
tentatively concluded that the potential
burdens of the more stringent energy
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t Total benefits for both the 3 percent and 7 percent cases are presented using the average SC-GHG with a
3 percent discount rate.
l Costs include incremental equipment costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.H document. DOE's NIA includes all impacts (both
costs and benefits) along the distribution chain beginning with the increased costs to the manufacturer to
manufacture the equipment and ending with the increase in price experienced by the consumer. DOE also
separately conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J of this
document. In the detailed MIA, DOE models manufacturers' pricing decisions based on assumptions
regarding investments, conversion costs, cashflow, and margins. The MIA produces a range of impacts,
which is the rule's expected impact on the INPV. The change in INPV is the present value of all changes in
industry cash flow, including changes in production costs, capital expenditures, and manufacturer profit
margins. The annualized change in INPV is calculated using the industry weighted average cost of capital
value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD for a complete
description of the industry weighted average cost of capital). For ACF, those values are -$8 million and no
annualized change in INPV. DOE accounts for that range of likely impacts in analyzing whether a TSL is
economically justified. See section V. C of this document. DOE is presenting the range of impacts to the
INPV under two markup scenarios: the Conversion Cost Recovery scenario, which is the manufacturer
markup scenario where manufacturers increase their markups in response to changes in energy
conservation standards, and the Preservation of Operating Profit Markup scenario, where DOE assumed
manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the
above table, drawing on the MIA explained further in section IV.J of this document, to provide additional
context for assessing the estimated impacts of this rule to society, including potential changes in production
and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include
the INPV into the annualized net benefit calculation for this proposed rule, the annualized net benefits
would range from $1,481 million to $1,489 million at 3-percent discount rate and would range from $1,201
million to $1,209 million at 7-percent discount rate. Parentheses indicate negative values.
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efficiency levels would outweigh the
projected benefits.
Based on consideration of the public
comments DOE receives in response to
this document and related information
collected and analyzed during the
course of this rulemaking effort, DOE
may adopt energy efficiency levels
presented in this document that are
either higher or lower than the proposed
standards, or some combination of
level(s) that incorporate the proposed
standards in part.
II. Introduction
The following section briefly
discusses the statutory authority
underlying this proposed rule, as well
as some of the relevant historical
background related to the establishment
of standards for fans and blowers.
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A. Authority
EPCA authorizes DOE to regulate the
energy efficiency of a number of
consumer products and certain
industrial equipment. Title III, Part C 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’’).27 EPCA also provides that
‘‘covered equipment’’ includes any
other type of industrial equipment for
which the Secretary of Energy (‘‘the
Secretary’’) determines inclusion is
necessary to carry out the purpose of
Part A–1. (42 U.S.C. 6311(1)(L); 42
U.S.C. 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, the subjects
of this document. (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
27 ‘‘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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or commercial use; 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 concluding that the
inclusion of fans and blowers as covered
equipment was necessary to carry out
the purpose of Part A–1 and classifying
fans and blowers as covered equipment.
86 FR 46579, 46588.
The energy conservation program
under EPCA consists essentially of four
parts: (1) testing, (2) labeling, (3) the
establishment of Federal 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) There
are currently no Federal energy
conservation standards for fans and
blowers. However, as noted in the
Existing Efficiency Standards subsection
of section IV.C.1.b of this document, the
California Energy Commission (‘‘CEC’’)
has finalized a rulemaking that requires
manufacturers to report fan operating
boundaries that result in operation at a
FEI of greater than or equal to 1.00 for
all fans within the scope of that
rulemaking.28 The scope of the CEC
rulemaking includes some, but not all,
GFBs that are considered in the scope of
this energy conservation rulemaking.
The CEC rulemaking goes into effect on
November 1, 2023. However, if the
Federal standards in this NOPR are
finalized and made effective, they will
supersede the CEC standard
requirements. The CEC standards with
respect to fans and blowers covered by
a standard set in a final rule would be
superseded once the Federal standard
takes effect, meaning on the compliance
date applicable to GFBs, which is
expected to be 5 years after the
28 California Energy Commission. Commercial
and Industrial Fans and Blowers. Docket No. 22–
AAER–01. Available at efiling.energy.ca.gov/Lists/
DocketLog.aspx?docketnumber=22-AAER-01.
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publication of any final rule. 42 U.S.C.
6316(a)(10).
Furthermore, EPCA prescribes that all
representations of energy efficiency and
energy use, including those made on
marketing materials and product labels,
for certain equipment, including fans
and blowers, must be made in
accordance with an amended test
procedure, beginning 180 days after
publication of the final rule in the
Federal Register. (42 U.S.C. 6314(d)(1))
DOE notes that Federal test procedures
generally supersede any State regulation
insofar as such State regulation provides
for the disclosure of information with
respect to any measure of energy
consumption or water use of any
covered product (42 U.S.C 6297(a)(1))
The Federal test procedure for fans and
blowers was published on May 1, 2023,
and all representations of energy
efficiency and energy use, including
those made on marketing materials and
product labels, must be made in
accordance with this test procedure
beginning October 30, 2023. 88 FR
27312. Therefore, DOE notes that any
disclosure of information regarding any
measure of energy consumption for fans
required by the CEC must be tested in
accordance with the Federal test
procedure beginning October 30, 2023.
DOE may, however, grant waivers of
Federal preemption for particular State
laws or regulations, in accordance with
the procedures and other provisions set
forth under EPCA. (See 42 U.S.C.
6316(a) (applying the preemption
waiver provisions of 42 U.S.C. 6297).)
Subject to certain criteria and
conditions, DOE is required to develop
test procedures to measure the energy
efficiency, energy use, or estimated
annual operating cost of each covered
equipment. (42 U.S.C. 6295(o)(3)(A) and
42 U.S.C. 6295I) Manufacturers of
covered equipment must use the Federal
test procedures as the basis for: (1)
certifying to DOE that their equipment
complies with the applicable energy
conservation standards adopted
pursuant to EPCA (42 U.S.C. 6316(a); 42
U.S.C. 6295(s)), and (2) making
representations about the efficiency of
that equipment (42 U.S.C. 6314(d)).
Similarly, DOE must use these test
procedures to determine whether the
equipment complies with relevant
standards promulgated under EPCA. (42
U.S.C. 6316(a); 42 U.S.C. 6295(s)) The
DOE test procedures for fans and
blowers appear at title 10 of the Code of
Federal Regulations (‘‘CFR’’) part 431,
subpart J, appendices A and B.
DOE must follow specific statutory
criteria for prescribing new or amended
standards for covered equipment,
including fans and blowers. Any new or
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amended standard for covered
equipment must be designed to achieve
the maximum improvement in energy
efficiency that the Secretary of Energy
determines is technologically feasible
and economically justified. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(A) and 42
U.S.C. 6295(o)(3)(B)) Furthermore, DOE
may not adopt any standard that would
not result in the significant conservation
of energy. (42 U.S.C. 6316(a); (42 U.S.C.
6295(o)(3))
Moreover, DOE may not prescribe a
standard: (1) for certain equipment,
including fans and blowers, if no test
procedure has been established for the
equipment, or (2) if DOE determines by
rule that the standard is not
technologically feasible or economically
justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(3)(A)–(B)) In deciding whether a
proposed standard is economically
justified, DOE must determine whether
the benefits of the standard exceed its
burdens. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)) DOE must make this
determination after receiving comments
on the proposed standard, and by
considering, to the greatest extent
practicable, the following seven
statutory factors:
(1) The economic impact of the
standard on manufacturers and
consumers of the equipment subject to
the standard;
(2) The savings in operating costs
throughout the estimated average life of
the covered equipment in the type (or
class) compared to any increase in the
price, initial charges, or maintenance
expenses for the covered equipment that
are likely to result from the standard;
(3) The total projected amount of
energy (or, as applicable, water) savings
likely to result directly from the
standard;
(4) Any lessening of the utility or the
performance of the covered equipment
likely to result from the standard;
(5) The impact of any lessening of
competition, as determined in writing
by the Attorney General, that is likely to
result from the standard;
(6) The need for national energy and
water conservation; and
(7) Other factors the Secretary of
Energy (‘‘Secretary’’) considers relevant.
(42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(I)–(VII))
Further, EPCA establishes a rebuttable
presumption that a standard is
economically justified if the Secretary
finds that the additional cost to the
consumer of purchasing equipment
complying with an energy conservation
standard level will be less than three
times the value of the energy savings
during the first year that the consumer
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will receive as a result of the standard,
as calculated under the applicable test
procedure. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(iii))
EPCA also contains what is known as
an ‘‘anti-backsliding’’ provision, which
prevents the Secretary from prescribing
any amended standard that either
increases the maximum allowable
energy use or decreases the minimum
required energy efficiency of covered
equipment. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(1)) Also, the Secretary may not
prescribe an amended or new standard
if interested persons have established by
a preponderance of the evidence that
the standard is likely to result in the
unavailability in the United States in
any covered equipment type (or class) of
performance characteristics (including
reliability), features, sizes, capacities,
and volumes that are substantially the
same as those generally available in the
United States. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(4))
Additionally, EPCA specifies
requirements when promulgating an
energy conservation standard for
covered equipment that has two or more
subcategories. DOE must specify a
different standard level for a type or
class of equipment that has the same
function or intended use, if DOE
determines that equipment within such
group: (A) consume a different kind of
energy from that consumed by other
covered equipment within such type (or
class); or (B) have a capacity or other
performance-related feature which other
equipment within such type (or class)
do not have and such feature justifies a
higher or lower standard. (42 U.S.C.
6316(a); 42 U.S.C. 6295(q)(1)) In
determining whether a performancerelated feature justifies a different
standard for a group of equipment, DOE
must consider such factors as the utility
to the consumer of the feature and other
factors DOE deems appropriate. Id. Any
rule prescribing such a standard must
include an explanation of the basis on
which such higher or lower level was
established. (42 U.S.C. 6316(a); 42
U.S.C. 6295(q)(2))
B. Background
1. Current Standards
DOE does not currently have energy
conservation standards for fans and
blowers. The following section
summarizes relevant background
information regarding DOE’s
consideration of energy conservation
standards for fans and blowers.
On May 10, 2021, DOE published a
request for information requesting
comments on a potential fan or blower
definition. 86 FR 24752. DOE followed
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3735
this with a publication of a final
determination on August 19, 2021,
classifying fans and blowers as covered
equipment (‘‘August 2021 Final
Coverage Determination’’). 86 FR 46579.
At this time, DOE determined that the
term ‘‘blower’’ is used interchangeably
in the U.S. market with the term ‘‘fan.’’
86 FR 46579, 46583. DOE defines a fan
(or blower) as a rotary bladed machine
used to convert electrical or mechanical
power to air power, with an energy
output limited to 25 kilojoule (‘‘kJ’’) per
kilogram (‘‘kg’’) of air. It consists of an
impeller, a shaft and bearings and/or
driver to support the impeller, as well
as a structure or housing. A fan (or
blower) may include a transmission,
driver, and/or motor controller. 10 CFR
431.172.
2. History of Standards Rulemaking for
Fans and Blowers
In considering whether to establish
standards, on June 28, 2011 DOE
published a notice of proposed
determination of coverage to initiate an
energy conservation standards
rulemaking for fans, blowers, and fume
hoods. 76 FR 37678. Subsequently, DOE
published a notice of public meeting
and availability of the Framework
document for GFBs in the Federal
Register. 78 FR 7306 (February 1, 2013).
In the Framework document (‘‘2013
Framework Document’’), DOE requested
feedback from interested parties on
many issues, including the engineering
analysis, the MIA, the LCC and PBP
analyses, and the national impact
analysis (‘‘NIA’’).
On December 10, 2014, DOE
published a notice of data availability
(‘‘December 2014 NODA’’) that
estimated the potential economic
impacts and energy savings that could
result from promulgating energy
conservation standards for fans. 79 FR
73246. The December 2014 NODA
analysis used FEI, a ‘‘wire-to-air’’ fan
electrical input power metric, to
characterize fan performance.
In October 2014, several
representatives of fan manufacturers
and energy efficiency advocates 29
(‘‘Joint Stakeholders’’) presented DOE
with an alternative metric approach, the
‘‘Fan Efficiency Ratio,’’ which included
a fan efficiency-only metric approach
(‘‘FERH’’) and a wire-to-air metric
approach (‘‘FERW’’).30 On May 1, 2015,
29 The Air Movement and Control Association
(AMCA), New York Blower Company, Natural
Resources Defense Council (NRDC), the Appliance
Standards Awareness Project (ASAP), and the
Northwest Energy Efficiency Alliance (NEEA).
30 Supporting documents from this meeting,
including presentation slides are available at
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based on the additional information
received and comments to the December
2014 NODA, DOE published a second
NODA (‘‘May 2015 NODA’’) that
announced data availability from DOE
analyses conducted using a modified
FEI metric, similar to the FERW metric
presented by the Joint Stakeholders. 80
FR 24841, 24843.
Concurrent with these efforts, DOE
established an Appliance Standards
Rulemaking Federal Advisory
Committee (‘‘ASRAC’’) Working Group
(‘‘Working Group’’) to discuss
negotiated energy conservation
standards and test procedures for fans.31
The Working Group concluded its
negotiations on September 3, 2015, and,
by consensus vote,32 approved a term
sheet containing 27 recommendations
related to scope, test procedure, and
energy conservation standards (‘‘term
sheet’’). (See Docket No. EERE–2013–
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www.regulations.gov/document?D=EERE-2013-BTSTD-0006-0029.
31 Information on the ASRAC, the commercial
and industrial fans Working Group, and meeting
dates is available at: energy.gov/eere/buildings/
appliance-standards-and-rulemaking-federaladvisory-committee.
32 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
4 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 the term sheet.
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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)
On November 1, 2016, DOE published
a third notification of data availability
(‘‘November 2016 NODA’’) that
presented a revised analysis for GFBs
consistent with the scope and metric
recommendations in the term sheet. 81
FR 75742, 75743. As recommended by
the working group, the November 2016
NODA used the fan electrical input
power metric (FEP) 33 in conjunction
with FEI to characterize fan
performance. DOE made several
additional updates to the November
2016 NODA to address the term sheet
recommendations developed by the
Working Group as well as stakeholder
feedback submitted via public comment.
Specifically, the analysis presented in
the November 2016 NODA was updated
to include (1) augmentation of the Air
Movement and Control Association
International (‘‘AMCA’’) sales data used
in the May 2015 NODA to better
account for fans made by companies
that incorporate those fans for sale in
their own equipment, (2) augmentation
33 The FEP metric represents the electrical input
power of the fan and includes the performance of
the motor, and any transmission and/or control if
integrated, assembled, or packaged with the fan. In
the November 2016 NODA, DOE developed
standards based on FEI values evaluated relative to
the EL 3 standard FEP.
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of the AMCA sales data to represent
additional sales of forward-curved fans,
and (3) inclusion of original equipment
manufacturer (‘‘OEM’’) conversion
costs. Id. The November 2016 NODA
evaluated only fans with a fan shaft
input power equal to, or greater than, 1
horsepower (‘‘hp’’) and a fan airpower
equal to or less than 150 hp. 81 FR
75742, 75746.
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 definitions and potential
scope for ACFs. 86 FR 54412, 54414–
54415. DOE published a separate
request for information on February 8,
2022 (‘‘February 2022 RFI’’), to seek
input to aid in its development of the
technical and economic analyses
regarding whether standards for ACFs
may be warranted. 87 FR 7048. On
October 13, 2022, DOE published a
notice of data availability (‘‘October
2022 NODA’’) to present its preliminary
engineering analysis for ACFs and to
seek input to support DOE in
completing a notice of proposed
rulemaking analysis for all fans and
blowers. 87 FR 62038.
DOE received comments in response
to the October 2022 NODA from the
interested parties listed in Table II–1.
BILLING CODE 6450–01–P
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3737
Table 11-1 October 2022 NODA Written Comments
Commenter(s)
Association of Home
Appliance
Manufacturers
Air-Conditioning,
Heating, and
Refrigeration
Institute
Air Movement and
Control Association
International
Appliance Standards
Awareness Project,
American Council for
an Energy-Efficient
Economy, Consumer
Federation of
America, National
Consumer Law
Center, Natural
Resources Defense
Council
Ava Rohleder*
Brandon Damas, P.E.
and Jeff Boldt, P.E.
California InvestorOwned Utilities:
Pacific Gas and
Electric Company,
San Diego Gas and
Electric, and
Southern California
Edison
Ethan Dwver*
Abbreviation
Comment No. in the
Docket
AHAM
123
Trade Association
AHRI
130
Trade Association
AMCA
132
Trade Association
Efficiency Advocates
126
Efficiency
Organizations
Rohleder
13
Individual
Damas and Boldt
131
Individuals
CAIOUs
127
Utilities
Dwver
119
122
Individual
MIAQ
124
Manufacturer
Morrison
128
Manufacturer
NEMA
125
Trade Association
NEEA
129
Efficiency
Organization
Greenheck Group
Greenheck
Manufacturer
* DOE reviewed the comments from Rohleder, who supports adoptmg energy conservation standards for ACFs.
However, Rohleder's comments otherwise do not provide information or feedback that could be used for this NOPR
analysis and instead encouraged DOE to conduct ASRAC negotiations. Sinrilarly, DOE reviewed the comments from
Dwyer and detennined that Dwyer's comments summarize the October 2022 NODA and otherwise generally note their
support of DOE regulating fans and blowers, are out of scope of this rulemaking, or do not provide concrete
recommendations that DOE could use in the development of this NOPR analysis. Therefore, comments from these
stakeholders are not summarized in the document.
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Madison Indoor Air
Quality
Morrison Products
Inc.
National Electrical
Manufacturers
Association
Northwest Energy
Efficiency Alliance
Commenter Type
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BILLING CODE 6450–01–C
DOE also acknowledges that it
received numerous identical comments
via a mass email campaign stating that
standards for fans and blowers is an
important issue and requesting that DOE
pursue an approach that is fair and
equitable to both businesses and
consumers. 34
A parenthetical reference at the end of
a comment quotation or paraphrase
provides the location of the item in the
public record.35
C. Deviation From Process Rule
In accordance with section 3(a) of 10
CFR part 430, subpart C, appendix A
(‘‘Process Rule’’), DOE notes that it is
deviating from the provision in the
Process Rule regarding the pre-NOPR
and NOPR stages for an energy
conservation standards rulemaking.
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1. Framework Document
Section 6(a)(2) of the Process Rule
states that if DOE determines it is
appropriate to proceed with a
rulemaking, the preliminary stages of a
rulemaking to issue or amend an energy
conservation standard that DOE will
undertake will be a framework
document and preliminary analysis, or
an advance notice of proposed
rulemaking.
As described in section II.B.2 of this
document, DOE published the 2013
Framework Document, the December
2014 NODA, the May 2015 NODA, and
the November 2016 NODA for GFBs. 78
FR 7306; 79 FR 73246; 80 FR 24841; 81
FR 75742. The three NODAs presented
DOE’s analysis at various points,
provided stakeholders opportunity to
review and provide comment.
Furthermore, while DOE published the
February 2022 RFI and October 2022
NODA for ACFs, DOE did not publish
a framework document in conjunction
with the NODA for ACFs. 87 FR 62038.
DOE notes that ACFs and GFBs are
analyzed separately, however, the
general analytical framework that DOE
uses in evaluating and developing
potential new energy conservation
standards for both GFBs and ACFs is
similar. As such, publication of a
separate framework document for ACFs
would be largely redundant of
previously published documents.
34 Comment numbers 14–118 in the docket
(Docket No. EERE–2022–BT–STD–0002, maintained
at www.regulations.gov).
35 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, maintained at
www.regulations.gov). The references are arranged
as follows: (commenter name, comment docket ID
number, page of that document).
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2. Public Comment Period
Section 6(f)(2) of the Process Rule
specifies that the length of the public
comment period for a NOPR will be not
less than 75 calendar days. For this
NOPR, DOE is instead providing a 60day comment period, consistent with
EPCA requirements. 42 U.S.C. 6316(a);
42 U.S.C. 6295(p). DOE is opting to
deviate from the 75-day comment
period because of the robust
opportunities already afforded to
stakeholders to provide comments on
this proposed rulemaking.
DOE is providing a 60-day comment
period, which DOE believes is
appropriate given the substantial
stakeholder engagement for general fans
and blowers to date, as discussed in
section II.B.2 of this document.
Furthermore, the request for information
on air circulating fans that was
published on February 8, 2022,
provided early notice to interested
parties that DOE was interested in
evaluating potential energy conservation
standards for air circulating fans. DOE
also provided a 45-day comment period
for the notice of data availability that
was published on October 13, 2022.
Therefore, DOE believes a 60-day
comment period is appropriate and will
provide interested parties with a
meaningful opportunity to comment on
the proposed rule.
III. General Discussion
DOE developed this proposal after
considering oral and written comments,
data, and information from interested
parties that represent a variety of
interests. The following discussion
addresses issues raised by these
commenters.
A. General Comments
This section summarizes general
comments received from interested
parties in response to the October 2022
NODA regarding rulemaking timing,
process, and impact.
In response to many of DOE’s requests
for comment, AMCA recommended that
DOE obtain the requested information
through confidential interviews with fan
manufacturers. (AMCA, No. 132 at pp.
6–14) DOE notes that it used
information collected during
manufacturer interviews to inform its
engineering, market, and manufacturer
analyses.
NEMA commented that its
interpretation of DOE’s analysis in the
October 2022 NODA was that DOE was
proposing energy efficiency
requirements for motors that are used in
ACFs, which would be confusing and
problematic for the motor industry,
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since there is a separate rulemaking for
motors. (NEMA, No. 125 at pp. 2, 4).
Additionally, NEMA stated that DOE’s
inclusion of higher efficiency small,
non-‘‘small electric motor’’ electric
motors (‘‘SNEMs’’) as a technology
option for increasing the efficiency of
ACFs could be an issue because of an
ongoing rulemaking for SNEMs. (NEMA,
No. 125 at p. 2) DOE notes that in a
NOPR for expanded scope electric
motors (‘‘ESEMs’’) published on
December 15, 2023 (‘‘December 2023
ESEM NOPR’’), motors that were
previously referred to as SNEMs were
redefined to be ESEMs. 88 FR 87062
DOE will use the term ‘‘ESEM’’
throughout the remainder of this
document to refer to these motors.
Morrison commented that it is
concerned about the small motors
rulemaking being in progress at the
same time as this fans and blowers
rulemaking. (Morrison, No. 128 at p. 1)
DOE notes that it is proposing energy
conservation standards for fans and
blowers, including ACFs and GFBs, and
that it is not proposing energy
conservation standards for motors in
this rulemaking. DOE typically defines
a likely design path to structure its
engineering analysis; however, DOE
notes that this design path is not
prescriptive. DOE heard from ACF
manufacturers that replacing a less
efficient motor with a more efficient
motor would be one of the first options
they would evaluate. Therefore, DOE
considered more efficient motors as an
option that a manufacturer might apply
to reach a given ACF efficiency level.
DOE acknowledges that the electric
motors rulemaking involving ESEMs is
ongoing (see EERE–2020–BT–STD–
0007) and that stakeholders made a joint
recommendation for the efficiencies at
which they believe the standards for
ESEMs should be set. (Docket No.
EERE–2020–BT–STD–0007, Joint
Stakeholders, No. 38 at p. 6, Table 2) As
discussed in section IV.C.2.c, DOE
defined an efficiency level (EL 2) in its
ACF engineering analysis based on the
efficiencies recommended for ESEMs by
the Joint Stakeholders. DOE may
consider adjusting the baseline
efficiency level for ACFs if it sets a
standard in the ESEM rulemaking at the
recommended ESEM levels.
AMCA commented that it generally
supports NEMA’s comments. (AMCA,
No. 132 at pp. 2, 21) DOE therefore
notes that throughout this document,
reference to comments made by NEMA
are understood to be representative of
the viewpoints of AMCA as well.
Greenheck stated that it would be
beneficial for the ACF rulemaking to be
delayed until after AMCA 230–2023 is
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published. (Greenheck, No. 122 at p. 1)
AMCA commented that DOE should
finalize a test procedure before
proceeding with its fans and blowers
energy conservation standards
rulemaking so that stakeholders can
make informed comments on the energy
conservation standards rulemaking.
(AMCA, No. 132 at p. 10) DOE notes
that ACMA 230–23 was published on
February 10, 2023, and that DOE has
since published its test procedure final
rule for fans and blowers, on May 1,
2023. 88 FR 27312.
MIAQ commented that it disagrees
with DOE’s decision to provide a 45-day
comment period instead of the usual 75day comment period for the October
2022 NODA. (MIAQ, No. 124 at p. 2) In
the October 2022 NODA, DOE discussed
its decision to deviate from section 3(a)
of appendix A to subpart C of 10 CFR
part 430 and reduce the comment
period. 87 FR 62038, 62039. DOE
provided a 45-day comment period
given the substantial stakeholder
engagement prior to the publication of
the NODA and to provide DOE with
ample time to review comments to
inform this NOPR analysis. Id.
The CA IOUs commented that they
are concerned that the energy
conservation standards may supersede
the fan input power limits currently in
place for building codes, such as the
California Building Energy Code (Title
24), American Society of Heating,
Refrigerating, and Air-Conditioning
Engineers (‘‘ASHRAE’’) Standard 90.1,
‘‘Energy Standard for Buildings Except
Low-Rise Residential Buildings,’’ and
the International Energy Conservation
Code (‘‘IECC’’) 2021, which would
reduce the influence of these building
codes and ultimately result in an
increase in the energy consumption of
the equipment in which fans are
embedded because the fan power limits
in those codes are significantly more
stringent than the FEI requirements and
ensure the overall fan system in a
building is designed efficiently. (CA
IOUs, No. 127 at p. 6) Damas and Boldt
also expressed their concern that energy
conservation standards may preempt the
limits on fan system power in building
energy codes such as ASHRAE 90.1 and
therefore could potentially increase
energy use in new construction. (Damas
and Boldt, No. 131 at p. 5) AHRI
commented that an energy conservation
standard is not needed for fans because
all States are obligated to comply with
ASHRAE 90.1. (AHRI, No. 130 at pp.
16–17)
DOE notes that neither ASHRAE 90.1
nor IECC 2021 are federally mandated
standards. Although ASHRAE 90.1 and
IECC 2021 may be incorporated into
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municipal and/or building codes, this is
not required and is performed on a State
and local level. Furthermore, their
incorporation does not always mandate
standard efficiency requirements. DOE
also acknowledges that as stated in
section II.A, 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)
Therefore, if energy conservation
standards for fans and blowers were to
be adopted, they would supersede State
laws and regulations for the efficiency
of individual fans and blowers at the
product or equipment level. DOE
considered the fan efficiency
requirements in ASHRAE 90.1 and IECC
2021 in its analysis, as discussed in
section IV.C.1.b of this document. With
regard to CA IOUs concern that DOE’s
regulation would supersede current
regulations for fan input power limits,
DOE notes that the standards proposed
in this NOPR apply only to individual
fans, whether embedded or standalone,
that are within the proposed scope of
this rulemaking. DOE is not proposing
minimum input power requirements for
fan systems that may be incorporated
into buildings. Therefore, although the
individual fans used in fan systems
would be required to comply with
DOE’s minimum FEI requirements if the
fan is within the proposed scope of this
rulemaking, DOE’s proposed regulations
would not supersede input power
requirements for fan systems.
B. Scope of Coverage
This NOPR covers those commercial
and industrial equipment that meet the
definition of ‘‘fan’’ or ‘‘blower,’’ as
codified at 10 CFR 431.172 and for
which DOE has finalized test
procedures in subpart J of 10 CFR part
431.
As discussed, DOE defines a ‘‘fan’’ or
‘‘blower’’ as a rotary bladed machine
used to convert electrical or mechanical
power to air power, with an energy
output limited to 25 kJ/kg of air. It
consists of an impeller, a shaft and
bearings and/or driver to support the
impeller, as well as a structure or
housing. A fan or blower may include
a transmission, driver, and/or motor
controller. 10 CFR 431.172. DOE
separates fans and blowers into general
fans and blowers and air circulating
fans.
An ‘‘air circulating fan’’ means 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
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static pressure loss, and is not a jet fan.
10 CFR 431.172. Fans and blowers that
are not ACFs are referred to as general
fans and blowers (‘‘GFBs’’) throughout
this document.
In response to the October 2022
NODA, DOE received comments on the
fans considered within the scope of its
analysis.
Greenheck, AMCA, and Morrison
commented that ACFs should be
considered in a separate rule from GFBs
since ACFs and GFBs are utilized in
different applications and use different
industry test procedures (i.e., AMCA
230 for ACFs and AMCA 214 for GFBs).
(Greenheck, No. 122 at p. 1; AMCA, No.
132 at pp. 1, 20–21; Morrison, No. 128
at p. 2)
DOE acknowledges that ACFs and
GFBs have separate utilities and test
procedures. In the test procedure final
rule that was published on May 1, 2023
(‘‘May 2023 TP Final Rule’’), DOE
adopted separate test procedures for
GFBs and ACFs (see appendix A and
appendix B, respectively, to subpart J of
10 CFR part 431). 88 FR 27312.
Similarly, in this NOPR, separate
analyses were conducted for ACFs and
GFBs to account for the difference in
test procedures, metrics, and utility.
DOE is proposing separate standards for
GFBs and ACFs, expressed in different
metrics, as discussed in later sections.
1. General Fans and Blowers
In the May 2023 TP Final Rule, DOE
established the scope of the test
procedure. 88 FR 27312. In this NOPR,
DOE is proposing energy conservation
standards for GFBs consistent with the
scope of coverage defined in the May
2023 TP Final Rule.
Specifically, in this NOPR, DOE
proposes energy conservation standards
for the following GFB categories, as
defined in the DOE test procedure: (1)
axial inline fan; (2) axial panel fan; (3)
centrifugal housed fan; (4) centrifugal
unhoused fan; (5) centrifugal inline fan;
(6) radial housed fan; and (7) power
roof/wall ventilator (‘‘PRV’’).
Furthermore, consistent with the DOE
test procedure, DOE proposes that the
scope of this energy conservation
standards rulemaking for GFBs would
apply to fans with duty points with a
fan shaft input power equal to or greater
than 1 hp and a fan static or total air
power equal to or less than 150 hp.
Additionally, DOE did not evaluate or
consider potential energy conservation
standards for GFBs that were not
included in the scope of its test
procedure. See 10 CFR 431.174. DOE
notes that its test procedure excludes
fans that create a vacuum of 30 inches
water gauge or greater. 10 CFR
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431.174(a)(2)(vii) In this NOPR, DOE
proposes to further clarify that this
provision excludes fans that are
manufactured and marketed exclusively
to create a vacuum of 30 inches water
gauge or greater.
DOE requests comment on its
proposed clarification for fans that
create a vacuum. Specifically, DOE
requests comment on whether fans that
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are manufactured and marketed
exclusively to create a vacuum of 30
inches water gauge or greater could also
be used in positive pressure
applications. Additionally, DOE
requests information on the applications
in which a fan not manufactured or
marketed exclusively for creating a
vacuum would be used to create a
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vacuum of 30 inches water gauge or
greater.
Consistent with the test procedure,
DOE has excluded certain embedded
fans, listed in Table III–1, from its
analysis. See the May 2023 TP Final
Rule for a detailed discussion of these
exclusions. 88 FR 27312, 27322–27331.
BILLING CODE 6450–01–P
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Table 111-1 Embedded Fans Proposed for Exclusion from the Scope of the Energy
Conservation Standards Rulemakine
Fans embedded in:
Direct-expansion dedicated outdoor air systems ("DX-DOASes") subject to any DOE
test procedures in appendix B to subpart F of part 431
Single-phase central air conditioners and heat pumps rated with a certified cooling
capacity less than 65,000 British thermal units per hour ("Btu/h"), that are subject to
DOE's energv conservation standard at 10 CFR 430.32(e)
Three-phase, air-cooled, small commercial packaged air-conditioning and heating
equipment rated with a certified cooling capacity less than 65,000 Btu/h, that are
subject to DOE's energy conservation standard at 10 CFR 431.97(b)
Transport refrigeration (i.e., Trailer refrigeration, Self-powered truck refrigeration,
Vehicle-powered truck refrigeration, Marine/Rail container refrigerant), and fans
exclusively powered by combustion engines
Vacuum cleaners
Heat Rejection Equipment:
• Packaged evaporative open circuit cooling towers
• Evaporative field-erected open circuit cooling towers
• Packaged evaporative closed-circuit cooling towers
• Evaporative field-erected closed-circuit cooling towers
• Packaged evaporative condensers
• Field-erected evaporative condensers
• Packaged air-cooled (dry) coolers
• Field-erected air-cooled (dry) coolers
• Air-cooled steam condensers
• Hybrid (water saving) versions of all of the previously listed equipment that
contain both evaporative and air-cooled heat exchange sections
Air curtains
*Air-cooled commercial package air conditioners and heat pumps (CUAC, CUHP)
with a certified cooling capacity between 5.5 tons (65,000 Btu/h) and 63.5 tons
(760,000 Btu/h) that are subject to DOE's energy conservation standard at 10 CFR
431.97(b)
*Water-cooled and evaporatively cooled commercial air conditioners and water-source
commercial heat pumps that are subject to DOE's energy conservation standard at 10
CFR 431.97(b)
*Single package vertical air conditioners and heat pumps that are subject to DOE's
energy conservation standard at 10 CFR 431.97(d)
*Packaged terminal air conditioners (PTAC) and packaged terminal heat pumps
(PTHP) that are subject to DOE's energv conservation standard at 10 CFR 431.97(e)
*Computer room air conditioners that are subject to DOE's energy conservation
standard at 10 CFR 431.97(e)
*Variable refrigerant flow multi-split air conditioners and heat pumps that are subject
to DOE's energy conservation standard at 10 CFR 431.97([)
* The exclusion only applies to supply and condenser fans embedded in this equipment.
BILLING CODE 6450–01–C
In response to the October 2022
NODA, DOE received comments
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regarding the scope of the energy
conservation standards for GFBs.
AHAM agreed with DOE’s proposal to
only cover GFBs that were rated at 1 hp
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or higher because it effectively excluded
most fans used in consumer product
applications. (AHAM, No. 123 at p. 5)
AHRI commented that regulating GFBs
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with an input power of less than 1 hp
would include residential fans. (AHRI,
No. 130 at p. 3) Morrison expressed
concern with the minimum power limit
for GFBs being 0.1 hp instead of 1 hp
since most GFBs with input powers less
than 1 hp are not commercial or
industrial. (Morrison, No. 128 at p. 1).
DOE interprets Morrison’s reference to a
0.1 hp limit to be a reference to the 0.1
hp representative unit for ACFs in the
October 2022 NODA. DOE notes that a
minimum power limit of 0.1 hp for
GFBs was not proposed in the October
2022 NODA. As discussed, GFBs with
an input power of less than 1 hp are
excluded from the scope of this
rulemaking, which is consistent with
the scope of coverage in the DOE test
procedure. See 10 CFR 431.174(a)(4)(i).
In response to both the October 2022
NODA and the July 2022 TP NOPR,
AHRI and Morrison commented that
they were concerned about how energy
conservation standards would apply to
replacement fans. (Morrison, No. 128 at
p. 2; AHRI, No. 130 at pp. 2, 5, 12)
Morrison and AHRI stated that
replacement fans should be exempt
from the standards rulemaking because
a fan with the same specific
performance and safety devices needs to
be used for replacement in order to
achieve the same system performance
and to comply with safety requirements.
Id. DOE notes that the comments from
AHRI and Morrison submitted in
response to the October 2022 NODA are
identical in content to the comments
submitted from these and other
stakeholders to the July 2022 NOPR.
These comments are fully summarized
in the May 2023 TP Final Rule. 88 FR
27312, 27334.
CA IOUs stated that consumers
seeking to replace low-pressure fans in
constrained spaces may not be able to
find replacement fans that meet a higher
FEI. Since a more efficient fan may
require a larger diameter, it might not fit
in the constrained space. Therefore,
either the constrained space will need to
be enlarged to fit the larger fan (which
is likely to be costly for the consumer)
or the consumer would select a
replacement fan of the same size but
with higher pressure (resulting in more
power use to achieve the same airflow).
(CA IOUs, No. 127 at p. 6) CA IOUs
therefore proposed a narrow exception
for [non-embedded] centrifugal fans
with a rated pressure not greater than
1.5 inches water gauge. (CA IOUs, No.
127 at p. 7)
Consistent with DOE’s response to
these comments in the April 2023 Final
Rule, DOE is proposing to exclude
certain embedded fans from potential
energy conservation standards in this
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rulemaking, whether sold for
incorporation into the equipment or
already incorporated in the equipment,
if embedded in equipment listed in
Table III–1. This approach would
exclude replacement fans for the
equipment listed in Table III–1. For
equipment not listed in Table III–1, DOE
notes that it is not excluding
replacement fans from the scope of the
rulemaking, consistent with the scope of
the DOE test procedure. In its analysis,
which is discussed in further detail in
section IV.C.1 of this document, DOE
evaluated improved efficiency options
while maintaining constant diameter
and duty point (i.e., air flow and
operating pressures remained constant
as efficiency increased); therefore, DOE
has tentatively concluded that a
compliant fan of the same size and
performance would be available for use
as an embedded fan or replacement for
an embedded fan. Additionally, DOE
does not expect that manufacturers of
equipment that contain embedded fans
would need to redesign their
equipment. Furthermore, DOE is not
excluding centrifugal fans based on its
rated pressure. In its analysis, DOE
specifically examined centrifugal
housed fans designed at both lower- and
higher-pressure duty points. Based on
that analysis, DOE did not find a
significant difference in the achievable
FEI values between the higher- and
lower-pressure duty points.
Accordingly, DOE has tentatively
determined that centrifugal housed fans
do not require an exclusion based on
rated pressure. Additional details on
DOE’s analysis are presented in chapter
3 of the accompanying TSD.
DOE also received multiple comments
from stakeholders about fans that
should be excluded from the scope of
the rulemaking; these comments were
similar to the comments received in
response to the July 2022 TP NOPR.
Morrison and AHRI commented that
they are concerned over double
regulation of products. (Morrison, No.
128 at pp. 2–3; AHRI, No. 130 at p. 2)
AHRI commented that fans embedded
in boilers and commercial water heaters
should be excluded. (AHRI, No. 130 at
pp. 10–11) DOE notes that these
comments were summarized and
responded to in the May 2023 TP Final
Rule. 88 FR 27312, 27329–27330.
Additionally, AHRI commented that the
regulation of fans within air-cooled
water chillers would not improve the
efficiency of the entire equipment, nor
would it lead to net energy savings
because ASHRAE 90.1 already sets
efficiency standards for the equipment
and the entire system is designed to
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meet the ASHRAE 90.1 efficiency
standards. (AHRI, No. 130 at pp. 9–10)
MIAQ commented that energy
conservation standards for embedded
fans would not necessarily improve the
performance of the products in which
the fans are embedded if the products
are already regulated. (MIAQ, No. 124 at
p. 4)
As previously discussed, DOE is
exempting fans embedded in the
equipment listed in Table III–1,
consistent with the DOE test procedure,
and continues to exclude fans in
covered equipment in which the fan
energy use is already captured in the
equipment-specific test procedures.
Furthermore, as discussed in section
III.A of this document, ASHRAE 90.1 is
not a federally mandated standard,
though it may be adopted by State and
local governments, and therefore DOE is
not specifically exempting fans that are
in equipment that are regulated by IECC
and ASHRAE 90.1.
More details regarding the scope of
GFBs that are included in this NOPR
can be found in the May 2023 TP Final
Rule. 88 FR 27312, 27317–27336.
2. Air Circulating Fans
In the October 2022 NODA, DOE
stated that it was considering all air
circulating fans in its analysis of
potential energy conservation standards
for fans and blowers, including
unhoused air circulating fan heads and
housed air circulating fan heads. 87 FR
62038, 62041. DOE received comments
from stakeholders in response to the
scope discussion in the October 2022
NODA.
AHAM commented there is a lack of
clarity about which products are
included and excluded in DOE’s
proposed scope and that DOE was
improperly expanding the scope of
products included in the fans and
blowers category by including
residential products. AHAM stated that
it did not believe that the metric,
technology options, assumptions, and
test procedure discussed in the October
2022 NODA are relevant to residential
fans. (AHAM, No. 123 at pp. 1–2)
Specifically, AHAM commented that
the proposed test procedure from the
July 2022 TP NOPR and AMCA 214–21
are not applicable to residential fans
and that no energy conservation
standards should be set for residential
fans until a test procedure for
residential fans is established. (AHAM,
No. 123 at pp. 5, 9) AHAM, Greenheck,
and AMCA also commented that ACFs
with an input power less than 125 W
should be excluded from scope to
coincide with the scope limit in AMCA
230–23 and IEC 60879. (AHAM, No. 123
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AMCA, No. 132 at pp. 1–2, 19–20)
AHAM noted that this would effectively
differentiate between residential and
consumer products, so long as the 125
W threshold applies to the fan rating
alone and not to the entire product or
the fan and motor. (AHAM, No. 123 at
p. 5) DOE notes that ACFs are tested in
a configuration that measures electrical
input power to the fan, inclusive of the
motor, and that the existing test
procedures (i.e., AMCA 230–23 or IEC
60879:2019) do not allow measuring the
mechanical shaft power to the fan,
exclusive of the motor. Therefore, DOE
has determined that a limit in terms of
electrical input power (applicable to the
fan and motor) is more appropriate.
DOE notes that AHAM submitted
additional comments recommending
exclusion of residential fans and fans
embedded in residential products that
were also submitted in response to the
July 2022 TP NOPR. (AHAM, No. 123 at
pp. 2–5) DOE addressed those
comments in the May 2023 TP Final
Rule. 88 FR 27312, 27326. In the May
2023 TP Final Rule, DOE established the
scope of the test procedure for ACFs and
excluded ACFs with an input power of
less than 125 W at maximum speed. 88
FR 27312, 27331. In this NOPR, DOE is
proposing energy conservation
standards for ACFs consistent with the
scope of coverage defined in the May
2023 TP Final Rule. (see 10 CFR
431.174(b)). Therefore, DOE proposes
that ACFs with an input power of less
than 125 W at maximum speed are
excluded from the scope of this
standards rulemaking. DOE is aware,
however, that ACFs with an input
power less than 125 W at maximum
speed could be distributed in commerce
for industrial and commercial use, and
that ACFs with an input power greater
than 125 W at maximum speed could be
distributed in commerce for residential
use. However, any equipment that meets
the definition of air circulating fan, has
an input power greater than or equal to
125 W at maximum speed, as measured
by the test procedure at high speed, and
is of a type that is not a covered
consumer product and is, to any
significant extent, distributed in
commerce for industrial or commercial
purposes would be subject to these
proposed energy conservation
standards, regardless of whether it is
sold for use in commercial, industrial,
or residential settings.
AHAM commented that the
terminology used in the October 2022
NODA for fan head diameter, rather
than fan blade diameter, is inconsistent
with how residential ACFs are typically
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analyzed. (AHAM, No. 123 at p. 8) DOE
notes that while it works to use
terminology that is consistent with
industry terminology, it is not always
possible given the size and maturity of
test standards development in a given
industry. DOE clarifies that its usage of
the term ‘‘fan head diameter’’ in the
October 2022 NODA was intended to be
analogous to ‘‘fan blade diameter.’’
Additionally, DOE notes that it is
proposing a definition for ‘‘diameter’’
for fans and blowers that is consistent
with the term ‘‘fan blade diameter’’ in
this NOPR, which is discussed in
section IV.A.1.b of this document.
AHAM also commented that it did not
believe that DOE has enough data on
residential fans to analyze them. AHAM
stated that DOE’s analysis in the
October 2022 NODA had an ACF with
a 24-inch (‘‘in.’’) blade and a 0.5 hp
motor, which is not representative of
residential ACFs. (AHAM, No. 123 at p.
8) DOE notes that in the October 2022
NODA, it analyzed ACFs at multiple
representative sizes and motor
horsepowers, including a 12 in.
diameter, 0.1 motor hp unit; a 20 in.
diameter, 0.33 motor hp unit; a 24 in.
diameter, 0.5 motor hp unit; a 36 in.
diameter, 0.5 motor hp unit; and 50 in.
diameter, 1 motor hp unit. 87 FR 62038,
62046. DOE had determined that these
diameters and motor horsepowers were
representative of the full scope of ACFs
considered in the October 2022 NODA.
Id.
AHAM stated that the size of motors
that are typically used in residential
ACFs are excluded from the scope of the
ongoing electric motors rulemaking;
therefore, residential ACFs should be
excluded from this rulemaking since
DOE would not see potential savings.
(AHAM, No. 123 at p. 9) DOE notes that
this is a rulemaking for fans and
blowers. For ACFs, DOE considers
higher-efficiency motors as a design
option as well as other design options
but emphasizes that the approach that
DOE uses to evaluate potential
efficiency standards is not prescriptive
(see section IV.A.3 of this document).
Furthermore, DOE considers both
potential economic and energy savings
in its analysis, which is discussed in
section IV.G of this document.
Additionally, AHAM commented that
it was their understanding that the
proposed definitions for ACFs in the
July 2022 TP NOPR did not include
bladeless fans and agreed with the
exclusion of bladeless ACFs from scope.
(AHAM, No. 123 at p. 5) The definition
of air circulating fan, ‘‘a fan that has no
provision for connection to ducting or
separation of the fan inlet from its outlet
using a pressure boundary, operates
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against zero external static pressure loss,
and is not a jet fan,’’ does not exclude
bladeless fans. See 10 CFR 431.172.
However, as discussed above, ACFs
with input powers less than 125 W at
maximum speed are excluded from the
scope of this rulemaking. Therefore,
bladeless fans, which have input power
less than 125 W are excluded from the
scope of this NOPR.
NEMA expressed concern that the
July 2022 TP NOPR proposed only
including fans with a shaft input power
between 1 hp and 150 hp, but that the
October 2022 NODA proposed
including fans with a shaft input power
of less than 1 hp. (NEMA, No. 125 at p.
2). DOE notes that, as specified in the
test procedure, the 1 hp and 150 hp
limits are applicable to GFBs, and that
GFBs with an input power of less than
1 hp are excluded from scope. See 10
CFR 431.174(a)(4)(i). Additionally, DOE
clarifies that the 150-hp limit applies to
the fan air power. 10 CFR
431.174(a)(4)(ii) DOE notes that the ACF
scope evaluated in this NOPR is
consistent with the scope DOE adopted
in the May 2023 TP Final Rule, which
excludes ACFs with an input power of
less than 125 W. 88 FR 27312, 27333.
a. Ceiling Fan Distinction
DOE explained in the coverage
determination that fans and blowers, the
subjects of this rulemaking, do not
include ceiling fans, as defined at 10
CFR 430.2. See 86 FR 46579, 46586 and
10 CFR 431.171. Therefore, as stated in
the May 2023 TP Final Rule, equipment
that meets the definition of a ceiling fan
would be excluded from the scope of
equipment included under ‘‘fan and
blower’’. 88 FR 27312, 27365. A ceiling
fan means a nonportable device that is
suspended from a ceiling for circulating
air via the rotation of fan blades. 10 CFR
430.2. In the ceiling fan test procedure
final rule published on August 16, 2022,
DOE finalized an amendment to the
ceiling fan definition at 10 CFR 430.2 to
specify that a ceiling fan provides
‘‘circulating air,’’ which means ‘‘the
discharge of air in an upward or
downward direction. A ceiling fan that
has a ratio of fan blade span (in inches)
to maximum rotation rate (in
revolutions per minute) greater than
0.06 provides circulating air.’’ 87 FR
50396, 50402. Specifically, the 0.06 in/
RPM ratio was added in the ceiling fans
definition to distinguish fans with
directional airflow from circulating
airflow. Id.
DOE also finalized a definition for
‘‘high-speed belt-driven ceiling fan’’
(‘‘HSBD’’) and added language to clarify
that high-speed belt-driven ceiling fans
were to be subject to the AMCA 230–15
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test procedure and subject to a similar
efficiency metric as large-diameter
ceiling fans (namely the ceiling fan
energy index ‘‘CFEI’’). Id. at 87 FR
50424, 50426, 50431.
In the May 2023 TP Final Rule, DOE
established the definitions of ACF and
related terms. DOE defined the term 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’’. In addition, DOE
defined an unhoused circulating fan as
‘‘an air circulating fan without housing,
having an axial impeller with a ratio of
fan blade span (in inches) to maximum
rate of rotation (in revolutions per
minute) less than or equal to 0.06. The
impeller may or may not be guarded.’’
88 FR 27312, 27389–27390. DOE relied
on the blade span to maximum rpm
ratio to distinguish these ACFs from
ceiling fans. 87 FR 44194, 44216. For
housed ACFs however, DOE defined a
housed ACF as an air circulating fan
with an axial or centrifugal impeller,
and a housing. 88 FR 27312, 27390. This
definition aligns with the housed ACF
definition in AMCA 230–23 and does
not specify a diameter to speed ratio
limit because housed ACFs can have
blade span to maximum rpm ratios that
are in the same range as ceiling fans
(i.e., greater than 0.06).
In the Ceiling Fan ECS NOPR
published on June 22, 2023, DOE noted
that that a ceiling fan must be
‘‘distributed in commerce with
components that enable it to be
suspended from a ceiling.’’ 88 FR 40932,
40943. Belt-driven fans are often
distributed in commerce without
components that enable the fan to be
suspended from a ceiling. For example,
some belt-driven fans are sold
connected to wheels or to a pedestal
base. In this case, such a fan would not
meet the definition of a ceiling fan
because it has not been manufactured to
be suspended from the ceiling, and
therefore would not be subject to the
HSBD test procedure or any potential
energy conservation standards for
HSBDs even though a consumer could
independently purchase their own
straps or chains and elect to hang this
fan from the ceiling. 88 FR 40932,
40943.
DOE stated that HSBD ceiling fans, in
contrast to belt-driven fans connected to
wheel or a pedestal base, are distributed
in commerce with specific straps,
chains, or other similar components that
are designed and tested by the
manufacturer to safely support the
weight of the ceiling fan in an overhead
configuration. Further, they circulate air
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since they meet the 0.06 blade span to
maximum rpm ratio. 88 FR 40932,
40943.
Many belt-driven fans are housed (i.e.,
the fan blades are contained within a
cylindrical enclosure, often with solid
metal sides and a cage on the front and
back). However, the presence of a
housing is not relevant in determining
whether a product meets the definition
of ceiling fan. While a housing is
generally included to better direct air, a
housing could be added to a ceiling fan,
including those that are clearly intended
to circulate air. As such, DOE
emphasizes that the definition of a
ceiling fan requires that fan to be
‘‘suspended from a ceiling’’ and to
‘‘circulate air’’, rather than the presence
or absence of a fan housing. 88 FR
40932, 40943.
In response to the June 2023 Ceiling
Fan ECS NOPR (88 FR 40932), CA IOUs
commented that CFEI is not intended
for small-diameter ceiling fans.36 (CA
IOUs, No. EERE–2021–BT–STD–0011–
0049 at p. 3). All HSBD ceiling fans
identified by DOE would be smalldiameter ceiling fans. Therefore, DOE
interprets CA IOU’s comment to mean
that the CFEI metric is not intended for
HSBD ceiling fans. VES also pointed out
in response to the September 2019
Ceiling Fan TP NOPR (84 FR 51440) that
they sell shrouded fans that currently
are not subject to ceiling fan energy
conservation standards because they are
belt-driven. VES added that if they
transition to a direct-drive motor they
would be subject to high-speed smalldiameter ceiling fan standards, which
are not appropriate as the airflow of
their products is significantly higher
than high-speed small-diameter ceiling
fans given the intended directional
application. (VES, No. EERE–2013–BT–
TP–0050–0026 at pp. 1–2)
DOE notes that VES did not make a
statement as to whether or not the 0.06
blade span to rpm ratio would
appropriately distinguish between their
circulating fans and traditional ceiling
fans. However, as the air circulating fan
definitions have pointed out, the 0.06
blade span to rpm ratio is most
appropriate for distinguishing between
unhoused air circulating fans. Housed
air circulating fans may exceed the 0.06
blade span to rpm ratio and commonly
do, despite the fact that they are
typically thought of in industry as air
circulating fans and not ceiling fans,
even if they are ceiling mounted.
36 According to the DOE test procedure for ceiling
fans at appendix U to subpart B of 10 CFR part 430,
a small diameter ceiling fan means ‘‘a ceiling fan
that has a represented value of blade span, as
determined in 10 CFR 429.32(a)(3)(i), less than or
equal to seven feet.’’
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Based on the interpretation of the
ceiling fan definition in the June 2023
Ceiling Fan ECS NOPR, an identical fan
product could switch between being
regulated as a high-speed belt-driven
ceiling fan and a housed air circulating
fan based only on if the equipment is
sold with straps or chains for mounting
overhead. Similarly, an identical direct
drive fan product could switch between
being regulated as a high-speed smalldiameter ceiling fan and a housed air
circulating fan based only on the if the
product is sold with straps or chains for
mounting overhead. Further
complicating the analysis is the fact that
high-speed belt-driven ceiling fans, air
circulating fans and high-speed smalldiameter ceiling fans are subject to
different test procedures and different
efficiency standards. DOE believes this
confusion necessitates further
refinement.
To avoid this confusion, DOE is
reinterpreting the scope of the ceiling
fan definition based on the potential
overlap of products with housed air
circulating fans. As DOE noted in the
September 2019 Ceiling Fan TP NOPR,
the intent of the ceiling fan definition is
to be limited to ‘‘nonportable’’ devices
that ‘‘circulate air’’. 84 FR 51440, 51444.
Specifically, to clarify the distinction
between air circulating fans and ceiling
fans, DOE is interpreting the elements of
the ceiling fan definition in the
following way:
• Portable—means: (1) that a fan is
offered for mounting on surfaces other
than or in addition to the ceiling; and
(2) that a consumer can vary the
location of the product/equipment
throughout the product/equipment
lifetime. A ceiling fan is only mounted
to the ceiling and is not intended to be
installed in any other mounting
configuration or change location after
it’s been installed. This is in contrast to
housed air circulating fans sold with
straps and chains, where the products
are intended to be regularly modified to
direct air in different directions or move
airflow around different obstacles or in
different areas. DOE also notes that once
a ceiling fan is mounted to the ceiling,
it is often hard-wired in place;
• Not for the purpose of circulating
air—While DOE has traditionally
emphasized the 0.06 fan blade span to
maximum rotation rate ratio as the
distinction between circulating air and
direction airflow, DOE notes that the
definition of ‘‘circulating air’’ in the
ceiling fan definition is provided in
contrast to directional airflow. DOE is
interpreting the presence of a housing as
evidence of airflow that is intended to
be directional. In addition, DOE is
interpreting the ability for the consumer
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to easily modify the direction of the
airflow via mounting by ceiling
mounted chains, straps or via a ceiling
bracket wherein the fan is able to be
pointed in different directions as
evidence that the fan is providing
directional airflow.37
Based on the interpretation, the scope
of the ceiling fan definition would be
limited to only traditional ceiling fan
products that are connected to the
ceiling via a downrod, flush mounting,
or similar, non-portable device. All
other portable ceiling mounted fans that
provide directional airflow would be
regulated under the air circulating fan
regulation. While the June 2023 Ceiling
Fan ECS NOPR included proposed
efficiency standards for high-speed beltdriven ceiling fans, under the proposed
interpretation of the ceiling fan
definition, all high-speed belt-driven
ceiling fan products identified by DOE
would not be within the scope of the
ceiling fan definition and would instead
meet the definition of housed aircirculating fans. Further, any directdrive ceiling-mounted fan that is
portable and provides directional
airflow (i.e., with a housing) would meet
the housed air circulating fan definition
and be subject to the air circulating fan
test procedure and standards. In line
with this interpretation of the ceiling
fan definition, all housed air-circulating
fans have been included within this
NOPR analysis regardless of whether
they are sold with a straps or chains to
hang them from the ceiling or with
wheels or other mounting
configurations.
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C. Test Procedure and Metric
EPCA sets forth generally applicable
criteria and procedures for DOE’s
adoption and amendment of test
procedures. (42 U.S.C. 6314(a))
Manufacturers of covered products must
use these test procedures to certify to
DOE that their product complies with
energy conservation standards and to
quantify the efficiency of their product.
As previously discussed, DOE
published its test procedure final rule
on May 1, 2023, which established
separate uniform test procedures for
GFBs and ACFs. 88 FR 27312. The test
procedure for GFBs is based on
American National Standards Institute
(‘‘ANSI’’)/AMCA Standard 214–21 ‘‘Test
Procedure for Calculating Fan Energy
Index (FEI) for Commercial and
Industrial Fans and Blowers’’ (‘‘AMCA
214–21’’) with some modification and
37 See example of ‘‘ceiling mounted fans’’ that are
intended to provide directional, rather than
circulating air at www.trianglefans.com/type/
ceiling-mounted-fans.
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prescribes test methods for measuring
the fan electrical input power and
determining the FEI of GFBs. The test
procedure for ACFs is based on ANSI/
AMCA Standard 230–23 ‘‘Laboratory
Methods of Testing Air Circulating Fans
for Rating and Certification’’ (‘‘AMCA
230–23’’) with some modification and
prescribes test methods for measuring
the fan airflow in cubic feet per minute
per watt (‘‘CFM/W’’) of electric input
power to an ACF. (See 10 CFR part 431,
subpart J, appendices A and B,
respectively.) 88 FR 27312, 27315.
In response to the October 2022
NODA, AHAM commented that the test
procedure proposed in the July 2022 TP
NOPR was inconsistent with agreements
made in the 2015 ASRAC negotiations,
which diminishes the value of
participating in ASRAC negotiations.
(AHAM, No. 123 at pp. 10–11) DOE
notes that the context of this comment
is the same as an AHAM comment
submitted by AHAM to the July 2022 TP
NOPR that DOE summarized and
responded to in the May 2023 TP Final
Rule. 88 FR 27312, 27377.
1. General Fans and Blowers
a. General
DOE is proposing energy conservation
standards for GFBs in terms of FEI,
which is calculated in accordance with
the DOE test procedure. See 10 CFR part
431, subpart J, appendix A. In
accordance with the DOE test
procedure, the FEI metric would be
evaluated at each duty point as
specified by the manufacturer and, if
adopted, DOE proposes that each duty
point at which the fan is offered for sale
would need to meet the proposed
energy conservation standards.
FEI provides for evaluation of the
efficiency of a GFB across a range of
operating conditions, captures the
performance of the motor, transmission,
or motor controllers (if any), and allows
for the differentiation of fans with
motors, transmissions, and motor
controllers with differing efficiency
levels. FEI is a wire-to-air metric, which
means that it considers the efficiency
from the input power to the output
power of a fan, including the
efficiencies of the motor, motor
controller (if included), transmission,
and fan itself. The inclusion of all of
these components encourages the
improvement of motor, motor controller,
and transmission efficiencies, in
addition to the improvement of a fan’s
aerodynamic efficiency. In addition, FEI
aligns with the industry test standard
(AMCA 214–21) and can help drive
better fan selections by making it easier
to compare performance of different
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fans. AMCA 214–21 defines FEI as the
ratio of the electrical input power
(‘‘FEP’’) of a reference fan to the FEP of
the fan for which the FEI is calculated,
both established at the same duty point.
The DOE test procedure provides
methods to calculate both FEP and FEI
of a fan at a given duty point.
In response to the October 2022
NODA, DOE received comment on the
metric used for GFBs. Morrison and
AHRI commented that they disagreed
with using the weighted FEI (‘‘WFEI’’)
metric that was discussed in the July
2022 TP NOPR. (Morrison, No. 128 at
pp. 1, 3; AHRI, No. 130 at p. 2–3). DOE
notes that these comments are similar to
the comments submitted to the July
2022 TP NOPR that DOE summarized in
the May 2023 TP Final Rule. MIAQ
commented in support of using FEI as
the metric used for regulation and
disagreed with the use of WFEI because
it has not been evaluated by fan
manufacturers or their customers
(MIAQ, No. 124 at p. 2). In the May
2023 TP Final Rule, DOE responded to
similar comments and ultimately
defined FEI as the metric for general
fans and blowers. 88 FR 27312, 27367–
27369.
Morrison commented that the FEI
metric aligned well with the agreements
made in the ASRAC Term Sheet and
that FEI is now being used by numerous
standards as the metric for efficiency.
(Morrison, No. 128 at pp. 2–3) DOE
interprets Morrison’s comment as
support for using the FEI metric.
Morrison commented that variablefrequency drive (‘‘VFD’’) control
provides a good method to dynamically
achieve part-load operation to promote
energy savings. Morrison stated that
since the FEP calculation metric
penalizes the use of VFDs, DOE should
consider providing an equivalent bonus
factor, at a minimum, to gain back the
losses in the calculation. Morrison
commented that operating at part load
saves significantly more energy than any
other efficiency change. (Morrison, No.
128 at p. 3) As discussed in the May
2023 TP Final Rule, DOE is not adopting
a control credit in the calculation of FEP
for fans with a motor controller, such as
a VFD; however, as shown in Table I–
1, DOE is proposing lower standards for
fans sold with motor controllers to
account for the motor controller losses
in the FEP metric associated with
testing a fan with a controller.
As discussed in the May 2023 TP
Final Rule, to the extent that
manufacturers of general fans and
blowers are making voluntary
representations of FEI, then they would
need to ensure that the product is tested
in accordance with the DOE test
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procedure and that any voluntary
representations of FEI (such as in
marketing materials or on any label
affixed to the product) disclosure the
results of such testing. DOE recognizes
that the ability to make an additional
voluntary representation of the EU
metric in marketing materials and on
product labels may limit manufacturer
burden. DOE is clarifying that
manufacturers may represent the
additional EU metric, but if doing so
they must also represent the FEI metric
in accordance with the existing DOE test
procedure.
b. Combined Motor and Motor
Controller Efficiency Calculation
For fans with a polyphase regulated
motor and a controller, AMCA 214–21
allows testing these fans using a shaftto-air test (i.e., a test that does not
include the motor and controller
performance). When conducting a shaftto-air test, the mechanical fan shaft
input power is measured and the FEP is
calculated by using a mathematical
model to represent the performance of
the combined motor and controller (i.e.,
its part-load efficiency). The FEP is then
used to calculate the FEI of the fan.
Section 6.4.2.4 of AMCA 214–21,
which relies on Annex B, ‘‘Motor
Constants if Used With VFD
(Normative),’’ and Annex C, ‘‘VFD
Performance Constants (Normative),’’
provides a method to estimate the
combined motor and controller partload efficiency for certain electric
motors and controller combinations that
meet the requirements in sections
6.4.1.3 and 6.4.1.4 of AMCA 214–21,
which specify that the motor must be
polyphase regulated motor (i.e., an
electric motor subject to energy
conservation standards at 10 CFR
431.25).
In the July 2022 TP NOPR, DOE stated
its concerns that the equations
described in section 6.4.2.4 of AMCA
214–21 may not be appropriately
representative, resulting in FEI ratings
that would be higher than FEI ratings
obtained using the wire-to-air test
method described in section 6.1 of
AMCA 214–21. Therefore, in the July
2022 TP NOPR, DOE did not propose to
allow the use of section 6.4.2.4 of
AMCA 214–21. Instead, DOE proposed
that fans with a motor and controller be
tested in accordance with section 6.1 of
AMCA 214–21. DOE indicated that
manufacturers would still be able to rely
on a mathematical model (including the
same mathematical model as described
in section 6.4.2.4 of AMCA 214–21, if
the mathematical model met the AEDM
requirements) in lieu of testing to
determine the FEI of a fan with a motor
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and controller. 87 FR 44194, 44223. In
the July 2022 TP NOPR, DOE also
reviewed the reference motor and
controller (‘‘power drive system’’)
efficiency provided in IEC 61800–9–
2:2017 ‘‘Adjustable speed electrical
power drive systems Part 9–2:
Ecodesign for power drive systems,
motor starters, power electronics and
their driven applications—Energy
efficiency indicators for power drive
systems and motor starters,’’ which also
provides equations to represent the
performance of a motor and controller
used with fans, and found that the IEC
model predicted values of efficiency
that were significantly lower (more than
10 percent on average) than the model
included in AMCA 214–21. Id.
In the May 2023 TP Final Rule, DOE
further reviewed the model in AMCA
214–21 section 6.4.2.4 and stated that it
continued to have concerns that
applying the model in section 6.4.2.4 of
AMCA 214–21 may result in fan FEI
ratings that would be higher than FEI
ratings obtained using the wire-to-air
test method described in section 6.1 of
AMCA 214–21. 88 FR 27312, 27347.
Specifically, DOE reviewed information
provided by AMCA analyzing the AHRI
1210 database of certified motor
controllers and providing graphical
representations comparing the AHRI
data to the AMCA 207 model and found
that there were several AHRI-certified
motor and motor controller
combinations that had a tested
efficiency that is lower than the model
in section 6.4.2.4 of AMCA 214–21.
(Docket No. EERE–2021–BT–TP–0021–
0046, AMCA, No. 41 at pp. 18–19) In
their comments, AMCA stated that the
model in AMCA 214–21, section 6.4.2.4,
was not intended to be a conservative
estimate of losses. Instead, according to
AMCA, the model was intended to
provide a level playing field between
manufacturers that chose to test wire-toair and those that chose to test fan shaft
power and calculate wire-to-air losses.
(Docket No. EERE–2021–BT–TP–0021–
0046, AMCA, No. 41 at p. 18) 88 FR
27312, 27348.
Therefore, to minimize the possibility
that using the calculation approach
would result in better energy efficiency
ratings than when testing the equipment
inclusive of the motor and controller, in
the May 2023 TP Final Rule, DOE did
not allow the use of section 6.4.2.4 of
AMCA 214–21. Instead, DOE required
that fans with motor and controller be
tested in accordance with section 6.1 of
AMCA 214–21. DOE noted that
manufacturers would still be able to rely
on a mathematical model (including the
same mathematical model as described
in section 6.4.2.4 of AMCA 214–21) in
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lieu of testing to determine the FEI of a
fan with a motor and controller, as long
as the mathematical model meets the
AEDM requirements. Id. In other words,
manufacturers would not be able to
generally apply the model in section
6.4.2.4 of AMCA 214–21. Manufacturers
would have to first go through the
AEDM validation process to
demonstrate that the FEI as established
by the AEDM (or a calculation method
that would rely on the model in section
6.4.2.4 of AMCA 214–21) would be less
than or equal to 105 percent of the FEI
determined from the wire-to-air test of
the basic models used to validate the
AEDM. See 10 CFR 429.70(n).
Since the publication of the May 2023
Final Rule, the IEC published a new
version of IEC 61800–9–2 (‘‘IEC 61800–
9–2: 2023’’). Compared to IEC 61800–9–
2:2017, which included a calculation
method to directly establish typical
losses of a reference motor and motor
controller combination (or ‘‘Power Drive
System’’, ‘‘PDS’’), this version provides
the reference motor controller. It also
points to a separate IEC publication (IEC
TS 60034–30–2:2016 ‘‘Rotating
electrical machines—Part 30–2:
Efficiency classes of variable speed AC
motors (IE-code)’’) for establishing the
reference motor losses. The detailed
calculations of losses for a reference
motor and motor controller are also
described in IEC TS 60034–31: 2021
(‘‘Rotating electrical machines—Part 31:
Selection of energy-efficient motors
including variable speed applications—
Application guidelines’’).
IEC 61800–9–2:2023 also
characterizes the reference motor
controller or ‘‘complete drive module’’
(‘‘CDM’’) as corresponding to an IE1
efficiency class.38 See section 6.2 of IEC
61800–9–2:2023. IEC 61800–9–2:2023
further establishes efficiency classes for
PDS based on pairing different levels of
efficiency motors to baseline efficiency
CDMs at IE2 levels. See section 6.5 of
IEC 61800–9–2:2023. DOE reviewed a
report from the International Energy
Agency, Electric Motor Systems
Annex 39 which included test data from
179 tests on 57 motor controllers, as
well as additional market data and
showed that VFDs on the market today
are all within the same efficiency class
corresponding to ‘‘IE2’’, in line with the
baseline levels used in IEC 61800–9–2
38 IEC 61900–9–2 Ed.2:2023 establishes three
efficiency classes (IE0, IE1, and IE2) to characterize
the different efficiency levels of CDMs on the
market.
39 International Energy Agency, Electric Motor
Systems Annex, Report on Round Robin of
Converter Losses, Final Report of Results. www.iea4e.org/wp-content/uploads/2022/11/rrc_report_
final_2022dec.pdf.
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Ed. 2:2023. Therefore, DOE has
tentatively determined that the IE2 level
is appropriate to represent a baseline
CDM or motor controller.
In order to support an alternative
credit calculation (See discussion in
section IV.C.1.b) and potentially reduce
test burden, DOE evaluated the model in
IEC 61800–9–2:2023 assuming a
polyphase regulated motor that exactly
meets the standards at 10 CFR 431.25,
and a motor controller at IE2 level. In
addition, DOE adjusted the IE3 levels 40
to exactly match the standards at 10
CFR 431.25 and be comparable to the
motor losses in AMCA 214–21.41 DOE
found that compared to the AMCA
model, the IEC 61800–9–2:2023 model
resulted in generally lower combined
motor and motor controller
efficiencies.42 Based on this analysis,
DOE has tentatively determined that the
IEC model provides a better
representation of a baseline motor and
VFD combination (i.e., resulting in a
conservative estimate of losses) as by
definition it relies on a regulated
polyphase motor that exactly meets the
standards at 10 CFR 431.25 and on a
baseline IE2 motor controller.
Therefore, DOE proposes to reduce
test burden by adding a combined motor
and controller efficiency calculation to
allow establishing the FEI of fans sold
with a regulated polyphase motor and a
motor controller based on a shaft-to-air
test and calculated motor and controller
efficiency. DOE proposes that the
performance of the motor and motor
controller combination be allowed for
certain electric motors and controller
combinations that meet the
requirements in sections 6.4.1.3 and
6.4.1.4 of AMCA 214–21, which specify
that the motor must be polyphase
regulated motor (i.e., an electric motor
subject to energy conservation standards
at 10 CFR 431.25). To support this
approach, DOE proposes that the
performance of the motor and motor
controller combination be calculated in
accordance with the model described in
40 The IEC defines motor efficiency classes. See
IEC TS 60034–30–2:2016, Rotating electrical
machines—Part 30–2: Efficiency classes of variable
speed AC motors (IE-code).
41 For the purposes of this analysis, DOE
considered a 4-pole motor. DOE relied on the
coefficients provided in the EXCEL sheet
accompanying the IEC TS 60034–31 Ed.2:2021 to
calculate the motor losses equivalent to an IE3
motor (See Table 4 of IEC TS 60034–30–2:2016) and
multiplied each coefficient by ((100-hr) hIE3)/((100hIE3) hr where hr is the minimum value of full-load
efficiency at 10 CFR 431.25 at a given horsepower
across open and enclosed enclosure categories and
hIE3 is the IE3 full load efficiency at the same
horsepower and pole configuration.
42 Two percent lower on average for 4 poles
motors at 1, 10, 15, 25, 75, and 200 hp for loads
between 0.25 and 1.
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IEC 61800–9–2:2023 and the calculation
in IEC TS 60034–31: 2016, and
assuming a regulated polyphase motor
that exactly meets the standards at 10
CFR 431.25 and a baseline IE2 motor
controller. For the final rule, DOE may
also consider an approach where the
calculation of AMCA 214–21 would be
preserved but adjusted (i.e., same
equations but with different
coefficients) to align with the results of
the IEC 61800–9–2:2023 model as
proposed.
DOE requests comments and feedback
on the proposed methodology and
calculation of motor and motor
controller losses as well as potentially
using an alternative calculation based
on adjusted AMCA 214–21 equations.
2. Air Circulating Fans
In the October 2022 NODA, DOE used
FEI as the metric for ACFs in its
analysis. DOE requested feedback on the
FEI values that it determined and its
approach for estimating FEI values for
ACFs. 87 FR 62038, 62050.
AHAM commented that FEI is not an
appropriate metric to use for residential
ACFs because the reference fan used for
FEI is based on a commercial fan.
(AHAM, No. 123 at p. 7) Furthermore,
AHAM commented that the AMCA 214–
21 test procedure, which DOE proposed
to incorporate by reference in the July
2022 TP NOPR, is not applicable to
residential ACFs. (AHAM, No. 123 at p.
6) DOE notes that, as discussed in
section III.B.2 of this document, ACFs
with an input power of less than 125 W
are excluded from the scope of the
rulemaking.
The CA IOUs and AMCA commented
that the reason FEI values are much
higher for ACFs at diameters less than
20 in. is because the airflow constant in
the FEI calculation (3,210 CFM) is more
impactful for ACFs with lower CFM.
(CA IOUs, No. 127 at pp. 4–5; AMCA,
No. 132 at pp. 10–11, 19) To support
their comment, the CA IOUs provided
data demonstrating how, at lower
airflows, there is a ‘‘bonus’’ value added
to reference shaft input power as a
result of the airflow constant. (CA IOUs,
No. 127 at pp. 4–5) Ultimately, the CA
IOUs recommended that DOE consider
using a different airflow constant for
lower airflow fans to counter this effect.
Id. Greenheck explained that the airflow
constant in AMCA 214–21 is higher
than the 12-in. representative unit can
generate; therefore, Greenheck would
expect that efficiencies of the 12-in.
representative unit would be greater
than the efficiencies of larger units,
which is why AMCA 214–21 limits the
application of FEI to fans with
airpowers of at least 125 W. (Greenheck,
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No. 122 at p. 2) NEEA suggested that
DOE review and confirm the increases
in FEI for ACFs at diameters of 20 in.
or less. (NEEA, No. 129 at p. 4) AMCA
commented that there was a
discrepancy between the airflow
constant defined for ACFs in the July
2022 TP NOPR (3,210 CFM) and the
airflow constant that DOE used in the
October 2022 NODA (3,201 CFM).
(AMCA, No. 132 at p. 10) In response,
DOE confirms that the airflow constant
used in the October 2022 NODA is
consistent with that in the July 2022 TP
NOPR (3,210 CFM) and that the value of
3,201 CFM was a typographical error in
the October 2022 NODA. Greenheck
commented that using the FEI metric for
both GFBs and ACFs would cause
confusion regarding which constants
should be used for GFBs and which
constants should be used for ACFs.
(Greenheck, No. 122 at p. 1)
Based on additional evaluation and
stakeholder feedback on the airflow
constant in the FEI calculation, DOE has
adopted the efficacy metric in terms of
CFM/W at maximum speed for ACFs in
appendix B to subpart J of 10 CFR part
431 (see section 2.2). In the May 2023
TP Final Rule, DOE explained that it has
concerns over the readiness of an FEI
metric for ACFs and acknowledged the
uncertainty regarding the airflow and
pressure constant values that should be
used when calculating FEI for ACFs.
Additionally, the efficacy metric is
consistent with the metric used in the
ACF industry. 88 FR 27312, 27371.
Therefore, DOE conducted its analysis
for this NOPR and is proposing
standards in efficacy in terms of CFM/
Wat maximum speed.
D. Technological Feasibility
1. General
In each energy conservation standards
rulemaking, DOE conducts a screening
analysis based on information gathered
on all current technology options and
prototype designs that could improve
the efficiency of the equipment that is
the subject of the rulemaking. As the
first step in such an analysis, DOE
develops a list of technology options for
consideration in consultation with
manufacturers, design engineers, and
other interested parties. DOE then
determines which of those means for
improving efficiency are technologically
feasible. DOE considers technologies
incorporated in commercially available
equipment or in working prototypes to
be technologically feasible. 10 CFR
431.4; 10 CFR part 430, subpart C,
appendix A, section 6I(3)(i) and 7(b)(1)
(‘‘Process Rule’’).
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After DOE has determined that
particular technology options are
technologically feasible, it further
evaluates each technology option in
light of the following additional
screening criteria: (1) practicability to
manufacture, install, and service; (2)
adverse impacts on product utility or
availability; (3) adverse impacts on
health or safety, and (4) unique-pathway
proprietary technologies. 10 CFR 431.4;
Sections 6(b)(3)(ii)–(v) and 7(b)(2)–(5) of
the Process Rule. Section IV.B of this
document discusses the results of the
screening analysis for fans and blowers,
particularly the designs DOE
considered, those it screened out, and
those that are the basis for the standards
considered in this rulemaking. For
further details on the screening analysis
for this rulemaking, see chapter 4 of the
NOPR technical support document
(‘‘TSD’’).
2. Maximum Technologically Feasible
Levels
When DOE proposes to adopt a
standard for a type or class of covered
equipment, it must determine the
maximum improvement in energy
efficiency or maximum reduction in
energy use that is technologically
feasible for such equipment. (42 U.S.C.
6316(a); 42 U.S.C. 6295(p)(1))
Accordingly, in the engineering
analysis, DOE determined the maximum
technologically feasible (‘‘max-tech’’)
improvements in energy efficiency for
fans and blowers, using the design
parameters for the most efficient
products available on the market or in
working prototypes. The max-tech
levels that DOE determined for this
rulemaking are described in section IV.C
of this proposed rule and in chapter 5
of the NOPR TSD.
E. Energy Savings
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1. Determination of Savings
For each trial standard level (‘‘TSL’’),
DOE projected energy savings from
application of the TSL to fans and
blowers purchased in the 30-year period
that begins in the first full year of
compliance with the proposed
standards (2030–2059).43 The savings
are measured over the entire lifetime of
fans and blowers purchased in the
previous 30-year period. DOE quantified
the energy savings attributable to each
TSL as the difference in energy
consumption between each standards
43 Each TSL is composed of specific efficiency
levels for each product class. The TSLs considered
for this NOPR are described in section V.A of this
document. DOE conducted a sensitivity analysis
that considers impacts for products shipped in a 9year period.
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case and the no-new-standards case.
The no-new-standards case represents a
projection of energy consumption that
reflects how the market for equipment
would likely evolve in the absence of
energy conservation standards.
DOE used its national impact analysis
(‘‘NIA’’) spreadsheet model to estimate
national energy savings (‘‘NES’’) from
potential new standards for fans and
blowers. The NIA spreadsheet model
(described in section IV.I of this
document) calculates energy savings in
terms of site energy, which is the energy
directly consumed by equipment at the
locations where they are used. For
electricity, DOE reports national energy
savings in terms of primary energy
savings, which is the savings in the
energy that is used to generate and
transmit the site electricity. DOE also
calculates NES in terms of FFC energy
savings. The FFC metric includes the
energy consumed in extracting,
processing, and transporting primary
fuels (i.e., coal, natural gas, petroleum
fuels), and thus presents a more
complete picture of the impacts of
energy conservation standards.44 DOE’s
approach is based on the calculation of
an FFC multiplier for each of the energy
types used by covered products or
equipment. For more information on
FFC energy savings, see section IV.H.2
of this document.
2. Significance of Savings
To adopt any new or amended
standards for covered equipment, DOE
must determine that such action would
result in significant energy savings. (42
U.S.C. 6316(a); (42 U.S.C. 6295(o)(3)(B))
The significance of energy savings
offered by a new or amended energy
conservation standard cannot be
determined without knowledge of the
specific circumstances surrounding a
given rulemaking.45 For example, some
covered equipment have most of their
energy consumption occur during
periods of peak energy demand. The
impacts of these equipment on the
energy infrastructure can be more
pronounced than equipment with
relatively constant demand.
Accordingly, DOE evaluates the
significance of energy savings on a caseby-case basis, taking into account the
significance of cumulative FFC national
energy savings, the cumulative FFC
44 The FFC metric is discussed in DOE’s
statement of policy and notice of policy
amendment. 76 FR 51282 (August 18, 2011), as
amended at 77 FR 49701 (August 17, 2012).
45 The numeric threshold for determining the
significance of energy savings established in a final
rule published on February 14, 2020 (85 FR 8626,
8670), was subsequently eliminated in a final rule
published on December 13, 2021 (86 FR 70892).
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emissions reductions, and the need to
confront the global climate crisis, among
other factors. DOE has initially
determined the energy savings from the
proposed standard levels are
‘‘significant’’ within the meaning of 42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(B).
F. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides
seven factors to be evaluated in
determining whether a potential energy
conservation standard is economically
justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(I)–(VII)) The following
sections discuss how DOE has
addressed each of those seven factors in
this rulemaking.
a. Economic Impact on Manufacturers
and Consumers
In determining the impacts of a
potential new standard on
manufacturers, DOE conducts an MIA,
as discussed in section IV.J of this
document. DOE first uses an annual
cash flow approach to determine the
quantitative impacts. This step includes
both a short-term assessment—based on
the cost and capital requirements during
the period between when a regulation is
issued and when entities must comply
with the regulation—and a long-term
assessment over a 30-year period. The
industry-wide impacts analyzed include
(1) INPV, which values the industry on
the basis of expected future cash flows,
(2) cash flows by year, (3) changes in
revenue and income, and (4) other
measures of impact, as appropriate.
Second, DOE analyzes and reports the
impacts on different types of
manufacturers, including impacts on
small manufacturers. Third, DOE
considers the impact of standards on
domestic manufacturer employment and
manufacturing capacity, as well as the
potential for standards to result in plant
closures and loss of capital investment.
Finally, DOE takes into account
cumulative impacts of various DOE
regulations and other regulatory
requirements on manufacturers.
For individual consumers, measures
of economic impact include the changes
in LCC and PBP associated with new
standards. These measures are
discussed further in the following
section. For consumers in the aggregate,
DOE also calculates the national net
present value of the consumer costs and
benefits expected to result from
particular standards. DOE also evaluates
the impacts of potential standards on
identifiable subgroups of consumers
that may be affected disproportionately
by a standard.
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b. Savings in Operating Costs Compared
To Increase in Price (LCC and PBP)
d. Lessening of Utility or Performance of
Products
EPCA requires DOE to consider the
savings in operating costs throughout
the estimated average life of the covered
equipment in the type (or class)
compared to any increase in the price
of, or in the initial charges for, or
maintenance expenses of, the covered
equipment that are likely to result from
a standard. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this
comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase
price of equipment (including its
installation) and the operating expense
(including energy, maintenance, and
repair expenditures) discounted over
the lifetime of the equipment. The LCC
analysis requires a variety of inputs,
such as equipment prices, equipment
energy consumption, energy prices,
maintenance and repair costs,
equipment lifetime, and discount rates
appropriate for consumers. To account
for uncertainty and variability in
specific inputs, such as equipment
lifetime and discount rate, DOE uses a
distribution of values, with probabilities
attached to each value.
The PBP is the estimated amount of
time (in years) it takes consumers to
recover the increased purchase cost
(including installation) of more efficient
equipment through lower operating
costs. DOE calculates the PBP by
dividing the change in purchase cost
due to a more-stringent standard by the
change in annual operating cost for the
year that standards are assumed to take
effect.
For its LCC and PBP analysis, DOE
assumes that consumers will purchase
the covered equipment in the first full
year of compliance with new standards.
The LCC savings for the considered
efficiency levels are calculated relative
to the case that reflects projected market
trends in the absence of new or
amended standards. DOE’s LCC and
PBP analysis is discussed in further
detail in section IV.F of this document.
In establishing equipment classes and
in evaluating design options and the
impact of potential standard levels, DOE
evaluates potential standards that would
not lessen the utility or performance of
the considered equipment. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(IV))
Based on data available to DOE, the
standards proposed in this document
would not reduce the utility or
performance of the equipment under
consideration in this rulemaking.
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c. Energy Savings
Although significant conservation of
energy is a separate statutory
requirement for adopting an energy
conservation standard, EPCA requires
DOE, in determining the economic
justification of a standard, to consider
the total projected energy savings that
are expected to result directly from the
standard. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(III)) As discussed in
section III.E, DOE uses the NIA
spreadsheet models to project national
energy savings.
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e. Impact of Any Lessening of
Competition
EPCA directs DOE to consider the
impact of any lessening of competition,
as determined in writing by the
Attorney General, that is likely to result
from a proposed standard. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(V)) It
also directs the Attorney General to
determine the impact, if any, of any
lessening of competition likely to result
from a proposed standard and to
transmit such determination to the
Secretary within 60 days of the
publication of a proposed rule, together
with an analysis of the nature and
extent of the impact. (42 U.S.C. 6316(a);
42 U.S.C. 6295(o)(2)(B)(ii)) DOE will
transmit a copy of this proposed rule to
the Attorney General with a request that
the Department of Justice (‘‘DOJ’’)
provide its determination on this issue.
DOE will publish and respond to the
Attorney General’s determination in the
final rule. DOE invites comment from
the public regarding the competitive
impacts that are likely to result from
this proposed rule. In addition,
stakeholders may also provide
comments separately to DOJ regarding
these potential impacts. See the
ADDRESSES section for information to
send comments to DOJ.
f. Need for National Energy
Conservation
DOE also considers the need for
national energy and water conservation
in determining whether a new or
amended standard is economically
justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VI)) The energy savings
from the proposed standards are likely
to provide improvements to the security
and reliability of the Nation’s energy
system. Reductions in the demand for
electricity also may result in reduced
costs for maintaining the reliability of
the Nation’s electricity system. DOE
conducts a utility impact analysis to
estimate how standards may affect the
Nation’s needed power generation
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3749
capacity, as discussed in section IV.M of
this document.
DOE maintains that environmental
and public health benefits associated
with the more efficient use of energy are
important to take into account when
considering the need for national energy
conservation. The proposed standards
are likely to result in environmental
benefits in the form of reduced
emissions of air pollutants and
greenhouse gases (‘‘GHGs’’) associated
with energy production and use. DOE
conducts an emissions analysis to
estimate how potential standards may
affect these emissions, as discussed in
section IV.K; the estimated emissions
impacts are reported in section V.B.6 of
this document. DOE also estimates the
economic value of emissions reductions
resulting from the considered TSLs, as
discussed in section V.C.1 of this
document.
g. Other Factors
In determining whether an energy
conservation standard is economically
justified, DOE may consider any other
factors that the Secretary deems to be
relevant. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VII)) To the extent DOE
identifies any relevant information
regarding economic justification that
does not fit into the other categories
described previously, DOE could
consider such information under ‘‘other
factors.’’
2. Rebuttable Presumption
EPCA creates a rebuttable
presumption that an energy
conservation standard is economically
justified if the additional cost to the
equipment that meets the standard is
less than three times the value of the
first year’s energy savings resulting from
the standard, as calculated under the
applicable DOE test procedure. (42
U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(iii)) DOE’s LCC and PBP
analyses generate values used to
calculate the effects that proposed
energy conservation standards would
have on the payback period for
consumers. These analyses include, but
are not limited to, the 3-year payback
period contemplated under the
rebuttable-presumption test. In addition,
DOE routinely conducts an economic
analysis that considers the full range of
impacts to consumers, manufacturers,
the Nation, and the environment, as
required under 42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i). The results of
this analysis serve as the basis for DOE’s
evaluation of the economic justification
for a potential standard level (thereby
supporting or rebutting the results of
any preliminary determination of
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economic justification). The rebuttable
presumption payback calculation is
discussed in section V.B.1.c of this
proposed rule.
IV. Methodology and Discussion of
Related Comments
This section addresses the analyses
DOE has performed for this rulemaking
with regard to fans and blowers.
Separate subsections address each
component of DOE’s analyses.
DOE used several analytical tools to
estimate the impact of the standards
proposed in this document. The first
tool is a spreadsheet that calculates the
LCC savings and PBP of potential new
energy conservation standards. The
national impacts analysis uses a second
spreadsheet set that provides shipments
projections and calculates national
energy savings and net present value of
total consumer costs and savings
expected to result from potential energy
conservation standards. DOE uses the
third spreadsheet tool, the Government
Regulatory Impact Model (‘‘GRIM’’), to
assess manufacturer impacts of potential
standards. These three spreadsheet tools
are available on the DOE website for this
proposed rulemaking:
www1.eere.energy.gov/buildings/
appliance_standards/
standards.aspx?productid=
51&action=viewlive. Additionally, DOE
used output from the latest version of
the Energy Information Administration’s
(‘‘EIA’s’’) Annual Energy Outlook
(‘‘AEO’’), a widely known energy
projection for the United States, for the
emissions and utility impact analyses.
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A. Market and Technology Assessment
DOE develops information in the
market and technology assessment that
provides an overall picture of the
market for the equipment concerned,
including the purpose of the equipment,
the industry structure, manufacturers,
market characteristics, and technologies
used in the equipment. This activity
includes both quantitative and
qualitative assessments, based primarily
on publicly available information. The
subjects addressed in the market and
technology assessment for this
rulemaking include (1) determination of
equipment classes, (2) scope of the
analysis and data availability, and (3)
technology and design options that
could improve the energy efficiency of
fans and blowers. The key findings of
DOE’s market assessment are
summarized in the following sections.
See chapter 3 of the NOPR TSD for
further discussion of the market and
technology assessment.
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1. Equipment Classes
When evaluating and establishing
energy conservation standards, DOE is
required to establish separate standards
for a group of covered equipment (i.e.,
establish a separate equipment class)
based on the type of energy used. DOE
may also establish separate standards if
DOE determines that an equipment’s
capacity or other performance-related
feature that other equipment lacks
justifies a different standard. (42 U.S.C.
6316(a); 42 U.S.C. 6295(q)) In making a
determination whether a performancerelated feature justifies a different
standard, DOE must consider such
factors as the utility of the feature to the
consumer and other factors DOE
determines are appropriate. (Id.)
a. General Fans and Blowers
As discussed, DOE develops
equipment classes based on specific
performance-related features that impact
utility and may necessarily impact
efficiency in serving that utility. For
GFBs, DOE identified the direction of
airflow through the fan, the outlet
configuration of the fan, housing
features, and impeller features as
characteristics that may justify
establishing separate equipment classes.
DOE also considered the presence of
motor controllers as an additional factor
for developing equipment classes.
Based on the direction of airflow
through a fan impeller, the classification
of a fan may be either axial or
centrifugal. Axial fans move air parallel
to their axis of rotation and are suitable
for applications requiring high airflow
at relatively low pressures.
Alternatively, centrifugal fans move air
radially outward from the axis of
rotation, resulting in a change in
direction of the air from the inlet of the
fan to the impeller edge occurring at or
close to 90 degrees. This air is often
redirected by a housing, which may
concentrate the airflow into a
perpendicular outlet, as in the case of a
scroll housing, or again redirect the air
to move parallel to the inlet flow, as in
the case of an inline fan. Centrifugal
fans can overcome much higher
pressures than axial fans, but operate at
lower airflow, resulting in a difference
in utility where different airflows and
pressures are required. DOE has
tentatively determined that the
differences between axial- and
centrifugal-flow fans result in a
difference in utility based on the
pressure and airflow ranges under
which they are able to operate. For
example, an axial fan may be better
suited for a general-purpose ventilation
application, in which large volumes of
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air are required at low pressure, whereas
a centrifugal fan may be more
appropriate for an air conditioning
application, which may require a greater
operating pressure than could be
achieved by an axial fan. Mixed-flow
fans utilize a combination of axial and
centrifugal flows to provide similar
pressures at higher airflows compared to
centrifugal fans where the outlet flow is
parallel to the inlet flow. Based on a
review of the market, DOE has
tentatively determined that mixed-flow
fans do not provide a unique utility
from centrifugal fans in similar
arrangements, due to their similar
operating pressure and airflow ranges.
Therefore, DOE separated GFBs into
equipment classes based on whether
they utilize an axial or centrifugal
airflow in this NOPR.
The outlet configuration of a fan can
also affect its efficiency. In the DOE test
procedure, DOE established test
configuration and measurement
requirements based on whether the
immediate outlet of a fan is ducted or
not ducted.46 See appendix A to subpart
J of 10 CFR part 431. For GFBs, ducted
fans may be utilized to move air directly
from the outlet of the fan through HVAC
ducting internal to a building, while not
ducted fans discharge air into a plenum
or open space. For example, not ducted
fans may be utilized to exhaust large
quantities of air from a building. Not
ducted fans are also better suited for
applications in which the fan discharge
needs to split into multiple directions,
such as ventilation systems which
recirculate air from one room to other
parts of a building via multiple
branching outlets. When a fan outlet is
ducted, the outlet air moves through the
duct system, and the velocity pressure
associated with that air can be regained
as static pressure as it travels through
the ducting. In this case, FEI is
calculated based on a total pressure
basis accounting for both the static
pressure and the pressure associated
with the speed of the outlet air of the
fan.47 When a fan outlet is not ducted,
46 For the purposes of DOE’s test procedure,
ducting refers to the immediate discharge of a fan
and not the fan’s application. For example, a
centrifugal unhoused fan which exhausts air in all
directions into a plenum or open space would be
considered not ducted, and tested via the
corresponding test configuration, even if that fan is
ultimately installed in ducted ventilation system.
47 Static pressure is defined as the pressure
exerted by a fluid that is not in motion. Total
pressure is defined as the sum of the static pressure
and the pressure that arises from the movement of
a fluid, or the velocity pressure. A fan’s static
pressure is the static pressure at the outlet of the
fan minus the total pressure at the inlet of the fan.
The total pressure of a fan is the total pressure at
the outlet of the fan minus the total pressure at the
inlet of the fan.
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the outlet air is immediately released
into the surroundings, and the velocity
pressure of this air is lost to its
surroundings. In this case, FEI is
calculated only on a static pressure
basis since the pressure associated with
the outlet speed of the air is not aiding
the system. Because these outlet
configurations have different utilities,
and in providing this utility the
efficiency is calculated differently
according to the DOE test procedure,
DOE is proposing to separate GFBs into
equipment classes based on their outlet
configuration.
DOE has determined that a fan’s
housing may also impact utility. A fan
housing is the structure that encloses
and guides the airflow of a fan. Fans
require certain housing features for
specific utilities. For example, PRVs
require a special housing to prevent
precipitation from entering buildings.
Further, different fan housings result in
different outlet directions for airflow.
For example, centrifugal fans with a
scroll-shaped housing redirect airflow
perpendicular to the fan inlet, while
centrifugal fans with a cylindrical or
inline housing have parallel inlet and
outlet airflow. In applications that
require continuous airflow in a single
direction, such as in a long ventilation
duct, a centrifugal fan with inline
housing could be directly placed in the
duct to push air along the single
direction. Inserting a centrifugal fan
with a scroll housing in the same
application, however, would create
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unnecessary complexity because it
would create multiple changes of
direction of airflow, may require
changes to the ducting work, and could
lead to reduced performance in a spaceconstrained environment. Because the
described housings have specific
utilities and DOE has observed different
FEI ranges for fans with the described
housings, DOE is proposing to separate
GFBs into separate equipment classes by
whether they are housed or unhoused,
and to further separate GFBs by the
types of housings described.
DOE also considered impeller features
for separating fans into equipment
classes. DOE identified that radial
impellers as defined in AMCA 214–21
offer unique self-cleaning characteristics
that allow them to be utilized with
significantly less maintenance in
airstreams with a high density of
particulate matter, such as fume exhaust
from a mine.48 However, these impellers
are also less efficient than other
centrifugal impellers. Therefore, DOE is
proposing a separate equipment class
for fans that use a radial impeller.
The last feature that DOE evaluated
for separating GFBs into equipment
classes was the use of motor controllers,
which allow a fan to adapt to changing
48 AMCA 214–21 defines a radial impeller as a
form of centrifugal impeller with several blades
extending radially from a central hub. Airflow
enters axially through a single inlet and exits
radially at the impeller periphery into a housing
with impeller blades; the blades are positioned so
their outward direction is perpendicular within 25
degrees to the axis of rotation.
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load requirements. This enables a fan to
run at lower speed when the system
requirements allow, thus saving energy.
While this may result in energy savings
during operation, the DOE test
procedure for fans does not account for
these possible changes in operation and
energy savings. Furthermore, FEI is a
wire-to-air metric, as discussed in
section III.C.1 of this document, which
means that the use of a motor controller
would act to reduce the FEI of a fan at
each of its individual operating points.
Any efficiency standard set without
consideration of the motor controller
would be more stringent. DOE
recognizes the energy savings benefits of
using a motor controller with a fan to
allow the energy consumption of fan to
be adjusted based on the changing load
requirements of the system; therefore, to
avoid penalizing the use of such
technology, DOE proposes to create
equipment classes for GFBs sold with
and without motor controllers.
In the DOE Test Procedure, DOE
adopted definitions consistent with
AMCA 214–21 for several categories of
fans and blowers that are within the
scope of this NOPR. See 10 CFR
431.172. DOE also established a
modified definition for axial-panel fans
to distinguish these fans from ACFs. Id.
Table IV–1 presents the fan categories
and corresponding definitions adopted
by DOE.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table IV-1 Fan Cate2ory Definitions
Fan Category
Definition from test procedure
Axial Inline
Fan
A fan with an axial impeller and a cylindrical housing with or without turning
vanes.
An axial fan, without cylindrical housing, that includes a panel, orifice plate,
or ring with brackets for mounting through a wall, ceiling, or other structure
that separates the fan's inlet from its outlet.
A fan with a centrifugal or mixed flow impeller in which airflow exits into a
housing that is generally scroll-shaped to direct the air through a single fan
outlet. A centrifugal housed fan does not include a radial impeller. •
A fan with a centrifugal or mixed flow impeller in which airflow enters
through a panel and discharges into free space. Inlets and outlets are not
ducted. This fan type also includes fans designed for use in fan arrays that
have partition walls separating the fan from other fans in the array. ••
A fan with a centrifugal or mixed flow impeller in which airflow enters
axially at the fan inlet and the housing redirects radial airflow from the
impeller to exit the fan in an axial direction.
A fan with a radial impeller in which airflow exits into a housing that is
generally scroll-shaped to direct the air through a single fan outlet. Inlets and
outlets can optionally be ducted.
A fan with an internal driver and a housing to prevent precipitation from
entering the building. It has a base designed to fit over a roof or wall
opening, usually by means of a roof curb.
Panel Fan
Centrifugal
Housed Fan
Centrifugal
Unhoused Fan
Centrifugal
Inline Fan
Radial Housed
Fan
Power Roof
Ventilators
("PRVs")
*The inclusion of "scroll-shaped" in this definition excludes inline fans.
**Radial fans are housed and therefore not included in this definition.
During its analysis, DOE tentatively
determined that additional definitions
would help to clarify certain fan
equipment classes. DOE is proposing in
this NOPR to adopt the definitions for
‘‘radial impeller’’, ‘‘mixed-flow
impeller’’ and ‘‘housing’’ presented in
Table IV–2. DOE notes that these
proposed definitions are consistent with
those in AMCA 214–21, with some
minor modifications for clarity.
Table IV-2 Proposed Definitions for Fan Features
Mixed Flow
Impeller
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Fan Housing
A form of centrifugal impeller with several blades extending radially from a
central hub. Airflow enters axially through a single inlet and exits radially at
the impeller periphery into a housing; the blades are positioned so their
outward direction is perpendicular within 25 degrees to the axis of rotation.
Impellers can have a back plate and/or shroud.
An impeller featuring construction characteristics between those of an axial
and centrifugal impeller. A mixed-flow impeller has a fan flow angle 49
greater than 20 degrees and less than 70 degrees. Airflow enters axially
through a single inlet and exits with combined axial and radial directions at a
mean diameter greater than the inlet diameter.
Any fan component(s) that direct airflow into or away from the impeller
and/or provide(s) protection for the internal components of a fan or blower
that is not an air circulating fan. A housing mav serve as a fan's structure.
DOE found some fans are sold as
radial fans but have impellers that
incorporate both radial and non-radial
features, such as blades with a slight
backward-inclined design or blades
with both straight and backward-curved
portions. To ensure that these fans are
properly and consistently classified as
either radial or centrifugal housed, DOE
49 AMCA 214–21 defines fan flow angle as the
angle of the centerline of the air-conducting surface
of a fan blade measured at the midpoint of its
trailing edge with the centerline of the rotation axis
in a plane through the rotation axis and the
midpoint of the trialing edge.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
is proposing a definition for ‘‘radial
impeller’’.
Additionally, DOE is proposing to
define ‘‘mixed flow impeller’’ to
distinguish mixed flow impellers from
axial and centrifugal impellers and to
ensure that fans sold with a mixed flow
impeller are correctly classified. DOE
notes that, as defined in Table IV–1,
inline fans with mixed flow impellers
are considered in the centrifugal inline
equipment class.
Lastly, DOE is proposing to define
‘‘fan housing’’ since housing is a
criterion used to separate equipment
classes. In its evaluation of the market,
DOE found some fans that may not be
easily classified without a clear and
consistent definition for housing. For
example, cabinet fans are sold with an
enclosure surrounding their internal
moving components and an additional
enclosure further directing airflow. DOE
has observed that cabinet fans are
commonly marketed as inline fans since
the outermost enclosure directs the
airflow to be inline; however, the
internal enclosure, which directs
airflow into and out of the impeller,
directs airflow at a 90-degree angle,
which would be consistent with a
centrifugal housed fan. Based on DOE’s
proposed definitions, cabinet fans
would be part of the centrifugal housed
equipment class.
DOE evaluated each of the fan
categories defined in the DOE test
procedure using the identified GFB
performance features and proposes that
each fan category defined in the test
procedure will be evaluated as a
3753
separate equipment class. For PRVs,
DOE has found that they can be either
axial or centrifugal, and their outlets can
either be ducted or not ducted. PRVs
used for supply will have a ducted
outlet, while PRVs used for exhaust will
not have a ducted outlet. DOE notes that
while centrifugal PRVs serve both
supply and exhaust functions, DOE did
not find a significant number of axial
PRVs being used for supply in the
market. Therefore, DOE is proposing to
further divide PRVs into three distinct
equipment classes: axial PRVs,
centrifugal PRV exhaust fans, and
centrifugal PRV supply fans. Table IV–
3 presents the proposed definitions for
each of the three PRV fan equipment
classes, which align with the definitions
in AMCA 214–21.
Table IV-3 Proposed PRV Fan Cateeories and Definitions
Fan
Equipment
Class
Proposed Definition
Axial PRV
A PRV with an axial impeller that either supplies or exhausts air to a building
where the inlet and outlet are not tvoicallv ducted.
A PRV with a centrifugal or mixed-flow impeller that exhausts air from a
building and which is typically mounted on a roof or a wall.
A PRV with a centrifugal or mixed-flow impeller that supplies air to a
building and which is typically mounted on a roof or a wall.
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Additionally, DOE is proposing that
each GFB equipment class be split into
a class of fans that are sold with motor
controllers and a class of fans that are
sold without motor controllers. For
example, there would be two equipment
classes for axial PRVs—one for axial
PRVs sold with motor controllers and
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one for axial PRVs sold without motor
controllers. This would be the same for
all remaining proposed GFB equipment
classes.
In summary, DOE is proposing to
separate GFBs into 18 equipment classes
in this NOPR. These equipment classes
are shown in Table IV–4. As just
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discussed, DOE notes that each
equipment class shown in the table has
a variable-speed and a constant-speed
variant. As mentioned previously, these
equipment classes directly correspond
to the GFB fan categories defined in the
DOE test procedure, with the exception
of PRVs.
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Centrifugal
PRV Exhaust
Fan
Centrifugal
PRV Supply
Fan
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table IV-4 Proposed Equipment Classes for General Fans and Blowers
Equipment Class*
Airflow
Outlet
Confi2uration
Housing
Impeller
Feature
Axial Inline
Axial
Ducted
Inline
Standard
Panel
Axial
Not Ducted
none
Standard
Axial Power Roof Ventilator
Axial
Not Ducted
Precipitation
protection
Standard
Centrifugal Inline* *
Centrifugal
Ducted
Inline
Standard
Centrifugal Power Roof Ventilator Supply
Centrifugal
Ducted
Precipitation
protection
Standard
Centrifugal Housed
Centrifugal
Ducted
Scroll
Standard
Radial Housed
Centrifugal
Ducted
Scroll
Self-Cleaning
Centrifugal Unhoused
Centrifugal
Not Ducted
none
Standard
Centrifugal Power Roof Ventilator Exhaust
Centrifugal
Not Ducted
Precipitation
protection
Standard
Although GFBs were not discussed in
the October 2022 NODA, DOE received
comment on GFB equipment classes.
Specifically, AHRI commented that
forward-curved fans, which are
typically used in low-pressure
applications, could be removed from the
market by energy conservation
standards. (AHRI, No. 130 at pp. 12–13)
AHRI stated that forward-curved fans
should have a separate equipment class
because they provide code-required
sound quality in low-pressure and lowspeed ranges. Id. Morrison and AHRI
also commented that return or relief
fans, which are commonly used for
energy-saving economizer functions in
systems, could be removed from the
market if they are regulated by a DOE
energy conservation standard.
(Morrison, No. 128 at p. 2; AHRI, No.
130 at p. 2, 13)
DOE notes that the FEI metric is a
function of the operating pressure. As
mentioned in section III.C.1 of this
document, FEI is the ratio of the
reference FEP to the actual FEP. The
reference fan is used to normalize the
FEI calculation by evaluating fan
performance compared to a consistent
reference fan at each duty point and
configuration. Evaluating FEI in this
manner allows for comparison of
different fans independent of the wide
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variety of fan types and duty points.
Consequently, a return or relief fan
operating at a lower pressure than a
supply fan at a given airflow would be
compared to a reference FEP specific to
that duty point, which accounts for the
lower operating pressure and mitigates
disproportionate impacts; therefore,
DOE has tentatively concluded that
return and relief fans do not need a
separate equipment class.
To address AHRI’s comment that
forward-curved fans provide coderequired sound quality in low-pressure
and low-speed ranges, DOE evaluated
data on inlet and outlet noise obtained
from manufacturer fan selection
software for centrifugal-housed fans at
low-pressure duty points. Based on this
analysis, DOE observed centrifugalhoused fans with both backwardinclined and airfoil impellers that
provided equivalent or nearly
equivalent noise levels, in A-weighted
decibels, to forward-curved fans
operating at the same duty point.
Furthermore, DOE observed that noise
levels significantly decreased as the FEI
of the fan increased, indicating that
energy conservation standards would
not inhibit fans from complying with
sound quality requirements. Therefore,
DOE has tentatively determined that
forward-curved fans do not require a
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separate equipment class. However, to
ensure that forward-curved fans were
adequately evaluated, DOE evaluated a
parallel design path in which it
assumed that all forward-curved fans
would be redesigned to meet any
proposed energy conservation
standards, rather than replacing the
forward-curved impeller with another
impeller topology such as airfoil or
backward-inclined. DOE evaluated this
parallel design path to consider the
costs required to preserve forwardcurved fans in the market. Additional
details on the parallel design path for
forward-curved fans are provided in
section IV.C.1.b of this document and
chapter 5 of the NOPR TSD.
DOE received no further comments on
GFB equipment classes and is therefore
proposing the equipment classes in
Table IV–4.
b. Air Circulating Fans
In response to the October 2022
NODA, AMCA recommended that DOE
use the same ACF definitions as those
used in AMCA 230–23. (AMCA, No. 132
at pp. 2, 18) As discussed in the May
2023 Test Procedure Final Rule, the
definitions that DOE adopted for ACF,
unhoused air circulating fan head
(‘‘ACFH’’), housed ACFH, air circulating
axial panel fan, box fan, cylindrical
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* Each eqmpment class 1s further separated by whether the fan 1s sold with motor controllers as discussed below
** Includes mixed-flow fans
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
ACF, and housed centrifugal ACF align
with the definitions published in AMCA
230–23. 88 FR 27312, 27339. DOE
additionally adopted definitions for air
circulating axial panel fan, box fan,
cylindrical ACF, and housed centrifugal
ACF in the DOE test procedure, as
defined in Annex B of AMCA 230–23.
3755
See 10 CFR 431.172. These definitions
are reproduced Table IV–5.
Table IV-5 ACF Definitions in DOE Fans Test Procedure (10 CFR 431.172)
ACF Term
Air Circulating Fan
Unhoused Air Circulating
Fan Head
Housed Air Circulating
Fan Head
Air circulating axial panel
fan
Box fan
Cylindrical Air Circulating
Fan*
Housed centrifugal Air
Circulating Fan
Definitions
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 iet fan.
An ACF without a housing, having an axial impeller with a ratio
of fan-blade span (in inches) to maximum rate of rotation (in
revolutions per minute) less than or equal to 0.06. This impeller
may or may not be guarded.
An ACF with an axial or centrifugal impeller and a housing.
An axial housed ACFH without a cylindrical housing or box
housing that is mounted on a panel, orifice plate, or ring.
An axial housed ACFH without a cylindrical housing that is
mounted on a panel, orifice plate, or ring and is mounted in a box
housing.
An axial housed ACFH with a cylindrical housing that is not a
Positive Pressure Ventilator as defined in ANSI/AMCA Standard
240-15, Laboratory Methods of Testing Positive Pressure
Ventilators for Aerodynamic Performance Rating.
A housed ACFH with a centrifugal or radial impeller in which
airflow exits into a housing that is generally scroll shaped to
direct the air through a single. narrow fan outlet.
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BILLING CODE 6450–01–C
In the October 2022 NODA, DOE did
not evaluate separate equipment classes
for housed and unhoused ACFs and
requested comment and supporting data
on whether housed and unhoused ACFs
have significant differences in utility
and/or efficiency. 87 FR 62038, 62045.
NEEA stated that DOE should analyze
unhoused and housed ACFs separately
in its analysis because the efficiencies of
housed and unhoused fans differ
enough that an analysis of both together
could result in non-representative EL
values. To support this point, NEEA
referenced a plot that was included in
the supplementary spreadsheet for the
October 2022 NODA that showed ACF
efficiency distribution overlayed on the
efficiency levels analyzed in the
NODA 50 and stated that the efficiency
distributions in the plot were wide for
all diameters. (NEEA, No. 129 at p. 1–
2) NEEA commented that, given the
50 See Docket No. EERE–2022–BT–STD–0002, No.
11 for the supplementary spreadsheet associated
with the October 2022 NODA.
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many performance-related features with
unquantifiable impacts on the fan
efficiency data DOE used for its
analysis, DOE should separate housed
and unhoused ACFs into separate
equipment classes to ensure that housed
and unhoused ACFs are fairly analyzed.
NEEA added that the separation of
housed and unhoused fans aligns with
the approach taken for GFBs in NODA
3. (NEEA, No. 129 at p. 2–3)
The Efficiency Advocates commented
that DOE should group ACFHs, box
fans, panel fans, and personnel coolers
together into a single axial ACF class
since they are all axial fans that provide
directional airflow and do not differ
significantly in FEI. (Efficiency
Advocates, No. 126 at p. 3) They noted
that the ACF subcategories in AMCA
230 are delineated in AMCA 230
primarily for descriptive purposes and
not for regulatory purposes. Id. DOE
interprets ACFHs and personnel coolers,
as referenced by the Efficiency
Advocates, to align with the definitions
given for unhoused ACFHs and
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cylindrical ACFs, respectively, in Table
IV–5. DOE therefore interprets the
Efficiency Advocates’ comment as a
recommendation to combine all axial
ACFs into a single equipment class.
DOE’s review of the ACF market
generally indicated that air circulating
axial panel fans, box fans, cylindrical
ACFs, and unhoused ACFHs could all
be used interchangeably for air
circulation applications. DOE did
observe that cylindrical ACFs are
sometimes marketed toward highvelocity applications. To verify whether
design in high-velocity applications
would warrant separating cylindrical
ACFs into their own equipment class,
DOE reviewed available air velocity and
thrust data for air circulating axial panel
fans, box fans, cylindrical ACFs, and
unhoused ACFHs. Based on this
analysis, DOE did not find a consistent
trend of one or more of these
subcategories of ACFs producing more
air velocity or thrust than another,
further indicating that they may be used
interchangeably. DOE therefore
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*AMCA 230-23, which is referenced in the DOE test procedure, lists personnel coolers, barrel fans, drum fans, high
velocity fans, portable coolers, thermal mixing fans, destratification fans, and down-blast fans as examples of
cylindrical ACFs in Annex B.3.2.3.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
evaluated air circulating axial panel
fans, box fans, cylindrical ACFs, and
unhoused ACFHs as a single ‘‘axial
ACF’’ equipment class in this NOPR.
DOE is therefore proposing that an axial
ACF be defined as ‘‘an ACF with an
axial impeller that is either housed or
unhoused.’’ DOE considers all fans that
meet the axial ACF definition to be
subject to the DOE test procedure, and
these fans, unless specifically excluded,
would be subject to any future energy
conservation standards.
DOE requests comment on whether
there are specific fans that meet the
axial ACF definition that provide utility
substantially different from the utility
provided from other axial ACFs and that
would impact energy use. If so, DOE
requests information on how the utility
of these fans differs from other axial
ACFs and requests data showing the
differences in energy use due to
differences in utility between these fans
and other axial ACFs.
In the October 2022 NODA, DOE also
requested comment on whether each of
the following design characteristics may
impact the utility of air circulating fans:
presence or absence of a safety guard,
presence or absence of housing, housing
design, blade type, power requirements,
and air velocity or throw. 87 FR 62038,
62045. Additionally, DOE requested
information on any additional design
characteristics that may impact ACF
utility. Id. In response, AMCA
commented that all the design variables
on which DOE requested comment are
combined to influence an ACF’s
performance characteristics. (AMCA,
No. 132 at p. 6–7). DOE reviewed the
market and found that adjusting these
design variables while keeping other
design parameters constant did not
produce a significant difference in
efficiency, impact the operation, or
impact the fan’s application. Therefore,
DOE has tentatively decided not to
delineate separate equipment classes for
axial ACFs based on safety guards,
housing, blade type, power
requirements, or air velocity and throw.
In the October 2022 NODA, DOE
additionally requested comment and
supporting data on whether belt-driven
and direct-driven ACFs have significant
differences in utility or efficiency. 87 FR
62038, 62045. The Efficiency Advocates
commented that DOE should not
consider belt-driven fans as a separate
equipment class because those fans are
merely a low-cost alternative to the
more efficient direct-drive fans rather
than a different performance or utility
consideration, and that a separate
equipment class for belt-driven ACFs
could undermine the potential energy
savings for larger diameter ACFs.
(Efficiency Advocates, No. 126 at p. 3)
DOE’s review of belt-driven ACFs on the
market indicated that, while belt drives
do provide a utility for adjusting the
rotational speed of the ACF, VFDs also
allow users to adjust the rotational
speed of the ACF. Therefore, DOE has
tentatively determined that belt drives
do not provide a unique utility and DOE
did not treat belt-driven ACFs as an
equipment class in its NOPR analysis.
The shift from belt drive to direct drive
is instead discussed as a design option
in section IV.C.2.b of this document.
DOE further reviewed the ACF market
to determine if additional equipment
classes were appropriate for axial ACFs.
DOE observed that axial ACFs with
larger impeller diameters tended to be
more efficient than axial ACFs with
smaller impeller diameters. DOE also
received feedback during manufacturer
interviews that fans with larger
diameters are generally more efficient.
Therefore, DOE considered diameter as
a class-setting variable for axial ACFs in
this NOPR. DOE found multiple
efficiency incentive programs that
provide rebates to agricultural fan
manufacturers if they meet certain
efficiency targets.51 For axial ACFs,
these agricultural rebate programs
typically define four diameter ranges to
which the rebate efficiency levels
applied: ‘‘12-inch to less than 24-inch
diameter range,’’ ‘‘24-inch to less than
36-inch diameter range,’’ ‘‘36-inch to
less than 48-inch diameter range,’’ and
‘‘48-inch diameter or greater range.’’ To
align with these programs, DOE initially
considered four different equipment
classes for axial ACFs, one for each
diameter range. However, after
reviewing efficacy data for axial ACFs,
DOE did not find a significant difference
in efficacy between axial ACFs in the
12-inch to less than 24-inch diameter
range and the 24-inch to less than 36inch diameter range. Therefore, DOE
combined these two diameter ranges
into a single equipment class: the ‘‘12inch to less than 36-inch diameter axial
ACF’’ class. DOE assigned the 36-inch to
less than 48-inch diameter range to a
‘‘36-inch to less than 48-inch diameter
axial ACF’’ class and the 48-inch
diameter or greater range to a ‘‘48-inch
diameter or greater axial ACF’’ class.
The term ‘‘diameter’’ in the context of
fans and blowers refers to the impeller
diameter of a fan. Impeller diameter is
typically determined by measuring the
radial distance from the tip of one of the
impeller blades to the center of the
impeller hub and doubling that value.
DOE is therefore proposing to define
diameter for fans and blowers as ‘‘the
impeller diameter of a fan, which is
twice the measured radial distance
between the tip of one of the impeller
blades of a fan to the center axis of its
impeller hub.’’ DOE notes that impeller
diameter may often be different than
nominal diameter.
Additionally, in the October 2022
NODA, DOE summarized a comment
from the Efficiency Advocates stating
that portable blowers may require an
equipment class separate from other
ACFs because they provide a unique
application (i.e., drying floors), have
centrifugal rather than axial
construction, and are relatively low in
efficiency. 87 FR 62038, 62045. DOE
understands the term ‘‘portable blower’’
to be a housed centrifugal ACF. As
discussed in section IV.A.1.a of this
document, DOE tentatively determined
that axial and centrifugal fans generally
have different utilities. DOE also
reviewed the housed centrifugal ACF
market and found that housedcentrifugal ACFs are used primarily as
carpet dryers. Additionally, DOE
observed that housed-centrifugal ACFs
with input powers greater than or equal
to 125 W typically have impeller
diameters of 4 in. to 20 in., while axial
ACFs with input powers greater than
125 W often have impeller diameters
exceeding 20 in. DOE also reviewed
housed centrifugal ACF efficiency data
and found that the most efficient housed
centrifugal ACFs can be 3 to 4 times less
efficient than the most efficient axial
ACFs with a comparable diameter.
Since housed centrifugal ACFs have a
different construction, are only used as
carpet dryers, are smaller, and are less
efficient than axial ACFs, DOE has
created a separate equipment class for
housed centrifugal ACFs. DOE did not
consider different diameter ranges for
the housed centrifugal ACF equipment
class because it did not observe a
significant variation in efficiency for
housed centrifugal ACFs with diameter.
The proposed equipment classes for
ACFs are summarized in Table IV–6.
51 See cecnet.net/agriculture; www.ecirec.coop/
rebate-forms-and-specifications; and
www.tiprec.com/rebates.
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Table IV-6 Proposed Equipment Classes for ACFs
12-in. to less than 36-in. diameter axial
ACFs
36-in. to less than 48-in. diameter axial
ACFs
48-in. diameter or greater axial ACFs
Housed Centrifugal ACFs
2. Scope of Analysis and Data
Availability
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a. General Fans and Blowers
DOE conducted the GFB engineering
analysis for this NOPR using a database
of confidential sales information
provided by AMCA (‘‘AMCA sales
database’’), performance data from
manufacturer online fan selection
software, and performance data
provided from confidential
manufacturer interviews.
In response to the July 2022 TP
NOPR, DOE received comments about
the data used in its historical analyses.
Specifically, AHRI expressed concern
with DOE’s use of the AMCA sales
database in the December 2014 NODA,
the May 2015 NODA, and the November
2016 NODA, which contains efficiencies
established at a variety of different
speeds. (Docket No. EERE–2021–BT–
TP–0021, AHRI, No. 40 at p. 13). AHRI
stated that this approach was
inconsistent with the ASRAC Working
Group agreement for establishing
product performance and, as disclosed
during ASRAC negotiations, much of
the data in the database was not
certified performance and may not be
reliable for evaluating the impact of
efficiency standards. (Id.)
With respect to the AMCA sales
database providing efficiency data at a
variety of speeds, DOE notes that, in
accordance with the DOE test
procedure, fans must be tested at a range
of duty points over which they may
operate. Duty points are characterized
by a given airflow and pressure at a
corresponding operating speed. In other
words, fans could be tested at a variety
of different speeds depending on the
duty point at which the fan is being
operated. As discussed in section IV.B
of this document, DOE evaluated the
entire range of duty points when
developing the proposed efficiency
levels for each class; therefore, DOE has
used the performance data provided in
the AMCA sales database as a basis for
its engineering analysis. Furthermore, in
response to the data in the database not
being certified performance data, DOE
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Equipment Categories Grouped into Equipment
Class, as defined in TP Final Rule
Axial Air Circulating Axial Panel Fans
Box Fans
Cylindrical ACFs
Unhoused ACFHs
Housed Centrifugal ACFs
compared the fan models in the AMCA
sales database with the fan models in
the AMCA Certified Rating Program.52
DOE found that the fan models in the
AMCA sales database are certified as
part of AMCA’s Certified Rating
Program.
The AMCA sales database that DOE
used in this analysis is the same
database that was used in the May 2015
NODA and the November 2016 NODA.
To validate that the AMCA sales
database remains representative of the
current market, DOE verified the data
with current manufacture product
literature. DOE selected several fans
from the AMCA sales database from
each manufacturer and equipment class
and verified that those fans are currently
available with the same performance
data. DOE specifically checked that the
model, diameter, operating pressure,
airflow, and brake horsepower (‘‘bhp’’)
aligned between the AMCA sales
database and current product literature.
DOE was able to verify a majority of the
fans selected from each manufacturer
and equipment class. Additionally, DOE
obtained recent performance and sales
data from confidential manufacturer
interviews and determined that the data
were consistent with the data in the
AMCA sales database; therefore, DOE
has tentatively concluded that the
AMCA sales database that it uses in its
engineering analysis for this NOPR is
representative of the current market.
DOE notes that it made some updates
to the AMCA sales database to ensure
consistency with the proposed scope
and equipment classes for PRVs. The
AMCA sales database grouped all
centrifugal PRVs together; however, as
discussed in section IV.A.1.a, DOE has
separated centrifugal PRVs by whether
they are supply or exhaust (ducted or
non-ducted). To separately analyze the
two classes, DOE manually
recategorized the centrifugal PRVs as
either supply or exhaust fans using the
manufacturer and model provided in
the AMCA sales database for most fans
52 Detail on AMCA’s Certified Ratings Program
can be found at www.amca.org/certify/#about-crp
(last accessed September 2022).
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to identify from manufacturer literature
which centrifugal PRVs were supply
and which were exhaust. Centrifugal
PRVs that could not be identified by
their model name were left categorized
as exhaust for the analysis since, based
on data collected during confidential
manufacturer interviews, DOE believes
that there are more centrifugal PRV
exhaust fan product lines and models
than centrifugal PRV supply fans.
Additionally, DOE determined that
the AMCA sales database included
many radial fans that are considered out
of scope in the DOE test procedure. 10
CFR 431.174((a)2)(i). As discussed in
section III.B.1, radial fans that are
unshrouded and have an impeller
diameter less than 30 in. or a blade
width of less than 3 in. are excluded
from the scope of the DOE test
procedure. DOE identified these radial
fans by looking up each model in
manufacturer product literature to
determine whether it contained a
shrouded impeller. Some fans in the
database could not be identified by
model, or the impeller characteristics
could not be determined from their
catalogs. DOE opted to include these
fans in the database for analysis because
including them likely results in a more
conservative estimate of FEI since DOE
has found that unshrouded impellers
typically have lower FEI.
DOE acknowledges that there are
limitations to the data provided in the
AMCA sales database. For example,
factors such as drive type, motor
horsepower, and the presence of motor
controllers were not specified in the
AMCA sales database, unless indicated
by the model number. Additionally,
DOE estimates that AMCA members
make up 60 percent of fan
manufacturers. DOE understands that
the AMCA sales database includes only
a portion of the sales data from AMCA
members; however, given the range in
equipment classes, FEIs, and costs in
the AMCA sales database, DOE believes
that the data are representative of the
U.S. GFB market. Furthermore, to
supplement the data from the AMCA
sales database, DOE also pulled
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performance data from online fan
manufacturer selection software. DOE
notes that it did not select
representative units, such as a particular
fan model, to conduct its analysis since
fan performance relies on fan diameter
and operating point. Instead, DOE
identified between three and ten
representative diameters and operating
points for each equipment class in the
AMCA sales database and pulled
additional performance data for these
operating points from manufacturer fan
selection software. Each representative
operating point was defined by
equipment class, diameter, operating
pressure, and airflow. DOE analyzed
data points from multiple fan models
and manufacturers for each
representative diameter and operating
point representing a variety of fan
designs and efficiencies. Using the data
from manufacturer fan selection
software, DOE was able to identify the
drive type, motor horsepower, and
whether or not motor controllers were
present for each evaluated fan.
More detail on the databases DOE
used in its analyses can be found in
chapter 5 of the NOPR TSD.
b. Air Circulating Fans
During manufacturer interviews
conducted prior to the October 2022
NODA, manufacturers recommended
that DOE use ACF data from a publicly
available database provided by the
Bioenvironmental and Structural
Systems Laboratory associated with the
University of Illinois-Champaign
(‘‘BESS Labs database’’).53 Based on this
feedback, DOE conducted its October
2022 NODA analyses using data from
the BESS Labs database and data
collected from ACF testing performed
by DOE at BESS Labs. DOE referred to
this collective database as the ‘‘BESS
Labs combined database’’ in the October
2022 NODA. DOE notes that, although
BESS Labs uses the test setups defined
in the 2012 edition of AMCA 230 for its
testing, BESS Labs does not apply
standard air density conversions to its
measurements, which are required by
the DOE test procedure. See section
2.2.2 of appendix B to subpart J to 10
CFR part 431. Therefore, in the October
2022 NODA, DOE applied conversion
formulas to the BESS Labs combined
database performance data to align the
airflow and input power calculations
with the DOE test procedure. Details on
53 BESS Labs is a research, product testing, and
educational laboratory. BESS Labs provides
engineering data to aid in the selection and design
of agricultural buildings and assists equipment
manufacturers in developing better products. Test
reports for ACFs are publicly available at
bess.illinois.edu/searchc.asp.
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these conversions can be found in
chapter 5 of the TSD.
As discussed in section III.B.2, all
ACFs with input power less than 125 W
are outside the proposed scope of this
rulemaking. Therefore, DOE removed all
ACFs with input powers less than 125
W from the BESS Labs combined
database prior to its analysis for this
NOPR.
In the October 2022 NODA, DOE
requested comment on whether the
BESS Labs combined database was
representative of the performance of the
entire ACF market. 87 FR 62038, 62045.
In response, AMCA commented that it
expects the fan efficiencies reported in
the BESS Labs database to be higher
than the typical efficiencies seen on the
market for ACFs. AMCA stated that this
is because the fans in the BESS Labs
database are typically agricultural fans,
and these fans are the subject of utility
rebates to encourage the production of
higher-efficiency fans. AMCA further
stated that it is unlikely performance
data for a fan was voluntarily added to
the public BESS Labs database unless
the fan was eligible for these utility
rebates. (AMCA, No. 132 at p. 4–5)
Greenheck also commented that the
ACF efficiencies in the BESS Labs
database would generally be higher than
typical ACFs on the market because of
their participation in rebate efficiency
incentive programs, and Greenheck
suggested that DOE utilize more data
sources than just the BESS Labs
combined database. (Greenheck, No. 122
at p. 2)
In the October 2022 NODA, DOE also
requested information on ACF
performance data. 87 FR 62038, 62045.
In response, AMCA commented that
ACF catalog data is publicly available.
However, AMCA also stated that it
believes that public performance data
for fans not listed in the BESS Labs
database was likely either not collected
using the most recent version of AMCA
230 or not collected using any version
of AMCA 230 at all. AMCA further
commented that testing of ACFs at an
AMCA-accredited facility yielded
performance data that was inconsistent
with the performance data published in
catalogs for certain tested fans, and
because of this, AMCA cautioned DOE
on the use of catalog data that has not
been certified by a third party. (AMCA,
No. 132 at p. 5–6) Similarly, Greenheck
recommended that DOE only use ACF
data that has been certified by an
independent performance certification
program to ensure that the data are
accurate. (Greenheck, No. 122 at p. 2) In
the October 2022 NODA, DOE discussed
a comment from AMCA stating that ACF
product literature may advertise
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performance calculated using outdated
versions of AMCA 230 and that all
versions aside from AMCA 230–15 had
at least one error pertaining to the
calculations of thrust, airflow, or input
power. 87 FR 62038, 62043–62044. A
table summarizing these errors can be
found in the October 2022 NODA. Id.
In the October 2022 NODA, DOE also
requested comment on whether the fan
affinity laws could be used to
extrapolate ACF performance data to
smaller and larger diameters to increase
the size of its ACF dataset. 87 FR 62038,
62045. In response, NEEA stated that
since the fan affinity laws assume that
efficiency remains constant, utilizing
them for determining efficiency gains
would be incorrect. Instead, NEEA
recommended that DOE obtain data on
smaller- and larger-diameter ACFs by
either testing additional smaller- and
larger-diameter ACFs or by using
empirical relationships to extrapolate
data to smaller and larger diameters.
(NEEA, No. 129 at p. 3–4) AMCA stated
that the fan affinity laws require
knowledge of the impeller shaft power,
which is often not measured for ACFs.
AMCA added that electrical input
power, which is often measured for
ACFs, cannot be scaled to obtain
reasonable estimates. (AMCA, No. 132
at p. 6) In response to this feedback,
DOE did not utilize the fan affinity laws
to extrapolate fan performance data to
different diameters and instead
included catalog data in its dataset for
this NOPR.
DOE acknowledges that the BESS
Labs combined database likely contains
higher efficiency fans than the overall
ACF market, since many agricultural
incentive programs require that fans be
tested at BESS Labs and meet certain
performance requirements.
Additionally, DOE notes that the BESS
Labs combined database contains data
on axial ACFs only. Therefore, to
supplement the BESS Labs combined
database and gain additional
information representative of the ACF
market, DOE collected ACF catalog data
from manufacturer and distributor
websites. DOE did not consider catalog
data in the October 2022 NODA because
catalog data did not include information
on the air density measured during
testing, which is required to calculate
FEI. Since DOE updated the ACF metric
to be efficacy instead of FEI, DOE was
able to use catalog data for this NOPR.
In response to AMCA and Greenheck’s
concerns about the accuracy of catalog
data that have not been certified by a
third party, DOE notes that, while the
catalog data it collected is not certified
by a third party, there were no ACFs
listed in AMCA’s certified product
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database at the time of DOE’s market
review,54 and DOE is not aware of any
other certification programs for ACFs.
In response to AMCA’s concerns
about manufacturers’ use of outdated
and inaccurate versions of AMCA 230 to
generate catalog data, DOE applied a
correction factor to some catalog data.
DOE is aware that many ACF
manufacturers may use an outdated
version of AMCA 230 and that the
calculation methods used in these older
versions do not align with AMCA 230–
15 or with AMCA 230–23, which is
referenced by the DOE test procedure.
See section 2.2.2 of appendix B to
subpart J of 10 CFR part 431. In DOE’s
review of the ACF market and product
literature, it observed that the 1999
edition of AMCA 230 (‘‘AMCA 230–99’’)
was the most common test method
manufacturers cited in their product
literature for measurement of ACF
performance data, while a small number
of manufacturers cited AMCA 230–15.
DOE did not find any other methods
that manufacturers cited for measuring
ACF performance. Therefore, for all
manufacturers that did not explicitly
state in their product literature that they
collected their ACF performance data
using AMCA 230–15, DOE applied a
correction factor to the catalog data to
account for differences in the
calculation methods between AMCA
230–99 and the DOE test procedure.
DOE acknowledges that this approach
may result in lower efficacy values for
ACFs where a correction factor was
already applied; however, DOE notes
that it lacks other sources of ACF
performance data aside from the BESS
Labs combined database and this catalog
data. DOE combined the corrected
catalog data and the BESS Labs data,
herein referred to as the ‘‘updated ACF
database,’’ and used this database for its
analysis of ACFs in this NOPR.
DOE also removed outliers from the
dataset using a box plot approach. For
axial ACF catalog data, DOE removed
extremely high-efficacy outliers and did
not identify any extremely low-efficacy
outliers. For axial ACFs from the BESS
Labs combined database, DOE only
removed extremely high-efficacy
outliers because ACFs in the BESS Labs
combined database are generally
expected to have higher efficacies than
the overall ACF market. DOE did not
remove outliers for housed centrifugal
ACFs.
54 AMCA’s certified product database for ACFs
can be found at www.amca.org/certify/certifiedproduct-search/product-type/air-circulatingfan.html (last accessed 4/10/23).
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3. Technology Options
In the February 2022 RFI, DOE
identified five technology options that
would be expected to improve the
efficiency of ACFs, as expected to be
measured by a future DOE test
procedure. These technology options
were improved aerodynamic design,
blade shape, more efficient motors,
material selection, and variable-speed
drives (‘‘VSDs’’). 87 FR 7048, 7052. In
the October 2022 NODA, DOE focused
its analyses on aerodynamic redesign
and more efficient motors. 87 FR 62038,
62042. In response to the October 2022
NODA, the CA IOUs suggested that DOE
investigate individual components of
improved aerodynamic design so that
incremental efficiency levels could be
evaluated in the engineering analysis.
(CA IOUs, No. 127 at p. 2) DOE has
since identified several additional
technology options that would be
expected to improve the efficiency of
GFBs and ACFs, including options that
are components of aerodynamic design.
The technology options that DOE
considered for this NOPR are:
• Improved housing design;
• Reduced manufacturing tolerances;
• Addition of guide vanes;
• Addition of appurtenances;
• Improved impeller design;
• Impeller topology;
• Increased impeller diameter;
• Impeller material;
• More efficient transmissions;
• More efficient motors; and
• Motor controllers.
DOE notes that not every technology
option listed above will be analyzed for
each equipment class in this NOPR. For
example, DOE did not analyze increased
impeller diameter for ACFs because
impeller diameter is used to separate
ACF equipment classes (see section
IV.A.1.b). The following discussion
provides a brief overview of the
technology options under consideration
and addresses stakeholder comments
that DOE has received on the October
2022 NODA.
Improved housing design includes
any changes to the enclosure of a fan,
such as modifying the volute 55 for
centrifugal fans or reducing the bladeto-housing clearance for axial fans. In
response to the October 2022 NODA, the
CA IOUs stated that a fan’s blade-tohousing clearance determines its static
pressure capabilities and efficiency, and
fans with larger clearances generally
have lower efficiency. They also stated
that the use of a wall ring can improve
the efficiency of an ACF. (CA IOUs, No.
127 at pp. 2–3) DOE has considered the
55 A volute is a spiral or scroll-shaped housing
used with centrifugal fans.
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addition of a wall ring under the
‘‘improved housing design’’ technology
option. Additionally, DOE considered
the effects of reduced running
clearances as a component of the
‘‘reduced manufacturing tolerances’’
technology option. During manufacturer
interviews, manufacturers stated that
reducing the manufacturing tolerances
for fan components can increase
efficiency. Therefore, DOE considered
reduced manufacturing tolerances as a
technology option for this NOPR.
The addition of guide vanes reduces
pressure loss by directing and
smoothing airflow as it exits a fan. DOE
observed in its market research that the
integration of guide vanes into the outlet
of a fan can improve efficiency by over
10 percent. For example, DOE observed
that vane axial fans can achieve up to
20-percent higher FEIs than similarly
sized tube axial fans. Appurtenances are
similar to guide vanes but are not
integral to the fan—rather,
appurtenances can be added to change
the performance of a fan and fans may
be sold with different appurtenances to
provide the end user with the desired
effect. In the October 2022 NODA, DOE
summarized a comment from ebm-papst
stating that the use of outlet guide vanes
or appurtenances, such as inlet cones on
housings or winglets on impellers,
could improve the fan efficiency. 87 FR
62038, 62042. DOE recognizes that the
addition of appurtenances described by
ebm-papst has the potential to increase
fan efficiency. Therefore, DOE
considered the addition of guide vanes
and appurtenances as technology
options in this NOPR.
Regarding impeller design, DOE
considered any aerodynamic
improvement of an impeller that does
not include a change to its topology
under the impeller design technology
option. This includes modifications,
such as incorporating beneficial ridges
into the blade surface as well as
improving impeller blade surface
quality. DOE observed the presence of
these modifications to blade design
during teardowns of GFBs and ACFs.
Therefore, DOE considered improved
impeller design as a technology option
in this NOPR.
Regarding fan impeller topology, DOE
considered changes in the orientation or
basic shape of the blades, such as
switching from a backward-curved
blade to an airfoil blade. In the October
2022 NODA, DOE summarized a
comment from the Joint Commenters
encouraging DOE to evaluate more
efficient blade designs as a technology
option because of their energy savings
potential. The Joint Commenters added
that the use of advanced blade designs,
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such as airfoil blades, can improve the
efficiency of a fan relative to traditional
single-thickness blades. 87 FR 62038,
62042. In addition, DOE received
comment from the CA IOUs in response
to the October 2022 NODA stating that
impeller blades may have either a
‘‘true’’ or ‘‘progressive’’ pitch, and that
the pitch of the blades will affect
efficiency. (CA IOUs, No. 127 at p. 2)
DOE’s research and feedback received
during manufacturer interviews also
indicated that certain impeller
topologies can be more efficient than
others. Therefore, DOE considered
impeller topology as a technology
option.
In response to the October 2022
NODA, AHAM commented that DOE’s
use of general blade design as a
technology option for ACFs did not
factor in specific differences in
application of different blade shapes
between unique fan configurations,
including ACFs with horizontal axes,
ACFs with vertical axes, or bladeless
ACFs. AHAM added that DOE has not
tested these different fan configurations.
(AHAM, No. 123 at p. 8) DOE notes that
the DOE test procedure specifies testing
ACFs only in a horizontal configuration.
DOE also notes that bladeless fans are
excluded from the proposed scope for
ACFs, as discussed in section III.B.2 of
this document. Therefore, DOE did not
consider differences in axis orientation
or bladeless fans in its evaluation of
ACF impeller topology or improved
impeller design.
DOE received feedback during
confidential GFB manufacturer
interviews that increasing the diameter
of a fan impeller can improve the
efficiency of a fan. Additionally, when
comparing fans on the market with
different diameters and otherwise
similar characteristics, DOE observed
that fans with larger diameters were
typically more efficient for certain
equipment classes; therefore, DOE
considered increased impeller diameter
as a technology option in this NOPR.
When reviewing available data from
the market, its databases, and
information received during
confidential manufacturer interviews,
DOE could not distinguish between the
effects of improved housing design,
reduced manufacturing tolerances,
addition of appurtenances, and
improved impeller design on the
performance of GFBs; therefore, DOE
has grouped these technology options
together and collectively refers to them
as ‘‘aerodynamic redesign’’ for GFBs in
the remainder of this document. For
ACFs, DOE additionally lacked
quantitative efficiency data regarding
specific impeller topologies and the
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addition of guide vanes, and therefore
grouped the addition of guide vanes as
well as any blade adjustments that
improve the efficiency of ACFs, such as
the curvature or pitch, along with
improved housing design, reduced
manufacturing tolerances, addition of
appurtenances, and improved impeller
design under the umbrella of
aerodynamic redesign for ACFs in the
remainder of this document. The
technology options considered under
aerodynamic redesign for both GFBs
and ACFs are summarized in Table IV–
7.
DOE previously considered ‘‘material
selection’’ in general as a technology
option in the February 2022 RFI. 87 FR
7048, 7052. For this NOPR, DOE is
clarifying that material selection is
specific to impeller materials. DOE did
not receive comments from stakeholders
pertaining to material selection for
either the February 2022 RFI or the
October 2022 NODA; however, during
confidential interviews, manufacturers
stated that minimal efficiency gains
would be achieved by changing the
blade material. When reviewing
manufacturer fan selection software
data, DOE identified similar fans with
different blade materials and
investigated the impact of different
materials on FEI. Consistent with
manufacturer feedback, DOE found that
material selection of the impeller had
minimal or no impact on efficiency for
either GFBs or ACFs. Therefore, DOE
did not consider material selection as a
technology option in this NOPR.
With regard to transmissions, DOE
notes that the DOE test procedure
includes a loss factor associated with
belt-drive transmissions, while directdrive transmissions are treated as
having no loss when calculating
efficiency. This indicates that replacing
a belt-drive with a direct-drive
transmission can improve efficiency.
For ACFs, DOE considered the change
from belt-drive to direct-drive as a
technology option. For GFBs, as
discussed in section IV.A.1.a, DOE is
proposing to establish separate
equipment classes for GFBs sold with or
without motor controllers to account for
the added utility provided by GFBs with
motor controllers (i.e., variable-speed
operation to allow a fan to adapt to
changing load requirements). Belt-drive
transmissions can be manually adjusted
during installation to achieve all airflow
and pressure operating requirements in
a fan’s operating range for different field
applications, whereas direct-drive fans
would only be able to achieve all
operating points within the fan’s
operating range if paired with a motor
controller. As a result, DOE did not
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consider the shift from belt-drive to
direct-drive transmission as a
technology option for GFBs to maintain
the added utility provided by belt-drive
transmission.
Regarding motors, motor efficiency
can depend on motor topology as well
as the individual design features of a
single motor topology. For example,
most motors used in ACFs are
permanent split capacitor (‘‘PSC’’)
motors, and these motors have a wide
range of operating efficiencies. In
addition, some ACFs use electronically
commutated motors (‘‘ECMs’’). ECMs
operate in a higher efficiency range than
PSC motors, so using an ECM may
improve the overall efficiency of an
ACF. In this NOPR, DOE considers both
switching to a more efficient motor
topology and improved efficiency of a
single motor topology in the more
efficient motors technology option.
For GFBs, DOE learned from
confidential manufacturer interviews
that motors are not always sold as
integral parts of a fan. Many sales of
GFBs do not include a motor and
require the customer to provide this
part. Furthermore, the motors used for
GFBs are nearly all 3-phase induction
motors currently regulated by DOE,
including motors between 100 and 150
hp. See 10 CFR 431.25. On June 1, 2023,
DOE published an energy efficiency
standards direct final rule for these
electric motors. 88 FR 36066. In this
rule, DOE increased the minimum
required efficiency of induction motors
between 100 and 250 hp from IE 3 to IE
4. 88 FR 36066, 36144. IE 3 and IE 4
motor efficiencies are defined in IEC
60034–30–1:2014: ‘‘Rotating Electrical
Machines—Part 30–1: Efficiency classes
of line operated AC motors (IE code),’’
(‘‘IEC 60034–30–1:2014’’) published by
the International Electrotechnical
Commission. The compliance date of
this rule is June 1, 2027 and any
standards promulgated as a result of this
fans rulemaking would take effect after
that date.
Because of the new 2027 electric
motor standards, there will be impacts
on the motor market from a product
availability, size, and technology
standpoint as the efficiency moves from
IE 3 to IE 4. These changes would need
to be considered in this rulemaking, but
electric motor manufacturers are still in
the design and planning process to
migrate their product offerings to be in
compliance with the 2027 electric
motors standards recently adopted. If
DOE were closer to the 2027 compliance
date or this was a first-time regulation
for these induction motors, DOE would
be able to better understand how
manufacturers were going to fully
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
respond and the innovations that may
be introduced into the market to be able
to carefully consider how the motors
offerings could be considered as part of
the CIFB designs affecting the fan
efficiencies. At this time, DOE does not
have sufficient data to fully evaluate the
impact of those efficiency and
technology changes on the proposed
efficiency levels (‘‘ELs’’). DOE has
therefore not evaluated more efficient
motors as a technology option for GFBs
in this NOPR; however, DOE may
consider more efficient motors as a
viable technology option for improving
GFB efficiency in a future rulemaking.
DOE evaluated more efficient motors
for ACFs in the October 2022 NODA. 87
FR 62038, 62042. DOE also assumed
that all ACFs are sold with a motor. Id.
Furthermore, DOE requested comment
on its estimated base manufacturer
production cost for ACFs excluding
motors. 87 FR 62038, 62053. In
response, AMCA commented that, to the
best of its knowledge, ACFs are always
sold with motors. (AMCA, No. 132 at p.
12) In this NOPR, DOE therefore
continued with its assumption that all
ACFs are sold with motors.
In the October 2022 NODA, DOE
assumed that most motors paired with
ACFs are lower efficiency induction
motors that were not regulated by DOE
and requested comment on that
assumption. 87 FR 62038, 62042. DOE
also requested data on the percentage of
ACFs sold with split-phase, PSC,
shaded-pole and ECMs. 87 FR 62038,
62049. In response, AMCA commented
that some of its members sell ACFs with
shaded-pole motors, PSC motors,
polyphase motors, or ECMs. (AMCA,
No. 132 at p. 3) NEMA commented that,
depending on the horsepower
requirements, a split-phase, shadedpole, capacitor start/capacitor run, or
three-phase motor could be used for
ACFs. NEMA added that shaded-pole
motors are often used at 0.1 hp and
under for ACFs, while PSC motors are
very common for 1 hp and under.
(NEMA, No. 125 at p. 3) In response to
this feedback, DOE conducted a review
of its updated ACF database (discussed
further in section IV.A.2.b) and
identified ACFs sold with multiple
different motor topologies, including
PSC, polyphase, and EC motors.
Additionally, DOE identified many
ACFs using PSC motors at high and low
motor efficiencies. Because DOE has
identified that ACF motor efficiency
may be improved through changing
motor topology as well as improving
efficiency within a single motor
topology, it considered both switching
to a more efficient motor topology and
improving efficiency within a single
motor topology as components of the
more efficient motors technology option
for ACFs.
Regarding motor controllers, motor
controllers are used to change the
operating point of fans by altering their
motor speed. This allows a fan to
operate at a lower speed when possible,
which can result in a reduction of
power consumption. In response to the
October 2022 NODA, the Efficiency
Advocates encouraged DOE to evaluate
fans that operate at multiple speeds,
rather than just the highest speed,
because lowering the fan speed can
significantly reduce the amount of
power used by a fan. (Efficiency
Advocates, No. 126 at p. 2–3)
Conversely, AMCA stated that the
utility of ACFs to provide the necessary
air-throw distance and air velocity may
be diminished or removed entirely by
reducing the fan speed with motor
controllers, which is a negative impact
on product utility. (AMCA, No. 132 at
p. 3) While DOE acknowledges that fan
power consumption can be reduced by
3761
lowering the speed of a fan, it notes that
the DOE test procedure for ACFs
specifies testing and reporting efficacy
for ACFs at the maximum speed of the
fan. See appendix B to subpart J of 10
CFR part 431, section 2.2.1. DOE’s
analysis in this NOPR remains
consistent with the DOE test procedure
for ACFs, so DOE did not evaluate
efficiencies at less than maximum
speed. Therefore, DOE did not consider
motor controllers as a technology option
for ACFs in this NOPR.
In response to the October 2022
NODA, the CA IOUs commented that
choosing a low-speed range for a
particular impeller improves its
efficiency. (CA IOUs, No. 127 at p. 2)
DOE notes the speed and operating
point of a fan are strongly related and
that any change to the speed of a fan
will likely change the utility of that fan.
Therefore, DOE did not consider
reduced speed as a technology option
for this NOPR.
As discussed in section IV.A.1.a,
GFBs with motor controllers allow a fan
to adapt to changing load requirements.
While this may result in energy savings
during application, the DOE test
procedure for fans does not account for
these possible changes in operation and
energy savings. As a result, DOE is
proposing to establish separate
equipment classes for GFBs sold with
and without motor controllers and is not
considering motor controllers as a
technology option.
Table IV–7 lists the technology
options for GFBs and ACFs that DOE
evaluated in its screening analysis. Both
GFBs and ACFs include an aerodynamic
redesign technology option, which
contains technology options that DOE
determined to be viable, but for which
DOE lacked sufficient data to fully
analyze individually.
Table IV-7 Technolo!!:v Options Evaluated in this NOPR
•
•
•
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ACFs
Aerodynamic redesign
0
improved housing design
0
reduced manufacturing tolerances
0
addition of appurtenances
0
improved impeller design
0
addition of guide vanes
0
impeller topology
Increased impeller diameter
More efficient transmissions
More efficient motors
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GFBs
Aerodynamic redesign
0
improved housing design
0
reduced manufacturing tolerances
0
addition of appurtenances
0
improved impeller design
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Impeller topology
Increased impeller diameter
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Further details on technology options
that DOE considered for this NOPR can
be found in chapter 3 of the NOPR TSD.
B. 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.
Technologies that are not incorporated
in industrial equipment or in
commercially viable, existing prototypes
will not be considered further.
(2) Practicability to manufacture,
install, and service. If it is determined
that mass production of a technology in
industrial equipment and reliable
installation and servicing of the
technology could not be achieved on the
scale necessary to serve the relevant
market at the time of the projected
compliance date of the standard, then
that technology will not be considered
further.
(3) Impacts on product utility. If a
technology is determined to have a
significant adverse impact on the utility
of the equipment to subgroups of
consumers, or results in the
unavailability of any covered equipment
type with performance characteristics
(including reliability), features, sizes,
capacities, and volumes that are
substantially the same as products
generally available in the United States
at the time, it will not be considered
further.
(4) Safety of technologies. If it is
determined that a technology would
have significant adverse impacts on
health or safety, it will not be
considered further.
(5) Unique-pathway proprietary
technologies. If a technology has
proprietary protection and represents a
unique pathway to achieving a given
efficiency level, it will not be
considered further, due to the potential
for monopolistic concerns.
10 CFR 431.4; 10 CFR part 430,
subpart C, appendix A, sections 6(c)(3)
and 7(b).
In summary, 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.
Through a review of each technology,
DOE tentatively concludes that the
technologies listed in Table IV–7 of this
document met all five screening criteria
to be examined further as design options
in DOE’s NOPR analysis. Comments
DOE received regarding screening for
these technologies are discussed below.
In response to the October 2022
NODA, DOE received several comments
pertaining to how the screening criteria
apply to aerodynamic redesign, blade
shape, and motors. AMCA stated that
aerodynamic efficiency improvements
can often lead to an increase in the cost
and complexity of manufacturing,
which can have an adverse impact on
the practicability of manufacturing.
AMCA added that some ACF
components that can be adjusted to
improve efficiency are patentable,
including impellers, impeller blades,
impeller rings, housings, outlet
appurtenances, and motors, which
relates to the screening criteria for
unique-pathway proprietary
technologies. (AMCA, No. 132 at p. 3).
AMCA also commented that the
removal of a safety guard on an ACF to
increase its efficiency would decrease
the safety of an ACF, which is an
adverse impact on health or safety. Id.
Regarding AMCA’s comment on the
potential for increased cost or
complexity of manufacturing associated
with an aerodynamic redesign, DOE
notes that it accounted for this increased
cost and complexity through conversion
costs, which are discussed in section
IV.J. Regarding patentable technologies,
DOE notes that in manufacturer
interviews, it specifically asked about
whether patentable technologies could
pose a problem in meeting energy
conservation standards. In response, no
GFB or ACF manufacturers expressed
concerns regarding patents. Therefore,
DOE has tentatively concluded that
none of the proposed design options
meet the unique pathway-proprietary
technologies screening criteria.
In terms of safety guards, DOE agrees
that the removal of a safety guard would
compromise the safety of a fan.
DOE notes that the motor efficiency
technology options are based on general
industry standards rather than specific
motor designs that could be patented;
therefore, DOE has tentatively
concluded that the unique-pathway
proprietary technologies screening
criterion does not apply to the moreefficient motor technology option.
DOE did not receive comment related
to screening for any other technology
options. The remaining technology
options that DOE did not screen from its
analysis are listed in Table IV–8.
Table IV-8 Remainine Technoloe:v Options for GFBs and ACFs
•
•
•
DOE has initially determined that
these technology options are
technologically feasible because they are
being used or have previously been used
in commercially available equipment or
working prototypes. DOE also finds that
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ACFs
Aerodynamic redesign
0
improved housing design
0
reduced manufacturing tolerances
0
addition of appurtenances
0
improved impeller design
0
addition of guide vanes
0
impeller topology
Increased impeller diameter
More efficient motors
More efficient transmissions
all of the remaining technology options
meet the other screening criteria (i.e.,
practicable to manufacture, install, and
service and do not result in adverse
impacts on consumer utility, product
availability, health, or safety, unique-
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pathway proprietary technologies). For
additional details, see chapter 4 of the
NOPR TSD.
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GFBs
Aerodynamic redesign
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tolerances
0
addition of appurtenances
0
improved impeller design
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
C. Engineering Analysis
The purpose of the engineering
analysis is to establish the relationship
between the efficiency and cost of fans
and blowers. There are two elements to
consider in the engineering analysis; the
selection of efficiency levels to analyze
(i.e., the ‘‘efficiency analysis’’) and the
determination of equipment cost at each
efficiency level (i.e., the ‘‘cost
analysis’’). In determining the
performance of higher-efficiency
equipment, DOE considers technologies
and design option combinations not
eliminated by the screening analysis.
For each equipment class, DOE
estimates the baseline cost, as well as
the incremental cost for the equipment
at efficiency levels above the baseline.
The output of the engineering analysis
is a set of cost-efficiency ‘‘curves’’ that
are used in downstream analyses (i.e.,
the LCC and PBP analyses and the NIA).
ddrumheller on DSK120RN23PROD with PROPOSALS2
1. General Fans and Blowers
a. Baseline Efficiency
For each equipment class, DOE
generally selects a baseline model as a
reference point for each class, and
measures changes resulting from
potential energy conservation standards
against the baseline. The baseline model
in each equipment class represents the
typical characteristics of that class (e.g.,
capacity, physical size). Generally, a
baseline model is one that just meets
current energy conservation standards,
or, if no standards are in place, the
baseline is typically the most common
or least efficient unit on the market.
As discussed in section II.B.1, there
are currently no energy conservation
standards for GFBs. In this analysis,
DOE set the baseline efficiency as the
lowest reasonable efficiency on the
market after removing potential outliers
for each analyzed equipment class.
DOE established baseline ELs using
performance data in the AMCA sales
database. DOE filtered the database by
equipment class and evaluated the fan
performance range for each equipment
class. Additionally, as described in
section IV.A.3, DOE based its GFB
analysis on design options that
specifically improve fan performance.
DOE did not consider improvements to
the motor, transmission, or motor
controllers. Therefore, for this analysis,
DOE calculated FEI according to the
bare shaft method described in the DOE
Test Procedure. See sections 2.2 and 2.6
of appendix A to subpart J of 10 CFR
part 431. For both the AMCA sales
database and any manufacturer fan
selection software data, DOE
recalculated FEI on a bare shaft basis.
Accordingly, the standards proposed in
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this notice are based only on fan design
and exclude any impact that the motor,
transmission, or motor controllers may
have on fan efficiency.
Based on a review of the market, DOE
tentatively determined that the FEI
values corresponding to the 5th
percentile in the AMCA sales database
were generally representative of
baseline efficiency across all diameters
and duty points within a given
equipment class. Defining baseline
efficiency at the 5th percentile enabled
DOE to remove potential outlier fans
and fans that may no longer exist on the
market. DOE compared the 5th
percentile for each equipment class to
data retrieved from manufacturer fan
selection software to ensure that
baseline efficiencies were representative
of the current market. In instances
where the 5th percentile removed a
substantial number of models that had
FEI values consistent with what was
seen on the market, DOE adjusted the
baseline efficiency to align with the
distribution of FEIs observed in the
manufacturer fan selection software.
Additional details on the development
of baseline efficiency levels for each
equipment class are included in chapter
5 of the NOPR TSD.
b. Selection of Efficiency Levels
DOE typically uses one of two
approaches to develop energy efficiency
levels for the engineering analysis: (1)
relying on observed efficiency levels in
the market (i.e., the efficiency-level
approach), or (2) determining the
incremental efficiency improvements
associated with incorporating specific
design options to a baseline model (i.e.,
the design-option approach). Using the
efficiency-level approach, the efficiency
levels established for the analysis are
determined based on the market
distribution of existing equipment (in
other words, based on the range of
efficiencies and efficiency level
‘‘clusters’’ that already exist on the
market). Using the design option
approach, the efficiency levels
established for 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.
DOE may also rely on a combination of
these two approaches. For example, the
efficiency-level approach (based on
actual equipment on the market) may be
extended using the design option
approach to ‘‘gap fill’’ levels (to bridge
large gaps between other identified
efficiency levels) and/or to extrapolate
to the max-tech level (particularly in
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3763
cases where the max-tech level exceeds
the maximum efficiency level currently
available on the market).
In this NOPR, DOE relied on a
combination of the efficiency level and
design-option approaches. DOE used the
efficiency level approach to determine
the baseline, max-tech, and
aerodynamic redesign efficiency levels
and used the design-option approach to
gap fill intermediate efficiency levels.
General Approach
DOE applied design options to the
initial efficiency levels evaluated above
baseline for each equipment class. As
discussed in section IV.A.3, DOE has
identified the following design options
for GFBs:
• Impeller topology;
• Addition of guide vanes;
• Increased impeller diameter; and
• Aerodynamic redesign (improved
housing design, reduced manufacturing
tolerances, addition of appurtenances,
improved impeller design).
For each equipment class, DOE
evaluated both the AMCA sales database
as a whole and data from manufacturer
fan selection software for specific
representative diameters and operating
points to set the efficiency levels and
associated design options for its
analysis. DOE used data pulled from
manufacturer fan selection software to
understand the incremental impact of
design options on fan performance and
cost. DOE then applied these
incremental FEI increases to the
baseline fan for each equipment class to
set intermediate efficiency levels.
To estimate the incremental increases
in FEI, DOE first selected between three
and six representative operating points
based on the fan diameters, operating
pressures, and airflows that were most
common for each equipment class in the
AMCA sales database, as discussed in
section IV.A.2.a. DOE then used
manufacturer fan selection software to
obtain data for each representative
operating point at a specific diameter,
airflow, and pressure. From the
manufacturer fan selection software,
DOE evaluated how FEI changed as
various design options were applied
while holding constant the diameter (for
all equipment classes except PRVs) and
duty point. DOE calculated bare shaft
FEI for fans evaluated using
manufacturer fan selection software to
eliminate the effects of transmission on
the efficiency. Additional details on
how manufacturer fan selection
software was evaluated and used in the
development of intermediate efficiency
levels are included in chapter 5 of the
NOPR TSD.
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
DOE recognizes that relying on data
from fans at representative diameters
and operating points to characterize
efficiency improvements may not
sufficiently account for the entire range
of duty points and diameters typical for
each equipment class. Therefore, after
determining the impact of potential
design options on fan efficiency using
the manufacturer fan selection software,
DOE used the AMCA sales database to
validate the estimated incremental FEI
increases for each design option. In its
review of the market, DOE found that
most manufacturer model numbers
correspond to a specific impeller type
and design. To make comparisons
between fan models in the AMCA sales
database, DOE used the model numbers
included in the AMCA sales database to
characterize each fan’s impeller. DOE
then evaluated the potential efficiency
gain of each design option across the
entire range of operating points in the
AMCA sales database. For example, for
centrifugal housed fans, DOE calculated
the average increase in FEI that would
be observed for a fan with a backwardinclined impeller at a given diameter
compared to a fan with a forwardcurved impeller at the same diameter.
DOE evaluated the AMCA sales
database in this way to confirm that its
estimated increases in FEI seemed
feasible across the range of operating
duty points, since the AMCA sales
database contains data points at a
variety of duty points for each
equipment class.
In response to the July 2022 TP
NOPR, AHRI commented that fan
performance in the AMCA sales
database was never confirmed to be
reflective of embedded fans, including
system effect, and that finalizing the
determination using the analysis
conducted to date, especially if
embedded fans are within the scope,
would be inappropriate. (Docket No.
EERE–2021–BT–TP–0021, AHRI, No. 40
at p. 13) DOE notes that, as discussed in
III.B.1, embedded fans listed in Table
III–1 are outside the scope of this
analysis. All other fans within the scope
of this rulemaking would be tested in
accordance with the DOE test
procedure, which reflects performance
of fans outside of equipment into which
they may be installed and does not
evaluate system effects.
Additionally, in response to the
October 2022 NODA, Morrison
suggested that the data evaluation and
analysis conducted in the 2016 NODA
should be restarted to address current
stakeholder concerns and account for
changes in the market environment,
including widespread adoption of
building codes and use of the FEI
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metric. (Morrison, No. 128 at p. 3) In
response to the July 2022 TP NOPR,
AHRI commented that it is not
reasonable to assume that substitutions
can be made for any fan within 20
percent of static pressure or airflow
requirements and within two inches of
the original diameter tolerances. AHRI
stated that selecting a fan that two
inches larger in diameter would
translate to a four-inch increase in
housing size. Additionally, AHRI
commented that commercial heating,
ventilation, and air conditioning
(‘‘HVAC’’) equipment fan selection
requires design to a specific airflow and
static pressure and that in virtually all
cases, a two-percent selection window
is required so the 20 percent selection
window would not satisfy the heating,
cooling or ventilation needs for the
application. (Docket No. EERE–2021–
BT–TP–0021, AHRI, No. 40 at p. 12–13)
Furthermore, AHRI commented that
variable air volume systems and systems
with economizers need to operate over
a range of airflow. Low static, high
airflow fans (forward-curved fans) are
used in these applications; therefore, the
number of fans that would require
redesign is closer to 100 percent than
the 30 percent included in the NODA 3
(2016 NODA) analysis. (Id.)
DOE notes that all analyses from the
2016 NODA have been reevaluated in
this NOPR to reflect current market
trends and industry standards. While
DOE maintained some structural
elements from the 2016 NODA, such as
some equipment classes and use of the
AMCA sales database, DOE updated its
efficiency levels and cost analyses based
on manufacturer feedback from recent
interviews, publicly available sales data,
and a thorough review of the current
market. Additionally, in this analysis,
DOE did not assume that static pressure
or airflow could vary by 20 percent or
that the diameter of embedded fans
could increase by any amount. In its
analysis for this NOPR, DOE evaluated
efficiency increases with operating
point and diameter remaining constant
for fan equipment classes that could be
embedded in equipment, which is
discussed in more detail in section
IV.C.1.b (subsection Determination of
Efficiency Levels). Additionally, DOE’s
analysis reflects that forward-curved
fans should be preserved in the market
and would likely be redesigned to do so.
In section IV.C.1.b (see subsection
Parallel Design Path for Forward-curved
Fans), DOE describes how it analyzed
forward-curved fans. DOE also
evaluated the potential impact of duty
point on whether a fan could be
redesigned to higher FEI levels. Using
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the AMCA sales database, DOE
developed FEI distributions for each
equipment class to evaluate how FEI
varied with specified design pressure,
airflow, and diameter. Based on these
FEI distributions, DOE was not able to
identify any duty point ranges with
disproportionately lower fan availability
at higher FEI values for any equipment
class. DOE has tentatively determined
that the efficiency relationships it
developed based on the selected
representative operating points could be
applied to fans at other diameters and
duty points; therefore, there is only one
set of efficiency levels for each
equipment class.
Determination of Efficiency Levels
The first design option that DOE
evaluated for most equipment classes
was changing the fan impeller. Based on
its review of the market, DOE
determined that manufacturers often
have a variety of impeller topologies
available for each fan class. For
example, some manufacturers have
economy impellers, which are less
efficient and less expensive than other
available impellers. DOE also found that
manufacturers may have impellers that
are designed to operate at different duty
points, such as high-pressure impellers.
These impellers achieve different levels
of performance based on blade shape,
blade pitch, number of blades, etc.
Therefore, rather than attempt to
characterize each of these individual
impellers and how they may impact FEI,
DOE evaluated manufacturer fan
selection software to estimate the
average increase in FEI for a typical
impeller change for each equipment
class and then used the AMCA sales
database to validate that these increases
are applicable to the broader fans
market. DOE notes that the centrifugal
housed equipment class is the only
equipment class for which specific
impeller changes were characterized.
This is because DOE was able to identify
distinct differences in efficiency
between forward-curved, backwardinclined or backward-curved,56 and
airfoil impellers for centrifugal housed
fans. The impeller change design
options were either applied to the
baseline fan or applied successively to
a previous impeller change.
56 In reviewing both the AMCA sales database and
manufacturer fan selection software, DOE was
unable to distinguish between backward-inclined
and backward-curved impellers for many fan
models. It is also DOE’s understanding that both
backward-inclined and backward-curved impellers
perform similarly regarding fan efficiency.
Therefore, DOE considered both backward-inclined
and backward-curved impellers together as a single
design option.
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DOE followed a similar method of
analyzing both the manufacturer fan
selection software and the AMCA sales
database to estimate the increase in FEI
that could be achieved for design
options other than impeller changes,
including substituting a tube axial fan
for a vane axial fan, substituting a mixed
flow fan for a centrifugal inline fan, and
increasing the PRV fans diameter.
Additional details on how DOE
estimated the incremental increases in
FEI for each design option and for each
equipment class are included in chapter
5 of the NOPR TSD.
For many categories of fans,
increasing the diameter of a fan could
increase efficiency when a fan operates
at the same duty point; however, during
manufacturer interviews, DOE received
feedback that increasing the diameter of
a fan is only applicable to certain fan
classes. Specifically, DOE learned that
increasing the diameter of a fan that
would be embedded in OEM equipment
could impact the overall performance of
the equipment, could impact its utility
for use in space-constrained OEM
equipment, and would substantially
increase OEM redesign costs.
Alternatively, for fan types that do not
have space-constraints, a fan could
typically be increased by one or two
sizes without impacting the utility of
the fan.
For fan equipment classes that could
be embedded, either into other
equipment or into spaced constrained
applications, such as ducted ventilation
systems, DOE did not consider
increased impeller diameter as a design
option. These types of fans include axial
inline, panel, centrifugal housed,
centrifugal unhoused, and centrifugal
inline fans.
For radial fans, DOE analyzed the
diameter increase design option since
this fan class is typically not used in
space-constrained applications;
However, DOE did not observe
consistent efficiency changes with
increased diameter for radial fans;
therefore, DOE did not consider larger
fan diameter as a design option for
radial fans.
In general, PRVs (axial PRV,
centrifugal PRV exhaust, and centrifugal
PRV supply) are not subject to the same
size and weight constraints experienced
by other embedded fan classes. These
units are placed in open air
environments to supply or exhaust air
from the top of a building, which
enables them to increase in size. DOE
found that increasing PRV diameter
consistently increases the efficiency;
therefore, DOE considered diameter
increase as a design option for axial and
centrifugal PRVs.
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DOE requests comment on its
understanding that the diameter
increase design option could be applied
to non-embedded, non-spaceconstrained equipment classes.
In its analysis for axial and centrifugal
PRVs, DOE used an 18-percent increase
in diameter to represent a diameter
increase and rounded the impeller
diameter to the nearest whole number,
since DOE found that the 18-percent
increase was representative of the fan
sizes available on the market. For
example, the increased diameter design
option for a 15-in. diameter fan would
increase the fan diameter to 18-in. and
a 36-in. diameter fan would increase to
a 42-in. diameter fan. When analyzing
its data sources, DOE found that this 18
percent diameter increase when
maintaining the operating point could
result in a range of FEI increases, from
as low as 4-percent to as high as 30percent, corresponding to a FEI increase
of approximately 0.03 to 0.30. For this
NOPR analysis, DOE assumed that a
diameter increase for centrifugal PRV
exhaust and supply fans would result in
a 0.03 increase in FEI and a diameter
increase for axial PRV fans would result
in a 0.09–0.10 increase in FEI. DOE
recognizes that initial diameter size,
operating airflow, and operating
pressure may impact how effective an
impeller diameter increase is for
increasing FEI. Specifically, the duty
points that DOE chose to evaluate may
be duty points where a diameter
increase is very effective at increasing
fan efficiency or may be duty points
where a diameter increase has minimal
impact on fan efficiency. DOE could
adjust the efficiency gains from an
impeller diameter increase in its
analysis so that there is a larger FEI gain
for all PRVs, and where PRVs could
reach higher FEI values for a lower cost.
Alternately, DOE could decrease the FEI
gain for axial PRVs from an impeller
diameter increase, allowing axial PRVs
to reach higher FEI values for a higher
cost since the impeller diameter
increase would no longer provide such
a large increase in FEI.
DOE requests comment on whether
the FEI increases associated with an
impeller diameter increase for
centrifugal PRVs and for axial PRVs are
realistic. Specifically, DOE requests
comment on whether it is realistic for
axial PRVs to have a FEI increase that
is 3 times greater than that for
centrifugal PRVs when starting at the
same initial diameter. Additionally,
DOE requests comment on the factors
that may impact how much an impeller
diameter increase impacts a FEI
increase.
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3765
In its analysis, DOE applied the
impeller changes and aerodynamic
redesigns for PRVs to the baseline fan
such that PRVs could reach higher
efficiency levels while maintaining the
baseline impeller diameter. While
manufacturers would have the option of
achieving higher efficiencies by
increasing fan diameter, DOE assumed
that if manufacturers were to change the
impeller or redesign a PRV,
manufacturers would apply these design
changes to their entire diameter range,
enabling the baseline diameter fan to
reach the higher efficiency levels.
The design path for all PRVs is shown
in Table IV–11. For the PRV equipment
classes, the impeller change(s) and
diameter increase(s) are ordered by FEI
increase, where the design option with
the smallest FEI increase is ordered first.
DOE could consider an analysis with a
different ordering of design option
based on MSP increase or costeffectiveness. Alternately, DOE could
consider an analysis that does not
include increased fan diameter as a
design option. In this alternative
analysis, DOE could consider an
additional impeller change as a design
option to increase FEI. However, based
on its analysis, DOE expects that
removing increased fan diameter as a
design option in its analysis would
increase the cost to achieve a higher
efficiency of a PRV.
DOE requests comment on the
ordering and implementation of design
options for centrifugal PRV exhaust and
supply fans and axial PRV fans.
DOE additionally determined that
manufacturers may improve efficiency
through aerodynamic redesign, as
described in section IV.A.3 of this
document. It is DOE’s understanding
that aerodynamic redesign may require
significant product and capital
investment. Accordingly, DOE only
applied aerodynamic redesign after
applying the design options DOE
expected would be less cost-intensive
for manufacturers. Additionally, the
impact of aerodynamic redesign on
efficiency is expected to vary
significantly depending on the design
choices made by the manufacturer.
Therefore, DOE determined that the
design option approach would not be
appropriate for evaluating efficiency
improvements for aerodynamic
redesign. Instead, DOE evaluated
aerodynamic redesign using the
efficiency level approach. Generally,
DOE set the FEIs for aerodynamic
redesigns by assigning evenly spaced
FEIs between the highest non-redesign
EL (i.e., the EL immediately before the
first aerodynamic redesign) and the
max-tech EL. A numerical example
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
demonstrating how FEIs were assigned
to the aerodynamic redesign ELs for the
centrifugal PRV exhaust equipment
class is provided in the following
section.
ddrumheller on DSK120RN23PROD with PROPOSALS2
Existing Efficiency Standards
DOE also evaluated other efficiency
programs to inform the development of
its efficiency levels. Energy efficiency
provisions for commercial fans are
prescribed in U.S. building codes,
primarily developed by the
International Code Council and
specified in the International Energy
Conservation Code (‘‘IECC’’). The IECC
was most recently updated in 2021
(‘‘IECC–2021’’) and specifies that
commercial buildings shall comply with
the requirements of ASHRAE 90.1.57
The most recent edition of ASHRAE
90.1 was published in September 2022,
and sets an FEI target of 1.00 for all fans
within the scope of ASHRAE 90.1.58
While the standards established under
IECC and ASHRAE 90.1 are not
federally mandated, they are used by
individual States and municipalities to
support the development of local
building codes. DOE is also aware that
the CEC has finalized a rulemaking,
which requires manufacturers to report
fan operating boundaries that result in
operation at an FEI of greater than or
equal to 1.00 for all fans within the
scope of that rulemaking.59
Furthermore, during confidential
manufacturer interviews, DOE received
feedback that an FEI of 1.00 is a realistic
efficiency target and DOE does not have
any indication that an FEI of 1.00 would
not be achievable for all fan equipment
classes.
Based on this feedback and to align
with the aforementioned standards,
DOE elected to evaluate an efficiency
level at an FEI of 1.00 for all fan classes.
The efficiency level and design option
that corresponds to an FEI of 1.00 differs
for each equipment class depending on
the FEI difference between the baseline
and max-tech efficiency levels for each
equipment class and the efficiency gain
identified for each design option. For
the axial inline, centrifugal inline, and
centrifugal unhoused equipment
57 International Code Council. ‘‘2021
International Energy Conservation Code Chapter 4:
Commercial Energy Efficiency’’. September 2021.
Available at codes.iccsafe.org/content/IECC2021P2/
chapter-4-ce-commercial-energy-efficiency.
58 ASHRAE. ‘‘Standard 90.1–2022—Energy
Standard for Sites and Buildings Except Low-Rise
Residential Buildings.’’ September 2022. Available
at www.ashrae.org/technical-resources/bookstore/
standard-90-1.
59 California Energy Commission. Commercial
and Industrial Fans and Blowers. Docket No. 22–
AAER–01. Available at efiling.energy.ca.gov/Lists/
DocketLog.aspx?docketnumber=22-AAER-01.
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classes, DOE determined that an FEI of
1.00 could be achieved using the
identified design options. Therefore,
each of these equipment classes has
specific design options associated with
the EL set at an FEI of 1.00. For
example, for the centrifugal inline
equipment class, DOE tentatively
determined through the design option
approach that an FEI of 1.00 could be
achieved by using a mixed flow
impeller (EL 3). For all other equipment
classes, DOE assumed that
manufacturers could achieve an FEI of
1.00 through an aerodynamic redesign.
For equipment classes that had an
aerodynamic redesign assigned at an EL
with an FEI of 1.00, DOE evenly spaced
all other aerodynamic redesign ELs at
FEIs above and below a value of 1.00,
where applicable. For example, the
centrifugal PRV exhaust equipment
class has a total of four aerodynamic
redesign ELs, with the second
aerodynamic redesign (EL 4)
corresponding to an FEI of 1.00. The
highest non-redesign EL occurs at EL 2,
corresponding to an FEI of 0.76, and
max- tech occurs at EL 6, corresponding
to an FEI of 1.37. Therefore, the first
aerodynamic redesign was set at the
midpoint between EL 2 and EL 4,
corresponding to an FEI of 0.88, and the
third aerodynamic redesign was set as
the midpoint between an FEI of 1.00
and the max-tech EL, corresponding to
an FEI of 1.19.
Parallel Design Path for Forward-Curved
Fans
DOE received feedback during
interviews that forward-curved
impellers should be preserved in the
market because they offer distinct utility
over backward-inclined or airfoil
impellers and typically operate at lower
pressures where efficiency is inherently
lower. However, as discussed in section
IV.A.1.a, DOE has tentatively
determined that forward-curved fans do
not require a separate equipment class
since the FEI metric is a function of
operating pressure and accounts for the
inherently lower efficiency at lower
pressures.
Instead, to assess any costs associated
with preserving forward-curved fans,
DOE evaluated two parallel design paths
for centrifugal housed fans. DOE used
the first design path (hereafter referred
to as the ‘‘primary design path’’) to
evaluate all fans with impellers other
than forward-curved impellers. For the
primary design path, DOE observed a
significant number of fans with
backward-inclined impellers that
exhibited FEIs similar to those with
forward-curved impellers, despite
backward-inclined impellers generally
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being more efficient. Therefore, DOE
assigned the same baseline FEI to both
design paths and assumed baseline
efficiency on the primary design path to
be represented by an inefficient
backward-inclined fan which would
meet EL 1 via aerodynamic redesign of
the backward-inclined impeller. EL 2 on
the primary design path represents
substituting a more typical backwardinclined impeller with an airfoil
impeller to achieve an FEI of 1.00.
For the second design path (hereafter
referred to as the ‘‘forward-curved
design path’’), DOE assumed that the
baseline efficiency was represented by a
forward-curved fan that would meet all
subsequent ELs via aerodynamic
redesign while maintaining a forwardcurved impeller. The design options for
both design paths are summarized in
Table IV–9 and additional details on
how DOE defined the efficiency levels
for the separate centrifugal housed
design paths are provided in chapter 5
of the NOPR TSD.
Additionally, for the forward-curved
design path, EL 4 approaches max-tech
for forward-curved fans. Although DOE
identified fans with forward-curved
impellers above this EL, DOE could not
confirm that forward-curved fans could
be designed above this EL at all duty
points. Therefore, DOE defined the third
aerodynamic redesign on the forwardcurved design path (EL 4) as the maxtech for forward-curved impellers and
assumed that any fans above this FEI
would need to transition to a backwardinclined or airfoil impeller. As such, all
fans above EL 4 were analyzed using the
primary design path.
DOE notes that, in practice,
manufacturers may substitute forwardcurved impellers with a backwardinclined or airfoil impeller to improve
efficiency. However, based on DOE’s
review of the market and stakeholder
feedback on the importance of
maintaining fans with forward-curved
impellers, DOE could not determine a
representative percentage of forwardcurved fans that would be redesigned
versus substituted with a different
impeller. Therefore, to avoid
underestimating the costs required to
preserve forward-curved impellers, DOE
assumed that all forward-curved fans
currently on the market would maintain
their impellers and follow the forwardcurve design path.
DOE utilized a dual-design path
approach for centrifugal housed fans to
consider the fact that manufacturers
may be required to incur higher
conversion costs to maintain use of
forward-curved impellers. DOE
estimated the costs associated with
redesigning forward-curved fans using
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the same method used to estimate
aerodynamic redesign conversion costs
for all other equipment classes and
product types, as discussed in section
IV.J.2.c. However, DOE may revise its
analysis to consider additional
conversion costs for forward-curved
fans if sufficient data is provided to
demonstrate that these fans may
EL
ELO
ELI
EL2
EL3
experience unique challenges in
meeting higher FEI values.
DOE requests comment on its
approach for estimating the industrywide conversion costs that may be
necessary to redesign fans with forwardcurved impellers to meet higher FEI
values. Specifically, DOE is interested
in the costs associated with any capital
equipment, research and development,
3767
or additional labor that would be
required to design more efficient fans
with forward-curved impellers. DOE
additionally requests comment and data
on the percentage of forward-curved
impellers that manufacturers would
expect to maintain as a forward-curved
impeller relative to those expected to
transition to a backward-inclined or
airfoil impeller.
Table IV-9 Centrifue:al Housed Fan Desie:n Paths
Design Options - Primary Design
Design Options- Forward-curved
Desie:n Path
Path
Inefficient Backward-inclined Impeller
Baseline Forward-curved Impeller
Typical Backward-inclined Impeller
Aerodynamic Redesign 1*
Airfoil Impeller
Aerodynamic Redesign 1*
Aerodynamic Redesign 1
Aerodynamic Redesign 2
EL4
Aerodynamic Redesign 2
Aerodynamic Redesign 3
EL5**
Aerodynamic Redesign 3
-
*The first aerodynamic redesign for the forward-curved design path was split into two ELs to maintain
alignment with the main design path. Equivalent conversion costs were assumed for EL 1 and EL 2.
**EL 4 is assumed to approach max-tech for forward-curved fans. Therefore, all forward-curved fans are
assumed to transition to a backward-inclined or airfoil impeller above EL 4 and both the primary and
forward-curved design paths converge for EL 5.
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A=
T/mtr,2023
T/mtr,2014
Where hmtr,2023 is the motor efficiency
in accordance with table 8 at 10 CFR
431.25, and hmtr,2014 is the motor
efficiency in accordance with table 5 at
10 CFR 431.25 and Annex A of AMCA
214–21, and FEPact is determined
according to the DOE test procedure in
appendix A to subpart J of part 431. The
FEI in accordance with the proposed
TSL would be multiplied by this
correction factor to result in the FEI
standard. For fans with motors rated
below 100 hp, the correction factor, A,
would be equal to 1.00. DOE is also
proposing to add the motor efficiency
requirements specified in Table 5 at 10
CFR 431.25 for motors rated at or
between 100 hp and 250 hp in 10 CFR
431.175 and reference these values for
the correction factor calculation to
ensure that these motor efficiency
values are not inadvertently removed in
any separate motors rulemakings.
Efficiency Levels for General Fans and
Blowers With a Motor Controller
As discussed in the May 2023 TP
Final Rule, DOE adopted the FEP and
FEI calculation as specified in AMCA
214–21 but did not develop a control
credit for fans with a controller to offset
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As discussed in the May 2023 TP
Final Rule, DOE adopted the FEP and
FEI calculations specified in AMCA
214–21, which provides a method for
calculating the FEI of fans sold with
motors based on a table of polyphase
regulated motors (See Annex A of
AMCA 214–21). 88 FR 27312, 27348.
However, as discussed in the May 2023
TP Final Rule, the DOE test procedure
replaces Annex A of AMCA 214–21
with a reference to the current energy
conservation standards for polyphase
regulated motors in 10 CFR 431.25, with
the intention that the values of regulated
polyphase motor efficiencies would
remain up to date with any potential
future updates established by DOE. 88
FR 27312, 27349.
In a final rule published on June 1,
2023, DOE finalized amended energy
conservation standards for electric
motors. These standards adopted
amended efficiency requirements for
motors rated at or between 100 hp and
250 hp. Therefore, for GFBs sold with a
motor rated at or between 100 hp and
250 hp, FEI would be evaluated using
the amended efficiencies specified in
table 8 of 10 CFR 431.25, in accordance
with the DOE test procedure. However,
the motor efficiencies used to calculate
the reference fan FEP have not been
similarly updated based on the
amended standards for electric motors.
Therefore, the reference fan FEP for
GFBs with a motor rated at or between
100 hp and 250 hp would be calculated
using a motor efficiency that would not
be compliant with the adopted energy
conservation standards for electric
motors and would no longer be
available on the market. In other words,
the reference fan used in the FEI
calculation would have a lower
efficiency than that required for electric
motors, resulting in an inappropriately
greater FEI for the tested fan.
To avoid providing an unintended
advantage to these GFBs, DOE proposes
that the FEI level for GFBs sold with a
motor rated at or between 100 hp and
250 hp would be calculated by applying
a correction factor to the FEI standard
for GFBs sold with any other sized
motor. This correction factor would be
designed to offset the difference in
motor efficiencies specified for the
reference fan versus the amended motor
efficiency standards. DOE found that, at
a given duty point, the correction factor,
A, can be expressed as a function of the
motor efficiency as follows:
EP19JA24.027
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Efficiency Levels for General Fans and
Blowers Sold With a Motor
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the losses inherent to the motor
controller when calculating the FEI of
these fans at a given duty point. In the
May 2023 TP Final Rule, DOE stated
that, to the extent use of a controller
impacts the energy use characteristics of
a fan or blower, the test procedure
should account for such impact and that
appropriate consideration of any such
impact would be part of the evaluation
of potential energy conservation
standards. 88 FR 27312, 27371. DOE
further stated that the FEP [and FEI]
metric penalizes the use of VFDs
(variable speed drives which are a
category of motor controller), since
these metrics incorporate the losses
from the VFD and that appropriate
consideration of any such impact would
be part of the evaluation of potential
energy conservation standards. 88 FR
27312, 27372.
To avoid penalizing GFBs sold with a
motor controller, DOE proposes that the
FEI standard for GFBs sold with a motor
controller be calculated by applying a
credit to the FEI standard for GFBs sold
without a motor controller, where the
credit is designed to offset the losses
inherent to the motor controller. To
determine the credit, DOE compared the
FEP values of fans with a motor
controller (FEPact,mc) to the FEP values of
the same fans without a motor
controller, as calculated in accordance
with section 6.4.2.4 of AMCA 214–21
which represents typical motor and
motor controller performance, and using
FE/EL_mc
Where FEIEL_no_mc is the FEI value at
a given EL for a fan without a motor
controller.
When applying this equation, DOE
observed that for GFBs with a motor
the fan selection duty points provided
in the sample of consumers.60 (See
section IV.E.1). DOE found that, at a
given duty point, the credit can be
expressed as a function of the FEP, in
kW, as follows:
Credit= 0.03 x
FEPact
+ 0.08
Where FEPact is the actual fan
electrical input power of the fan with a
motor controller at the given duty point.
To convert the credit into a multiplier
to the FEI and to calculate the FEI
values at each efficiency level
considered for GFBs with a motor
controller, DOE relied on the following
equation:
FEPact - Credit
FEPact
= FE/EL_no_mc X
controller and with FEP values above 20
kW, the value of the multiplier to the
FEI is approximately constant and equal
to 0.966. Therefore, DOE proposes to
simplify the calculation of FEI standards
for fans with motor controllers as
follows:
Table IV-10: FEI levels for GFBs with Motor Controller
Fans with motor
FEI level for Fans with motor controller*
controller with:
FEPact-Credit
h
·were·
B=
FEPact
FEPact
FE Pact
'
Credit= 0.03 x
< 20 kW (26.8
hp)
2'. 20 kW (26.8
hp)
•
FEPact
Credit= 0.03
X FEPact
FE/EL_no_mc X
0.966
+ 0.08 [SI]
+ 0.08 X 1.341 [IP]
credit calculation based on the proposed
equations in section III.C.1.b of this
document. Additionally, DOE requests
comment on its use of a constant value,
and its proposed value, of the credit
applied for determining the FEI
standard for GFBs with a motor
controller and an FEPact of greater than
or equal for 20 kW.
60 For this calculation, DOE used the AMCA 214–
21 equations for the motor and motor controller
which are representative of the losses of typical
variable frequency drives instead of equations
discussed in section III.C.1 which were developed
as representative of less efficient, baseline, motor
and motor controller combinations (i.e.,
representative of lowest market efficiency).
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motor and motor controller
performance, and would potentially
result in a higher credit.
DOE requests comment on the
equations developed to calculate the
credit for determining the FEI standard
for GFBs sold with a motor controller
and with an FEPact less than 20 kW and
on potentially using an alternative
EP19JA24.030
Further, considering the proposed
addition of default calculation methods
to represent the combined motor and
motor controller efficiency (see section
III.C.1.b), in the final rule, DOE may also
consider an alternative credit
calculation based on the proposed
equations in section III.C.1.b which
represent baseline (and not typical)
EP19JA24.029
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*Rounded to the hundredth
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c. Higher Efficiency Levels
As part of DOE’s analysis, the
maximum available efficiency level is
the highest efficiency unit currently
available on the market. DOE also
defines a ‘‘max-tech’’ efficiency level to
represent the maximum possible
efficiency for a given product. Similar to
the baseline efficiency levels, DOE
established max-tech efficiency levels
by reviewing the performance data in
the AMCA sales database. DOE initially
evaluated max-tech for each class using
the FEI corresponding to the 95th
percentile (i.e., the FEI resulting in a 5percent pass rate). DOE used the 95th
percentile instead of the absolute
maximum FEI observed in the AMCA
sales database to avoid setting a maxtech FEI that may not be achievable
across most of a fan’s operating range.
DOE further refined these levels based
on manufacturer fan selection software
performance data collected at the
representative diameters and operating
points for each class. Additional details
on the selection of max-tech efficiency
levels can be found in chapter 5 of the
NOPR TSD.
As previously described, DOE
assigned design options and
corresponding FEIs to each equipment
class based on the analysis described in
sections IV.C.1.a–b. DOE conducted this
analysis up to a max-tech EL for each
equipment class. Final results are
shown in Table IV–11. These results
were used in all downstream analyses
for this NOPR.
BILLING CODE 6450–01–P
Table IV-11 Summary of Efficiency Levels for All GFB Equipment Classes
Panel
Axial PRV
Centrifuga
lPRV
Exhaust
Centrifuga
lPRV
Supply
Centrifuga
l Housed
Main Path
Centrifuga
l Housed
FC Path**
Centrifuga
l
Unhoused
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Centrifuga
l Inline
Radial
Design
Option
FEI
Design
Option
FEI
Design
Option
FEI
Design
Ootion
FEI
Design
Option
FEI
Design
Option
FEI
Design
Option
FEI
ELl
EL2
EL3
EL4
EL5t
EL6t
EL7t
Baseline:
tube axial
0.84
Impeller
change
0.87
Impeller
change
0.86
Impeller
change 1
0.69
Diameter
Increase
0.7
Diameter
Increase
0.72
Impeller
change
0.93
Impeller
change
0.93
Switch to
vane axial
1.00
st
1 Aero
redesign
1.00
Impeller
change 2
0.72
Impeller
change*
0.72
Impeller
change*
0.76
Airfoil
Impeller
1.00
st
1 Aero
redesign
1.00
2nd Aero
redesign
1.36
rd
3 Aero
redesign
1.48
Diameter
Increase*
0.85
2nd Aero
redesign
1.00
2nd Aero
redesign
1.00
2nd Aero
redesign
1.31
rd
3 Aero
redesign
1.31
3rd Aero
redesign
1.55
th
4 Aero
redesign
1.73
st
1 Aero
redesign
1.00
3rd Aero
redesign
1.20
3rd Aero
redesign
1.19
3rd Aero
redesign
1.46
-
-
-
-
-
-
2nd Aero
redesign
3rd Aero
redesign
Design
Option
Baseline
Impeller
change 1
Impeller
change 2
1st Aero
redesign
1.18
nd
2 Aero
redesign
1.24
Diameter
Increase*
0.75
1st Aero
redesign
0.86
pt Aero
redesign
0.88
1st Aero
redesign
1.15
nd
2 Aero
redesign
1.15
pt Aero
redesign
FEI
0.94
1.00
1.10
1.23
1.35
1.49
Design
Option
Baseline
Impeller
Change
Guide
Vanes
Mixed
flow*
MF with
guide
vanes
1st Aero
redesign
2nd Aero
redesign
-
FEI
0.65
0.70
0.77
1.28
1.46
-
Baseline
Impeller
change 1
Impeller
change 2
1.00
Aero
redesign
-
-
Design
Option
Baseline
0.80
Baseline
0.66
Baseline
0.67
Baseline
0.69
Baseline
0.63
Baseline
0.63
pt
1.07
Aero
redesign
2nd
-
3rd
Aero
redesign
-
-
2nd Aero
redesign
1.25
4th Aero
redesign
1.39
4th Aero
redesign
1.37
3rd Aero
redesign
1.49
-
-
-
-
-
-
-
-
-
-
FEI
0.82
0.87
0.93
1.00
1.17
1.34
*Design option applied relative to baseline fan instead of previous EL.
** The centrifugal housed forward-curved path was applied to uniquely consider the costs associated with
redesigning forward-curved fans. See section IV.C. 1.b for additional details.
t Dash marks are used to indicate that the specified EL does not apply to the corresponding equipment
class.
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Inline
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Potential Adjustments to Efficiency
Levels Based on AMCA 211 Tolerances
GFBs can be certified by AMCA to
bear the AMCA certified ratings seal.
AMCA publishes a manual prescribing
the technical procedures to be used in
connection with the AMCA Certified
Ratings Program for fan air performance:
‘‘AMCA 211–22 (Rev. 01–23)—Certified
Ratings Program—Product Rating
Manual for Fan Air Performance’’
(‘‘AMCA 211–22’’)
Certified AMCA GFBs are subject to
precertification and periodic check tests
as defined in section 10 of AMCA 211–
22. When products are check tested, the
check test performance must be within
the tolerance for airflow, pressure, and
power when compared with the
manufacturer’s catalog data.
Specifically, section 10 of AMCA 211–
22 allows for a 5 percent tolerance on
the fan shaft power when conducting a
precertification check test and a 7.5
percent tolerance when conducting a
periodic check test.
As discussed in section IV.A.2.a, DOE
conducted the GFB engineering analysis
for this NOPR primarily using a
database of confidential sales
information provided by AMCA, which
includes AMCA certified data related to
fan shaft power at a given duty point.
DOE also relied on manufacturer fan
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selection software from manufacturers
that are AMCA members, which
frequently provided data that was
AMCA certified.
DOE understands that it may be
common practice for manufacturers to
include the AMCA 211–22 tolerance
when submitting performance data to
AMCA. As a result, the fan shaft power
data included in the AMCA sales
database and manufacturer fan selection
software may include a 5 to 7.5-percent
tolerance and may be underestimated.61
For the final rule, DOE is considering
adjusting the fan shaft power values
included in the performance data used
in its analysis to account for this
tolerance. In the final rule, DOE is also
considering adjusting the values of FEI
associated to each efficiency level
analyzed to account for this tolerance.
DOE may consider revising the brake
horsepower values in the AMCA sales
database and from manufacturer fan
selection software by increasing each
value by 5 percent. DOE used the 5percent precertification check test
tolerance for the adjustments, as DOE
expects this would be the tolerance
applied to any ratings certified to
61 For example, a manufacturer may report a
value of 92.5 instead of 100 to incorporate a 7.5
percent tolerance.
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AMCA. This would result in lower FEI
values for each data point and could
result in lower FEI values associated
with each EL.
To determine how this may impact
the analysis, DOE increased the brake
horsepower values in the AMCA sales
database by 5 percent and recalculated
the bare shaft FEIs of all fans in the
database. As discussed in section IV.C.1,
the baseline and max-tech FEIs of all
equipment classes were determined
based on percentiles in the AMCA sales
database. DOE used the same
percentiles to determine the baseline
and max-tech for each equipment class
using the recalculated bare shaft FEIs.
For efficiency levels that were based on
the design option approach (e.g.,
impeller changes), DOE maintained the
percent increases in FEI associated with
each design option to determine the
adjusted FEI. For ELs that were based on
the efficiency level approach (i.e.,
aerodynamic redesigns), DOE adjusted
the FEI levels to maintain the same
percentage of models that meet each
aerodynamic redesign efficiency level
(i.e., pass rate). The FEI values in Table
IV–12 show what the results of the
engineering analysis may look like if the
tolerance that is allowed in AMCA 211–
22 is considered in the databases.
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Table IV-12 Summary of Efficiency Levels for All GFB Equipment Classes
Considerin2 a 5-percent AMCA 211-22 Tolerance Allowance
ELO
ELl
EL2
EL3
EL4
EL5
EL6
EL7
Axial Inline
0.80
0.83
0.96
1.12
1.30
1.48
-
-
Panel
0.76
0.82
0.95
1.18
1.41
1.65
-
-
AxialPRV
0.63
0.67
0.69
0.72
0.82
0.95
1.19
1.42
0.64
0.67
0.68
0.82
0.95
1.14
1.33
-
0.65
0.68
0.72
0.83
0.95
1.13
1.29
-
0.60
0.90
0.96
1.09
1.24
1.39
-
-
0.60
0.90
0.96
1.09
1.24
1.39
-
-
0.89
0.94
1.04
1.17
1.28
1.42
-
0.62
0.66
0.73
0.95
1.02
1.22
1.39
0.78
0.83
0.89
0.95
1.11
1.27
-
-
Centrifugal
PRV
Exhaust
Centrifugal
PRVSupply
Centrifugal
Housed
Main Path
Centrifugal
Housed
FC Path*
Centrifugal
Unhoused
Centrifugal
Inline
Radial
*Design option applied relative to baseline fan instead of previous EL.
DOE requests comments on whether it
should apply a correction factor to the
analyzed efficiency levels to account for
the tolerance allowed in AMCA 211–22
and if so, DOE requests comment on the
appropriate correction factor. DOE
requests comment on the potential
revised levels as presented in Table IV–
12. Additionally, DOE requests
comments on whether it should
continue to evaluate an FEI of 1.00 for
all fan classes if it updates the databases
used in its analysis to consider the
tolerance allowed in AMCA 211–22.
Additionally, DOE does not anticipate
that the efficiency levels captured in
Table IV–12 would impact the cost,
energy, and economic analyses
presented in this document. As such,
DOE considers the results of these
analyses presented throughout this
document applicable to the efficiency
levels with a 5% tolerance allowance.
DOE seeks comment on the analyses as
applied to the efficiency levels in Table
IV–12.
d. Cost Analysis
The cost analysis portion of the
engineering analysis is conducted using
one or a combination of cost
approaches. The selection of cost
approach depends on a suite of factors,
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including the availability and reliability
of public information, characteristics of
the regulated equipment, and the
availability and timeliness of
purchasing the equipment on the
market. The cost approaches are
summarized as follows:
• Physical teardowns: Under this
approach, DOE physically dismantles
commercially available equipment,
component-by-component, to develop a
detailed bill of materials for the
equipment.
• Catalog teardowns: In lieu of
physically deconstructing equipment,
DOE identifies each component using
parts diagrams (available from
manufacturer websites or appliance
repair websites, for example) to develop
the bill of materials for the equipment.
• Price surveys: If neither a physical
nor catalog teardown is feasible (for
example, for tightly integrated products
such as fluorescent lamps, which are
infeasible to disassemble and for which
parts diagrams are unavailable) or costprohibitive and otherwise impractical
(e.g., large commercial boilers), DOE
conducts price surveys using publicly
available pricing data published on
major online retailer websites and/or by
soliciting prices from distributors and
other commercial channels.
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In the present case, DOE conducted
its analysis for GFBs using a
combination of price surveys from
manufacturer fan selection software, the
AMCA sales database, and physical
teardowns. DOE notes that due to time
constraints and the variety of fans
available in the market (e.g., commercial
or industrial application, construction
class, equipment class), DOE was unable
to conduct sufficient teardowns to rely
solely on a manufacturer production
cost (‘‘MPC’’) approach informed by
physical teardowns. Therefore, DOE
used manufacturer sales prices (‘‘MSP’’)
for its cost analysis since DOE had
substantially more MSP data than MPC
data available for GFBs. When DOE
pulled data from manufacturer fan
selection software, the fan MSP was
typically included; if the MSP was not
included, DOE requested quotes to
obtain a sales price. The AMCA sales
database includes confidential total
sales value and total sales volume for
each fan model. DOE divided the total
sales value by the sales volume to
calculate the MSP for a single fan. MSPs
from the AMCA sales database were
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adjusted to 2022 dollars to account for
inflation.62
DOE recognizes that fan costs would
not follow a simple scaling model as
there are several factors that could
impact the sales price of a fan, including
construction class,63 drive assembly,
production volume, manufacturer
purchasing power, mark-up, commercial
or industrial application, etc. To
account for these factors, DOE averaged
MSPs from the AMCA sales database at
each diameter for each fan equipment
class to conduct its cost analysis.
Average MSPs were obtained at a range
of duty points that DOE determined to
be reflective of the entire market, rather
than only at the specific representative
operating points that DOE selected.
Additionally, based on its analysis of
manufacturer fan selection software,
DOE determined that fans may be sold
with a variety of motors, each with a
distinct cost that contributes to the
overall selling price. Therefore, DOE
decided to use average MSPs to account
for the variety of motors on the market,
rather than attempt to evaluate fan costs
without a motor by subtracting an
assumed unique motor cost from each
fan in the AMCA sales database. This
process was completed to ensure that all
fan design options were evaluated with
constant motor and motor controller
cost estimates and DOE notes that the
MSP change from EL to EL ultimately
drives the downstream analyses. While
DOE recognizes that an average is not
representative of all fan designs, DOE
had limited data and therefore
determined that an average would
provide the most representative estimate
based on the data available.
DOE used data from both the AMCA
sales database and sales data pulled
from manufacturer fan selection
software to create an MSP versus
diameter curve for each equipment
class. First, DOE averaged the MSPs in
the AMCA sales database, as discussed
earlier, to generate an MSP-versusdiameter curve. DOE then calibrated
this curve with MSPs from
manufacturer fan selection software.
DOE used the MSP-versus-diameter
curves to determine the baseline MSP
62 DOE used the Federal Reserve Economic Data’s
‘‘Producer Price Index by Industry: Fan, Blower, Air
Purification Equipment Manufacturing’’ to account
for inflation to 2022 dollars. DOE used a
multiplication factor of 1.4 to convert from 2012
dollars to 2022 dollars. (fred.stlouisfed.org/series/
PCU333413333413)
63 Fans can be grouped into three AMCA
construction classes (Class I–III) based on operation
static pressure and outlet velocity. A Class I fan
would have a lower operating static pressure and
outlet velocity than a Class III fan. As a result, Class
I fans tend to have a less-rugged construction than
Class II–III fans.
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for each equipment class at a given
diameter.
As discussed in section IV.C.1.b, DOE
used individual design options for the
lower ELs in each class and
aerodynamic redesign for the higher
ELs. To determine the incremental costs
associated with the design option ELs
above baseline, DOE compared the
MSPs of similarly constructed fans
operating at the same duty point. For
example, DOE evaluated the increase in
MSP for impeller changes by calculating
the percentage change in MSP for two
fans operating at the same duty point
and with similar housings, but different
impeller designs. DOE averaged changes
in MSP for each analyzed fan within
each equipment class to obtain typical
incremental costs for each design
option, which were applied above
baseline to obtain MSPs for each
efficiency level. For fans where
diameter increases were evaluated as a
design option, DOE used the diameterversus-MSP curves to estimate the
increase in MSP relative to the baseline
fan. As discussed in section IV.C.1.b,
DOE used an 18-percent increase as the
standard value for each impeller
diameter increase. MSPs corresponding
to each EL assume no change in motor
or drive costs since DOE kept the motor
and drive costs constant over all ELs;
therefore, the change in MSP at each
design option EL is reflective of the cost
of incorporating the corresponding
design option.
DOE additionally conducted
teardowns to validate the MSPs applied
to each EL. For axial inline fans, DOE
initially estimated a high MSP from
manufacturer fan selection software for
replacing a tube axial fan with a vane
axial fan; however, teardown data
suggested that a lower MSP would be
more realistic. DOE believes this
discrepancy is due to differences in
production volume between tube axial
and vane axial fans, with vane axial fans
having lower production volumes in the
current market. In the presence of
energy conservation standards,
however, DOE expects that production
volumes for vane axial fans would
increase, reducing this price difference.
Therefore, DOE adjusted the MSP for
substituting a tube axial fan with a vane
axial fan assuming equivalent
production volumes in the presence of
energy conservation standards.
Similarly, for centrifugal inline fans,
DOE found that the average MSP when
substituting a centrifugal inline impeller
with a mixed-flow impeller was higher
than would have been expected based
on the teardown data. DOE believes this
may be due to a mix of lower
production volumes in the current
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market, underlying conversion costs,
and increased markups for mixed-flow
fans in the current market. Therefore,
DOE reduced the MSP when
substituting a centrifugal inline impeller
with a mixed-flow impeller. To account
for any costs associated with
redesigning a centrifugal inline fan,
DOE modelled most costs for applying
a mixed-flow impeller as conversion
costs, similar to those applied for
aerodynamic redesigns.
As discussed, DOE evaluated
aerodynamic redesigns as the final ELs
for all equipment classes. DOE assumed
a constant MSP for each aerodynamic
redesign EL, with no change in MSP
from the last design option EL to the
first aerodynamic redesign EL. DOE
assumed that the redesign,
reengineering, and new production
equipment required for aerodynamic
redesign efficiency levels would result
in significant one-time capital and
product conversion costs. To account
for expected manufacturer markups at
these ELs, DOE applied a conversion
cost markup that increases as capital
costs increase. Aerodynamic redesign
conversion costs are further discussed
in section IV.J.2.c of this NOPR.
DOE assumed that shipping costs
remained constant over all analyzed ELs
for all equipment classes except for
PRVs, where the increased diameter
design options are expected to have a
substantial impact on equipment
dimensions and weight. To estimate
shipping costs for PRVs, DOE used data
from product teardowns and product
literature for the representative
operating points. DOE compared
measured shipping dimensions from
physical teardowns with listed unit
dimensions in manufacturers’ product
literature and extrapolated the
difference between them to estimate
representative shipping dimensions for
the units that DOE did not tear down.
These dimensions were then used to
estimate the number of PRVs that could
be shipped per truck load. Based on this
analysis, an additional shipping cost for
each individual PRV was then applied
to DOE’s estimated MSPs.
DOE requests comment on its method
to use both the AMCA sales database
and sales data pulled from manufacturer
fan selection data to estimate MSP. DOE
also requests comment on the use of the
MSP approach for its cost analysis for
GFBs or whether an MPC-based
approach would be appropriate. If
interested parties believe an MPC-based
approach would be more appropriate,
DOE requests MPC data for the
equipment classes and efficiency levels
analyzed, which may be confidentially
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2. Air Circulating Fans
In the following sections, DOE
discusses the engineering analysis
performed to establish a relationship
between ACF efficacy and MPC.
a. Representative Units
When performing engineering
analyses for energy conservation
standards rulemakings, rather than
model every possible set of
characteristics an equipment could
have, DOE often evaluates the efficiency
and cost of specific units that are most
representative of the equipment. These
representative units are typically chosen
based on size or performance-related
features. In the October 2022 NODA,
DOE modeled five ACF representative
units: a 12-in. ACF with a 0.01 hp
motor; a 20-in. ACF with a 0.33 hp
motor; a 24-in. ACF with a 0.5 hp motor,
a 36-in. ACF with a 0.5 hp motor; and
a 50-in. ACF with a 1 hp motor. 87 FR
62038, 62046. In the October 2022
NODA, DOE requested comment on
whether the motor hp it has associated
with each representative diameter (i.e.,
0.1 hp for 12 in., 0.33 hp for 20 in., 0.5
hp for 24 in. and 36 in., and 1 hp for
50 in.) appropriately represented the
motor hp for fans sold with those
corresponding diameters. Id.
In response to the October 2022
NODA, AMCA commented that DOE
should consider decoupling fan size and
motor nameplate hp for its
representative units because the motor
nameplate hp is not always
representative of how much loading is
placed on the motors and may therefore
mislead any estimates of efficiency.
(AMCA, No. 132 at p. 7)
In response to stakeholder concerns
about establishing representative motor
powers for the engineering analysis,
DOE reevaluated its approach. After
reviewing the updated ACF database,
which contains catalog data not
included in the October 2022 NODA
analysis, DOE found that motor
nameplate power may vary too much
from fan to fan to establish a single
representative motor power for a given
fan diameter. Instead, for this NOPR
analysis, DOE used the distribution of
motor nameplate powers for each
representative diameter to determine
weighted averages for motor efficiency
and motor costs. Further details on
these distributions and their use can be
found in chapter 5 of the NOPR TSD.
For this NOPR, DOE evaluated
slightly different representative units
than it evaluated in the October 2022
NODA analysis. DOE did not consider a
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12-in. representative unit for the NOPR
because ACFs with input powers less
than 125 W were excluded from the
scope, which significantly reduced the
number of in-scope 12-in. ACFs in
DOE’s updated ACF database. As
discussed in section IV.A.1.b, DOE
identified three equipment classes for
axial ACFs, a 12-in. to less than 36-in.
diameter axial ACF class, a 36-in. to less
than 48-in. diameter axial ACF class,
and a 48-in. diameter or greater axial
ACF class. DOE defined a single
representative unit for each axial ACF
equipment class. DOE reviewed ACF
diameters in its updated ACF database
and determined that the most common
diameters for the 12-in. to less than 36in. diameter range, the 36-in. to less
than 48-in. diameter range, and the 48in. diameter or greater range were 24 in.,
36 in., and 52 in., respectively.
Therefore, DOE used these three
diameters as its representative units for
the ACF analysis. DOE did not consider
the 20-in. or 50-in. representative units
included in the October 2022 NODA
because neither of these sizes were the
most common diameter for axial ACFs
in the corresponding diameter range.
For housed centrifugal ACFs, DOE
chose 11 in. as the representative unit,
since it is the most common diameter
for housed centrifugal ACFs in the
updated ACF database, Further details
regarding the selection of representative
units can be found in chapter 5 of the
NOPR TSD.
b. Baseline Efficiency and Efficiency
Level 1
Motors
As discussed in section IV.C.1.a,
baseline models are typically either the
most common or the least efficient units
on the market. In the October 2022
NODA, DOE assigned split-phase
motors to be the baseline technology
option for ACFs because split-phase
motors are the least efficient type of
motor used for ACFs. 87 FR 62038,
62048. As discussed in the October 2022
NODA, the BESS Labs combined
database contained ACFs sold with PSC
motors, polyphase motors, and ECMs,
but no split-phase motors. Id. Therefore,
DOE used the lowest efficiencies
observed in the BESS Labs combined
database, associated with low-efficiency
PSC motors, to establish EL 1. To
estimate baseline efficiencies from EL 1,
DOE applied an efficiency loss
associated with switching from a lowefficiency PSC motor to a split-phase
motor. 87 FR 62038, 62049.
In the October 2022 NODA, DOE
requested feedback on the methodology
used to determine the baseline
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efficiency values for the representative
units and on the expected average
improvement in ACF efficiency when a
split-phase motor is replaced by a lowefficiency PSC motor. 87 FR 62038,
62049. In response, the Efficiency
Advocates stated that, since DOE
utilized the BESS Labs combined
database to determine efficiency in the
October 2022 NODA, that baseline
efficiency could be higher than the
actual least efficient ACFs on the
market. (Efficiency Advocates, No. 126
at p. 1) In response to stakeholder
feedback and after reviewing its updated
ACF database, DOE utilized a different
methodology for determining baseline
efficiency in this NOPR. Rather than
determining EL 1 and back-calculating
baseline from EL 1, DOE defined the
baseline efficiencies for each
representative unit using the minimum
efficiency values in its updated ACF
database. Additionally, as discussed in
section IV.A.3 of this NOPR, additional
review of the ACF market indicated that
very few ACFs use split-phase motors
compared to the number of ACFs that
use PSC motors. Therefore, DOE
decided to consider low-efficiency PSC
motors as a baseline design option for
ACFs in this NOPR.
As discussed in section IV.A.2.b, DOE
included catalog data in its updated
ACF database to supplement the BESS
Labs combined database. DOE did not
consider catalog data in the October
2022 NODA because catalog data did
not include information on the air
density measured during testing, which
is required when calculating FEI. Since
DOE updated the ACF efficiency metric
to be efficacy instead of FEI, DOE was
able to use catalog data for efficiency
information for this NOPR. Therefore,
DOE expects the minimum efficacy
values used in this NOPR analysis to be
more representative of the baseline fans
on the market than those used in the
October 2022 NODA.
Transmission
In the October 2022 NODA, since
DOE did not consider more efficient
transmissions as a design option, the
baseline fan was not defined by a
transmission type. However, in this
NOPR analysis, DOE is considering
more-efficient transmissions as a design
option for ACFs. As discussed in section
IV.A.3, using a direct-drive transmission
instead of a belt-drive transmission can
increase the efficiency of a fan.
Manufacturers also indicated in
interviews that the fan industry is
transitioning away from using belt-drive
transmissions in favor of direct-drive
transmissions. Therefore, DOE decided
to assign a belt-drive transmission as a
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baseline design option and tentatively
determined that a change from beltdrive to direct-drive would be the first
design change ACF manufacturers
would make to improve efficiency.
Therefore, DOE chose a direct-drive
transmission as the EL 1 design option.
DOE notes, however, that not all the
equipment classes it analyzed typically
use belt drives. DOE reviewed the
housed centrifugal ACF market and
concluded that belt drives are not used
for housed centrifugal ACFs.
Additionally, DOE’s review of the axial
ACF market indicated that belt drives
are not commonly used for axial ACFs
less than 36 in. in diameter. DOE found
that only 2 percent of ACF models in its
updated ACF database with a diameter
less than 36 in. had belt drives, while
66 percent of ACF models in its updated
ACF database with a diameter of 36 in.
or larger had belt drives. Therefore, DOE
has determined that a direct-driven fan
is representative of both the baseline
and EL 1 for the 24-in. axial ACF and
centrifugal housed ACF representative
units.
For the 36-in. and 52-in. axial ACF
representative units, DOE determined
EL 1 by applying an efficacy delta to the
baseline efficacy representing a
transition from a belt-drive transmission
to a direct-drive transmission. To
estimate this incremental impact on
efficacy when transitioning from a beltdrive transmission to a direct-drive
transmission, DOE used the equations
defined in sections 6.3.1 and 6.3.2 of
AMCA 214–21. The equations in section
6.3.1 of AMCA 214–21 define the
efficiency of direct-drive transmissions
as 100 percent and define the efficiency
of belt-drive transmissions based on the
shaft power of the fan. Since shaft
powers are generally unknown for
ACFs, DOE used the equation defined in
section 6.3.2 of AMCA 214–21 to
determine theoretical motor output
powers associated with given shaft
powers and transmission efficiencies.
DOE then plotted a curve to estimate
belt-drive transmission efficiency as a
function of motor output power, which
was used to estimate the belt-drive
efficiencies for all motor hp values in its
updated ACF database. To account for
the range of motor hp values that could
be used in ACFs for each representative
unit, DOE determined the percentage of
fans in its updated ACF database that
corresponded to each motor hp in the
database. DOE then used these
percentages as weights to calculate a
weighted-average belt-drive efficiency
for each motor hp.
DOE evaluated the relationship
between transmission efficiency and fan
efficacy and determined that
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transmission efficiency and fan efficacy
are directly proportional. Therefore, the
percent increase in fan efficacy
associated with using a more efficient
transmission is equal to the percent
increase in transmission efficiency.
Further details of this analysis can be
found in chapter 5 of the NOPR TSD.
DOE applied the percent increase in
efficiency when transitioning from a
belt-drive transmission to a direct-drive
transmission to the baseline efficacies
for the 36-in. axial ACF and 52-in. axial
ACF representative units to determine
EL 1. DOE used the resulting weightedaverage belt-drive efficiency to
determine the percent difference in
efficiency between a belt-drive
transmission and a direct-drive
transmission. Based on this approach,
DOE estimated 13.5-percent and 10.4percent improvements in efficacy when
changing from a belt-drive transmission
to a direct-drive transmission for the 36in. axial ACF and 52-in. axial ACF
representative units, respectively.
As mentioned previously, DOE
defined both the baseline fan and EL 1
as direct driven for the 24-in. axial ACF
and the housed centrifugal ACF
representative units. Therefore, for these
two representative units, DOE set EL 1
equal to the baseline efficacy to account
for the fact that there would be no
efficacy gain associated with the moreefficient transmission design option.
This was done to maintain consistent
design options for each EL for all ACF
equipment classes.
Further discussion of DOE’s
methodology for determining baseline
efficiency and EL 1 can be found in
chapter 5 of the NOPR TSD.
c. Selection of Efficiency Levels
In this section, DOE discusses
comments it received on its ACF
efficiency analysis in the October 2022
NODA and describes the efficiency
analysis methodology it used for this
NOPR. As discussed in section IV.C.1.b,
DOE typically uses either an efficiencylevel approach, a design-option
approach, or a combination of the two
for its efficiency analysis. In this NOPR,
DOE used a combination efficiencylevel and design-option approach for its
analysis of ACFs. DOE used the
efficiency-level approach to determine
the baseline and aerodynamic redesign
ELs and used the design-option
approach to gap fill intermediate ELs.
For the design-option approach, DOE
used the efficiencies determined for the
baseline design options and moreefficient design options to assign
incremental efficiency gains for each EL.
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General Approach and Related
Comments
In the October 2022 NODA, DOE
evaluated more-efficient motors and
aerodynamic redesign as options for
increasing ACF efficiency. 87 FR 62038,
62048. DOE did not conduct a formal
screening analysis in the October 2022
NODA; however, as discussed in section
IV.B, DOE conducted a formal screening
analysis for this NOPR, and screened in
the following design options for ACFs:
• Aerodynamic redesign (improved
housing design, reduced manufacturing
tolerances, addition of appurtenances,
improved impeller design, addition of
guide vanes, impeller topology);
• Increased impeller diameter;
• More-efficient transmissions (belt
drive and direct drive); and
• More-efficient motors.
DOE did not evaluate the efficiency
impacts of all these design options in
the engineering analysis for ACFs.
Specifically, DOE did not consider the
efficiency impacts of increased impeller
diameter since DOE defined equipment
classes based on diameter in section
IV.A.1.b. Therefore, when developing
the proposed ELs, DOE only considered
more-efficient transmissions, moreefficient motors, and aerodynamic
redesign as design options for its
analysis of ACFs in this NOPR. Moreefficient transmissions were associated
with EL 0 and EL 1, which were
discussed in section IV.C.2.b.
Regarding motors, DOE evaluated
multiple motor options for ACFs in the
October 2022 NODA, specifically splitphase motors at baseline, PSC 1 motors
at EL 1, PSC 2 motors at EL 2, and ECMs
at EL 3. 87 FR 62038, 62048. PSC 1
motors were defined as basic PSC
motors, while PSC 2 motors were
defined as ‘‘more efficient PSC motors’’.
Id. In this NOPR, DOE refers to basic
PSC motors as ‘‘low-efficiency PSC
motors’’ and refers to more-efficient PSC
motors as ‘‘high-efficiency PSC motors.’’
In the October 2022 NODA, DOE also
assumed that airflow, pressure, motor
speed, and motor inrush current
remained constant when replacing a
less-efficient motor with a moreefficient motor and requested feedback
on these assumptions. 87 FR 62038,
62049.
In response, AMCA commented that,
provided the shaft speed does not
change much, the fan affinity laws can
be used to predict airflow and total
pressure. However, AMCA added that
there can be discrepancies between the
torque required by the load and the
torque produced by the motor for lowpower motors. AMCA further stated
that, given the very low starting torque
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of ACFs, inrush current is likely
insignificant for ACF motors. (AMCA,
No. 132 at p. 9) NEMA stated that while
motor performance can be optimized,
changing the motor may impact other
aspects of fan performance. NEMA
specifically stated that more-efficient
motors will typically have higher
speeds, which may require a redesign of
the fan. (NEMA, No. 125 at p. 5) AMCA
also stated that motors with higher
rotational speeds will generally be more
efficient. (AMCA, No. 132 at pp. 16–17)
NEMA commented that changing the
efficiencies of motors used for ACFs
could require the use of a larger, heavier
motor and could therefore require other
design changes to the fan. (NEMA, No.
125 at p. 2) AMCA also stated that
replacing a motor with a more-efficient
motor may result in the need for
aerodynamic redesign or redesign of the
mounting and supports of an ACF
because of differences in motor size,
shape, or weight. (AMCA, No. 132 at p.
12)
DOE investigated the issue of higherefficiency motors having higher speeds
in the December 2023 ESEMs NOPR
TSD.64 For the typical motor types and
sizes used in ACF applications,65 DOE
found only a 0.5-percent to 0.7-percent
increase from the minimum full-load
speed to the maximum full-load speed.
Given the relatively small speed
changes between ESEMs with different
efficiencies, DOE has tentatively
concluded that increases in motor speed
associated with transitioning to moreefficient motors would be insignificant
and would not require additional
changes to fan design.
DOE requests feedback on whether
using a more efficient motor would
require an ACF redesign. Additionally,
DOE requests feedback on what
percentage of motor speed change
would require an ACF redesign.
Regarding stakeholder feedback that
ACFs may need to be redesigned to
accommodate differences in motor size
or shape when changing to moreefficient motors, DOE expects this type
of redesign could be done with minimal
efficiency impact because it expects that
only motor supports would be
redesigned. As discussed in section
IV.C.2.d, DOE found that there is
sufficient space for an increase in motor
volume without needing to redesign
64 The ESEMs NOPR TSD can be found at
www.regulations.gov/document/EERE-2020-BTSTD-0007-0056.
65 DOE’s review of the ACF market indicated that
low-torque, 6-pole, air-over ESEMs are the most
commonly used motor types for ACFs. Table 5.4.2
of the December 2023 ESEM NOPR TSD shows the
full-load speeds for these motors at different
efficiency levels.
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other fan components, such as housing
or safety guards. Consequently, DOE
assumed that the only redesign required
for an ACF when switching to a larger
motor would be to increase the weight
of the motor supports to accommodate
an increase motor weight. Therefore,
DOE assumed that when changing to a
more-efficient motor, the only
significant impact to the efficiency of an
ACF was the efficiency gained from the
motor.
Additionally, AMCA commented in
response to the October 2022 NODA
that motor nameplate information is
generally not very relevant for ACFs
because ACF manufacturers often use
motors in power ranges outside those
listed on motor nameplates. AMCA
stated that operating motors above their
nameplate load may provide the best
material efficiency and that this is
possible for ACFs because motors are
very well ventilated when used for
ACFs. AMCA also stated that the use of
a flatter pitch blade may not load a fan
to its listed motor horsepower, while a
steeper pitch blade may load the motor
past its listed horsepower. (AMCA, No.
132 at pp. 6–8) Further, AMCA stated
that motor nameplate efficiencies
depend on the number of phases and
the synchronous speed of the motors
and that the actual motor efficiency
would be different since motors are
used at higher power ratings than their
nameplate power ratings for ACFs.
(AMCA, No. 132 at pp. 16–17)
In consideration of AMCA’s
comments, DOE analyzed confidential
ESEM testing data to examine how
motor efficiency is impacted when
motors are operated at loads above their
nameplate rating. DOE compared the
efficiencies of motors tested at
nameplate load, 115 percent of
nameplate load, and 125 percent of
nameplate load. Through its analysis,
DOE found that, on average, motor
efficiency increased by a percent change
of 1.01 percent for motors tested at 115
percent of nameplate load and motor
efficiency increased by a percent change
of 1.23 percent for motors tested at 125
percent of nameplate load. DOE notes
that these percentages represent
percentage changes, rather than nominal
changes in motor efficiency. For
example, a 0.25 hp motor might have an
efficiency of 72.84 percent when tested
at 100 percent load compared to an
efficiency of 73.54 percent when tested
at 115 percent load, representing a
percentage increase in efficiency of 0.96
percent (i.e., [73.54¥72.84]/72.84 =
0.96%). The positive percentage change
found for motors tested at both 115
percent and 125 percent of rated load
indicates that, up to 125 percent rated
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load, efficiency generally increases for
motors operated at loads above their
nameplate rating. Hence,
representations of motor efficiency
calculated at nameplate load may
provide a more conservative estimate of
motor efficiency. For the motors that
exhibited a decrease in efficiency at 125
percent of rated load, DOE further
investigated the percentage change in
motor efficiency. For these motors, the
average percentage change in motor
efficiency remained under 1.5 percent
for motors tested at both 115 percent
and 125 percent of their rated load, with
a maximum percentage change in
efficiency of 2.3 percent. Since the
average percentage change in motor
efficiency from the rated efficiency is
small when motors are operated at
above their rated loads, DOE has
tentatively determined that motor
efficiencies calculated at rated load
represent adequate estimates of true
motor efficiency, even if those motors
are operated above their rated loads.
As discussed in section IV.A.3, DOE
considered split-phase motors, lowefficiency PSC motors, high-efficiency
PSC motors, and ECMs in its October
2022 NODA analysis. 87 FR 62038,
62048. DOE has since reviewed its
updated ACF database in response to
comments from AMCA and NEMA
about motors used in ACFs. Based on
the distribution of motor types in the
database, DOE tentatively concluded
that very few ACFs use shaded-pole,
split-phase, or capacitor start/capacitor
run motors. Rather, DOE found that the
most common motors used in ACFs are
PSC motors, and that some ACFs utilize
polyphase motors and ECMs. Specific
percentages of ACFs in the updated ACF
database with each motor type can be
found in Chapter 5 of the NOPR TSD.
Furthermore, in the October 2022
NODA, DOE requested comment on
whether ACFs with single-phase motors
and polyphase motors would be used
for different utilities or have different
efficiencies because of their end-use
applications. 87 FR 62038, 62045. In
response, NEMA stated that three-phase
motors typically have slightly higher
efficiencies than single-phase motors
but added that if only a single-phase
power supply is available, a three-phase
motor could not be used in place of a
single-phase motor. NEMA added that at
higher motor powers (1.5 hp and above),
three-phase motors tend to be equally as
or slightly less expensive than singlephase motors. (NEMA, No. 125 at p. 4).
DOE’s review of motor literature and
testing data for motors used in ACFs
indicated that polyphase motors are
generally more efficient than PSC
motors, as stated by NEMA.
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Additionally, DOE acknowledges that,
as NEMA stated, in situations where
only single-phase power is available, a
polyphase motor could not be used in
place of a single-phase motor without
the use of additional electronics, such as
a phase converter. As such, DOE did not
consider a change from PSC motor to
polyphase motor as a design option for
improving efficiency. Additionally, as
discussed above, the majority of the
ACFs in DOE’s updated ACF database
utilize PSC motors; therefore, DOE used
PSC motors to generally model the
efficiencies of induction motors used in
ACFs. DOE notes that this approach
provides conservative estimates of
induction motor efficiency relative to an
approach that includes polyphase motor
efficiencies since polyphase motors are
generally more efficient than PSC
motors. DOE considered low-efficiency
PSC motors and high-efficiency PSC
motors as induction motor design
options. Additionally, DOE considered
ECMs as a motor design option since
they are the most efficient type of motor
used in ACFs.
Determination of Efficiency Levels
As discussed in section IV.C.2.b, DOE
considered low-efficiency PSC motors
and belt-drive transmissions as baseline
design options and considered directdrive transmissions as the design option
for EL 1.
DOE received feedback during
confidential manufacturer interviews
that ACF manufacturers were more
likely to improve the efficiency of a
motor before performing an
aerodynamic redesign. Therefore, DOE
considered a high-efficiency PSC motor
as the design option for EL 2, prior to
considering aerodynamic redesign. DOE
modeled the efficiency gain associated
with changing from a low-efficiency
PSC motor to a high-efficiency PSC
motor. DOE determined the efficacy for
EL 2 for all equipment classes by
estimating efficiencies for low-efficiency
PSC motors and high-efficiency PSC
motors, determining the efficiency delta
between them, and applying that
efficiency delta to EL 1. In the October
2022 NODA, DOE estimated the
efficiencies of low-efficiency PSC
motors and high-efficiency PSC motors
using DOE’s database of catalog motor
data (‘‘motors database’’). 87 FR 62038,
62049. DOE associated low-efficiency
PSC motors with EL 1 and highefficiency PSC motors with EL 2 in the
October 2022 NODA analysis. DOE
estimated the increase in FEI from EL 1
to EL 2 by applying the percent increase
in efficiency from a low-efficiency PSC
motor to a high-efficiency PSC motor
directly to the EL 1 FEI value. DOE
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requested comment on its determined
efficiency gains when replacing a lowefficiency PSC motor with a highefficiency PSC motor and whether
catalog performance data for PSC motors
were representative of the performance
of motors used in ACFs. Id.
In response, NEEA commented that it
agreed with DOE’s approach to model
the efficiency improvements for the
overall fan as equal to the motor
efficiency improvements when only the
motor is changed and nothing else, such
as the duty point, motor speed, drive
type, etc. (NEEA, No. 129 at p. 3)
Greenheck expressed concern that the
motor efficiencies used by DOE in its
analysis may not have been accurate
and stated that Greenheck could not
confirm the accuracy of the efficiencies
used since the motor database was not
included with the supplementary
information. Greenheck also requested
clarity on which motors were included
in DOE’s analyses of low-efficiency PSC
and high-efficiency PSC motors.
Specifically, Greenheck stated motors
that DOE deemed low-efficiency PSC
motors should be analyzed as a separate
dataset from high-efficiency PSC
motors, rather than determining lowefficiency PSC motor performance from
the average efficiency of all PSC motors.
(Greenheck, No. 122 at p. 2) AMCA
commented that determining general
values for the change in efficiency
between one motor type and another is
difficult to do with confidence because
motors with the same topology and
power rating can have different
efficiencies. (AMCA, No. 132 at p. 8–9)
NEMA commented that the efficiencies
of fan motors are often not quantified
and that it is incorrect to assume that all
ACFs use low-efficiency motors.
(NEMA, No. 125 at p. 3) NEMA added
that the source of DOE’s ESEM catalog
data is unclear, given that most motor
manufacturers do not publish
performance information for the
fractional horsepower, single-phase
motors that DOE assumed were used for
ACFs in its October 2022 NODA
analysis. NEMA further stated that
catalog motors typically meet or exceed
the ratings listed for them in catalogs.
(NEMA, No. 125 at p. 3)
In response to stakeholder feedback,
DOE adjusted its methodology for
determining efficiencies associated with
low-efficiency PSC motors and highefficiency PSC motors in this NOPR. In
the October 2022 NODA, DOE
determined low-efficiency PSC motor
efficiency from the average of all airover PSC motors in the motors database.
87 FR 62038, 62049. For this NOPR,
DOE instead determined low-efficiency
PSC motor efficiency from the minimum
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efficiency of all 6-pole, fan-specific
motors in the motors database. The use
of the minimum efficiency, rather than
the average efficiency, produced a more
conservative estimate for low-efficiency
PSC motor efficiency. DOE analyzed 6pole motors specifically because DOE’s
review of the ACF market indicated that
6-pole motors are most common for
ACFs. DOE determined low-efficiency
PSC motor efficiencies at all motor
powers in its updated ACF database and
calculated a weighted average efficiency
using the distribution of motor powers
for each representative unit. Regarding
Greenheck and NEMA’s concerns about
the accuracy of the motor data in the
motors database, DOE acknowledges
that the motors in the database are
unregulated and therefore the data may
be inaccurate. However, DOE notes that
it received no additional information on
ACF motor efficiencies from
stakeholders that it could use instead of
the information in the motors database.
Regarding NEMA’s concerns about the
source of the PSC motor data in the
motors database, DOE notes that the
information it compiled from the
database for fan-specific, 6-pole PSC
motors consisted of published catalog
data from four different motor brands. In
response to AMCA’s concerns about
variations in motor efficiency with the
same topology and power rating, DOE
acknowledges that motors with the same
topology and power rating can have
different efficiencies. Therefore, DOE
used weighted-average motor
efficiencies in this NOPR analysis,
which allowed DOE to consider the
effects of a wide range of motor
efficiencies across many power ratings
for a particular motor topology.
Unlike low-efficiency PSC motors,
DOE did not use the motors database to
determine efficiencies for highefficiency PSC motors in this NOPR. As
part of the electric motors rulemaking,
stakeholders made a joint
recommendation for the efficiencies at
which they believe the standards for
ESEMs should be set. (Docket No.
EERE–2020–BT–STD–0007, Joint
Stakeholders, No. 38 at p. 6, Table 2)
The joint recommendation represented
the motors industry, energy efficiency
organizations and utilities (collectively,
‘‘the Electric Motors Working Group’’)
and addressed energy conservation
standards for high-torque, mediumtorque, low-torque, and polyphase
ESEMs that are 0.25–3 hp and
polyphase, and air-over ESEMs. In
reference to this ongoing rulemaking,
DOE has tentatively defined its highefficiency PSC motor efficiencies using
the efficiencies recommended by the
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ESEM Joint Stakeholders. DOE used the
average of the recommended efficiencies
for enclosed and open 6-pole PSC
motors since DOE’s review of the ACF
market indicated that both enclosed and
open motors are used for ACFs. DOE
then calculated weighted-average highefficiency PSC motor efficiencies using
the average recommended efficiencies at
different motor powers for each
representative unit. DOE then
determined the percent difference in
efficiency between high-efficiency PSC
motors and low-efficiency PSC motors.
DOE evaluated the relationship
between motor efficiency and fan
efficacy and determined that motor
efficiency and fan efficacy are directly
proportional. Therefore, the percent
increase in efficacy associated with
changing to a more efficient motor is
equal to the percent increase in motor
efficiency. Further details of this
analysis can be found in chapter 5 of the
NOPR TSD. DOE applied the percent
increase in motor efficiency when
transitioning from a low-efficiency PSC
motor to a high-efficiency PSC motor to
EL 1 to determine EL 2 for each
representative unit.
DOE recognizes that if it sets a
standard at the recommended ESEM
efficiencies, high-efficiency PSC motors
would effectively become the baseline
motor for ACFs. DOE performed a
sensitivity analysis to evaluate the
impact of setting ESEM standards at the
recommended efficiencies on its ACF
analysis. DOE found that, given the
small number of shipments at EL 0 and
EL 1 for ACFs, if EL 2 were set as the
baseline EL, there would be a minimal
impact on proposed ACF standards due
to the low shipments below EL2 (see
IV.F.8). DOE notes that if it sets a
standard in the ESEM rulemaking at the
recommended ESEM levels, DOE may
consider using EL2 proposed in this
NOPR as baseline for ACFs in a future
final rule.
In response to the October 2022
NODA, NEEA commented that DOE’s
assumption that the least-efficient fans
in the BESS Labs combined database
used the least-efficient motors may be
incorrect, since these fans could instead
have non-motor-related performance
features that caused them to have low
efficiencies. NEEA added that this could
cause non-representative ELs in DOE’s
analysis since some of DOE’s ELs are
based on motor efficiency increases.
(NEEA, No. 129 at p. 2) DOE notes that
information on the specific motor
models integrated into ACFs, including
motor efficiency, is not often publicly
available. DOE also notes that it
requested quantitative efficiency data on
ACF motors in the October 2022 NODA,
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and it has not received any quantitative
information on motor efficiency from
stakeholders. 87 FR 62038, 62063. As
discussed in section IV.A.2.b, DOE’s
dataset now includes catalog data in
addition to the BESS Labs combined
database. Therefore, as discussed in
section IV.C.2.b, DOE expects the
baseline efficacies that it used in this
analysis to be more representative of the
least efficient ACFs on the market than
the baseline used in the October 2022
NODA. Additionally, as previously
discussed, DOE updated its
methodology for determining motor
efficiencies for low-efficiency and highefficiency PSC motors. Given these
adjustments, DOE expects that the EL 2
efficacies are representative of ACFs
with high-efficiency PSC motors.
In the October 2022 NODA, DOE
considered ECMs as the design option
for EL 3 and considered aerodynamic
redesign as the design option for EL 4.
In response, the CA IOUs commented
that DOE should consider aerodynamic
efficiency improvements at ELs lower
than max-tech because they expect that
manufacturers would consider
aerodynamic redesigns before switching
to ECMs. The CA IOUs also
recommended that DOE consider
intermediate aerodynamic redesign
levels rather than a single ‘‘maximum’’
option. (CA IOUs, No. 127 at p. 2) The
Efficiency Advocates recommended that
DOE consider more ELs in its efficiency
analysis to better represent the range of
ACF efficiencies presented in its
analysis, and that DOE specifically
consider aerodynamic redesign. The
Efficiency Advocates stated that
additional ELs could be used to bridge
the large gap between EL 3 and EL 4 in
the October 2022 NODA. (Efficiency
Advocates, No. 126 at p. 2)
In response to this feedback, DOE did
not consider ECMs as a design option
immediately after considering highefficiency PSC motors in this NOPR;
rather, DOE evaluated three
aerodynamic redesign ELs—EL 3, EL 4,
and EL 5—and considered ECMs as the
max-tech design option at EL 6. DOE
assumed that more complex
aerodynamic redesign would be needed
for EL 4 compared to EL 3 and for EL
5 compared to EL 4.
In response to the October 2022
NODA, NEEA stated that the wide
distribution of efficiencies in the BESS
Labs combined database was likely due
to factors other than variation in motor
efficiency since the database consists of
fans that use the same kind of motor
(PSC). DOE infers from this comment
that variations in ACF efficiency in the
updated ACF database, which, like the
BESS Labs combined database,
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contained many ACFs with PSC motors,
can largely be attributed to differences
in aerodynamic efficiency between fans.
Therefore, although DOE could not
relate specific design options to a given
efficacy for its three aerodynamic
redesign levels, DOE defined
aerodynamic redesign levels using an
efficiency-level approach from its
updated ACF database. Since DOE
anticipated that more complex redesigns
would be required at EL 4 than EL 3,
DOE defined EL 3 as 33 percent of the
way between EL 2 and EL 4 for all
equipment classes.
DOE took different approaches for
establishing EL 4 for axial ACFs and
housed centrifugal ACFs. For axial
ACFs, DOE referenced agricultural fan
efficiency incentive programs to set the
efficacies at EL 4. All agricultural fan
efficiency incentive programs that DOE
found use units of thrust per kilowatt
(‘‘thrust/kW’’) to define minimum
performance targets to qualify for the
incentives. DOE converted these targets
into units of CFM/W. Details of this
conversion can be found in chapter 5 of
the NOPR TSD. As discussed in section
IV.C.2.a of this NOPR, ACF performance
targets are defined by diameter. To be
consistent with its lowest-diameter
equipment class, DOE averaged the
incentive program performance targets
for the 12-in. to less than 24-in.
diameter range and the 24-in. to less
than 36-in. diameter range to estimate
EL 4 for the 24-in. axial ACF
representative unit. DOE used the
performance targets for the 36-in. to 48in. diameter range and 48-in. or greater
diameter range to estimate EL 4 for the
36-in. axial ACF and 52-in. axial ACF
representative units, respectively.
For housed centrifugal ACFs, DOE
could not use the agricultural fan
efficiency incentive programs to define
EL 4 because housed centrifugal ACFs
are not used in agricultural applications.
Since DOE assumed that more complex
redesigns would be required at EL 5
than EL 4, DOE also assumed that the
efficiency gain between EL 5 and EL 4
would be greater than the efficiency
gain between EL 4 and EL 3. To reflect
this assumption, DOE defined EL 4 as
halfway between EL 2 and EL 5 for
housed centrifugal ACFs.
DOE defined EL 5 for each equipment
class based on the maximum efficacies
in the updated ACF database. DOE used
the maximum efficacies in the updated
ACF database to define EL 5 since DOE
found that the maximum efficacy ACFs
in the updated ACF database did not
have ECMs. Therefore, these ACFs did
not correspond to the max-tech level,
and DOE instead assumed that these
ACFs utilized highly efficient
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aerodynamic designs to achieve high
efficacies. As discussed in section
IV.A.2.b, DOE removed some highefficacy outliers from the ACF database
prior to determining the maximum
efficacies for EL5.
As discussed previously, DOE
considered an ACF with an ECM and a
highly efficient aerodynamic design to
be the max-tech design option. DOE’s
research indicated that ECMs are the
most efficient type of motor used in
ACFs, and, as indicated in the CA IOUs’
comment on aerodynamic redesign,
ACF manufacturers may consider
implementing aerodynamic redesign
prior to switching to an ECM. To
determine the max-tech efficiency, DOE
applied an incremental efficiency gain
associated with changing from a highefficiency PSC motor to an ECM to EL
5 for each equipment class.
In the October 2022 NODA, DOE used
a database of dedicated-purpose pool
pump (‘‘DPPP’’) motors to determine
efficiencies for ECMs and highefficiency PSC motors and the efficiency
gain expected when switching from a
high-efficiency PSC motor to an ECM.
87 FR 62038, 62050. DOE requested
comment on its use of DPPP motors for
comparing efficiencies of PSC motors
and ECMs. Id. In response, NEMA
commented that DPPP motor efficiency
levels should not be used to compare
PSC to ECM motor efficiency. NEMA
stated that the DPPP efficiency
regulations define system (motor and
pump) efficiency levels and not
standalone motor efficiencies. NEMA
also stated that it had concerns with
applying a market like DPPP, which has
a dedicated purpose and experiences
less variety of designs and
manufacturers, to the much more
diverse market of fans and blowers.
(NEMA, No. 125 at p. 5)
In response to NEMA’s concerns
about its use of DPPP motors to model
the efficiencies of ECMs, DOE adjusted
its methodology for determining ECM
efficiencies. To determine the
efficiencies of ECMs, DOE first
considered the motor efficiencies
specified in IEC 60034–30–1:2014. The
motor efficiencies defined in the IE code
are intended to serve as reference points
for governments to use when defining
efficiency standards. DOE understands
that the current IE 1 through IE 4
efficiencies defined in IEC 60034–30–
1:2014 are intended to represent
induction motor efficiencies. DOE also
understands that, should a higher IE
motor efficiency, IE 5, be defined in a
future standard, the IE 5 efficiencies
would likely align with ECM
efficiencies. DOE used theoretical IE 5
efficiencies to estimate the efficiencies
of ECMs and assumed that the
efficiencies included the effects of ECM
controllers. The IE 1 through IE 4 levels
defined in IEC 60034–30–1:2014 are
based on a 20-percent reduction in
power losses going from one IE level to
the next. For example, IE 4-level
efficiency is determined from IE 3-level
efficiency by assuming a 20-percent
reduction in power losses. Therefore,
DOE estimated IE 5 efficiency by
assuming a 20-percent reduction in
power losses from the IE 4 efficiency.
DOE determined the percent difference
between the estimated IE 5 efficiency
and the estimated high-efficiency PSC
motor efficiency. As discussed
previously, DOE determined that a
percent increase in motor efficiency
corresponds to an equal percent
increase in efficacy. Therefore, DOE
applied the percent increase in motor
efficiency when transitioning from a
high-efficiency PSC motor to an ECM to
EL 5 to determine EL 6. Further details
on the methodology DOE used to
determine the efficacies for each EL can
be found in chapter 5 of the NOPR TSD.
The efficacies determined for each EL
and representative unit and design
options associated with each EL are
shown in Table IV–13.
Table IV-13 Summary of Efficiency Levels for all ACF Representative Units
(CFM/W)
0
1
2
3
4
5
Design Option
Baseline
Direct-drive
High-efficiency
PSC motor
Aerodynamic
redesign 1
Aerodynamic
redesign 2
Aerodynamic
redesign 3
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ECM
As discussed in section V.C.1.b, DOE
notes that the standards it is proposing
for axial ACFs are discrete efficacy
values in CFM/W. This approach aligns
with the method used by agricultural
fan efficiency incentive programs,
where performance targets are specified
for certain diameter ranges. However,
DOE notes that setting a standard for
efficacy in this way may not fully
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ACF
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Representative Units
36-in. axial
52-in. axial
ACF
ACF
5.21
8.39
5.91
9.26
6.48
10.6
6.14
10.1
14.2
2.17
12.2
17.3
21.5
3.65
20.0
25.2
27.2
5.87
24.3
29.8
30.8
7.02
incorporate the effect of diameter on the
ACF efficacy. Setting a standard using
this approach could also make it easier
for larger diameter fans to meet the
standard and more difficult for smaller
diameter fans to meet the standard. DOE
recognizes that there is generally a
linear relationship between efficacy in
CFM/W and fan diameter. DOE notes
that it is additionally considering setting
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efficacy standards for axial ACFs as a
linear function of diameter, similar to
the approach used for ceiling fans (see
10 CFR 430.32(s)(1)). To establish a
linear equation for efficacy as a function
of diameter, DOE may consider in the
final rule, for example, plotting
efficacies for each representative unit
versus the representative unit diameters
and determining a best-fit line through
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these points. The efficacy standard
would then change continuously as a
function of diameter. While this
approach would not align with the
approach used by agricultural fan
efficiency incentive programs, it might
better incorporate the effect of diameter
when setting standards for ACFs,
specifically for ACFs with diameters at
the periphery of the diameter range.
DOE requests feedback on whether
setting an ACF standard using discrete
efficacy values over a defined diameter
range appropriately represents the
differences in efficacy between axial
ACFs with different diameters, and if
not, would a linear equation for efficacy
as a function of diameter be appropriate.
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Input Power Estimation
In addition to determining efficacy
values associated with each EL, DOE
also developed estimates of input power
associated with each EL. These input
power estimates were used in the LCC
and PBP analyses, discussed in section
IV.F. For each representative unit, DOE
developed input power versus efficacy
curves based on the data in the updated
ACF database and then estimated the
input powers associated with each
efficiency level. Further details on
DOE’s methodology for estimating input
powers are discussed in chapter 5 of the
NOPR TSD.
d. Cost Analysis
In this section, DOE discusses its
approach to estimating MPCs for ACFs
in this NOPR and discusses comments
relating to its cost analysis in the
October 2022 NODA. As discussed in
section IV.C.1.d, the cost analysis
portion of the engineering analysis is
conducted using physical teardowns,
catalog teardowns, price surveys, or a
combination of these approaches. In the
case of ACFs, DOE conducted its
analysis using physical teardowns,
which involve deconstructing
equipment and recording every part and
material used to make them. The
resulting bill of materials (‘‘BOM’’)
provided the basis for DOE’s MPC
estimates. DOE builds these MPCs based
on the cumulative estimated cost of
materials, labor, depreciation, and
overhead for each equipment. Further
details on these cost inputs can be
found in chapter 5 of the NOPR TSD.
To support the October 2022 NODA,
DOE estimated the MPCs of unhoused
and housed ACFs across all efficiency
levels and representative diameters
using data gathered from teardowns of
nine ACFs. 87 FR 62038, 62052. In the
October 2022 NODA, DOE assumed that
all ACFs were manufactured in China
and that all materials and parts were
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sourced from China. DOE used the
BOMs developed for each ACF and
catalog teardowns to estimate MPCs for
baseline ACFs. DOE then used
incremental MPCs estimated for each
design option to estimate MPCs for
higher efficiency levels. Id.
DOE made several updates to its MPC
estimation approach pertaining to axial
ACFs in this NOPR. First, DOE adjusted
how it considered ACF housings
compared to the October 2022 NODA.
As discussed in section IV.A.1.b, DOE
considered air circulating axial panel
fans, box fans, cylindrical ACFs, and
unhoused ACFHs under the axial ACFs
class. To account for the different
housing configurations used in these
four subcategories, DOE developed
separate MPC estimates for housed
ACFs with panel housing, housed ACFs
with cylindrical housing, and unhoused
ACFHs. DOE assumed that the costs of
box housing and panel housing were
comparable; therefore, DOE did not
generate separate MPC estimates for
ACFs with box housing. DOE averaged
the MPCs of air circulating axial panel
fans (and box fans), cylindrical ACFs,
and unhoused ACFHs to estimate an
overall MPC for axial ACFs. DOE did
not include the cost of mounting gear,
casters, or wheels in its MPC estimates
for any equipment class because these
features do not affect the efficacy of an
ACF. Second, based on information
received during confidential
manufacturer interviews and further
review of the ACF market, DOE updated
its assumptions about manufacturing
location and the source of purchased
parts for this NOPR. Specifically, DOE
concluded that most ACFs are made in
the United States and that most ACF
manufacturers source parts from
suppliers in the United States and
abroad. DOE understands that there are
variations between OEMs in the ACF
industry and chose production factors
and modeling methods to reflect the
range of OEMs. Further details on the
development of the MPC estimates for
axial ACFs can be found in chapter 5 of
the NOPR TSD.
DOE did not evaluate housed
centrifugal ACFs in the October 2022
NODA. To develop the MPC estimates
for housed centrifugal ACFs, DOE
performed teardowns on three housed
centrifugal ACFs and created BOMs for
each. DOE assumed that all housed
centrifugal ACFs are manufactured in
China and that all parts were purchased
in China based on its review of the
housed centrifugal market. DOE used
these BOMs and catalog teardowns to
estimate MPCs for housed centrifugal
ACFs. Further details of the
development of the MPC estimates for
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housed centrifugal ACFs can be found
in chapter 5 of the NOPR TSD.
In the October 2022 NODA, DOE
assumed that motors included in ACFs
are purchased parts and determined the
incremental MPCs associated with
changing from a split-phase motor to a
low-efficiency PSC motor, highefficiency PSC motor, or ECM using data
in its internal parts database. 87 FR
62038, 62053. DOE did not have
sufficient pricing information for splitphase motors, so DOE approximated the
split-phase motor MPC using prices for
shaded-pole motors for the October
2022 NODA. Id. DOE estimated lowefficiency PSC motor MPCs by
developing a best-fit line for motor price
as a function of motor power and used
this line to estimate low-efficiency PSC
motor MPCs at the representative motor
powers. DOE estimated high-efficiency
PSC motor MPCs by determining the
95th percentile PSC motor MPC of the
data it had available for each
representative motor power and
establishing a best-fit line for the 95th
percentile MPCs as a function of motor
power. DOE estimated ECM MPCs by
establishing a best-fit line for the MPCs
of ECMs as a function of motor power.
87 FR 62038, 62053. Id.
In response to the October 2022
NODA, NEMA commented that DOE’s
estimated motor costs were lower than
actual motor costs. NEMA further stated
that the cost of motors for commercial
applications would generally be lower
than those for industrial applications.
(NEMA, No. 125 at p. 6) In response to
this feedback, DOE reevaluated its
motor costs for this NOPR. DOE’s
research indicates that most ACFs are
sold in higher volumes, which suggests
a commercial market, rather than an
industrial market. In general, DOE finds
that industrial equipment is sold in
lower volumes and is manufactured for
specific applications, and DOE has not
observed that ACFs are typically sold or
manufactured in this way. Therefore,
DOE did not consider a separate MPC
for industrial ACFs in this NOPR. DOE
reviewed market information for fan
motors and determined current fan
motor sales prices. As such, DOE
believes that its updated motor costs are
more representative of the current fan
motor market than those estimated in
the October 2022 NODA.
In this NOPR, DOE also reevaluated
how it estimated motor costs. For both
low-efficiency PSC motors and highefficiency PSC motors, DOE identified
specific PSC fan motors and used the
costs of these motors to estimate MPCs.
Rather than using a single motor cost,
DOE determined a weighted-average
motor cost at each hp in its updated
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ACF database. As discussed in section
IV.C.2.c, DOE determined the
percentage of motor hp values in the
updated ACF database for each
representative unit. DOE used these
percentages and the MPCs determined
for each motor type to calculate the
weighted-average motor MPCs for each
representative unit. Further details of
DOE’s modeling of ACF motor costs can
be found in chapter 5 of the NOPR TSD.
Additionally, as discussed in section
IV.C.2.c of this NOPR, DOE received
feedback from NEMA and AMCA that
changing to a more-efficient motor
could also require changes to fan design.
Specifically, NEMA commented that
changing ACF motor efficiencies could
require the use of a larger, heavier motor
and could therefore require other design
changes to the fan. (NEMA, No. 125 at
p. 2) AMCA stated that replacing a
motor with a more-efficient motor may
result in the need for aerodynamic
redesign or redesign of a fan’s mounting
and supports because of differences in
motor size, shape, or weight. (AMCA,
No. 132 at p. 12)
To evaluate these concerns, DOE
estimated costs to redesign an ACF if a
larger motor replaced a smaller motor.
DOE evaluated the effects of motor
volume and motor weight when
considering a change from a smaller
motor to a larger motor. DOE found
during ACF teardowns that there is
sufficient space for an increase in motor
volume without needing to redesign
other fan components, such as housing
or safety guards. Therefore, DOE
assumed that the only redesign required
for an ACF when switching to a larger
motor would be to increase the weight
of the motor supports to accommodate
an increased motor weight, which is
consistent with what DOE has observed
in teardowns. DOE used data gathered
during ACF teardowns to approximate a
relationship between motor weight and
the cost of motor support materials.
DOE used this relationship to estimate
the increase in cost that would be
expected for a given increase in motor
weight. DOE found that even for a 100percent increase in motor weight, which
DOE believes is highly conservative,
motor support costs increased fan MPC
by 1.5 percent or less. Therefore, DOE
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has tentatively concluded that
additional material costs would be
minimal if a manufacturer incorporated
a heavier motor into an ACF.
For this NOPR, DOE evaluated belt
drives and low-efficiency PSC motors as
the baseline design options, as
discussed in section IV.C.2.c. To
determine the baseline costs, DOE first
determined the cost of a baseline ACF
without a motor or transmission (‘‘bareshaft ACF’’) for each representative unit.
Then, DOE added the costs determined
for a belt drive and a low-efficiency PSC
motor to the base-shaft ACF to calculate
the MPC of the baseline ACF for each
representative unit. DOE did not find a
significant difference in MPC between
belt drives associated with different
motor hp, so DOE chose a single belt
drive cost for each representative unit.
Further details on belt drive costs and
baseline MPCs can be found in chapter
5 of the NOPR TSD.
For this NOPR, DOE assigned a directdrive transmission as the design option
for EL 1. DOE assumed that a change
from a belt-drive transmission to a
direct-drive transmission would involve
the removal of the belt drive with no
other adjustments to the ACF.
Therefore, for the 36-in. and 52-in. axial
ACF representative units, DOE
estimated the cost associated with this
design option by subtracting the belt
drive MPC from the baseline MPC. For
the 24-in. axial ACF and housed
centrifugal ACF representative units,
DOE set the EL 1 MPC equal to the
baseline MPC.
DOE assigned a high-efficiency PSC
motor as the ACF design option for EL
2 in this NOPR. For all equipment
classes, DOE determined the EL 2 MPC
by adding the estimated cost difference
between a high-efficiency PSC motor
and a low-efficiency PSC motor to the
EL 1 MPC. The MPCs DOE estimated for
low-efficiency PSC motors and highefficiency PSC motors are included in
chapter 5 of the NOPR TSD.
DOE associated EL 3, EL 4, and EL 5
in this NOPR with three different levels
of aerodynamic redesign. In the October
2022 NODA, DOE defined a single
aerodynamic redesign level at max-tech.
DOE assumed that the redesign,
reengineering, and new equipment that
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could be required for the aerodynamic
redesign would result in a significant
one-time conversion cost, such that
aerodynamic redesigns would have a
significantly greater impact on
conversion costs than they would on
MPCs. Therefore, DOE assumed that the
change in MPC associated with the
aerodynamic redesign was negligible
compared to the conversion costs
incurred by the manufacturer to
implement this redesign. In this NOPR,
DOE assumed that MPCs for EL 3, EL 4,
and EL 5 were equal to the MPC for EL
2 for all equipment classes. DOE
assumed that the complexity of ACF
redesign would increase as ELs increase;
therefore, DOE estimated that
manufacturer investment in engineer
time and equipment would increase
with each EL. Information on DOE’s
estimated conversion costs can be found
in section IV.J.2.c of this NOPR and in
chapter 12 of the NOPR TSD.
DOE defined an ECM as the design
option for EL 6. For all equipment
classes, DOE determined the EL 6 MPC
by adding the estimated cost delta
between an ECM and a high-efficiency
PSC motor to the EL 5 MPC. The MPCs
DOE estimated for high-efficiency PSC
motors and ECMs can be found in
chapter 5 of the NOPR TSD.
To account for manufacturers’ nonproduction costs and profit margin, DOE
applies a multiplier (the manufacturer
markup) to the MPC. The resulting
manufacturer selling price (‘‘MSP’’) is
the price at which the manufacturer
distributes a unit into commerce. DOE
developed an average manufacturer
markup by examining the annual
Securities and Exchange Commission
(SEC) 10–K reports filed by publicly
traded manufacturers primarily engaged
in air circulating fan manufacturing.
DOE then adjusted these manufacturer
markups based on feedback
manufacturers during interviews. DOE
used a manufacturer markup of 1.5 in
this NOPR analysis. The manufacturer
markups used in this NOPR are
discussed in more detail in section
IV.J.2.a of this document and in chapter
12 of the NOPR TSD. The MSPs
determined for ACFs are shown in Table
IV–14.
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Table IV-14 Estimated MSPs for ACF Equipment Classes and ELs
Representative
Unit
24-inch axial
ACF
36-inch axial
ACF
52-inch axial
ACF
11-inch housed
centrifugal
ACF
EL0
EL 1
EL2
EL3
EL4
EL5
EL6
$166.67
$166.67
$193.94
$193.94
$193.94
$193.94
$239.99
$412.43
$319.29
$346.68
$346.68
$346.68
$346.68
$396.86
$644.45
$549.53
$589.74
$589.74
$589.74
$589.74
$650.82
$119.70
$119.70
$169.49
$169.49
$169.49
$169.49
$216.09
3. Cost-Efficiency Results
The results of the engineering analysis
are reported as cost-efficiency data (or
‘‘curves’’) in the form of FEI versus MSP
(in dollars) for GFBs or efficacy versus
MSP for ACFs.
For GFBs, as discussed in section
IV.C.1.d, DOE developed baseline MSP
versus diameter curves and incremental
costs for each design option for each
equipment class. DOE used these
correlations to estimate the MSP at each
EL for each equipment class at all
nominal impeller diameters. As such,
each equipment class has multiple MSP
versus FEI curves representing the range
of impeller diameters that exist on the
market. As discussed in section
IV.C.1.b, the FEIs at each EL remain
constant for each equipment class,
regardless of impeller diameter. These
FEIs were developed by determining the
FEIs for the baseline equipment and
implementing design options above
baseline until all available design
options were employed (i.e., at the maxtech level). In contrast to the ACF
analysis which used MPCs, DOE
directly estimated MSPs for GFBs using
the AMCA sales database and
manufacturer fan selection software.
For ACFs, DOE developed curves for
each representative unit. The
methodology for developing the curves
started with determining the efficacy for
baseline equipment and the MPCs for
this equipment. Above the baseline,
DOE implemented design options until
all available design options were
employed (i.e., at the max-tech level).
To convert from MPCs to MSPs, DOE
applied manufacturer markups as
described in section 0.
Table IV–15 provides example costefficiency results from the GFB
engineering analysis for the axial inline
equipment class. Results are provided at
an impeller diameter of 15 in. and an
impeller diameter of 48 in.; however, as
noted previously, DOE applied the same
relative increases in MSP to obtain
results at all impeller diameters for
GFBs.
Table IV–16 contains example costefficiency results from the ACF
engineering analysis for the 24-in.
representative unit. As noted
previously, ACF results were not scaled
to all impeller diameters. Rather, the
cost-efficiency results in Table IV–16
are relevant to all ACFs with an
impeller diameter greater than or equal
to 12 in. and less than 36 in.
See chapter 5 of the NOPR TSD for
additional detail on the engineering
analysis and appendix 5A of the NOPR
TSD for complete cost-efficiency results.
Table IV-15 Axial PRV Example En2ineerin2 Results
EL
Design Option
0
1
2
3
4
5
Baseline
Blade change 1
Blade change 2
+ 1 Diameter increase
+2 Diameter increase
Aerodynamic
redesign 1
Aerodynamic
redesign 2
Aerodynamic
redesign 3
MSP at 48 inches
($2022)
$4 180
$6 144
$6,222
$5 106
$6,491
$6,222
1.25
$3,800
$6,222
1.49
$3,800
$6,222
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7
0.66
0.69
0.72
0.75
0.85
1.00
MSP at 24 inches
($2022)
$2 522
$3 751
$3,800
$2 733
$3,028
$3,800
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Table IV-16 Air Circulating Fan Engineering Results - Impeller Diameter~ 12 in.
and< 36 in.
EL
Design Options
Efficacy
(CFM/W)
MSP ($2022)
0
1
2
3
Baseline - Baseline Motor with Direct Drive*
2.98
$111.11
Baseline Motor with Direct Drive
2.98
$111.11
More Efficient Induction Motor, Direct Drive
3.18
$129.29
More Efficient Induction Motor, Direct Drive,
6.14
$129.29
Aerodynamic Redesign 1
4
More Efficient Induction Motor, Direct Drive,
12.2
$129.29
Aerodynamic Redesign 2
5
More Efficient Induction Motor, Direct Drive,
20.0
$129.29
Aerodynamic Redesign 3
6
ECM, Direct-Drive, Aerodynamic Redesign 3
24.3
$159.99
* EL0 is equivalent to ELI because DOE found that belt drives are uncommon for ACFs with an impeller
diameter< 36 inches.
The markups analysis develops
appropriate markups (e.g., retailer
markups, distributor markups,
contractor markups) in the distribution
chain and sales taxes to convert the
MSP estimates derived in the
engineering analysis to consumer prices,
which are then used in the LCC and PBP
analysis and in the manufacturer impact
analysis. At each step in the distribution
channel, companies mark up the price
of the product to cover business costs
and profit margin.
For GFBs, the main parties in the
distribution chain are OEMs,
distributors (including manufacturer inhouse distributors), and contractors.
DOE distinguished fan manufacturers
in-house by OEMs from other fans and
blowers and identified the distribution
channels and associated fraction of
shipments (i.e., percentage of sales
going through each channel) by
equipment class.
For ACFs, the main parties in the
distribution chain distributors
(including ACF manufacturer in-house
distributors) and contractors. In the
October 2022 NODA, DOE identified the
distribution channels and fraction of
shipments associated with each channel
based on feedback from manufacturer
interviews. 87 FR 62038, 62054. DOE
did not receive any comments on these
channels and relied on the same
distribution channels for this NOPR. In
addition, as discussed in section IV.F.5
of this document, DOE included a motor
or belt replacement as potential repairs
for ACFs. Therefore, DOE additionally
identified distribution channels
associated with the purchase of a
replacement motor or belt.
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DOE developed baseline and
incremental markups for each actor in
the distribution chain. Baseline
markups are applied to the price of
equipment 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.66
DOE relied on economic data from the
U.S. Census Bureau as well as data from
RS Means 67 to estimate average baseline
and incremental markups.
Chapter 6 of the NOPR TSD provides
details on DOE’s development of
markups for fans and blowers.
DOE seeks comment on the
distribution channels identified for
GFBs and ACFs and fraction of sales
that go through each of these channels.
E. Energy Use Analysis
The purpose of the energy use
analysis is to determine the annual
energy consumption of fans and blowers
at different efficiencies in representative
applications, and to assess the energy
savings potential of increased fan and
blower efficiency. The energy use
analysis estimates the range of energy
use of fans and blowers in the field (i.e.,
66 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
reasonably competitive markets, it is unlikely that
standards would lead to a sustainable increase in
profitability in the long run.
67 RS Means Electrical Cost Data 2023. Available
at: www.rsmeans.com.
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as they are actually used by consumers).
The energy use analysis provides the
basis for other analyses DOE performed,
particularly assessments of the energy
savings and the savings in consumer
operating costs that could result from
adoption of amended or new standards.
To characterize variability and
uncertainty, the energy use is calculated
for a representative sample of fan and
blower consumers. This method of
analysis, referred to as a Monte Carlo
method, is explained in more detail in
section IV.F of this document. Results of
the energy use analysis for each
equipment class group or representative
unit were derived from a sample of
10,000 consumers. This section presents
DOE’s approach to develop consumer
samples and energy use inputs that DOE
applied in the energy use analysis.
1. General Fans and Blowers
For GFBs, annual energy use depends
on the annual hours of operation,
operating pressure and airflow, and load
profile. It includes the electricity
consumed by the motor driving the fan,
as well as losses related to any belts and
motor controller (e.g., variable speed
drive or ‘‘VFD’’) included in the fan.
Sample of Consumers
DOE developed a consumer sample to
represent consumers of GFBs in the
commercial and industrial sectors. DOE
used the sample to determine fan and
blower annual energy consumption as
well as to conduct the LCC and PBP
analyses.
To develop this sample, DOE used
2012 sales data from AMCA
corresponding to 92,287 units sold
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(‘‘2012 AMCA sales data’’).68 The data
included information on the design
operating flow, operating pressure, and
shaft input power for which each fan
was purchased and representative of
fans sold as standalone equipment (i.e.,
not incorporated in another equipment).
In addition, to represent fans sold
incorporated in other equipment (i.e.,
embedded fans manufactured in-house
by OEMs or ‘‘OEM fans’’), DOE used
data specific to HVAC equipment in
which these fans are used to
characterize the fan impeller topology
(i.e., category code) typically used in
HVAC equipment and in the scope of
this analysis to identify the range of
operating flow, pressure, and shaft input
power specific to these fans. Based on
this information, DOE identified fan
models from the 2012 AMCA sales data
with the same equipment class, category
code and shaft input power. DOE used
these models to develop a sample
representative of OEM fans. DOE then
used sales data for the whole U.S.
market to develop weights for each fan
model and develop the fan consumer
sample (where each consumer is
assigned with a fan model and
associated fan equipment class, category
code, power bin, design operating flow,
operating pressure, and shaft input
power). Specifically, DOE developed the
weights such that for each equipment
class, the sample included the same
proportions of GFBs by market segment
(i.e., fans sold as standalone equipment
and OEM fans), category code, and
power bin as in the total U.S. market.
In addition, each consumer in the
sample was assigned a sector and a
configuration (i.e., direct or belt driven
and with or without VFD). The sector
determines the field use characteristics,
such as annual operating hours, load
profile, and equipment lifetimes as well
as the economic parameters (i.e.,
electricity prices and discount rates). To
estimate the percentage of consumers in
the industrial and commercial sectors,
DOE primarily relied on data from the
DOE–AMO report ‘‘U.S. Industrial and
Commercial Motor System Market
Assessment Report Volume 1:
Characteristics of the Installed Base’’
(‘‘MSMA report’’).69 To estimate the
percentage of consumers that operate a
3783
fan with or without belts, and with or
without VFDs, DOE relied on
information from manufacturer
interviews.
Annual Operating Hours
To develop distributions of annual
operating hours, DOE relied on
information from the MSMA report,
which provides distributions of annual
operating hours for fans used in the
commercial and industrial sector.
Load Profiles
DOE relied on the design flow and
pressure, associated shaft input power,
and fan configuration information of
each fan in the sample to characterize
the operating flow and pressure and
associated shaft input power. DOE
further relied on information from
manufacturer interviews to estimate the
share of fans that operate at constant
load or at variable load by equipment
class.70 Based on this information, DOE
estimated the percentage of fans
operating at variable load as shown in
Table IV–17.
For fans operating at constant load,
DOE reviewed information from the
MSMA report which indicates that the
majority of constant load fans operate at
or above 75 percent of the motor full
load.71 This indicates that constant load
fans primarily operate near the design
point. Therefore, in this NOPR, for both
the commercial and industrial sectors,
DOE assumed that all constant load fans
operate at the design point.72
For fans used at variable load, in the
commercial sector, DOE relied on
information previously provided by
AHRI to develop a variable load profile
(Docket No. EERE–2013–BT–STD–0006,
AHRI, No. 129, at p. 2). In the industrial
sector, DOE did not find any data to
characterize the typical load profile and
given the wide range of possible
applications, DOE assumed equal
weights at each of the considered load
points.73 DOE has tentatively
determined that while DOE has not
found data to characterize the field
operating loads of GFBs used in the
industrial sector, using a weightedaverage across multiple load points and
weighting all those points equally is a
more representative load profile when
compared to calculating the efficiency at
a single point.
68 Air Movement and Control Association
(AMCA). 2012 Detailed Confidential Fan Sales Data
from 17 Manufacturers. November 2014.
69 Prakash Rao et al., ‘‘U.S. Industrial and
Commercial Motor System Market Assessment
Report Volume 1: Characteristics of the Installed
Base,’’ January 12, 2021. Available at: doi.org/
10.2172/1760267.
70 DOE also reviewed information from the
MSMA report. However, the information provided
in the MSMA report did not differentiate fans by
equipment class, and DOE therefore relied on the
information collected during manufacturer
interviews instead.
71 See: motors.lbl.gov/analyze/kb-0q19q1M.
72 Based on typical motor sizing practices, which
suggest a motor horsepower equal to 1.2 (i.e., the
design fan shaft input power), DOE believes that the
design point represents 1/1.2 = 83 percent of the
motor full load. The 1.2 sizing factor is based on
input from the Working Group (Docket No. EERE–
2013–BT–STD–0006; No. 179, Recommendation
#10 at p. 6).
73 The load profile is represented by four load
points defined as 25, 50, 75, and 100 percent of the
design flow as well as the percentage annual
operating hours spent at each of these points (i.e.,
weights).
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Table IV-17: Load characterization by Equipment Class
Equipment Class
Variable Load Constant Load
Axial Inline Fans
49.1%
50.9%
Axial Panel Fans
22.6%
77.4%
Centrifugal Housed Fans
40.1%
59.9%
Centrifugal Inline Fans
15.0%
85.0%
Centrifugal Unhoused Fans
65.2%
34.8%
Axial Power Roof Ventilator - Exhaust
23.0%
77.0%
Centrifugal Power Roof Ventilator - Exhaust
23.0%
77.0%
Centrifugal Power Roof Ventilator - Supply
34.0%
66.0%
Radial Housed Fans
0.3%
99.7%
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NEEA commented that the
assumptions made for the load profiles
presented in the 2016 NODA LCC are
outdated and that DOE should collect
additional information on load profiles
for fans and blowers.74 NEEA
recommended that DOE collect end-user
data, use information on fan loading
information from the MSMA report, or
reach out to fan operation professionals
in order to update DOE’s load profile
assumptions. (NEEA, No. 129 at p. 7)
DOE reviewed the energy use data
provided in the MSMA report. However,
DOE notes that the load fraction
provided in the MSMA report are in
terms of average fraction of motor full
load output power and are not
expressed in terms of percentage time
spent at a given percentage of design
flow.75 Therefore, DOE could not use
this information to develop the load
profiles for variable load fans. In
addition, DOE did not receive any data
on load profile in response to the
February 2022 RFI.76 Instead, as
previously stated, in this NOPR, for fans
used in the commercial sector with
VFDs, DOE relied on information
previously provided by AHRI to develop
a variable load profile in the commercial
sector (Docket No. EERE–2013–BT–
STD–0006, AHRI, No. 129, at p. 2). In
the industrial sector, as stated
previously, DOE did not find any
information to help characterize the
load profile and assumed equal weights
at each of the considered load points.
In response to the October 2022
NODA, NEEA commented that DOE
should account for different power load
relationships associated with different
fan control methods. NEEA stated that
fans can operate below 100 percent of
the design flow. NEEA noted that DOE
captured this operation in its 2016
NODA analysis through the use of load
profiles.77 NEEA noted that in its
previous annual energy use calculation,
DOE relied on the affinity laws as
representative of the power load
74 NEEA cited: 2016 NODA Life-Cycle Cost (LCC)
and Payback Period (PBP) Analyses Spreadsheet,
Tab ‘‘Sectors and Applications,’’ Notes cell B49.
Available at: www.regulations.gov/document/EERE2013-BT-STD-0006-0190.
75 See for example: motors.lbl.gov/analyze/30819.
76 DOE notes that although the February 2022 RFI
did not specifically request feedback on such load
profiles, DOE stated that it received written
comments from the public on any subject within
the scope of this document (including those topics
not specifically raised in the RFI), as well as the
submission of data and other relevant information.
87 FR 7048.
77 NEEA cited the November 2016 NODA LifeCycle Cost (LCC) and Payback Period (PBP)
Analyses Spreadsheet. Available at:
www.regulations.gov/document/EERE-2013-BTSTD-0006-0190.
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relationship for all fans, regardless of
the control method. NEEA added that
while the installation of variable speed
control can dramatically reduce a fan’s
energy consumption, in DOE’s analysis
its power load relationship (and
therefore energy use) is assumed to be
equal to that of the same fan operating
with a more consumptive control
strategy. NEEA commented that using
the fan laws is an unreasonable proxy
for other power load relationships.
Instead, NEEA commented that various
equipment and appurtenances allow
fans to meet reduced flow rates, and the
relationship between the required flow
and a fan’s power draw is unique to
each equipment or ‘‘control method’’
(e.g., the use of outlet vanes, disc
throttle, inlet vanes, and controllable
pitch blades). NEEA provided further
examples of such relationships and
associated references.78 NEEA added
that the installation of a drive is often
considered an energy efficiency
opportunity for fan systems. NEEA
stated that the installation of VFDs has
been identified as the measure with the
largest savings opportunity for
industrial fans and the second largest
savings for commercial fans.79 NEEA
commented that the savings associated
with installing a VFD are directly
related to a more efficient power-load
relationship, and that assuming all load
control methods follow the fan laws
would understate the energy use of fans
without VFDs. Therefore, NEEA
commented that DOE should account
for the different power-load
relationships associated with different
load control methods and applying
different power-load relationships based
on the distribution of flow control
methods seen in the market. In addition,
NEEA recommended that DOE consider
the power-load relationship for fans
operating without a load control method
by developing ‘‘representative’’ fan
performance curves to model the energy
consumption of fans that do not have
load control. NEEA recommended that
DOE develop representative fan curves,
similar to those developed for the
energy use analysis in the December
78 Improving Fan System Performance: A
Sourcebook for Industry, Figure 2–20, Page 43. May
2014. Available at: www.energy.gov/sites/default/
files/2014/05/f16/fan_sourcebook.pdf; and The
Uniform Methods Project: Methods for Determining
Energy Efficiency Savings for Specific Measures.
Chapter 18: Variable Frequency Drive Evaluation
Protocol, Table 1, Page 12. Available at:
www.nrel.gov/docs/fy17osti/68574.pdf.
79 NEEA cited: U.S. Industrial and Commercial
Motor System Market Assessment Report Volume 3:
Energy Saving Opportunity, 7/2022, Figure 17 and
Figure 18. Available at: eta-publications.lbl.gov/
sites/default/files/u.s._industrial_and_commercial_
motor_system_market_assessment_report_volume_
3_energy_saving_opportunity_p_rao.pdf.
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2015 Pumps Final Rule,80 which would
enable DOE to account for fan-specific
performance. NEEA noted that this
performance curve method was used in
DOE’s first NODA 81 but was removed in
the second NODA.82 Lastly, NEEA
recommended that DOE utilize
published power load equations to
determine energy uses for fans with
non-VFD controls.83 (NEEA, No. 129 at
pp. 4–7)
As noted by NEEA, different
categories of controls result in different
energy savings, which do not always
follow the fan affinity laws. However,
based on the MSMA report, DOE
estimates that the majority of fans do
not have load control (88 percent), and
that the majority of fans with load
control utilize VFDs (9 percent), while
1 percent of fans with load control rely
on other categories of controls and
another 1 percent of fans had an
unknown configuration.84 Therefore, in
this NOPR, for fans with load control
(and operating at variable load) DOE
only considered VFDs as the primary
load control equipment and applied the
affinity laws when calculating the
resulting savings. For fans without load
control and operating at constant load,
as stated earlier, DOE believes the
majority of these fans operate near the
design point. In addition, although DOE
developed information on typical fan
curves as part of previous analysis as
noted by NEEA, the AMCA data did not
provide sufficient information to relate
the design point to a location on the fan
curve. Therefore, for constant load fans,
DOE was unable to utilize this
information in combination with the
2012 AMCA data to estimate the energy
use at a reduced flow and thus assumed
operation at the design point.85
80 NEEA referenced: 2015–12–30 Final Rule
Technical Support Document: Energy Efficiency
Program for Consumer Products and Commercial
and Industrial Equipment: Pumps. NEEA
commented that section 7.2.1.3 outlined the process
to develop representative performance curves.
Available at: www.regulations.gov/document/EERE2011-BT-STD-0031-0056.
81 NEEA cited: 2014–12–03 NODA Life-Cycle
Cost (LCC) Spreadsheet. Available at:
www.regulations.gov/document/EERE-2013-BTSTD-0006-0034.
82 See: 2015–04–21 NODA Life-Cycle Cost (LCC)
Spreadsheet. Available at: www.regulations.gov/
document/EERE-2013-BT-STD-0006-0060.
83 NEEA referenced this study: The Uniform
Methods Project: Methods for Determining Energy
Efficiency Savings for Specific Measures. Chapter
18: Variable Frequency Drive Evaluation Protocol,
Table 1, Page 12. Available at: www.nrel.gov/docs/
fy17osti/68574.pdf.
84 See: motors.lbl.gov/analyze/4b-0j0Bd0.
85 As noted by NEAA, DOE updated its
methodology between its first NODA and second
NODA in order to enable the utilization of the
AMCA 2012 data which represented thousands of
fan selection data. While the first NODA relied on
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Drive Components
The fan energy use calculation
includes motor, VFD (if present) and
transmission (i.e., belt) losses. To
represent the performance of the motor
and belts, DOE used the mathematical
models from the DOE test procedure
(See 87 FR 27312) which assumes the
motor is compliant with the upcoming
DOE standard for electric motors at 10
CFR 431.25 and characterizes belt
efficiency based on a model published
in AMCA 214–21 as referenced in the
DOE test procedure.86 To represent the
performance of the motor combined
with a VFD, DOE used the mathematical
models from section 6.4 of AMCA 214–
21 which is representative of typical
motor and VFD combinations, as
referenced in the DOE test procedure.
DOE further relied on information from
manufacturer interviews to estimate the
share of belt-driven fans.
2. Air-Circulating Fans
DOE calculated the energy use of
ACFs by combining ACF input power
consumption from the engineering
analysis with annual operating hours.
For each consumer in the sample, DOE
associates a value of ACF annual
operating hours drawn from statistical
distributions as described in the
remainder of this section.
Sample of Consumers
In the October 2022 NODA, DOE
included commercial, industrial, and
agricultural applications in the energy
use analysis of ACFs with input power
greater than or equal to 125 W. 87 FR
62038, 62056. DOE did not receive any
comments on this approach.
Accordingly, in the NOPR, DOE created
a sample of 10,000 consumers for each
representative unit to represent the
range of air-circulating fan energy use in
the commercial, industrial, and
agricultural sectors.
Annual Operating Hours
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In the October 2022 NODA, 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
representative units and representative fans curves,
as well as confidential data from a single
manufacturer to develop distributions of operating
points, the second NODA relies on fan selection
data and sales data from 17 manufacturers to inform
the LCC sample and location of the operating
points.
86 ANSI/AMCA Standard 214–21 ‘‘Test Procedure
for Calculating Fan Energy Index (FEI) for
Commercial and Industrial Fans and Blowers.’’
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Analysis.87 To represent a range of
possible operating hours around this
representative value, DOE relied on 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). 87 FR 62038, 62056–
62057
In response to the October 2022
NODA, ebm-papst stated that the usages
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)
AMCA commented that ACFs and
ceiling fans in commercial and
industrial buildings serve similar
functions during warmer months, which
is to provide a low-energy method for
cooling. AMCA added however that
ACFs are often not used during cooler
months, while ceiling fans are either
used in a reversed direction mode or
run at a lower speed. Therefore, only
ceiling fan usage during warmer months
can be used as a proxy for ACF usage,
and the annual operating hours of
ceiling fans will be greater than those of
ACFs. AMCA added that ACFs used for
horticulture applications may have
different usage hours than that of other
ACFs or ceiling fans. (AMCA, No. 132
at p. 13)
DOE established the annual operating
hours as the product of the daily
operating hours and the number of
operating days per year. In line with the
information presented in the October
2022 NODA, for all ACFs except
centrifugal housed ACFs, DOE assumed
average daily operating hours of 12
hours per day. To reflect the variability
in usage by application as noted by
ebm-papst, DOE relied on a uniform
distribution between 6 and 18 hours per
day. For centrifugal housed ACFs, DOE
relied on lower operating hours as these
fans are primarily used for carpet drying
applications and are less likely to
operate 12 hours per day on average.
DOE did not receive any feedback on
daily operating hours and assumed
average daily operating hours of 6 hours
per day. To represent a range of possible
operating hours around this
representative value, DOE relied on a
uniform distribution between 0 hours
per day and 12 hours per day.
With the exception of centrifugal
housed ACFs, ACFs are primarily used
for cooling purposes in the commercial
sector (e.g., to cool people in loading
docks, warehouses, gyms, etc.), in the
87 See
section 7.4.2 of Chapter 7 of the Ceiling Fan
Preliminary Analysis Technical Support Document.
Available at: www.regulations.gov/document/EERE2021-BT-STD-0011-0015.
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3785
industrial sector, (e.g., to cool people in
factory workstations, etc.), and in the
agricultural sector (e.g., to reduce
livestock heat stress). To establish the
number of annual operating days for
ACFs other than centrifugal housed
ACFS, and to reflect AMCA’s note that
these ACFs are not used in cooler
months, DOE relied on weather data to
estimate a distribution of annual
operating days for ACFs. While some
ACFs may also be used for non-cooling
purposes,88 DOE did not find any data
to establish the market share of such
applications and assumed all ACFs are
used for cooling purposes, as this is the
primary application of ACFs. Based on
input from manufacturer interviews,
DOE further estimated that 20 percent of
ACFs are used in the commercial sector,
20 percent in the industrial sector, and
60 percent in the agricultural sector. In
the case of centrifugal housed ACFs,
which are primarily used for carpet
drying, DOE assumed these are
exclusively used in the commercial
sector and throughout the year.
Input Power
In the October 2022 NODA, DOE
described that 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 and assuming
an equal amount of time spent at each
tested speed. 87 FR 62038, 62055–
62057. Consistent with the May 2023 TP
Final Rule, DOE estimates that these
fans are primarily used at high speed
and assumed operation at high speed
only.
Chapter 7 of the NOPR TSD provides
details on DOE’s energy use analysis for
fans and blowers.
DOE seeks comment on the overall
methodology and inputs used to
estimate GFBs and ACFs energy use.
Specifically, for GFBs, DOE seeks
feedback on the methodology and
assumptions used to determine the
operating point(s) both for constant and
variable load fans. For ACFs, DOE
requests feedback on the average daily
operating hours, annual days of
operation by sector and application, and
input power assumptions. In addition,
DOE requests feedback on the market
share of GFBs and ACFs by sector (i.e.,
commercial, industrial, and
agricultural).
88 This include fans that are also used for cooling
and may be left on during cooler months as they
are also used for non-cooling applications (e.g.,
ACFs used for reducing foul odors/manure gases/
moisture/dust, drying, cooling machinery).
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F. Life-Cycle Cost and Payback Period
Analyses
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DOE conducted LCC and PBP
analyses to evaluate the economic
impacts on individual consumers of
potential energy conservation standards
for fans and blowers. The effect of new
or amended energy conservation
standards on individual consumers
usually involves a reduction in
operating costs and an increase in
purchase cost. DOE used the following
two metrics to measure consumer
impacts:
• The LCC is the total consumer
expense of the equipment over the life
of that equipment, 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 equipment.
• The PBP is the estimated amount of
time (in years) it takes consumers to
recover the increased purchase cost
(including installation) of more efficient
equipment 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 fans and blowers in the
absence of new or amended energy
conservation standards. The PBP for a
given efficiency level is also measured
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relative to the no-new-standards case
efficiency distribution.
For each considered TSL in each
equipment class, DOE calculated the
LCC and PBP for a nationally
representative set of consumers. As
stated previously, DOE developed
consumer samples from a variety of data
sources as described in section IV.F of
this document. For each sample
consumer, DOE determined the energy
consumption for the fans and blowers
and the appropriate energy price. By
developing a representative sample of
consumers, the analysis captured the
variability in energy consumption and
energy prices associated with the use of
fans and blowers.
Inputs to the calculation of total
installed cost include the cost of the
equipment—which includes MPCs,
manufacturer markups (including the
additional manufacturer conversion cost
markups where appropriate), retailer
and distributor markups, and sales
taxes—and installation costs. Inputs to
the calculation of operating expenses
include annual energy consumption,
energy prices and price projections,
repair and maintenance costs,
equipment lifetimes, and discount rates.
DOE created distributions of values for
equipment lifetime, discount rates, and
sales taxes, with probabilities attached
to each value, to account for their
uncertainty and variability.
The computer model DOE uses to
calculate the LCC 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 fan and
blower user samples. The model
calculates the LCC for equipment at
each efficiency level for 10,000
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consumers per simulation run and
equipment class. 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 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.
DOE calculated the LCC and PBP for
consumers of fans and blowers as if
each were to purchase new equipment
in the expected year of required
compliance with new or amended
standards. New standards would apply
to fans and blowers manufactured 5
years after the date on which any new
standard is published. (42 U.S.C
6316(a); 42 U.S.C. 6295(l)(2)) At this
time, DOE estimates publication of a
final rule in the second half of 2024.
Therefore, for the purposes of its
analysis, DOE used 2030 as the first full
year of compliance with any new
standards for fans and blowers.
Table IV–18 Summary of Inputs and
Methods for the LCC and PBP Analysis*
summarizes the approach and data DOE
used to derive inputs to the LCC and
PBP calculations. The subsections that
follow provide further discussion.
Details of the spreadsheet model, and of
all the inputs to the LCC and PBP
analyses, are contained in chapter 8 of
the NOPR TSD and its appendices.
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Table IV-18 Summary of Inputs and Methods for the LCC and PBP Analysis*
Inputs
Equipment Cost
Installation Costs
Annual Energy Use
Energy Prices
Energy Price Trends
Repair and
Maintenance Costs
Equipment Lifetime
Discount Rates
Compliance Date
Source/Method
Derived by multiplying MPCs by manufacturer (including a
manufacturer conversion markup where appropriate) and distribution
channel markups and sales tax. Used historical data to derive a price
index to project product costs.
Assumed no change with efficiency level, except for PRV s where there
.
.
.
.
1s an mcrease m size.
Fan electrical input power multiplied by the annual operating hours at
the considered operating point(s);
Variability: By sector and application.
Electricity: Based on EEi data for 2022.
Variability: By sector.
Based onAEO2023 price projections.
GFBs: Assumed no change with efficiency level.
ACFs: Relied on different belt and motor repair costs by EL.
Average for GFBs: 16.0 years.
Average for ACFs: 6.3 years.
Calculated as the weighted average cost of capital for entities
purchasing fans. Primary data source was Damodaran Online.
2030 (first full year)
In response to the October 2022
NODA, AMCA commented that DOE
should refer to interviews with
individual manufacturers for feedback
on the inputs and considered methods
used for the LCC and PBP analyses.
(AMCA, No. 132 at p. 14) As noted
throughout this section, DOE relied on
input from manufacturer interviews
where available.
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1. Equipment Cost
To calculate equipment costs, DOE
multiplied the MSPs developed in the
engineering analysis by the distribution
channel markups described previously
(along with sales taxes). DOE used
different markups for baseline
equipment and higher-efficiency
equipment because DOE applies an
incremental markup to the increase in
MSP associated with higher-efficiency
equipment. Further, as described in
section IV.C of this document, at ELs
with associated manufacturer
conversion costs, DOE applied a
manufacturer conversion markup when
calculating the equipment price of redesigned units.
Economic literature and historical
data suggest that the real costs of many
products may trend downward over
time according to ‘‘learning’’ or
‘‘experience’’ curves. Experience curve
analysis implicitly includes factors such
as efficiencies in labor, capital
investment, automation, materials
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prices, distribution, and economies of
scale at an industry-wide level.
For GFBs, to develop an equipment
price trend for the NOPR, DOE derived
an inflation-adjusted index of the
Producer Price Index (PPI) for industrial
and commercial fans and blowers
equipment over the period 2003–2022.89
These data show a general price index
increase from 2003 through 2009, a
slower growth trend over the period
2009–2020, and a high increase since
2020. However, the outbreak of COVID–
19 pandemic caused immense
uncertainties in global supply chain and
international trade resulting in price
surges across all sectors since 2020.
DOE believes that the extent to which
these macroeconomic trends will
continue in the future is very uncertain.
Therefore, DOE used a constant price
assumption as the default trend to
project future fan prices. Thus, for
GFBs, prices projected for the LCC and
PBP analysis are equal to the 2022
values for each efficiency level in each
equipment class.
For ACFs, DOE did not find PPI data
specific to ACFs, and instead, DOE
adopted a component-based approach to
develop a price trend by identifying
ACF components most likely to undergo
a price variation over the forecast
period. Using this approach, the price
trend only applies to the cost of the
component and not to the total cost of
the ACF. For EL0 through EL5, which
are efficiency levels that assume AC
induction motors, DOE determined that
ACF motors are the most likely
component to undergo price variation
over time and analyzed long-term trends
in the integral and fractional
horsepower motors PPI series.90 The
deflated price index for integral and
fractional horsepower motors was found
to align with the copper, steel, and
aluminum deflated price indices. DOE
believes that the extent to which these
commodity price trends will continue in
the future is very uncertain and
therefore does not project commodity
prices. In addition, the deflated price
index for fractional horsepower motors
was mostly flat during the entire period
from 1967 to 2020. Therefore, DOE
relied on a constant price assumption as
the default price factor index to project
future ACF prices at EL 0 through EL 5.
At EL 6, which assumes an ECM motor,
DOE did not find any historical data
specifically regarding ECM motors. For
its analysis, DOE assumed that the
circuitry and electronic controls
associated with ECM motors would
potentially be the most affected by price
trends driven by the larger electronics
industry as a whole. DOE obtained PPI
data on ‘‘Semiconductors and related
89 Series ID PCU3334133334132. Available at:
www.bls.gov/ppi/.
90 Series ID PCU3353123353123 and
PCU3353123353121. Available at: www.bls.gov/ppi/.
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* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8
of the NOPR TSD.
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device manufacturing’’ 91 between 1967
and 2022 to estimate the historic price
trend in electronic components. These
data show a price decline over the entire
period. Therefore, DOE applied a
decreasing price trend for the controls
portion of the ECM price. See chapter 8
for more details on the price trends.
DOE requests feedback on the price
trends developed for GFBs and ACFs.
2. Installation Cost
Installation cost includes labor,
overhead, and any miscellaneous
materials and parts needed to install the
equipment.
For GFBs, DOE found no evidence
that installation costs would be
impacted with increased efficiency
levels and did not include installation
costs in its analysis, except at efficiency
levels where an increase in size is
assumed (i.e., for PRVs). In this case,
DOE incorporated higher installation
(i.e., shipping) costs due to the change
in size.
For ACFs, DOE stated in the October
2022 NODA that it found no evidence
that installation costs would be
impacted with increased efficiency
levels and, as a result, DOE was not
planning on including installation costs
in the LCC. 87 FR 62038, 62058. DOE
did not receive any comments to the
October 2022 NODA related to
installation costs and continued with
this approach for ACFs.
DOE requests feedback on the
installation costs developed for GFBs
and on whether installation costs of
ACFs may increase at higher ELs.
3. Annual Energy Consumption
For each sampled consumer, DOE
determined the energy consumption for
a fan at different efficiency levels using
the approach described previously in
section IV.E of this document.
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4. Energy Prices
Because marginal electricity prices
more accurately capture the incremental
savings associated with a change in
energy use from higher efficiency, they
provide a better representation of
incremental change in consumer costs
than average electricity prices.
Therefore, DOE applied average
electricity prices for the energy use of
the equipment purchased in the nonew-standards case, and marginal
electricity prices for the incremental
change in energy use associated with
the other efficiency levels considered.
DOE derived electricity prices in 2022
using data from EEI Typical Bills and
91 Series ID: PCU334413334413. Available at
www.bls.gov/ppi/.
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Average Rates reports. Based upon
comprehensive, industry-wide surveys,
this semi-annual report presents typical
monthly electric bills and average
kilowatt-hour costs to the customer as
charged by investor-owned utilities. For
the commercial and industrial sector,
DOE calculated electricity prices using
the methodology described in Coughlin
and Beraki (2019).92
DOE’s 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 analysis. For fans
and blowers, DOE considered sectorspecific electricity prices. See chapter 8
of the NOPR TSD for details.
To estimate energy prices in future
years, DOE multiplied the 2022 energy
prices by the projection of annual
average price changes from the
Reference case in AEO2023, which has
an end year of 2050.93 To estimate price
trends after 2050, the 2050 prices were
held constant.
5. Maintenance and Repair Costs
Repair costs are associated with
repairing or replacing equipment
components that have failed in an
appliance; maintenance costs are
associated with maintaining the
operation of the equipment. Typically,
small incremental increases in
equipment efficiency entail no, or only
minor, changes in repair and
maintenance costs compared to baseline
efficiency equipment.
For GFBs, DOE found no evidence
that maintenance and repair costs
would be impacted with increased
efficiency levels. Therefore, because
DOE expresses results in terms of LCC
savings, DOE did not account for
maintenance and repair costs in the
LCC.
For ACFs, in the October 2022 NODA,
DOE stated that it did not find any
information supporting changes in
maintenance costs as a function of
efficiency. 87 FR 62038, 62058. DOE did
not receive any comments in response
to the October 2022 NODA related to
maintenance costs; DOE continues to
believe these do not vary by efficiency
and did not include maintenance costs
in its analysis.
92 Coughlin, K. and B. Beraki. 2019. Nonresidential Electricity Prices: A Review of Data
Sources and Estimation Methods. Lawrence
Berkeley National Lab. Berkeley, CA. Report No.
LBNL–2001203. Available at: ees.lbl.gov/
publications/non-residential-electricity-prices.
93 EIA. Annual Energy Outlook 2023 with
Projections to 2050. Washington, DC. Available at:
www.eia.gov/forecasts/aeo/ (last accessed June 6,
2023).
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In the October 2022 NODA, DOE
identified the motor replacement as a
potential repair for ACFs. DOE
requested feedback on its assumptions
about repair practices of ACFs. 87 FR
62038, 62058.
In response, AMCA commented that
belt replacement could be the only
significant maintenance or repair
necessary for ACFs. AMCA added that
DOE should reference manufacturer
interviews for further information.
AMCA added that ACFs are often used
in environments with harsher
conditions than other fans and
experience higher temperatures, higher
moisture content, higher particulate
concentrations, and more power source
fluctuations than do other fans. Because
of this, AMCA stated that ACF repairs
and replacements are more frequent
than for other fans. (AMCA, No. 132 at
pp. 14–15)
For ACFs, DOE found no evidence
that maintenance costs would be
impacted with increased efficiency
levels and did not include maintenance
costs in its analysis. However, DOE did
include repair costs associated with belt
repair at EL 0, which represents belt
driven ACFs as appropriate. In addition,
although stakeholder feedback did not
indicate the possibility of a motor repair
for ACFs, DOE identified several ACF
manufacturers offering replacement
motors. DOE assumed such repair is not
frequent as it was not identified as a
potential repair by stakeholders.
Therefore, DOE assumed that only 5
percent of ACFs include a motor repair
and estimated the repair costs
associated with motor replacement. In
order to calculate these repair costs,
DOE relied on inputs from the
engineering analysis.
DOE requests feedback on whether
the maintenance and repair costs of
GFBs may increase at higher ELs.
Specifically, DOE requests comments on
the frequency of motor replacements for
ACFs. DOE also requests comments on
whether the maintenance and repair
costs of ACFs may increase at higher
ELs and on the repair costs developed
for ACFs.
6. Equipment Lifetime
For GFBs, in the NODA DOE used
average lifetimes of 30 years in the
industrial sector based on input from a
subject matter expert, and 15 years in
the commercial sector based on the
expected lifetimes of HVAC equipment.
Across all sectors and equipment
classes, the average lifetime for GFBs is
16 years. To characterize the range of
possible lifetimes, DOE developed
Weibull distributions of equipment
lifetimes.
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For ACFs, in the October 2022 NODA,
DOE stated that it did not find lifetime
data specific to ACFs and was
considering using 30 years, similar to
GFBs lifetimes in a previous DOE
analysis. (November 2016 NODA)
In response to the October 2022
NODA, AMCA commented that DOE
should assume a lifetime of 10 years
instead of 30, because ACFs often are
used in non-conditioned spaces or
agricultural environments that expose
them to dust, debris, moisture, and
other debilitating factors. In addition,
AMCA stated that in a previous report,94
DOE estimated average lifetimes of
fractional (i.e., less than 1 horsepower)
electric motors to 10 to 15 years. AMCA
added that ACFs are typically used in
areas without air conditioning and
experience higher air temperatures,
higher humidity, higher concentrations
of particulate matter in the air, and
greater fluctuations in power quality,
compared to fans in buildings with full
HVAC systems and tight envelopes. For
these reasons, AMCA stated that it is
unlikely for an ACF to have a lifetime
of 30 years. Instead, AMCA
recommended using a value of 10 years,
which is the lower end of the motor life
expectancy in the DOE report. (AMCA,
No. 132 at pp. 2, 18–19)
In this analysis, as suggested by
AMCA, DOE relied on separate lifetimes
for ACFs and GFBs. DOE considered
two separate lifetimes for ACFs
depending on whether the lifetime
included a motor replacement or not.
For ACFs that do not include a motor
replacement, DOE assumed the average
lifetime was equal to the estimated
average motor lifetime of 6 years based
on input from manufacturer interviews.
DOE believes this value is more
representative of ACF motor lifetimes as
it is more recent and specific to the
ACFs compared to the estimate
provided by AMCA, which relied on a
general motor and pump study
published in 1980. For ACFs that
include a motor replacement, DOE
assumed an average lifetime of 12 years
(i.e., twice the motor lifetime). DOE
further assumed 5 percent of ACFs have
a motor repair (see section IV.F.5 of this
document), while 95 percent of ACFs do
not, resulting in an overall average
lifetime of 6.3 years. To characterize the
range of possible lifetimes, DOE
developed Weibull distributions of
equipment lifetimes.
DOE requests comments on the
average lifetime estimates used for GFBs
and ACFs.
94 AMCA referenced the following study: 1980.
‘‘Classification and evaluation of electric motors
and pumps.’’ United States. Available at: doi.org/
10.2172/6719781.
95 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.
96 Damodaran Online, Data Page: Costs of Capital
by Industry Sector (2021). Available at:
pages.stern.nyu.edu/∼adamodar/(last accessed
April 22, 2022).
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7. Discount Rates
In the calculation of LCC, DOE
applies discount rates appropriate for
consumers to estimate the present value
of future operating cost savings. DOE
estimated a distribution of discount
rates for fans and blowers 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.95 The LCC
analysis estimates net present value
over the lifetime of the 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 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 commercial, industrial,
and agricultural discount rates for fans
and blowers, DOE estimated the
weighted-average cost of capital using
data from Damodaran Online.96 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
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3789
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 discount rates in
the commercial, industrial, and
agricultural sectors are 6.77, 7.25, and
7.15 percent, respectively.
DOE did not receive any comments
related to discount rates.
See chapter 8 of the NOPR TSD for
further details on the development of
discount rates.
8. Energy 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 considered the projected
distribution (market shares) of
equipment efficiencies under the nonew-standards case (i.e., the case
without new energy conservation
standards).
To estimate the energy efficiency
distribution of GFBs for 2030, DOE
relied on the 2012 AMCA sales data
from the sample (see section IV.E.1 of
this document). DOE notes that since
2012, the ASHRAE Standard 90.1–2010
Energy Standard for Buildings Except
Low-Rise Residential Building
(‘‘ASHRAE Standard 90.1’’) includes
limits on the FEI of certain fans and has
been adopted in some States.97 In
addition, the California Energy
Commission recently finalized reporting
requirements to promote fan selections
at duty points with FEI ratings greater
than or equal to 1.00.98 However, DOE
reviewed recent manufacturer catalogs
and found that the market has not
changed significantly since 2012 (see
detailed discussion in section IV.A.2.a
of this document). Therefore, in this
NOPR, DOE relied on the 2012
efficiency distributions to characterize
the no-new-standards case in 2030. The
estimated market shares for the no-newstandards case for GFBs are shown in
Table IV–19.
97 See 2020 Florida Building Code, Energy
Conservation, 7th edition—Section C403.2.12.3 Fan
Efficiency, effective December 31, 2020; 2021
Oregon Efficiency Specialty Code (OEESC): The
2021 OEESC, based on ASHRAE Standard 90.1–
2019, effective April 1, 2021.
98 These requirements take effect in November
2023. See www.energy.ca.gov/rules-andregulations/appliance-efficiency-regulations-title20/appliance-efficiency-proceedings-11.
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Table IV-19: No New Standards Case Efficiency Distribution in 2030 - GFBs
Equipment Class
EL0 ELl EL2 EL3 EL4 EL5 EL6 EL7
Axial Inline
5.2% 7.4% 20.8% 37.4% 24.5% 4.8% NIA NIA
Axial Panel
8.1% 11.7% 31.6% 32.0% 13.2% 3.4% NIA NIA
Centrifugal Housed
20.8% 5.6% 22.8% 31.9% 16.6% 2.5% NIA NIA
Centrifugal Inline
8.4% 5.9% 32.7% 13.7% 26.9% 10.2% 2.3% NIA
Centrifugal Unhoused
4.2% 6.0% 21.8% 50.1% 15.4% 2.5% NIA NIA
Axial Power Roof Ventilator
6.1% 4.4% 2.5% 13.0% 24.5% 30.9% 13.4% 5.3%
Centrifugal Power Roof
7.9% 1.3% 9.7% 16.6% 33.8% 24.8% 6.0% NIA
Ventilator - Exhaust
Centrifugal Power Roof
6.3% 3.8% 16.2% 25.6% 35.6% 9.1% 3.3% NIA
Ventilator - Supply
Radial Housed
7.3% 3.5% 7.0% 32.7% 27.2% 22.2% NIA NIA
The entry "NIA" indicates the EL is not available for the considered equipment class.
In the October 2022 NODA, DOE
stated that it would rely on information
from the BESS Labs dataset to develop
efficiency distribution and that it would
randomly assign an equipment
efficiency to each consumer drawn from
the consumer samples. 87 FR 62038,
62060. DOE did not receive any
comments on this topic.
For ACFs, DOE collected model
performance data from the BESS Labs
database as well as information from
manufacturer catalogs. As noted in
section IV.A.1.a, the BESS Labs database
contains fans with higher efficiencies
than the overall ACF market and is not
representative of the ACF market as a
whole. DOE collected catalog data from
manufacturer and distributor websites
to supplement the BESS Labs database.
DOE relied on the performance data
from both datasets establish the no-newstandards case efficiency distribution of
ACFs in 2030 and used a weighted
average when calculating the overall
efficiency distributions to reflect that
fact that the models in the BESS Labs
database are representative of the top of
the market in terms of efficiency.99 DOE
did not find historical performance data
for ACFs and assumed the efficiency
distribution would remain the same
over time. The resulting market shares
for the no-new-standards case for ACFs
are shown in Table IV–20.
Table IV-20: No New Standards Case Efficiency Distribution in 2030 - ACFs
Equipment Class*
EL0
ELl
EL2
EL3
EL4
EL5
EL6
Axial ACFs; 12" :'.S D < 36"
0%
1%
6%
41%
45%
6%
2%
Axial ACFs; 36" :'.S D < 48"
5%
3%
9%
52%
31%
0%
0%
Axial ACFs· 48" < D
6%
0%
19%
57%
17%
1%
0%
Housed Centrifugal ACFs
D: diameter in inches
5%
0%
24%
48%
21%
2%
0%
support any efficiency trends over time
for GFBs and ACFs.
9. Payback Period Analysis
The payback period is the amount of
time (expressed in years) it takes the
consumer to recover the additional
installed cost of more-efficient
equipment, compared to the no-newstandards case equipment, through
energy cost savings. Payback periods
that exceed the life of the equipment
mean that the increased total installed
cost is not recovered in reduced
operating expenses.
The inputs to the PBP calculation for
each efficiency level are the change in
total installed cost of the equipment and
the change in the first-year annual
operating expenditures relative to the
baseline. DOE refers to this as a ‘‘simple
PBP’’ because it does not consider
changes over time in operating cost
savings. The PBP calculation uses the
same inputs as the LCC analysis when
deriving first-year operating costs.
As noted previously, EPCA
establishes a rebuttable presumption
that a standard is economically justified
if the Secretary finds that the additional
cost to the consumer of purchasing
equipment complying with an energy
conservation standard level will be less
than three times the value of the first
year’s energy savings resulting from the
standard, as calculated under the
applicable test procedure. (42 U.S.C
99 Specifically, to reflect that the BESS data is not
representative of the majority of the ACF market,
DOE assumed that a quarter of ACFs are
represented by the BESS labs data and applied a
weight of 0.25 to the BESS Labs database and a
weight of 0.75 to the catalog data collected from
manufacturer and distributor websites.
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See chapter 8 of the NOPR TSD for
further information on the derivation of
the efficiency distributions.
The LCC Monte Carlo simulations
draw from the efficiency distributions
and randomly assign an efficiency to the
fans and blowers purchased by each
sample consumer in the no-newstandards case. The resulting percentage
shares within the sample match the
market shares in the efficiency
distributions.
DOE requests feedback and
information on the no-new-standards
case efficiency distributions used to
characterize the market of GFBs and
ACFs. DOE requests information to
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
6316(a); 42 U.S.C. 6295(o)(2)(B)(iii)) For
each considered efficiency level, DOE
determined the value of the first year’s
energy savings by calculating the energy
savings in accordance with the
applicable DOE test procedure, and
multiplying those savings by the average
energy price projection for the year in
which compliance with the standards
would be required.
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G. Shipments Analysis
DOE uses projections of annual
equipment shipments to calculate the
national impacts of potential amended
or new energy conservation standards
on energy use, NPV, and future
manufacturer cash flows.100 The
shipments model takes an accounting
approach, tracking market shares of
each equipment class and the vintage of
units in the stock. Stock accounting uses
equipment shipments as inputs to
estimate the age distribution of inservice equipment stocks for all years.
The age distribution of in-service
equipment stocks is a key input to
calculations of both the NES and NPV,
because operating costs for any year
depend on the age distribution of the
stock.
1. General Fans and Blowers
DOE first estimated total shipments in
the base year. For fans sold as a
standalone equipment by equipment
class, DOE relied on the estimate in the
November 2016 NODA, which relied on
a market research report,101 and AMCA
confidential sales data from 2012. To
estimate the shipments of fans sold
incorporated in other equipment (‘‘OEM
fans’’), DOE first identified HVAC
equipment that incorporate the
embedded fans in the scope of analysis
(i.e., HVAC equipment not listed in
Table III–1). DOE then determined the
average quantity of fans used in each of
the identified HVAC equipment and
estimated the total number of HVAC
fans as the product of HVAC equipment
sales and average number of fans per
equipment. The OEM fan shipments in
scope were then calculated by
subtracting the estimated number of
standalone fans purchased by OEMs
from the total number of fans in HVAC
equipment, to avoid double counting.
See chapter 9 for more details.
AHRI provided feedback on
shipments values published in the
November 2016 NODA. Specifically,
AHRI disagreed with DOE’s estimate of
100 DOE uses data on manufacturer shipments as
a proxy for national sales, as aggregate data on sales
are lacking. In general, one would expect a close
correspondence between shipments and sales.
101 IHS Technology (March 2014), Fans and
Blowers, World.
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air handling units and estimated the
shipments to be 65,000 units per year.
AHRI further commented that 75
percent of these units have variable air
volume (‘‘VAV’’) capability, and that
60–70% of those are equipped with
variable speed drives; AHRI questioned
whether DOE accounted for this in its
energy use analysis. Finally, AHRI
commented that they identified
approximately 40 percent of air
handling units with either a return or an
exhaust fan, as opposed to 50 percent
assumed in the November 2016 NODA.
(AHRI, No. 130 at pp. 7–8)
DOE reviewed the information
provided by AHRI and agrees with the
more recent shipments estimate of
65,000 units per year. In addition, DOE
accounted for variable load operation in
its energy use analysis as described in
section IV.E.1 of this document.
However, DOE did not estimate the
percentage of VAV units by HVAC
equipment but by GFBs equipment class
(up to 65 percent depending on the
equipment class). Finally, for this
NOPR, DOE estimated the percentage of
air handling units with either a return
or an exhaust fan as 30 percent based on
more recent input from manufacturer
interviews.
AHRI disagreed with DOE’s estimate
of panel fans per air-cooled water chiller
and the number of air-cooled water
chillers shipped. AHRI stated that the
average number of panel fans per unit
is seven instead of the DOE estimate of
14 in the November 2016 NODA. AHRI
also stated that the number of air-cooled
chillers shipped is 26,000 per year.
(AHRI, No. 130 at pp. 9–10)
DOE reviewed the information
provided by AHRI as well as additional
information from previous comments
estimating average annual shipments of
air-cooled chillers to 27,000 units per
year based on the U.S. Census MA35M/
MA333M series.102 DOE agrees with the
more recent shipments estimate of
26,000–27,000 units per year and 7 fans
per unit for air-cooled water chillers. As
such, DOE relied on this estimate
(27,000) rather than on the values
published in the November 2016 NODA.
AHRI disagreed with DOE’s estimate
of commercial unitary air conditioners
and heat pumps with and without
return/exhaust fans. AHRI stated that
less than 10 percent of units under
240,000 Btu/h have return/exhaust fans
and about 70 percent of units over
240,000 Btu/h have return/exhaust fans.
AHRI also commented that 80 percent of
102 See: AHRI data, CEC Docket 17–AAER–06,
TN#221201–1, p.10 https://efiling.energy.ca.gov/Get
Document.aspx?tn=221201-1&DocumentContent
Id=26700.
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units over 240,000 Btu/h have variable
speed drives and VAVs. AHRI
commented that these estimates were
based on a survey of its members.
(AHRI, No. 130 at p. 9)
DOE reviewed the information
provided by AHRI and agrees with the
more recent percentage values to
estimate the fraction of units with a
return or exhaust fan. As such DOE
relied on these estimates rather than on
the values published in the November
2016 NODA to estimate the number of
fans per unit in commercial unitary air
conditioners and heat pumps.
To project shipments of fans in the
industrial sector, DOE assumed in the
no-new-standards case that the longterm growth of fan shipments will be
driven by long-term growth of fixed
investments in equipment including
fans, which follow the same trend as the
gross domestic product (‘‘GDP’’). DOE
relied on fixed investment data from the
Bureau of Economic Analysis and
AEO2023 forecast of GDP through 2050
to inform its shipments projection. For
the commercial sector, DOE projected
shipments using AEO2023 projections
of commercial floor space. In 2030, DOE
estimates the total shipments of GFBs to
1.38 million units.
DOE also derived high and low
shipments projections based on
AEO2023 economic growth scenarios.
DOE further assumed that standards
would have a negligible impact on fan
shipments and applied a zero priceelasticity under standards cases. It is
likely that following a standard, rather
than foregoing a fan purchase under a
standards case, a consumer might
simply switch brands or fans to
purchase a fan that is best suited for
their application. As a result, DOE used
the same shipments projections in the
standards case as in the no-newstandards case.
DOE requests feedback on the
methodology and inputs used to project
shipments of GFBs in the no-newstandards case. DOE requests comments
and feedback on the potential impact of
standards on GFB shipments and
information to help quantify these
impacts.
2. Air Circulating Fans
In the October 2022 NODA, DOE
estimated total shipments of ACFs to
over 2 million using information from
manufacturer interviews indicating
shipments estimates of 494,950 units of
unhoused air circulating fan heads and
255,100 units of cylindrical air
circulating fans and applying expansion
factors to determine the shipments of
other categories of ACFs included in the
scope. 87 FR 62038, 62061. DOE did not
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receive any feedback or information on
shipments in response to the October
2022 NODA.
For this NOPR, DOE reviewed the
information from manufacturer
interviews and has determined that the
shipments estimates provided were for
the total market of axial ACFs (rather
than specific to unhoused air circulating
fan heads and cylindrical air circulating
fans only, as previously determined). In
addition, DOE estimated that housed
centrifugal ACFs represent one percent
of the total ACF market based on the
small number of manufacturers
identified in the catalog data collected
by DOE from manufacturer and
distributor websites.
In the October 2022 NODA, DOE
estimated that shipments of ACFs
follow similar trends as shipments of
large-diameter ceiling fans. Therefore,
DOE stated that it was 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 largediameter ceiling fans.103 87 FR 62038,
62061. In response to the October 2022
NODA, 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, as well as climate change
could all be reasons for possible growth
in the ACFs market. (ebm-papst, No. 8
at p. 4)
DOE agrees with the qualitative
comment from ebm-papst regarding the
potential causes for future ACF market
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103 See docket No. EERE–2021–BT–STD–0011–
0015.
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growth. However, DOE notes that this
information does not allow for a
quantitative estimation of projected
shipments. DOE did not receive any
additional feedback on this approach
and applied this methodology in the
NOPR. In 2030, DOE estimates the total
shipments of fans to be 1.30 million
units.
DOE requests feedback on the
methodology and inputs used to
estimate and project shipments of ACFs
in the no-new-standards case. DOE
requests comments and feedback on the
potential impact of standards on ACF
shipments and information to help
quantify these impacts.
H. National Impact Analysis
The NIA assesses the national energy
savings (‘‘NES’’) and the NPV from a
national perspective of total consumer
costs and savings that would be
expected to result from new or amended
standards at specific efficiency levels.104
(‘‘Consumer’’ in this context refers to
consumers of the equipment being
regulated.) 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 fans and
104 The
NIA accounts for impacts in the 50 States
and U.S. territories.
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blowers sold from 2030 through
2059.105
DOE evaluates the impacts of new or
amended standards by comparing a case
without such standards with standardscase projections. 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 (i.e., the TSLs or
standards cases) for that class. For the
standards cases, DOE considers how a
given standard would likely affect the
market shares of equipment with
efficiencies greater than the standard.
DOE uses a spreadsheet model to
calculate the energy savings and the
national consumer costs and savings
from each TSL. Interested parties can
review DOE’s analyses by changing
various input quantities within the
spreadsheet. The NIA spreadsheet
model uses typical values (as opposed
to probability distributions) as inputs.
Table IV–21 summarizes the inputs
and methods DOE used for the NIA
analysis for the NOPR. Discussion of
these inputs and methods follows the
table. See chapter 10 of the NOPR TSD
for further details.
105 Because the anticipated compliance date is
late in the year, for analytical purposes, DOE
conducted the analysis for shipments from 2030
through 2059.
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Table IV-21 Summary of Inputs and Methods for the National Impact Analysis
Inputs
Method
Efficiency Trends
Annual Energy Consumption per Unit
Total Installed Cost per Unit
Annual Energy Cost per Unit
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Repair and Maintenance Cost per Unit
Energy Price Trends
Energy Site-to-Primary and FFC
Conversion
Discount Rate
Present Year
1. 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. Section IV.F.8 of
this document describes how DOE
developed an energy efficiency
distribution for the no-new-standards
case (which yields a shipment-weighted
average efficiency) for each of the
considered equipment classes for the
first full year of anticipated compliance
with an amended or new standard. To
project the trend in efficiency absent
amended standards for GFBs and ACFS
over the entire shipments projection
period, DOE assumed a constant
efficiency trend. The approach is further
described in chapter 10 of the NOPR
TSD.
For the standards cases, DOE used a
‘‘roll-up’’ scenario to establish the
shipment-weighted efficiency for the
first full year that standards are assumed
to become effective (2030). In this
scenario, the market shares of
equipment 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 equipment above the standard
would remain unchanged.
To develop standards case efficiency
trends after 2030, DOE assumed a
constant efficiency trend, similar to the
no-new standards case.
2. National Energy Savings
The national energy savings analysis
involves a comparison of national
energy consumption of the considered
equipment between each potential
standards case (‘‘TSL’’) and the case
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Annual shipments from shipments model.
2030 (first full year)
No-new-standards case: constant trend
Standards cases: constant trend
Annual weighted-average values are a function of energy use at
each TSL.
Annual weighted-average values are a function of cost at each
TSL.
Incorporates projection of future product prices based on
historical data.
Annual weighted-average values as a function of the annual
energy consumption per unit and energy prices.
Annual values do not change with efficiency level.
AEO2023 projections (to 2050) and held constant thereafter.
A time-series conversion factor based onAEO2023.
3 percent and 7 percent
2024
with no new or amended energy
conservation standards. DOE calculated
the national energy consumption by
multiplying the number of units (stock)
of each equipment (by vintage or age) by
the unit energy consumption (also by
vintage). DOE calculated annual NES
based on the difference in national
energy consumption for the no-new
standards case and for each higher
efficiency standard case. DOE estimated
energy consumption and savings based
on site energy and converted the
electricity consumption and savings to
primary energy (i.e., the energy
consumed by power plants to generate
site electricity) using annual conversion
factors derived from AEO2023.
Cumulative energy savings are the sum
of the NES for each year over the
timeframe of the analysis.
Use of higher-efficiency equipment is
sometimes associated with a direct
rebound effect, which refers to an
increase in utilization of the equipment
due to the increase in efficiency. For
example, when a consumer realizes that
a more efficient fan used for cooling will
lower the electricity bill, that person
may opt for increased comfort in the
building by using the equipment more,
thereby negating a portion of the energy
savings. In commercial buildings,
however, the person owning the
equipment (i.e., the building owner) is
usually not the person operating the
equipment (i.e., the renter). Because the
operator usually does not own the
equipment, that person will not have
the operating cost information necessary
to influence how they operate the
equipment. Therefore, DOE believes that
a rebound effect is unlikely to occur in
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commercial buildings. In the industrial
and agricultural sectors, DOE believes
that fans are likely to be operated
whenever needed for the required
application, so a rebound effect is also
unlikely to occur in the industrial and
agricultural sectors. Therefore, DOE did
not apply a rebound effect for fans and
blowers.
DOE requests comment and data
regarding the potential increase in
utilization of GFBs and ACFs due to any
increase in efficiency.
In 2011, in response to the
recommendations of a committee on
‘‘Point-of-Use and Full-Fuel-Cycle
Measurement Approaches to Energy
Efficiency Standards’’ appointed by the
National Academy of Sciences, DOE
announced its intention to use FFC
measures of energy use and greenhouse
gas and other emissions in the national
impact analyses and emissions analyses
included in future energy conservation
standards rulemakings. 76 FR 51281
(Aug. 18, 2011). After evaluating the
approaches discussed in the August 18,
2011 notice, DOE published a statement
of amended policy in which DOE
explained its determination that EIA’s
National Energy Modeling System
(‘‘NEMS’’) is the most appropriate tool
for its FFC analysis and its intention to
use NEMS for that purpose. 77 FR 49701
(Aug. 17, 2012). NEMS is a public
domain, multi-sector, partial
equilibrium model of the U.S. energy
sector 106 that EIA uses to prepare its
106 For more information on NEMS, refer to The
National Energy Modeling System: An Overview
2009, DOE/EIA–0581(2009), October 2009.
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Annual Energy Outlook. The FFC factors
incorporate losses in production and
delivery in the case of natural gas
(including fugitive emissions) and
additional energy used to produce and
deliver the various fuels used by power
plants. The approach used for deriving
FFC measures of energy use and
emissions is described in appendix 10B
of the NOPR TSD.
3. Net Present Value Analysis
The inputs for determining the NPV
of the total costs and benefits
experienced by consumers are (1) total
annual installed cost, (2) total annual
operating costs (energy costs and repair
and maintenance costs), and (3) a
discount factor to calculate the present
value of costs and savings. DOE
calculates net savings each year as the
difference between the no-newstandards case and each standards case
in terms of total savings in operating
costs versus total increases in installed
costs. DOE calculates operating cost
savings over the lifetime of each
equipment shipped during the
projection period.
As discussed in section IV.F.1 of this
document, DOE developed price trends
for GFBs and ACFs based on historical
PPI data. DOE applied the same trends
to project prices for each equipment
class at each considered efficiency level.
For GFBs, DOE applied constant
equipment price trends. For ACFs, DOE
also applied a constant price trend
except for ACFs at EL6 where a
declining price trend was used. By
2059, which is the end date of the
projection period, the average ACF price
at EL6 is projected to drop 14 percent
relative to 2022. DOE’s projection of
product prices is described in appendix
10C of the NOPR TSD.
To evaluate the effect of uncertainty
regarding the price trend estimates, DOE
investigated the impact of different
product price projections on the
consumer NPV for the considered TSLs
for GFBs and ACFs. In addition to the
default price trend, DOE considered two
product price sensitivity cases: (1) a
high price decline case based on
historical PPI data and (2) a low price
decline case based on the AEO2023
‘‘deflator—industrial equipment’’
forecast for GFBs and historical PPI data
for ACFs. The derivation of these price
trends and the results of these
sensitivity cases are described in
appendix 10C of the NOPR TSD.
The energy cost savings are calculated
using the estimated energy savings in
each year and the projected price of the
Available at: www.eia.gov/forecasts/aeo/index.cfm
(last accessed April 4, 2023).
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appropriate form of energy. To estimate
energy prices in future years, DOE
multiplied the average regional energy
prices by the projection of annual
national-average commercial and
industrial energy price changes in the
Reference case from AEO2023, which
has an end year of 2050. To estimate
price trends after 2050, the 2050 price
was used for all years. As part of the
NIA, DOE also analyzed scenarios that
used inputs from variants of the
AEO2023 Reference case that have
lower and higher economic growth.
Those cases have lower and higher
energy price trends compared to the
Reference case. NIA results based on
these cases are presented in appendix
10C of the NOPR TSD.
In addition, for ACFs, the NPV
calculation also includes the total repair
costs which are calculated based on the
outputs from the life-cycle analysis.
In calculating the NPV, DOE
multiplies the net savings in future
years by a discount factor to determine
their present value. For this NOPR, DOE
estimated the NPV of consumer benefits
using both a 3-percent and a 7-percent
real discount rate. DOE uses these
discount rates in accordance with
guidance provided by the Office of
Management and Budget (‘‘OMB’’) to
Federal agencies on the development of
regulatory analysis.107 The discount
rates for the determination of NPV are
in contrast to the discount rates used in
the LCC analysis, which are designed to
reflect a consumer’s perspective. The 7percent real value is an estimate of the
average before-tax rate of return to
private capital in the U.S. economy. The
3-percent real value represents the
‘‘social rate of time preference,’’ which
is the rate at which society discounts
future consumption flows to their
present value.
I. Consumer Subgroup Analysis
In analyzing the potential impact of
new or amended energy conservation
standards on consumers, DOE evaluates
the impact on identifiable subgroups of
consumers that may be
disproportionately affected by a new or
amended national standard. The
purpose of a subgroup analysis is to
determine the extent of any such
disproportional impacts. DOE evaluates
impacts on particular subgroups of
consumers by analyzing the LCC
impacts and PBP for those particular
consumers from alternative standard
levels. For this NOPR, DOE analyzed the
107 Office of Management and Budget. Circular A–
4: Regulatory Analysis. September 17, 2003. Section
E. Available at https://www.whitehouse.gov/wpcontent/uploads/legacy_drupal_files/omb/circulars/
A4/a-4.pdf.
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impacts of the considered standard
levels on small businesses. DOE used
the LCC and PBP spreadsheet model to
estimate the impacts of the considered
efficiency levels on these subgroups,
and used inputs specific to that
subgroup. Chapter 11 in the NOPR TSD
describes the consumer subgroup
analysis.
J. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate
the financial impacts of new energy
conservation standards on
manufacturers of fans and blowers and
to estimate the potential impacts of such
standards on employment and
manufacturing capacity. The MIA has
both quantitative and qualitative aspects
and includes analyses of projected
industry cash flows, the INPV,
investments in research and
development (‘‘R&D’’) and
manufacturing capital, and domestic
manufacturing employment.
Additionally, the MIA seeks to
determine how new energy conservation
standards might affect manufacturing
employment, capacity, and competition,
as well as how standards contribute to
overall regulatory burden. Finally, the
MIA serves to identify any
disproportionate impacts on
manufacturer subgroups, including
small business manufacturers.
The quantitative part of the MIA
primarily relies on the GRIM, an
industry cash flow model with inputs
specific to this rulemaking. The key
GRIM inputs include data on the
industry cost structure, unit production
costs, equipment shipments,
manufacturer markups, and investments
in R&D and manufacturing capital
required to produce compliant
equipment. The key GRIM outputs are
the INPV, which is the sum of industry
annual cash flows over the analysis
period, discounted using the industryweighted average cost of capital, and the
impact on domestic manufacturing
employment. The model uses standard
accounting principles to estimate the
impacts of new energy conservation
standards on a given industry by
comparing changes in INPV and
domestic manufacturing employment
between a no-new-standards case and
the various standards cases (i.e., TSLs).
To capture the uncertainty relating to
manufacturer pricing strategies
following new standards, the GRIM
estimates a range of possible impacts
under different markup scenarios.
The qualitative part of the MIA
addresses manufacturer characteristics
and market trends. Specifically, the MIA
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considers such factors as a potential
standard’s impact on manufacturing
capacity, competition within the
industry, the cumulative impact of other
DOE and non-DOE regulations, and
impacts on manufacturer subgroups.
The complete MIA is outlined in
chapter 12 of the NOPR TSD.
DOE conducted the MIA for this
rulemaking in three phases. In Phase 1
of the MIA, DOE prepared a profile of
the fan and blower manufacturing
industry based on the market and
technology assessment, preliminary
manufacturer interviews, and publicly
available information. This included a
top-down analysis of fan and blower
manufacturers that DOE used to derive
preliminary financial inputs for the
GRIM (e.g., revenues; materials, labor,
overhead, and depreciation expenses;
selling, general, and administrative
expenses (‘‘SG&A’’); and R&D expenses).
DOE also used public sources of
information to further calibrate its
initial characterization of the fan and
blower manufacturing industry,
including company filings of form 10–
K from the SEC,108 corporate annual
reports, the U.S. Census Bureau’s
Economic Census,109 and reports from
D&B Hoovers.110
In Phase 2 of the MIA, DOE prepared
a framework industry cash flow analysis
to quantify the potential impacts of new
energy conservation standards. The
GRIM uses several factors to determine
a series of annual cash flows starting
with the announcement of the standard
and extending over a 30-year period
following the compliance date of the
standard. These factors include annual
expected revenues, costs of sales, SG&A
and R&D expenses, taxes, and capital
expenditures. In general, energy
conservation standards can affect
manufacturer cash flow in three distinct
ways: (1) creating a need for increased
investment, (2) raising production costs
per unit, and (3) altering revenue due to
higher per-unit prices and changes in
sales volumes.
In addition, during Phase 2, DOE
developed interview guides to distribute
to manufacturers of fans and blowers in
order to develop other key GRIM inputs,
including capital and product
conversion costs, and to gather
additional information on the
anticipated effects of energy
conservation standards on revenues,
direct employment, capital assets,
industry competitiveness, and subgroup
impacts.
108 See
www.sec.gov/edgar.
www.census.gov/programs-surveys/asm/
data/tables.html.
110 See app.avention.com.
109 See
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In Phase 3 of the MIA, DOE
conducted structured, detailed
interviews with representative
manufacturers. During these interviews,
DOE discussed engineering,
manufacturing, procurement, and
financial topics to validate assumptions
used in the GRIM and to identify key
issues or concerns. See section IV.J.3 of
this document for a description of the
key issues raised by manufacturers
during the interviews. As part of Phase
3, DOE also evaluated subgroups of
manufacturers that may be
disproportionately impacted by new
energy conservation standards or that
may not be accurately represented by
the average cost assumptions used to
develop the industry cash flow analysis.
Such manufacturer subgroups may
include small business manufacturers,
low-volume manufacturers (‘‘LVMs’’),
niche players, and/or manufacturers
exhibiting a cost structure that largely
differs from the industry average. DOE
identified one subgroup for a separate
impact analysis: small business
manufacturers. The small business
subgroup is discussed in section VI.B,
‘‘Review under the Regulatory
Flexibility Act’’ and in chapter 12 of the
NOPR TSD.
2. Government Regulatory Impact Model
and Key Inputs
DOE uses the GRIM to quantify the
changes in cash flow due to new energy
conservation standards that result in a
higher or lower industry value. The
GRIM uses a standard, annual
discounted cash flow analysis that
incorporates manufacturer costs,
markups, shipments, and industry
financial information as inputs. The
GRIM models changes in costs,
distribution of shipments, investments,
and manufacturer margins that could
result from new energy conservation
standards. The GRIM spreadsheet uses
the inputs to arrive at a series of annual
cash flows, beginning in 2024 (the base
year of the analysis) and continuing to
2059. DOE calculated INPVs by
summing the stream of annual
discounted cash flows during this
period. For manufacturers of fans and
blowers, DOE used a real discount rate
of 11.4 percent, which was derived from
industry financials and then modified
according to feedback received during
manufacturer interviews.
The GRIM calculates cash flows using
standard accounting principles and
compares changes in INPV between the
no-new-standards case and each
standards case. The difference in INPV
between the no-new-standards case and
a standards case represents the financial
impact of the new energy conservation
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standards on manufacturers. As
discussed previously, DOE developed
critical GRIM inputs using a number of
sources, including publicly available
data, results of the engineering analysis,
and information gathered from industry
stakeholders during the course of
manufacturer interviews and
subsequent Working Group meetings.
The GRIM results are presented in
section V.B.2. Additional details about
the GRIM, the discount rate, and other
financial parameters can be found in
chapter 12 of the NOPR TSD.
a. Manufacturer Production Costs
Manufacturing more efficient
equipment is typically more expensive
than manufacturing baseline equipment
due to the use of more complex
components, which are typically more
costly than baseline components. The
changes in the MPCs of covered
equipment can affect the revenues, gross
margins, and cash flow of the industry.
For GFBs, DOE developed baseline
MSP versus diameter curves and
incremental costs for each design option
for each equipment class. DOE used
these correlations to estimate the MSP at
each EL for each equipment class at all
nominal impeller diameters. As such,
each equipment class has multiple MSP
versus FEI curves representing the range
of impeller diameters that exist on the
market. For ACFs, DOE developed
curves for each representative unit. The
methodology for developing the curves
started with determining the efficiency
for baseline equipment and the MPCs
for this equipment. Above the baseline,
DOE implemented design options until
all available design options were
employed (i.e., at the max-tech level).
For a complete description of the
MPCs, see chapter 5 of the NOPR TSD.
b. Shipments Projections
The GRIM estimates manufacturer
revenues based on total unit shipment
projections and the distribution of those
shipments by efficiency level. Changes
in sales volumes and efficiency mix
over time can significantly affect
manufacturer finances. For this analysis,
the GRIM uses the NIA’s annual
shipment projections derived from the
shipments analysis from 2024 (the base
year) to 2059 (the end year of the
analysis period). See chapter 9 of the
NOPR TSD for additional details.
c. Product and Capital Conversion Costs
New energy conservation standards
could cause manufacturers to incur
conversion costs to bring their
production facilities and equipment
designs into compliance. DOE evaluated
the level of conversion-related
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expenditures that would be needed to
comply with each considered efficiency
level in each equipment class. For the
MIA, DOE classified these conversion
costs into two major groups: (1) product
conversion costs; and (2) capital
conversion costs. Product conversion
costs are investments in research,
development, testing, marketing, and
other non-capitalized costs necessary to
make equipment designs comply with
new energy conservation standards.
Capital conversion costs are investments
in property, plant, and equipment
necessary to adapt or change existing
production facilities such that new
compliant equipment designs can be
fabricated and assembled.
In response to the October 2022
NODA, AMCA commented that DOE
should conduct interviews with
individual manufacturers to gather
information regarding potential
conversion costs for fan and blower
manufacturers. (AMCA, No. 132 at p.
12) DOE conducted manufacturer
interviews with several interested
parties, including several fan and
blower manufacturers, after the
publication of the October 2022 NODA
and prior to conducting this NOPR
analysis. The results and methodology
for estimating conversion costs are
described in this section.
DOE used a bottom-up cost estimate
to arrive at a total product conversion
cost at each EL for all equipment
classes. DOE first estimated the number
of unique basic models for each
equipment class and at each EL using
the AMCA sales database for GFBs and
the updated ACF database for ACFs.
Next, DOE estimated the percentage of
models that would not meet each
analyzed EL based on information from
the appropriate database. DOE also
estimated the percentage of failing
models that are assumed to be
redesigned at each analyzed EL. DOE
then estimated the amount of
engineering time needed to redesign and
test a single non-compliant basic model
into a compliant model and the time
necessary to conduct additional air,
sound, and certification testing once the
model is redesigned. DOE used data
from the U.S. Bureau of Labor
Statistics 111 (‘‘BLS’’) to estimate the
total hourly employer compensation to
conduct the redesign and to conduct
testing. DOE based the number of hours
associated with a per model redesign
and per model testing estimates on
information received during
manufacturer interviews. DOE estimated
that longer per model redesign
111 See www.bls.gov/oes/current/oes_stru.htm and
www.bls.gov/bls/news-release/ecec.htm#current.
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engineering hours would be required to
achieve higher ELs, since more
engineering resources would be
required to achieve higher ELs.
However, DOE assumed the same per
model testing cost for all ELs, since DOE
did not assume the testing cost will
increase at higher ELs. Lastly, DOE
multiplied the per model redesign (for
each EL) and per model testing costs by
the number models that are estimated to
be redesigned at each EL.
DOE estimated the capital conversion
costs based on information received
during manufacturer interviews. During
manufacturer interviews, manufacturers
provided estimates on the percentage of
total conversion costs that would be
associated with the purchasing on
equipment and machinery (capital
conversion costs) and the percentage of
total conversion costs that would be
associated with engineering resources to
conduct redesigns and testing (product
conversion costs). In addition to
assuming increased product costs at
higher ELs, DOE also assumed that the
ratio of product conversion costs to
capital conversion costs would decrease
at higher ELs (i.e., higher ELs are
expected to have higher capital
conversion costs since manufacturers
would be expected to increase
investments in new tooling and
potentially different production
processes). In sum, DOE used these
percentage estimates provided during
manufacturer interviews and the
product conversion cost estimates
previously described to estimate the
total capital conversion costs for each
equipment class at each analyzed EL.
CA IOUs stated that some ACF
manufacturers purchase the impellors
that they use rather than design and
manufacture them in-house. Therefore,
CA IOUs stated purchasing more
efficient impeller designs may be
possible without significant design and
capital costs. (CA IOUs, No. 127 at p.3)
DOE conducted manufacturer
interviews with a variety of ACF
manufacturers. The cost estimates
included in this analysis assume that
ACF manufacturers produce their
impellors in-house. While some ACF
manufacturers might purchase impellors
from another company, whatever
company that is manufacturing the more
efficient impellors is will incur
additional product and capital
conversion costs and those costs will
likely be passed on to their customers.
Section IV.J.2.d discusses how an
increase in product and capital
conversion costs (regardless of if an
impellor manufacturer or an ACF
manufacturer incurs them) could result
in an increased ACF MSP that is
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incorporated into all down-stream and
consumer analyses.
In general, DOE assumes all
conversion-related investments occur
between the year of publication of the
final rule and the year by which
manufacturers must comply with the
new standard. The conversion cost
figures used in the GRIM can be found
in section V.B.2 of this document. For
additional information on the estimated
capital and product conversion costs,
see chapter 12 of the NOPR TSD.
d. Markup Scenarios
MSPs include direct manufacturing
production costs (i.e., labor, materials,
and overhead estimated in DOE’s MPCs)
and all non-production costs (i.e.,
SG&A, R&D, and interest), along with
profit. To calculate the MSPs in the
GRIM, DOE applied non-production
cost markups to the MPCs estimated in
the engineering analysis for ACFs at
each equipment class and efficiency
level. For GFBs, the engineering
analysis estimated the MSPs. Therefore,
the MIA did not calculate the MSPs for
GFBs using the MPCs. Instead, the MIA
estimated the MPC by dividing the
MSPs, which were estimated in the
engineering analysis, by a manufacturer
markup. For GFBs, DOE estimated a
manufacturer markup of 1.35 for all
equipment classes in the no-newstandards case. This corresponds to a
manufacturer gross margin percentage of
approximately 25.9 percent. For ACFs,
DOE estimated a manufacturer markup
of 1.50 for all equipment classes in the
no-new-standards case. This
corresponds to a manufacturer gross
margin percentage of approximately
33.3 percent. DOE estimated these
manufacturers markups based on
information obtained during
manufacturer interviews. Modifying
these manufacturer markups in the
standards case yields different sets of
impacts on manufacturers. For the MIA,
DOE modeled two standards-case
markup scenarios to represent
uncertainty regarding the potential
impacts on prices and profitability for
manufacturers following the
implementation of new energy
conservation standards: (1) a conversion
cost recovery markup scenario; and (2)
a preservation of operating profit
markup scenario. These scenarios lead
to different manufacturer markup values
that, when applied to the MPCs, result
in varying revenue and cash flow
impacts.
Under the conversion cost recovery
markup scenario, DOE modeled a
scenario in which manufacturers
increase their markups in response to
new energy conservation standards. For
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ELs that DOE’s engineering analysis
assumed would require an aerodynamic
redesign, the engineering analysis
assumed there is no increase in the
MPCs (for the ELs that are assumed
would require an aerodynamic
redesign). However, DOE did assume
that fan and blower manufacturers will
incur conversion costs to redesign noncompliant models. Therefore, DOE
modeled a manufacturer markup
scenario in which fan and blower
manufacturers attempt to recover the
investments they must make to conduct
these aerodynamic redesigns through an
increase in their manufacturer markup.
Therefore, in the standards cases, the
manufacturer markup of models that
would need to be re-designed is larger
than the manufacturer markup used in
the no-new-standards case. DOE
calibrated these manufacturer markups,
in the standards case conversion cost
recovery scenario, for each equipment
class at each EL to cause the
manufacturer INPV in the standards
cases to be approximately equal to the
manufacturer INPV in the no-newstandards case. In this markup scenario,
manufacturers earn additional revenue
in the standards cases after the
compliance date that offsets the
conversion costs that were incurred
prior to the compliance date. This
represents the upper-bound of
manufacturer profitability, as in this
manufacturer markup scenario as
measured by INPV, fan and blower
manufacturers are able to fully recover
their conversion costs by the end of the
30-year analysis period.
Under the preservation of operating
profit markup scenario, DOE modeled a
markup scenario where manufacturers
are not able to increase their per-unit
operating profit in proportion to
increases in MPCs. Under this scenario,
as the MPCs increase, manufacturers
reduce their markups (on a percentage
basis) to a level that maintains the nonew-standards operating profit (in
absolute dollars). The implicit
assumption behind this manufacturer
markup scenario is that the industry can
only maintain its operating profit in
absolute dollars after compliance with
new standards. Therefore, the
percentage of the operating margin is
reduced between the no-new-standards
case and the analyzed standards cases.
DOE adjusted the manufacturer
markups in the GRIM at each TSL to
yield approximately the same earnings
before interest and taxes in the
standards case as in the no-newstandards case. This manufacturer
markup scenario represents the lower
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bound to industry profitability under
new energy conservation standards.
A comparison of industry financial
impacts under the two manufacturer
markup scenarios is presented in
section V.B.2.a of this document.
3. Manufacturer Interviews
DOE interviewed a variety of fan and
blower manufacturers prior to
conducting this NOPR analysis. During
these interviews, DOE asked
manufacturers to describe their major
concerns regarding this rulemaking. The
following section highlights
manufacturer concerns that helped
inform the projected potential impacts
of a new standard on the industry.
Manufacturer interviews are conducted
under non-disclosure agreements
(‘‘NDAs’’), so DOE does not document
these discussions in the same way that
it does public comments in the
comment summaries and DOE’s
responses throughout the rest of this
document.
Embedded Fans
Several fan and blower manufacturers
stated that they are concerned that
including fans and blowers that are
embedded in other products or
equipment already regulated by DOE
creates redundant regulations.
Additionally, manufacturers stated that
the electricity used by the fan or blower
in these systems is a relatively
insignificant portion of the energy
consumed by the entire system. Lastly,
manufacturers stated that increasing the
efficiency of a fan or blower used in a
product or equipment already regulated
by DOE could limit the effectiveness of
a future energy conservation standard
on the performance of those products or
equipment covered by DOE.
DOE is proposing to exclude fans and
blowers that are embedded in specific
types of equipment. Table III–1 lists the
embedded fans and blowers that are
excluded from the scope of this energy
conservation standards rulemaking.
Testing Costs and Burden
Several fan and blower manufacturers
stated that a concern that compliance
with energy conservation standards
would require fan and blower
manufacturers to test all covered fans
and blowers. Manufacturers specifically
are concerned that the legacy testing
data that they have already conducted
for the AMCA certification testing
program would need to be re-tested to
demonstrate compliance with a DOE
energy conservation standard. As stated
in the May 2023 TP Final Rule, DOE
understands that manufacturers of fans
and blowers likely have historical test
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data which were developed with
methods consistent with the DOE test
procedure adopted in the May 2023
Final Rule, and does not expect
manufacturers to regenerate all of the
historical test data unless the rating
resulting from the historical methods
would no longer be valid. 88 FR 27312,
27378.
Additionally, manufacturers were
concerned that requiring a test sample
of two fans or blowers would be overly
burdensome for manufacturers to
comply with an energy conservation
standard. As stated in the May 2023 TP
Final Rule ‘‘DOE believe it is
appropriate to allow a minimum of one
unit for fans and blowers other than air
circulating fans’’ to be tested to comply
with any DOE energy conservation
standard. 88 FR 27312, 27378.
Lastly, some manufacturers were
concerned that if DOE did not allow the
use of an alternative energy
determination method (‘‘AEDM’’) to
determine fan performance,
manufacturers would have to physically
test all covered fans and blowers.
Manufacturers stated that physically
testing every fan and blower would
place a larger and costly testing burden
on manufacturers. As stated in the May
2023 TP Final Rule, ‘‘DOE allows the
use of an AEDM in lieu of testing to
determine fan performance, which
would mitigate the potential cost
associated with having to physically test
units.’’ 88 FR 27312, 27372.
4. Discussion of MIA Comments
AHRI stated that for end-use products
(i.e., a product or equipment that has a
fan or blower embedded in it) testing
must take place following internal
component swaps or cabinet redesigns.
This testing could include seismic and
wind load testing for HVAC equipment
installed exterior to the building;
electric heat, safety, refrigerant, and
sound testing for heating equipment;
and transportation, vibration, and sound
testing for most end-use products. AHRI
stated that testing lab availability is
limited at this time, given the wideranging changes in refrigerant and safety
standards requirements, and standards
that result in a redesign to accommodate
a new fan will impact virtually every
model of HVACR product on the
market. (AHRI, No. 130 at pp. 5–6) DOE
acknowledges that end-use products
may have to be re-test if the current fan
that they use does not meet the adopted
energy conservation standards.
However, DOE’s engineering analysis
primarily examined replacement fans
and blowers with the same diameter and
would not require a cabinet redesign for
an end-use product.
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AHRI stated that there is a significant
monetary impact for OEMs for a fan
swap, as a significant amount of retesting and potential re-certification
would need to be conducted for a fan
swap, even if the size of the cabinet
does not change. AHRI stated that based
on a review of their AHRI Certification
Program they identified approximately
6,000 basic models that have a covered
fan embedded in these end-use
products. AHRI continued by stating
they estimate it would cost
approximately $300,000 for each enduse product basic model that would be
required to incorporate a new fan if the
existing fan used in their end-use
product does not comply with DOE’s
energy conservation standards for that
fan. (AHRI, No. 130 at p. 6–7) DOE
acknowledges that OEMs may incur retesting and re-certification costs if the
fan used in their equipment does not
meet the adopted energy conservation
standard for fans. The MIA for this
rulemaking specifically examines the
conversion costs that fan and blower
manufacturers would incur due to the
analyzed energy conservation standards
for fans and blowers in comparison to
the revenue and free cash fan and
blower manufacturers receive. The OEM
testing and certification costs were not
included in the MIA, and neither were
the OEM revenues and free cash flows,
as these costs and revenue are not
specific to fan and blower
manufacturers.
MIAQ also stated that redesign of the
end-use product to accommodate a new
fan will result in retesting and possible
recertification and model number
changes for end-use products, which
will be a massive, costly, and timeconsuming undertaking (and could even
cause a disruption in the market) as
there would be changes to electrical,
physical, or functional characteristics of
the end-use product that affect energy
consumption/efficiency. (MIAQ, No.
124 at pp. 2–3) DOE is proposing to
exclude fans that are embedded in
commercial HVAC equipment that is
already covered by DOE energy
conservation standards as well as a
variety of other products. The full list of
embedded fans proposed for exclusion
from the scope of this energy
conservation standards rulemaking can
be found in Table III–1.
DOE requests comment on the
number of end-use product (i.e., a
product or equipment that has a fan or
blower embedded in it) basic models
that would not be excluded by the list
of products or equipment listed in Table
III–1.
MIAQ and AHRI stated that it was not
realistic to expect manufacturers to
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comply with any energy conservation
standards within 180 days. (MIAQ, No.
124 at p. 2–3; AHRI, No. 130 at p. 5)
DOE notes that the May 2023 TP Final
Rule stated that beginning 180 days after
the publication of the May 2023 TP
Final Rule, any representations made
with respect to energy use or efficiency
of fans or blowers must be made based
on testing in accordance with the May
2023 TP Final Rule. Neither the May
2023 TP Final Rule nor this NOPR
requires that fan and blower
manufacturers meet a minimum energy
conservation standard 180 days after the
publication of the May 2023 TP Final
Rule. Compliance with any energy
conservation standards would not be
required until 5 years after publication
of the energy conservation standard
final rule.
AHRI expressed concern about unfair
advantage given to imported HVAC
products that may not need to comply
with components regulations. AHRI
stated that imported HVAC products
with embedded fans are excluded from
the fan and blower energy conservation
standard, but fans assembled into
similar equipment manufactured
domestically would be subject to DOE
energy conservation standards (AHRI,
No. 130, at p. 4) DOE is proposing to
require fans and blowers that are
imported in HVAC products to comply
with the energy conservation standards
established in this rulemaking as long as
those products or equipment are not
listed in Table III–1. This is the same
requirement that applies to fans and
blowers that are assembled into the
same equipment manufactured
domestically.
K. Emissions Analysis
The emissions analysis consists of
two components. The first component
estimates the effect of potential energy
conservation standards on power sector
and site (where applicable) combustion
emissions of CO2, NOX, SO2, and Hg.
The second component estimates the
impacts of potential standards on
emissions of two additional greenhouse
gases, CH4 and N2O, as well as the
reductions to emissions of other gases
due to ‘‘upstream’’ activities in the fuel
production chain. These upstream
activities comprise extracting,
processing, and transporting fuels to the
site of combustion.
The analysis of electric power sector
emissions of CO2, NOX, SO2, and Hg
uses emissions factors intended to
represent the marginal impacts of the
change in electricity consumption
associated with amended or new
standards. The methodology is based on
results published for the AEO, including
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a set of side cases that implement a
variety of efficiency-related policies.
The methodology is described in
appendix 13A of the NOPR TSD. The
analysis presented in this notice uses
projections from AEO2023. Power sector
emissions of CH4 and N2O from fuel
combustion are estimated using
Emission Factors for Greenhouse Gas
Inventories published by the
Environmental Protection Agency
(EPA).112
FFC upstream emissions, which
include emissions from fuel combustion
during extraction, processing, and
transportation of fuels, and ‘‘fugitive’’
emissions (direct leakage to the
atmosphere) of CH4 and CO2, are
estimated based on the methodology
described in chapter 15 of the NOPR
TSD.
The emissions intensity factors are
expressed in terms of physical units per
MWh or MMBtu of site energy savings.
For power sector emissions, specific
emissions intensity factors are
calculated by sector and end use. Total
emissions reductions are estimated
using the energy savings calculated in
the national impact analysis.
1. Air Quality Regulations Incorporated
in DOE’s Analysis
DOE’s no-new-standards case for the
electric power sector reflects the AEO,
which incorporates the projected
impacts of existing air quality
regulations on emissions. AEO2023
generally represents current legislation
and environmental regulations,
including recent government actions,
that were in place at the time of
preparation of AEO2023, including the
emissions control programs discussed in
the following paragraphs.113
SO2 emissions from affected electric
generating units (‘‘EGUs’’) are subject to
nationwide and regional emissions capand-trade programs. Title IV of the
Clean Air Act sets an annual emissions
cap on SO2 for affected EGUs in the 48
contiguous States and the District of
Columbia (DC). (42 U.S.C. 7651 et seq.)
SO2 emissions from numerous States in
the eastern half of the United States are
also limited under the Cross-State Air
Pollution Rule (‘‘CSAPR’’). 76 FR 48208
(Aug. 8, 2011). CSAPR requires these
States to reduce certain emissions,
including annual SO2 emissions, and
112 Available at: www.epa.gov/sites/production/
files/2021-04/documents/emission-factors_
apr2021.pdf (last accessed July 12, 2021).
113 For further information, see the Assumptions
to AEO2023 report that sets forth the major
assumptions used to generate the projections in the
Annual Energy Outlook. Available at: www.eia.gov/
outlooks/aeo/assumptions/ (last accessed February
6, 2023).
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went into effect as of January 1,
2015.114 AEO2023 incorporates
implementation of CSAPR, including
the update to the CSAPR ozone season
program emission budgets and target
dates issued in 2016. 81 FR 74504 (Oct.
26, 2016). Compliance with CSAPR is
flexible among EGUs and is enforced
through the use of tradable emissions
allowances. Under existing EPA
regulations, any excess SO2 emissions
allowances resulting from the lower
electricity demand caused by the
adoption of an efficiency standard could
be used to permit offsetting increases in
SO2 emissions by another regulated
EGU.
However, beginning in 2016, SO2
emissions began to fall as a result of the
Mercury and Air Toxics Standards
(‘‘MATS’’) for power plants. 77 FR 9304
(Feb. 16, 2012). In the MATS final rule,
EPA established a standard for hydrogen
chloride as a surrogate for acid gas
hazardous air pollutants (‘‘HAP’’), and
also established a standard for SO2 (a
non-HAP acid gas) as an alternative
equivalent surrogate standard for acid
gas HAP. The same controls are used to
reduce HAP and non-HAP acid gas;
thus, SO2 emissions are being reduced
as a result of the control technologies
installed on coal-fired power plants to
comply with the MATS requirements
for acid gas. In order to continue
operating, coal power plants must have
either flue gas desulfurization or dry
sorbent injection systems installed. Both
technologies, which are used to reduce
acid gas emissions, also reduce SO2
emissions. Because of the emissions
reductions under the MATS, it is
unlikely that excess SO2 emissions
allowances resulting from the lower
electricity demand would be needed or
used to permit offsetting increases in
SO2 emissions by another regulated
EGU. Therefore, energy conservation
standards that decrease electricity
generation would generally reduce SO2
emissions. DOE estimated SO2
emissions reduction using emissions
factors based on AEO2023.
CSAPR also established limits on NOX
emissions for numerous States in the
114 CSAPR requires States to address annual
emissions of SO2 and NOX, precursors to the
formation of fine particulate matter (PM2.5)
pollution, in order to address the interstate
transport of pollution with respect to the 1997 and
2006 PM2.5 National Ambient Air Quality Standards
(‘‘NAAQS’’). CSAPR also requires certain States to
address the ozone season (May–September)
emissions of NOX, a precursor to the formation of
ozone pollution, in order to address the interstate
transport of ozone pollution with respect to the
1997 ozone NAAQS. 76 FR 48208 (Aug. 8, 2011).
EPA subsequently issued a supplemental rule that
included an additional five States in the CSAPR
ozone season program; 76 FR 80760 (Dec. 27, 2011)
(Supplemental Rule).
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eastern half of the United States. Energy
conservation standards would have
little effect on NOX emissions in those
States covered by CSAPR emissions
limits if excess NOX emissions
allowances resulting from the lower
electricity demand could be used to
permit offsetting increases in NOX
emissions from other EGUs. In such
case, NOX emissions would remain near
the limit even if electricity generation
goes down. A different case could
possibly result, depending on the
configuration of the power sector in the
different regions and the need for
allowances, such that NOX emissions
might not remain at the limit in the case
of lower electricity demand. In this case,
energy conservation standards might
reduce NOX emissions in covered
States. Despite this possibility, DOE has
chosen to be conservative in its analysis
and has maintained the assumption that
standards will not reduce NOX
emissions in States covered by CSAPR.
Energy conservation standards would be
expected to reduce NOX emissions in
the States not covered by CSAPR. DOE
used AEO2023 data to derive NOX
emissions factors for the group of States
not covered by CSAPR.
The MATS limit mercury emissions
from power plants, but they do not
include emissions caps and, as such,
DOE’s energy conservation standards
would be expected to slightly reduce Hg
emissions. DOE estimated mercury
emissions reduction using emissions
factors based on AEO2023, which
incorporates the MATS.
L. Monetizing Emissions Impacts
As part of the development of this
proposed rule, for the purpose of
complying with the requirements of
Executive Order 12866, DOE considered
the estimated monetary benefits from
the reduced emissions of CO2, CH4,
N2O, NOX, and SO2 that are expected to
result from each of the TSLs considered.
In order to make this calculation
analogous to the calculation of the NPV
of consumer benefit, DOE considered
the reduced emissions expected to
result over the lifetime of products
shipped in the projection period for
each TSL. This section summarizes the
basis for the values used for monetizing
the emissions benefits and presents the
values considered in this NOPR.
To monetize the benefits of reducing
GHG emissions, this analysis uses the
interim estimates presented in the
Technical Support Document: Social
Cost of Carbon, Methane, and Nitrous
Oxide Interim Estimates Under
Executive Order 13990 published in
February 2021 by the IWG.
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1. Monetization of Greenhouse Gas
Emissions
DOE estimates the monetized benefits
of the reductions in emissions of CO2,
CH4, and N2O by using a measure of the
SC of each pollutant (e.g., SC–CO2).
These estimates represent the monetary
value of the net harm to society
associated with a marginal increase in
emissions of these pollutants in a given
year, or the benefit of avoiding that
increase. These estimates are intended
to include (but are not limited to)
climate-change-related changes in net
agricultural productivity, human health,
property damages from increased flood
risk, disruption of energy systems, risk
of conflict, environmental migration,
and the value of ecosystem services.
DOE exercises its own judgment in
presenting monetized climate benefits
as recommended by applicable
Executive orders, and DOE would reach
the same conclusion presented in this
proposed rulemaking in the absence of
the social cost of greenhouse gases. That
is, the social costs of greenhouse gases,
whether measured using the February
2021 interim estimates presented by the
Interagency Working Group on the
Social Cost of Greenhouse Gases or by
another means, did not affect the rule
ultimately proposed by DOE.
DOE estimated the global social
benefits of CO2, CH4, and N2O
reductions using SC–GHG values that
were based on the interim values
presented in the Technical Support
Document: Social Cost of Carbon,
Methane, and Nitrous Oxide Interim
Estimates under Executive Order 13990,
published in February 2021 by the IWG.
The SC–GHGs is the monetary value of
the net harm to society associated with
a marginal increase in emissions in a
given year, or the benefit of avoiding
that increase. In principle, SC–GHGs
includes the value of all climate change
impacts, including (but not limited to)
changes in net agricultural productivity,
human health effects, property damage
from increased flood risk and natural
disasters, disruption of energy systems,
risk of conflict, environmental
migration, and the value of ecosystem
services. The SC–GHGs therefore
reflects the societal value of reducing
emissions of the gas in question by one
metric ton. The SC–GHGs is the
theoretically appropriate value to use in
conducting benefit-cost analyses of
policies that affect CO2, N2O and CH4
emissions. As a member of the IWG
involved in the development of the
February 2021 SC–GHG TSD, DOE
agrees that the interim SC–GHG
estimates represent the most appropriate
estimate of the SC–GHG until revised
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estimates have been developed
reflecting the latest, peer-reviewed
science.
The SC–GHGs estimates presented
here were developed over many years,
using transparent process, peerreviewed methodologies, the best
science available at the time of that
process, and with input from the public.
Specifically, in 2009, the IWG, which
included the DOE and other executive
branch agencies and offices, was
established to ensure that agencies were
using the best available science and to
promote consistency in the social cost of
carbon (SC-CO2) values used across
agencies. The IWG published SC-CO2
estimates in 2010 that were developed
from an ensemble of three widely cited
integrated assessment models (IAMs)
that estimate global climate damages
using highly aggregated representations
of climate processes and the global
economy combined into a single
modeling framework. The three IAMs
were run using a common set of input
assumptions in each model for future
population, economic, and CO2
emissions growth, as well as
equilibrium climate sensitivity—a
measure of the globally averaged
temperature response to increased
atmospheric CO2 concentrations. These
estimates were updated in 2013 based
on new versions of each IAM. In August
2016, the IWG published estimates of
the social cost of methane (SC-CH4) and
nitrous oxide (SC-N2O) using
methodologies that are consistent with
the methodology underlying the SC-CO2
estimates. The modeling approach that
extends the IWG SC-CO2 methodology
to non-CO2 GHGs has undergone
multiple stages of peer review. The SCCH4 and SC-N2O estimates were
developed by Marten et al.115 and
underwent a standard double-blind peer
review process prior to journal
publication. In 2015, as part of the
response to public comments received
to a 2013 solicitation for comments on
the SC-CO2 estimates, the IWG
announced a National Academies of
Sciences, Engineering, and Medicine
review of the SC-CO2 estimates to offer
advice on how to approach future
updates to ensure that the estimates
continue to reflect the best available
science and methodologies. In January
2017, the National Academies released
their final report, Valuing Climate
Damages: Updating Estimation of the
Social Cost of Carbon Dioxide, and
recommended specific criteria for future
updates to the SC-CO2 estimates, a
modeling framework to satisfy the
specified criteria, and both near-term
updates and longer-term research needs
pertaining to various components of the
estimation process (National
Academies, 2017).116 Shortly thereafter,
in March 2017, President Trump issued
Executive Order 13783, which
disbanded the IWG, withdrew the
previous TSDs, and directed agencies to
ensure SC-CO2 estimates used in
regulatory analyses are consistent with
the guidance contained in OMB’s
Circular A–4, ‘‘including with respect to
the consideration of domestic versus
international impacts and the
consideration of appropriate discount
rates’’ (E.O. 13783, Section 5(c)).
Benefit-cost analyses following E.O.
13783 used SC–GHG estimates that
attempted to focus on the U.S.-specific
share of climate change damages as
estimated by the models and were
calculated using two discount rates
recommended by Circular A–4, 3
percent and 7 percent. All other
methodological decisions and model
versions used in SC–GHG calculations
remained the same as those used by the
IWG in 2010 and 2013, respectively.
On January 20, 2021, President Biden
issued Executive Order 13990, which reestablished the IWG and directed it to
ensure that the U.S. Government’s
estimates of the social cost of carbon
and other greenhouse gases reflect the
best available science and the
recommendations of the National
Academies (2017). The IWG was tasked
with first reviewing the SC–GHG
estimates currently used in Federal
analyses and publishing interim
estimates within 30 days of the E.O. that
reflect the full impact of GHG
emissions, including by taking global
damages into account. The interim SC–
GHG estimates published in February
2021 are used here to estimate the
climate benefits for this proposed
rulemaking. The E.O. instructs the IWG
to update the interim SC–GHG estimates
by January 2022 taking into
consideration the advice of the National
Academies of Science, Engineering, and
Medicine as reported in Valuing Climate
Damages: Updating Estimation of the
Social Cost of Carbon Dioxide (2017)
and other recent scientific literature.
The February 2021 SC–GHG TSD
provides a complete discussion of the
IWG’s initial review conducted under
115 Marten, A.L., E.A. Kopits, C.W. Griffiths, S.C.
Newbold, and A. Wolverton. Incremental CH4 and
N2O mitigation benefits consistent with the US
Government’s SC-CO2 estimates. Climate Policy.
2015. 15(2): pp. 272–298.
116 National Academies of Sciences, Engineering,
and Medicine. Valuing Climate Damages: Updating
Estimation of the Social Cost of Carbon Dioxide.
2017. The National Academies Press: Washington,
DC.
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E.O. 13990. In particular, the IWG found
that the SC–GHG estimates used under
E.O. 13783 fail to reflect the full impact
of GHG emissions in multiple ways.
First, the IWG found that the SC–GHG
estimates used under E.O. 13783 fail to
fully capture many climate impacts that
affect the welfare of U.S. citizens and
residents, and those impacts are better
reflected by global measures of the SC–
GHG. Examples of omitted effects from
the E.O. 13783 estimates include direct
effects on U.S. citizens, assets, and
investments located abroad; supply
chains, U.S. military assets and interests
abroad, and tourism; and spillover
pathways such as economic and
political destabilization and global
migration that can lead to adverse
impacts on U.S. national security,
public health, and humanitarian
concerns. In addition, assessing the
benefits of U.S. GHG mitigation
activities requires consideration of how
those actions may affect mitigation
activities by other countries, as those
international mitigation actions will
provide a benefit to U.S. citizens and
residents by mitigating climate impacts
that affect U.S. citizens and residents. A
wide range of scientific and economic
experts have emphasized the issue of
reciprocity as support for considering
global damages of GHG emissions. If the
United States does not consider impacts
on other countries, it is difficult to
convince other countries to consider the
impacts of their emissions on the United
States. The only way to achieve an
efficient allocation of resources for
emissions reduction on a global basis—
and so benefit the United States and its
citizens—is for all countries to base
their policies on global estimates of
damages. As a member of the IWG
involved in the development of the
February 2021 SC–GHG TSD, DOE
agrees with this assessment and,
therefore, in this proposed rule DOE
centers attention on a global measure of
SC–GHG. This approach is the same as
that taken in DOE regulatory analyses
from 2012 through 2016. A robust
estimate of climate damages that accrue
only to U.S. citizens and residents does
not currently exist in the literature. As
explained in the February 2021 TSD,
existing estimates are both incomplete
and an underestimate of total damages
that accrue to the citizens and residents
of the U.S. because they do not fully
capture the regional interactions and
spillovers discussed above, nor do they
include all of the important physical,
ecological, and economic impacts of
climate change recognized in the
climate change literature. As noted in
the February 2021 SC–GHG TSD, the
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IWG will continue to review
developments in the literature,
including more robust methodologies
for estimating a U.S.-specific SC–GHG
value, and explore ways to better inform
the public of the full range of carbon
impacts. As a member of the IWG, DOE
will continue to follow developments in
the literature pertaining to this issue.
Second, the IWG found that the use of
the social rate of return on capital (7
percent under current OMB Circular A–
4 guidance) to discount the future
benefits of reducing GHG emissions
inappropriately underestimates the
impacts of climate change for the
purposes of estimating the SC–GHG.
Consistent with the findings of the
National Academies (2017) and the
economic literature, the IWG continued
to conclude that the consumption rate of
interest is the theoretically appropriate
discount rate in an intergenerational
context 117 and recommended that
discount rate uncertainty and relevant
aspects of intergenerational ethical
considerations be accounted for in
selecting future discount rates.
Furthermore, the damage estimates
developed for use in the SC–GHG are
estimated in consumption-equivalent
terms, and so an application of OMB
Circular A–4’s guidance for regulatory
analysis would then use the
consumption discount rate to calculate
the SC–GHG. DOE agrees with this
assessment and will continue to follow
developments in the literature
pertaining to this issue. DOE also notes
that while OMB Circular A–4, as
published in 2003, recommends using 3
percent and 7 percent discount rates as
117 Interagency Working Group on Social Cost of
Carbon. Social Cost of Carbon for Regulatory Impact
Analysis under Executive Order 12866. 2010.
United States Government. Available at:
www.epa.gov/sites/default/files/2016-12/
documents/scc_tsd_2010.pdf (last accessed April
15, 2022); Interagency Working Group on Social
Cost of Carbon. Technical Update of the Social Cost
of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. 2013. Available at:
www.federalregister.gov/documents/2013/11/26/
2013-28242/technical-support-document-technicalupdate-of-the-social-cost-of-carbon-for-regulatoryimpact (last accessed April 15, 2022); Interagency
Working Group on Social Cost of Greenhouse Gases,
United States Government. Technical Support
Document: Technical Update on the Social Cost of
Carbon for Regulatory Impact Analysis-Under
Executive Order 12866. August 2016. Available at:
www.epa.gov/sites/default/files/2016-12/
documents/sc_co2_tsd_august_2016.pdf (last
accessed January 18, 2022); Interagency Working
Group on Social Cost of Greenhouse Gases, United
States Government. Addendum to Technical
Support Document on Social Cost of Carbon for
Regulatory Impact Analysis under Executive Order
12866: Application of the Methodology to Estimate
the Social Cost of Methane and the Social Cost of
Nitrous Oxide. August 2016. Available at:
www.epa.gov/sites/default/files/2016-12/
documents/addendum_to_sc-ghg_tsd_august_
2016.pdf (last accessed January 18, 2022).
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‘‘default’’ values, Circular A–4 also
reminds agencies that ‘‘different
regulations may call for different
emphases in the analysis, depending on
the nature and complexity of the
regulatory issues and the sensitivity of
the benefit and cost estimates to the key
assumptions.’’ On discounting, Circular
A–4 recognizes that ‘‘special ethical
considerations arise when comparing
benefits and costs across generations,’’
and Circular A–4 acknowledges that
analyses may appropriately ‘‘discount
future costs and consumption benefits
. . . at a lower rate than for
intragenerational analysis.’’ In the 2015
Response to Comments on the Social
Cost of Carbon for Regulatory Impact
Analysis, OMB, DOE, and the other IWG
members recognized that ‘‘Circular A–4
is a living document’’ and ‘‘the use of
7 percent is not considered appropriate
for intergenerational discounting. There
is wide support for this view in the
academic literature, and it is recognized
in Circular A–4 itself.’’ Thus, DOE
concludes that a 7% discount rate is not
appropriate to apply to value the social
cost of greenhouse gases in the analysis
presented in this analysis.
To calculate the present and
annualized values of climate benefits,
DOE uses the same discount rate as the
rate used to discount the value of
damages from future GHG emissions, for
internal consistency. That approach to
discounting follows the same approach
that the February 2021 SC–GHG TSD
recommends ‘‘to ensure internal
consistency—i.e., future damages from
climate change using the SC–GHG at 2.5
percent should be discounted to the
base year of the analysis using the same
2.5 percent rate.’’ DOE has also
consulted the National Academies’ 2017
recommendations on how SC–GHG
estimates can ‘‘be combined in RIAs
with other cost and benefits estimates
that may use different discount rates.’’
The National Academies reviewed
several options, including ‘‘presenting
all discount rate combinations of other
costs and benefits with [SC–GHG]
estimates.’’ As a member of the IWG
involved in the development of the
February 2021 SC–GHG TSD, DOE
agrees with the above assessment and
will continue to follow developments in
the literature pertaining to this issue.
While the IWG works to assess how best
to incorporate the latest, peer-reviewed
science to develop an updated set of
SC–GHG estimates, it set the interim
estimates to be the most recent estimates
developed by the IWG prior to the group
being disbanded in 2017. The estimates
rely on the same models and
harmonized inputs and are calculated
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using a range of discount rates. As
explained in the February 2021 SC–
GHG TSD, the IWG has recommended
that agencies revert to the same set of
four values drawn from the SC–GHG
distributions based on three discount
rates as were used in regulatory analyses
between 2010 and 2016 and were
subject to public comment. For each
discount rate, the IWG combined the
distributions across models and
socioeconomic emissions scenarios
(applying equal weight to each) and
then selected a set of four values
recommended for use in benefit-cost
analyses: an average value resulting
from the model runs for each of three
discount rates (2.5 percent, 3 percent,
and 5 percent), plus a fourth value,
selected as the 95th percentile of
estimates based on a 3 percent discount
rate. The fourth value was included to
provide information on potentially
higher-than-expected economic impacts
from climate change. As explained in
the February 2021 SC–GHG TSD, and
DOE agrees, this update reflects the
immediate need to have an operational
SC–GHG for use in regulatory benefitcost analyses and other applications that
is developed using a transparent
process, peer-reviewed methodologies,
and the science available at the time of
that process. Those estimates were
subject to public comment in the
context of dozens of proposed
rulemakings as well as in a dedicated
public comment period in 2013.
There are a number of limitations and
uncertainties associated with the SC–
GHG estimates. First, the current
scientific and economic understanding
of discounting approaches suggests
discount rates appropriate for
intergenerational analysis in the context
of climate change are likely to be less
than 3 percent, near 2 percent or
lower.118 Second, the IAMs used to
produce these interim estimates do not
include all of the important physical,
ecological, and economic impacts of
climate change recognized in the
climate change literature and the
science underlying their ‘‘damage
functions’’ (i.e., the core parts of the
IAMs that map global mean temperature
changes and other physical impacts of
climate change into economic (both
market and nonmarket) damages) lags
behind the most recent research. For
118 Interagency Working Group on Social Cost of
Greenhouse Gases (IWG). 2021. Technical Support
Document: Social Cost of Carbon, Methane, and
Nitrous Oxide Interim Estimates under Executive
Order 13990. February. United States Government.
Available at: www.whitehouse.gov/briefing-room/
blog/2021/02/26/a-return-to-science-evidencebased-estimates-of-the-benefits-of-reducing-climatepollution/.
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example, limitations include the
incomplete treatment of catastrophic
and non-catastrophic impacts in the
integrated assessment models, their
incomplete treatment of adaptation and
technological change, the incomplete
way in which inter-regional and
intersectoral linkages are modeled,
uncertainty in the extrapolation of
damages to high temperatures, and
inadequate representation of the
relationship between the discount rate
and uncertainty in economic growth
over long-time horizons. Likewise, the
socioeconomic and emissions scenarios
used as inputs to the models do not
reflect new information from the last
decade of scenario generation or the full
range of projections. The modeling
limitations do not all work in the same
direction in terms of their influence on
the SC–CO2 estimates. However, as
discussed in the February 2021 TSD, the
IWG has recommended that, taken
together, the limitations suggest that the
interim SC–GHG estimates used in this
proposed rule likely underestimate the
damages from GHG emissions. DOE
concurs with this assessment.
DOE’s derivations of the SC–CO2, SC–
N2O, and SC–CH4 values used for this
NOPR are discussed in the following
sections, and the results of DOE’s
analyses estimating the benefits of the
reductions in emissions of these GHGs
are presented in section IV.L.1.a of this
document.
a. Social Cost of Carbon
The SC–CO2 values used for this
NOPR were based on the values
presented for the IWG’s February 2021
TSD. Table IV shows the updated sets
of SC–CO2 estimates from the IWG’s
TSD in 5-year increments from 2020 to
2050. The full set of annual values that
DOE used is presented in appendix 14–
A of the NOPR TSD. For purposes of
capturing the uncertainties involved in
regulatory impact analysis, DOE has
determined it is appropriate include all
four sets of SC–CO2 values, as
recommended by the IWG.119
Table IV-22 Annual SC-CO2 Values from 2021 Interagency Update, 2020-2050
(2020$ per Metric Ton CO2)
5%
Avera2e
2020
2025
2030
2035
2040
2045
2050
14
17
19
22
25
28
32
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For 2051 to 2070, DOE used SC–CO2
estimates published by EPA, adjusted to
2020$.120 These estimates are based on
methods, assumptions, and parameters
identical to the 2020–2050 estimates
published by the IWG (which were
based on EPA modeling). DOE expects
additional climate benefits to accrue for
any longer-life fans and blowers after
2070, but a lack of available SC–CO2
estimates for emissions years beyond
2070 prevents DOE from monetizing
these potential benefits in this analysis.
DOE multiplied the CO2 emissions
reduction estimated for each year by the
119 For example, the February 2021 TSD discusses
how the understanding of discounting approaches
suggests that discount rates appropriate for
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Discount Rate and Statistic
3%
2.5%
Avera2e
Avera2e
51
56
62
67
73
79
85
76
83
89
96
103
ll0
ll6
SC–CO2 value for that year in each of
the four cases. DOE adjusted the values
to 2022 dollars using the implicit price
deflator for gross domestic product
(‘‘GDP’’) from the Bureau of Economic
Analysis. To calculate a present value of
the stream of monetary values, DOE
discounted the values in each of the
four cases using the specific discount
rate that had been used to obtain the
SC–CO2 values in each case.
3%
95th percentile
152
169
187
206
225
242
260
b. Social Cost of Methane and Nitrous
Oxide
The SC–CH4 and SC–N2O values used
for this NOPR were based on the values
developed for the February 2021 TSD.
Table IV–23 shows the updated sets of
SC–CH4 and SC–N2O estimates from the
latest interagency update in 5-year
increments from 2020 to 2050. The full
set of annual values used is presented
in appendix 14–A of the NOPR TSD. To
capture the uncertainties involved in
regulatory impact analysis, DOE has
determined it is appropriate to include
all four sets of SC–CH4 and SC–N2O
values, as recommended by the IWG.
DOE derived values after 2050 using the
approach described above for the SC–
CO2.
intergenerational analysis in the context of climate
change may be lower than 3 percent.
120 See EPA, Revised 2023 and Later Model Year
Light-Duty Vehicle GHG Emissions Standards:
Regulatory Impact Analysis, Washington, DC,
December 2021. Available at: https://nepis.epa.gov/
Exe/ZyPDF.cgi?Dockey=P1013ORN.pdf (last
accessed January 13, 2023).
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Table IV-23 Annual SC-CH4 and SC-N2O Values from 2021 Interagency Update,
2020-2050 (2020$ per Metric Ton)
2020
2025
2030
2035
2040
2045
2050
SC-N20
Discount Rate and Statistic
5%
3%
2.5%
Average
Average
Average
670
800
940
1500
1700
2000
2200
2500
2800
3100
2000
2200
2500
2800
3100
3500
3800
llOO
1300
1500
1700
DOE multiplied the CH4 and N2O
emissions reduction estimated for each
year by the SC–CH4 and SC–N2O
estimates for that year in each of the
cases. DOE adjusted the values to 2022
dollars using the implicit price deflator
for gross domestic product (‘‘GDP’’)
from the Bureau of Economic Analysis.
To calculate a present value of the
stream of monetary values, DOE
discounted the values in each of the
cases using the specific discount rate
that had been used to obtain the SC–CH4
and SC–N2O estimates in each case.
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2. Monetization of Other Emissions
Impacts
For the NOPR, DOE estimated the
monetized value of NOX and SO2
emissions reductions from electricity
generation using the latest benefit per
ton estimates for that sector from the
EPA’s Benefits Mapping and Analysis
Program.121 DOE used EPA’s values for
PM2.5-related benefits associated with
NOX and SO2 and for ozone-related
benefits associated with NOX for 2025,
2030, and 2040, calculated with
discount rates of 3 percent and 7
percent. DOE used linear interpolation
to define values for the years not given
in the 2025 to 2040 period; for years
beyond 2040 the values are held
constant. DOE combined the EPA
benefit per ton estimates with regional
information on electricity consumption
and emissions to define weightedaverage national values for NOX and
SO2 as a function of sector (see
appendix 14B of the NOPR TSD). DOE
multiplied the site emissions reduction
(in tons) in each year by the associated
$/ton values, and then discounted each
series using discount rates of 3 percent
and 7 percent as appropriate.
121 See Estimating the Benefit per Ton of
Reducing PM2.5 Precursors from 21 Sectors.
Available at: www.epa.gov/benmap/estimatingbenefit-ton-reducing-pm25-precursors-21-sectors.
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3%
95th
percentile
3900
4500
5200
6000
6700
7500
8200
5%
3%
2.5%
Average
Average
Average
5800
6800
7800
9000
10000
12000
13000
18000
21000
23000
25000
28000
30000
33000
27000
30000
33000
36000
39000
42000
45000
M. Utility Impact Analysis
The utility impact analysis estimates
the changes in installed electrical
capacity and generation projected to
result for each considered TSL. The
analysis is based on published output
from the NEMS associated with
AEO2023. NEMS produces the AEO
Reference case, as well as a number of
side cases that estimate the economywide impacts of changes to energy
supply and demand. For the current
analysis, impacts are quantified by
comparing the levels of electricity sector
generation, installed capacity, fuel
consumption and emissions in the
AEO2023 Reference case and various
side cases. Details of the methodology
are provided in the appendices to
chapters 13 and 15 of the NOPR TSD.
The output of this analysis is a set of
time-dependent coefficients that capture
the change in electricity generation,
primary fuel consumption, installed
capacity and power sector emissions
due to a unit reduction in demand for
a given end use. These coefficients are
multiplied by the stream of electricity
savings calculated in the NIA to provide
estimates of selected utility impacts of
potential new or amended energy
conservation standards.
N. Employment Impact Analysis
DOE considers employment impacts
in the domestic economy as one factor
in selecting a proposed standard.
Employment impacts from new or
amended energy conservation standards
include both direct and indirect
impacts. Direct employment impacts are
any changes in the number of
employees of manufacturers of the
equipment subject to standards, their
suppliers, and related service firms. The
MIA addresses those impacts. Indirect
employment impacts are changes in
national employment that occur due to
the shift in expenditures and capital
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3%
95th
percentile
48000
54000
60000
67000
74000
81000
88000
investment caused by the purchase and
operation of more efficient appliances.
Indirect employment impacts from
standards consist of the net jobs created
or eliminated in the national economy,
other than in the manufacturing sector
being regulated, caused by (1) reduced
spending by consumers on energy, (2)
reduced spending on new energy supply
by the utility industry, (3) increased
consumer spending on the equipment to
which the new standards apply and
other goods and services, and (4) the
effects of those three factors throughout
the economy.
One method for assessing the possible
effects on the demand for labor of such
shifts in economic activity is to compare
sector employment statistics developed
by the Labor Department’s Bureau of
Labor Statistics (‘‘BLS’’). BLS regularly
publishes its estimates of the number of
jobs per million dollars of economic
activity in different sectors of the
economy, as well as the jobs created
elsewhere in the economy by this same
economic activity. Data from BLS
indicate that expenditures in the utility
sector generally create fewer jobs (both
directly and indirectly) than
expenditures in other sectors of the
economy.122 There are many reasons for
these differences, including wage
differences and the fact that the utility
sector is more capital-intensive and less
labor-intensive than other sectors.
Energy conservation standards have the
effect of reducing consumer utility bills.
Because reduced consumer
expenditures for energy likely lead to
increased expenditures in other sectors
of the economy, the general effect of
efficiency standards is to shift economic
122 See U.S. Department of Commerce–Bureau of
Economic Analysis. Regional Multipliers: A User
Handbook for the Regional Input-Output Modeling
System (RIMS II). 1997. U.S. Government Printing
Office: Washington, DC. Available at: https://
apps.bea.gov/scb/pdf/regional/perinc/meth/
rims2.pdf (last accessed March 27, 2023).
E:\FR\FM\19JAP2.SGM
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EP19JA24.044
Year
SC-CH4
Discount Rate and Statistic
3804
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
activity from a less labor-intensive
sector (i.e., the utility sector) to more
labor-intensive sectors (e.g., the retail
and service sectors). Thus, the BLS data
suggest that net national employment
may increase due to shifts in economic
activity resulting from energy
conservation standards.
DOE estimated indirect national
employment impacts for the standard
levels considered in this NOPR using an
input/output model of the U.S. economy
called Impact of Sector Energy
Technologies version 4 (‘‘ImSET’’).123
ImSET is a special-purpose version of
the ‘‘U.S. Benchmark National InputOutput’’ (‘‘I–O’’) model, which was
designed to estimate the national
employment and income effects of
energy-saving technologies. The ImSET
software includes a computer-based I–O
model containing structural coefficients
that characterize economic flows among
187 sectors most relevant to industrial,
commercial, and residential building
energy use.
DOE notes that ImSET is not a general
equilibrium forecasting model, and that
the uncertainties involved in projecting
employment impacts especially changes
in the later years of the analysis.
Because ImSET does not incorporate
price changes, the employment effects
predicted by ImSET may overestimate
actual job impacts over the long run for
this rule. Therefore, DOE used ImSET
only to generate results for near-term
timeframes (2034), where these
uncertainties are reduced. For more
details on the employment impact
analysis, see chapter 16 of the NOPR
TSD.
V. Analytical Results and Conclusions
The following section addresses the
results from DOE’s analyses with
respect to the considered energy
conservation standards for GFBs and
ACFs. It addresses the TSLs examined
by DOE, the projected impacts of each
of these levels if adopted as energy
conservation standards for GFBs and
ACFs, and the standards levels that DOE
is proposing to adopt in this NOPR.
Additional details regarding DOE’s
analyses are contained in the NOPR
TSD supporting this document.
A. Trial Standard Levels
In general, DOE typically evaluates
potential standards for products and
equipment by grouping individual
efficiency levels for each class into
TSLs. Use of TSLs allows DOE to
identify and consider manufacturer cost
interactions between the equipment
classes, to the extent that there are such
interactions, and market cross elasticity
from consumer purchasing decisions
that may change when different
standard levels are set.
For GFBs, in the analysis conducted
for this NOPR, DOE analyzed the
benefits and burdens of 6 TSLs. DOE
developed TSLs that combine efficiency
levels for each analyzed equipment
class.
Table V–1 presents the TSLs and the
corresponding efficiency levels that
DOE has identified for potential new
energy conservation standards for GFBs.
TSL 6 represents the max-tech energy
efficiency for all product classes. TSL 5
represents the highest efficiency level
with positive LCC savings. TSL 4 is an
intermediate level consisting of the next
level below TSL 5 with positive LCC
savings. TSL 3 is an intermediate level
consisting of the same level as TSL 4 or
in the next level below TSL 4 with
positive LCC savings and above TSL 2,
where available. TSL 2 represents a
combination of efficiency levels that
correspond to a FEI of 1 across all
equipment classes as required in
ASHRAE 90.1, except for Axial Power
Roof Ventilator—Exhaust, where it is set
one efficiency level lower due to
negative LCC savings at the EL
corresponding to a FEI value of 1 (EL 5).
TSL 1 represents combination of
efficiency levels that corresponds to one
efficiency level below the efficiency
level corresponding to a FEI value of 1.
Equipment Class
TSLl
TSL2
TSL3
TSL4
TSL5
TSL6
Axial Inline Fans
Axial Panel Fans
Centrifugal Housed Fans
Centrifugal Inline Fans
Centrifugal Unhoused Fans
Axial Power Roof-Ventilator Exhaust
Centrifugal Power Roof-Ventilator Exhaust
Centrifugal Power Roof-Ventilator Supply
Radial Housed Fans
ELI
ELI
ELI
EL2
ELI
EL4
EL2
EL2
EL2
EL3
ELI
EL4
EL3
EL3
EL3
EL4
EL3
EL4
EL3
EL4
EL4
EL5
EL4
EL4
EL4
EL5
EL5
EL6
EL5
EL4
EL5
EL5
EL5
EL6
EL5
EL7
EL3
EL4
EL4
EL4
EL4
EL6
EL3
EL4
EL5
EL5
EL6
EL6
EL2
EL3
EL4
EL4
EL5
EL5
DOE constructed the TSLs for this
NOPR to include ELs representative of
ELs with similar characteristics (i.e.,
using similar technologies and/or
efficiencies, and having roughly
comparable equipment availability). The
use of representative ELs provided for
greater distinction between the TSLs.
DOE did not consider ELs for which the
average LCC savings were negative other
than for TSL 6 (max-tech). While
representative ELs were included in the
TSLs, DOE considered all efficiency
levels as part of its analysis.124
123 Livingston, O.V., S.R. Bender, M.J. Scott, and
R.W. Schultz. ImSET 4.0: Impact of Sector Energy
Technologies Model Description and User Guide.
2015. Pacific Northwest National Laboratory:
Richland, WA. PNNL–24563.
124 Efficiency levels that were analyzed for this
NOPR are discussed in section IV.C of this
document. Results by efficiency level are presented
in NOPR TSD chapter 8.
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Table V-1 Trial Standard Levels for GFBs
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
For ACFs, in the analysis conducted
for this NOPR, DOE analyzed the
benefits and burdens of six TSLs. DOE
developed TSLs that combine efficiency
levels for each analyzed equipment
class.
Table V–2 presents the TSLs and the
corresponding efficiency levels that
DOE has identified for potential new
energy conservation standards for ACFs.
TSL 6 represents the max-tech energy
efficiency for all equipment classes. TSL
5 represents a level corresponding to EL
5 for all axial ACFs and EL 3 for housed
centrifugal ACFs. It represents the
highest EL below max-tech with
3805
positive LCC savings. TSL 4 is
constructed with the same efficiency
level EL 4 for all axial ACFs and
represents EL 0 for housed centrifugal
ACFs. Similarly, TSL 3 through TSL 1
represent levels corresponding to EL 3
through EL 1 for all axial ACFs and EL
0 for housed centrifugal ACFs.
Table V-2 Trial Standard Levels for ACFs
TSLl TSL2 TSL3 TSIA TSL5 TSL6
Eauiument Class
Axial ACFs; 12" s D < 36" (ACFl)
ELI
EL2
EL3
EL4
EL5
EL6
Axial ACFs; 36" s D < 48" (ACF2)
ELI
EL2
EL3
EL4
EL5
EL6
Axial ACFs; 48" s D (ACF3)
ELI
EL2
EL3
EL4
EL5
EL6
Housed Centrifugal ACFs (ACF4)
ELO
ELO
ELO
ELO
EL3
EL6
DOE constructed the TSLs for this
NOPR to include ELs representative of
ELs with similar characteristics (i.e.,
using similar technologies within
similar equipment classes). DOE did not
consider EL 1 through EL 2 for housed
centrifugal ACFs as the average LCC
savings are negative at these levels for
this equipment class. While
representative ELs were included in the
TSLs, DOE considered all efficiency
levels as part of its analysis.125
B. Economic Justification and Energy
Savings
a. Life-Cycle Cost and Payback Period
In general, higher-efficiency
equipment affects consumers in two
ways: (1) purchase price increases and
(2) annual operating costs decrease.
Inputs used for calculating the LCC and
PBP include total installed costs (i.e.,
product price plus installation costs),
and operating costs (i.e., annual energy
use, energy prices, energy price trends,
repair costs, and maintenance costs).
The LCC calculation also uses
equipment lifetime and a discount rate.
Chapter 8 of the NOPR TSD provides
detailed information on the LCC and
PBP analyses.
Table V–3 through Table V–20 show
the LCC and PBP results for the TSLs
considered for each equipment class for
GFBs. Table V–21 through Table V–28
show the LCC and PBP results for the
TSLs considered for each equipment
class for ACFs. The simple payback and
other impacts are measured relative to
the efficiency distribution in the nonew-standards case in the compliance
year (see section IV.F.8 of this
document). Because the average LCC
savings refer only to consumers who are
affected by a standard at a given TSL,
the average savings are greater than the
difference between the average LCC in
the no-new-standards case and the
average LCC at each TSL. The savings
refer only to consumers who are affected
by a standard at a given TSL. Those who
already purchase equipment with
efficiency at or above a given TSL are
not affected. Consumers for whom the
LCC increases at a given TSL experience
a net cost.
BILLING CODE 6450–01–P
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new-standards case.
125 Efficiency levels that were analyzed for this
NOPR are discussed in section IV.C.1.b of this
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in NOPR TSD chapters 8.
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Table V-3 Avera2e LCC and PBP Results for Axial Inline Fans
Avera2e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Level
Period
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
0
11,748
1,690
20,464
32,212
27.6
11,756
1,682
20,364
32,120
1.0
27.6
1
1
2
2
11,873
1,669
20,209
32,082
5.8
27.6
12,465
1,616
19,563
32,028
3-4
3
9.6
27.6
13,704
1,490
18,034
31,738
5
4
9.8
27.6
6
5
18,129
1,334
16,148
34,276
17.9
27.6
EP19JA24.046
ddrumheller on DSK120RN23PROD with PROPOSALS2
1. Economic Impacts on Individual
Consumers
DOE analyzed the economic impacts
on fan and blower consumers by looking
at the effects that potential new
standards at each TSL would have on
the LCC and PBP. DOE also examined
the impacts of potential standards on
selected consumer subgroups. These
analyses are discussed in the following
sections.
3806
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-4 Average LCC Savings Relative to the No-New-Standards Case for Axial
Inline Fans
Life-Cycle Cost Savings
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1,766
1
1
0.9%
1,029
2
2
7.5%
3-4
3
550
23.6%
5
4
670
51.3%
6
5
-2,169
79.3%
* The savings represent the average LCC for affected consumers.
Table V-5 Average LCC and PBP Results for Axial Panel Fans
Average Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Period
Level
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
6,304
7,575
13,879
0
782
15.2
6,434
7,461
13,895
770
1
1
15.2
10.9
6,452
7,268
13,720
2
2
750
4.7
15.2
6,499
6,654
13,153
688
3
3
2.1
15.2
4
4
6,597
607
5,864
12,460
1.7
15.2
6,922
5,120
12,042
5-6
5
530
2.5
15.2
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
Table V-6 Average LCC Savings Relative to the No-New-Standards Case for Axial
Panel Fans
Life-Cycle Cost Savings
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1
1
-194
6.3%
2
2
802
7.3%
1,413
3
3
11.0%
1,702
4
4
19.5%
1,902
5-6
5
29.9%
EP19JA24.050
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* The savings represent the average LCC for affected consumers.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3807
Table V-7 Avera2e LCC and PBP Results for Centrifu2al Housed Fans
Avera2e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Period
Level
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
0
9,734
1,750
17,492
27,227
15.0
9,742
1,710
17,128
26,871
1
1
0.2
15.0
9,755
1,692
16,951
26,706
2
2
0.4
15.0
9,779
1,636
16,421
26,200
3
3
0.4
15.0
9,868
1,531
15,397
25,266
4
4
0.6
15.0
3.1
15.0
5-6
5
10,825
1,397
14,065
24,890
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
Table V-8 Average LCC Savings Relative to the No-New-Standards Case for
Centrifu2al Housed Fans
Life-Cycle Cost Savin2s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1,714
1
1
1.5%
1,977
2
2
2.4%
2,092
3
3
6.0%
2,423
12.9%
4
4
5-6
5
2,398
41.5%
* The savings represent the average LCC for affected consumers.
EP19JA24.053
EP19JA24.052
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
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I' F ans
Tabl e V-9Avera2e LCC an d PBP R esu It s tor Cen t r1'fu1iaI I nme
Avera2e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Level
Period
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
10,598
1,180
11,996
22,593
0
16.7
1
10,623
1,168
11,880
22,503
2.2
16.7
10,751
1,159
11,791
22,542
1
2
7.6
16.7
10,674
1,107
11,267
21,941
1.1
16.7
2
3
11,325
1,080
10,993
22,318
3
4
7.3
16.7
11,858
21,757
9,899
6.1
16.7
4
5
972
5-6
6
13,457
865
8,809
22,265
9.1
16.7
3808
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-10 Average LCC Savings Relative to the No-New-Standards Case for
Centrifu2al Inline Fans
Life-Cycle Cost Savines
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1
3.4%
L073
1
2
355
9.9%
2
3
4.6%
L389
3
4
454
36.6%
4
5
955
49.2%
5-6
6
335
66.7%
* The savings represent the average LCC for affected consumers.
Table V-11 Avera2e LCC and PBP Results for Centrifu2al
Avera2e Costs (2022$)
First
Efficiency
Lifetime
TSL
Installed
Year's
Level
Operating LCC
Operating
Cost
Cost
Cost
8,983
1,482
14,318
23,301
0
9,006
1,475
14,252
23,258
1-2
1
9,085
1,466
14,172
23,256
2
9,086
1,441
13,932
23,018
3
3
9,118
1,368
13,223
22,341
4
4
9,199
12,148
5-6
21.346
5
L257
Unhoused Fans
Simple
Average
Payback
Lifetime
Period
(years)
(years)
3.5
6.7
2.6
1.2
1.0
14.9
14.9
14.9
14.9
14.9
14.9
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
Table V-12 Average LCC Savings Relative to the No-New-Standards Case for
Centrifu2al U nhoused Fans
Life-Cycle Cost Savines
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1-2
1
1,009
2.2%
2
433
7.0%
3
3
884
4.8%
4
4
1,170
10.5%
5-6
5
2,004
13.7%
EP19JA24.056
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3809
Table V-13 Average LCC and PBP Results for Axial Power Roof-Ventilator APRV
Averaee Costs (2022$)
Simple
Average
First
Payback
Efficiency
Lifetime
TSL
Lifetime
Installed
Year's
Period
Level
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
9,488
1,085
11,173
20,661
17.5
0
9,652
1,063
10,940
20,592
1
7.5
17.5
9,665
1,058
10,884
20,549
6.5
17.5
2
9,470
1,050
10,803
20,273
3
NIA
17.5
1-5
9,958
1,017
10,458
20,416
7.0
17.5
4
11,695
9,704
21,399
945
15.8
17.5
5
14,382
802
8,232
22,614
17.3
17.5
6
22,584
7,046
29,630
6
687
32.9
17.5
7
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to the
no-new standards case. The entry "NI A" means not applicable because there is a decrease in average installed
costs at higher TSLs compared to the no-new-standards case.
Table V-14 Average LCC Savings Relative to the No-New-Standards Case for Axial
Power Roof-Ventilator - APRV
Life-Cycle Cost Savin es
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1,132
1
4.0%
1,076
2
5.9%
2,988
3
1.8%
1-5
4
945
14.3%
-1,463
5
41.7%
-2,402
6
68.3%
6
7
-9 470
89.0%
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* The savings represent the average LCC for affected consumers.
3810
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-15 Average LCC and PBP Results for Centrifugal Power Roof VentilatorExhaust CPRV
Avera2e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Period
Level
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
7,213
582
5,809
13,023
16.0
0
7,303
575
5,746
13,049
14.0
16.0
1
7,248
5,732
12,980
574
4.4
16.0
2
7,409
5,591
13,000
3
1
560
9.0
16.0
7,608
12,968
537
8.9
16.0
2-5
4
5J60
8,267
4,879
5
13J46
11.5
16.0
490
10,570
434
4,326
14,896
22.8
16.0
6
6
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
Table V-16 Average LCC Savings Relative to the No-New-Standards Case for
Cent ri"fu !aI Power R 00 f VenflI ator- Ex haus t CPRV
Life-Cycle Cost Savin2s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1
-339
5.8%
2
468
4.9%
1
3
122
13.1%
2-5
4
154
25.8%
5
-178
53.7%
6
6
-1,992
84.7%
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
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Table V-17 Average LCC and PBP Results for Centrifugal Power Roof Ventilator Supply CPRV
Avera2e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Level
Period
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
0
6,538
529
5,239
11,777
15.9
5,175
11,855
6,680
522
22.9
15.9
1
5,141
11,682
6,541
519
0.3
15.9
2
6,577
503
4,981
11,558
1.5
15.9
1
3
4,734
11,347
6,613
478
1.5
15.9
2
4
6,714
426
4,211
10,925
15.9
3-4
1.7
5
5-6
6,961
377
3,727
10,688
2.8
15.9
6
EP19JA24.059
ddrumheller on DSK120RN23PROD with PROPOSALS2
* The savings represent the average LCC for affected consumers.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3811
Table V-18 Average LCC Savings Relative to the No-New-Standards Case for
Centrifu~al Power Roof Ventilator - Supply CPRV
Life-Cvcle Cost Savine:s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
-
0
-1,228
1
932
2
831
1
3
827
2
4
973
3-4
5
1,126
5-6
6
* The savings represent the average LCC for affected consumers.
5.5%
3.1%
8.8%
16.5%
24.9%
32.3%
Table V-19 Averae:e LCC and PBP Results for Radial Housed Fans
Averae:e Costs (2022$)
Simple
Average
First
Lifetime
Efficiency
Payback
TSL
Lifetime
Installed
Year's
Operating
Level
Period
LCC
(years)
Operating
Cost
Cost
(years)
Cost
11,072
2,498
31,987
43,059
28.7
0
11,111
2,487
31,851
42,962
3.6
28.7
1
1
11,131
2,478
31,743
42,874
3.0
28.7
2
11,177
2,459
31,499
42,676
2.7
28.7
2
3
11,349
2,330
29,831
41,180
3-4
4
1.7
28.7
11,944
2,104
26,923
38,867
5-6
2.2
28.7
5
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
Table V-20 Average LCC Savings Relative to the No-New-Standards Case for
Radial Housed Fans
Life-Cvcle Cost Savine:s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
2.8%
3.3%
5.1%
13.3%
24.4%
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0
1
1,337
1
2
1,708
2
3
2,145
3-4
3,714
4
5-6
5,391
5
* The savings represent the average LCC for affected consumers.
ddrumheller on DSK120RN23PROD with PROPOSALS2
-
3812
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-21 Average LCC and PBP Results for Equipment Class: Axial ACF, 12" <
D <36" (ACFl)
Avera2e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
Lifetime
Installed
Year's
TSL
Level
Period
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
0
297
95
498
795
6.3
1*
1
297
95
498
795
6.3
2
2
297
95
497
794
2.7
6.3
3
3
298
88
461
759
0.2
6.3
4
4
313
62
327
640
0.5
6.3
5
5
445
41
219
664
2.8
6.3
6
6
484
35
188
672
3.1
6.3
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
*ELO =ELI
Table V-22 Average LCC Savings Relative to the No-New-Standards Case for
Axial ACF, 12" < D <36" (ACFl)
Life-Cycle Cost Savine:s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
1
2
3
4
5
6
I**
-
-
2
3
4
5
6
35
495
327
141
126
0.1%
0.0%
0.2%
40.4%
45.1%
0
EP19JA24.066
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* The savings represent the average LCC for affected consumers.
**ELO=ELl
3813
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-23 Avera2e LCC and PBP Results for Axial ACF, 36" < D <48"
Avera2e Costs (2022$)
Simple
First
Efficiency
Payback
Lifetime
TSL
Installed
Year's
Level
Period
Operating LCC
Operating
Cost
(years)
Cost
Cost
I
2
3
4
5
6
0
I
2
3
4
5
6
561
556
558
560
575
717
762
166
164
162
147
100
71
61
870
859
849
770
527
374
323
-
1,431
1,415
1,407
1,329
1,103
1,091
I 085
NIA
NIA
NIA
0.2
1.6
1.9
(ACF2)
Average
Lifetime
(years)
6.3
6.3
6.3
6.3
6.3
6.3
6.3
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case. The entry "NI A" means not applicable because there is a decrease in average
installed costs at higher TSLs compared to the no-new standards case.
Table V-24 Average LCC Savings Relative to the No-New-Standards Case for Axial
ACF, 36" < D <48" (ACF2)
Life-Cycle Cost Savin2s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
-
0
1
2
3
4
5
6
1
2
3
4
5
6
-
-
297
291
606
478
341
346
0.0%
0.2%
0.0%
0.0%
22.7%
23.6%
* The savings represent the average LCC for affected consumers.
0
I
2
3
4
5
6
939
932
935
936
954
1,093
1,161
305
303
299
274
197
158
141
I 595
I 579
1,560
1,432
1,029
829
742
2 533
2,511
2,495
2,368
1,983
I 923
1,903
NIA
NIA
NIA
0.1
I.I
1.4
Average
Lifetime
(years)
6.3
6.3
6.3
6.3
6.3
6.3
6.3
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case. The entry "NI A" means not applicable because there is a decrease in average
installed costs at higher TSLs compared to the no-new standards case.
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I
2
3
4
5
6
Simple
Payback
Period
(years)
EP19JA24.068
ddrumheller on DSK120RN23PROD with PROPOSALS2
-
48" < D (ACF3)
EP19JA24.067
Table V-25 Avera2e LCC and PBP Results for Axial ACF,
Avera2e Costs (2022$)
First
Efficiency
Lifetime
TSL
Installed
Year's
Level
Operating LCC
Operating
Cost
Cost
Cost
3814
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-26 Average LCC Savings Relative to the No-New-Standards Case for Axial
ACF, 48" ~ D (ACF3)
Life-Cvcle Cost Savine:s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
0
1
1
343
2
2
587
3
3
628
4
4
668
5
5
613
6
6
630
* The savings represent the average LCC for affected consumers.
0.0%
0.0%
0.0%
0.0%
9.3%
11.3%
Table V-27 Averae:e LCC and PBP Results for Housed Centrifue:al ACFs (ACF4)
Averae:e Costs (2022$)
Simple
Average
First
Efficiency
Payback
Lifetime
TSL
Lifetime
Installed
Year's
Level
Period
Operating LCC
(years)
Operating
Cost
(years)
Cost
Cost
1-4
5
6
0
1*
2
3
4
5
6
250
250
253
307
535
1,675
1,779
93
93
93
81
56
37
32
490
490
488
428
295
198
171
-
740
740
741
735
830
1,873
1,950
7.8
4.8
7.7
25.5
25.0
6.3
6.3
6.3
6.3
6.3
6.3
6.3
Note: The results for each TSL are calculated considering all consumers. The PBP is measured relative to
the no-new standards case.
*ELO = ELI
14.1%
60.0%
97.2%
99.7%
**ELO =ELI
b. Consumer Subgroup Analysis
In the consumer subgroup analysis,
DOE estimated the impact of the
considered TSLs on small businesses.
Table V–29 and Table V–30 compare the
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average LCC savings and PBP at each
efficiency level for the consumer
subgroup with similar metrics for the
entire consumer sample for GFBs and
ACFs, respectively. In most cases, the
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average LCC savings and PBP for small
businesses at the considered TSLs are
not substantially different from the
average for all consumers. Chapter 11 of
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EP19JA24.071
3
18
-118
4
5
-1.164
6
6
-1.210
* The savings represent the average LCC for affected consumers.
EP19JA24.070
ddrumheller on DSK120RN23PROD with PROPOSALS2
5
EP19JA24.072
Table V-28 Average LCC Savings Relative to the No-New-Standards Case for
Housed Centrifue:al ACFs (ACF4)
Life-Cycle Cost Savin~s
TSL Efficiency Level Average LCC Savings * Percent of Consumers that
(2022$)
Experience Net Cost
1-4
0
1
**
-25
2
3.2%
-
3815
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
the NOPR TSD presents the complete
LCC and PBP results for the subgroup.
Table V-29 Comparison of LCC Savings and PBP for Small Businesses and All
Consumers; GFBs
TSL
EL
Small
Businesses
Axial Inline Fans
1
2
3-4
5
6
0
1
2
3
4
5
Simple Payback
years
Average LCC Savings*
2022$
Consumers with Net
Cost(%)
All
Businesses
Small
Businesses
All
Businesses
Small
Businesses
All
Businesses
-
-
-
-
-
-
1,533
771
164
162
-2,841
1,766
1,029
550
670
-2,169
0.9
5.4
9.0
9.1
16.8
1.0
5.8
9.6
9.8
17.9
1.0
8.2
25.1
53.4
82.1
0.9
7.5
23.6
51.3
79.4
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
-
0
-49
-194
1
1
8.4
2
2
967
802
3.6
3
3
1,613
1,413
1.6
4
4
1,942
1,702
1.3
1.9
5-6
5
2,212
1,902
Centrifugal Housed
0
l
1
2,026
1,714
0.2
2
2
2,346
1,977
0.3
3
3
2,463
2,092
0.3
4
4
2,813
2,423
0.5
5-6
5
2,852
2,398
2.3
Centrifugal Inline
0
l
1,192
1,073
1.7
1
2
482
355
5.9
2
3
1,516
1,389
0.8
3
4
588
454
5.7
4
5
1,134
955
4.8
5-6
6
562
335
7.2
Centrifugal Unhoused
0
1-2
1,009
1
2.6
1235
2
658
433
5.0
3
3
1,075
884
1.9
4
4
1,366
1,170
0.9
2,004
5-6
5
2 326
0.7
Axial Power Roof Ventilator
0
1
1,220
1,132
6.1
1,076
5.3
2
1147
2,988
3
3 069
NIA
1-5
4
1,037
945
5.6
5
-1,336
-1,463
12.6
6
-2.218
-2.402
13.8
6
7
-9.236
-9.470
26.1
Centrifugal Power Roof-Ventilator - Exhaust
0
-282
-339
1
11.0
2
529
468
3.5
1
3
210
122
7.1
154
7.0
2-5
4
251
5
-69
-178
9.0
6
6
-1853
-1992
17.7
Centrifugal Power Roof-Ventilator - Supply
0
1
-1,159
-1,228
18.1
2
996
933
0.2
-
-
-
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-
-
10.9
4.7
2.1
1.7
2.5
6.1
6.7
9.8
17.4
26.6
6.3
7.3
11.0
19.5
29.9
-
-
-
0.2
0.4
0.4
0.6
3.1
1.2
2.0
5.1
11.4
37.7
1.5
2.4
6.0
12.9
41.5
-
-
-
2.2
7.6
1.1
7.3
6.1
9.1
3.2
9.5
4.2
34.5
45.9
63.6
3.4
9.9
4.6
36.6
49.2
66.7
-
-
-
3.5
6.7
2.6
1.2
1.0
2.1
6.6
4.2
9.1
11.7
2.2
7.0
4.8
10.5
13.7
-
-
-
7.5
6.5
NIA
7.0
15.8
17.3
32.9
4.1
5.8
1.6
14.1
41.3
67.6
88.6
4.0
5.9
1.8
14.3
41.7
68.3
89.0
-
-
-
14.0
4.4
9.0
8.9
11.5
22.8
5.6
4.8
12.6
24.7
51.6
83.1
5.8
4.9
13.1
25.8
53.7
84.7
-
-
-
22.9
0.3
5.4
2.9
5.5
3.2
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3816
3817
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
1
2
3-4
5-6
3
4
5
6
904
913
1.088
1.283
831
827
973
1,126
1.2
1.2
1.3
2.2
1.5
1.5
1.7
2.8
8.1
14.9
22.1
29.2
8.8
16.5
24.9
32.3
Radial Housed
1
2
3-4
5-6
0
1
2
3
4
5
-
-
-
-
-
-
979
1270
1601
2847
4067
1338
1708
2145
3714
5391
3.6
3.1
2.7
1.7
2.2
3.6
3.0
2.7
1.7
2.2
3.2
4.0
6.0
15.6
28.3
2.8
3.3
5.1
13.3
24.4
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The entry "NI A" means not applicable because there is a decrease in average installed costs at higher TSLs
compared to the no-new-standards case.
3818
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-30 Comparison of LCC Savings and PBP for Small Businesses and All
Consumers; ACFs
TSL
EL
Average LCC Savings*
2022$
Small
Businesses
Axial ACF, 12" < D <36"
0
1
1
2
2
3
4
3
4
5
6
5
6
2
3
4
3
4
5
6
5
6
Small
Businesses
All
Businesses
Small
Businesses
All
Businesses
-
-
-
-
-
35
495
327
141
126
2.6
0.2
0.5
2.6
2.9
2.7
0.2
0.5
2.8
3.1
0.1
0.0
0.2
40.1
45.0
0.1
0.0
0.2
40.4
45.1
-
NIA
NIA
NIA
NIA
NIA
NIA
0.2
1.5
1.8
0.2
1.6
1.9
NIA
NIA
NIA
NIA
NIA
NIA
0.1
1.0
1.2
-25
18
-118
-1,164
-1,210
33
504
335
148
133
297
291
606
478
341
346
296
618
489
351
358
Axial ACF, 48" < D
0
1
1
347
2
2
597
3
3
643
4
4
684
5
5
632
6
6
343
587
628
668
613
630
651
Housed Centrifugal ACFS
1-4
0
1
2
-11
5
3
80
4
-47
5
-1,080
6
6
Consumers with Net
Cost(%)
All
Businesses
Axial ACF, 36" ~ D <48"
0
1
1
300
2
Simple Payback
years
-1,121
-
-
0.0
0.2
0.0
0.0
22.9
23.8
0.0
0.2
0.0
0.0
22.7
23.6
-
-
0.1
1.1
1.4
0.0
0.0
0.0
0.0
9.5
11.5
0.0
0.0
0.0
0.0
9.3
11.3
-
-
-
-
5.7
3.5
5.6
18.7
18.3
7.8
4.8
7.7
25.5
25.0
2.6
11.1
51.7
96.2
98.8
3.2
14.1
60.0
97.2
99.7
ddrumheller on DSK120RN23PROD with PROPOSALS2
c. Rebuttable Presumption Payback
As discussed in section III.F.2, EPCA
establishes a rebuttable presumption
that an energy conservation standard is
economically justified if the increased
purchase cost for equipment that meets
the standard is less than three times the
value of the first-year energy savings
resulting from the standard. In
calculating a rebuttable presumption
payback period for each of the
considered TSLs, DOE used discrete
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values and, as required by EPCA, based
the energy use calculation on the DOE
test procedure for fans and blowers. In
contrast, the PBPs presented in section
V.B.1.a were calculated using
distributions that reflect the range of
energy use in the field.
Table V–31 and Table V–32 present
the rebuttable-presumption payback
periods for the considered TSLs for
GFBs and ACFs. While DOE examined
the rebuttable-presumption criterion, it
considered whether the standard levels
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considered for the NOPR are
economically justified through a more
detailed analysis of the economic
impacts of those levels, pursuant to 42
U.S.C 6316(a); 42 U.S.C. 6295(o)(2)(B)(i),
that considers the full range of impacts
to the consumer, manufacturer, Nation,
and environment. The results of that
analysis serve as the basis for DOE to
definitively evaluate the economic
justification for a potential standard
level, thereby supporting or rebutting
E:\FR\FM\19JAP2.SGM
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EP19JA24.076
The entry "NI A" means not applicable because there is a decrease in average installed costs at higher TSLs
compared to the no-new-standards case.
3819
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
the results of any preliminary
determination of economic justification.
Table V-31 Rebuttable-Presumption Payback Periods for GFBs
Rebuttable Payback Period
years
Equipment Class
TSL 1
TSL2
TSL3
TSL4
TSL 5
TSL6
Axial lnline Fans
1.0
5.9
9.7
9.7
9.8
17.9
Axial Panel Fans
10.8
4.6
2.1
1.7
2.5
2.5
Centrifugal Housed Fans
0.2
0.4
0.4
0.6
3.1
3.1
Centrifugal lnline Fans
7.6
1.1
7.3
6.1
9.1
9.1
Centrifugal Unhoused Fans
3.5
3.5
2.6
1.2
1.0
1.0
Axial Power Roof Ventilator
7.0
7.0
7.0
7.0
7.0
32.9
9.0
9.0
9.0
9.0
9.0
22.8
1.5
1.5
1.7
1.7
2.8
2.8
3.0
2.7
1.7
1.7
2.2
2.2
Centrifugal Power Roof-Ventilator Exhaust
Centrifugal Power Roof-Ventilator Supply
Radial Housed Fans
Table V-32 Rebuttable-Presumption Payback Periods for ACFs
Rebuttable Payback Period
years
Equipment Class
TSL 1
Axial ACFs; 12" :!. D < 36"
Axial ACFs; 36" :!. D < 48"
Axial ACFs; 48" :!. D
Housed Centrifugal ACFs
-
TSL2
2.6
TSL3
0.2
N/A
N/A
N/A
N/A
N/A
N/A
TSL4
0.5
0.2
0.1
-
-
-
-
TSLS
2.8
1.6
1.1
25.5
TSL6
3.1
1.9
1.4
25.0
DOE performed an MIA to estimate
the impact of new energy conservation
standards on manufacturers of fans and
blowers. The following section
describes the expected impacts on
manufacturers at each considered TSL.
Chapter 12 of the NOPR TSD explains
the analysis in further detail.
ddrumheller on DSK120RN23PROD with PROPOSALS2
a. Industry Cash Flow Analysis Results
In this section, DOE provides GRIM
results from the analysis, which
examines changes in the industry that
would result from new standards. The
following tables summarize the
estimated financial impacts (represented
by changes in INPV) of potential new
energy conservation standards on
manufacturers of fans and blowers, as
well as the conversion costs that DOE
estimates manufacturers of fans and
blowers would incur at each TSL. DOE
analyzes the potential impacts on INPV
separately for ACFs and GFBs. To
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evaluate the range of cash flow impacts
on the fan and blower industry, DOE
modeled two manufacturer markup
scenarios using different assumptions
that correspond to the range of
anticipated market responses to new
energy conservation standards: (1) the
conversion cost recovery markup
scenario and (2) the preservation of
operating profit markup scenario.
To assess the less severe end of the
range of potential impacts, DOE
modeled a conversion cost recovery
markup scenario in which
manufacturers are able to increase their
manufacturer markups in response to
new energy conservation standards. To
assess the more severe end of the range
of potential impacts, DOE modeled a
preservation of operating profit markup
scenario in which manufacturers are not
able to maintain their original
manufacturer markup, used in the nonew-standards case, in the standards
cases. Instead, manufacturers maintain
the same operating profit (in absolute
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dollars) in the standards cases as in the
no-new-standards case, despite higher
MPCs.
Each of the modeled manufacturer
markup scenarios results in a unique set
of cash flows and corresponding
industry values at the given TSLs for
each group of fan and blower
manufacturers. In the following
discussion, the INPV results refer to the
difference in industry value between the
no-new-standards case and each
standards case resulting from the sum of
discounted cash flows from 2024
through 2059. To provide perspective
on the short-run cash flow impact, DOE
includes in the discussion of results a
comparison of free cash flow between
the no-new-standards case and the
standards case at each TSL in the year
before new standards take effect.
DOE presents the range in INPV for
GFB manufacturers in Table V–33 and
Table V–34 and the range in INPV for
ACF manufacturers in Table V–36 and
Table V–37.
E:\FR\FM\19JAP2.SGM
19JAP2
EP19JA24.077
2. Economic Impacts on Manufacturers
EP19JA24.078
The entry "NIA" means not applicable because there is a decrease in average installed costs at higher TSLs
compared to the no-new standards case.
3820
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
General Fans and Blowers
Table V-33 Industry Net Present Value for General Fans and Blowers-Conversion
Cost Recovery Markup Scenario
No-New
Standards
Case
4,935
Units
INPV
Change
inINPV
2022$ millions
2022$ millions
Trial Standard Levels
-
%
1
2
3
4
5
6
4,948
13
0.3
4,940
5
0.1
4,936
1
0.0
4,936
1
0.0
4,946
11
0.2
4,975
40
0.8
Table V-34 Industry Net Present Value for General Fans and BlowersPreservation of Operatin2 Profit Scenario
Units
INPV
Change
inINPV
No-New
Standards
Case
2022$
millions
Trial Standard Levels
1
2
3
4
5
6
4,935
4,907
4,847
4,697
4,479
3,671
2,647
-
(28)
(87)
(238)
(455)
(1,263)
(2,287)
(0.6)
(1.8)
(4.8)
(9.2)
(25.6)
(46.4)
2022$
millions
%
Table V-35 Cash Flow Analysis for General Fans and Blowers
2022$
millions
%
2022$
millions
2022$
millions
2022$
millions
ddrumheller on DSK120RN23PROD with PROPOSALS2
BILLING CODE 6450–01–C
At TSL 6, for GFB manufacturers,
DOE estimates the impacts on INPV will
range from ¥$2,287 million to $40
million, which represents a change of
¥46.4 percent to 0.8 percent,
respectively. At TSL 6, industry free
cash flow decreases to ¥$1,132 million,
which represents a decrease of
approximately 336 percent, compared to
the no-new-standards case value of $480
million in 2029, the year before the
modeled compliance year. The negative
cash flow in the years leading up to the
modeled compliance date implies that
most, if not all, GFB manufacturers will
need to borrow funds in order to make
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1
2
3
4
5
6
480
463
420
316
161
(407)
(1,132)
-
(17.3)
(59.7)
(164.4)
(318.5)
(886.7)
(1,612.2)
(3.6)
(12.4)
(34.3)
(66.4)
(184.8)
(335.9)
20
62
154
260
435
698
-
23
86
248
510
1,640
3,052
-
43
147
402
770
2,075
3,750
the investments necessary to comply
with standards. This has the potential to
significantly alter the market dynamics
as some smaller manufacturers may not
be able to secure this funding and could
exit the market as a result of standards
set at TSL 6.
TSL 6 would set energy conservation
standards at max-tech for all GFBs. DOE
estimates that approximately 4 percent
of the GFB shipments would already
meet the efficiency levels required at
TSL 6 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 96
percent of GFB shipments by the
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estimated compliance date. It is unclear
if most GFB manufacturers would have
the engineering capacity to complete the
necessary redesigns within the 5-year
compliance period. If manufacturers
require more than 5 years to redesign
their non-compliant GFB models, they
will likely prioritize redesigns based on
sales volume, which could result in
customers not being able to obtain
compliant GFBs covering the duty
points that they require.
At TSL 6, DOE expects GFB
manufacturers to incur approximately
$698 million in product conversion
costs to conduct aerodynamic redesigns
for non-compliant GFB models.
E:\FR\FM\19JAP2.SGM
19JAP2
EP19JA24.081
2022$
millions
Trial Standard Levels
EP19JA24.080
Free Cash
Flow (2029)
Change in
Free Cash
Flow (2029)
Product
Conversion
Costs
Capital
Conversion
Costs
Total
Conversion
Costs
No-New
Standards
Case
EP19JA24.079
Units
ddrumheller on DSK120RN23PROD with PROPOSALS2
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Additionally, GFB manufacturers would
incur approximately $3,052 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant GFB models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 6, the $3,750 million
in conversion costs are fully recovered,
over the 30-year analysis period,
causing INPV at TSL 6 to remain
approximately equal to the no-newstandards case INPV in this conversion
cost recovery scenario. Given the large
size of the conversion costs,
approximately 1.3 times the sum of the
annual free cash flows over the years
between the estimated final rule
announcement date and the estimated
standards year (i.e., the time period that
these conversion costs would be
incurred), it is highly unlikely that the
GFB market will accept the large
increases in the MSPs that would be
needed for GFB manufacturers to fully
recover these conversion costs, making
the MSPs that result from this
manufacturer markup scenario less
likely to be obtained by manufacturers.
This represents the upper-bound, or
least-severe impact, on manufacturer
profitability and is the manufacturer
markup scenario used in all downstream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increases by approximately 2.2
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $3,750
million in conversion costs incurred by
manufacturers cause a significantly
negative change in INPV at TSL 6 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 5, for GFB manufacturers,
DOE estimates the impacts on INPV will
range from ¥$1,263 million to $11
million, which represents a change of
¥25.6 percent to 0.2 percent,
respectively. At TSL 5, industry free
cash flow decreases to ¥$407 million,
which represents a decrease of
approximately 185 percent, compared to
the no-new-standards case value of $480
million in 2029, the year before the
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modeled compliance year. The negative
cash flow in the years leading up to the
modeled compliance date implies that
most, if not all, GFB manufacturers will
need to borrow funds in order to make
the investments necessary to comply
with standards. This has the potential to
significantly alter the market dynamics
as some smaller manufacturers may not
be able to secure this funding and could
exit the market as a result of standards
set at TSL 5.
TSL 5 would set energy conservation
standards for axial inline fans at EL 4;
axial panel fans at EL 5; centrifugal
housed fans at EL 5; centrifugal inline
fans at EL 6; centrifugal unhoused fans
at EL 5; axial PRVs at EL 4; centrifugal
PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 6; and radial
housed fans at EL 5. DOE estimates that
approximately 7 percent of the GFB
shipments would already meet or
exceed the efficiency levels required at
TSL 5 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 93
percent of GFB shipments by the
estimated compliance date. It is unclear
if most GFB manufacturers would have
the engineering capacity to complete the
necessary redesigns within the 5-year
compliance period. If manufacturers
require more than 5 years to redesign
their non-compliant GFB models, they
will likely prioritize redesigns based on
sales volume, which could result in
customers not being able to obtain
compliant GFBs covering the duty
points that they require.
At TSL 5, DOE expects GFB
manufacturers to incur approximately
$435 million in product conversion
costs to conduct aerodynamic redesigns
for non-compliant GFB models.
Additionally, GFB manufacturers would
incur approximately $1,640 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant GFB models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 5, the $2,075 million
in conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. Given the large size of the
conversion costs, approximately 90
percent of the sum of the annual free
cash flows over the years between the
estimated final rule announcement date
and the estimated standards year (i.e.,
the time period that these conversion
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3821
costs would be incurred), it is unlikely
that the GFB market will accept the
large increases in the MSPs that would
be needed for GFB manufacturers to
fully recover these conversion costs,
making the MSPs that result from this
manufacturer markup scenario less
likely to be obtained by manufacturers.
This represents the upper-bound, or
least-severe impact, on manufacturer
profitability and is the manufacturer
markup scenario used in all downstream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increases by approximately 2.2
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $2,075
million in conversion costs incurred by
manufacturers cause a significantly
negative change in INPV at TSL 5 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 4, for GFB manufacturers,
DOE estimates the impacts on INPV will
range from ¥$455 million to $1 million,
which represents a change of ¥9.2
percent to less than 0.1 percent,
respectively. At TSL 4, industry free
cash flow decreases to $161 million,
which represents a decrease of
approximately 66.4 percent, compared
to the no-new-standards case value of
$480 million in 2029, the year before the
modeled compliance year.
TSL 4 would set energy conservation
standards for axial inline fans at EL 3;
axial panel fans at EL 4; centrifugal
housed fans at EL 4; centrifugal inline
fans at EL 5; centrifugal unhoused fans
at EL 4; axial PRVs at EL 4; centrifugal
PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 5; and radial
housed fans at EL 4. DOE estimates that
approximately 25 percent of the GFB
shipments would already meet or
exceed the efficiency levels required at
TSL 4 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 75
percent of GFB shipments by the
estimated compliance date.
At TSL 4, DOE expects GFB
manufacturers to incur approximately
$260 million in product conversion
costs to conduct aerodynamic redesigns
for non-compliant GFB models.
Additionally, GFB manufacturers would
E:\FR\FM\19JAP2.SGM
19JAP2
ddrumheller on DSK120RN23PROD with PROPOSALS2
3822
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
incur approximately $510 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant GFB models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 4, the $770 million
in conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. At TSL 4, conversion costs
represent approximately 33 percent of
the sum of the annual free cash flows
over the years between the estimated
final rule announcement date and the
estimated standards year (i.e., the time
period that these conversion costs
would be incurred). It is possible that
the GFB market will not accept the full
increase in the MSPs that would be
needed for GFB manufacturers to fully
recover these conversion costs. This
represents the upper-bound, or leastsevere impact, on manufacturer
profitability and is the manufacturer
markup scenario used in all downstream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increases by approximately 1.1
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $770
million in conversion costs incurred by
manufacturers cause a moderately
negative change in INPV at TSL 4 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 3, for GFB manufacturers,
DOE estimates the impacts on INPV will
range from ¥$238 million to $1 million,
which represents a change of ¥4.8
percent to less than 0.1 percent,
respectively. At TSL 3, industry free
cash flow decreases to $316 million,
which represents a decrease of
approximately 34.3 percent, compared
to the no-new-standards case value of
$480 million in 2029, the year before the
modeled compliance year.
TSL 3 would set energy conservation
standards for axial inline fans at EL 3;
axial panel fans at EL 3; centrifugal
housed fans at EL 3; centrifugal inline
fans at EL 4; centrifugal unhoused fans
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at EL 3; axial PRVs at EL 4; centrifugal
PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 5; and radial
housed fans at EL 4. DOE estimates that
approximately 60 percent of the GFB
shipments would already meet or
exceed the efficiency levels required at
TSL 3 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 40
percent of GFB shipments by the
estimated compliance date.
At TSL 3, DOE expects GFB
manufacturers to incur approximately
$154 million in product conversion
costs to redesign all non-compliant GFB
models. Additionally, GFB
manufacturers would incur
approximately $248 million in capital
conversion costs to purchase new
tooling and equipment necessary to
produce compliant GFB models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 3, the $402 million
in conversion costs are fully recovered,
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. This represents the upperbound, or least-severe impact, on
manufacturer profitability and is the
manufacturer markup scenario used in
all down-stream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increases by approximately 1.1
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $402
million in conversion costs incurred by
manufacturers cause a negative change
in INPV at TSL 3 in this preservation of
operating profit scenario. This
represents the lower-bound, or most
severe impact, on manufacturer
profitability.
At TSL 2, for GFB manufacturers,
DOE estimates the impacts on INPV will
range from ¥$87 million to $5 million,
which represents a change of ¥1.8
percent to 0.1 percent, respectively. At
TSL 2, industry free cash flow decreases
to $420 million, which represents a
decrease of approximately 12.4 percent,
compared to the no-new-standards case
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value of $480 million in 2029, the year
before the modeled compliance year.
TSL 2 would set energy conservation
standards for axial inline fans at EL 2;
axial panel fans at EL 2; centrifugal
housed fans at EL 2; centrifugal inline
fans at EL 3; centrifugal unhoused fans
at EL 1; axial PRVs at EL 4; centrifugal
PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 4; and radial
housed fans at EL 3. DOE estimates that
approximately 85 percent of the GFB
shipments would already meet or
exceed the efficiency levels required at
TSL 2 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 15
percent of GFB shipments by the
estimated compliance date.
At TSL 2, DOE expects GFB
manufacturers to incur approximately
$62 million in product conversion costs
to redesign all non-compliant GFB
models. Additionally, GFB
manufacturers would incur
approximately $86 million in capital
conversion costs to purchase new
tooling and equipment necessary to
produce compliant GFB models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 2, the $147 million
in conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. This represents the upperbound, or least-severe impact, on
manufacturer profitability and is the
manufacturer markup scenario used in
all down-stream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increases by approximately 0.6
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $147
million in conversion costs incurred by
manufacturers cause a slight negative
change in INPV at TSL 2 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 1, for GFB manufacturers,
DOE estimates the impacts on INPV will
range from ¥$28 million to $13 million,
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
which represents a change of ¥0.6
percent to 0.3 percent, respectively. At
TSL 1, industry free cash flow decreases
to $463 million, which represents a
decrease of approximately 3.6 percent,
compared to the no-new-standards case
value of $480 million in 2029, the year
before the modeled compliance year.
TSL 1 would set energy conservation
standards for axial inline fans at EL 1;
axial panel fans at EL 1; centrifugal
housed fans at EL 1; centrifugal inline
fans at EL 2; centrifugal unhoused fans
at EL 1; axial PRVs at EL 4; centrifugal
PRV exhaust fans at EL 3; centrifugal
PRV supply fans at EL 3; and radial
housed fans at EL 2. DOE estimates that
approximately 91 percent of the GFB
shipments would already meet or
exceed the efficiency levels required at
TSL 1 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 9
percent of GFB shipments by the
estimated compliance date.
At TSL 1, DOE expects GFB
manufacturers to incur approximately
$20 million in product conversion costs
to redesign all non-compliant GFB
models. Additionally, GFB
manufacturers would incur
approximately $23 million in capital
conversion costs to purchase new
tooling and equipment necessary to
produce compliant GFB models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 1, the $43 million in
conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. This represents the upperbound, or least-severe impact, on
manufacturer profitability and is the
manufacturer markup scenario used in
all down-stream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increases by approximately 0.6
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $43
million in conversion costs incurred by
manufacturers cause a very slight
negative change in INPV at TSL 1 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
Air Circulating Fans
BILLING CODE 6450–01–P
Table V-36 Industry Net Present Value for Air Circulating Fans - Conversion Cost
Recovery Markup Scenario
Units
INPV
No-New
Standards
Case
2022$
millions
2022$
Change in INPV
millions
%
Trial Standard Levels
1
2
3
4
5
6
649
649
649
649
649
652
653
-
0
0
0
0
3
3
0.0
0.0
0.0
0.0
0.5
0.5
Table V-37 Industry Net Present Value for Air Circulating Fans - Preservation of
Operating Profit Scenario
Units
INPV
No-New
Standards
Case
2022$
millions
2022$
2
3
4
5
6
649
650
649
645
579
16
(85)
-
1
0
(4)
(71)
(633)
(734)
0.1
0.0
(0.6)
00.9)
(97.5)
013.1)
EP19JA24.083
millions
%
1
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Sfmt 4725
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Change in INPV
Trial Standard Levels
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Table V-38 Cash Flow Analysis for Air Circulatin~ Fans
Free Cash
Flow (2029)
Change in
Free Cash
Flow (2029)
Product
Conversion
Costs
Capital
Conversion
Costs
Total
Conversion
Costs
No-New
Standards
Case
1
2
3
4
5
6
51
51
51
48
1
(400)
(456)
-
(0.0)
(0.1)
(3.1)
(50.2)
(451.0)
(507.1)
%
-
(0.1)
(0.1)
(6.2)
(99.0)
(888.8)
(999.3)
2022$
-
0.1
0.2
1.9
27.0
213.6
239.1
-
0.0
0.0
5.5
91.1
829.0
928.1
-
0.1
0.2
7.4
118.1
1,042.6
1,167.2
2022$
millions
2022$
millions
millions
2022$
millions
2022$
millions
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At TSL 6, for ACF manufacturers,
DOE estimates the impacts on INPV will
range from ¥$734 million to $3 million,
which represents a change of ¥113.1
percent to 0.5 percent, respectively. At
TSL 6, industry free cash flow decreases
to ¥$456 million, which represents a
decrease of approximately 999 percent,
compared to the no-new-standards case
value of $51 million in 2029, the year
before the modeled compliance year.
The negative cash flow in the years
leading up to the modeled compliance
date implies that most, if not all, ACF
manufacturers will need to borrow
funds in order to make the investments
necessary to comply with standards.
This has the potential to significantly
alter the market dynamics as some
smaller manufacturers may not be able
to secure this funding and could exit the
market as a result of standards set at
TSL 6.
TSL 6 would set energy conservation
standards at max-tech for all ACFs. DOE
estimates that approximately 1 percent
of the ACF shipments would already
meet the efficiency levels required at
TSL 6 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 99
percent of ACF shipments by the
estimated compliance date. It is unclear
if most ACF manufacturers would have
the engineering capacity to complete the
necessary redesigns within the 5-year
compliance period. If manufacturers
require more than 5 years to redesign
their non-compliant ACF models, they
will likely prioritize redesigns based on
sales volume, which could result in
customers not being able to obtain
compliant ACFs covering the duty
points that they require.
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At TSL 6, DOE expects ACF
manufacturers to incur approximately
$239 million in product conversion
costs to conduct aerodynamic redesigns
for non-compliant ACF models.
Additionally, ACF manufacturers would
incur approximately $928 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant ACF models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 6, the $1,167 million
in conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. Given the large size of the
conversion costs, over 5 times the sum
of the annual free cash flows over the
years between the estimated final rule
announcement date and the estimated
standards year (i.e., the time period that
these conversion costs would be
incurred), it is unlikely that the ACF
market will accept the large increases in
the MSPs that would be needed for ACF
manufacturers to fully recover these
conversion costs, making the MSPs that
result from this manufacturer markup
scenario less likely to be obtained by
manufacturers. This represents the
upper-bound, or least-severe impact, on
manufacturer profitability and is the
manufacturer markup scenario used in
all down-stream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
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additional profit from their investments
or potentially higher MPCs. In this
scenario, the shipment weighted average
MPC increase by approximately 4.7
percent, causing a reduction in the
manufacturer margin after the analyzed
compliance year. This reduction in the
manufacturer margin and the $1,167
million in conversion costs incurred by
manufacturers cause an extremely
negative change in INPV at TSL 6 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 5, for ACF manufacturers,
DOE estimates the impacts on INPV will
range from ¥$633 million to $3 million,
which represents a change of ¥97.5
percent to 0.5 percent, respectively. At
TSL 5, industry free cash flow decreases
to ¥$400 million, which represents a
decrease of approximately 889 percent,
compared to the no-new-standards case
value of $51 million in 2029, the year
before the modeled compliance year.
The negative cash flow in the years
leading up to the modeled compliance
date implies that most, if not all, ACF
manufacturers will need to borrow
funds in order to make the investments
necessary to comply with standards.
This has the potential to significantly
alter the market dynamics as some
smaller manufacturers may not be able
to secure this funding and could exit the
market as a result of standards set at
TSL 5.
TSL 5 would set energy conservation
standards at EL 5 for all ACFs, except
housed centrifugal ACFs which are set
at EL 3. DOE estimates that
approximately 4 percent of the ACF
shipments would already meet or
exceed the efficiency levels required at
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TSL 5 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 96
percent of ACF shipments by the
estimated compliance date. It is unclear
if most ACF manufacturers would have
the engineering capacity to complete the
necessary redesigns within the 5-year
compliance period. If manufacturers
require more than 5 years to redesign
their non-compliant ACF models, they
will likely prioritize redesigns based on
sales volume, which could result in
customers not being able to obtain
compliant ACFs covering the duty
points that they require.
At TSL 5, DOE expects ACF
manufacturers to incur approximately
$214 million in product conversion
costs to conduct aerodynamic redesigns
for non-compliant ACF models.
Additionally, ACF manufacturers would
incur approximately $829 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant ACF models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 5, the $1,043 million
in conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. Given the large size of the
conversion costs, over 4.5 times the sum
of the annual free cash flows over the
years between the estimated final rule
announcement date and the estimated
standards year (i.e., the time period that
these conversion costs would be
incurred), it is unlikely that the ACF
market will accept the large increases in
the MSPs that would be needed for ACF
manufacturers to fully recover these
conversion costs, making the MSPs that
result from this manufacturer markup
scenario less likely to be obtained by
manufacturers. This represents the
upper-bound, or least-severe impact, on
manufacturer profitability and is the
manufacturer markup scenario used in
all down-stream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. The $1,043
million in conversion costs incurred by
manufacturers cause a significantly
negative change in INPV at TSL 5 in this
preservation of operating profit
scenario. This represents the lower-
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bound, or most severe impact, on
manufacturer profitability.
At TSL 4, for ACF manufacturers,
DOE estimates the impacts on INPV will
range from ¥$71 million to no change,
which represents a maximum possible
change of ¥10.9 percent. At TSL 4,
industry free cash flow decreases to $1
million, which represents a decrease of
approximately 99.0 percent, compared
to the no-new-standards case value of
$51 million in 2029, the year before the
modeled compliance year.
TSL 4 would set energy conservation
standards at EL 4 for all ACFs, except
housed centrifugal ACFs which would
not have any energy conservation
standard. DOE estimates that
approximately 36 percent of the ACF
shipments would already meet or
exceed the efficiency levels required at
TSL 4 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 64
percent of ACF shipments by the
estimated compliance date.
At TSL 4, DOE expects ACF
manufacturers to incur approximately
$27 million in product conversion costs
to conduct aerodynamic redesigns for
non-compliant ACF models.
Additionally, ACF manufacturers would
incur approximately $91 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant ACF models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 4, the $118 million
in conversion costs are fully recovered
causing INPV to remain approximately
equal to the no-new-standards case
INPV in this conversion cost recovery
scenario. At TSL 4, conversion costs
represent approximately 50 percent of
the sum of the annual free cash flows
over the years between the estimated
final rule announcement date and the
estimated standards year (i.e., the time
period that these conversion costs
would be incurred). It is possible that
the ACF market will not accept the full
increase in the MSPs that would be
needed for ACF manufacturers to fully
recover these conversion costs. This
represents the upper-bound, or leastsevere impact, on manufacturer
profitability and is the manufacturer
markup scenario used in all downstream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
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3825
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. The $118
million in conversion costs incurred by
manufacturers cause a moderately
negative change in INPV at TSL 4 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 3, for ACF manufacturers,
DOE estimates the impacts on INPV will
range from ¥$4 million to no change,
which represents a maximum change of
¥0.6 percent. At TSL 3, industry free
cash flow decreases to $48 million,
which represents a decrease of
approximately 6.2 percent, compared to
the no-new-standards case value of $51
million in 2029, the year before the
modeled compliance year.
TSL 3 would set energy conservation
standards at EL 3 for all ACFs, except
housed centrifugal ACFs which would
not have any energy conservation
standard. DOE estimates that
approximately 84 percent of the ACF
shipments would already meet or
exceed the efficiency levels required at
TSL 3 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 16
percent of ACF shipments by the
estimated compliance date.
At TSL 3, DOE expects ACF
manufacturers to incur approximately
$1.9 million in product conversion costs
to conduct aerodynamic redesigns for
non-compliant ACF models.
Additionally, ACF manufacturers would
incur approximately $5.5 million in
capital conversion costs to purchase
new tooling and equipment necessary to
produce compliant ACF models to meet
these energy conservation standards.
In the conversion cost recovery
markup scenario, manufacturers
increase their manufacturer markups to
fully recover the conversion costs they
incur to redesign non-compliant
equipment. At TSL 3, the $7.4 million
in conversion costs are fully recovered
causing INPV to remain equal to the nonew-standards case INPV in this
conversion cost recovery scenario. This
represents the upper-bound, or leastsevere impact, on manufacturer
profitability and is the manufacturer
markup scenario used in all downstream consumer analyses.
Under the preservation of operating
profit scenario, manufacturers earn the
same per-unit operating profit as would
be earned in the no-new-standards case,
but manufacturers do not earn
additional profit from their investments
or potentially higher MPCs. The $7.4
million in conversion costs incurred by
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manufacturers cause a slight negative
change in INPV at TSL 3 in this
preservation of operating profit
scenario. This represents the lowerbound, or most severe impact, on
manufacturer profitability.
At TSL 2, for ACF manufacturers,
DOE estimates there will be no
substantive change to INPV. At TSL 2,
industry free cash flow sightly decreases
by approximately 0.1 percent in 2029,
the year before the modeled compliance
year.
TSL 2 would set energy conservation
standards at EL 2 for all ACFs, except
housed centrifugal ACFs which would
not have any energy conservation
standard. DOE estimates that
approximately 96 percent of the ACF
shipments would already meet or
exceed the efficiency levels required at
TSL 2 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 4
percent of ACF shipments by the
estimated compliance date.
At TSL 2, DOE expects ACF
manufacturers to incur approximately
$0.2 million in product conversion costs
to redesign the few non-compliant ACF
models. DOE estimates that ACF
manufacturers would not incur any
capital conversion costs, as
manufacturers already have the tooling
and production equipment necessary to
produce ACF models that meet these
energy conservation standards.
The conversion costs incurred by
manufacturers, which are relatively
minor due to the majority of shipments
already meeting the energy conservation
standards, and changes in MPCs at TSL
2 are not severe enough to have a
significant impact on ACF
manufacturers in either of the
manufacturer markup scenarios.
At TSL 1, for ACF manufacturers,
DOE estimates the impacts on INPV will
range from no change to an increase of
$0.5 million, which represents a
maximum change of 0.1 percent. At TSL
1, industry free cash flow sightly
decreases by less than 0.1 percent in
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2029, the year before the modeled
compliance year.
TSL 1 would set energy conservation
standards at EL 1 for all ACFs, except
housed centrifugal ACFs which would
not have any energy conservation
standard. DOE estimates that
approximately 96 percent of the ACF
shipments would already meet or
exceed the efficiency levels required at
TSL 1 in 2030, in the no-new-standards
case. Therefore, DOE estimates that
manufacturers would have to redesign
models representing approximately 4
percent of ACF shipments by the
estimated compliance date.
At TSL 1, DOE expects ACF
manufacturers to incur approximately
$0.1 million in product conversion costs
to redesign the few non-compliant ACF
models. DOE estimates that ACF
manufacturers would not incur any
capital conversion costs, as
manufacturers already have the tooling
and production equipment necessary to
produce ACF models that meet these
energy conservation standards.
The conversion costs incurred by
manufacturers, which are relatively
minor due to the majority of shipments
already meeting the energy conservation
standards, and the change in MPCs at
TSL 1 are not severe enough to have a
significant impact on ACF
manufacturers in either of the
manufacturer markup scenarios.
b. Direct Impacts on Employment
To quantitatively assess the potential
impacts of new energy conservation
standards on direct employment in the
fan and blower industry, DOE used the
GRIM to estimate the domestic labor
expenditures and number of direct
employees in the no-new-standards case
and in each of the standards cases
during the analysis period.
Production employees are those who
are directly involved in fabricating and
assembling equipment within
manufacturer facility. Workers
performing services that are closely
associated with production operations,
such as materials handling tasks using
forklifts, are included as production
labor, as well as line supervisors.
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DOE used the GRIM to calculate the
number of production employees from
labor expenditures. DOE used statistical
data from the U.S. Census Bureau’s 2021
Annual Survey of Manufacturers 126
(‘‘ASM’’) and the results of the
engineering analysis to calculate
industry-wide labor expenditures. Labor
expenditures related to product
manufacturing depend on the labor
intensity of the product, the sales
volume, and an assumption that wages
remain fixed in real terms over time.
The total labor expenditures in the
GRIM were then converted to domestic
production employment levels by
dividing production labor expenditures
by the annual payment per production
worker.
Non-production employees account
for those workers that are not directly
engaged in the manufacturing of the
covered equipment. This could include
sales, human resources, engineering,
and management. DOE estimated nonproduction employment levels by
multiplying the number of fan and
blower production workers by a scaling
factor. The scaling factor is calculated
by taking the ratio of the total number
of employees, and the total production
workers associated with the industry
North American Industry Classification
System (‘‘NAICS’’) code 333413, which
covers fan and blower manufacturing.
Using the GRIM, DOE estimates that
there would be approximately 13,819
domestic production workers, and 6,091
non-production workers for GFBs in
2030 in the absence of new energy
conservation standards. DOE estimates
that there would be approximately 648
domestic production workers and 286
non-production workers for ACFs in
2030 in the absence of new energy
conservation standards. Table V–39
shows the range of the impacts of energy
conservation standards on U.S.
production of GFBs and Table V–40
shows the range of the impacts of energy
conservation standards on U.S.
production of ACFs.
126 See www.census.gov/programs-surveys/asm/
data/tables.html.
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• 2030
Table V-39D omes t"1c Em r> Ioymentfior GeneraIFans an dBi owers m
No-NewStandards
Case
Trial Standard Levels
1
2
3
4
5
Domestic Production
13,819
13,901
13,898
13,969
13,970
14,460
Workers in 2030
Domestic NonProduction Workers
6,091
6,127
6,126
6,157
6,157
6,373
in2030
Total Direct
19,910
20,028
20,024
20,126
20,127
20,833
Employment in 2030*
Potential Changes in
(1,991)- (2,986)- (4,977)0-118
0-114
Total Direct
216
217
923
Employment in 2030*
* Numbers may not sum exactly due to rounding. Number in parentheses indicate a negative number.
6
14,464
6,375
20,839
(5,973)929
Table V-40 Domestic Employment for Air Circulatin2 Fans in 2030
Trial Standard Levels
3
5
4
Domestic Production
648
644
644
644
644
644
Workers in 2030
Domestic NonProduction Workers
286
284
284
284
284
284
in2030
Total Direct
934
928
928
928
928
928
Employment in 2030*
Potential Changes in
(140)(234)(6)-0
-6)-0
(93)-(6)
Total Direct
(6)
(6)
Employment in 2030*
* Numbers may not sum exactly due to rounding. Number in parentheses indicate a negative number.
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The direct employment impacts
shown in Table V–39 and Table V–40
represent the potential changes in direct
employment that could result following
the compliance date for GFBs and ACFs.
Employment could increase or decrease
due to the labor content of the various
equipment being manufactured
domestically that meet the analyzed
standards or if manufacturers decided to
move production facilities abroad
because of new standards. At one end of
the range, DOE assumes that all
manufacturers continue to manufacture
the same scope of equipment
domestically after new standards are
required. However, since the labor
content of GFBs and ACFs vary by
efficiency level, this can either result in
an increase or decrease in domestic
employment, even if all domestic
production remains in the U.S.
The lower end of the range assumes
that some domestic manufacturing
either is eliminated or moves abroad
due to the analyzed new standards. DOE
assumes that for TSL 1 and TSL 2 ACF
and GFB manufacturers already have
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the tooling and production equipment
necessary to produce ACF and GFB
models that meet these energy
conservation standards, making it
unlikely that manufacturers would
move any domestic product abroad at
these analyzed TSLs. At TSL 3 through
TSL 6, DOE conservatively estimates
that some domestic manufacturing
could move abroad as these TSLs
require manufacturers to make larger
investments in production equipment
that could cause some manufacturers to
consider moving production facilities to
a lower-labor cost country.
c. Impacts on Manufacturing Capacity
During manufacturer interviews most
manufacturers stated that any standards
set at max-tech would severely disrupt
manufacturing capacity. Many fan and
blower manufacturers do not offer any
GFB or ACF models that would meet
these max-tech efficiency levels. Based
on the shipments analysis used in the
NIA, DOE estimates that approximately
4 percent of all GFB shipments and
approximately 1 percent of ACF
shipments will meet max-tech efficiency
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6
591
261
852
(280) (82)
levels, in the no-new-standards case in
2030, the modeled compliance year of
new energy conservation standards.
Manufacturers stated that they do not
have the necessary engineers that would
be required to convert models that
represent approximately 96 percent of
GFB shipments and approximately 99
percent of ACF shipments into
compliant models.
Additionally, most manufacturers
stated they would not be able to provide
a full portfolio of fans and blower,
covering their current offering of
operating pressure and airflow ranges,
for any equipment class that required
max-tech efficiency levels. Most
manufacturers stated that they do not
currently have the machinery,
technology, or engineering resources to
manufacture these fans and blowers.
Additionally, the few manufacturers
that do have the capability of producing
max-tech fans and blowers are not able
to produce these fans and blowers for all
necessary operating pressures and
airflows that the market requires and in
the volumes that would fulfill the entire
fan and blower markets. Lastly, most
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manufacturers stated that they would
not be able to ramp up those production
volumes over the five-year compliance
period.
For fan and blower manufacturers to
either completely redesign their fan and
blower production lines to be capable of
producing max-tech fans and blowers or
to significantly expand their limited
max-tech fan and blower production
lines to meet larger production volumes
would require a massive retooling and
engineering effort, which would take
more than the five-year compliance
period.
DOE estimates there is a strong
likelihood of manufacturer capacity
constraints for any equipment classes
that require max-tech efficiency levels.
d. Impacts on Subgroups of
Manufacturers
As discussed in section IV.J.1 of this
document, using average cost
assumptions to develop an industry
cash flow estimate may not be adequate
for assessing differential impacts among
manufacturer subgroups. Small
manufacturers, niche manufacturers,
and manufacturers exhibiting a cost
structure substantially different from the
industry average could be affected
disproportionately. DOE used the
results of the industry characterization
to group manufacturers exhibiting
similar characteristics. Consequently,
DOE considered three manufacturer
subgroups in the MIA: GFB
manufacturers, ACF manufacturers, and
small manufacturers as a subgroup for a
separate impact analysis. DOE discussed
the potential impacts on GFB
manufacturers and ACF manufacturers
separately in sections V.B.2.a and
V.B.2.b.
For the small business subgroup
analysis, DOE applied the small
business size standards published by
the Small Business Administration
(‘‘SBA’’) to determine whether a
company is considered a small business.
The size standards are codified at 13
CFR part 121. To be categorized as a
small business under NAICS code
333413, ‘‘industrial and commercial fan
and blower and air purification
equipment manufacturing,’’ a fan and
blower manufacturer and its affiliates
may employ a maximum of 500
employees. The 500-employee threshold
includes all employees in a business’s
parent company and any other
subsidiaries. For a discussion of the
impacts on the small manufacturer
subgroup, see the Regulatory Flexibility
Analysis in section VI.B.
e. Cumulative Regulatory Burden
One aspect of assessing manufacturer
burden involves looking at the
cumulative impact of multiple DOE
standards and the equipment-specific
regulatory actions of other Federal
agencies that affect the manufacturers of
a covered product or equipment. While
any one regulation may not impose a
significant burden on manufacturers,
the combined effects of several existing
or impending regulations may have
serious consequences for some
manufacturers, groups of manufacturers,
or an entire industry. Assessing the
impact of a single regulation may
overlook this cumulative regulatory
burden. In addition to energy
conservation standards, other
regulations can significantly affect
manufacturers’ financial operations.
Multiple regulations affecting the same
manufacturer can strain profits and lead
companies to abandon product lines or
markets with lower expected future
returns than competing products. For
these reasons, DOE conducts an analysis
of cumulative regulatory burden as part
of its rulemakings pertaining to
appliance efficiency.
DOE requests information regarding
the impact of cumulative regulatory
burden on manufacturers of fans and
blowers associated with multiple DOE
standards or product-specific regulatory
actions of other Federal agencies.
DOE evaluates product-specific
regulations that will take effect
approximately 3 years before or after the
estimated 2030 compliance date of any
new energy conservation standards for
fans and blowers. This information is
presented in Table V–41.
Table V-41 Compliance Dates and Expected Conversion Expenses of Federal
Eneri!V Conservaf10n Stan dar ds Affecfm• Fanan d Bl ower Manufacturers
Number
of Mfrs*
Number of
Manufacturers
Affected from
this Rule**
Approx.
Standards
Year
Industry
Conversion
Costs
(millions)
Industry
Conversion
Costs / Product
Revenue***
Ceiling Fans,
107.2
88FR40932
91
5
2028
1.9%
(2022$)
(Jun. 22. 2023)t
Electric Motors
468.5
88FR36066
74
1
2027
2.6%
(2021$)
(Jun. 1 2023)
* This column presents the total number of manufacturers identified in the energy conservation standard
rule contributing to cumulative regulatory burden.
** This column presents the number of manufacturers producing fans and blowers that are also listed as
manufacturers in the listed energy conservation standard contributing to cumulative regulatory burden.
*** This column presents industry conversion costs as a percentage of product revenue during the
conversion period. Industry conversion costs are the upfront investments manufacturers must make to sell
compliant products/equipment. The revenue used for this calculation is the revenue from just the covered
product/equipment associated with each row. The conversion period is the time frame over which
conversion costs are made and lasts from the publication year of the final rule to the compliance year of the
energy conservation standard. The conversion period typically ranges from 3 to 5 years, depending on the
rulemaking.
t Indicated a NOPR publication. The values listed could change upon the publication of a final rule.
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Federal Energy
Conservation
Standard
3829
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
MIAQ and AHRI expressed concerns
about the HVAC industry burden of
multiple DOE energy conservation
standards and safety standards being
passed in close succession, requiring
significant retesting to be performed on
equipment. (MIAQ, No. 124 at p. 3–4)
and (AHRI, No. 130 at p.13–14) DOE
conducts a cumulative regulatory
burden on the manufactures of the
products or equipment that is being
regulated, so for this rulemaking that is
a cumulative regulatory burden on fan
and blower manufacturers. Table V–41
lists other products or equipment that
fan and blower manufacturers make that
also have a potential DOE energy
conservation standard required within 3
years of the compliance date for this
rulemaking, modeled to be 2030.
Additionally, Table III–1 listed products
and equipment, including several HVAC
equipment that if they have a fan
embedded in the equipment, the fans
would be excluded for this energy
conservation standard, if finalized as
proposed.
3. National Impact Analysis
This section presents DOE’s estimates
of the national energy savings and the
NPV of consumer benefits that would
result from each of the TSLs considered
as potential amended standards.
a. Significance of Energy Savings
fans and blowers, DOE compared their
energy consumption under the no-newstandards case to their anticipated
energy consumption under each TSL.
The savings are measured over the
entire lifetime of products purchased in
the 30-year period that begins in the
first full year of anticipated compliance
with new standards (2030–2059). Table
V–42 and Table V–43 present DOE’s
projections of the national energy
savings for each TSL considered for
GFBs and ACFs. The savings were
calculated using the approach described
in section IV.H of this document.
BILLING CODE 6450–01–P
To estimate the energy savings
attributable to potential standards for
Table V-42 Cumulative National Energy Savings for GFBs; 30 Years of Shipments
(2030-2059)
Primarv energy
PFC energy
1
I
2
1.7
1.7
I
I
2.9
3.0
Trial Standard Level
3
4
I
I
I
quads
I 7.5 I 13.4 I
I 7.7 I 13.8 I
5
I
6
23.1
23.7
I
I
24.6
25.3
2
0.1
0.1
0.2
0.2
Trial Standard Level
3
4
uads
1.2
4.4
1.2
4.5
5
6
6.3
6.5
7.0
7.2
OMB Circular A–4 127 requires
agencies to present analytical results,
including separate schedules of the
monetized benefits and costs that show
the type and timing of benefits and
costs. Circular A–4 also directs agencies
to consider the variability of key
elements underlying the estimates of
benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis
using 9 years, rather than 30 years, of
product shipments. The choice of a 9year period is a proxy for the timeline
in EPCA for the review of certain energy
conservation standards and potential
revision of and compliance with such
revised standards.128 The review
timeframe established in EPCA is
generally not synchronized with the
equipment lifetime, equipment
manufacturing cycles, or other factors
specific to fans and blowers. Thus, such
results are presented for informational
purposes only and are not indicative of
any change in DOE’s analytical
methodologies. NES sensitivity analysis
results based on a 9-year analytical
period are presented in Table V–44 and
Table V–45 for GFBs and ACFs. The
impacts are counted over the lifetime of
equipment purchased in 2030–2038.
127 Office of Management and Budget. Circular A–
4: Regulatory Analysis. September 17, 2003.
Available at https://www.whitehouse.gov/wpcontent/uploads/legacy_drupal_files/omb/circulars/
A4/a-4.pdf.
128 EPCA requires DOE to review its standards at
least once every 6 years, and requires, for certain
products, a 3-year period after any new standard is
promulgated before compliance is required, except
that in no case may any new standards be required
within 6 years of the compliance date of the
previous standards. While adding a 6-year review
to the 3-year compliance period adds up to 9 years,
DOE notes that it may undertake reviews at any
time within the 6-year period and that the 3-year
compliance date may yield to the 6-year backstop.
A 9-year analysis period may not be appropriate
given the variability that occurs in the timing of
standards reviews and the fact that for some
products, the compliance period is 5 years rather
than 3 years.
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Table V-43 Cumulative National Energy Savings for ACFs; 30 Years of Shipments
2030-2059
3830
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-44 Cumulative National Energy Savings for GFBs; 9 Years of Shipments
(2030-2038)
Primary energy
FFC enernv
1
I
2
0.4
0.5
I
I
0.8
0.8
Trial Standard Level
I 3 I 4 I 5
quads
I 2.0 I 3.6 I 6.1
I 2.0 I 3.7 I 6.3
16
I
I
6.5
6.7
Table V-45 Cumulative National Energy Savings for ACFs; 9 Years of Shipments
(2030-2038)
Primarv enernv
FFC energy
b. Net Present Value of Consumer Costs
and Benefits
DOE estimated the cumulative NPV of
the total costs and savings for
1
I
2
0.0
0.0
I
I
0.0
0.0
Trial Standard Level
3
4
5
I
I
I
quads
I 0.2 I 0.8 I 1.1
I 0.2 I 1.2 I 1.3
consumers that would result from the
TSLs considered for fans and blowers.
In accordance with OMB’s guidelines on
regulatory analysis,129 DOE calculated
NPV using both a 7-percent and a 3-
16
I
I
3.5
3.6
percent real discount rate. Table V–46
and Table V–47 show the consumer
NPV results with impacts counted over
the lifetime of equipment purchased in
2030–2059 for GFBs and ACFs.
Table V-46 Cumulative Net Present Value of Consumer Benefits for GFBs; 30 Years
of Shipments (2030-2059)
Discount Rate
1
I
2
I
3 percent
7 percent
3.8
1.3
I
I
7.2
2.6
I
I
Trial Standard Level
3
4
I
billion 2022$
19.0
I 36.9
6.8
I 13.7
I
5
I
6
I
I
54.8
19.2
I
I
49.3
15.8
1
I
2
I
3 percent
7 percent
0.4
0.2
I
I
0.7
0.3
I
I
I
5
I
6
I
I
13.1
5.2
I
I
14.5
5.7
are counted over the lifetime of
products purchased in 2030–2038. As
mentioned previously, such results are
presented for informational purposes
only and are not indicative of any
change in DOE’s analytical methodology
or decision criteria.
129 Office of Management and Budget. Circular A–
4: Regulatory Analysis. September 17, 2003.
Available at https://www.whitehouse.gov/wp-
content/uploads/legacy_drupal_files/omb/circulars/
A4/a-4.pdf.
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The NPV results based on the
aforementioned 9-year analytical period
are presented in Table V–48 and Table
V–49 for GFBs and ACFs. The impacts
EP19JA24.093
Discount Rate
Trial Standard Level
3
4
I
billion 2022$
3.6
I 12.6
1.5
I 5.3
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Table V-47 Cumulative Net Present Value of Consumer Benefits for ACFs; 30 Years
of Shipments (2030-2059)
3831
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-48 Cumulative Net Present Value of Consumer Benefits for GFBs; 9 Years
of Shipments (2030-2038)
Discount Rate
1
3 percent
7 percent
1.4
0.6
I
2
I
I
I
2.6
1.3
I
I
Trial Standard Level
3
4
I
billion 2022$
I
5
I
6
I
I
I
I
20.0
9.4
I
I
18.0
7.8
6.9
3.4
13.4
6.7
Table V-49 Cumulative Net Present Value of Consumer Benefits for ACFs; 9 Years
of Shipments (2030-2038)
3 percent
7 percent
0.1
0.1
ddrumheller on DSK120RN23PROD with PROPOSALS2
The previous results reflect the use of
a default trend to estimate the change in
price for fans and blowers over the
analysis period (see section IV.F.1 of
this document). DOE also conducted a
sensitivity analysis that considered one
scenario with a lower rate of price
decline than the reference case and one
scenario with a higher rate of price
decline than the reference case. The
results of these alternative cases are
presented in appendix 10C of the NOPR
TSD. In the high-price-decline case, the
NPV of consumer benefits is higher than
in the default case. In the low-pricedecline case, the NPV of consumer
benefits is lower than in the default
case.
c. Indirect Impacts on Employment
It is estimated that new energy
conservation standards for fans and
blowers would reduce energy
expenditures for consumers of those
products, with the resulting net savings
being redirected to other forms of
economic activity. These expected shifts
in spending and economic activity
could affect the demand for labor. As
described in section IV.N of this
document, DOE used an input/output
model of the U.S. economy to estimate
indirect employment impacts of the
TSLs that DOE considered. There are
uncertainties involved in projecting
employment impacts, especially
changes in the later years of the
analysis. Therefore, DOE generated
results for near-term timeframes (2030–
2035), where these uncertainties are
reduced.
The results suggest that the proposed
standards would be likely to have a
negligible impact on the net demand for
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2
I
I
I
0.2
0.1
I
I
Trial Standard Level
3
4
I
billion 2022$
I
5
I
6
I
I
I
I
3.4
2.0
I
I
3.4
2.0
0.9
0.6
3.3
2.0
labor in the economy. The net change in
jobs is so small that it would be
imperceptible in national labor statistics
and might be offset by other,
unanticipated effects on employment.
Chapter 16 of the NOPR TSD presents
detailed results regarding anticipated
indirect employment impacts.
4. Impact on Utility or Performance of
Products
As discussed in section III.F.1.d of
this document, DOE has tentatively
concluded that the standards proposed
in this NOPR would not lessen the
utility or performance of the fans and
blowers under consideration in this
rulemaking. Manufacturers of these
equipment currently offer units that
meet or exceed the proposed standards.
5. Impact of Any Lessening of
Competition
DOE considered any lessening of
competition that would be likely to
result from new or amended standards.
As discussed in section III.F.1.e, the
Attorney General determines the
impact, if any, of any lessening of
competition likely to result from a
proposed standard, and transmits such
determination in writing to the
Secretary, together with an analysis of
the nature and extent of such impact. To
assist the Attorney General in making
this determination, DOE has provided
DOJ with copies of this NOPR and the
accompanying NOPR TSD for review.
DOE will consider DOJ’s comments on
the proposed rule in determining
whether to proceed to a final rule. DOE
will publish and respond to DOJ’s
comments in that document. DOE
invites comment from the public
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regarding the competitive impacts that
are likely to result from this proposed
rule. In addition, stakeholders may also
provide comments separately to DOJ
regarding these potential impacts. See
the ADDRESSES section for information
to send comments to DOJ.
6. Need of the Nation To Conserve
Energy
Enhanced energy efficiency, where
economically justified, improves the
Nation’s energy security, strengthens the
economy, and reduces the
environmental impacts (costs) of energy
production. Reduced electricity demand
due to energy conservation standards is
also likely to reduce the cost of
maintaining the reliability of the
electricity system, particularly during
peak-load periods. Chapter 15 in the
NOPR TSD presents the estimated
impacts on electricity generating
capacity, relative to the no-newstandards case, for the TSLs that DOE
considered in this rulemaking.
Energy conservation resulting from
potential energy conservation standards
for fans and blowers is expected to yield
environmental benefits in the form of
reduced emissions of certain air
pollutants and greenhouse gases. Table
V–50 and Table V–51 provide DOE’s
estimate of cumulative emissions
reductions expected to result from the
TSLs considered in this rulemaking for
GFBs and ACFs, respectively. The
emissions were calculated using the
multipliers discussed in section IV.K of
this document. DOE reports annual
emissions reductions for each TSL in
chapter 13 of the NOPR TSD.
BILLING CODE 6450–01–P
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3832
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Trial Standard Level
2
3
4
Power Sector Emissions
1
CO2 (million metric
tons)
CRi (thousand tons)
N2O (thousand tons)
NOx (thousand tons)
SO2 (thousand tons)
Hg (tons)
CO2 (million metric
tons)
CH4 (thousand tons)
N2O (thousand tons)
NOx (thousand tons)
SO2 (thousand tons)
Hg (tons)
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CO2 (million metric
tons)
CRi (thousand tons)
N2O (thousand tons)
NOx (thousand tons)
SO2 (thousand tons)
Hg (tons)
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26.82
1.95
0.27
12.13
8.87
0.06
46.75
3.40
8.77
0.47
1.22
21.11
54.39
15.47
39.95
0.11
0.28
Upstream Emissions
2.80
254.61
0.01
43.65
0.16
0.00
120.73
4.88
12.60
1,148.00
444.08
0.02
0.05
76.13
196.81
0.28
0.73
0.00
0.00
Total FFC Emissions
5
6
216.82
372.65
397.92
15.78
2.19
98.08
71.74
0.50
27.09
3.76
168.27
123.30
0.86
28.92
4.01
179.43
131.66
0.92
22.60
38.86
41.52
2 058.08
0.10
352.83
1.31
0.00
3,539.94
0.17
606.87
2.25
0.00
3 782.34
0.18
648.43
2.41
0.00
29.61
51.62
133.33
239.41
411.51
439.45
256.56
0.28
55.78
9.04
0.06
447.48
0.49
97.24
15.75
0.11
1,156.77
1.27
251.20
40.68
0.28
2 073.86
2.29
450.91
73.06
0.50
3,567.04
3.93
775.15
125.56
0.86
3 811.26
4.19
827.86
134.07
0.92
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Table V-50 Cumulative Emissions Reduction for GFBs Shipped in 2030-2059
3833
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-51 Cumulative Emissions Reduction for ACFs Shipped in 2030-2059
Trial Standard Level
3
4
Power Sector Emissions
1
CO2 (million metric
tons)
CRi (thousand tons)
N2O (thousand tons)
NOx (thousand tons)
SO2 (thousand tons)
Hg (tons)
CO2 (million metric
tons)
CH4 (thousand tons)
N2O (thousand tons)
NOx (thousand tons)
SO2 (thousand tons)
Hg (tons)
CO2 (million metric
tons)
CRi (thousand tons)
N2O (thousand tons)
NOx (thousand tons)
SO2 (thousand tons)
Hg (tons)
As part of the analysis for this
rulemaking, DOE estimated monetary
benefits likely to result from the
reduced emissions of CO2 that DOE
estimated for each of the considered
5
6
71.01
101.82
113.80
4.50
0.61
31.04
19.24
0.13
6.46
0.88
44.51
27.59
0.19
7.22
0.99
49.75
30.84
0.21
7.50
10.75
12.02
682.18
0.03
116.98
0.44
0.00
978.13
0.05
167.72
0.63
0.00
1 093.20
0.05
187.45
0.71
0.00
2
1.58
0.10
0.01
0.69
0.43
0.00
3.46
0.22
1.23
0.03
0.17
1.51
8.50
0.94
5.27
0.01
0.04
Upstream Emissions
0.17
15.15
0.00
2.60
0.01
0.00
19.45
0.36
2.05
33.21
186.82
0.00
0.01
5.69
32.03
0.02
0.12
0.00
0.00
Total FFC Emissions
1.74
3.82
21.50
78.51
112.57
125.81
15.25
0.01
3.29
0.44
0.00
33.43
0.03
7.21
0.96
0.01
188.05
0.18
40.54
5.39
0.04
686.69
0.65
148.02
19.69
0.13
984.59
0.93
212.23
28.23
0.19
1 100.41
1.04
237.20
31.55
0.21
TSLs for GFBs and AFCs. Section IV.L
of this document discusses the SC–CO2
values that DOE used. Table V–52 and
Table V–53 present the value of CO2
emissions reduction at each TSL for
each of the SC–CO2 cases for GFBs and
ACFs, respectively. The time-series of
annual values is presented for the
proposed TSL in chapter 14 of the
NOPR TSD.
Table V-52 Present Value of CO2 Emissions Reduction for GFBs Shipped in 20302059
5%
Average
0.26
0.45
1.15
2.11
3.59
3.80
3.45
5.98
15.22
27.97
47.58
50.42
EP19JA24.098
1
2
3
4
5
6
3%
95 percentile
th
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TSL
SC-CO2 Case
Discount Rate and Statistics
3%
2.5%
Average
Average
Billion 2022$
1.14
1.79
1.97
3.11
5.03
7.92
9.23
14.53
15.71
24.73
16.65
26.21
3834
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-53 Present Value of CO2 Emissions Reduction for ACFs Shipped in 20302059
TSL
5%
Average
1
2
3
4
5
6
0.02
0.04
0.22
0.80
1.14
1.28
SC-CO2 Case
Discount Rate and Statistics
3%
2.5%
Average
Average
Billion 2022$
0.08
0.12
0.17
0.26
0.94
1.47
3.43
5.37
4.92
7.70
5.50
8.61
As discussed in section IV.L.2, DOE
estimated the climate benefits likely to
result from the reduced emissions of
methane and N2O that DOE estimated
for each of the considered TSLs for
GFBs and ACFs. Table V–54 and Table
V–55 present the value of the CH4
emissions reduction at each TSL for
GFBs and ACFs, respectively, and Table
V–56 and Table V–57 present the value
3%
95 th percentile
0.23
0.51
2.85
10.40
14.91
16.66
of the N2O emissions reduction at each
TSL for GFBs and ACFs, respectively.
The time-series of annual values is
presented for the proposed TSL in
chapter 14 of the NOPR TSD.
Table V-54 Present Value of Methane Emissions Reduction for GFBs Shipped in
2030-2059
TSL
5%
Average
1
2
3
4
5
6
0.10
0.18
0.46
0.85
1.44
1.53
SC-CH4 Case
Discount Rate and Statistics
3%
2.5%
Average
Average
Billion 2022$
0.32
0.45
0.56
0.79
1.43
2.01
2.61
3.67
4.45
6.25
4.72
6.64
3%
95 th percentile
0.85
1.48
3.77
6.91
11.77
12.48
1
2
3
4
5
6
0.01
0.02
0.09
0.32
0.46
0.51
3%
95 th percentile
0.06
0.12
0.70
2.54
3.64
4.07
EP19JA24.101
5%
Average
EP19JA24.100
TSL
SC-CH4 Case
Discount Rate and Statistics
3%
2.5%
Average
Average
Billion 2022$
0.02
0.03
0.05
0.07
0.26
0.37
0.97
1.35
1.38
1.93
1.55
2.16
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Table V-55 Present Value of Methane Emissions Reduction for ACFs Shipped in
2030-2059
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3835
Table V-56 Present Value of Nitrous Oxide Emissions Reduction for GFBs Shipped
in 2030-2059
TSL
5%
Average
1
2
3
4
5
6
0.00
0.00
0.00
0.01
0.01
0.01
SC-N20 Case
Discount Rate and Statistics
3%
2.5%
Average
Average
Billion 2022$
0.00
0.01
0.02
0.03
0.05
0.06
3%
95th percentile
0.01
0.01
0.03
0.05
0.08
0.09
0.01
0.02
0.05
0.09
0.15
0.15
Table V-57 Present Value of Nitrous Oxide Emissions Reduction for ACFs Shipped
in 2030-2059
TSL
5%
Average
1
2
3
4
5
6
0.000
0.000
0.001
0.003
0.004
0.004
SC-N20 Case
Discount Rate and Statistics
3%
2.5%
Average
Average
Billion 2022$
0.000
0.000
0.003
0.010
0.015
0.016
DOE is well aware that scientific and
economic knowledge continues to
evolve rapidly about the contribution of
CO2 and other GHG emissions to
changes in the future global climate and
the potential resulting damages to the
global and U.S. economy. DOE, together
with other Federal agencies, will
continue to review methodologies for
estimating the monetary value of
reductions in CO2 and other GHG
emissions. This ongoing review will
consider the comments on this subject
that are part of the public record for this
3%
95th percentile
0.000
0.001
0.004
0.016
0.023
0.025
and other rulemakings, as well as other
methodological assumptions and issues.
DOE notes that the proposed standards
would be economically justified even
without inclusion of monetized benefits
of reduced GHG emissions.
DOE also estimated the monetary
value of the health benefits associated
with NOX and SO2 emissions reductions
anticipated to result from the
considered TSLs for GFBs and ACFs.
The dollar-per-ton values that DOE used
are discussed in section IV.L of this
document. Table V–58 and Table V–59
0.001
0.001
0.007
0.027
0.039
0.043
present the present value for NOX
emissions reduction for each TSL
calculated using 7-percent and 3percent discount rates, for GFBs and
ACFs, respectively; and Table V–60 and
Table V–61 present similar results for
SO2 emissions reductions for GFBs and
ACFs, respectively. The results in these
tables reflect application of EPA’s low
dollar-per-ton values, which DOE used
to be conservative. The time-series of
annual values is presented for the
proposed TSL in chapter 14 of the
NOPR TSD.
Table V-58 Present Value ofNOx Emissions Reduction for GFBs Shipped in 20302059
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1
2
3
4
5
6
3% Discount Rate
7% Discount Rate
million 2022$
827
2 353
1,428
4,082
3,626
10,443
6,702
19,053
11.376
32 519
12.026
34 536
19JAP2
EP19JA24.102
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TSL
3836
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-59 Present Value ofNOx Emissions Reduction for ACFs Shipped in 2030-2059
TSL
1
2
3
4
5
6
3% Discount Rate
7% Discount Rate
million 2022$
58
153
128
336
718
1 890
2,622
6,902
3,760
9,897
4,202
ll,061
Table V-60 Present Value of SO2 Emissions Reduction for GFBs Shipped in 2030-2059
TSL
1
2
3
4
5
6
3% Discount Rate
7% Discount Rate
million 2022$
191
537
329
931
836
2,382
L546
4.346
2,624
7-417
2,774
7,877
Table V-61 Present Value of SO2 Emissions Reduction for ACFs Shipped in 2030-2059
1
2
3
4
5
6
3% Discount Rate
7% Discount Rate
million 2022$
ll
29
24
63
137
354
498
1,292
715
1,852
799
2,070
7. Other Factors
The Secretary of Energy, in
determining whether a standard is
economically justified, may consider
any other factors that the Secretary
deems to be relevant. (42 U.S.C 6216(a);
42 U.S.C. 6295(o)(2)(B)(i)(VII)) No other
factors were considered in this analysis.
EP19JA24.106
8. Summary of Economic Impacts
Table V–62 and Table V–63 presents
the NPV values that result from adding
the estimates of the potential economic
benefits resulting from reduced GHG
and NOX and SO2 emissions to the NPV
of consumer benefits calculated for each
TSL considered in this rulemaking, for
GFBs and ACFs, respectively. The
consumer benefits are domestic U.S.
monetary savings that occur as a result
of purchasing the covered GFBs and
ACFs, and are measured for the lifetime
of equipment shipped in 2030–2059.
The climate benefits associated with
reduced GHG emissions resulting from
the adopted standards are global
benefits, and are also calculated based
on the lifetime of GFBs and ACFs
shipped in 2030–2059.
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Not all the public health and
environmental benefits from the
reduction of greenhouse gases, NOX,
and SO2 are captured in the values
above, and additional unquantified
benefits from the reductions of those
pollutants as well as from the reduction
of direct PM and other co-pollutants
may be significant. DOE has not
included monetary benefits of the
reduction of Hg emissions because the
amount of reduction is very small.
EP19JA24.107
TSL
3837
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-62 Consumer NPV Combined with Present Value of Climate Benefits and
Health Benefits for GFBs
TSL 1
Catei:wrv
TSL2
TSL3
TSL4
TSL5
TSL6
Using 3% discount rate for Consumer NPV and Health Benefits (billion 2022$)
7.1
12.8
33.5
63.3
99.8
5% Average SC-GHG case
8.2
14.8
38.3
72.2
115.0
3% Average SC-GHG case
2.5% Average SC-GHG case
8.9
16.1
41.8
78.6
125.9
11.0
19.7
50.9
95.3
154.3
3% 95th percentile SC-GHG case
97.1
113.2
124. 7
154.8
Usin}! 7% discount rate for Consumer NPV and Health Benefits (billion 2022$)
5% Average SC-GHG case
2.7
5.0
12.9
24.9
38.2
3% Average SC-GHG case
3.8
6.9
17.8
33.8
53.4
2.5% Average SC-GHG case
4.6
8.2
21.3
40.2
64.3
3% 95th percentile SC-GHG case
6.6
11.8
30.3
56.9
92.7
36.0
52.0
63. 6
93.7
Using 3% discount rate for Consumer NPV and Health Benefits (billion 2022$)
0.6
1.2
6.2
21.9
26.4
5% Average SC-GHG case
0.7
1.3
7.1
25.2
31.1
3% Average SC-GHG case
0.8
1.4
7.7
27.5
34.5
2.5% Average SC-GHG case
0.9
1.7
9.4
33.7
43.4
3% 95th percentile SC-GHG case
29.4
34.7
38 4
48.4
Usin}! 7% discount rate for Consumer NPV and Health Benefits (billion 2022$)
0.3
0.5
2.7
9.5
11.3
5% Average SC-GHG case
3% Average SC-GHG case
0.4
0.7
3.6
12.8
16.0
0.4
0.8
4.2
15.1
19.4
2.5% Average SC-GHG case
3% 95th percentile SC-GHG case
0.5
1.1
5.9
21.3
28.3
12.5
17.7
21 5
31.5
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For this NOPR, DOE considered the
impacts of new standards for GFBs and
ACFs at each TSL, beginning with the
max-tech feasible level, to determine
whether that level was economically
justified. Where the max-tech level was
not justified, DOE then considered the
next most efficient level and undertook
the same evaluation until it reached the
highest efficiency level that is both
technologically feasible and
economically justified and saves a
significant amount of energy.
To aid the reader as DOE discusses
the benefits and/or burdens of each TSL,
tables in this section present a summary
of the results of DOE’s quantitative
analysis for each TSL. In addition to the
quantitative results presented in the
tables, DOE also considers other
burdens and benefits that affect
economic justification. These include
the impacts on identifiable subgroups of
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consumers who may be
disproportionately affected by a national
standard and impacts on employment.
1. Benefits and Burdens of TSLs
Considered for Fans and Blowers
Standards
a. General Fans and Blowers
Table V–64 and Table V–65
summarize the quantitative impacts
estimated for each TSL for GFBs. The
national impacts are measured over the
lifetime of GFBs purchased in the 30year period that begins in the
anticipated first full year of compliance
with new standards (2030–2059). The
energy savings, emissions reductions,
and value of emissions reductions refer
to full-fuel-cycle results. The efficiency
levels contained in each TSL are
described in section V.A of this
document.
BILLING CODE 6450–01–P
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EP19JA24.109
C. Conclusion
When considering new or amended
energy conservation standards, the
standards that DOE adopts for any type
(or class) of covered equipment must be
designed to achieve the maximum
improvement in energy efficiency that
the Secretary determines is
technologically feasible and
economically justified. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(A)) In
determining whether a standard is
economically justified, the Secretary
must determine whether the benefits of
the standard exceed its burdens by, to
the greatest extent practicable,
considering the seven statutory factors
discussed previously. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(B)(i)) The
new or amended standard must also
result in significant conservation of
energy. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(3)(B))
EP19JA24.108
ddrumheller on DSK120RN23PROD with PROPOSALS2
Table V-63 Consumer NPV Combined with Present Value of Climate Benefits and
Health Benefits for ACFs
TSL 1 TSL2 TSL3 TSL4 TSL5 TSL6
Cate2orv
3838
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-64 Summary of Analytical Results for GFBs TSLs: National Impacts
TSL 1
Cate2orv
Cumulative FFC National Ener2V Savin2s
Quads
1.7
Cumulative FFC Emissions Reduction
CO2 (million metric tons)
29.6
CRi (thousand tons)
256.6
N2O (thousand tons)
0.3
NOx (thousand tons)
55.8
SO2 (thousand tons)
9.0
Hg (tons)
0.1
Present Value of Monetized Benefits and Costs
Consumer Operating Cost Savings
5.3
Climate Benefits*
1.5
Health Benefits**
2.9
Total Benefitst
9.6
Consumer Incremental Product
Costs:t
Consumer Net Benefits
Total Net Benefits
1.5
TSL2
TSL3
TSL4
TSL5
TSL6
3.0
7.7
13.8
23.7
25.3
51.6
133.3
239.4
411.5
447.5
1156.8 2073.9 3567.0
0.5
1.3
2.3
3.9
97.2
251.2
450.9
775.1
15.8
40.7
73.1
125.6
0.1
0.3
0.5
0.9
(3% discount rate, billion 2022$)
9.1
23.0
42.7
72.3
2.5
6.5
11.9
20.2
5.0
12.8
23.4
39.9
16.7
42.3
78.0
132.4
1.9
4.0
3.8
7.2
19.0
8.2
14.8
38.3
Present Value of Monetized Benefits and Costs ( 7% discount rate,
Consumer Operating Cost Savings
2.1
3.5
8.9
Climate Benefits*
1.5
2.5
6.5
Health Benefits**
1.0
1.8
4.5
4.5
7.8
19.8
Total Benefitst
Consumer Incremental Product
Costs:t
Consumer Net Benefits
Total Net Benefits
5.7
439.4
3811.3
4.2
827.9
134.1
0.9
76.4
21.4
42.4
140.2
17.4
27.0
36.9
54.8
72.2
115.0
billion 2022$)
16.6
28.0
11.9
20.2
8.2
14.0
36.8
62.3
49.3
113.2
29.5
21.4
14.8
65.7
0.7
1.0
2.0
2.9
8.9
13.7
1.3
3.8
2.6
6.9
6.8
17.8
13.7
33.8
19.2
53.4
15.8
52.0
Note: This table presents the costs and benefits associated with GFBs shipped in 2030-2059. These results
include benefits to consumers which accrue after 2059 from the products shipped in 20230-2059.
* Climate benefits are calculated using four different estimates of the SC-CO2, SC-CH4 and SC-N2O.
Together, these represent the global SC-GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3-percent discount rate are shown; however, DOE emphasizes the
importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the
benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
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published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for NOx and SO2) PM2.s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2.s emissions. The health benefits are presented at real discount rates of 3 and 7
percent. See section IV.M of this document for more details.
t Total and net benefits include consumer, climate, and health benefits. For presentation puiposes, total and
net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GH G with 3percent discount rate.
:j: Costs include incremental equipment costs as well as installation costs.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3839
(million 2022$)
(No-new-standards
case
INPV = 4,935)
Industry NPV (%
4,9074,948
4,8474,940
(0.6)(1.8)change)
0.3
0.1
Consumer Average LCC Savings (2022$)
Axial Inline
1,766
1,029
ddrumheller on DSK120RN23PROD with PROPOSALS2
4,4794,936
3,6714,946
2,6474,975
(4.8) - 0.0
(9.2)0.0
(25.6)0.2
(46.4)0.8
550
550
670
(2,169)
Axial Panel
(194)
802
1,413
1,702
1,902
1,902
Centrifugal Housed
1,714
1,977
2,092
2,423
2,398
2,398
1,389
454
955
335
335
1,009
884
1,170
2,004
2,004
945
945
945
945
(9,470)
154
154
154
154
(1,992)
827
973
973
1,126
1,126
2,145
3,714
3,714
5,391
5,391
1,256
1,425
1,694
2,030
1,751
5.8
9.6
9.6
9.8
17.9
Centrifugal Inline
355
Centrifugal
1,009
Unhoused
Axial Power Roof
945
Ventilator
Centrifugal Power
Roo- Ventilator 122
Exhaust
Centrifugal Power
Roo- Ventilator 831
Supply
Radial Housed
1,708
Shipment907
Weighted Average •
Consumer Simple PBP (years)
Axial Inline
1.0
Axial Panel
10.9
4.7
2.1
1.7
2.5
2.5
Centrifugal Housed
0.2
0.4
0.4
0.6
3.1
3.1
Centrifugal Inline
Centrifugal
Unhoused
Axial Power Roof
Ventilator
Centrifugal Power
Roo- Ventilator Exhaust
Centrifugal Power
Roo- Ventilator Supply
Radial Housed
7.6
1.1
7.3
6.1
9.1
9.1
3.5
3.5
2.6
1.2
1.0
1.0
7.0
7.0
7.0
7.0
7.0
32.9
9.0
8.9
8.9
8.9
8.9
22.8
1.5
1.5
1.7
1.7
2.8
2.8
3.0
2.7
1.7
1.7
2.2
2.2
4.6
3.0
2.3
1.8
2.9
3.8
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Table V-65 Summary of Analytical Results for GFBs TSLs: Manufacturer and
Consumer Impacts
TSLl
TSL2
TSL3
TSL4
TSL5
TSL6
Category
Manufacturer Impacts
Industry NPV
3840
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Category
Weighted Average •
TSL 1
TSL2
TSL3
TSL4
TSL5
TSL6
Percent of Consumers that Experience a Net Cost
Axial Inline
0.9%
7.5%
23.6%
23.6%
51.3%
79.4%
Axial Panel
6.3%
7.3%
11.0%
19.5%
29.9%
29.9%
Centrifugal Housed
1.5%
2.4%
6.0%
12.9%
41.5%
41.5%
ddrumheller on DSK120RN23PROD with PROPOSALS2
BILLING CODE 6450–01–C
DOE first considered TSL 6, which
represents the max-tech efficiency
levels. At TSL 6, DOE expects all
equipment classes would require the
highest tier aerodynamic redesign.
TSL 6 would save an estimated 25.3
quads of full-fuel cycle energy, an
amount DOE considers significant.
Under TSL 6, the NPV of consumer
benefit would be $15.8 billion using a
discount rate of 7 percent, and $49.3
billion using a discount rate of 3
percent.
The cumulative emissions reductions
at TSL 6 are 439.4 Mt of CO2, 134.1
thousand tons of SO2, 827.9 thousand
tons of NOX, 0.9 tons of Hg, 3,811.3
thousand tons of CH4, and 4.2 thousand
tons of N2O. The estimated monetary
value of the climate benefits from
reduced GHG emissions (associated
with the average SC–GHG at a 3-percent
discount rate) at TSL 6 is $21.4 billion.
The estimated monetary value of the
health benefits from reduced SO2 and
NOX emissions at TSL 6 is $14.8 billion
using a 7-percent discount rate and
$42.4 billion using a 3-percent discount
rate.
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Using a 7-percent discount rate for
consumer benefits and costs, health
benefits from reduced SO2 and NOX
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
total NPV at TSL 6 is $52.0 billion.
Using a 3-percent discount rate for all
benefits and costs, the estimated total
NPV at TSL 6 is $113.2 billion. The
estimated total NPV is provided for
additional information, however DOE
primarily relies upon the NPV of
consumer benefits when determining
whether a proposed standard level is
economically justified.
At TSL 6, for the largest equipment
classes, which are represented by axial
panel fans, centrifugal housed fans, and
centrifugal unhoused fans—which
together represent approximately 85
percent of annual shipments—there is a
life-cycle cost savings of $1,902, $2,398,
and $2,004 and a payback period of 2.5
years, 3.1 years, and 1.0 years,
respectively. For these equipment
classes, the fraction of customers
experiencing a net LCC cost is 29.9
percent, 41.5 percent, and 13.7 percent
due to increases in total installed cost of
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$618, $1,090 and $215, respectively.
The life-cycle costs savings are negative
for axial inline fans, axial PRV, and
centrifugal PRV exhaust, and equal to
¥$2,169, ¥$9,470, and ¥$1,992. For
these equipment classes the payback is
17.9, 32.9 and 22.8 years and the
fraction of customers experiencing a net
LCC cost is 79.4 percent, 89.0 percent,
and 84.7 percent. The life-cycle costs
savings for centrifugal inline, centrifugal
PRV supply, and radial housed fans are
positive and equal to $335, $1,126, and
$5,391, respectively. For these
equipment classes the payback is 9.1,
2.8, and 2.2 years and the fraction of
customers experiencing a net LCC cost
is 66.7 percent, 32.3 percent, and 24.4
percent. At TSL 6, the shipmentsweighted average LCC is equal to
$1,751, the payback period is equal to
3.8 and the fraction of customers
experiencing a net LCC cost is 32.8
percent.
At TSL 6, the projected change in
INPV ranges from a decrease of $2,287
million to an increase of $40 million,
which corresponds to a decrease of 46.4
percent and an increase of 0.8 percent,
respectively. DOE estimates that
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Centrifugal Inline
9.9%
4.6%
36.6%
49.2%
66.7%
66.7%
Centrifugal
2.2%
2.2%
4.8%
10.5%
13.7%
13.7%
Unhoused
Axial Power Roof
14.3%
14.3%
14.3%
14.3%
14.3%
89.0%
Ventilator
Centrifugal Power
Roo- Ventilator 13.1%
25.8%
25.8%
25.8%
25.8%
84.7%
Exhaust
Centrifugal Power
Roo- Ventilator 8.8%
16.5%
24.9%
24.9%
32.3%
32.3%
Supply
Radial Housed
3.3%
5.1%
13.3%
13.3%
24.4%
24.4%
Shipment3.8%
5.0%
9.5%
15.7%
30.2%
32.8%
Weighted Average •
Parentheses indicate negative (-) values. The entry "-" means no impact because the TSL
considered is equivalent to the no-new standards case. The entry "NIA." means not applicable
because there is a decrease in average installed costs at the considered TSLs compared to the
no-new standards case.
* Weighted by shares of each equipment class in total projected shipments in 2030.
ddrumheller on DSK120RN23PROD with PROPOSALS2
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
industry must invest $3,750 million to
conduct aerodynamic redesigns on all
equipment classes to comply with
standards set at TSL 6. An investment
of $3,750 million in conversion costs
represents approximately 1.3 times the
sum of the annual free cash flows over
the years between the estimated final
rule announcement date and the
estimated standards year (i.e., the time
period that these conversion costs
would be incurred) and represents over
75 percent of the entire no-newstandards case INPV over the 30-year
analysis period.130
In the no-new-standards case, free
cash flow is estimated to be $480
million in 2029, the year before the
modeled compliance date. At TSL 6, the
estimated free cash flow is ¥$1,132
million in 2029. This represents a
decrease in free cash flow of 336
percent, or a decrease of $1,612 million,
in 2029. A negative free cash flow
implies that most, if not all,
manufacturers will need to borrow
substantial funds to be able to make
investments necessary to comply with
energy conservation standards at TSL 6.
The extremely large drop in free cash
flows could cause some GFB
manufacturers to discontinue certain
products offerings and shift their
resources to other business units not
impacted by this rule, even though
recovery may be possible over the 30year analysis period. DOE is concerned
about the uncertainty of the market that
may exists at TSL 6 if manufacturers
choose not to maintain their full
product offerings in response to the
investments needed to support TSL 6.
Additionally, most small businesses
will struggle to secure this funding, due
to their size and the uncertainty of
recovering their investments. At TSL 6,
models representing 4 percent of all
GFB shipments are estimated to meet
the efficiency requirements at this TSL
in the no-new-standards case by 2030,
the modeled compliance year.
Therefore, models representing 96
percent of all GFB shipments will need
be remodeled in the 5-year compliance
period.
Manufacturers are unlikely to have
the engineering capacity to conduct this
massive redesign effort in 5 years.
Instead, they will likely prioritize
redesigns based on sales volume, which
could leave market gaps in equipment
offered by manufacturers and even the
entire industry. The resulting market
gaps in equipment offerings could result
130 The sum of annual free cash flows is estimated
to be $2,348 million for 2025–2029 in the no-newstandards case and the no-new-standards case INPV
is estimated to be $4,935 million.
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in sub-optimal selection of fan duty
points (airflow, pressure, speed
combination) for some applications,
potentially leading to a reduction in the
estimated energy savings, and estimated
consumer benefits, at this TSL. Most
small businesses will be at a
competitive disadvantage at this TSL
because they have less technical and
financial resources and the capital
investments required will be spread
over fewer units.
The Secretary tentatively concludes
that at TSL 6 for GFBs, the benefits of
energy savings, positive NPV of
consumer benefits, emission reductions,
and the estimated monetary value of the
emissions reductions would be
outweighed by the economic burden on
many consumers, and the impacts on
manufacturers, including the extremely
large conversion costs (representing
approximately 1.3 times the sum of the
annual free cash flows during the time
period that these conversion costs will
be incurred and are approximately equal
to 75 percent of the entire no-newstandards case INPV), profitability
impacts that could result in a large
reduction in INPV (up to a decrease of
46.4 percent), the large negative free
cash flows in the years leading up to the
compliance date (annual free cash flow
is estimated to be ¥$1,132 million in
the year before the compliance date), the
lack of manufacturers currently offering
equipment meeting the efficiency levels
required at this TSL (models
representing 96 percent of shipments
will need to be redesigned to meet this
TSL), including most small businesses,
and the likelihood of the significant
disruption in the GFB market. Due to
the limited amount of engineering
resources each manufacturer has, it is
unclear if most manufacturers will be
able to redesign models representing on
average 96 percent of their GFB
shipments covered by this rulemaking
in the 5-year compliance period.
Consequently, the Secretary has
tentatively concluded that TSL 6 is not
economically justified.
DOE then considered TSL 5, which
represents a combination of the highest
efficiency levels resulting in positive
life-cycle costs savings. At TSL 5, DOE
expects all equipment classes, except for
axial PRVs, would require an
aerodynamic redesign. Axial panel,
centrifugal housed, centrifugal inline,
centrifugal unhoused, centrifugal PRV
supply, and radial housed fans would
all require the highest tier aerodynamic
redesign. Axial inline and centrifugal
PRV exhaust fans would require the
second to highest tier aerodynamic
redesign. Axial PRV fans would require
two size increases in diameter.
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TSL 5 would save an estimated 23.7
quads of energy, an amount DOE
considers significant. Under TSL 5, the
NPV of consumer benefit would be
$19.2 billion using a discount rate of 7
percent, and $54.8 billion using a
discount rate of 3 percent.
The cumulative emissions reductions
at TSL 5 are 411.5 Mt of CO2, 125.6
thousand tons of SO2, 775.1 thousand
tons of NOX, 0.9 tons of Hg, 3,567.0
thousand tons of CH4, and 3.9 thousand
tons of N2O. The estimated monetary
value of the climate benefits from
reduced GHG emissions (associated
with the average SC–GHG at a 3-percent
discount rate) at TSL 5 is $20.2 billion.
The estimated monetary value of the
health benefits from reduced SO2 and
NOX emissions at TSL 5 is $14.0 billion
using a 7-percent discount rate and
$39.9 billion using a 3-percent discount
rate.
Using a 7-percent discount rate for
consumer benefits and costs, health
benefits from reduced SO2 and NOX
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
total NPV at TSL 5 is $53.4 billion.
Using a 3-percent discount rate for all
benefits and costs, the estimated total
NPV at TSL 5 is $115.0 billion. The
estimated total NPV is provided for
additional information, however DOE
primarily relies upon the NPV of
consumer benefits when determining
whether a proposed standard level is
economically justified.
At TSL 5, for the largest equipment
classes (which are represented by axial
panel fans, centrifugal housed fans, and
centrifugal unhoused fans) the
standards are set at the max-tech EL as
with TSL 6. There is a life-cycle cost
savings of $1,902, $2,398, and $2,004
and a payback period of 2.5 years, 3.1
years, and 1.0 years, respectively. For
these equipment classes, the fraction of
customers experiencing a net LCC cost
is 29.9 percent, 41.5 percent, and 13.7
percent due to increases in total
installed cost of $618, $1,090 and $215,
respectively. The life-cycle costs savings
for axial inline, centrifugal inline, and
radial housed fans are positive and
equal to $670, $335, and $5,391,
respectively. For these equipment
classes the payback is 9.8, 9.1, and 2.2
years and the fraction of customers
experiencing a net LCC cost is 51.3
percent, 66.7 percent, and 24.4 percent.
The life-cycle costs savings for axial
PRVs, centrifugal PRV exhaust, and
centrifugal PRV supply fans are positive
and equal to $945, $154, and $1,126,
respectively. For these equipment
classes the payback is 7.0, 8.9, and 2.8
years and the fraction of customers
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experiencing a net LCC cost is 14.3
percent, 25.8 percent, and 32.3 percent.
At TSL5, the shipments-weighted
average LCC is equal to $2,030, the
payback period is equal to 2.9 and the
fraction of customers experiencing a net
LCC cost is 30.2 percent.
At TSL 5, the projected change in
INPV ranges from a decrease of $1,263
million to an increase of $11 million,
which corresponds to a decrease of 25.6
percent and an increase of 0.2 percent,
respectively. DOE estimates that
industry must invest $2,075 million to
conduct aerodynamic redesigns on all
equipment classes except axial PRVs
and to increase the diameter by two
sizes for axial PRVs to comply with
standards set at TSL 5. An investment
of $2,075 million in conversion costs
represents approximately 90 percent of
the sum of the annual free cash flows
over the years between the estimated
final rule announcement date and the
estimated standards year (i.e., the time
period that these conversion costs
would be incurred) and represents over
42 percent of the entire no-newstandards case INPV over the 30-year
analysis period.131
In the no-new-standards case, free
cash flow is estimated to be $480
million in 2029, the year before the
modeled compliance date. At TSL 5, the
estimated free cash flow is -$407 million
in 2029. This represents a decrease in
free cash flow of 185 percent, or a
decrease of $887 million, in 2029. A
negative free cash flow implies that
most, if not all, manufacturers will need
to borrow substantial funds to be able to
make investments necessary to comply
with energy conservation standards at
TSL 5. The large drop in free cash flows
could cause some GFB manufacturers to
exit the GFB market entirely, even
though recovery may be possible over
the 30-year analysis period.
Additionally, most small businesses
will struggle to secure this funding due
to their size and the uncertainty of
recovering their investments. At TSL 5,
models representing 7 percent of all
GFB shipments are estimated to meet or
exceed the efficiency requirements at
this TSL in the no-new-standards case
by 2030, the modeled compliance year.
Therefore, models representing 93
percent of all GFB shipments will need
to be remodeled in the 5-year
compliance period.
Manufacturers are unlikely to have
the engineering capacity to conduct this
massive redesign effort in 5 years.
131 The sum of annual free cash flows is estimated
to be $2,348 million for 2025–2029 in the no-newstandards case and the no-new-standards case INPV
is estimated to be $4,935 million.
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Instead, they will likely prioritize
redesigns based on sales volume, which
could leave market gaps in equipment
offered by manufacturers and even the
entire industry. The resulting market
gaps in equipment offerings could result
in sub-optimal selection of fan duty
points (airflow, pressure, speed
combination) for some applications,
potentially leading to a reduction in the
estimated energy savings, and estimated
consumer benefits, at this TSL. Most
small businesses will be at a
competitive disadvantage at this TSL
because they have less technical and
financial resources and the capital
investments required will be spread
over fewer units.
The Secretary tentatively concludes
that at TSL 5 for GFBs, the benefits of
energy savings, the economic benefits
on many consumers, positive NPV of
consumer benefits, emission reductions,
and the estimated monetary value of the
emissions reductions would be
outweighed by the impacts on
manufacturers, including the extremely
large conversion costs (representing
approximately 90 percent of the sum of
the annual free cash flows during the
time period these conversion costs will
be incurred and are approximately equal
to 42 percent of the entire no-newstandards case INPV), profitability
margin impacts that could result in a
large reduction in INPV (up to a
decrease of 25.6 percent), the large
negative free cash flows in the years
leading up to the compliance date
(annual free cash flow is estimated to be
¥$407 million in the year before the
compliance date), the lack of
manufacturers currently offering
equipment meeting the efficiency levels
required at this TSL (models
representing 93 percent of all GFB
shipments will need to be redesigned to
meet this TSL), including most small
businesses, and the likelihood of the
significant disruption in the GFB
market. Due to the limited amount of
engineering resources each
manufacturer has, it is unclear if most
manufacturers will be able to redesign
models representing on average 93
percent of their GFB shipments covered
by this rulemaking in the 5-year
compliance period. Consequently, the
Secretary has tentatively concluded that
TSL 5 is not economically justified.
DOE then considered TSL 4, which
represents an intermediate level that is
one efficiency level below TSL 5 for
each equipment class. At TSL 4, DOE
expects all equipment classes, except for
axial PRVs, would require an
aerodynamic redesign. Axial panel,
centrifugal housed, centrifugal inline,
centrifugal unhoused, centrifugal PRV
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supply, and radial housed fans would
all require the second highest tier
aerodynamic redesign. Axial inline fans
would require the lowest tier
aerodynamic redesign. Centrifugal PRV
exhaust fans would require the second
to lowest tier aerodynamic redesign.
Axial PRV fans would require one size
increase in diameter.
TSL 4 would save an estimated 13.8
quads of energy, an amount DOE
considers significant. Under TSL 4, the
NPV of consumer benefit would be
$13.7 billion using a discount rate of 7
percent, and $36.9 billion using a
discount rate of 3 percent.
The cumulative emissions reductions
at TSL 4 are 239.4 Mt of CO2, 73.1
thousand tons of SO2, 450.9 thousand
tons of NOX, 0.5 tons of Hg, 2,073.9
thousand tons of CH4, and 2.3 thousand
tons of N2O. The estimated monetary
value of the climate benefits from
reduced GHG emissions (associated
with the average SC–GHG at a 3-percent
discount rate) at TSL 4 is $11.9 billion.
The estimated monetary value of the
health benefits from reduced SO2 and
NOX emissions at TSL 5 is $8.2 billion
using a 7-percent discount rate and
$23.4 billion using a 3-percent discount
rate.
Using a 7-percent discount rate for
consumer benefits and costs, health
benefits from reduced SO2 and NOX
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
total NPV at TSL 4 is $33.8 billion.
Using a 3-percent discount rate for all
benefits and costs, the estimated total
NPV at TSL 4 is $72.2 billion. The
estimated total NPV is provided for
additional information, however DOE
primarily relies upon the NPV of
consumer benefits when determining
whether a proposed standard level is
economically justified.
At TSL 4, for the largest equipment
classes which are represented by axial
panel fans, centrifugal housed fans, and
centrifugal unhoused fans; there is a
life-cycle cost savings of $1,702, $2,423,
and $1,170; and a payback period of 1.7
years, 0.6 years, and 1.2 years,
respectively. For these equipment
classes, the fraction of customers
experiencing a net LCC cost is 19.5
percent, 12.9 percent, and 10.5 percent
due to increases in total installed cost of
$293, $134 and $135, respectively. The
life-cycle costs savings for axial inline,
centrifugal inline, and radial housed
fans are positive and equal to $550,
$955, and $3,714, respectively. For
these equipment classes the payback is
9.6, 6.1, and 1.7 years and the fraction
of customers experiencing a net LCC
cost is 23.6 percent, 49.2 percent, and
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13.3 percent. The life-cycle costs
savings for axial PRVs, centrifugal PRV
exhaust, and centrifugal PRV supply
fans are positive and equal to $945,
$154, and $973, respectively. For these
equipment classes the payback is 7.0,
8.9, and 1.7 years and the fraction of
customers experiencing a net LCC cost
is 14.3 percent, 25.8 percent, and 24.9
percent At TSL 4, the shipmentweighted average LCC is equal to
$1,694, the payback period is equal to
1.8 and the fraction of customers
experiencing a net LCC cost is 15.7
percent.
At TSL 4, the projected change in
INPV ranges from a decrease of $455
million to an increase of $1 million,
which corresponds to a decrease of 9.2
percent and an increase of less than 0.1
percent, respectively. DOE estimates
that industry must invest $770 million
to comply with standards set at TSL 4.
An investment of $770 million in
conversion costs represents
approximately 33 percent of the sum of
the annual free cash flows over the years
between the estimated final rule
announcement date and the estimated
standards year (i.e., the time period that
these conversion costs would be
incurred) and represents over 15 percent
of the entire no-new-standards case
INPV over the 30-year analysis
period.132
In the no-new-standards case, free
cash flow is estimated to be $480
million in 2029, the year before the
modeled compliance date. At TSL 4, the
estimated free cash flow is $161 million
in 2029. This represents a decrease in
free cash flow of 66.4 percent, or a
decrease of $319 million, in 2029.
Annual cash flows remain positive for
all years leading up to the modeled
compliance date. At TSL 4, models
representing 25 percent of all GFB
shipments are estimated to meet or
exceed the efficiency requirements at
this TSL in the no-new-standards case
by 2030, the modeled compliance year.
Therefore, models representing 75
percent of all GFB shipments will need
to be remodeled in the 5-year
compliance period. DOE estimates that
while this represents a significant
redesign effort, most GFB manufacturers
will have the engineering capacity to
complete these redesigns in a 5-year
compliance period.
After considering the analysis and
weighing the benefits and burdens, the
Secretary has tentatively concluded that
a standard set at TSL 4 for GFBs would
be economically justified. At this TSL,
the average LCC savings for all GFB
equipment class consumers is positive.
An estimated 15.7 percent of consumers
experience a net cost. The FFC national
energy savings are significant and the
NPV of consumer benefits is positive
using both a 3-percent and 7-percent
discount rate. Notably, the benefits to
consumers vastly outweigh the cost to
manufacturers. At TSL 4, the NPV of
consumer benefits, even measured at the
more conservative discount rate of 7
percent is over 30 times higher than the
maximum estimated manufacturers’ loss
in INPV. The standard levels at TSL 4
are economically justified even without
weighing the estimated monetary value
of emissions reductions. When those
emissions reductions are included—
representing $11.9 billion in climate
benefits (associated with the average
SC–GHG at a 3-percent discount rate),
and $23.4 billion (using a 3-percent
discount rate) or $8.2 billion (using a 7percent discount rate) in health
benefits—the rationale for setting
standards at TSL 4 for GFBs is further
strengthened. Additionally, the impact
to manufacturers is significantly
reduced at TSL 4. While manufacturers
have to invest $770 million to comply
with standards at TSL 4, annual free
cash flows remain positive for all years
leading up to the compliance date.
Lastly, DOE estimates that most GFB
manufacturers will have the engineering
capacity to complete these redesigns in
a 5-year compliance period.
As stated, DOE conducts the walkdown analysis to determine the TSL that
represents the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified as required under
EPCA. The walk-down is not a
comparative analysis, as a comparative
analysis would result in the
maximization of net benefits instead of
energy savings that are technologically
feasible and economically justified,
which would be contrary to the statute.
86 FR 70892, 70908. While DOE
recognizes that TSL 4 is not the TSL that
maximizes net monetized benefits, DOE
has weighed other non-quantified and
non-monetized factors in accordance
with EPCA in reaching this
determination. DOE notes that as
compared to TSL 5 and TSL 6, TSL 4
has significantly smaller percentages of
GFBs consumers experiencing a net
132 The sum of annual free cash flows is estimated
to be $2,348 million for 2025–2029 in the no-new-
standards case and the no-new-standards case INPV
is estimated to be $4,935 million.
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3843
cost, a lower simple payback period, a
lower maximum decrease in INPV,
lower manufacturer conversion costs,
and significantly less likelihood of a
major disruption to the GFB market, as
DOE does not anticipate gaps in GFB
equipment offerings at TSL 4.
Although DOE considered proposed
new standard levels for GFBs by
grouping the efficiency levels for each
equipment class into TSLs, DOE
evaluates all analyzed efficiency levels
in its analysis. For all equipment
classes, TSL 4 represents the maximum
energy savings that does not result in
significant negative economic impacts
to GFB manufacturers. At TSL 4
conversion costs are estimated to be
$770 million, significantly less than at
TSL 5 ($2,075 million) and at TSL 6
($3,750 million). At TSL 4 conversion
costs represent a significantly smaller
size of the sum of GFB manufacturers’
annual free cash flows for 2025 to 2029
(33 percent), than at TSL 5 (90 percent)
and at TSL 6 (130 percent) and a
significantly smaller portion of GFB
manufacturers’ no-new-standards case
INPV (15 percent), than at TSL 5 (42
percent) and at TSL 6 (75 percent). At
TSL 4, GFB manufacturers will have to
redesign a significantly smaller portion
of their GFB models to meet the ELs set
at TSL 4 (models representing 75
percent of all GFB shipments), than at
TSL 5 (93 percent) and at TSL 6 (96
percent). Lastly, GFB manufacturers’
free cash flow remains positive at TSL
4 for all years leading up to the
compliance date. Whereas at TSL 5
annual free cash flow is estimated to be
¥$407 million and at TSL 6 annual free
cash flow is estimated to be ¥$1,132
million in 2029, the year before the
modeled compliance year. The ELs at
the proposed TSL result in average
positive LCC savings for all equipment
classes, significantly reduce the number
of consumers experiencing a net cost,
and reduce the decrease in INPV and
conversion costs to the point where
DOE has concluded they are
economically justified, as discussed for
TSL 4 in the preceding paragraphs.
Therefore, based on the previous
considerations, DOE proposes to adopt
the energy conservation standards for
GFBs at TSL 4. The proposed energy
conservation standards for GFBs, which
are expressed as FEI values, are shown
in Table V–66.
BILLING CODE 6450–01–P
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Table V-66 Proposed Enere:v Conservation Standards for GFBs
Equipment Class
With or Without
Fan Energy Index
(FEI)*
Motor Controller
Axial Inline
Without
1.18 * A
Axial Panel
Without
1.48 * A
Axial Power Roof Ventilator
Without
0.85 * A
Centrifugal Housed
Without
1.31 * A
Centrifugal Unhoused
Without
1.35 * A
Centrifugal Inline
Without
1.28 * A
1.17*A
Radial Housed
Without
Centrifugal Power Roof Ventilator Without
1.00 * A
-Exhaust
Centrifugal Power Roof Ventilator Without
1.19 * A
- Supply
1.18*A*B
Axial Inline
With
1.48 * A* B
Axial Panel
With
0.85 * A* B
Axial Power Roof Ventilator
With
1.31*A*B
Centrifugal Housed
With
1.35 *A* B
Centrifugal Unhoused
With
1.28 * A* B
Centrifugal Inline
With
1.17*A*B
Radial Housed
With
1.00 * A* B
Centrifugal Power Roof Ventilator With
-Exhaust
1.19*A*B
Centrifugal Power Roof Ventilator With
- Supply
*A is a constant representing an adjustment in FEI for motor hp, which can be found in Table V-67. B is a
constant representing an adjustment in FEI for motor controllers, which can be found in Table V-67.
Table V-67 Constants for GFB Proposed Enere:v Conservation Standards
Constant Condition
Value
Motor hp < 100 hp
A
A= 1.00
17mtr,2023
Motor hp ~ 100 hp and :S 250 hp
A=
With Motor
Controller
FEPact of<
20 kW (26.8
hp)
FEPact of~
20 kW (26.8
hp)
B=
17mtr 2014
FEPact-Credit
h
; were:
FEPact
Credit= 0.03 x
[SI]
FEPact
+ 0.08
Credit= 0.03 X FEPact + 0.08 X
1.341 rIPl
B = 0.966
is the motor efficiency in accordance with Table 8 at 10 CFR 431.25, TJm1r,2014 is the motor
efficiency in accordance with Table 5 at 10 CFR 431.25, which DOE is proposing to adopt into 10 CFR
431.17 5, and FEPact is determined according to the DOE test procedure in Appendix A to Subpart J of Part
431.
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DOE is proposing an FEI level of 0.85
(EL4) for axial PRVs. In section IV.C.1.b,
DOE developed the MSP-efficiency
relationship based on data from the
AMCA sales database as well as
performance data from manufacturer fan
selection software and performance data
provided from confidential
manufacturer interviews. From its
analysis, DOE estimated that EL4 for
axial PRVs would be achieved by
implementing two impeller diameter
increases. Based on the MSP-efficiency
results, EL4 for axial PRVs is the highest
level with positive life-cycle costs
savings. Furthermore, as discussed in
section IV.C.1.b, ASHRAE 90.1–2022 set
an FEI target of 1.00 for all fans within
the scope of that standard, which
includes axial PRVs. CEC requires
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manufacturers to report fan operating
boundaries that result in operation at a
FEI of greater than or equal to 1.00 for
all fans within the scope of that
rulemaking, which includes axial PRVs.
DOE also notes that, based on its
shipments analysis, 50-percent of axial
PRVs have an FEI of at least 1.00.
Additionally, based on its review of the
market, DOE has found that most
manufacturers offer models of APRVs
that have an FEI of at least 1.00 at a
range of diameters. Based on this, DOE
expects that the market is already
shifting towards an FEI of 1.00 for axial
PRVs and that this level may not be
unduly burdensome for manufacturers
to achieve.
DOE requests comment on the
proposed standard level for axial PRVs,
including the design options and costs,
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3845
as well as the burdens and benefits
associated with this level and the
industry standards/California
regulations FEI level of 1.00.
b. Air Circulating Fans
Table V–68 and Table V–69
summarize the quantitative impacts
estimated for each TSL for ACFs. The
national impacts are measured over the
lifetime of ACFs purchased in the 30year period that begins in the
anticipated first full year of compliance
with new standards (2030–2059). The
energy savings, emissions reductions,
and value of emissions reductions refer
to full-fuel-cycle results. The efficiency
levels contained in each TSL are
described in section V.A of this
document.
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Table V-68 Summary of Analytical Results for ACFs TSLs: National Impacts
TSL 1 TSL2 TSL3 TSL4 TSL5
Cate2orv
Cumulative FFC National Ener2V Savin2s
Quads
0.1
0.2
1.2
4.5
6.5
Cumulative FFC Emissions Reduction
CO2 (million metric tons)
1.7
3.8
21.5
78.5
112.6
CRi (thousand tons)
15.3
33.4
188.0
686.7
984.6
N2O (thousand tons)
0.0
0.0
0.2
0.6
0.9
7.2
NOx (thousand tons)
3.3
40.5
148.0
212.2
SO2 (thousand tons)
0.4
1.0
5.4
19.7
28.2
Hg (tons)
0.0
0.0
0.0
0.1
0.2
Present Value of Monetized Benefits and Costs (3% discount rate, billion 2022$)
Consumer Operating Cost Savings
0.3
0.6
3.6
13.2
18.9
Climate Benefits*
0.1
0.2
1.2
4.4
6.3
Health Benefits**
0.2
0.4
2.2
8.2
11.7
Total Benefitst
0.6
1.2
7.0
25.8
36.9
Consumer Incremental Product
Costs:t
Consumer Net Benefits
Total Net Benefits
-0.1
-0.1
0.0
0.4
0.7
3.6
0.7
1.3
7.1
Present Value of Monetized Benefits and Costs ( 7% discount rate,
Consumer Operating Cost Savings
0.1
0.3
1.5
Climate Benefits*
0.1
0.2
1.2
Health Benefits**
0.1
0.2
0.9
0.3
0.6
3.6
Total Benefitst
Consumer Incremental Equipment
Costs
Consumer Net Benefits
Total Net Benefits
0.6
5.8
12.6
13.1
25.2
31.1
billion 2022$)
5.5
7.9
4.4
6.3
3.1
4.5
13.1
18.7
TSL6
7.2
125.8
1100.4
1.0
237.2
31.5
0.2
20.6
7.1
13.1
40.8
6.1
14.5
34.7
8.7
7.1
5.0
20.7
-0.1
0.0
0.0
0.3
2.7
3.0
0.2
0.4
0.3
0.7
1.5
3.6
5.3
12.8
5.2
16.0
5.7
17.7
Note: This table presents the costs and benefits associated with ACFs shipped in 2030-2059. These results
include benefits to consumers which accrue after 2059 from the products shipped in 2030-2059.
* Climate benefits are calculated using four different estimates of the SC-CO2, SC-CH4 and SC-N2O.
Together, these represent the global SC-GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3-percent discount rate are shown; however, DOE emphasizes the
importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the
benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.
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** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for NOx and SO2) PM2.s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2.s emissions. The health benefits are presented at real discount rates of 3 and 7
percent. See section IV.L of this document for more details.
t Total and net benefits include consumer, climate, and health benefits. For presentation puiposes, total and
net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GH G with 3percent discount rate. DOE emphasizes the importance and value of considering the benefits calculated
using all four sets of SC-GHG estimates.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3847
Table V-69 Summary of Analytical Results for ACFs TSLs: Manufacturer and
Consumer Impacts
Category
Manufacturer Impacts
Industry NPV (million
2022$) (No-new-standards
case INPV = 649)
TSL2
TSL3
TSL4
TSL5
TSL6
649- 650
649649
645649
579649
16652
(85)653
0.0- 0.1
0.00.0
(0.6)0.0
(10.9)0.0
(97.5)0.5
(113.1)0.5
Consumer Average LCC Savings (2022$)
Axial ACFs; 12" :S D <
35
495
327
141
126
36" (ACFl)
Axial ACFs; 36" :S D <
291
606
478
341
346
297
48" (ACF2)
Axial ACFs; 48" :S D
343
587
628
668
613
630
(ACF3)
Housed Centrifugal ACFs
18
-1,210
(ACF4)
Shipment-Weighted
192
289
564
479
353
342
Average *
Consumer Simple PBP (years)
Axial ACFs; 12" :S D <
2.7
0.2
0.5
2.8
3.1
36" (ACFl)
Axial ACFs; 36" :S D <
NIA
NIA
NIA
0.2
1.6
1.9
48" (ACF2)
Axial ACFs; 48" :S D
NIA
NIA
NIA
0.1
1.1
1.4
(ACF3)
Housed Centrifugal ACFs
4.8
25.0
(ACF4)
Shipment-Weighted
NIA
1.1
0.1
0.3
1.9
2.4
Average *
Percent of Consumers that Experience a Net Cost
Axial ACFs; 12" :S D <
0.1%
0.0%
0.2%
40.4%
45.1%
36" (ACFl)
Axial ACFs; 36" :S D <
0.0%
0.2%
0.0%
0.0%
22.7%
23.6%
48" (ACF2)
Axial ACFs; 48" :S D
0.0%
0.0%
0.0%
0.0%
9.3%
11.3%
(ACF3)
Housed Centrifugal ACFs
14.1%
99.7%
(ACF4)
Shipment-Weighted
0.0%
0.1%
0.0%
0.1%
24.8%
28.6%
Average *
Parentheses indicate negative (-) values. The entry "-" means no impact because the TSL
considered is equivalent to the no-new standards case. The entry ''NIA." means not applicable
because there is a decrease in average installed costs at the considered TSLs compared to the nonew standards case.
* Weighted by shares of each equipment class in total projected shipments in 2030.
BILLING CODE 6450–01–C
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equipment classes would require an
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ECM. TSL 6 would save an estimated
7.2 quads of energy, an amount DOE
considers significant. Under TSL 6, the
NPV of consumer benefit would be $5.7
billion using a discount rate of 7
percent, and $14.5 billion using a
discount rate of 3 percent.
The cumulative emissions reductions
at TSL 6 are 125.8 Mt of CO2, 31.5
thousand tons of SO2, 237.2 thousand
tons of NOX, 0.2 tons of Hg, 1,100.4
thousand tons of CH4, and 1.0 thousand
tons of N2O. The estimated monetary
value of the climate benefits from
reduced GHG emissions (associated
with the average SC–GHG at a 3-percent
discount rate) at TSL 6 is $7.1 billion.
The estimated monetary value of the
health benefits from reduced SO2 and
NOX emissions at TSL 6 is $5.0 billion
using a 7-percent discount rate and
$13.1 billion using a 3-percent discount
rate.
Using a 7-percent discount rate for
consumer benefits and costs, health
benefits from reduced SO2 and NOX
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
total NPV at TSL 6 is $17.7 billion.
Using a 3-percent discount rate for all
benefits and costs, the estimated total
NPV at TSL 6 is $34.7 billion. The
estimated total NPV is provided for
additional information, however DOE
primarily relies upon the NPV of
consumer benefits when determining
whether a proposed standard level is
economically justified.
At TSL 6, for the largest equipment
classes, which are represented by ACF1,
ACF2, and ACF3—which together
represent approximately 99 percent of
annual shipments—there is a life-cycle
cost savings of $126, $346, and $630
and a payback period of 3.1 years, 1.9
years, and 1.4 years, respectively. For
these equipment classes, the fraction of
customers experiencing a net LCC cost
is 45.1 percent, 23.6 percent, and 11.3
percent due to increases in total
installed cost of $187, $201 and $222,
respectively. For the remaining
equipment class (ACF4), the average
LCC savings are ¥$1,210, a majority of
consumers (99.7 percent) would
experience a net cost and the payback
period is 25.0 years.
At TSL 6, the projected change in
INPV ranges from a decrease of $734
million to an increase of $3 million,
which corresponds to decreases of 113.1
percent and an increase of 0.5 percent,
respectively. DOE estimates that
industry must invest $1,167 million to
conduct aerodynamic redesigns on all
equipment classes and to implement
ECMs for all equipment classes to
comply with standards set at TSL 6. An
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investment of $1,167 million in
conversion costs represents over 5 times
the sum of the annual free cash flows
over the years between the estimated
final rule announcement date and the
estimated standards year (i.e., the time
period that these conversion costs
would be incurred) and represents
approximately 1.8 times the entire nonew-standards case INPV over the 30year analysis period.133
In the no-new-standards case, free
cash flow is estimated to be $51 million
in 2029, the year before the modeled
compliance date. At TSL 6, the
estimated free cash flow is ¥$456
million in 2029. This represents a
decrease in free cash flow of 999
percent, or a decrease of $507 million,
in 2029. A negative free cash flow
implies that most, if not all,
manufacturers will need to borrow
substantial funds to be able to make
investments necessary to comply with
energy conservation standards at TSL 6.
The extremely large drop in free cash
flows could cause some ACF
manufacturers to exit the ACF market
entirely, even though recovery may be
possible over the 30-year analysis
period. Additionally, most small
businesses will struggle to secure this
funding, due to their size and the
uncertainty of recovering their
investments. At TSL 6, models
representing 1 percent of all ACF
shipments are estimated to meet the
efficiency requirements at this TSL in
the no-new-standards case by 2030, the
modeled compliance year. Therefore,
models representing 99 percent of all
ACF shipments will need to be
remodeled in the 5-year compliance
period.
Manufacturers are unlikely to have
the engineering capacity to conduct this
massive redesign effort in 5 years.
Instead, they will likely prioritize
redesigns based on sales volume, which
could leave market gaps in equipment
offered by manufacturers and even the
entire industry. The resulting market
gaps in equipment offerings could result
in sub-optimal selection of fan duty
points (airflow, pressure, speed
combination) for some applications,
potentially leading to a reduction in the
estimated energy savings, and estimated
consumer benefits, at this TSL. Most
small businesses will be at a
competitive disadvantage at this TSL
because they have less technical and
financial resources and the capital
133 The sum of annual free cash flows is estimated
to be $227 million for 2025–2029 in the no-newstandards case and the no-new-standards case INPV
is estimated to be $649 million.
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investments required will be spread
over fewer units.
The Secretary tentatively concludes
that at TSL 6 for ACFs, the benefits of
energy savings, the economic benefits
on many consumers, positive NPV of
consumer benefits, emission reductions,
and the estimated monetary value of the
emissions reductions would be
outweighed by the impacts on
manufacturers, including the extremely
large conversion costs (representing
approximately 5 times the sum of the
annual free cash flows during the time
period that these conversion costs will
be incurred and are approximately equal
to 1.8 times the entire no-new-standards
case INPV), profitability impacts that
could result in a large reduction in INPV
(up to a decrease of 113.1 percent), the
large negative free cash flows in the
years leading up to the compliance date
(annual free cash flow is estimated to be
¥$456 million in the year before the
compliance date), the lack of
manufacturers currently offering
equipment meeting the efficiency levels
required at TSL 6 (models representing
99 percent of all ACF shipments will
need to be redesigned to meet this TSL),
including most small businesses, and
the likelihood of the significant
disruption in the ACF market. Due to
the limited amount of engineering
resources each manufacturer has, it is
unclear if most manufacturers will be
able to redesign models representing on
average 99 percent of their ACF
shipments covered by this rulemaking
in the 5-year compliance period.
Consequently, the Secretary has
tentatively concluded that TSL 6 is not
economically justified.
DOE then considered TSL 5, which
represents the highest EL below maxtech with positive LCC savings and is a
combination of efficiency level 5 for
axial ACFs and efficiency level 3 for
housed centrifugal ACFs. At TSL 5, DOE
expects that axial ACFs would require
the highest tier of aerodynamic redesign
and housed centrifugal ACFs would
require the lowest tier of aerodynamic
redesign. TSL 5 would save an
estimated 6.5 quads of energy, an
amount DOE considers significant.
Under TSL 5, the NPV of consumer
benefit would be $5.2 billion using a
discount rate of 7 percent, and $13.1
billion using a discount rate of 3
percent.
The cumulative emissions reductions
at TSL 5 are 112.6 Mt of CO2, 28.2
thousand tons of SO2, 212.2 thousand
tons of NOX, 0.2 tons of Hg, 984.6
thousand tons of CH4, and 0.9 thousand
tons of N2O. The estimated monetary
value of the climate benefits from
reduced GHG emissions (associated
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with the average SC–GHG at a 3-percent
discount rate) at TSL 5 is $6.3 billion.
The estimated monetary value of the
health benefits from reduced SO2 and
NOX emissions at TSL 5 is $4.5 billion
using a 7-percent discount rate and
$11.7 billion using a 3-percent discount
rate.
Using a 7-percent discount rate for
consumer benefits and costs, health
benefits from reduced SO2 and NOX
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
total NPV at TSL 5 is $16.0 billion.
Using a 3-percent discount rate for all
benefits and costs, the estimated total
NPV at TSL 5 is $31.1 billion. The
estimated total NPV is provided for
additional information, however DOE
primarily relies upon the NPV of
consumer benefits when determining
whether a proposed standard level is
economically justified.
At TSL 5, for the largest equipment
classes, which are represented by ACF1,
ACF2, and ACF3—which together
represent approximately 99 percent of
annual shipments—there is a life-cycle
cost savings of $141, $341, and $613
and a payback period of 2.8 years, 1.6
years, and 1.1 years, respectively. For
these equipment classes, the fraction of
customers experiencing a net LCC cost
is 40.4 percent, 22.7 percent, and 9.3
percent due to increases in total
installed cost of $148, $156 and $155,
respectively. For the remaining
equipment class (ACF4), the average
LCC savings are $18 and 14.1 percent of
consumers would experience a net cost
and the payback period is 4.8 years.
At TSL 5, the projected change in
INPV ranges from a decrease of $633
million to an increase of $3 million,
which corresponds to a decrease of 97.5
percent and an increase of 0.5 percent,
respectively. DOE estimates that
industry must invest $1,043 million to
conduct significant aerodynamic
redesigns for non-compliant axial ACFs
and minor aerodynamic redesign for
non-compliant housed centrifugal ACFs
to comply with standards set at TSL 5.
An investment of $1,043 million in
conversion costs represents over 4.5
times the sum of the annual free cash
flows over the years between the
estimated final rule announcement date
and the estimated standards year (i.e.,
the time period that these conversion
costs would be incurred) and represents
approximately 1.6 times the entire nonew-standards case INPV over the 30year analysis period.134
In the no-new-standards case, free
cash flow is estimated to be $51 million
in 2029, the year before the modeled
compliance date. At TSL 5, the
estimated free cash flow is ¥$400
million in 2029. This represents a
decrease in free cash flow of 889
percent, or a decrease of $451 million,
in 2029. A negative free cash flow
implies that most, if not all,
manufacturers will need to borrow
substantial funds to be able to make
investments necessary to comply with
energy conservation standards at TSL 5.
The large drop in free cash flows could
cause some ACF manufacturers to exit
the ACF market entirely, even though
recovery may be possible over the 30year analysis period. Additionally, most
small businesses will struggle to secure
this funding, due to their size and the
uncertainty of recovering their
investments. At TSL 5, models
representing 4 percent of all ACF
shipments are estimated to meet or
exceed the efficiency requirements at
this TSL in the no-new-standards case
by 2030, the modeled compliance year.
Therefore, models representing 96
percent of all ACF shipments will need
to be remodeled in the 5-year
compliance period.
Manufacturers are unlikely to have
the engineering capacity to conduct this
massive redesign effort in 5 years.
Instead, they will likely prioritize
redesigns based on sales volume, which
could leave market gaps in equipment
offered by manufacturers and even the
entire industry. The resulting market
gaps in equipment offerings could result
in sub-optimal selection of fan duty
points (airflow, pressure, speed
combination) for some applications,
potentially leading to a reduction in the
estimated energy savings, and estimated
consumer benefits, at this TSL. Most
small businesses will be at a
competitive disadvantage at this TSL
because they have less technical and
financial resources and the capital
investments required will be spread
over fewer units.
The Secretary tentatively concludes
that at TSL 5 for ACFs, the benefits of
energy savings, the economic benefits
on many consumers, positive NPV of
consumer benefits, emission reductions,
and the estimated monetary value of the
emissions reductions would be
outweighed by the impacts on
manufacturers, including the extremely
large conversion costs (representing
approximately 4.5 times the sum of the
annual free cash flows during the time
period that these conversion costs will
134 The sum of annual free cash flows is estimated
to be $227 million for 2025–2029 in the no-new-
standards case and the no-new-standards case INPV
is estimated to be $649 million.
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3849
be incurred and are approximately equal
to 1.6 times the entire no-new-standards
case INPV), profitability impacts that
could result in a large reduction in INPV
(up to a decrease of 97.5 percent), the
large negative free cash flows in the
years leading up to the compliance date
(annual free cash flow is estimated to be
¥$400 million in the year before the
compliance date), the lack of
manufacturers currently offering
equipment meeting the efficiency levels
required at TSL 5 (models representing
96 percent of all ACF shipments will
need to be redesigned to meet this TSL),
including most small businesses, and
the likelihood of the significant
disruption in the ACF market. Due to
the limited amount of engineering
resources each manufacturer has, it is
unclear if most manufacturers will be
able to redesign models representing on
average 96 percent of their ACF
shipments covered by this rulemaking
in the 5-year compliance period.
Consequently, the Secretary has
tentatively concluded that TSL 5 is not
economically justified.
DOE then considered TSL 4, which
represents efficiency level 4 for axial
ACFs and efficiency level 0 for housed
centrifugal ACFs (no new standards for
housed centrifugal ACFs). DOE expects
that the second highest tier of
aerodynamic redesign would be
required for axial ACFs at TSL 4 would
save an estimated 4.5 quads of energy,
an amount DOE considers significant.
Under TSL 4, the NPV of consumer
benefit would be $5.3 billion using a
discount rate of 7 percent, and $12.6
billion using a discount rate of 3
percent.
The cumulative emissions reductions
at TSL 4 are 78.5 Mt of CO2, 19.7
thousand tons of SO2, 148.0 thousand
tons of NOX, 0.1 tons of Hg, 686.7
thousand tons of CH4, and 0.6 thousand
tons of N2O. The estimated monetary
value of the climate benefits from
reduced GHG emissions (associated
with the average SC–GHG at a 3-percent
discount rate) at TSL 4 is $4.4 billion.
The estimated monetary value of the
health benefits from reduced SO2 and
NOX emissions at TSL 4 is $3.1 billion
using a 7-percent discount rate and $8.2
billion using a 3-percent discount rate.
Using a 7-percent discount rate for
consumer benefits and costs, health
benefits from reduced SO2 and NOX
emissions, and the 3-percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
total NPV at TSL 4 is $12.8 billion.
Using a 3-percent discount rate for all
benefits and costs, the estimated total
NPV at TSL 4 is $25.2 billion. The
estimated total NPV is provided for
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additional information, however DOE
primarily relies upon the NPV of
consumer benefits when determining
whether a proposed standard level is
economically justified.
At TSL 4, for the largest equipment
classes, which are represented by ACF1,
ACF2, and ACF3—which together
represent approximately 99 percent of
annual shipments—there is a life-cycle
cost savings of $327, $478, and $668
and a payback period of 0.5 years, 0.2
years, and 0.1 years, respectively. For
these equipment classes, the fraction of
customers experiencing a net LCC cost
is 0.2 percent, 0 percent, and 0 percent
due to increases in total installed cost of
$16, $14, and $15, respectively. For the
remaining equipment class (ACF4), the
considered TSL would not set any
energy conservation standards.
At TSL 4, the projected change in
INPV ranges from a decrease of $71
million to an increase of less than $0.1
million, which correspond to a decrease
of 10.9 percent and an increase of less
than 0.1 percent, respectively. DOE
estimates that industry must invest
$118.1 million to implement the second
highest tier of aerodynamic redesign for
axial ACFs to comply with standards set
at TSL 4. An investment of $118.1
million in conversion costs represents
approximately 50 percent of the sum of
the annual free cash flows over the years
between the estimated final rule
announcement date and the estimated
standards year (i.e., the time period that
these conversion costs would be
incurred) and represents over 18 percent
of the entire no-new-standards case
INPV over the 30-year analysis
period.135
In the no-new-standards case, free
cash flow is estimated to be $51 million
in 2029, the year before the modeled
compliance date. At TSL 4, the
estimated free cash flow is $1 million in
2029. This represents a decrease in free
cash flow of 99.0 percent, or a decrease
of $50.2 million, in 2029. Annual cash
flows remain positive for all years
leading up to the modeled compliance
date. At TSL 4, models representing 36
percent of all ACF shipments are
estimated to meet or exceed the
efficiency requirements at this TSL in
the no-new-standards case by 2030, the
modeled compliance year. Therefore,
models representing 64 percent of all
ACF shipments will need to be
remodeled in the 5-year compliance
period. DOE estimates that while this
represents a significant redesign effort,
most ACF manufacturers will have the
engineering capacity to complete these
redesigns in a 5-year compliance period.
After considering the analysis and
weighing the benefits and burdens, the
Secretary has tentatively concluded that
at a standard set at TSL 4 for ACFs
would be economically justified. While
DOE recognizes that TSL 4 is not the
TSL that maximizes net monetized
benefits, DOE has weighed other nonquantified and non-monetized factors in
accordance with EPCA in reaching this
determination. At this TSL, the average
LCC savings for all ACF consumers are
positive. An estimated 0.1 percent of
consumers experience a net cost. The
FFC national energy savings are
significant and the NPV of consumer
benefits is positive using both a 3percent and 7-percent discount rate.
Notably, the benefits to consumers
vastly outweigh the cost to
manufacturers. At TSL 4, the NPV of
consumer benefits, even measured at the
more conservative discount rate of 7
percent is over 74 times higher than the
maximum estimated manufacturers’ loss
in INPV. The standard levels at TSL 4
are economically justified even without
weighing the estimated monetary value
of emissions reductions. When those
emissions reductions are included—
representing $4.4 billion in climate
benefits (associated with the average
SC–GHG at a 3-percent discount rate),
and $8.2 billion (using a 3-percent
discount rate) or $3.1 billion (using a 7percent discount rate) in health
benefits—the rationale for setting
standards at TSL 4 for ACFs is further
strengthened. Additionally, the impact
to manufacturers is significantly
reduced at TSL 4. While manufacturers
have to invest $118.1 million to comply
with standards at TSL 4, annual free
cash flows remain positive for all years
leading up to the compliance date.
Lastly, DOE estimates that most ACF
manufacturers will have the engineering
capacity to complete these redesigns in
a 5-year compliance period.
As stated, DOE conducts the walkdown analysis to determine the TSL that
represents the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified as required under
EPCA. The walk-down is not a
comparative analysis, as a comparative
analysis would result in the
maximization of net benefits instead of
energy savings that are technologically
feasible and economically justified,
which would be contrary to the statute.
86 FR 70892, 70908. Although DOE has
not conducted a comparative analysis to
135 The sum of annual free cash flows is estimated
to be $227 million for 2025–2029 in the no-new-
standards case and the no-new-standards case INPV
is estimated to be $649 million.
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select the proposed energy conservation
standards, DOE notes that as compared
to TSL 5 and TSL 6, TSL 4 has higher
average LCC savings, significantly
smaller percentages of GFBs consumers
experiencing a net cost, a lower simple
payback period, a lower maximum
decrease in INPV, lower manufacturer
conversion costs, and significantly less
likelihood of a major disruption to the
ACF market, as DOE does not anticipate
gaps in ACF equipment offerings at TSL
4.
Although DOE considered proposed
new standard levels for ACFs by
grouping the efficiency levels for each
equipment class into TSLs, DOE
evaluates all analyzed efficiency levels
in its analysis. For all equipment
classes, TSL 4 represents the maximum
energy savings that does not result in
significant negative economic impacts
to ACF manufacturers. At TSL 4
conversion costs are estimated to be
$118.1 million, significantly less than at
TSL 5 ($1,043 million) and at TSL 6
($1,167 million). At TSL 4 conversion
costs represent a significantly smaller
size of the sum of ACF manufacturers’
annual free cash flows for 2025 to 2029
(50 percent), than at TSL 5 (450 percent)
and at TSL 6 (500 percent) and a
significantly smaller portion of ACF
manufacturers’ no-new-standards case
INPV (18 percent), than at TSL 5 (161
percent) and at TSL 6 (180 percent). At
TSL 4, ACF manufacturers will have to
redesign a significantly smaller portion
of their ACF models to meet the ELs set
at TSL 4 (models representing 64
percent of all ACF shipments), than at
TSL 5 (96 percent) and at TSL 6 (99
percent). Lastly, ACF manufacturers’
free cash flow remains positive at TSL
4 for all years leading up to the
compliance date. Whereas at TSL 5
annual free cash flow is estimated to be
¥$400 million and at TSL 6 annual free
cash flow is estimated to be ¥$456
million in 2029, the year before the
modeled compliance year. The ELs at
the proposed TSL result in average
positive LCC savings for all equipment
classes, significantly reduce the number
of consumers experiencing a net cost,
and reduce the decrease in INPV and
conversion costs to the point where
DOE has concluded they are
economically justified, as discussed for
TSL 4 in the preceding paragraphs.
Therefore, based on the previous
considerations, DOE proposes to adopt
the energy conservation standards for
ACFs at TSL 4. The proposed new
energy conservation standards for ACFs,
E:\FR\FM\19JAP2.SGM
19JAP2
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3851
which are expressed as efficacy in CFM/
W, are shown in Table V–70.
BILLING CODE 6450–01–P
Table V-70 Proposed New Enen?:v Conservation Standards for ACFs
Efficacy
(CFM/W)
12.2
17.3
21.5
NIA
Equipment Class *
Axial ACFs; 12" ~ D < 36"
Axial ACFs; 36" ~ D < 48"
Axial ACFs; 48" ~ D
Housed Centrifugal ACFs
*D: diameter m mches
NIA means not applicable as DOE is not proposing to set a standard for this equipment class.
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quantitative impacts estimated for each
TSL for GFBs and ACFs are discussed
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in sections V.C.1.a and V.C.1.b and of
this document.
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ddrumheller on DSK120RN23PROD with PROPOSALS2
Table V–71 summarizes the
quantitative impacts estimated at the
proposed TSLs for GFBs and ACFs. The
3852
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-71 Summary of Cumulative Monetized Benefits and Costs of Proposed
Ener2V Conservation Standards for GFBs and ACFs (TSL 4)
Million 2022$/year
Primary
Estimate
Low-NetBenefits
Estimate
High-NetBenefits
Estimate
3% discount rate
Consumer Operating Cost Savings
55.8
52.0
59.5
Climate Benefits*
16.3
15.7
16.9
Health Benefits**
31.6
30.4
32.9
Total Benefitsi"
103.7
98.0
109.4
Consumer Incremental Equipment
Costs:t
6.3
8.1
4.7
Net Benefits
97.4
89.9
104.7
(0.5) - 0
(0.5) - 0
(0.5) - 0
Change in Producer Cashflow
ONPV:t:t)
7% discount rate
Consumer Operating Cost Savings
22.2
20.8
23.5
Climate Benefits* (3% discount rate)
16.3
15.7
16.9
Health Benefits**
11.4
11.0
11.8
Total Benefitsi"
49.8
47.4
52.2
3.2
3.9
2.5
46.6
43.5
49.8
(0.5) - 0
(0.5) - 0
(0.5) - 0
Consumer Incremental Equipment
Costs:t
Net Benefits
Note: This table presents the costs and benefits associated with GFBs and ACFs shipped in 2030-2059.
These results include consumer, climate, and health benefits that accrue after 2059 from the products
shipped in 2030-2059. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize
projections of energy prices from the A F:02023 Reference case, Low Economic Growth case, and High
Economic Growth case, respectively. In addition, incremental equipment costs reflect a constant rate in the
Primary Estimate, an increasing rate in the Low Net Benefits Estimate, and a declining rate in the High Net
Benefits Estimate for GFBs, and a low declining rate in the Primary Estimate, an increasing rate in the Low
Nel Benefits Estimale, and a high declining rale in U1e High Nel Benefils Eslimale for ACFs. The meU10ds
used to derive projected price trends are explained in sections IV.F .1 and IV.H.3 of this document. Note
that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3 percent discount rate are shown, but DOE does not have a single central SC-GHG point
estimate, and it emphasizes the importance and value of considering the benefits calculated using all four
sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the
interim estimates presented in the Technical Support Document: Social Cost of Carbon, Afethane, and
Nitrous Oxide Interim Estimates Under Executive Order 13990, published in Februaiy 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to moneti7.e other effects such as health benefits from
reductions in direct PM2.5 emissions. See section IV.L of this document for more details.
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Change in Producer Cashflow
ONPV:1::1:)
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3853
t Total benefits for both the 3 percent and 7 percent cases are presented using the average SC-GHG with a
3 percent discount rate, but DOE does not have a single central SC-GHG point estimate.
l Costs include incremental equipment costs as well as installation costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.H. DOE's NIA includes all impacts (both costs and
benefits) along the distribution chain beginning with the increased costs to the manufacturer to manufacture
the equipment and ending with the increase in price experienced by the consumer. DOE also separately
conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J. In the detailed
MIA, DOE models manufacturers' pricing decisions based on assumptions regarding investments,
conversion costs, cashflow, and margins. The MIA produces a range of impacts, which is the rule's
expected impact on the INPV. The change in INPV is the present value of all changes in industry cash
flow, including changes in production costs, capital expenditures, and manufacturer profit margins. Change
in INPV is calculated using the industry weighted average cost of capital value of 11.4 percent that is
estimated in the MIA (see chapter 12 of the NOPR TSD for a complete description of the industry weighted
average cost of capital). For GFB & ACF, those values are -$526 million and $1 million. DOE accounts
for that range of likely impacts in analyzing whether a TSL is economically justified. See section V.C.
DOE is presenting the range of impacts to the INPV under two markup scenarios: the Conversion Cost
Recovery scenario, which is the manufacturer markup scenario where manufacturers increase their markups
in response to changes in energy conservation standards, and the Preservation of Operating Profit scenario,
where DOE assumed manufacturers would not be able to increase per-unit operating profit in proportion to
increases in manufacturer production costs. DOE includes the range of estimated INPV in the above table,
drawing on the MIA explained further in Section IV.J, to provide additional context for assessing the
estimated impacts of this rule to society, including potential changes in production and consumption, which
is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include the INPV into the net
benefit calculation for this proposed rule, the net benefits would range from $96.9 billion to $97.4 billion at
3-percent discount rate and would range from $46.1 billion to $46.6 billion at 7-percent discount rate.
Parentheses indicate negative values.
ddrumheller on DSK120RN23PROD with PROPOSALS2
This section presents the combined
results for GFBs and ACFs. Specific
results for GFBs and ACFs are also
discussed in section V.C.2.a and
V.C.2.b, respectively.
The benefits and costs of the proposed
standards can also be expressed in terms
of annualized values. The annualized
net benefit is (1) the annualized national
economic value (expressed in 2022
dollars) of the benefits from operating
products that meet the proposed
standards (consisting primarily of
operating cost savings from using less
energy, minus increases in product
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purchase costs, and (2) the annualized
monetary value of the climate and
health benefits from emission
reductions.
Table V–72 shows the annualized
values for GFBs and ACFs under TSL 4,
expressed in 2022 dollars. The results
under the primary estimate are as
follows.
Using a 7 percent discount rate for
consumer benefits and costs and health
benefits from reduced NOX and SO2
emissions, and the 3 percent discount
rate case for climate benefits from
reduced GHG emissions, the estimated
cost of the standards proposed in this
rule is $360 million per year in
increased equipment costs, while the
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estimated annual benefits are $2,506
million in reduced equipment operating
costs, $963 million in monetized
climate benefits, and $1,285 million in
monetized health benefits. In this case,
the monetized net benefit would
amount to $4,394 million per year.
Using a 3 percent discount rate for all
benefits and costs, the estimated cost of
the proposed standards is $374 million
per year in increased equipment costs,
while the estimated annual benefits are
$3,302 million in reduced operating
costs, $963 million in monetized
climate benefits, and $1,869 million in
monetized health benefits. In this case,
the monetized net benefit would
amount to $5,760 million per year.
E:\FR\FM\19JAP2.SGM
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EP19JA24.119
2. Annualized Benefits and Costs of the
Proposed Standards
3854
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-72 Annualized Monetized Benefits and Costs of Proposed Energy
Conservation Standards for GFBs and ACFs (TSL 4)
Million 2022$/year
Low-NetBenefits
Estimate
High-NetBenefits
Estimate
3,302
3,074
3,521
Climate Benefits*
963
926
1,002
Health Benefits**
1,869
1,796
1,945
Total Benefitsi"
6,134
5,796
6,469
374
478
276
5,760
5,317
6,192
(62) - 0
(62) - 0
(62) - 0
2,506
2,346
2,658
963
926
1,002
Health Benefits**
1,285
1,240
1,330
Total Benefitsi"
4,754
4,513
4,991
360
441
280
4,394
4,072
4,710
(62) - 0
(62) - 0
(62) - 0
Primary
Estimate
3% discount rate
Consumer Operating Cost Savings
Consumer Incremental Equipment
Costs:t
Net Benefits
Change in Producer Cashflow
ONPV:t:t)
7% discount rate
Consumer Operating Cost Savings
Climate Benefits* (3% discount rate)
Consumer Incremental Equipment
Costs:t
Net Benefits
Note: This table presents the costs and benefits associated with GFBs and ACFs shipped in 2030-2059.
These results include consumer, climate, and health benefits that accrue after 2059 from the products
shipped in 2030-2059. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize
projections of energy prices from the A F:02023 Reference case, Low Economic Growth case, and High
Economic Growth case, respectively. In addition, incremental equipment costs reflect a constant rate in the
Primary Estimate, an increasing rate in the Low Net Benefits Estimate, and a declining rate in the High Net
Benefits Estimate for GFBs, and a low declining rate in the Primary Estimate, an increasing rate in the Low
Nel Benefits Estimale, and a high declining rale in U1e High Nel Benefils Eslimale for ACFs. The melhods
used to derive projected price trends are explained in sections IV.F .1 and IV.H.3 of this document. Note
that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3 percent discount rate are shown, but DOE does not have a single central SC-GHG point
estimate, and it emphasizes the importance and value of considering the benefits calculated using all four
sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the
interim estimates presented in the Technical Support Document: Social Cost of Carbon, Afethane, and
Nitrous Oxide Interim Estimates Under Executive Order 13990, published in Februaiy 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to moneti7.e other effects such as health benefits from
reductions in direct PM2_5 emissions. See section IV.L of this document for more details.
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Change in Producer Cashflow
ONPV:1::1:)
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3855
t Total benefits for both the 3 percent and 7 percent cases are presented using the average SC-GHG with a
3 percent discount rate, but DOE does not have a single central SC-GHG point estimate.
l Costs include incremental equipment costs as well as installation costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.H. DOE's NIA includes all impacts (both costs and
benefits) along the distribution chain beginning with the increased costs to the manufacturer to manufacture
the equipment and ending with the increase in price experienced by the consumer. DOE also separately
conducts a detailed analysis on the impacts on manufacturers (the MIA). See section IV.J. In the detailed
MIA, DOE models manufacturers' pricing decisions based on assumptions regarding investments,
conversion costs, cashflow, and margins. The MIA produces a range of impacts, which is the rule's
expected impact on the INPV. The change in INPV is the present value of all changes in industry cash
flow, including changes in production costs, capital expenditures, and manufacturer profit margins. The
annualized change in INPV is calculated using the industry weighted average cost of capital value of 11.4
percent that is estimated in the MIA (see chapter 12 of the NOPR TSD for a complete description of the
industry weighted average cost of capital). For GFB & ACF, those values are -$62 million and less than
$0.1 million. DOE accounts for that range of likely impacts in analyzing whether a TSL is economically
justified. See section V. C. DOE is presenting the range of impacts to the INPV under two markup
scenarios: the Conversion Cost Recovery scenario, which is the manufacturer markup scenario where
manufacturers increase their markups in response to changes in energy conservation standards, and the
Preservation of Operating Profit Markup scenario, where DOE assumed manufacturers would not be able to
increase per-unit operating profit in proportion to increases in manufacturer production costs. DOE
includes the range of estimated annualized change in INPV in the above table, drawing on the MIA
explained further in section IV.J, to provide additional context for assessing the estimated impacts of this
rule to society, including potential changes in production and consumption, which is consistent with
OMB's Circular A-4 and E.O. 12866. IfDOE were to include the INPV into the annualized net benefit
calculation for this proposed rule, the annualized net benefits would range from $5,698 million to $5,760
million at 3-percent discount rate and would range from $4,332 million to $4,394 million at 7-percent
discount rate. Parentheses indicate negative values.
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Table V–73 shows the annualized
values for GFBs under TSL 4, expressed
in 2022 dollars. The results under the
primary estimate are as follows.
Using a 7-percent discount rate for
consumer benefits and costs and NOX
and SO2 reduction benefits, and a 3percent discount rate case for GHG
social costs, the estimated cost of the
proposed standards for GFBs is $329
million per year in increased equipment
costs, while the estimated annual
benefits are $1,880 million from
reduced equipment operating costs,
$703 million in climate benefits, and
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$932 million in health benefits. In this
case, the net benefit amounts to $3,185
million per year.
Using a 3-percent discount rate for all
benefits and costs, the estimated cost of
the proposed standards for GFBs is $340
million per year in increased equipment
costs, while the estimated annual
benefits are $2,524 million in reduced
operating costs, $703 million in
monetized climate benefits, and $1,384
million from in monetized health
benefits. In this case, the net benefit
amounts to $4,271 million per year.
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ddrumheller on DSK120RN23PROD with PROPOSALS2
a. General Fans and Blowers
The benefits and costs of the proposed
standards can also be expressed in terms
of annualized values. The annualized
net benefit is (1) the annualized national
economic value (expressed in 2022
dollars) of the benefits from operating
products that meet the proposed
standards (consisting primarily of
operating cost savings from using less
energy, minus increases in product
purchase costs, and (2) the annualized
monetary value of the climate and
health benefits from emission
reductions.
3856
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-73 Annualized Monetized Benefits and Costs of Proposed Energy
Conservation Standards for GFBs (TSL 4)
Million 2022$/year
Low-NetBenefits
Estimate
High-Net-Benefits
Estimate
2,524
2,321
2,724
Climate Benefits*
703
666
742
Health Benefits**
1,384
1,311
1,461
Total Monetized Benefitst
4,611
4,297
4,927
340
442
243
4,271
3,855
4,684
(53) - 0
(53) - 0
(53) - 0
1,880
1,739
2,017
Climate Benefits* (3% discount
rate)
703
666
742
Health Benefits**
932
888
978
3,515
3,293
3,736
329
409
251
3,185
2,884
3,486
(53) - 0
(53) - 0
(53) - 0
Primary
Estimate
3% discount rate
Consumer Operating Cost Savings
Consumer Incremental Equipment
Costst
Net Monetized Benefits
Change in Producer Cashflow (NPV:t:1:)
7% discount rate
Consumer Operating Cost Savings
Total Monetized Benefitst
Consumer Incremental Equipment
Costst
Net Monetized Benefits
Note: This table presents the costs and benefits associated with products shipped in 2030-2059. These
results include consumer, climate, and health benefits that accrue after 2059 from the products shipped in
2030-2059. The Primruy, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy
prices from theAEO2023 Reference case, Low Economic Growth case, and High Economic Growth case,
respectively. In addition, incremental equipment costs reflect. a constant price in the Primaty Estimate, an
increasing rate in the Low Net Benefits Estimate, and a declining rate in the High Net Benefits Estimate.
The methods used lo derive projected price trends are explained in sections IV.F.l and IV.H.3 oftlris
document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.M of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3-percent discount rate are shown, but DOE does not have a single central SC-GHG point
estimate, and it emphasizes the importance and value of considering the benefits calculated using all four
sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions this analysis uses the interim
estimates presented in the Technical Supp011Document: Social Cost ofCarbon, lvfethane, and Nitrous Oxide Interim
Estimates Under Executive Order 13990 published in February 2021 by the Interagency Working Group on the Social
Cost of Greenhouse Gases (IWG).
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2s precursor health benefits and (for NOx) ozone precursor health
benefits, but will continue to assess tl1e ability lo monetize otl1er effects such as health benefits from
reductions in direct PM2.5 enrissions. See section IV.M of this document for more details.
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Change in Producer Cashflow (NPV:t:I:)
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3857
t Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with a
3-percent discount rate, but DOE does not have a single central SC-GHG point estimate.
Costs include incremental equipment costs as well as installation costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.Hof this document. DOE's NIA includes all
impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
manufacturer to manufacture the equipment and ending with the increase in price experienced by the
consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA).
See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions
based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces
a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present
value of all changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. The annualized change in INPV is calculated using the industry weighted
average cost of capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD
for a complete description of the industry weighted average cost of capital). For GFB, those values are $53 million and less than $0.1 million. DOE accounts for that range of likely impacts in analyzing whether
a TSL is economically justified. See section V.C of this document. DOE is presenting the range of impacts
to the INPV under two markup scenarios: the Conversion Cost Recovery scenario, which is the
manufacturer markup scenario where manufacturer increase markups to account for changes in energy
conservation standards, and the Preservation of Operating Profit Markup scenario, where DOE assumed
manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the
above table, drawing on the MIA explained further in section IV.J of this document, to provide additional
context for assessing the estimated impacts of this rule to society, including potential changes in production
and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include
the INPV into the annualized net benefit calculation for this proposed rule, the annualized net benefits
would range from $4,218 million to $4,271 million at 3-percent discount rate and would range from $3,132
million to $3,185 million at 7-percent discount rate. Parentheses indicate negative values.
t
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Table V–74 shows the annualized
values for ACFs under TSL 4, expressed
in 2022 dollars. The results under the
primary estimate are as follows.
Using a 7-percent discount rate for
consumer benefits and costs and NOX
and SO2 reduction benefits, and a 3percent discount rate case for GHG
social costs, the estimated cost of the
proposed standards for ACFs is $31
million per year in increased equipment
costs, while the estimated annual
benefits are $626 million from reduced
equipment operating costs, $261 million
from GHG reductions, and $353 million
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from reduced NOX and SO2 emissions.
In this case, the net benefit amounts to
$1,209 million per year.
Using a 3-percent discount rate for all
benefits and costs, the estimated cost of
the proposed standards for ACFs is $34
million per year in increased equipment
costs, while the estimated annual
benefits are $778 million in reduced
operating costs, $261 million in
monetized climate benefits, and $485
million in monetized health benefits. In
this case, the net benefit amounts to
$1,489 million per year.
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ddrumheller on DSK120RN23PROD with PROPOSALS2
b. Air Circulating Fans
The benefits and costs of the proposed
standards can also be expressed in terms
of annualized values. The annualized
net benefit is (1) the annualized national
economic value (expressed in 2022
dollars) of the benefits from operating
products that meet the proposed
standards (consisting primarily of
operating cost savings from using less
energy, minus increases in product
purchase costs, and (2) the annualized
monetary value of the climate and
health benefits from emission
reductions.
3858
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table V-74 Annualized Monetized Benefits and Costs of Proposed Energy
Conservation Standards for ACFs (TSL 4)
Million 2022$/year
Primary
Estimate
Low-NetBenefits
Estimate
High-NetBenefits
Estimate
3% discount rate
Consumer Operating Cost Savings
778
753
796
Climate Benefits*
261
261
261
Health Benefits**
485
485
485
Total Monetized Benefitst
1,523
1,498
1,542
34
36
33
Net Monetized Benefits
1,489
1,462
1,509
Change in Producer Cashflow
(INPV:t:t)
(8)-0
(8)- 0
(8) - 0
Consumer Incremental Equipment
Costs:!:
7% discount rate
Consumer Operating Cost Savings
626
607
641
Climate Benefits* (3% discount
rate)
261
261
261
Health Benefits**
353
353
353
1,239
1,221
1,254
31
32
30
Net Monetized Benefits
1,209
1,188
1,225
Change in Producer Cashflow
(INPV:t:t)
(8)- 0
(8)- 0
(8) - 0
Total Monetized Benefitst
Note: This table presents the costs and benefits associated with products shipped in 2030-2059. These
results include consumer, climate, and health benefits that accrue after 2059 from the products shipped in
2030-2059. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy
prices from the AEO2023 Reference case, Low Economic Growth case, and High Economic Growth case,
respectively. In addition, incremental equipment costs reflect a low declining rate in the Primary Estimate,
an increasing rate in the Low Net Benefits Estimate, and a high declining rate in the High Net Benefits
Estimate. The methods used to derive projected price trends are explained in sections IV.F.1 and IV.HJ of
this document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.M of
this document). For presentational purposes of this table, the climate benefits associated with the average
SC-GHG at a 3-percent discount rate are shown, but DOE does not have a single central SC-GHG point
estimate. and it emphasizes the importance and value of considering the benefits calculated using all four
sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the
interim estimates presented in the Technical Support Document: Social Cost of Carbon, Afethane, and
Nitrous Oxide Interim Estimates Under Executive Order 13990 published in Febmary 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOx and SO2. DOE is currently only
monetizing (for SO2 and NOx) PM2s precursor healtl1 benefits and (for NOx) ozone precursor health
benefits, but will continue to assess the ability to monetize other effects such as health benefits from
reductions in direct PM2.5 emissions. See section IV.M of this document for more details.
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Consumer Incremental Equipment
Costst
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3859
BILLING CODE 6450–01–C
D. Reporting, Certification, and
Sampling Plan
Manufacturers, including importers,
must use equipment-specific
certification templates to certify
compliance to DOE. For fans and
blowers, the certification template
reflects the general certification
requirements specified at 10 CFR 429.12
and the product-specific requirements
specified at 10 CFR 429.69. DOE is not
proposing to amend the product-specific
certification requirements for this
equipment. DOE may consider
certification reporting requirements for
GFBs in a separate rulemaking.
E. Representations and Enforcement
Provisions
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1. Representations for General Fans and
Blowers
In the May 2023 TP Final Rule, DOE
summarized stakeholder comments
related to FEI representations at
compliant and non-compliant duty
points. DOE stated that it was not
establishing energy conservation
standards for fans and blowers and
therefore, the May 2023 TP final rule
would not result in any compliant or
non-compliant operating points. DOE
further stated that it would consider
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representations and any issues related to
compliance with any potential energy
conservation standard in a separate
energy conservation standards
rulemaking. 88 FR 27312, 27369.
In response to the October 2022
NODA, the CA IOUs recommended that
DOE consider allowing representations
at all duty points for fans designed for
low-pressure, space-constrained
applications. (CA IOUs, No. 127 at pp.
6–7) The CA IOUs stated that for a lowpressure application fan to meet an
energy conservation standard, a
consumer would have to either increase
the diameter of the fan, which would
result in a costly redesign of the system,
or the consumer would have to replace
the non-compliant fan with a compliant
fan of the same diameter running at a
higher pressure, which could result in
greater power consumption of the
system. Id. Furthermore, the CA IOUs
encouraged DOE to discuss the issue of
whether to allow the publication of noncompliant, low-pressure duty points
with manufacturers. Id.
Damas and Boldt commented that
they disagree with DOE’s proposal to
restrict the publication of fan and
blower performance data at duty points
that do not comply with a proposed
energy conservation standard and
recommended that DOE instead require
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that any non-compliant duty points be
highlighted. (Damas and Boldt, No. 131
at pp. 1, 5) They provided several
example scenarios where a fan may be
selected for use that is outside its
compliant range: space-constrained lowflow high-pressure applications, spaceconstrained low-pressure applications,
retrofitted systems, VAV systems that
require operation over a wide range of
duty points, systems with pressure
consuming elements that may vary in
their pressure consumption such that a
fan must be selected for a worst case
scenario instead of an average use
scenario, and situations where the
system that a fan is operating in
changes. (Damas and Boldt, No. 131 at
pp. 2–4) Furthermore, Damas and Boldt
commented that they are concerned that
designers may artificially increase the
pressure consumption of a system by
closing dampers to allow the fan to
operate at a compliant duty point,
which could ultimately increase energy
consumption. (Damas and Boldt, No.
131 at pp. 3–4) Additionally, Damas and
Boldt stated that there may be safety
issues when a fan operates near its
highest efficiency duty point, which is
often near the unstable region of a fan.
(Damas and Boldt, No. 131 at p. 4)
Damas and Boldt commented that
system engineers need full fan
E:\FR\FM\19JAP2.SGM
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t Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with a
3-percent discount rate, but DOE does not have a single central SC-GHG point estimate.
t Costs include incremental equipment costs.
U Operating Cost Savings are calculated based on the life cycle costs analysis and national impact analysis
as discussed in detail below. See sections IV.F and IV.Hof this document. DOE's NIA includes all
impacts (both costs and benefits) along the distribution chain beginning with the increased costs to the
manufacturer to manufacture the equipment and ending with the increase in price experienced by the
consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers (the MIA).
See section IV.J of this document. In the detailed MIA, DOE models manufacturers' pricing decisions
based on assumptions regarding investments, conversion costs, cashflow, and margins. The MIA produces
a range of impacts, which is the rule's expected impact on the INPV. The change in INPV is the present
value of all changes in industry cash flow, including changes in production costs, capital expenditures, and
manufacturer profit margins. The annualized change in INPV is calculated using the industry weighted
average cost of capital value of 11.4 percent that is estimated in the MIA (see chapter 12 of the NOPR TSD
for a complete description of the industry weighted average cost of capital). For ACF, those values are -$8
million and no annualized change in INPV. DOE accounts for that range of likely impacts in analyzing
whether a TSL is economically justified. See section V.C. DOE is presenting the range of impacts to the
INPV under two markup scenarios: the Conversion Cost Recovery scenario, which is the manufacturer
markup scenario where manufacturers increase their markups in response to changes in energy
conservation standards, and the Preservation of Operating Profit Markup scenario, where DOE assumed
manufacturers would not be able to increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated annualized change in INPV in the
above table, drawing on the MIA explained further in section IV.J of this document, to provide additional
context for assessing the estimated impacts of this rule to society, including potential changes in production
and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866. IfDOE were to include
the INPV into the annualized net benefit calculation for this proposed rule, the annualized net benefits
would range from $1,481 million to $1,489 million at 3-percent discount rate and would range from $1,201
million to $1,209 million at 7-percent discount rate. Parentheses indicate negative values.
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
performance data to ensure that a
system design does not push the fan
into its unstable operating region. Id.
As discussed in detail in section
IV.C.1, DOE evaluated improved
efficiency options while maintaining
constant diameter and duty point (i.e.,
air flow and operating pressures
remained constant as efficiency
increased); therefore, DOE has
tentatively concluded that a compliant
fan of the same equipment class,
diameter, and duty point would be
available.
As discussed in section III.C.1 of this
document, the FEI metric is evaluated at
each duty point as specified by the
manufacturer as required by the DOE
test procedure. If adopted, the proposed
energy conservation standards would
have to be met at each duty point at
which the fan is sold.
Consistent with stakeholder feedback
from the CA IOUs and Damas and Boldt,
DOE recognizes that not allowing
representations of a fan’s entire
performance map could result in
increased energy consumption or
potential unintended consequences.
Therefore, DOE proposes that a
manufacturer could make
representations at non-compliant duty
points provided representations include
a disclaimer; however, the manufacturer
would be responsible for ensuring that
the fan is not sold and selected at the
non-compliant duty points. To ensure
this, a manufacturer could, for example:
(1) choose to make representations of
non-compliant duty points and identify
those duty points as non-compliant, but
would need to know the duty point(s)
for which the fan was selected and sold;
or (2) choose to only make
representations at compliant duty points
in the case where the manufacturer does
not know the duty point(s) for which
the fan is selected and sold.
In accordance with 42 U.S.C. 6295(r),
energy conservation standards may
include any requirement which the
Secretary determines is necessary to
assure that each covered product to
which such standard applies meets the
required minimum level of energy
efficiency. As such, to assure that each
GFB to which the proposed standard
would apply meets the required FEI
specified in such standard, and in
accordance with 42 U.S.C. 6295(r), DOE
proposes to additionally require that all
representations at non-compliant duty
points would be (1) identified by the
following disclaimer: ‘‘Sale at these
duty points violates Department of
Energy Regulations under EPCA’’ in all
capital letters, red, and bold font; and
(2) grayed out in any graphs or tables in
which they are included.
2. Enforcement Provisions for General
Fans and Blowers
Subpart C of 10 CFR part 429
establishes enforcement provisions
applicable to covered products and
covered equipment, including fans and
blowers. General enforcement
provisions are established in 10 CFR
429.110. Various provisions in 10 CFR
429.110 specify when DOE may test for
enforcement, how DOE will obtain units
for enforcement testing, where selected
units will be tested, and how DOE will
determine basic model compliance, both
in general and for specific products and
equipment. DOE is proposing to add
specific enforcement testing provisions
for GFBs at 10 CFR 429.110(e).
As previously stated, the FEI metric
would be evaluated at each duty point
as specified by the manufacturer and, if
adopted, the proposed energy
conservation standards would have to
be met at each duty point at which the
fan is sold. Therefore, while DOE
requires GFBs to follow the basic model
structure outlined in the May 2023 TP
Final Rule, DOE proposes that GFB
compliance will be determined by duty
point offered for sale. In other words, if
DOE finds that one or more duty
point(s) certified as compliant by a
manufacturer is not compliant with
proposed energy conservation
standards, if adopted, the basic model
would be considered non-compliant.
Pursuant to 10.CFR 429.104, DOE
may, at any time, test a basic model to
assess whether the basic model is in
compliance with the applicable energy
conservation standard(s). If DOE has
reason to believe that a basic model is
not in compliance it may test for
enforcement pursuant to 10 CFR
429.110. To verify compliance of GFBs,
DOE proposes to add the following
enforcement testing approach at 10 CFR
429.110(e).
When conducting assessment and
enforcement testing, DOE proposes to
test each basic model according to the
DOE test procedure, using the test
method specified by the manufacturer
submitted in their certification report
(i.e., based on section 6.1, 6.2, 6.3 or 6.4
of AMCA 214–21) pursuant to 10 CFR
429.69. When conducting enforcement
testing, DOE proposes that it may
choose to test either one fan at multiple
duty points or multiple fans at one or
more duty points to evaluate
compliance of a certified basic model at
each certified duty point.
a. Testing a Single Fan at Multiple Duty
Points
When testing a single fan at multiple
duty points, DOE proposes to first
determine either bhp or FEP, dependent
on the test method specified by the
manufacturer, for the range of certified
airflow, pressure, and speed (duty
points) according to appendix A of
subpart J to 10 CFR part 431. DOE
acknowledges that it may not be feasible
to exactly replicate the measurements at
the certified duty points, or within the
certified range of duty points; therefore,
DOE will verify that, at a given speed,
the airflow at which the test is being
conducted is within 5-percent of the
certified airflow and the pressure is
within between P × (1¥0.05)2 and
where P is the certified static or total
pressure. If DOE is unable to verify
some or all certified duty points (i.e., the
fan is unable to perform at airflows and
pressures at a given speed that are
within the prescribed margin of the
certified airflows and pressures), the
certified rating cannot be used to
determine compliance. DOE will
consider the certified rating to be
invalid and DOE will rely on the
measured duty point (i.e., measured
flow and pressure at the given speed) to
determine compliance. If DOE is able to
verify the certified duty points (i.e., DOE
is able to test the fan at airflows and
pressures at a given speed that are
within the prescribed margin of the
certified airflows and pressures), DOE
will convert the tested bhp or FEP at the
tested airflow to the certified airflow
and use the converted bhp or FEP
calculate the corresponding FEI at each
certified duty point, in accordance with
the DOE test procedure. To convert the
tested bhp or FEP at the tested airflow
to the certified airflow DOE will use the
following equations:
For fan shaft power:
Converted bhp = tested bhp x (certified duty point airflow) 3
tested duty point air[ low
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3860
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
3861
For fan electrical power:
Converted FEP = tested FEP x (certified duty point airflow) 3
tested duty point airflow
b. Testing Multiple Fans at One or
Several Duty Points
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If the FEI calculated at a certified or
measured duty point is less than the
minimum required FEI, DOE may make
a determination of noncompliance
based on that single test or may select
no more than three additional units of
a certified basic model for testing. For
each of the units tested, if the duty point
can be verified, DOE proposes to then
follow the approach described in the
preceding paragraph, to determine the
converted FEP or bhp and the associated
FEI at certified duty point(s). Similarly,
DOE proposes to determine compliance
at each duty point using the average FEI
for each certified duty point. If the duty
point(s) cannot be verified, DOE
proposes to use the same approach as in
the sampling provisions (see 10 CFR
429.69) to determine the average FEP or
bhp and the associated average FEI at
measured duty point(s).
3. Enforcement Provisions for Air
Circulating Fans
For air circulating fans, DOE proposes
to follow the general enforcement
testing provisions at 10 CFR 429.110.
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VI. Procedural Issues and Regulatory
Review
A. Review Under Executive Orders
12866, 13563, and 14094
Executive Order (‘‘E.O.’’) 12866,
‘‘Regulatory Planning and Review,’’ as
supplemented and reaffirmed by E.O.
13563, ‘‘Improving Regulation and
Regulatory Review,’’ 76 FR 3821 (Jan.
21, 2011) and amended by E.O. 14094,
‘‘Modernizing Regulatory Review,’’ 88
FR 21879 (April 11, 2023), requires
agencies, to the extent permitted by law,
to (1) propose or adopt a regulation only
upon a reasoned determination that its
benefits justify its costs (recognizing
that some benefits and costs are difficult
to quantify); (2) tailor regulations to
impose the least burden on society,
consistent with obtaining regulatory
objectives, taking into account, among
other things, and to the extent
practicable, the costs of cumulative
regulations; (3) select, in choosing
among alternative regulatory
approaches, those approaches that
maximize net benefits (including
potential economic, environmental,
public health and safety, and other
advantages; distributive impacts; and
equity); (4) to the extent feasible, specify
performance objectives, rather than
specifying the behavior or manner of
compliance that regulated entities must
adopt; and (5) identify and assess
available alternatives to direct
regulation, including providing
economic incentives to encourage the
desired behavior, such as user fees or
marketable permits, or providing
information upon which choices can be
made by the public. DOE emphasizes as
well that E.O. 13563 requires agencies to
use the best available techniques to
quantify anticipated present and future
benefits and costs as accurately as
possible. In its guidance, the Office of
Information and Regulatory Affairs
(‘‘OIRA’’) in the Office of Management
and Budget (‘‘OMB’’) has emphasized
that such techniques may include
identifying changing future compliance
costs that might result from
technological innovation or anticipated
behavioral changes. For the reasons
stated in the preamble, this proposed
regulatory action is consistent with
these principles.
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Section 6(a) of E.O. 12866 also
requires agencies to submit ‘‘significant
regulatory actions’’ to OIRA for review.
OIRA has determined that this proposed
regulatory action constitutes a
‘‘significant regulatory action’’ within
the scope of section 3(f)(1) of E.O.
12866. Accordingly, pursuant to section
6(a)(3)(C) of E.O. 12866, DOE has
provided to OIRA an assessment,
including the underlying analysis, of
benefits and costs anticipated from the
proposed regulatory action, together
with, to the extent feasible, a
quantification of those costs; and an
assessment, including the underlying
analysis, of costs and benefits of
potentially effective and reasonably
feasible alternatives to the planned
regulation, and an explanation why the
planned regulatory action is preferable
to the identified potential alternatives.
These assessments are summarized in
this preamble and further detail can be
found in the technical support
document for this proposed rulemaking.
Finally, in accordance with 5 U.S.C.
553(b)(4), a summary of this proposed
rule may be found at
www.regulations.gov/docket/EERE2020-BT-STD-0007.
B. Review Under the Regulatory
Flexibility Act
The Regulatory Flexibility Act (5
U.S.C. 601 et seq.) requires preparation
of an initial regulatory flexibility
analysis (‘‘IRFA’’) for any rule that by
law must be proposed for public
comment, unless the agency certifies
that the rule, if promulgated, will not
have a significant economic impact on
a substantial number of small entities.
As required by E.O. 13272, ‘‘Proper
Consideration of Small Entities in
Agency Rulemaking,’’ 67 FR 53461
(Aug. 16, 2002), DOE published
procedures and policies on February 19,
2003, to ensure that the potential
impacts of its rules on small entities are
properly considered during the
rulemaking process. 68 FR 7990. DOE
has made its procedures and policies
available on the Office of the General
Counsel’s website (www.energy.gov/gc/
office-general-counsel). DOE has
prepared the following IRFA for the
industrial equipment that is the subject
of this rulemaking.
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DOE proposes that if the FEI
calculated at the certified or measured
duty point is greater than or equal to the
minimum required FEI, then testing
would be complete and DOE would
consider the certified duty point to be
compliant. If the FEI calculated at a
certified or measured duty point is less
than the minimum required FEI, DOE
may make a determination of
noncompliance based on that single test
or may select no more than three
additional identical model numbers and
evaluate (a) specific duty point(s)
according to the procedure just
described to further determine whether
(a) specific duty point(s) is/are
compliant based on the average FEI of
all units tested when multiple units are
tested.
DOE also proposes to add the
provisions related to the verification of
duty points at 10 CFR 429.134.
3862
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
1. Description of Reasons Why Action Is
Being Considered
EPCA authorizes DOE to regulate the
energy efficiency of a number of
consumer products and certain
industrial equipment. 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)) DOE
is undertaking this NOPR pursuant to its
obligations under EPCA to propose
standards for covered industrial
equipment.
2. Objectives of, and Legal Basis for,
Rule
DOE must follow specific statutory
criteria for prescribing new or amended
standards for covered equipment,
including fans and blowers. Any new or
amended standard for a covered product
must be designed to achieve the
maximum improvement in energy
efficiency that the Secretary of Energy
determines is technologically feasible
and economically justified. (42 U.S.C.
6295(o)(2)(A) and 42 U.S.C.
6295(o)(3)(B))
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3. Description on Estimated Number of
Small Entities Regulated
For manufacturers of fans and
blowers, the SBA has set a size
threshold, which defines those entities
classified as ‘‘small businesses’’ for the
purposes of the statute. DOE used the
SBA’s small business size standards to
determine whether any small entities
would be subject to the requirements of
the rule. (See 13 CFR part 121.) The size
standards are listed by North American
Industry Classification System
(‘‘NAICS’’) code and industry
description and are available at
www.sba.gov/document/support-tablesize-standards. Manufacturing of fans
and blowers is classified under NAICS
335220, ‘‘Industrial and Commercial
Fan and Blower and Air Purification
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18:59 Jan 18, 2024
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Equipment Manufacturing.’’ The SBA
sets a threshold of 500 employees or
fewer for an entity to be considered as
a small business for this category.
DOE conducted a focused inquiry of
the companies that could be small
businesses that manufacture fans and
blowers covered by this rulemaking.
DOE used data from the AMCA sales
database; from the BESS Labs database;
and from ENERGY STAR’s certified
product database to create a list of
companies that potentially sell fans and
blowers covered by this rulemaking.
Additionally, DOE received feedback
from interested parties in response to
previous stages of this rulemaking. DOE
contacted select companies on its list, as
necessary, to determine whether they
met the SBA’s definition of a fan and
blower small business. DOE screened
out companies that did not offer
equipment covered by this rulemaking,
did not meet the definition of a ‘‘small
business,’’ or are foreign owned and
operated.
Using these data sources, DOE
identified 91 manufacturers of fans and
blowers. DOE then referenced D&B
Hoovers reports,136 as well as the online
presence of identified businesses in
order to determine whether they might
the criteria of a small business. DOE
screened out companies that do not
offer products covered by this
rulemaking, do not meet the definition
of a ‘‘small business,’’ or are foreign
owned and operated. Additionally, DOE
filters out businesses that do not
directly produce fans and blowers, but
instead relabel fans and blowers or
integrate them into a different product.
From these sources, DOE identified 46
unique businesses manufacturing at
least one covered fan or blower product
family and that also fall under SBA’s
employee threshold for this rulemaking.
Of the 46 small businesses, 41
manufacture at least one model of a
136 D&B Hoovers reports require a subscription to
D&B Hoovers and can be accessed at:
app.dnbhoovers.com.
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covered GFB and 15 of these small
businesses additionally manufacture at
least one model of a covered ACF.
Lastly, there are five small businesses
that only manufacture ACF models (and
do not manufacture any GFB models).
DOE requests comment on the
number of small business OEMs
identified that manufacture fans and
blowers covered by this rulemaking.
4. Description and Estimate of
Compliance Requirements Including
Differences in Cost, if Any, for Different
Groups of Small Entities
In section IV.J.2.c of this NOPR, DOE
reviews the methodology used to
calculate conversion costs, this is
further elaborated in chapter 12 of the
NOPR TSD. DOE used the same
methodology to estimate per small
business conversion costs as with the
broader industry—developing estimates
of the number of product families for
each small business using their websites
and product catalogs. DOE was also able
to find revenue estimates for each small
business identified.
Across the identified small
businesses, DOE identified 457 covered
GFB product families and 97 ACF
product families. DOE evaluated how
many of each type for each small
business would be compliant with TSL
4 based on the shipments analysis
efficiency level estimates. Then, DOE
assumed that all non-compliant product
families would be redesigned and
calculated the appropriate conversion
costs. DOE estimates that the total cost
to all small businesses to redesign GFB
product families would be
approximately $233.0 million and to
redesign ACF would be an additional
$29.1 million. DOE provides estimates
of conversion costs for each small
business in the following tables for
small businesses that manufacture both
GFBs and ACFs, GFBs only, and ACFs
only.
BILLING CODE 6450–01–P
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
Table VI-1 Small Business Impacts for Manufacturers of both General Fans and
Blowers and Air Circulatin2 Fans
Small
Business 1
Small
Business 2
Small
Business 3
Small
Business 4
Small
Business 5
Small
Business 6
Small
Business 7
Small
Business 8
Small
Business 9
Small
Business 10
Small
Business 11
Small
Business 12
Small
Business 13
Small
Business 14
Small
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Business 15
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Conversion
Costs(% of
Compliance
-Period
Revenue)
(2022$)
GFB
Product
Family
Count
GFBNonCompliant
Product
Families
ACF
Product
Family
Count
ACF NonCompliant
Product
Families
$416,790
6
5
5
2
$8,978,604
430.8%
$4,490,000
53
22
2
0
$27,717,925
123.5%
$6,150,000
22
11
1
0
$12,855,803
41.8%
$12,460,000
27
12
5
2
$18,618,710
29.9%
$29,020,000
23
11
21
11
$24,414,048
16.8%
$3,180,000
7
3
4
0
$2,411,773
15.2%
$5,210,000
7
2
1
0
$2,945,394
11.3%
$11,390,000
13
6
1
0
$6,161,091
10.8%
$4,190,000
7
2
1
0
$1,607,849
7.7%
$33,470,000
13
7
13
5
$11,002,812
6.6%
$43,389,999
3
1
20
10
$9,548,291
4.4%
$103,000,00
0
32
20
2
0
$20,091,122
3.9%
$15,380,000
7
2
1
0
$1,607,849
2.1%
$63,950,000
6
2
4
2
$4,560,513
1.4%
$14,190,000
1
0
3
0
$0
0.0%
18:59 Jan 18, 2024
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Conversion
Costs
(2022$)
19JAP2
EP19JA24.128
Small
Business
Estimated
Annual
Revenue
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Table VI-2 Small Business Impacts - General Fans and Blowers Only
Small Business
Estimated
Annual
Revenue
Product
Family
Count
(2022$)
Small Business 1
Small Business 2
Small Business 3
Small Business 4
Small Business 5
Small Business 6
Small Business 7
Small Business 8
Small Business 9
Small Business 10
Small Business 11
Small Business 12
Small Business 13
Small Business 14
Small Business 15
Small Business 16
Small Business 17
Small Business 18
Small Business 19
Small Business 20
Small Business 21
Small Business 22
Small Business 23
Small Business 24
Small Business 25
Small Business 26
15
19
8
5
14
6
3
36
4
18
17
4
11
9
6
14
4
9
2
6
5
3
5
2
3
2
$990,000
$1200,000
$1 030 000
$1 530 000
$2 590 000
$590,000
$810,000
$18 860 000
$870,000
$12 400 000
$21010 000
$4 690 000
$16 630 000
$21880000
$10 560 000
$25 500 000
$9 360 000
$23 900 000
$6 660 000
$29 740 000
$25 620 000
$33 599 999
$17 870 000
$21 170 000
$7 910 000
$7 760 000
NonCompliant
Product
Families
10
11
4
3
9
2
1
18
1
10
9
1
6
4
3
6
2
5
1
2
2
2
1
1
0
0
Conversion
Costs
(2022$)
Conversion Costs
(% of CompliancePeriod Revenue)
$9,376,788
$8 843 167
$3 884 470
$4 418 091
$7 235 318
$1 607 849
$803 924
$18,483,273
$803 924
$8 039 243
$9 241 637
$1472 697
$4 823 546
$5 222 015
$2 411 773
$5492318
$1 607 849
$4 019 621
$803 924
$2 945 394
$1 607 849
$1 607 849
$803 924
$803 924
189.4%
147.4%
75.4%
57.8%
55.9%
54.5%
19.8%
19.6%
18.5%
13.0%
8.8%
6.3%
5.8%
4.8%
4.6%
4.3%
3.4%
3.4%
2.4%
2.0%
1.3%
1.0%
0.9%
0.8%
0.0%
0.0%
-
-
Tabl e VI 3 SmaIIB usmess I m 1act s- A"Ir c·1rcuIafm2 F ans 01
DIV
(2022$)
Small Business 1
Small Business 2
Small Business 3
Small Business 4
Small Business 5
$9.300.000
$2,290,000
$5.420.000
$5,050,000
$1.440.000
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BILLING CODE 6450–01–C
Costs as a percentage of revenue vary
significantly across the small
businesses. For small manufacturers
that make both GFBs and ACFs, median
costs as a percentage of revenue are 10.8
percent. For small manufacturers that
only make GFBs, median costs as a
percentage of revenue are 5.3 percent.
For small businesses that only make
ACFs, most small businesses are
expected to incur zero redesign costs,
the highest cost estimated represents 6.9
percent of the affected small business’
compliance period revenue. Small
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6
3
2
1
1
NonCompliant
Product
Families
4
0
0
0
0
Conversion
Costs
(2022$)
$3 230 237
businesses that experience high
conversion costs as a percentage of
revenue will likely need to seek outside
capital to finance redesign efforts and or
prioritize redesigning product families
based on sales volume.
DOE requests comment on the
estimated small business costs and how
those may differ from the costs incurred
by larger manufacturers.
5. Duplication, Overlap, and Conflict
With Other Rules and Regulations
DOE is not aware of any other rules
or regulations that duplicate, overlap, or
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Conversion Costs
(% of CompliancePeriod Revenue)
6.9%
0.0%
0.0%
0.0%
0.0%
-
conflict with the rule being considered
today.
6. Significant Alternatives to the Rule
The discussion in the previous
section analyzes impacts on small
businesses that would result from DOE’s
proposed rule, represented by TSL 4. In
reviewing alternatives to the proposed
rule, DOE examined energy
conservation standards set at lower
efficiency levels. While selecting TSLs
1, 2, or 3 would reduce the possible
impacts on small businesses, it would
come at the expense of a significant
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Family
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EP19JA24.129
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Annual
Revenue
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reduction in energy savings and
consumer NPV.
For GFBs, TSL 1 achieves 88 percent
lower energy savings and 90 percent
lower consumer net benefits compared
to the energy savings and consumer net
benefits at TSL 4. TSL 2 achieves 78
percent lower energy savings and 80
percent lower consumer net benefits
compared to the energy savings and
consumer net benefits at TSL 4. TSL 3
achieves 44 percent lower energy
savings and 49 percent lower consumer
net benefits compared to the energy
savings and consumer net benefits at
TSL 4.
For ACFs, TSL 1 achieves 98 percent
lower energy savings and 96 percent
lower consumer net benefits compared
to the energy savings and consumer net
benefits at TSL 4. TSL 2 achieves 96
percent lower energy savings and 94
percent lower consumer net benefits
compared to the energy savings and
consumer net benefits at TSL 4. TSL 3
achieves 73 percent lower energy
savings and 71 percent lower consumer
net benefits compared to the energy
savings and consumer net benefits at
TSL 4.
Based on the presented discussion,
establishing standards at TSL 4 for GFBs
and for ACFs balances the benefits of
the energy savings and consumer
benefits with the potential burdens
placed on manufacturers and small
businesses better than alternate standard
levels. Accordingly, DOE does not
propose one of the other TSLs
considered in the analysis, or the other
policy alternatives examined as part of
the regulatory impact analysis and
included in chapter 17 of the NOPR
TSD.
C. Review Under the Paperwork
Reduction Act
Under the procedures established by
the Paperwork Reduction Act of 1995
(‘‘PRA’’), a person is not required to
respond to a collection of information
by a Federal agency unless that
collection of information displays a
currently valid OMB Control Number.
OMB Control Number 1910–1400,
Compliance Statement Energy/Water
Conservation Standards for Appliances,
is currently valid and assigned to the
certification reporting requirements
applicable to covered equipment,
including fans and blowers.
DOE’s certification and compliance
activities ensure accurate and
comprehensive information about the
energy and water use characteristics of
covered products and covered
equipment sold in the United States.
Manufacturers of all covered products
and covered equipment must submit a
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certification report before a basic model
is distributed in commerce, annually
thereafter, and if the basic model is
redesigned in such a manner to increase
the consumption or decrease the
efficiency of the basic model such that
the certified rating is no longer
supported by the test data. Additionally,
manufacturers must report when
production of a basic model has ceased
and is no longer offered for sale as part
of the next annual certification report
following such cessation. DOE requires
the manufacturer of any covered
product or covered equipment to
establish, maintain, and retain the
records of certification reports, of the
underlying test data for all certification
testing, and of any other testing
conducted to satisfy the requirements of
part 429, part 430, and/or part 431.
Certification reports provide DOE and
consumers with comprehensive, up-todate efficiency information and support
effective enforcement.
Certification data would be required
for fans and blowers were this NOPR to
be finalized as proposed; however, DOE
is not proposing certification or
reporting requirements for fans and
blowers in this NOPR. Instead, DOE
may consider proposals to establish
certification requirements and reporting
for fans and blowers under a separate
rulemaking regarding appliance and
equipment certification. DOE will
address changes to OMB Control
Number 1910–1400 at that time, as
necessary.
Notwithstanding any other provision
of the law, no person is required to
respond to, nor shall any person be
subject to a penalty for failure to comply
with, a collection of information subject
to the requirements of the PRA, unless
that collection of information displays a
currently valid OMB Control Number.
D. Review Under the National
Environmental Policy Act of 1969
DOE is analyzing this proposed
regulation in accordance with the
National Environmental Policy Act of
1969 (‘‘NEPA’’) and DOE’s NEPA
implementing regulations (10 CFR part
1021). DOE’s regulations include a
categorical exclusion for rulemakings
that establish energy conservation
standards for consumer products or
industrial equipment. 10 CFR part 1021,
subpart D, appendix B5.1. DOE
anticipates that this rulemaking
qualifies for categorical exclusion B5.1
because it is a rulemaking that
establishes energy conservation
standards for consumer products or
industrial equipment, none of the
exceptions identified in categorical
exclusion B5.1(b) apply, no
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extraordinary circumstances exist that
require further environmental analysis,
and it otherwise meets the requirements
for application of a categorical
exclusion. See 10 CFR 1021.410. DOE
will complete its NEPA review before
issuing the final rule.
E. Review Under Executive Order 13132
E.O. 13132, ‘‘Federalism,’’ 64 FR
43255 (Aug. 10, 1999), imposes certain
requirements on Federal agencies
formulating and implementing policies
or regulations that preempt State law or
that have federalism implications. The
Executive order requires agencies to
examine the constitutional and statutory
authority supporting any action that
would limit the policymaking discretion
of the States and to carefully assess the
necessity for such actions. The
Executive order also requires agencies to
have an accountable process to ensure
meaningful and timely input by State
and local officials in the development of
regulatory policies that have federalism
implications. On March 14, 2000, DOE
published a statement of policy
describing the intergovernmental
consultation process it will follow in the
development of such regulations. 65 FR
13735. DOE has examined this proposed
rule and has tentatively determined that
it would not have a substantial direct
effect on the States, on the relationship
between the national government and
the States, or on the distribution of
power and responsibilities among the
various levels of government. EPCA
governs and prescribes Federal
preemption of State regulations as to
energy conservation for the equipment
that are the subject of this proposed
rule. States can petition DOE for
exemption from such preemption to the
extent, and based on criteria, set forth in
EPCA. (42 U.S.C. 6316(a) and (b); 42
U.S.C. 6297) Therefore, no further
action is required by Executive Order
13132.
F. Review Under Executive Order 12988
With respect to the review of existing
regulations and the promulgation of
new regulations, section 3(a) of E.O.
12988, ‘‘Civil Justice Reform,’’ imposes
on Federal agencies the general duty to
adhere to the following requirements:
(1) eliminate drafting errors and
ambiguity, (2) write regulations to
minimize litigation, (3) provide a clear
legal standard for affected conduct
rather than a general standard, and (4)
promote simplification and burden
reduction. 61 FR 4729 (Feb. 7, 1996).
Regarding the review required by
section 3(a), section 3(b) of E.O. 12988
specifically requires that Executive
agencies make every reasonable effort to
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ensure that the regulation: (1) clearly
specifies the preemptive effect, if any,
(2) clearly specifies any effect on
existing Federal law or regulation, (3)
provides a clear legal standard for
affected conduct while promoting
simplification and burden reduction, (4)
specifies the retroactive effect, if any, (5)
adequately defines key terms, and (6)
addresses other important issues
affecting clarity and general
draftsmanship under any guidelines
issued by the Attorney General. Section
3(c) of Executive Order 12988 requires
Executive agencies to review regulations
in light of applicable standards in
section 3(a) and section 3(b) to
determine whether they are met or it is
unreasonable to meet one or more of
them. DOE has completed the required
review and determined that, to the
extent permitted by law, this proposed
rule meets the relevant standards of E.O.
12988.
G. Review Under the Unfunded
Mandates Reform Act of 1995
Title II of the Unfunded Mandates
Reform Act of 1995 (‘‘UMRA’’) requires
each Federal agency to assess the effects
of Federal regulatory actions on State,
local, and Tribal governments and the
private sector. Public Law 104–4,
section 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely
to result in a rule that may cause the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
in any one year (adjusted annually for
inflation), section 202 of UMRA requires
a Federal agency to publish a written
statement that estimates the resulting
costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a), (b))
The UMRA also requires a Federal
agency to develop an effective process
to permit timely input by elected
officers of State, local, and Tribal
governments on a proposed ‘‘significant
intergovernmental mandate,’’ and
requires an agency plan for giving notice
and opportunity for timely input to
potentially affected small governments
before establishing any requirements
that might significantly or uniquely
affect them. On March 18, 1997, DOE
published a statement of policy on its
process for intergovernmental
consultation under UMRA. 62 FR
12820. DOE’s policy statement is also
available at www.energy.gov/sites/prod/
files/gcprod/documents/umra_97.pdf.
Although this proposed rule does not
contain a Federal intergovernmental
mandate, it may require expenditures of
$100 million or more in any one year by
the private sector. Such expenditures
may include: (1) investment in research
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and development and in capital
expenditures by fans and blowers
manufacturers in the years between the
final rule and the compliance date for
the new standards and (2) incremental
additional expenditures by consumers
to purchase higher-efficiency fans and
blowers, starting at the compliance date
for the applicable standard.
Section 202 of UMRA authorizes a
Federal agency to respond to the content
requirements of UMRA in any other
statement or analysis that accompanies
the proposed rule. (2 U.S.C. 1532(c))
The content requirements of section
202(b) of UMRA relevant to a private
sector mandate substantially overlap the
economic analysis requirements that
apply under section 325(o) of EPCA and
Executive Order 12866. This
SUPPLEMENTARY INFORMATION section of
this NOPR and the TSD for this
proposed rule respond to those
requirements.
Under section 205 of UMRA, the
Department is obligated to identify and
consider a reasonable number of
regulatory alternatives before
promulgating a rule for which a written
statement under section 202 is required.
(2 U.S.C. 1535(a)) DOE is required to
select from those alternatives the most
cost-effective and least burdensome
alternative that achieves the objectives
of the proposed rule unless DOE
publishes an explanation for doing
otherwise, or the selection of such an
alternative is inconsistent with law. As
required by 42 U.S.C 6316(a); 42 U.S.C.
6295(m), this proposed rule would
establish energy conservation standards
for fans and blowers that are designed
to achieve the maximum improvement
in energy efficiency that DOE has
determined to be both technologically
feasible and economically justified, as
required by 42 U.S.C 6316(a); 42 U.S.C.
6295(o)(2)(A) and (o)(3)(B). A full
discussion of the alternatives
considered by DOE is presented in
chapter 17 of the NOPR TSD for this
proposed rule.
H. Review Under the Treasury and
General Government Appropriations
Act, 1999
Section 654 of the Treasury and
General Government Appropriations
Act, 1999 (Pub. L. 105–277) requires
Federal agencies to issue a Family
Policymaking Assessment for any rule
that may affect family well-being. This
rule would not have any impact on the
autonomy or integrity of the family as
an institution. Accordingly, DOE has
concluded that it is not necessary to
prepare a Family Policymaking
Assessment.
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I. Review Under Executive Order 12630
Pursuant to E.O. 12630,
‘‘Governmental Actions and Interference
with Constitutionally Protected Property
Rights,’’ 53 FR 8859 (Mar. 15, 1988),
DOE has determined that this proposed
rule would not result in any takings that
might require compensation under the
Fifth Amendment to the U.S.
Constitution.
J. Review Under the Treasury and
General Government Appropriations
Act, 2001
Section 515 of the Treasury and
General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides
for Federal agencies to review most
disseminations of information to the
public under information quality
guidelines established by each agency
pursuant to general guidelines issued by
OMB. OMB’s guidelines were published
at 67 FR 8452 (Feb. 22, 2002), and
DOE’s guidelines were published at 67
FR 62446 (Oct. 7, 2002). Pursuant to
OMB Memorandum M–19–15,
Improving Implementation of the
Information Quality Act (April 24,
2019), DOE published updated
guidelines which are available at
www.energy.gov/sites/prod/files/2019/
12/f70/DOE%20Final%20Updated%20
IQA%20Guidelines%20
Dec%202019.pdf. DOE has reviewed
this NOPR under the OMB and DOE
guidelines and has concluded that it is
consistent with applicable policies in
those guidelines.
K. Review Under Executive Order 13211
E.O. 13211, ‘‘Actions Concerning
Regulations That Significantly Affect
Energy Supply, Distribution, or Use,’’ 66
FR 28355 (May 22, 2001), requires
Federal agencies to prepare and submit
to OIRA at OMB, a Statement of Energy
Effects for any proposed significant
energy action. A ‘‘significant energy
action’’ is defined as any action by an
agency that promulgates or is expected
to lead to promulgation of a final rule,
and that (1) is a significant regulatory
action under Executive Order 12866, or
any successor order; and (2) is likely to
have a significant adverse effect on the
supply, distribution, or use of energy, or
(3) is designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be implemented,
and of reasonable alternatives to the
action and their expected benefits on
energy supply, distribution, and use.
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DOE has tentatively concluded that
this regulatory action, which proposes
energy conservation standards for fans
and blowers, is not a significant energy
action because the proposed standards
are not likely to have a significant
adverse effect on the supply,
distribution, or use of energy, nor has it
been designated as such by the
Administrator at OIRA. Accordingly,
DOE has not prepared a Statement of
Energy Effects on this proposed rule.
ddrumheller on DSK120RN23PROD with PROPOSALS2
L. Information Quality
On December 16, 2004, OMB, in
consultation with the Office of Science
and Technology Policy (‘‘OSTP’’),
issued its Final Information Quality
Bulletin for Peer Review (‘‘the
Bulletin’’). 70 FR 2664 (Jan. 14, 2005).
The Bulletin establishes that certain
scientific information shall be peer
reviewed by qualified specialists before
it is disseminated by the Federal
Government, including influential
scientific information related to agency
regulatory actions. The purpose of the
bulletin is to enhance the quality and
credibility of the Government’s
scientific information. Under the
Bulletin, the energy conservation
standards rulemaking analyses are
‘‘influential scientific information,’’
which the Bulletin defines as ‘‘scientific
information the agency reasonably can
determine will have, or does have, a
clear and substantial impact on
important public policies or private
sector decisions.’’ 70 FR 2664, 2667.
In response to OMB’s Bulletin, DOE
conducted formal peer reviews of the
energy conservation standards
development process and the analyses
that are typically used and has prepared
a report describing that peer review.137
Generation of this report involved a
rigorous, formal, and documented
evaluation using objective criteria and
qualified and independent reviewers to
make a judgment as to the technical/
scientific/business merit, the actual or
anticipated results, and the productivity
and management effectiveness of
programs and/or projects. Because
available data, models, and
technological understanding have
changed since 2007, DOE has engaged
with the National Academy of Sciences
to review DOE’s analytical
methodologies to ascertain whether
modifications are needed to improve
137 The 2007 ‘‘Energy Conservation Standards
Rulemaking Peer Review Report’’ is available at the
following website: energy.gov/eere/buildings/
downloads/energy-conservation-standardsrulemaking-peer-review-report-0 (last accessed
December 5, 2023).
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DOE’s analyses. DOE is in the process
of evaluating the resulting report.138
M. Description of Materials
Incorporated by Reference
In this NOPR, DOE proposes to
incorporate by reference the following
test standards published by the IEC.
IEC 61800–9–2:2023 specifies test
methods to determine the efficiency of
motor controllers as well as the
efficiency of motor and motor controller
combinations. It also establishes
efficiency classifications for this
equipment.
IEC TS 60034–30–2:2016 establishes
efficiency classifications for motors
driven by motor controllers.
IEC TS 60034–31:2021 provides a
guideline of technical and economical
aspects for the application of energyefficient electric AC motors and
example calculations.
IEC 61800–9–2:2023, IEC TS 60034–
30–2:2016, and IEC TS 60034–31:2021
are available for purchase from the
International Electrotechnical
Committee (IEC), Central Office, 3, rue
de Varembe´, P.O. Box 131, CH–1211
GENEVA 20, Switzerland; + 41 22 919
02 11; webstore.iec.ch.
The following standards appear in the
amendatory text of this document and
have already been approved for the
locations in which they appear: AMCA
210–16, AMCA 214–21, and ISO
5801:2017.
VII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the
public meeting are listed in the DATES
and ADDRESSES sections at the beginning
of this document. If you plan to attend
the public meeting, please notify the
Appliance and Equipment Standards
staff at (202) 287–1445 or Appliance_
Standards_Public_Meetings@ee.doe.gov.
Please note that foreign nationals
visiting DOE Headquarters are subject to
advance security screening procedures
which require advance notice prior to
attendance at the public meeting. If a
foreign national wishes to participate in
the public meeting, please inform DOE
of this fact as soon as possible by
contacting Ms. Regina Washington at
(202) 586–1214 or by email
(Regina.Washington@ee.doe.gov) so that
the necessary procedures can be
completed.
DOE requires visitors to have laptops
and other devices, such as tablets,
checked upon entry into the Forrestal
138 The report is available at
www.nationalacademies.org/our-work/review-ofmethods-for-setting-building-and-equipmentperformance-standards.
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Building. Any person wishing to bring
these devices into the building will be
required to obtain a property pass.
Visitors should avoid bringing these
devices, or allow an extra 45 minutes to
check in. Please report to the visitor’s
desk to have devices checked before
proceeding through security.
Due to the REAL ID Act implemented
by the Department of Homeland
Security (‘‘DHS’’), there have been
recent changes regarding ID
requirements for individuals wishing to
enter Federal buildings from specific
States and U.S. territories. DHS
maintains an updated website
identifying the State and territory
driver’s licenses that currently are
acceptable for entry into DOE facilities
at www.dhs.gov/real-id-enforcementbrief. A driver’s license from a State or
territory identified as not compliant by
DHS will not be accepted for building
entry and one of the alternate forms of
ID listed below will be required.
Acceptable alternate forms of Photo-ID
include U.S. Passport or Passport Card;
an Enhanced Driver’s License or
Enhanced ID-Card issued by States and
territories as identified on the DHS
website (Enhanced licenses issued by
these States and territories are clearly
marked Enhanced or Enhanced Driver’s
License); a military ID or other Federal
government-issued Photo-ID card.
In addition, you can attend the public
meeting via webinar. Webinar
registration information, participant
instructions, and information about the
capabilities available to webinar
participants will be published on DOE’s
website at www1.eere.energy.gov/
buildings/appliance_standards/
standards.aspx?productid=51.
Participants are responsible for ensuring
their systems are compatible with the
webinar software.
B. Procedure for Submitting Prepared
General Statements for Distribution
Any person who has plans to present
a prepared general statement may
request that copies of his or her
statement be made available at the
public meeting. Such persons may
submit requests, along with an advance
electronic copy of their statement in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format, to the appropriate address
shown in the ADDRESSES section at the
beginning of this document. The request
and advance copy of statements must be
received at least one week before the
public meeting and are to be emailed.
Please include a telephone number to
enable DOE staff to make follow-up
contact, if needed.
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C. Conduct of the Public Meeting
D. Submission of Comments
DOE will designate a DOE official to
preside at the public meeting and may
also use a professional facilitator to aid
discussion. The meeting will not be a
judicial or evidentiary-type public
hearing, but DOE will conduct it in
accordance with section 336 of EPCA.
(42 U.S.C. 6306) A court reporter will be
present to record the proceedings and
prepare a transcript. DOE reserves the
right to schedule the order of
presentations and to establish the
procedures governing the conduct of the
public meeting. There shall not be
discussion of proprietary information,
costs or prices, market share, or other
commercial matters regulated by U.S.
anti-trust laws. After the public meeting,
interested parties may submit further
comments on the proceedings, as well
as on any aspect of the proposed
rulemaking, until the end of the
comment period.
The public meeting will be conducted
in an informal, conference style. DOE
will present a general overview of the
topics addressed in this proposed
rulemaking, allow time for prepared
general statements by participants, and
encourage all interested parties to share
their views on issues affecting this
proposed rulemaking. Each participant
will be allowed to make a general
statement (within time limits
determined by DOE), before the
discussion of specific topics. DOE will
allow, as time permits, other
participants to comment briefly on any
general statements.
At the end of all prepared statements
on a topic, DOE will permit participants
to clarify their statements briefly.
Participants should be prepared to
answer questions by DOE and by other
participants concerning these issues.
DOE representatives may also ask
questions of participants concerning
other matters relevant to this
rulemaking. The official conducting the
public meeting will accept additional
comments or questions from those
attending, as time permits. The
presiding official will announce any
further procedural rules or modification
of the previous procedures that may be
needed for the proper conduct of the
public meeting.
A transcript of the public meeting will
be included in the docket, which can be
viewed as described in the Docket
section at the beginning of this
document and will be accessible on the
DOE website. In addition, any person
may buy a copy of the transcript from
the transcribing reporter.
DOE will accept comments, data, and
information regarding this proposed
rule before or after the public meeting,
but no later than the date provided in
the DATES section at the beginning of
this proposed rule. 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
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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 of 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. DOE
will make its own determination about
the confidential 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
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ddrumheller on DSK120RN23PROD with PROPOSALS2
information deemed to be exempt from
public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments
on any aspect of this proposal, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
(1) DOE requests comment on its
proposed clarification for fans that
create a vacuum. Specifically, DOE
requests comment on whether fans that
are manufactured and marketed
exclusively to create a vacuum of 30
inches water gauge or greater could also
be used in positive pressure
applications. Additionally, DOE
requests information on the applications
in which a fan not manufactured or
marketed exclusively for creating a
vacuum would be used to create a
vacuum of 30 inches water gauge or
greater.
(2) DOE requests comments and
feedback on the proposed methodology
and calculation of motor and motor
controller losses as well as potentially
using an alternative calculation based
on adjusted AMCA 214–21 equations.
(3) DOE requests comment on
whether there are specific fans that meet
the axial ACF definition that provide
utility substantially different from the
utility provided from other axial ACFs
and that would impact energy use. If so,
DOE requests information on how the
utility of these fans differs from other
axial ACFs and requests data showing
the differences in energy use due to
differences in utility between these fans
and other axial ACFs.
(4) DOE requests comment on its
understanding that the diameter
increase design option could be applied
to non-embedded, non-spaceconstrained equipment classes.
(5) DOE requests comment on
whether the FEI increases associated
with an impeller diameter increase for
centrifugal PRVs and for axial PRVs are
realistic. Specifically, DOE requests
comment on whether it is realistic for
axial PRVs to have a FEI increase that
is 3 times greater than that for
centrifugal PRVs when starting at the
same initial diameter. Additionally,
DOE requests comment on the factors
that may impact how much an impeller
diameter increase impacts a FEI
increase.
(6) DOE requests comment on the
ordering and implementation of design
options for centrifugal PRV exhaust and
supply fans and axial PRV fans.
(7) DOE requests comment on its
approach for estimating the industrywide conversion costs that may be
necessary to redesign fans with forward-
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curved impellers to meet higher FEI
values. Specifically, DOE is interested
in the costs associated with any capital
equipment, research and development,
or additional labor that would be
required to design more efficient fans
with forward-curved impellers. DOE
additionally requests comment and data
on the percentage of forward-curved
impellers that manufacturers would
expect to maintain as a forward-curved
impeller relative to those expected to
transition to a backward-inclined or
airfoil impeller.
(8) DOE requests comment on the
equations developed to calculate the
credit for determining the FEI standard
for GFBs sold with a motor controller
and with an FEPact less than 20 kW and
on potentially using an alternative
credit calculation based on the proposed
equations in section III.C.1.b of this
document. Additionally, DOE requests
comment on its use of a constant value,
and its proposed value, of the credit
applied for determining the FEI
standard for GFBs with a motor
controller and an FEPact of greater than
or equal for 20 kW.
(9) DOE requests comments on
whether it should apply a correction
factor to the analyzed efficiency levels
to account for the tolerance allowed in
AMCA 211–22 and if so, DOE requests
comment on the appropriate correction
factor. DOE requests comment on the
potential revised levels as presented in
Table IV–12. Additionally, DOE
requests comments on whether it should
continue to evaluate an FEI of 1.00 for
all fan classes if it updates the databases
used in its analysis to consider the
tolerance allowed in AMCA 211–22.
(10) Additionally, DOE does not
anticipate that the efficiency levels
captured in Table IV–12 would impact
the cost, energy, and economic analyses
presented in this document. As such,
DOE considers the results of these
analyses presented throughout this
document applicable to the efficiency
levels with a 5% tolerance allowance.
DOE seeks comment on the analyses as
applied to the efficiency levels in Table
IV–12.
(11) DOE requests comment on its
method to use both the AMCA sales
database and sales data pulled from
manufacturer fan selection data to
estimate MSP. DOE also requests
comment on the use of the MSP
approach for its cost analysis for GFBs
or whether an MPC-based approach
would be appropriate. If interested
parties believe an MPC-based approach
would be more appropriate, DOE
requests MPC data for the equipment
classes and efficiency levels analyzed,
which may be confidentially submitted
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3869
to DOE using the confidential business
information label.
(12) DOE requests feedback on
whether using a more efficient motor
would require an ACF redesign.
Additionally, DOE requests feedback on
what percentage of motor speed change
would require an ACF redesign.
(13) DOE requests feedback on
whether setting an ACF standard using
discrete efficacy values over a defined
diameter range appropriately represents
the differences in efficacy between axial
ACFs with different diameters, and if
not, would a linear equation for efficacy
as a function of diameter be appropriate.
(14) DOE seeks comment on the
distribution channels identified for
GFBs and ACFs and fraction of sales
that go through each of these channels.
(15) DOE seeks comment on the
overall methodology and inputs used to
estimate GFBs and ACFs energy use.
Specifically, for GFBs, DOE seeks
feedback on the methodology and
assumptions used to determine the
operating point(s) both for constant and
variable load fans. For ACFs, DOE
requests feedback on the average daily
operating hours, annual days of
operation by sector and application, and
input power assumptions. In addition,
DOE requests feedback on the market
share of GFBs and ACFs by sector (i.e.,
commercial, industrial, and
agricultural).
(16) DOE requests feedback on the
price trends developed for GFBs and
ACFs.
(17) DOE requests feedback on the
installation costs developed for GFBs
and on whether installation costs of
ACFs may increase at higher ELs.
(18) DOE requests feedback on
whether the maintenance and repair
costs of GFBs may increase at higher
ELs. Specifically, DOE requests
comments on the frequency of motor
replacements for ACFs. DOE also
requests comments on whether the
maintenance and repair costs of ACFs
may increase at higher ELs and on the
repair costs developed for ACFs.
(19) DOE requests comments on the
average lifetime estimates used for GFBs
and ACFs.
(20) DOE requests feedback and
information on the no-new-standards
case efficiency distributions used to
characterize the market of GFBs and
ACFs. DOE requests information to
support any efficiency trends over time
for GFBs and ACFs.
(21) DOE requests feedback on the
methodology and inputs used to project
shipments of GFBs in the no-newstandards case. DOE requests comments
and feedback on the potential impact of
standards on GFB shipments and
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
information to help quantify these
impacts.
(22) DOE requests feedback on the
methodology and inputs used to
estimate and project shipments of ACFs
in the no-new-standards case. DOE
requests comments and feedback on the
potential impact of standards on ACF
shipments and information to help
quantify these impacts.
(23) DOE requests comment and data
regarding the potential increase in
utilization of GFBs and ACFs due to any
increase in efficiency.
(24) DOE requests comment on the
number of end-use product (i.e., a
product or equipment that has a fan or
blower embedded in it) basic models
that would not be excluded by the list
of products or equipment listed in Table
III–1.
(25) DOE requests information
regarding the impact of cumulative
regulatory burden on manufacturers of
fans and blowers associated with
multiple DOE standards or productspecific regulatory actions of other
Federal agencies.
(26) DOE requests comment on the
proposed standard level for axial PRVs,
including the design options and costs,
as well as the burdens and benefits
associated with this level and the
industry standards/California
regulations FEI level of 1.00.
(27) DOE requests comment on the
number of small business OEMs
identified that manufacture fans and
blowers covered by this proposed
rulemaking.
(28) DOE requests comment on the
estimated small business costs and how
those may differ from the costs incurred
by larger manufacturers.
Additionally, DOE welcomes
comments on other issues relevant to
the conduct of this rulemaking that may
not specifically be identified in this
document.
VIII. Approval of the Office of the
Secretary
ddrumheller on DSK120RN23PROD with PROPOSALS2
10 CFR Part 429
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Household appliances, Reporting and
recordkeeping requirements.
10 CFR Part 431
Administrative practice and
procedure, Confidential business
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Signing Authority
This document of the Department of
Energy was signed on December 28,
2023, by Jeffrey Marootian, Principal
Deputy 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 December
29, 2023.
Treena V. Garrett,
Federal Register Liaison Officer, U.S.
Department of Energy.
For the reasons set forth in the
preamble, DOE proposes to amend parts
429 and 431 of chapter II, subchapter D,
of title 10 of the Code of Federal
Regulations, as set forth below:
PART 429—CERTIFICATION,
COMPLIANCE, AND ENFORCEMENT
FOR CONSUMER PRODUCTS AND
COMMERCIAL AND INDUSTRIAL
EQUIPMENT
1. The authority citation for part 429
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6317; 28 U.S.C.
2461 note.
2. Amend § 429.69 by adding
paragraph (a)(3) to read as follows:
■
§ 429.69
The Secretary of Energy has approved
publication of this notice of proposed
rulemaking and announcement of
public meeting.
List of Subjects
information, Energy conservation test
procedures, Incorporation by reference,
Reporting and recordkeeping
requirements.
Fans and blowers.
(a) * * *
(3) Required Disclaimer at NonCompliant Duty Points. Representation
of fan performance at duty points with
FEI that are not compliant with the
energy conservation standards at
§ 431.175 of this chapter is allowed and
must be identified by the following
disclaimer: ‘‘Sale at these duty points
violates Department of Energy
Regulations under EPCA’’ in red and
bold font; and (2) duty points must be
grayed out in any graphs or tables in
which they are included.
*
*
*
*
*
■ 3. Amend § 429.110 by redesignating
paragraphs (e)(7), (8), and (9) as
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paragraphs (e)(8), (9), and (10),
respectively, and adding a new
paragraph (e)(7) to read as follows:
§ 429.110
Enforcement testing.
*
*
*
*
*
(e) * * *
(7) For fans and blowers other than air
circulating fans, DOE will use an initial
sample of one unit to determine
compliance at each duty point for which
the fan basic model is distributed in
commerce. If one or more duty points is
determined to be non-compliant, the fan
basic model is determined to be noncompliant.
(i) When testing a single unit, DOE
will first determine either fan shaft
input power or FEP, dependent on the
test method specified by the
manufacturer, for the range of certified
duty points according to appendix A to
subpart J of part 431 of this chapter. For
each point in the certified operating
range (i.e., each certified duty point),
DOE will conduct a verification of the
duty points as described in
§ 429.134(bb)(2) and determine the FEI
at the certified duty point or at the
measured duty point. If the FEI
calculated at the certified or measured
duty point is greater than or equal to the
minimum required FEI, then testing is
complete and the certified or measured
duty point is compliant. If the FEI
calculated at a certified or measured
duty point is less than the minimum
required FEI, DOE may select additional
units to test in accordance with this
paragraph (e)(7)(ii) of this section.
(ii) When testing more than one unit,
DOE will select no more than three
additional units of a certified basic
model for testing and test each one at
one or several duty points within the
range of certified duty points. For each
unit and at each certified duty point,
DOE will conduct a verification of the
duty points as described in
§ 429.134(bb)(2) and determine the FEI
at the certified duty point or at the
measured duty point. In the case where
the certified duty point can be verified,
DOE will calculate the average FEI of all
units tested for each certified duty
point. If the duty point cannot be
verified, DOE will follow the sampling
procedures at § 429.69 to determine the
average FEI of all units tested at the
measured duty point. If the average FEI
calculated at the certified or measured
duty point is greater than or equal to the
minimum required FEI, then testing is
complete and the certified or measured
duty point is compliant. If the average
FEI calculated at a certified or measured
duty point is less than the minimum
required FEI, then testing is complete
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
and the certified or measured duty point
is not compliant.
*
*
*
*
*
■ 4. Amend § 429.134 by adding
paragraph (gg) to read as follows:
§ 429.134 Product-specific enforcement
provisions.
*
*
*
*
*
(gg) Fans and blowers. (1) Testing. For
fans and blowers other than air
circulating fans, DOE will test each fan
or blower basic model according to the
test method specified by the
manufacturer (i.e., based on the method
listed in table 1 to appendix A to
subpart J of part 431 of this chapter).
(2) Verification of duty points. For
fans and blowers other than air
circulating fans, at a given speed within
the certified operating range, the
pressure and flow of a duty point in the
certified range of operation (i.e.,
certified duty point) will be determined
in accordance with appendix A to
subpart J of part 431 of this chapter. At
a given speed, the certified duty point
will be considered valid only if the
measured airflow is within five percent
3871
of the certified airflow and the
measured static or total pressure is
between P × (1¥0.05)2 and P × (1 +
0.05)2 where P is the certified static or
total pressure.
(i)(A) If the certified duty point is
found to be valid, the certified duty
point will be used as the basis for
determining compliance. DOE will
convert the measured fan shaft power or
FEP at the measured airflow to the
certified airflow using the following
equations:
For fan shaft power:
Converted fan shaft power
certified airflow)
= Measured fan shaft power ( Measured airflow
3
For fan electrical power:
certified airflow ) 3
(
Converted FEP = Measured FEP x Measured airflow
5. The authority citation for part 431
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6317; 28 U.S.C.
2461 note.
6. Amend § 431.172 by adding in
alphabetical order definitions for ‘‘Axial
air circulating fan’’, ‘‘Axial power roof
ventilator’’, ‘‘Centrifugal power roof
ventilator—exhaust’’, ‘‘Centrifugal
power roof ventilator—supply’’,
‘‘Diameter’’, ‘‘Fan housing’’, ‘‘Mixed
flow impeller’’, and ‘‘Radial impeller’’
to read as follows:
ddrumheller on DSK120RN23PROD with PROPOSALS2
■
§ 431.172
*
*
Definitions.
*
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*
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Mixed flow impeller means an
impeller featuring construction
characteristics between those of an axial
and centrifugal impeller. A mixed-flow
impeller has a fan flow angle greater
than 20 degrees and less than 70
degrees. Airflow enters axially through
a single inlet and exits with combined
axial and radial directions at a mean
diameter greater than the inlet.
*
*
*
*
*
Radial impeller means a form of
centrifugal impeller with several blades
extending radially from a central hub.
Airflow enters axially through a single
inlet and exits radially at the impeller
periphery into a housing with impeller
blades; the blades are positioned so
their outward direction is perpendicular
within 25 degrees to the axis of rotation.
Impellers can have a back plate and/or
shroud.
*
*
*
*
*
■ 7. Amend § 431.173 by redesignating
paragraphs (c) and (d) as paragraphs (d)
and (e), respectively, and adding a new
paragraph (c) to read as follows:
§ 431.173 Materials incorporated by
reference.
*
*
*
*
*
(c) IEC. International Electrotechnical
Committee, Central Office, 3, rue de
Varembe´, P.O. Box 131, CH–1211
GENEVA 20, Switzerland; + 41 22 919
02 11; webstore.iec.ch.
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EP19JA24.132
PART 431—ENERGY EFFICIENCY
PROGRAM FOR CERTAIN
COMMERCIAL AND INDUSTRIAL
EQUIPMENT
Axial air circulating fan means an air
circulating fan with an axial impeller
that is either housed or unhoused.
*
*
*
*
*
Axial power roof ventilator means a
PRV with an axial impeller that either
supplies or exhausts air to a building
where the inlet and outlet are not
typically ducted.
*
*
*
*
*
Centrifugal power roof ventilator—
exhaust means a PRV with a centrifugal
or mixed-flow impeller that exhausts air
from a building and which is typically
mounted on a roof or a wall.
Centrifugal power roof ventilator—
supply means a PRV with a centrifugal
or mixed-flow impeller that supplies air
to a building and which is typically
mounted on a roof or a wall.
*
*
*
*
*
Diameter means the impeller diameter
of a fan, which is twice the measured
radial distance between the tip of one of
the impeller blades of a fan to the center
axis of its impeller hub.
*
*
*
*
*
Fan housing means any fan
component(s) that direct(s) airflow into
or away from the impeller and/or
provide protection for the internal
components of a fan or blower that is
not an air circulating fan. A housing
may serve as a fan’s structure.
*
*
*
*
*
EP19JA24.131
(B) DOE will use the converted fan
shaft power or FEP to calculate the
corresponding FEI at the certified duty
point, in accordance with the DOE test
procedure.
(ii) If the certified duty point is found
to be invalid, the measured flow and
pressure will be used as the basis for
determining compliance. DOE will use
the measured fan shaft power or FEP to
calculate the corresponding FEI at the
measured duty point, in accordance
with the DOE test procedure.
3872
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
(1) IEC 61800–9–2:2023, Adjustable
speed electrical power drive systems
(PDS)—Part 9–2: Ecodesign for motor
systems—Energy efficiency
determination and classification,
Edition 2.0, 2023–10; IBR approved for
appendix A to this subpart.
(2) IEC TS 60034–30–2:2016, Rotating
electrical machines—Part 30–2:
Efficiency classes of variable speed AC
motors (IE-code), Edition 1.0, 2016–12;
IBR approved for appendix A to this
subpart.
(3) IEC TS 60034–31:2021, Rotating
electrical machines—Part 31: Selection
of energy-efficient motors including
variable speed applications—
Application guidelines, Edition 2.0,
2021–03; IBR approved for appendix A
to this subpart.
*
*
*
*
*
■ 8. Section 431.175 is added to read as
follows:
§ 431.175 Energy conservation standards
and compliance dates.
(a) Each fan and blower, other than an
air circulating fan manufactured starting
on [DATE FIVE YEARS AFTER DATE
OF PUBLICATION OF FINAL RULE]
that is subject to the test procedure in
§ 431.174(a), must have a FEI value at
each duty point for which the fan is
distributed in commerce, that is equal or
greater than the value in table 1 of this
section. The manufacturer is responsible
for ensuring that each fan and blower,
other than an air circulating fan
manufactured starting on [DATE FIVE
YEARS AFTER DATE OF
PUBLICATION OF FINAL RULE] that is
subject to the test procedure in
§ 431.174(a), is sold and selected at
compliant duty points.
TABLE 1 TO PARAGRAPH (a)—ENERGY CONSERVATION STANDARDS FOR FANS AND BLOWERS OTHER THAN AIR
CIRCULATING FANS
Equipment class
With or without
motor controller
Axial Inline ...............................................................................................................................................
Axial Panel ..............................................................................................................................................
Axial Power Roof Ventilator ....................................................................................................................
Centrifugal Housed .................................................................................................................................
Centrifugal Unhoused .............................................................................................................................
Centrifugal Inline .....................................................................................................................................
Radial Housed ........................................................................................................................................
Centrifugal Power Roof Ventilator—Exhaust ..........................................................................................
Centrifugal Power Roof Ventilator—Supply ............................................................................................
Axial Inline ...............................................................................................................................................
Axial Panel ..............................................................................................................................................
Axial Power Roof Ventilator ....................................................................................................................
Centrifugal Housed .................................................................................................................................
Centrifugal Unhoused .............................................................................................................................
Centrifugal Inline .....................................................................................................................................
Radial Housed ........................................................................................................................................
Centrifugal Power Roof Ventilator—Exhaust ..........................................................................................
Centrifugal Power Roof Ventilator—Supply ............................................................................................
Without ...................
Without ...................
Without ...................
Without ...................
Without ...................
Without ...................
Without ...................
Without ...................
Without ...................
With ........................
With ........................
With ........................
With ........................
With ........................
With ........................
With ........................
With ........................
With ........................
Fan energy index
(FEI) *
1.18
1.48
0.85
1.31
1.35
1.28
1.17
1.00
1.19
1.18
1.48
0.85
1.31
1.35
1.28
1.17
1.00
1.19
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
A.
A.
A.
A.
A.
A
A.
A.
A.
A*
A*
A*
A*
A*
A*
A*
A*
A*
B.
B.
B.
B.
B.
B.
B.
B.
B.
* A is a constant representing an adjustment in FEI for motor hp, which can be found in table 2 of this section. B is a constant representing an
adjustment in FEI for motor controllers, which can be found in table 2 of this section.
Constant
A
Credit= 0.03 X FEPact
1.341 rIPl
FEPact of~ 20 B = 0.966
kW (26.8 hp)
+ 0.08 X
is the motor efficiency in accordance with table 8 at§ 431.25, TJm1r,2014 is the motor efficiency in
accordance with table 5 at§ 431.25, which DOE is proposing to adopt into this section, and FEPact is
determined according to the DOE test procedure in appendix A to subpart J of this part.
TJm1r,2023
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ddrumheller on DSK120RN23PROD with PROPOSALS2
B
Table 2 to Para2raph (a) - FEI Calculation Constants
Condition
Value
With Motor hp < 100 hp
A= 1.00
17mtr,2023
With Motor hp ~ 100 hp and :S 250
A=
hp
17mtr 2014
FEPact-Credit
h
With Motor
FEPact of<
; were:
B=
FEPact
Controller
20 kW (26.8
hp)
Credit= 0.03 x FEPact + 0.08
[SI]
3873
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
TABLE 3 TO PARAGRAPH (a)—2014 MOTOR EFFICIENCY VALUES, hmtr,2014
Nominal full-load efficiency (%)
Motor horsepower/standard kilowatt equivalent
2 Pole
Enclosed
100/75 ..............................................................
125/95 ..............................................................
150/110 ............................................................
200/150 ............................................................
250/186 ............................................................
(b) Each air circulating fan
manufactured starting on [DATE FIVE
YEARS AFTER DATE OF
4 Pole
Open
94.1
95.0
95.0
95.4
95.8
Enclosed
93.6
94.1
94.1
95.0
95.0
6 Pole
Open
95.4
95.4
95.8
96.2
96.2
Enclosed
95.4
95.4
95.8
95.8
95.8
PUBLICATION OF FINAL RULE] that is
subject to the test procedure in
§ 431.174(b), must have an efficacy
8 Pole
Open
95.0
95.0
95.8
95.8
95.8
Enclosed
95.0
95.0
95.4
95.4
95.8
Open
93.6
94.1
94.1
94.5
95.0
94.1
94.1
94.1
94.1
95.0
value in CFM/W at maximum speed that
is equal or greater than the value in
table 4 to this paragraph (b).
TABLE 4 TO PARAGRAPH (b)—ENERGY CONSERVATION STANDARDS FOR AIR CIRCULATING FANS
Efficacy at maximum speed
(CFM/W)
Equipment class *
Axial Air Circulating Fans; 12″ ≤ D < 36″ ....................................................................................................................
Axial Air Circulating Fans; 36″ ≤ D < 48″ ....................................................................................................................
Axial Air Circulating Fans; 48″ ≤ D ..............................................................................................................................
Housed Centrifugal ACFs ............................................................................................................................................
12.2
17.3
21.5
N/A
* D: diameter in inches.
N/A means not applicable as DOE is not proposing to set a standard for this equipment class.
9. Amend appendix A to subpart J of
part 431 by:
■ a. Revising the section 0 introductory
text and paragraph 0.2.(h);
■ b. Redesignating section 0.3 as 0.6;
■ c. Adding new section 0.3, and
sections 0.4 and 0.5;
■ d. Revising section 2.2.1;
■ e. Redesignating section 2.6 as 2.7;
and
■ f. Adding new section 2.6.
The revisions and additions read as
follows:
■
Appendix A to Subpart J of Part 431—
Uniform Test Method for the
Measurement of Energy Consumption of
Fans and Blowers Other Than Air
Circulating Fans
*
*
*
*
*
0. Incorporation by reference.
In § 431.173, DOE incorporated by
reference the entire standard for AMCA 210–
16, AMCA 214–21, IEC 61800–9–2:2023, IEC
TS 60034–30–2:2016, IEC TS 60034–31:2021,
and ISO 5801:2017; however, only
enumerated provisions of those documents
are applicable as follows. In cases where
there is a conflict, the language of this
appendix takes precedence over those
documents.
(b) Table 4 as referenced in section
2.6.1.2.2 of this appendix.
0.5 IEC TS 60034–31:2021:
(a) Section A.3 as referenced in section
2.6.1.2.1 of this appendix; and
*
2. * * *
2.2 * * *
2.2.1. General. The fan electrical power
(FEPact) in kilowatts must be determined at
every duty point specified by the
manufacturer in accordance with one of the
test methods listed in table 1, and the
following sections of AMCA 214–21: Section
2, ‘‘References (Normative)’’; Section 7,
‘‘Testing,’’ including the provisions of AMCA
210–16 and ISO 5801:2017 as referenced by
Section 7 and implicated by sections 2.2.2
and 2.2.3 of this appendix; Section 8.1,
‘‘Laboratory Measurement Only’’ (as
applicable); and Annex J, ‘‘Other data and
calculations to be retained.’’ In addition, the
provisions in this appendix apply.
*
*
*
*
0.2 * * *
(h) Section 6.4, ‘‘Fans with Polyphase
Regulated Motor’’ as referenced in sections
2.2 and 2.6 of this appendix;
*
*
*
*
*
0.3 IEC 61800–9–2:2023:
(a) Section 6.2 as referenced in section
2.6.2.2 of this appendix;
(b) Table A.1 as referenced in section
2.6.2.2 of this appendix; and
(c) Table E.4 as referenced in 2.6.1.2.1. of
this appendix; and
(d) Section F.2.1 as referenced in section
2.6.2.2 of this appendix.
0.4 IEC TS 60034–30–2:2016:
(a) Section 4.7 as referenced in section
2.6.1.2.2 of this appendix; and
*
*
*
*
*
ddrumheller on DSK120RN23PROD with PROPOSALS2
TABLE 1 TO APPENDIX A TO SUBPART J OF PART 431
Driver
Motor
controller
present?
Transmission
configuration?
Test method
Applicable section(s) of AMCA 214–21
Electric motor ................
Yes or No ....
Any ...............................
Wire-to-air .....................
Electric motor ................
Yes or No ....
Any ...............................
Calculation based on
Wire-to-air testing.
6.1 ‘‘Wire-to-Air Testing at the Required Duty
Point’’.
6.2 ‘‘Calculated Ratings Based on Wire to Air
Testing’’ (references Section 8.2.3, ‘‘Calculation to other speeds and densities for wire-toair testing,’’ and Annex G, ’’Wire-to-Air Measurement—Calculation to Other Speeds and
Densities (Normative)’’).
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Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
TABLE 1 TO APPENDIX A TO SUBPART J OF PART 431—Continued
Motor
controller
present?
Transmission
configuration?
Test method
Applicable section(s) of AMCA 214–21
Regulated polyphase
motor.
Yes or No ....
Shaft-to-air ....................
6.4 ‘‘Fans with Polyphase Regulated Motors,’’ *
(references Annex D, ‘‘Motor Performance
Constants (Normative)’’).
None or non-electric .....
Regulated polyphase
motor.
No ................
No ................
Direct drive, V-belt
drive, flexible coupling or synchronous
belt drive.
None .............................
Direct drive, V-belt
drive, flexible coupling or synchronous
belt drive.
Shaft-to-air ....................
Calculation based on
Shaft-to-air testing.
None or non-electric .....
No ................
Section 6.3, ‘‘Bare Shaft Fans’’.
Section 8.2.1, ‘‘Fan laws and other calculation
methods for shaft-to-air testing’’ (references
Annex D, ‘‘Motor Performance Constants
(Normative),’’ Annex E, ‘‘Calculation Methods
for Fans Tested Shaft-to-Air,’’ and Annex K,
‘‘Proportionality and Dimensional Requirements (Normative)’’).
Section 8.2.1, ‘‘Fan laws and other calculation
methods for shaft-to-air testing’’ (references
Annex E, ‘‘Calculation Methods for Fans Tested Shaft-to-Air,’’ and Annex K, ‘‘Proportionality and Dimensional Requirements (Normative)’’).
Driver
None .............................
Calculation based on
Shaft-to-air testing.
* With the modifications in section 2.6 of this appendix.
calculations must be rounded to the number
of significant digits present at the resolution
of the test instrumentation.
In cases where there is a conflict, the
provisions in AMCA 214–21 take precedence
over AMCA 210–16 and ISO 5801:2017. In
addition, the provisions in this appendix
apply.
*
*
2.6. Calculation based on Shaft-to-air
testing for Fans with Motors and Motor
Controllers. The provisions of section 6.4 of
AMCA 214–21 apply except that the
instructions in section 6.4.2.4.1 of AMCA
214–21 are replaced by section 2.6.1 of this
appendix, and the instructions in section
6.4.2.4.2. of AMCA 214–21 are replaced by
section 2.6.2 of this appendix.
2.6.1 Motor efficiency if used in
combination with a VFD. This section
replaces section 6.4.2.4.1 of AMCA 214–21
and provides methods to calculate the
efficiency of the motor if it is combined with
a VFD.
100 -
ddrumheller on DSK120RN23PROD with PROPOSALS2
PL
Where:
pL(n,T) are the relative losses of an IE3 motor
if used in combination with a VFD
calculated per section 2.6.1.2.1 of this
appendix.
ηr nominal full load efficiency per section
6.4.2.4.1.1 of AMCA 214–21
ηIE3 is nominal full load efficiency of an IE3
motor per section 2.6.1.2.2. of this
appendix.
2.6.1.2.1. Relative losses of an IE3 motor if
used in combination with a VFD. The relative
losses of an IE3 motor if used in combination
with a VFD, pL(n,T) are based on the actual
motor nameplate rated speed and the motor
nameplate output power and must be
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PL(n,
T) X
T/r
T/r
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Where:
ηmtr′,act is the actual motor efficiency if used
in combination with a VFD.
Lm is the is motor load ratio calculated per
section 6.4.2.4.1.3 of AMCA 214–21
p′L are the relative losses of a motor of if used
in combination with a VFD that that
exactly meets the applicable standards at
§ 431.25 per section 2.6.1.2. of this
appendix.
2.6.1.2. Relative losses of the actual motor
if used in combination with a VFD. This
section provides the methods to calculate the
relative losses P′L of a motor that exactly
meets the applicable standards at § 431.25, if
used in combination with a VFD:
T/IE3
X 100 - T/IE3
calculated per section A.3 of IEC TS 60034–
31:2021, using the coefficients in table E.4 of
IEC 61800–9–2:2023. If the motor nameplate
output power value is not shown in table E.4
of IEC 61800–9–2:2023, the instructions in
section 6.4.2.4.1.1 of AMCA 214–21 must be
used.
The calculation of pL(n,T) relies on the
relative speed (n) and relative torque (T)
values which are determined for each duty
point as follows:
And:
Lm
(Lm+ PL 1)
Where:
ηact is the fan speed in revolutions per
minute at the given duty point;
ηr is the nameplate nominal rated speed of
the actual motor revolutions per minute;
and
Lm is the motor load ratio calculated per
section 6.4.2.4.1.3 of AMCA 214–21.
2.6.1.2.2. Nominal full load efficiency of an
IE3 motor. The nominal full load efficiency
of an IE3 motor must be determined per
section 4.7 of IEC TS 60034–30–2:2016 and
is based on the actual motor nameplate rated
speed and the motor nameplate output
E:\FR\FM\19JAP2.SGM
19JAP2
EP19JA24.137
*
=
EP19JA24.136
*
T/mtr',act
EP19JA24.135
*
2.6.1.1 Motor efficiency Calculation, if
used in combination with a VFD. The
efficiency of the motor if it is combined with
a VFD is calculated as follows:
EP19JA24.134
Testing must be performed in accordance
with the required test configuration listed in
table 7.1 of AMCA 214–21. The following
values must be determined in accordance
with this appendix at each duty point
specified by the manufacturer: fan airflow in
cubic feet per minute; fan air density; fan
total pressure in inches of water gauge for
fans using a total pressure basis FEI in
accordance with table 7.1 of AMCA 214–21;
fan static pressure in inches of water gauge
for fans using a static pressure basis FEI in
accordance with table 7.1 of AMCA 214–21;
fan speed in revolutions per minute; and fan
shaft input power in horsepower for fans
tested in accordance with sections 6.3 or 6.4
of AMCA 214–21.
In addition, if applying the equations in
section E.2 of annex E of AMCA 214–21 for
compressible flows, the compressibility
coefficients must be included in the
equations as applicable.
All measurements must be recorded at the
resolution of the test instrumentation and
3875
Federal Register / Vol. 89, No. 13 / Friday, January 19, 2024 / Proposed Rules
power. If the motor nameplate output power
value is not shown in table 4 of IEC TS
60034–30–2:2016, the instructions in section
6.4.2.4.1.1 of AMCA 214–21 must be used.
2.6.2 VFD efficiency at the required motor
electrical power input. This section replaces
section 6.4.2.4.2 of AMCA 214–21 and
provides methods to calculate the efficiency
of the VFD at the required motor electrical
power input. A single VFD may operate one
or many motors.
2.6.2.1 VFD efficiency calculation. The
efficiency of the VFD at the required motor
electrical power input is calculated as
follows:
Le
1JVFD
=
(Le+ PVFD,L(f,iq))
The calculation of pVFD,L(f, iq) relies on the
relative motor frequency (f) and relative
torque current (iq) values which are
determined for each duty point as follows:
f=n
And:
iq =
TXHmo
Hco
Where:
n is the relative speed per section 2.6.1.2.1.
of this appendix;
T is the relative torque per section 2.6.1.2.1.
of this appendix;
Hmo is motor nameplate output power; and
Hco is rated power output of the VFD.
*
*
*
*
*
[FR Doc. 2023–28976 Filed 1–18–24; 8:45 am]
EP19JA24.139
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ddrumheller on DSK120RN23PROD with PROPOSALS2
Where:
ηVFD is the VFD efficiency at the required
motor electrical power input;
Lc is the is VFD load ratio calculated per
section 6.4.2.4.2.2 of AMCA 214–21; and
pVFD,L(f, iq) are the relative losses of a VFD at
IE2 levels per section 2.6.2.2 of this
appendix.
2.6.2.2. Relative losses of a VFD at IE2
levels. The relative losses of an IE2 VFD,
ηVFD,L(f, iq) are inter- or extrapolated from the
relative losses in table A.1 of IEC 61800–9–
2:2023, adapted for IE2 in accordance with
section 6.2 of IEC 61800–9–2:2023. The
calculations must follow the twodimensional linear inter- or extrapolation
from neighboring loss points in accordance
with section F.2.1 of IEC 61800–9–2:2023. In
addition, the relative losses of an IE2 VFD,
pVFD,L(f, iq), are based on the actual VFD
nameplate rated output power. If the motor
nameplate output power value is not shown
in table A.1 of IEC 61800–9–2:2023, the
instructions in section 6.4.2.4.1.1 of AMCA
214–21 must be used.
Agencies
[Federal Register Volume 89, Number 13 (Friday, January 19, 2024)]
[Proposed Rules]
[Pages 3714-3875]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-28976]
[[Page 3713]]
Vol. 89
Friday,
No. 13
January 19, 2024
Part II
Department of Energy
-----------------------------------------------------------------------
10 CFR Parts 429 and 431
Energy Conservation Program: Energy Conservation Standards for Fans and
Blowers; Proposed Rule
Federal Register / Vol. 89 , No. 13 / Friday, January 19, 2024 /
Proposed Rules
[[Page 3714]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Parts 429 and 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: Notice of proposed rulemaking and announcement of public
meeting.
-----------------------------------------------------------------------
SUMMARY: The Energy Policy and Conservation Act, as amended (``EPCA''),
prescribes energy conservation standards for various consumer products
and certain commercial and industrial equipment, including fans and
blowers. EPCA also requires the U.S. Department of Energy (``DOE'') to
periodically determine whether more stringent standards would be
technologically feasible and economically justified and would result in
significant energy savings. In this notice of proposed rulemaking
(``NOPR''), DOE proposes energy conservation standards for two
categories of fans and blowers: air circulating fans (``ACFs''), and
fans and blowers that are not ACFs, referred to as general fans and
blowers (``GFBs'') throughout this document. DOE also announces a
public meeting to receive comment on these proposed standards and
associated analyses and results.
DATES: Comments: DOE will accept comments, data, and information
regarding this NOPR no later than March 19, 2024.
Meeting: DOE will hold a public meeting on Wednesday, February 21,
2024, from 10 a.m. to 4 p.m., in Washington, DC. This meeting will also
be broadcast as a webinar.
Comments regarding the likely competitive impact of the proposed
standard should be sent to the Department of Justice contact listed in
the ADDRESSES section on or before February 20, 2024.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 6E-069, 1000 Independence Avenue SW,
Washington, DC 20585. See section VII of this document, ``Public
Participation,'' for further details, including procedures for
attending the in-person meeting, webinar registration information,
participant instructions, and information about the capabilities
available to webinar participants.
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 docket number
EERE-2022-BT-STD-0002 in the subject line of the message.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section VII of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, 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, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
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 VII of this document for information on how to submit comments
through www.regulations.gov.
EPCA requires the Attorney General to provide DOE a written
determination of whether the proposed standard is likely to lessen
competition. The U.S. Department of Justice Antitrust Division invites
input from market participants and other interested persons with views
on the likely competitive impact of the proposed standard. Interested
persons may contact the Division at [email protected] on or
before the date specified in the DATES section. Please indicate in the
``Subject'' line of your email the title and Docket Number of this
proposed rulemaking.
FOR FURTHER INFORMATION CONTACT: Mr. Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 586-9870. Email:
[email protected].
Ms. Amelia Whiting, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 586-2588. Email:
[email protected].
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact the Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: [email protected].
SUPPLEMENTARY INFORMATION: DOE maintains previously approved
incorporations by reference (AMCA 210-16, AMCA 214-21, and ISO
5801:2017) and incorporates by reference the following material into
part 431:
IEC 61800-9-2:2023, Adjustable speed electrical power drive systems
(PDS)--Part 9-2: Ecodesign for motor systems--Energy efficiency
determination and classification, Edition 2.0, 2023-10.
IEC TS 60034-30-2:2016, Rotating electrical machines--Part 30-2:
Efficiency classes of variable speed AC motors (IE-code), Edition 1.0,
2016-12.
IEC TS 60034-31:2021, Rotating electrical machines--Part 31:
Selection of energy-efficient motors including variable speed
applications--Application guidelines, Edition 2.0, 2021-03.
Copies of IEC 61800-9-2:2023, IEC TS 60034-30-2:2016 and IEC TS
60034-31:2021 are available from the International Electrotechnical
Committee (IEC), Central Office, 3, rue de Varemb[eacute], P.O. Box
131, CH-1211 GENEVA 20, Switzerland; + 41 22 919 02 11;
webstore.iec.ch.
For a further discussion of these standards, see section VI.M of
this document.
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
1. General Fans and Blowers
2. Air Circulating Fans
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Fans and Blowers
C. Deviation From Process Rule
1. Framework Document
2. Public Comment Period
III. General Discussion
A. General Comments
B. Scope of Coverage
1. General Fans and Blowers
2. Air Circulating Fans
a. Ceiling Fan Distinction
[[Page 3715]]
C. Test Procedure and Metric
1. General Fans and Blowers
a. General
b. Combined Motor and Motor Controller Efficiency Calculation
2. Air Circulating Fans
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC
and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Equipment Classes
a. General Fans and Blowers
b. Air Circulating Fans
2. Scope of Analysis and Data Availability
a. General Fans and Blowers
b. Air Circulating Fans
3. Technology Options
B. Screening Analysis
C. Engineering Analysis
1. General Fans and Blowers
a. Baseline Efficiency
b. Selection of Efficiency Levels
c. Higher Efficiency Levels
d. Cost Analysis
2. Air Circulating Fans
a. Representative Units
b. Baseline Efficiency and Efficiency Level 1
c. Selection of Efficiency Levels
d. Cost Analysis
3. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
1. General Fans and Blowers
2. Air-Circulating fans
F. Life-Cycle Cost and Payback Period Analyses
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Equipment Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the No-New-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
1. General Fans and Blowers
2. Air Circulating Fans
H. National Impact Analysis
1. Equipment Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Product and Capital Conversion Costs
d. Markup Scenarios
3. Manufacturer Interviews
4. Discussion of MIA Comments
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous Oxide
2. Monetization of Other Emissions Impacts
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
8. Summary of Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Fans and Blowers
Standards
a. General Fans and Blowers
b. Air Circulating Fans
2. Annualized Benefits and Costs of the Proposed Standards
a. General Fans and Blowers
b. Air Circulating Fans
D. Reporting, Certification, and Sampling Plan
E. Representations and Enforcement Provisions
1. Representations for General Fans and Blowers
2. Enforcement Provisions for General Fans and Blowers
a. Testing a Single Fan at Multiple Duty Points
b. Testing Multiple Fans at One or Several Duty Points
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866, 13563, and 14094
B. Review Under the Regulatory Flexibility Act
1. Description of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, Rule
3. Description on Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements Including
Differences in Cost, if Any, for Different Groups of Small Entities
5. Duplication, Overlap, and Conflict With Other Rules and
Regulations
6. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
M. Description of Materials Incorporated by Reference
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
The Energy Policy and Conservation Act, Public Law 94-163, 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 \2\ of EPCA established the Energy
Conservation Program for Certain Industrial Equipment. (42 U.S.C. 6311-
6317) Such equipment includes fans and blowers. This proposed rule
concerns two categories of fans and blowers: air circulating fans
(``ACFs''), and fans and blowers that are not ACFs, which are referred
to as general fans and blowers (``GFBs'') throughout this document.
---------------------------------------------------------------------------
\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020), which reflect the last statutory amendments that impact
Parts A and A-1 of EPCA.
\2\ For editorial reasons, upon codification in the U.S. Code,
Part C was redesignated Part A-1.
---------------------------------------------------------------------------
Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that DOE determines is technologically feasible and
economically justified. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A))
Furthermore, the new or amended standard must result in a significant
conservation of energy. (42 U.S.C.
[[Page 3716]]
6316(a); 42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later
than 6 years after issuance of any final rule establishing or amending
a standard, DOE must publish either a notice of determination that
standards for the product do not need to be amended, or a notice of
proposed rulemaking including new proposed energy conservation
standards (proceeding to a final rule, as appropriate). (42 U.S.C.
6316(a); 42 U.S.C. 6295(m))
In accordance with these and other statutory provisions discussed
in this document, DOE analyzed the benefits and burdens of six trial
standard levels (``TSLs'') for two categories of fans and blowers: GFBs
and ACFs. The TSLs and their associated benefits and burdens are
discussed in detail in sections V.A through V.C of this document. As
discussed in section V.C, DOE has tentatively determined that TSL 4
represents the maximum improvement in energy efficiency that is
technologically feasible and economically justified. The proposed
standards, which are expressed in terms of a fan energy index (``FEI'')
for GFBs, are shown in Table I-1 through Table I-3. The proposed
standards, which are expressed in terms of efficacy in cubic feet per
minute per watt (``CFM/W'') at maximum speed for ACFs, are shown in
Table I-3. These proposed standards, if adopted, would apply to all
GFBs listed in Table I-1 and Table I-2 and ACFs listed in Table I-3
manufactured in, or imported into, the United States starting on the
date 5 years after the publication of the final rule for this
rulemaking. For GFBs, DOE proposes that every duty point at which the
basic model is offered for sale would need to meet the proposed energy
conservation standards. (See section III.C.1 of this document).
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A. Benefits and Costs to Consumers
Table I-4 and Table I-5 present DOE's evaluation of the economic
impacts of the proposed standards on consumers of GFBs and ACFs, as
measured by the average life-cycle cost (``LCC'') savings and the
simple payback period (``PBP'').\3\ The average LCC savings are
positive for all equipment classes, and the PBP is less than the
average lifetime of the considered equipment, which is estimated to be
16.0 years for GFBs and 6.3 years for ACFs (see section IV.F.6 of this
document).
---------------------------------------------------------------------------
\3\ The average LCC savings refer to consumers that are affected
by a standard and are measured relative to the efficiency
distribution in the no-new-standards case, which depicts the market
in the compliance year in the absence of new or amended standards
(see section IV.E.9 of this document). The simple PBP, which is
designed to compare specific efficiency levels, is also measured
relative to the no-new-standards case (see section IV.C of this
document).
---------------------------------------------------------------------------
[[Page 3718]]
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[GRAPHIC] [TIFF OMITTED] TP19JA24.004
BILLING CODE 6450-01-C
DOE's analysis of the impacts of the proposed standards on
consumers is described in section IV.F of this document.
B. Impact on Manufacturers
The industry net present value (``INPV'') is the sum of the
discounted cash flows to the industry from the base year through the
end of the analysis period (2024-2059). Using a real discount rate of
11.4 percent, DOE estimates that the INPV for manufacturers of fans and
blowers in the case without new standards is $649 million in 2022
dollars for ACFs and $4,935 million in 2022 dollars for GFBs. Under the
proposed standards, the change in INPV is estimated to range from -10.9
percent to less than 0.1 percent for ACFs, which represents a change in
INPV of approximately -$71 million to less than $0.1 million, and from
-9.2 percent to less than 0.1 percent for GFBs, which represents a
change in INPV of approximately -$455 million to $1 million. In order
to bring products into compliance with new standards, it is estimated
that the industry would incur total conversion costs of $118 million
for ACFs and $770 million for GFBs.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this document. The
analytic results of the manufacturer impact analysis (``MIA'') are
presented in section V.B.2 of this document.
C. National Benefits and Costs 4
---------------------------------------------------------------------------
\4\ All monetary values in this document are expressed in 2022
dollars.
---------------------------------------------------------------------------
This section presents the combined results for GFBs and ACFs.
Specific results for GFBs and ACFs are also discussed in sections I.C.1
and I.C.2 of this document, respectively.
DOE's analyses indicate that the proposed energy conservation
standards for GFBs and ACFs would save a significant amount of energy.
Relative to the case without new standards, the lifetime energy savings
for GFBs and ACFs purchased in the 30-year period that begins in the
anticipated first full year of compliance with the new standards (2030-
2059) amount to 18.3 quadrillion British thermal units (``Btu''), or
quads.\5\
---------------------------------------------------------------------------
\5\ The quantity refers to full-fuel-cycle (``FFC'') energy
savings. FFC energy savings includes the energy consumed in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and, thus, presents a more complete
picture of the impacts of energy efficiency standards. For more
information on the FFC metric, see section IV.G.1 of this document.
---------------------------------------------------------------------------
The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for GFBs and ACFs ranges from $19.0
billion (at a 7 percent discount rate) to $49.5 billion (at a 3 percent
discount rate). This NPV expresses the estimated total value of future
operating cost savings minus the estimated increased equipment and
installation costs for GFBs and ACFs purchased in 2030-2059.
In addition, the proposed standards for GFBs and ACFs are projected
to yield significant environmental benefits. DOE estimates that the
proposed standards would result in cumulative emission reductions (over
the same period as for energy savings) of 317.9
[[Page 3719]]
million metric tons (``Mt'') \6\ of carbon dioxide
(``CO2''), 92.7 thousand tons of sulfur dioxide
(``SO2''), 598.9 thousand tons of nitrogen oxides
(``NOX''), 2,760.5 thousand tons of methane
(``CH4''), 2.9 thousand tons of nitrous oxide
(``N2O''), and 0.6 tons of mercury (``Hg'').\7\
---------------------------------------------------------------------------
\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\7\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2023 (``AEO2023''). AEO2023 represents current Federal and
State legislation and final implementation of regulations as of the
time of its preparation. See section IV.J of this document for
further discussion of AEO2023 assumptions that affect air pollutant
emissions.
---------------------------------------------------------------------------
DOE estimates the value of climate benefits from a reduction in
greenhouse gases (``GHG'') using four different estimates of the social
cost of CO2 (``SC-CO2''), the social cost of
methane (``SC-CH4''), and the social cost of nitrous oxide
(``SC-N2O''). Together these represent the social cost of
GHG (``SC-GHG''). DOE used interim SC-GHG values developed by an
Interagency Working Group on the Social Cost of Greenhouse Gases
(``IWG'').\8\ The derivation of these values is discussed in section
IV.L of this document. For presentational purposes, the climate
benefits associated with the average SC-GHG at a 3 percent discount
rate are estimated to be $16.3 billion. DOE does not have a single
central SC-GHG point estimate and it emphasizes the importance and
value of considering the benefits calculated using all four sets of SC-
GHG estimates.
---------------------------------------------------------------------------
\8\ To monetize the benefits of reducing GHG emissions, this
analysis uses the interim estimates presented in the Technical
Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990, published in February
2021 by the IWG (``February 2021 SC-GHG TSD''). www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.
---------------------------------------------------------------------------
DOE estimated the monetary health benefits of SO2 and
NOX emissions reductions using benefit per ton estimates
from the scientific literature, as discussed in section IV.L of this
document. DOE did not monetize the reduction in mercury emissions
because the quantity is very small. DOE estimated the present value of
the health benefits would be $11.4 billion using a 7 percent discount
rate, and $31.6 billion using a 3 percent discount rate.\9\ DOE is
currently only monetizing (for SO2 and NOX)
PM2.5 precursor health benefits and (for NOX)
ozone precursor health benefits, but will continue to assess the
ability to monetize other effects such as health benefits from
reductions in direct PM2.5 emissions.
---------------------------------------------------------------------------
\9\ DOE estimates the economic value of these emissions
reductions resulting from the considered trial standards levels
(``TSLs'') for the purpose of complying with the requirements of
Executive Order 12866.
---------------------------------------------------------------------------
Table I-6 summarizes the monetized benefits and costs expected to
result from the proposed standards for GFBs and ACFs. There are other
important unquantified effects, including certain unquantified climate
benefits, unquantified public health benefits from the reduction of
toxic air pollutants and other emissions, unquantified energy security
benefits, and distributional effects, among others.
BILLING CODE 6450-01-P
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[[Page 3721]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.006
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The monetary values for the
total annualized net benefits are (1) the reduced consumer operating
costs, minus (2) the increase in product purchase prices and
installation costs, plus (3) the monetized value of climate and health
benefits of emission reductions, all annualized.\10\
---------------------------------------------------------------------------
\10\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2024, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2030), and then discounted the present value from each year
to 2024. Using the present value, DOE then calculated the fixed
annual payment over a 30-year period, starting in the compliance
year, that yields the same present value.
---------------------------------------------------------------------------
The national operating cost savings are domestic private U.S.
consumer monetary savings that occur as a result of purchasing the
covered products and are measured for the lifetime of GFBs and ACFs
shipped in 2030-2059. The benefits associated with reduced emissions
achieved as a result of the proposed standards are also calculated
based on the lifetime of GFBs and ACFs shipped in 2030-2059. Total
benefits for both the 3 percent and 7 percent cases are presented using
the average GHG social costs with a 3-percent discount rate.\11\
Estimates of total benefits are presented for all four SC-GHG discount
rates in section V.B.6 of this document.
---------------------------------------------------------------------------
\11\ As discussed in section IV.L.1 of this document, DOE agrees
with the IWG that using consumption-based discount rates e.g., 3
percent) is appropriate when discounting the value of climate
impacts. Combining climate effects discounted at an appropriate
consumption-based discount rate with other costs and benefits
discounted at a capital-based rate (i.e., 7 percent) is reasonable
because of the different nature of the types of benefits being
measured.
---------------------------------------------------------------------------
Table I-7 presents the total estimated monetized benefits and costs
associated with the proposed standard, expressed in terms of annualized
values. The results under the primary estimate are as follows.
Using a 7 percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and the 3 percent discount rate case for climate benefits
from reduced GHG emissions, the estimated cost of the standards
proposed in this rule is $360 million per year in increased equipment
costs, while the estimated annual benefits are $2,506 million in
reduced equipment operating costs, $963 million in monetized climate
benefits, and $1,285 million in monetized health benefits. In this
case, the monetized net benefit would amount to $4,394 million per
year.
Using a 3 percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $374 million per year in
increased equipment costs, while the estimated annual benefits are
$3,302 million in reduced operating costs, $963 million in monetized
climate benefits, and $1,869 million in monetized health benefits. In
this case, the monetized net benefit would amount to $5,760 million per
year.
[[Page 3722]]
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[[Page 3723]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.008
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this document.
1. General Fans and Blowers
DOE's analyses indicate that the proposed energy conservation
standards for GFBs would save a significant amount of energy. Relative
to the case without new standards, the lifetime energy savings for GFBs
purchased in the 30-year period that begins in the anticipated first
full year of compliance with the new standards (2030-2059) amount to
13.8 quadrillion British thermal units (``Btu''), or quads.\12\ This
represents a savings of 11.4 percent relative to the energy use of
these products in the case without standards (referred to as the ``no-
new-standards case'').
---------------------------------------------------------------------------
\12\ The quantity refers to full-fuel-cycle (``FFC'') energy
savings. FFC energy savings includes the energy consumed in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and, thus, presents a more complete
picture of the impacts of energy efficiency standards. For more
information on the FFC metric, see section IV.G.1 of this document.
---------------------------------------------------------------------------
The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for GFBs ranges from $13.7 billion
(at a 7 percent discount rate) to $36.9 billion (at a 3 percent
discount rate). This NPV expresses the estimated total value of future
operating cost savings minus the estimated increased equipment and
installation costs for GFBs purchased in 2030-2059.
In addition, the proposed standards for GFBs are projected to yield
significant environmental benefits. DOE estimates that the proposed
standards would result in cumulative emission reductions (over the same
period as for energy savings) of 239.4 Mt of CO2, 73.1
thousand tons of SO2, 450.9 thousand tons of NOX,
2,073.9 thousand tons of CH4, 2.3 thousand tons of
N2O, and 0.5 tons of Hg''.\13\
---------------------------------------------------------------------------
\13\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in AEO 2023. AEO2023
represents current Federal and State legislation and final
implementation of regulations as of the time of its preparation. See
section IV.J of this document for further discussion of AEO2023
assumptions that affect air pollutant emissions.
---------------------------------------------------------------------------
DOE estimates the value of climate benefits from a reduction in
greenhouse gases (``GHG'') using four different estimates of the social
cost of CO2 (``SC-CO2''), the social cost of
methane (``SC-CH4''), and the social cost of nitrous oxide
(``SC-N2O''). Together these represent the social cost of
GHG (``SC-GHG''). DOE used interim SC-GHG values developed by an
Interagency Working Group on the Social Cost of Greenhouse Gases
(``IWG'').\14\ The derivation of these values is discussed in section
IV.K of this document. For presentational purposes, the climate
benefits associated with the average SC-GHG at a 3 percent discount
rate are estimated to be $11.9 billion. DOE does not have a single
central SC-GHG point estimate and it emphasizes the importance and
value of considering the benefits calculated using all four sets of SC-
GHG estimates.
---------------------------------------------------------------------------
\14\ To monetize the benefits of reducing GHG emissions, this
analysis uses the interim estimates presented in the Technical
Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990, published in February
2021 by the IWG (``February 2021 SC-GHG TSD''). www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupport
Document_SocialCostofCarbonMethaneNitrous Oxide.pdf.
---------------------------------------------------------------------------
DOE estimated the monetary health benefits of SO2 and
NOX emissions reductions using benefit per ton estimates
from the scientific literature, as discussed in section IV.L of this
document. DOE did not monetize the reduction in mercury emissions
because the quantity is very small. DOE estimated the present value of
the health benefits would be $8.2 billion using a 7 percent discount
rate, and $23.4 billion
[[Page 3724]]
using a 3 percent discount rate.\15\ DOE is currently only monetizing
(for SO2 and NOX) PM2.5 precursor
health benefits and (for NOX) ozone precursor health
benefits, but will continue to assess the ability to monetize other
effects such as health benefits from reductions in direct
PM2.5 emissions.
---------------------------------------------------------------------------
\15\ DOE estimates the economic value of these emissions
reductions resulting from the considered trial standards levels
(``TSLs'') for the purpose of complying with the requirements of
Executive Order 12866.
---------------------------------------------------------------------------
Table I-8 summarizes the monetized benefits and costs expected to
result from the proposed standards for GFBs. There are other important
unquantified effects, including certain unquantified climate benefits,
unquantified public health benefits from the reduction of toxic air
pollutants and other emissions, unquantified energy security benefits,
and distributional effects, among others.
[[Page 3725]]
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[[Page 3726]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.010
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The monetary values for the
total annualized net benefits are (1) the reduced consumer operating
costs, minus (2) the increase in product purchase prices and
installation costs, plus (3) the monetized value of climate and health
benefits of emission reductions, all annualized.\16\
---------------------------------------------------------------------------
\16\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2024, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2030), and then discounted the present value from each year
to 2024. Using the present value, DOE then calculated the fixed
annual payment over a 30-year period, starting in the compliance
year, that yields the same present value.
---------------------------------------------------------------------------
The national operating cost savings are domestic private U.S.
consumer monetary savings that occur as a result of purchasing the
covered products and are measured for the lifetime of GFBs shipped in
2030-2059. The benefits associated with reduced emissions achieved as a
result of the proposed standards are also calculated based on the
lifetime of GFBs shipped in 2030-2059. Total benefits for both the 3
percent and 7 percent cases are presented using the average GHG social
costs with a 3-percent discount rate.\17\ Estimates of total benefits
are presented for all four SC-GHG discount rates in section V.B.6 of
this document.
---------------------------------------------------------------------------
\17\ As discussed in section IV.L.1 of this document, DOE agrees
with the IWG that using consumption-based discount rates e.g., 3
percent) is appropriate when discounting the value of climate
impacts. Combining climate effects discounted at an appropriate
consumption-based discount rate with other costs and benefits
discounted at a capital-based rate (i.e., 7 percent) is reasonable
because of the different nature of the types of benefits being
measured.
---------------------------------------------------------------------------
Table I-9 presents the total estimated monetized benefits and costs
associated with the proposed standard, expressed in terms of annualized
values. The results under the primary estimate are as follows.
Using a 7 percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and the 3 percent discount rate case for climate benefits
from reduced GHG emissions, the estimated cost of the standards
proposed in this rule is $329 million per year in increased equipment
costs, while the estimated annual benefits are $1,880 million in
reduced equipment operating costs, $703 million in monetized climate
benefits, and $932 million in monetized health benefits. In this case,
the monetized net benefit would amount to $3,185 million per year.
Using a 3 percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $340 million per year in
increased equipment costs, while the estimated annual benefits are
$2,524 million in reduced operating costs, $703 million in monetized
climate benefits, and $1,384 million in monetized health benefits. In
this case, the monetized net benefit would amount to $4,271 million per
year.
[[Page 3727]]
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[[Page 3728]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.012
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this document.
2. Air Circulating Fans
DOE's analyses indicate that the proposed energy conservation
standards for ACFs would save a significant amount of energy. Relative
to the case without new standards, the lifetime energy savings for ACFs
purchased in the 30-year period that begins in the anticipated first
full year of compliance with the new standards (2030-2059) amount to
4.5 quadrillion British thermal units (``Btu''), or quads.\18\ This
represents a savings of 37.3 percent relative to the energy use of
these products in the case without standards (referred to as the ``no-
new-standards case'').
---------------------------------------------------------------------------
\18\ The quantity refers to full-fuel-cycle (``FFC'') energy
savings. FFC energy savings includes the energy consumed in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and, thus, presents a more complete
picture of the impacts of energy efficiency standards. For more
information on the FFC metric, see section IV.H.2 of this document.
---------------------------------------------------------------------------
The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for ACFs ranges from $5.3 billion
(at a 7 percent discount rate) to $12.6 billion (at a 3 percent
discount rate). This NPV expresses the estimated total value of future
operating-cost savings minus the estimated increased equipment costs
for ACFs purchased in 2030-2059.
In addition, the proposed standards for ACFs are projected to yield
significant environmental benefits. DOE estimates that the proposed
standards would result in cumulative emission reductions (over the same
period as for energy savings) of 78.5 Mt \19\ of CO2, 19.7
thousand tons of SO2, 148.0 thousand tons of NOX,
686.7 thousand tons of CH4, 0.6 thousand tons of
N2O, and 0.1 tons of mercury Hg.\20\
---------------------------------------------------------------------------
\19\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\20\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in AEO2023. AEO2023
represents current Federal and State legislation and final
implementation of regulations as of the time of its preparation. See
section IV.K of this document for further discussion of AEO2023
assumptions that affect air pollutant emissions.
---------------------------------------------------------------------------
DOE estimates the value of climate benefits from a reduction in
greenhouse gases (GHG) using four different estimates of the social
cost of CO2 (``SC-CO2''), the social cost of
methane (``SC-CH4''), and the social cost of nitrous oxide
(``SC-N2O''). Together these represent the social cost of
GHG (SC-GHG). DOE used interim SC-GHG values developed by an
Interagency Working Group on the Social Cost of Greenhouse Gases
(IWG).\21\ The derivation of these values is discussed in section IV.L
of this document. For presentational purposes, the climate benefits
associated with the average SC-GHG at a 3 percent discount rate are
estimated to be $4.4 billion. DOE does not have a single central SC-GHG
point estimate and it emphasizes the importance and value of
considering the benefits calculated using all four sets of SC-GHG
estimates.
---------------------------------------------------------------------------
\21\ To monetize the benefits of reducing GHG emissions, this
analysis uses the interim estimates presented in the Technical
Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive order 13990, published in February
2021 by the IWG.
---------------------------------------------------------------------------
DOE estimated the monetary health benefits of SO2 and
NOX emissions reductions using benefit per ton estimates
from the scientific literature, as discussed in section IV.L of this
document. DOE did not monetize the reduction in mercury emissions
because the quantity is very small. DOE estimated the present value of
the health benefits would be $3.1 billion using a 7-percent discount
rate, and $8.2 billion using a 3-percent discount rate.\22\ DOE
[[Page 3729]]
is currently only monetizing (for SO2 and NOX)
PM2.5 precursor health benefits and (for NOX)
ozone precursor health benefits, but will continue to assess the
ability to monetize other effects such as health benefits from
reductions in direct PM2.5 emissions.
---------------------------------------------------------------------------
\22\ DOE estimates the economic value of these emissions
reductions resulting from the considered TSLs for the purpose of
complying with the requirements of Executive Order 12866.
---------------------------------------------------------------------------
Table I-10 summarizes the monetized benefits and costs expected to
result from the proposed standards for ACFs. There are other important
unquantified effects, including certain unquantified climate benefits,
unquantified public health benefits from the reduction of toxic air
pollutants and other emissions, unquantified energy security benefits,
and distributional effects, among others.
[[Page 3730]]
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[[Page 3731]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.014
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The monetary values for the
total annualized net benefits are (1) the reduced consumer operating
costs, minus (2) the increase in product purchase prices and
installation costs, plus (3) the monetized value of climate and health
benefits of emission reductions, all annualized.\23\
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\23\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2022, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2030), and then discounted the present value from each year
to 2022. Using the present value, DOE then calculated the fixed
annual payment over a 30-year period, starting in the compliance
year, that yields the same present value.
---------------------------------------------------------------------------
The national operating cost savings are domestic private U.S.
consumer monetary savings that occur as a result of purchasing the
covered products and are measured for the lifetime of GFBs shipped in
2030-2059. The benefits associated with reduced emissions achieved as a
result of the proposed standards are also calculated based on the
lifetime of GFBs shipped in 2030-2059. Total benefits for both the 3
percent and 7 percent cases are presented using the average GHG social
costs with 3 percent discount rate.\24\ Estimates of total benefits are
presented for all four SC-GHG discount rates in section V.B.6 of this
document.
---------------------------------------------------------------------------
\24\ As discussed in section IV.L.1 of this document, DOE agrees
with the IWG that using consumption-based discount rates e.g., 3
percent) is appropriate when discounting the value of climate
impacts. Combining climate effects discounted at an appropriate
consumption-based discount rate with other costs and benefits
discounted at a capital-based rate (i.e., 7 percent) is reasonable
because of the different nature of the types of benefits being
measured.
---------------------------------------------------------------------------
Table I-11 presents the total estimated monetized benefits and
costs associated with the proposed standard, expressed in terms of
annualized values. The results under the primary estimate are as
follows.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated cost of the standards
proposed in this rule is $31 million per year in increased equipment
costs, while the estimated annual benefits are $626 million in reduced
equipment operating costs, $261 million in monetized climate benefits,
and $353 million in monetized health benefits. In this case. The net
monetized benefit would amount to $1,209 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $34 million per year in
increased equipment costs, while the estimated annual benefits are $778
million in reduced operating costs, $261 million in monetized climate
benefits, and $485 million in monetized health benefits. In this case,
the monetized net benefit would amount to $1,489 million per year.
[[Page 3732]]
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[[Page 3733]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.016
BILLING CODE 6450-01-C
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this document.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. Specifically, with regards to
technological feasibility products achieving these standard levels are
already commercially available for all equipment classes covered by
this proposal. As for economic justification, DOE's analysis shows that
the benefits of the proposed standard exceed, to a great extent, the
burdens of the proposed standards.
Using a 7-percent discount rate for consumer benefits and costs and
NOX and SO2 reduction benefits, and a 3-percent
discount rate case for GHG social costs, the estimated cost of the
proposed standards for GFBs is $329 million per year in increased GFB
costs, while the estimated annual benefits are $1,880 million in
reduced GFB operating costs, $703 million in monetized climate benefits
and $932 million in monetized health benefits. The net monetized
benefit amounts to $3,185 million per year. DOE notes that the net
benefits are substantial even in the absence of the climate
benefits,\25\ and DOE would adopt the same standards in the absence of
such benefits.
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\25\ The information on climate benefits is provided in
compliance with Executive Order 12866.
---------------------------------------------------------------------------
Using a 7-percent discount rate for consumer benefits and costs and
NOX and SO2 reduction benefits, and a 3-percent
discount rate case for GHG social costs, the estimated cost of the
proposed standards for ACFs is $31 million per year in increased ACF
costs, while the estimated annual benefits are $626 million in reduced
ACF operating costs, $261 million in monetized climate benefits and
$353 million in monetized health benefits. The net monetized benefit
amounts to $1,209 million per year.
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\26\ For
example, some covered products and equipment have substantial energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
products with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis.
---------------------------------------------------------------------------
\26\ Procedures, Interpretations, and Policies for Consideration
in New or Revised Energy Conservation Standards and Test Procedures
for Consumer Products and Commercial/Industrial Equipment, 86 FR
70892, 70901 (Dec. 13, 2021).
---------------------------------------------------------------------------
As previously mentioned, the proposed standards are projected to
result in estimated national energy savings of 13.8 quad FFC for GFBs
and 4.5 quads FFC for ACFs, the equivalent of the primary annual energy
use of 148 and 48 million homes, respectively. In addition, they are
projected to reduce CO2 emissions by 239.4 Mt and 78.5 Mt,
for GFBs and ACFs, respectively. Based on these findings, DOE has
initially determined the energy savings from the proposed standard
levels are ``significant'' within the meaning of 42 U.S.C.
6295(o)(3)(B). A more detailed discussion of the basis for these
tentative conclusions is contained in the remainder of this document
and the NOPR TSD.
DOE also considered more-stringent energy efficiency levels as
potential standards, and is still considering them in this rulemaking.
However, DOE has tentatively concluded that the potential burdens of
the more stringent energy
[[Page 3734]]
efficiency levels would outweigh the projected benefits.
Based on consideration of the public comments DOE receives in
response to this document and related information collected and
analyzed during the course of this rulemaking effort, DOE may adopt
energy efficiency levels presented in this document that are either
higher or lower than the proposed standards, or some combination of
level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed rule, as well as some of the relevant
historical background related to the establishment of standards for
fans and blowers.
A. Authority
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. Title III, Part
C 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'').\27\ EPCA
also provides that ``covered equipment'' includes any other type of
industrial equipment for which the Secretary of Energy (``the
Secretary'') determines inclusion is necessary to carry out the purpose
of Part A-1. (42 U.S.C. 6311(1)(L); 42 U.S.C. 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, the subjects of this
document. (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; 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 concluding that the inclusion of fans and blowers as
covered equipment was necessary to carry out the purpose of Part A-1
and classifying fans and blowers as covered equipment. 86 FR 46579,
46588.
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\27\ ``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) the establishment of Federal
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) There are currently no Federal
energy conservation standards for fans and blowers. However, as noted
in the Existing Efficiency Standards subsection of section IV.C.1.b of
this document, the California Energy Commission (``CEC'') has finalized
a rulemaking that requires manufacturers to report fan operating
boundaries that result in operation at a FEI of greater than or equal
to 1.00 for all fans within the scope of that rulemaking.\28\ The scope
of the CEC rulemaking includes some, but not all, GFBs that are
considered in the scope of this energy conservation rulemaking. The CEC
rulemaking goes into effect on November 1, 2023. However, if the
Federal standards in this NOPR are finalized and made effective, they
will supersede the CEC standard requirements. The CEC standards with
respect to fans and blowers covered by a standard set in a final rule
would be superseded once the Federal standard takes effect, meaning on
the compliance date applicable to GFBs, which is expected to be 5 years
after the publication of any final rule. 42 U.S.C. 6316(a)(10).
---------------------------------------------------------------------------
\28\ California Energy Commission. Commercial and Industrial
Fans and Blowers. Docket No. 22-AAER-01. Available at
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
---------------------------------------------------------------------------
Furthermore, EPCA prescribes that all representations of energy
efficiency and energy use, including those made on marketing materials
and product labels, for certain equipment, including fans and blowers,
must be made in accordance with an amended test procedure, beginning
180 days after publication of the final rule in the Federal Register.
(42 U.S.C. 6314(d)(1)) DOE notes that Federal test procedures generally
supersede any State regulation insofar as such State regulation
provides for the disclosure of information with respect to any measure
of energy consumption or water use of any covered product (42 U.S.C
6297(a)(1)) The Federal test procedure for fans and blowers was
published on May 1, 2023, and all representations of energy efficiency
and energy use, including those made on marketing materials and product
labels, must be made in accordance with this test procedure beginning
October 30, 2023. 88 FR 27312. Therefore, DOE notes that any disclosure
of information regarding any measure of energy consumption for fans
required by the CEC must be tested in accordance with the Federal test
procedure beginning October 30, 2023.
DOE may, however, grant waivers of Federal preemption for
particular State laws or regulations, in accordance with the procedures
and other provisions set forth under EPCA. (See 42 U.S.C. 6316(a)
(applying the preemption waiver provisions of 42 U.S.C. 6297).)
Subject to certain criteria and conditions, DOE is required to
develop test procedures to measure the energy efficiency, energy use,
or estimated annual operating cost of each covered equipment. (42
U.S.C. 6295(o)(3)(A) and 42 U.S.C. 6295I) Manufacturers of covered
equipment must use the Federal test procedures as the basis for: (1)
certifying to DOE that their equipment complies with the applicable
energy conservation standards adopted pursuant to EPCA (42 U.S.C.
6316(a); 42 U.S.C. 6295(s)), and (2) making representations about the
efficiency of that equipment (42 U.S.C. 6314(d)). Similarly, DOE must
use these test procedures to determine whether the equipment complies
with relevant standards promulgated under EPCA. (42 U.S.C. 6316(a); 42
U.S.C. 6295(s)) The DOE test procedures for fans and blowers appear at
title 10 of the Code of Federal Regulations (``CFR'') part 431, subpart
J, appendices A and B.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered equipment, including fans and blowers.
Any new or
[[Page 3735]]
amended standard for covered equipment must be designed to achieve the
maximum improvement in energy efficiency that the Secretary of Energy
determines is technologically feasible and economically justified. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(3)(B))
Furthermore, DOE may not adopt any standard that would not result in
the significant conservation of energy. (42 U.S.C. 6316(a); (42 U.S.C.
6295(o)(3))
Moreover, DOE may not prescribe a standard: (1) for certain
equipment, including fans and blowers, if no test procedure has been
established for the equipment, or (2) if DOE determines by rule that
the standard is not technologically feasible or economically justified.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a
proposed standard is economically justified, DOE must determine whether
the benefits of the standard exceed its burdens. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after
receiving comments on the proposed standard, and by considering, to the
greatest extent practicable, the following seven statutory factors:
(1) The economic impact of the standard on manufacturers and
consumers of the equipment subject to the standard;
(2) The savings in operating costs throughout the estimated average
life of the covered equipment in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered equipment that are likely to result from the standard;
(3) The total projected amount of energy (or, as applicable, water)
savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered
equipment likely to result from the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (``Secretary'') considers
relevant.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA establishes a rebuttable presumption that a standard
is economically justified if the Secretary finds that the additional
cost to the consumer of purchasing equipment complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an ``anti-backsliding''
provision, which prevents the Secretary from prescribing any amended
standard that either increases the maximum allowable energy use or
decreases the minimum required energy efficiency of covered equipment.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(1)) Also, the Secretary may not
prescribe an amended or new standard if interested persons have
established by a preponderance of the evidence that the standard is
likely to result in the unavailability in the United States in any
covered equipment type (or class) of performance characteristics
(including reliability), features, sizes, capacities, and volumes that
are substantially the same as those generally available in the United
States. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for covered equipment that has two or more
subcategories. DOE must specify a different standard level for a type
or class of equipment that has the same function or intended use, if
DOE determines that equipment within such group: (A) consume a
different kind of energy from that consumed by other covered equipment
within such type (or class); or (B) have a capacity or other
performance-related feature which other equipment within such type (or
class) do not have and such feature justifies a higher or lower
standard. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q)(1)) In determining
whether a performance-related feature justifies a different standard
for a group of equipment, DOE must consider such factors as the utility
to the consumer of the feature and other factors DOE deems appropriate.
Id. Any rule prescribing such a standard must include an explanation of
the basis on which such higher or lower level was established. (42
U.S.C. 6316(a); 42 U.S.C. 6295(q)(2))
B. Background
1. Current Standards
DOE does not currently have energy conservation standards for fans
and blowers. The following section summarizes relevant background
information regarding DOE's consideration of energy conservation
standards for fans and blowers.
On May 10, 2021, DOE published a request for information requesting
comments on a potential fan or blower definition. 86 FR 24752. DOE
followed this with a publication of a final determination on August 19,
2021, classifying fans and blowers as covered equipment (``August 2021
Final Coverage Determination''). 86 FR 46579. At this time, DOE
determined that the term ``blower'' is used interchangeably in the U.S.
market with the term ``fan.'' 86 FR 46579, 46583. DOE defines a fan (or
blower) as a rotary bladed machine used to convert electrical or
mechanical power to air power, with an energy output limited to 25
kilojoule (``kJ'') per kilogram (``kg'') of air. It consists of an
impeller, a shaft and bearings and/or driver to support the impeller,
as well as a structure or housing. A fan (or blower) may include a
transmission, driver, and/or motor controller. 10 CFR 431.172.
2. History of Standards Rulemaking for Fans and Blowers
In considering whether to establish standards, on June 28, 2011 DOE
published a notice of proposed determination of coverage to initiate an
energy conservation standards rulemaking for fans, blowers, and fume
hoods. 76 FR 37678. Subsequently, DOE published a notice of public
meeting and availability of the Framework document for GFBs in the
Federal Register. 78 FR 7306 (February 1, 2013). In the Framework
document (``2013 Framework Document''), DOE requested feedback from
interested parties on many issues, including the engineering analysis,
the MIA, the LCC and PBP analyses, and the national impact analysis
(``NIA'').
On December 10, 2014, DOE published a notice of data availability
(``December 2014 NODA'') that estimated the potential economic impacts
and energy savings that could result from promulgating energy
conservation standards for fans. 79 FR 73246. The December 2014 NODA
analysis used FEI, a ``wire-to-air'' fan electrical input power metric,
to characterize fan performance.
In October 2014, several representatives of fan manufacturers and
energy efficiency advocates \29\ (``Joint Stakeholders'') presented DOE
with an alternative metric approach, the ``Fan Efficiency Ratio,''
which included a fan efficiency-only metric approach
(``FERH'') and a wire-to-air metric approach
(``FERW'').\30\ On May 1, 2015,
[[Page 3736]]
based on the additional information received and comments to the
December 2014 NODA, DOE published a second NODA (``May 2015 NODA'')
that announced data availability from DOE analyses conducted using a
modified FEI metric, similar to the FERW metric presented by
the Joint Stakeholders. 80 FR 24841, 24843.
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\29\ The Air Movement and Control Association (AMCA), New York
Blower Company, Natural Resources Defense Council (NRDC), the
Appliance Standards Awareness Project (ASAP), and the Northwest
Energy Efficiency Alliance (NEEA).
\30\ Supporting documents from this meeting, including
presentation slides are available at www.regulations.gov/document?D=EERE-2013-BT-STD-0006-0029.
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Concurrent with these efforts, DOE established an Appliance
Standards Rulemaking Federal Advisory Committee (``ASRAC'') Working
Group (``Working Group'') to discuss negotiated energy conservation
standards and test procedures for fans.\31\
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\31\ Information on the ASRAC, the commercial and industrial
fans Working Group, and meeting dates is available at: energy.gov/eere/buildings/appliance-standards-and-rulemaking-federal-advisory-committee.
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The Working Group concluded its negotiations on September 3, 2015,
and, by consensus vote,\32\ 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)
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\32\ 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 4 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 the term sheet.
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On November 1, 2016, DOE published a third notification of data
availability (``November 2016 NODA'') that presented a revised analysis
for GFBs consistent with the scope and metric recommendations in the
term sheet. 81 FR 75742, 75743. As recommended by the working group,
the November 2016 NODA used the fan electrical input power metric (FEP)
\33\ in conjunction with FEI to characterize fan performance. DOE made
several additional updates to the November 2016 NODA to address the
term sheet recommendations developed by the Working Group as well as
stakeholder feedback submitted via public comment. Specifically, the
analysis presented in the November 2016 NODA was updated to include (1)
augmentation of the Air Movement and Control Association International
(``AMCA'') sales data used in the May 2015 NODA to better account for
fans made by companies that incorporate those fans for sale in their
own equipment, (2) augmentation of the AMCA sales data to represent
additional sales of forward-curved fans, and (3) inclusion of original
equipment manufacturer (``OEM'') conversion costs. Id. The November
2016 NODA evaluated only fans with a fan shaft input power equal to, or
greater than, 1 horsepower (``hp'') and a fan airpower equal to or less
than 150 hp. 81 FR 75742, 75746.
---------------------------------------------------------------------------
\33\ The FEP metric represents the electrical input power of the
fan and includes the performance of the motor, and any transmission
and/or control if integrated, assembled, or packaged with the fan.
In the November 2016 NODA, DOE developed standards based on FEI
values evaluated relative to the EL 3 standard FEP.
---------------------------------------------------------------------------
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
definitions and potential scope for ACFs. 86 FR 54412, 54414-54415. DOE
published a separate request for information on February 8, 2022
(``February 2022 RFI''), to seek input to aid in its development of the
technical and economic analyses regarding whether standards for ACFs
may be warranted. 87 FR 7048. On October 13, 2022, DOE published a
notice of data availability (``October 2022 NODA'') to present its
preliminary engineering analysis for ACFs and to seek input to support
DOE in completing a notice of proposed rulemaking analysis for all fans
and blowers. 87 FR 62038.
DOE received comments in response to the October 2022 NODA from the
interested parties listed in Table II-1.
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[[Page 3738]]
BILLING CODE 6450-01-C
DOE also acknowledges that it received numerous identical comments
via a mass email campaign stating that standards for fans and blowers
is an important issue and requesting that DOE pursue an approach that
is fair and equitable to both businesses and consumers. \34\
---------------------------------------------------------------------------
\34\ Comment numbers 14-118 in the docket (Docket No. EERE-2022-
BT-STD-0002, maintained at www.regulations.gov).
---------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\35\
---------------------------------------------------------------------------
\35\ 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, maintained at www.regulations.gov). The
references are arranged as follows: (commenter name, comment docket
ID number, page of that document).
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C. Deviation From Process Rule
In accordance with section 3(a) of 10 CFR part 430, subpart C,
appendix A (``Process Rule''), DOE notes that it is deviating from the
provision in the Process Rule regarding the pre-NOPR and NOPR stages
for an energy conservation standards rulemaking.
1. Framework Document
Section 6(a)(2) of the Process Rule states that if DOE determines
it is appropriate to proceed with a rulemaking, the preliminary stages
of a rulemaking to issue or amend an energy conservation standard that
DOE will undertake will be a framework document and preliminary
analysis, or an advance notice of proposed rulemaking.
As described in section II.B.2 of this document, DOE published the
2013 Framework Document, the December 2014 NODA, the May 2015 NODA, and
the November 2016 NODA for GFBs. 78 FR 7306; 79 FR 73246; 80 FR 24841;
81 FR 75742. The three NODAs presented DOE's analysis at various
points, provided stakeholders opportunity to review and provide
comment. Furthermore, while DOE published the February 2022 RFI and
October 2022 NODA for ACFs, DOE did not publish a framework document in
conjunction with the NODA for ACFs. 87 FR 62038. DOE notes that ACFs
and GFBs are analyzed separately, however, the general analytical
framework that DOE uses in evaluating and developing potential new
energy conservation standards for both GFBs and ACFs is similar. As
such, publication of a separate framework document for ACFs would be
largely redundant of previously published documents.
2. Public Comment Period
Section 6(f)(2) of the Process Rule specifies that the length of
the public comment period for a NOPR will be not less than 75 calendar
days. For this NOPR, DOE is instead providing a 60-day comment period,
consistent with EPCA requirements. 42 U.S.C. 6316(a); 42 U.S.C.
6295(p). DOE is opting to deviate from the 75-day comment period
because of the robust opportunities already afforded to stakeholders to
provide comments on this proposed rulemaking.
DOE is providing a 60-day comment period, which DOE believes is
appropriate given the substantial stakeholder engagement for general
fans and blowers to date, as discussed in section II.B.2 of this
document. Furthermore, the request for information on air circulating
fans that was published on February 8, 2022, provided early notice to
interested parties that DOE was interested in evaluating potential
energy conservation standards for air circulating fans. DOE also
provided a 45-day comment period for the notice of data availability
that was published on October 13, 2022. Therefore, DOE believes a 60-
day comment period is appropriate and will provide interested parties
with a meaningful opportunity to comment on the proposed rule.
III. General Discussion
DOE developed this proposal after considering oral and written
comments, data, and information from interested parties that represent
a variety of interests. The following discussion addresses issues
raised by these commenters.
A. General Comments
This section summarizes general comments received from interested
parties in response to the October 2022 NODA regarding rulemaking
timing, process, and impact.
In response to many of DOE's requests for comment, AMCA recommended
that DOE obtain the requested information through confidential
interviews with fan manufacturers. (AMCA, No. 132 at pp. 6-14) DOE
notes that it used information collected during manufacturer interviews
to inform its engineering, market, and manufacturer analyses.
NEMA commented that its interpretation of DOE's analysis in the
October 2022 NODA was that DOE was proposing energy efficiency
requirements for motors that are used in ACFs, which would be confusing
and problematic for the motor industry, since there is a separate
rulemaking for motors. (NEMA, No. 125 at pp. 2, 4). Additionally, NEMA
stated that DOE's inclusion of higher efficiency small, non-``small
electric motor'' electric motors (``SNEMs'') as a technology option for
increasing the efficiency of ACFs could be an issue because of an
ongoing rulemaking for SNEMs. (NEMA, No. 125 at p. 2) DOE notes that in
a NOPR for expanded scope electric motors (``ESEMs'') published on
December 15, 2023 (``December 2023 ESEM NOPR''), motors that were
previously referred to as SNEMs were redefined to be ESEMs. 88 FR 87062
DOE will use the term ``ESEM'' throughout the remainder of this
document to refer to these motors. Morrison commented that it is
concerned about the small motors rulemaking being in progress at the
same time as this fans and blowers rulemaking. (Morrison, No. 128 at p.
1)
DOE notes that it is proposing energy conservation standards for
fans and blowers, including ACFs and GFBs, and that it is not proposing
energy conservation standards for motors in this rulemaking. DOE
typically defines a likely design path to structure its engineering
analysis; however, DOE notes that this design path is not prescriptive.
DOE heard from ACF manufacturers that replacing a less efficient motor
with a more efficient motor would be one of the first options they
would evaluate. Therefore, DOE considered more efficient motors as an
option that a manufacturer might apply to reach a given ACF efficiency
level. DOE acknowledges that the electric motors rulemaking involving
ESEMs is ongoing (see EERE-2020-BT-STD-0007) and that stakeholders made
a joint recommendation for the efficiencies at which they believe the
standards for ESEMs should be set. (Docket No. EERE-2020-BT-STD-0007,
Joint Stakeholders, No. 38 at p. 6, Table 2) As discussed in section
IV.C.2.c, DOE defined an efficiency level (EL 2) in its ACF engineering
analysis based on the efficiencies recommended for ESEMs by the Joint
Stakeholders. DOE may consider adjusting the baseline efficiency level
for ACFs if it sets a standard in the ESEM rulemaking at the
recommended ESEM levels.
AMCA commented that it generally supports NEMA's comments. (AMCA,
No. 132 at pp. 2, 21) DOE therefore notes that throughout this
document, reference to comments made by NEMA are understood to be
representative of the viewpoints of AMCA as well.
Greenheck stated that it would be beneficial for the ACF rulemaking
to be delayed until after AMCA 230-2023 is
[[Page 3739]]
published. (Greenheck, No. 122 at p. 1) AMCA commented that DOE should
finalize a test procedure before proceeding with its fans and blowers
energy conservation standards rulemaking so that stakeholders can make
informed comments on the energy conservation standards rulemaking.
(AMCA, No. 132 at p. 10) DOE notes that ACMA 230-23 was published on
February 10, 2023, and that DOE has since published its test procedure
final rule for fans and blowers, on May 1, 2023. 88 FR 27312.
MIAQ commented that it disagrees with DOE's decision to provide a
45-day comment period instead of the usual 75-day comment period for
the October 2022 NODA. (MIAQ, No. 124 at p. 2) In the October 2022
NODA, DOE discussed its decision to deviate from section 3(a) of
appendix A to subpart C of 10 CFR part 430 and reduce the comment
period. 87 FR 62038, 62039. DOE provided a 45-day comment period given
the substantial stakeholder engagement prior to the publication of the
NODA and to provide DOE with ample time to review comments to inform
this NOPR analysis. Id.
The CA IOUs commented that they are concerned that the energy
conservation standards may supersede the fan input power limits
currently in place for building codes, such as the California Building
Energy Code (Title 24), American Society of Heating, Refrigerating, and
Air-Conditioning Engineers (``ASHRAE'') Standard 90.1, ``Energy
Standard for Buildings Except Low-Rise Residential Buildings,'' and the
International Energy Conservation Code (``IECC'') 2021, which would
reduce the influence of these building codes and ultimately result in
an increase in the energy consumption of the equipment in which fans
are embedded because the fan power limits in those codes are
significantly more stringent than the FEI requirements and ensure the
overall fan system in a building is designed efficiently. (CA IOUs, No.
127 at p. 6) Damas and Boldt also expressed their concern that energy
conservation standards may preempt the limits on fan system power in
building energy codes such as ASHRAE 90.1 and therefore could
potentially increase energy use in new construction. (Damas and Boldt,
No. 131 at p. 5) AHRI commented that an energy conservation standard is
not needed for fans because all States are obligated to comply with
ASHRAE 90.1. (AHRI, No. 130 at pp. 16-17)
DOE notes that neither ASHRAE 90.1 nor IECC 2021 are federally
mandated standards. Although ASHRAE 90.1 and IECC 2021 may be
incorporated into municipal and/or building codes, this is not required
and is performed on a State and local level. Furthermore, their
incorporation does not always mandate standard efficiency requirements.
DOE also acknowledges that as stated in section II.A, 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) Therefore, if energy conservation standards for
fans and blowers were to be adopted, they would supersede State laws
and regulations for the efficiency of individual fans and blowers at
the product or equipment level. DOE considered the fan efficiency
requirements in ASHRAE 90.1 and IECC 2021 in its analysis, as discussed
in section IV.C.1.b of this document. With regard to CA IOUs concern
that DOE's regulation would supersede current regulations for fan input
power limits, DOE notes that the standards proposed in this NOPR apply
only to individual fans, whether embedded or standalone, that are
within the proposed scope of this rulemaking. DOE is not proposing
minimum input power requirements for fan systems that may be
incorporated into buildings. Therefore, although the individual fans
used in fan systems would be required to comply with DOE's minimum FEI
requirements if the fan is within the proposed scope of this
rulemaking, DOE's proposed regulations would not supersede input power
requirements for fan systems.
B. Scope of Coverage
This NOPR covers those commercial and industrial equipment that
meet the definition of ``fan'' or ``blower,'' as codified at 10 CFR
431.172 and for which DOE has finalized test procedures in subpart J of
10 CFR part 431.
As discussed, DOE defines a ``fan'' or ``blower'' as a rotary
bladed machine used to convert electrical or mechanical power to air
power, with an energy output limited to 25 kJ/kg of air. It consists of
an impeller, a shaft and bearings and/or driver to support the
impeller, as well as a structure or housing. A fan or blower may
include a transmission, driver, and/or motor controller. 10 CFR
431.172. DOE separates fans and blowers into general fans and blowers
and air circulating fans.
An ``air circulating fan'' means 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. 10 CFR 431.172. Fans and blowers
that are not ACFs are referred to as general fans and blowers
(``GFBs'') throughout this document.
In response to the October 2022 NODA, DOE received comments on the
fans considered within the scope of its analysis.
Greenheck, AMCA, and Morrison commented that ACFs should be
considered in a separate rule from GFBs since ACFs and GFBs are
utilized in different applications and use different industry test
procedures (i.e., AMCA 230 for ACFs and AMCA 214 for GFBs). (Greenheck,
No. 122 at p. 1; AMCA, No. 132 at pp. 1, 20-21; Morrison, No. 128 at p.
2)
DOE acknowledges that ACFs and GFBs have separate utilities and
test procedures. In the test procedure final rule that was published on
May 1, 2023 (``May 2023 TP Final Rule''), DOE adopted separate test
procedures for GFBs and ACFs (see appendix A and appendix B,
respectively, to subpart J of 10 CFR part 431). 88 FR 27312. Similarly,
in this NOPR, separate analyses were conducted for ACFs and GFBs to
account for the difference in test procedures, metrics, and utility.
DOE is proposing separate standards for GFBs and ACFs, expressed in
different metrics, as discussed in later sections.
1. General Fans and Blowers
In the May 2023 TP Final Rule, DOE established the scope of the
test procedure. 88 FR 27312. In this NOPR, DOE is proposing energy
conservation standards for GFBs consistent with the scope of coverage
defined in the May 2023 TP Final Rule.
Specifically, in this NOPR, DOE proposes energy conservation
standards for the following GFB categories, as defined in the DOE test
procedure: (1) axial inline fan; (2) axial panel fan; (3) centrifugal
housed fan; (4) centrifugal unhoused fan; (5) centrifugal inline fan;
(6) radial housed fan; and (7) power roof/wall ventilator (``PRV'').
Furthermore, consistent with the DOE test procedure, DOE proposes that
the scope of this energy conservation standards rulemaking for GFBs
would apply to fans with duty points with a fan shaft input power equal
to or greater than 1 hp and a fan static or total air power equal to or
less than 150 hp.
Additionally, DOE did not evaluate or consider potential energy
conservation standards for GFBs that were not included in the scope of
its test procedure. See 10 CFR 431.174. DOE notes that its test
procedure excludes fans that create a vacuum of 30 inches water gauge
or greater. 10 CFR
[[Page 3740]]
431.174(a)(2)(vii) In this NOPR, DOE proposes to further clarify that
this provision excludes fans that are manufactured and marketed
exclusively to create a vacuum of 30 inches water gauge or greater.
DOE requests comment on its proposed clarification for fans that
create a vacuum. Specifically, DOE requests comment on whether fans
that are manufactured and marketed exclusively to create a vacuum of 30
inches water gauge or greater could also be used in positive pressure
applications. Additionally, DOE requests information on the
applications in which a fan not manufactured or marketed exclusively
for creating a vacuum would be used to create a vacuum of 30 inches
water gauge or greater.
Consistent with the test procedure, DOE has excluded certain
embedded fans, listed in Table III-1, from its analysis. See the May
2023 TP Final Rule for a detailed discussion of these exclusions. 88 FR
27312, 27322-27331.
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In response to the October 2022 NODA, DOE received comments
regarding the scope of the energy conservation standards for GFBs.
AHAM agreed with DOE's proposal to only cover GFBs that were rated
at 1 hp or higher because it effectively excluded most fans used in
consumer product applications. (AHAM, No. 123 at p. 5) AHRI commented
that regulating GFBs
[[Page 3742]]
with an input power of less than 1 hp would include residential fans.
(AHRI, No. 130 at p. 3) Morrison expressed concern with the minimum
power limit for GFBs being 0.1 hp instead of 1 hp since most GFBs with
input powers less than 1 hp are not commercial or industrial.
(Morrison, No. 128 at p. 1). DOE interprets Morrison's reference to a
0.1 hp limit to be a reference to the 0.1 hp representative unit for
ACFs in the October 2022 NODA. DOE notes that a minimum power limit of
0.1 hp for GFBs was not proposed in the October 2022 NODA. As
discussed, GFBs with an input power of less than 1 hp are excluded from
the scope of this rulemaking, which is consistent with the scope of
coverage in the DOE test procedure. See 10 CFR 431.174(a)(4)(i).
In response to both the October 2022 NODA and the July 2022 TP
NOPR, AHRI and Morrison commented that they were concerned about how
energy conservation standards would apply to replacement fans.
(Morrison, No. 128 at p. 2; AHRI, No. 130 at pp. 2, 5, 12) Morrison and
AHRI stated that replacement fans should be exempt from the standards
rulemaking because a fan with the same specific performance and safety
devices needs to be used for replacement in order to achieve the same
system performance and to comply with safety requirements. Id. DOE
notes that the comments from AHRI and Morrison submitted in response to
the October 2022 NODA are identical in content to the comments
submitted from these and other stakeholders to the July 2022 NOPR.
These comments are fully summarized in the May 2023 TP Final Rule. 88
FR 27312, 27334.
CA IOUs stated that consumers seeking to replace low-pressure fans
in constrained spaces may not be able to find replacement fans that
meet a higher FEI. Since a more efficient fan may require a larger
diameter, it might not fit in the constrained space. Therefore, either
the constrained space will need to be enlarged to fit the larger fan
(which is likely to be costly for the consumer) or the consumer would
select a replacement fan of the same size but with higher pressure
(resulting in more power use to achieve the same airflow). (CA IOUs,
No. 127 at p. 6) CA IOUs therefore proposed a narrow exception for
[non-embedded] centrifugal fans with a rated pressure not greater than
1.5 inches water gauge. (CA IOUs, No. 127 at p. 7)
Consistent with DOE's response to these comments in the April 2023
Final Rule, DOE is proposing to exclude certain embedded fans from
potential energy conservation standards in this rulemaking, whether
sold for incorporation into the equipment or already incorporated in
the equipment, if embedded in equipment listed in Table III-1. This
approach would exclude replacement fans for the equipment listed in
Table III-1. For equipment not listed in Table III-1, DOE notes that it
is not excluding replacement fans from the scope of the rulemaking,
consistent with the scope of the DOE test procedure. In its analysis,
which is discussed in further detail in section IV.C.1 of this
document, DOE evaluated improved efficiency options while maintaining
constant diameter and duty point (i.e., air flow and operating
pressures remained constant as efficiency increased); therefore, DOE
has tentatively concluded that a compliant fan of the same size and
performance would be available for use as an embedded fan or
replacement for an embedded fan. Additionally, DOE does not expect that
manufacturers of equipment that contain embedded fans would need to
redesign their equipment. Furthermore, DOE is not excluding centrifugal
fans based on its rated pressure. In its analysis, DOE specifically
examined centrifugal housed fans designed at both lower- and higher-
pressure duty points. Based on that analysis, DOE did not find a
significant difference in the achievable FEI values between the higher-
and lower-pressure duty points. Accordingly, DOE has tentatively
determined that centrifugal housed fans do not require an exclusion
based on rated pressure. Additional details on DOE's analysis are
presented in chapter 3 of the accompanying TSD.
DOE also received multiple comments from stakeholders about fans
that should be excluded from the scope of the rulemaking; these
comments were similar to the comments received in response to the July
2022 TP NOPR. Morrison and AHRI commented that they are concerned over
double regulation of products. (Morrison, No. 128 at pp. 2-3; AHRI, No.
130 at p. 2) AHRI commented that fans embedded in boilers and
commercial water heaters should be excluded. (AHRI, No. 130 at pp. 10-
11) DOE notes that these comments were summarized and responded to in
the May 2023 TP Final Rule. 88 FR 27312, 27329-27330. Additionally,
AHRI commented that the regulation of fans within air-cooled water
chillers would not improve the efficiency of the entire equipment, nor
would it lead to net energy savings because ASHRAE 90.1 already sets
efficiency standards for the equipment and the entire system is
designed to meet the ASHRAE 90.1 efficiency standards. (AHRI, No. 130
at pp. 9-10) MIAQ commented that energy conservation standards for
embedded fans would not necessarily improve the performance of the
products in which the fans are embedded if the products are already
regulated. (MIAQ, No. 124 at p. 4)
As previously discussed, DOE is exempting fans embedded in the
equipment listed in Table III-1, consistent with the DOE test
procedure, and continues to exclude fans in covered equipment in which
the fan energy use is already captured in the equipment-specific test
procedures. Furthermore, as discussed in section III.A of this
document, ASHRAE 90.1 is not a federally mandated standard, though it
may be adopted by State and local governments, and therefore DOE is not
specifically exempting fans that are in equipment that are regulated by
IECC and ASHRAE 90.1.
More details regarding the scope of GFBs that are included in this
NOPR can be found in the May 2023 TP Final Rule. 88 FR 27312, 27317-
27336.
2. Air Circulating Fans
In the October 2022 NODA, DOE stated that it was considering all
air circulating fans in its analysis of potential energy conservation
standards for fans and blowers, including unhoused air circulating fan
heads and housed air circulating fan heads. 87 FR 62038, 62041. DOE
received comments from stakeholders in response to the scope discussion
in the October 2022 NODA.
AHAM commented there is a lack of clarity about which products are
included and excluded in DOE's proposed scope and that DOE was
improperly expanding the scope of products included in the fans and
blowers category by including residential products. AHAM stated that it
did not believe that the metric, technology options, assumptions, and
test procedure discussed in the October 2022 NODA are relevant to
residential fans. (AHAM, No. 123 at pp. 1-2) Specifically, AHAM
commented that the proposed test procedure from the July 2022 TP NOPR
and AMCA 214-21 are not applicable to residential fans and that no
energy conservation standards should be set for residential fans until
a test procedure for residential fans is established. (AHAM, No. 123 at
pp. 5, 9) AHAM, Greenheck, and AMCA also commented that ACFs with an
input power less than 125 W should be excluded from scope to coincide
with the scope limit in AMCA 230-23 and IEC 60879. (AHAM, No. 123
[[Page 3743]]
at pp. 5-6; Greenheck, No. 122 at p. 2; AMCA, No. 132 at pp. 1-2, 19-
20) AHAM noted that this would effectively differentiate between
residential and consumer products, so long as the 125 W threshold
applies to the fan rating alone and not to the entire product or the
fan and motor. (AHAM, No. 123 at p. 5) DOE notes that ACFs are tested
in a configuration that measures electrical input power to the fan,
inclusive of the motor, and that the existing test procedures (i.e.,
AMCA 230-23 or IEC 60879:2019) do not allow measuring the mechanical
shaft power to the fan, exclusive of the motor. Therefore, DOE has
determined that a limit in terms of electrical input power (applicable
to the fan and motor) is more appropriate. DOE notes that AHAM
submitted additional comments recommending exclusion of residential
fans and fans embedded in residential products that were also submitted
in response to the July 2022 TP NOPR. (AHAM, No. 123 at pp. 2-5) DOE
addressed those comments in the May 2023 TP Final Rule. 88 FR 27312,
27326. In the May 2023 TP Final Rule, DOE established the scope of the
test procedure for ACFs and excluded ACFs with an input power of less
than 125 W at maximum speed. 88 FR 27312, 27331. In this NOPR, DOE is
proposing energy conservation standards for ACFs consistent with the
scope of coverage defined in the May 2023 TP Final Rule. (see 10 CFR
431.174(b)). Therefore, DOE proposes that ACFs with an input power of
less than 125 W at maximum speed are excluded from the scope of this
standards rulemaking. DOE is aware, however, that ACFs with an input
power less than 125 W at maximum speed could be distributed in commerce
for industrial and commercial use, and that ACFs with an input power
greater than 125 W at maximum speed could be distributed in commerce
for residential use. However, any equipment that meets the definition
of air circulating fan, has an input power greater than or equal to 125
W at maximum speed, as measured by the test procedure at high speed,
and is of a type that is not a covered consumer product and is, to any
significant extent, distributed in commerce for industrial or
commercial purposes would be subject to these proposed energy
conservation standards, regardless of whether it is sold for use in
commercial, industrial, or residential settings.
AHAM commented that the terminology used in the October 2022 NODA
for fan head diameter, rather than fan blade diameter, is inconsistent
with how residential ACFs are typically analyzed. (AHAM, No. 123 at p.
8) DOE notes that while it works to use terminology that is consistent
with industry terminology, it is not always possible given the size and
maturity of test standards development in a given industry. DOE
clarifies that its usage of the term ``fan head diameter'' in the
October 2022 NODA was intended to be analogous to ``fan blade
diameter.'' Additionally, DOE notes that it is proposing a definition
for ``diameter'' for fans and blowers that is consistent with the term
``fan blade diameter'' in this NOPR, which is discussed in section
IV.A.1.b of this document.
AHAM also commented that it did not believe that DOE has enough
data on residential fans to analyze them. AHAM stated that DOE's
analysis in the October 2022 NODA had an ACF with a 24-inch (``in.'')
blade and a 0.5 hp motor, which is not representative of residential
ACFs. (AHAM, No. 123 at p. 8) DOE notes that in the October 2022 NODA,
it analyzed ACFs at multiple representative sizes and motor
horsepowers, including a 12 in. diameter, 0.1 motor hp unit; a 20 in.
diameter, 0.33 motor hp unit; a 24 in. diameter, 0.5 motor hp unit; a
36 in. diameter, 0.5 motor hp unit; and 50 in. diameter, 1 motor hp
unit. 87 FR 62038, 62046. DOE had determined that these diameters and
motor horsepowers were representative of the full scope of ACFs
considered in the October 2022 NODA. Id.
AHAM stated that the size of motors that are typically used in
residential ACFs are excluded from the scope of the ongoing electric
motors rulemaking; therefore, residential ACFs should be excluded from
this rulemaking since DOE would not see potential savings. (AHAM, No.
123 at p. 9) DOE notes that this is a rulemaking for fans and blowers.
For ACFs, DOE considers higher-efficiency motors as a design option as
well as other design options but emphasizes that the approach that DOE
uses to evaluate potential efficiency standards is not prescriptive
(see section IV.A.3 of this document). Furthermore, DOE considers both
potential economic and energy savings in its analysis, which is
discussed in section IV.G of this document.
Additionally, AHAM commented that it was their understanding that
the proposed definitions for ACFs in the July 2022 TP NOPR did not
include bladeless fans and agreed with the exclusion of bladeless ACFs
from scope. (AHAM, No. 123 at p. 5) The definition of air circulating
fan, ``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,'' does not exclude bladeless fans. See 10 CFR 431.172. However, as
discussed above, ACFs with input powers less than 125 W at maximum
speed are excluded from the scope of this rulemaking. Therefore,
bladeless fans, which have input power less than 125 W are excluded
from the scope of this NOPR.
NEMA expressed concern that the July 2022 TP NOPR proposed only
including fans with a shaft input power between 1 hp and 150 hp, but
that the October 2022 NODA proposed including fans with a shaft input
power of less than 1 hp. (NEMA, No. 125 at p. 2). DOE notes that, as
specified in the test procedure, the 1 hp and 150 hp limits are
applicable to GFBs, and that GFBs with an input power of less than 1 hp
are excluded from scope. See 10 CFR 431.174(a)(4)(i). Additionally, DOE
clarifies that the 150-hp limit applies to the fan air power. 10 CFR
431.174(a)(4)(ii) DOE notes that the ACF scope evaluated in this NOPR
is consistent with the scope DOE adopted in the May 2023 TP Final Rule,
which excludes ACFs with an input power of less than 125 W. 88 FR
27312, 27333.
a. Ceiling Fan Distinction
DOE explained in the coverage determination that fans and blowers,
the subjects of this rulemaking, do not include ceiling fans, as
defined at 10 CFR 430.2. See 86 FR 46579, 46586 and 10 CFR 431.171.
Therefore, as stated in the May 2023 TP Final Rule, equipment that
meets the definition of a ceiling fan would be excluded from the scope
of equipment included under ``fan and blower''. 88 FR 27312, 27365. A
ceiling fan means a nonportable device that is suspended from a ceiling
for circulating air via the rotation of fan blades. 10 CFR 430.2. In
the ceiling fan test procedure final rule published on August 16, 2022,
DOE finalized an amendment to the ceiling fan definition at 10 CFR
430.2 to specify that a ceiling fan provides ``circulating air,'' which
means ``the discharge of air in an upward or downward direction. A
ceiling fan that has a ratio of fan blade span (in inches) to maximum
rotation rate (in revolutions per minute) greater than 0.06 provides
circulating air.'' 87 FR 50396, 50402. Specifically, the 0.06 in/RPM
ratio was added in the ceiling fans definition to distinguish fans with
directional airflow from circulating airflow. Id.
DOE also finalized a definition for ``high-speed belt-driven
ceiling fan'' (``HSBD'') and added language to clarify that high-speed
belt-driven ceiling fans were to be subject to the AMCA 230-15
[[Page 3744]]
test procedure and subject to a similar efficiency metric as large-
diameter ceiling fans (namely the ceiling fan energy index ``CFEI'').
Id. at 87 FR 50424, 50426, 50431.
In the May 2023 TP Final Rule, DOE established the definitions of
ACF and related terms. DOE defined the term 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''. In
addition, DOE defined an unhoused circulating fan as ``an air
circulating fan without housing, having an axial impeller with a ratio
of fan blade span (in inches) to maximum rate of rotation (in
revolutions per minute) less than or equal to 0.06. The impeller may or
may not be guarded.'' 88 FR 27312, 27389-27390. DOE relied on the blade
span to maximum rpm ratio to distinguish these ACFs from ceiling fans.
87 FR 44194, 44216. For housed ACFs however, DOE defined a housed ACF
as an air circulating fan with an axial or centrifugal impeller, and a
housing. 88 FR 27312, 27390. This definition aligns with the housed ACF
definition in AMCA 230-23 and does not specify a diameter to speed
ratio limit because housed ACFs can have blade span to maximum rpm
ratios that are in the same range as ceiling fans (i.e., greater than
0.06).
In the Ceiling Fan ECS NOPR published on June 22, 2023, DOE noted
that that a ceiling fan must be ``distributed in commerce with
components that enable it to be suspended from a ceiling.'' 88 FR
40932, 40943. Belt-driven fans are often distributed in commerce
without components that enable the fan to be suspended from a ceiling.
For example, some belt-driven fans are sold connected to wheels or to a
pedestal base. In this case, such a fan would not meet the definition
of a ceiling fan because it has not been manufactured to be suspended
from the ceiling, and therefore would not be subject to the HSBD test
procedure or any potential energy conservation standards for HSBDs even
though a consumer could independently purchase their own straps or
chains and elect to hang this fan from the ceiling. 88 FR 40932, 40943.
DOE stated that HSBD ceiling fans, in contrast to belt-driven fans
connected to wheel or a pedestal base, are distributed in commerce with
specific straps, chains, or other similar components that are designed
and tested by the manufacturer to safely support the weight of the
ceiling fan in an overhead configuration. Further, they circulate air
since they meet the 0.06 blade span to maximum rpm ratio. 88 FR 40932,
40943.
Many belt-driven fans are housed (i.e., the fan blades are
contained within a cylindrical enclosure, often with solid metal sides
and a cage on the front and back). However, the presence of a housing
is not relevant in determining whether a product meets the definition
of ceiling fan. While a housing is generally included to better direct
air, a housing could be added to a ceiling fan, including those that
are clearly intended to circulate air. As such, DOE emphasizes that the
definition of a ceiling fan requires that fan to be ``suspended from a
ceiling'' and to ``circulate air'', rather than the presence or absence
of a fan housing. 88 FR 40932, 40943.
In response to the June 2023 Ceiling Fan ECS NOPR (88 FR 40932), CA
IOUs commented that CFEI is not intended for small-diameter ceiling
fans.\36\ (CA IOUs, No. EERE-2021-BT-STD-0011-0049 at p. 3). All HSBD
ceiling fans identified by DOE would be small-diameter ceiling fans.
Therefore, DOE interprets CA IOU's comment to mean that the CFEI metric
is not intended for HSBD ceiling fans. VES also pointed out in response
to the September 2019 Ceiling Fan TP NOPR (84 FR 51440) that they sell
shrouded fans that currently are not subject to ceiling fan energy
conservation standards because they are belt-driven. VES added that if
they transition to a direct-drive motor they would be subject to high-
speed small-diameter ceiling fan standards, which are not appropriate
as the airflow of their products is significantly higher than high-
speed small-diameter ceiling fans given the intended directional
application. (VES, No. EERE-2013-BT-TP-0050-0026 at pp. 1-2)
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\36\ According to the DOE test procedure for ceiling fans at
appendix U to subpart B of 10 CFR part 430, a small diameter ceiling
fan means ``a ceiling fan that has a represented value of blade
span, as determined in 10 CFR 429.32(a)(3)(i), less than or equal to
seven feet.''
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DOE notes that VES did not make a statement as to whether or not
the 0.06 blade span to rpm ratio would appropriately distinguish
between their circulating fans and traditional ceiling fans. However,
as the air circulating fan definitions have pointed out, the 0.06 blade
span to rpm ratio is most appropriate for distinguishing between
unhoused air circulating fans. Housed air circulating fans may exceed
the 0.06 blade span to rpm ratio and commonly do, despite the fact that
they are typically thought of in industry as air circulating fans and
not ceiling fans, even if they are ceiling mounted.
Based on the interpretation of the ceiling fan definition in the
June 2023 Ceiling Fan ECS NOPR, an identical fan product could switch
between being regulated as a high-speed belt-driven ceiling fan and a
housed air circulating fan based only on if the equipment is sold with
straps or chains for mounting overhead. Similarly, an identical direct
drive fan product could switch between being regulated as a high-speed
small-diameter ceiling fan and a housed air circulating fan based only
on the if the product is sold with straps or chains for mounting
overhead. Further complicating the analysis is the fact that high-speed
belt-driven ceiling fans, air circulating fans and high-speed small-
diameter ceiling fans are subject to different test procedures and
different efficiency standards. DOE believes this confusion
necessitates further refinement.
To avoid this confusion, DOE is reinterpreting the scope of the
ceiling fan definition based on the potential overlap of products with
housed air circulating fans. As DOE noted in the September 2019 Ceiling
Fan TP NOPR, the intent of the ceiling fan definition is to be limited
to ``nonportable'' devices that ``circulate air''. 84 FR 51440, 51444.
Specifically, to clarify the distinction between air circulating fans
and ceiling fans, DOE is interpreting the elements of the ceiling fan
definition in the following way:
Portable--means: (1) that a fan is offered for mounting on
surfaces other than or in addition to the ceiling; and (2) that a
consumer can vary the location of the product/equipment throughout the
product/equipment lifetime. A ceiling fan is only mounted to the
ceiling and is not intended to be installed in any other mounting
configuration or change location after it's been installed. This is in
contrast to housed air circulating fans sold with straps and chains,
where the products are intended to be regularly modified to direct air
in different directions or move airflow around different obstacles or
in different areas. DOE also notes that once a ceiling fan is mounted
to the ceiling, it is often hard-wired in place;
Not for the purpose of circulating air--While DOE has
traditionally emphasized the 0.06 fan blade span to maximum rotation
rate ratio as the distinction between circulating air and direction
airflow, DOE notes that the definition of ``circulating air'' in the
ceiling fan definition is provided in contrast to directional airflow.
DOE is interpreting the presence of a housing as evidence of airflow
that is intended to be directional. In addition, DOE is interpreting
the ability for the consumer
[[Page 3745]]
to easily modify the direction of the airflow via mounting by ceiling
mounted chains, straps or via a ceiling bracket wherein the fan is able
to be pointed in different directions as evidence that the fan is
providing directional airflow.\37\
---------------------------------------------------------------------------
\37\ See example of ``ceiling mounted fans'' that are intended
to provide directional, rather than circulating air at
www.trianglefans.com/type/ceiling-mounted-fans.
---------------------------------------------------------------------------
Based on the interpretation, the scope of the ceiling fan
definition would be limited to only traditional ceiling fan products
that are connected to the ceiling via a downrod, flush mounting, or
similar, non-portable device. All other portable ceiling mounted fans
that provide directional airflow would be regulated under the air
circulating fan regulation. While the June 2023 Ceiling Fan ECS NOPR
included proposed efficiency standards for high-speed belt-driven
ceiling fans, under the proposed interpretation of the ceiling fan
definition, all high-speed belt-driven ceiling fan products identified
by DOE would not be within the scope of the ceiling fan definition and
would instead meet the definition of housed air-circulating fans.
Further, any direct-drive ceiling-mounted fan that is portable and
provides directional airflow (i.e., with a housing) would meet the
housed air circulating fan definition and be subject to the air
circulating fan test procedure and standards. In line with this
interpretation of the ceiling fan definition, all housed air-
circulating fans have been included within this NOPR analysis
regardless of whether they are sold with a straps or chains to hang
them from the ceiling or with wheels or other mounting configurations.
C. Test Procedure and Metric
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6314(a))
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product.
As previously discussed, DOE published its test procedure final
rule on May 1, 2023, which established separate uniform test procedures
for GFBs and ACFs. 88 FR 27312. The test procedure for GFBs is based on
American National Standards Institute (``ANSI'')/AMCA Standard 214-21
``Test Procedure for Calculating Fan Energy Index (FEI) for Commercial
and Industrial Fans and Blowers'' (``AMCA 214-21'') with some
modification and prescribes test methods for measuring the fan
electrical input power and determining the FEI of GFBs. The test
procedure for ACFs is based on ANSI/AMCA Standard 230-23 ``Laboratory
Methods of Testing Air Circulating Fans for Rating and Certification''
(``AMCA 230-23'') with some modification and prescribes test methods
for measuring the fan airflow in cubic feet per minute per watt (``CFM/
W'') of electric input power to an ACF. (See 10 CFR part 431, subpart
J, appendices A and B, respectively.) 88 FR 27312, 27315.
In response to the October 2022 NODA, AHAM commented that the test
procedure proposed in the July 2022 TP NOPR was inconsistent with
agreements made in the 2015 ASRAC negotiations, which diminishes the
value of participating in ASRAC negotiations. (AHAM, No. 123 at pp. 10-
11) DOE notes that the context of this comment is the same as an AHAM
comment submitted by AHAM to the July 2022 TP NOPR that DOE summarized
and responded to in the May 2023 TP Final Rule. 88 FR 27312, 27377.
1. General Fans and Blowers
a. General
DOE is proposing energy conservation standards for GFBs in terms of
FEI, which is calculated in accordance with the DOE test procedure. See
10 CFR part 431, subpart J, appendix A. In accordance with the DOE test
procedure, the FEI metric would be evaluated at each duty point as
specified by the manufacturer and, if adopted, DOE proposes that each
duty point at which the fan is offered for sale would need to meet the
proposed energy conservation standards.
FEI provides for evaluation of the efficiency of a GFB across a
range of operating conditions, captures the performance of the motor,
transmission, or motor controllers (if any), and allows for the
differentiation of fans with motors, transmissions, and motor
controllers with differing efficiency levels. FEI is a wire-to-air
metric, which means that it considers the efficiency from the input
power to the output power of a fan, including the efficiencies of the
motor, motor controller (if included), transmission, and fan itself.
The inclusion of all of these components encourages the improvement of
motor, motor controller, and transmission efficiencies, in addition to
the improvement of a fan's aerodynamic efficiency. In addition, FEI
aligns with the industry test standard (AMCA 214-21) and can help drive
better fan selections by making it easier to compare performance of
different fans. AMCA 214-21 defines FEI as the ratio of the electrical
input power (``FEP'') of a reference fan to the FEP of the fan for
which the FEI is calculated, both established at the same duty point.
The DOE test procedure provides methods to calculate both FEP and FEI
of a fan at a given duty point.
In response to the October 2022 NODA, DOE received comment on the
metric used for GFBs. Morrison and AHRI commented that they disagreed
with using the weighted FEI (``WFEI'') metric that was discussed in the
July 2022 TP NOPR. (Morrison, No. 128 at pp. 1, 3; AHRI, No. 130 at p.
2-3). DOE notes that these comments are similar to the comments
submitted to the July 2022 TP NOPR that DOE summarized in the May 2023
TP Final Rule. MIAQ commented in support of using FEI as the metric
used for regulation and disagreed with the use of WFEI because it has
not been evaluated by fan manufacturers or their customers (MIAQ, No.
124 at p. 2). In the May 2023 TP Final Rule, DOE responded to similar
comments and ultimately defined FEI as the metric for general fans and
blowers. 88 FR 27312, 27367-27369.
Morrison commented that the FEI metric aligned well with the
agreements made in the ASRAC Term Sheet and that FEI is now being used
by numerous standards as the metric for efficiency. (Morrison, No. 128
at pp. 2-3) DOE interprets Morrison's comment as support for using the
FEI metric.
Morrison commented that variable-frequency drive (``VFD'') control
provides a good method to dynamically achieve part-load operation to
promote energy savings. Morrison stated that since the FEP calculation
metric penalizes the use of VFDs, DOE should consider providing an
equivalent bonus factor, at a minimum, to gain back the losses in the
calculation. Morrison commented that operating at part load saves
significantly more energy than any other efficiency change. (Morrison,
No. 128 at p. 3) As discussed in the May 2023 TP Final Rule, DOE is not
adopting a control credit in the calculation of FEP for fans with a
motor controller, such as a VFD; however, as shown in Table I-1, DOE is
proposing lower standards for fans sold with motor controllers to
account for the motor controller losses in the FEP metric associated
with testing a fan with a controller.
As discussed in the May 2023 TP Final Rule, to the extent that
manufacturers of general fans and blowers are making voluntary
representations of FEI, then they would need to ensure that the product
is tested in accordance with the DOE test
[[Page 3746]]
procedure and that any voluntary representations of FEI (such as in
marketing materials or on any label affixed to the product) disclosure
the results of such testing. DOE recognizes that the ability to make an
additional voluntary representation of the EU metric in marketing
materials and on product labels may limit manufacturer burden. DOE is
clarifying that manufacturers may represent the additional EU metric,
but if doing so they must also represent the FEI metric in accordance
with the existing DOE test procedure.
b. Combined Motor and Motor Controller Efficiency Calculation
For fans with a polyphase regulated motor and a controller, AMCA
214-21 allows testing these fans using a shaft-to-air test (i.e., a
test that does not include the motor and controller performance). When
conducting a shaft-to-air test, the mechanical fan shaft input power is
measured and the FEP is calculated by using a mathematical model to
represent the performance of the combined motor and controller (i.e.,
its part-load efficiency). The FEP is then used to calculate the FEI of
the fan.
Section 6.4.2.4 of AMCA 214-21, which relies on Annex B, ``Motor
Constants if Used With VFD (Normative),'' and Annex C, ``VFD
Performance Constants (Normative),'' provides a method to estimate the
combined motor and controller part-load efficiency for certain electric
motors and controller combinations that meet the requirements in
sections 6.4.1.3 and 6.4.1.4 of AMCA 214-21, which specify that the
motor must be polyphase regulated motor (i.e., an electric motor
subject to energy conservation standards at 10 CFR 431.25).
In the July 2022 TP NOPR, DOE stated its concerns that the
equations described in section 6.4.2.4 of AMCA 214-21 may not be
appropriately representative, resulting in FEI ratings that would be
higher than FEI ratings obtained using the wire-to-air test method
described in section 6.1 of AMCA 214-21. Therefore, in the July 2022 TP
NOPR, DOE did not propose to allow the use of section 6.4.2.4 of AMCA
214-21. Instead, DOE proposed that fans with a motor and controller be
tested in accordance with section 6.1 of AMCA 214-21. DOE indicated
that manufacturers would still be able to rely on a mathematical model
(including the same mathematical model as described in section 6.4.2.4
of AMCA 214-21, if the mathematical model met the AEDM requirements) in
lieu of testing to determine the FEI of a fan with a motor and
controller. 87 FR 44194, 44223. In the July 2022 TP NOPR, DOE also
reviewed the reference motor and controller (``power drive system'')
efficiency provided in IEC 61800-9-2:2017 ``Adjustable speed electrical
power drive systems Part 9-2: Ecodesign for power drive systems, motor
starters, power electronics and their driven applications--Energy
efficiency indicators for power drive systems and motor starters,''
which also provides equations to represent the performance of a motor
and controller used with fans, and found that the IEC model predicted
values of efficiency that were significantly lower (more than 10
percent on average) than the model included in AMCA 214-21. Id.
In the May 2023 TP Final Rule, DOE further reviewed the model in
AMCA 214-21 section 6.4.2.4 and stated that it continued to have
concerns that applying the model in section 6.4.2.4 of AMCA 214-21 may
result in fan FEI ratings that would be higher than FEI ratings
obtained using the wire-to-air test method described in section 6.1 of
AMCA 214-21. 88 FR 27312, 27347. Specifically, DOE reviewed information
provided by AMCA analyzing the AHRI 1210 database of certified motor
controllers and providing graphical representations comparing the AHRI
data to the AMCA 207 model and found that there were several AHRI-
certified motor and motor controller combinations that had a tested
efficiency that is lower than the model in section 6.4.2.4 of AMCA 214-
21. (Docket No. EERE-2021-BT-TP-0021-0046, AMCA, No. 41 at pp. 18-19)
In their comments, AMCA stated that the model in AMCA 214-21, section
6.4.2.4, was not intended to be a conservative estimate of losses.
Instead, according to AMCA, the model was intended to provide a level
playing field between manufacturers that chose to test wire-to-air and
those that chose to test fan shaft power and calculate wire-to-air
losses. (Docket No. EERE-2021-BT-TP-0021-0046, AMCA, No. 41 at p. 18)
88 FR 27312, 27348.
Therefore, to minimize the possibility that using the calculation
approach would result in better energy efficiency ratings than when
testing the equipment inclusive of the motor and controller, in the May
2023 TP Final Rule, DOE did not allow the use of section 6.4.2.4 of
AMCA 214-21. Instead, DOE required that fans with motor and controller
be tested in accordance with section 6.1 of AMCA 214-21. DOE noted that
manufacturers would still be able to rely on a mathematical model
(including the same mathematical model as described in section 6.4.2.4
of AMCA 214-21) in lieu of testing to determine the FEI of a fan with a
motor and controller, as long as the mathematical model meets the AEDM
requirements. Id. In other words, manufacturers would not be able to
generally apply the model in section 6.4.2.4 of AMCA 214-21.
Manufacturers would have to first go through the AEDM validation
process to demonstrate that the FEI as established by the AEDM (or a
calculation method that would rely on the model in section 6.4.2.4 of
AMCA 214-21) would be less than or equal to 105 percent of the FEI
determined from the wire-to-air test of the basic models used to
validate the AEDM. See 10 CFR 429.70(n).
Since the publication of the May 2023 Final Rule, the IEC published
a new version of IEC 61800-9-2 (``IEC 61800-9-2: 2023''). Compared to
IEC 61800-9-2:2017, which included a calculation method to directly
establish typical losses of a reference motor and motor controller
combination (or ``Power Drive System'', ``PDS''), this version provides
the reference motor controller. It also points to a separate IEC
publication (IEC TS 60034-30-2:2016 ``Rotating electrical machines--
Part 30-2: Efficiency classes of variable speed AC motors (IE-code)'')
for establishing the reference motor losses. The detailed calculations
of losses for a reference motor and motor controller are also described
in IEC TS 60034-31: 2021 (``Rotating electrical machines--Part 31:
Selection of energy-efficient motors including variable speed
applications--Application guidelines'').
IEC 61800-9-2:2023 also characterizes the reference motor
controller or ``complete drive module'' (``CDM'') as corresponding to
an IE1 efficiency class.\38\ See section 6.2 of IEC 61800-9-2:2023. IEC
61800-9-2:2023 further establishes efficiency classes for PDS based on
pairing different levels of efficiency motors to baseline efficiency
CDMs at IE2 levels. See section 6.5 of IEC 61800-9-2:2023. DOE reviewed
a report from the International Energy Agency, Electric Motor Systems
Annex \39\ which included test data from 179 tests on 57 motor
controllers, as well as additional market data and showed that VFDs on
the market today are all within the same efficiency class corresponding
to ``IE2'', in line with the baseline levels used in IEC 61800-9-2
[[Page 3747]]
Ed. 2:2023. Therefore, DOE has tentatively determined that the IE2
level is appropriate to represent a baseline CDM or motor controller.
---------------------------------------------------------------------------
\38\ IEC 61900-9-2 Ed.2:2023 establishes three efficiency
classes (IE0, IE1, and IE2) to characterize the different efficiency
levels of CDMs on the market.
\39\ International Energy Agency, Electric Motor Systems Annex,
Report on Round Robin of Converter Losses, Final Report of Results.
www.iea-4e.org/wp-content/uploads/2022/11/rrc_report_final_2022dec.pdf.
---------------------------------------------------------------------------
In order to support an alternative credit calculation (See
discussion in section IV.C.1.b) and potentially reduce test burden, DOE
evaluated the model in IEC 61800-9-2:2023 assuming a polyphase
regulated motor that exactly meets the standards at 10 CFR 431.25, and
a motor controller at IE2 level. In addition, DOE adjusted the IE3
levels \40\ to exactly match the standards at 10 CFR 431.25 and be
comparable to the motor losses in AMCA 214-21.\41\ DOE found that
compared to the AMCA model, the IEC 61800-9-2:2023 model resulted in
generally lower combined motor and motor controller efficiencies.\42\
Based on this analysis, DOE has tentatively determined that the IEC
model provides a better representation of a baseline motor and VFD
combination (i.e., resulting in a conservative estimate of losses) as
by definition it relies on a regulated polyphase motor that exactly
meets the standards at 10 CFR 431.25 and on a baseline IE2 motor
controller.
---------------------------------------------------------------------------
\40\ The IEC defines motor efficiency classes. See IEC TS 60034-
30-2:2016, Rotating electrical machines--Part 30-2: Efficiency
classes of variable speed AC motors (IE-code).
\41\ For the purposes of this analysis, DOE considered a 4-pole
motor. DOE relied on the coefficients provided in the EXCEL sheet
accompanying the IEC TS 60034-31 Ed.2:2021 to calculate the motor
losses equivalent to an IE3 motor (See Table 4 of IEC TS 60034-30-
2:2016) and multiplied each coefficient by ((100-[eta]r)
[eta]IE3)/((100-[eta]IE3) [eta]r
where [eta]r is the minimum value of full-load efficiency
at 10 CFR 431.25 at a given horsepower across open and enclosed
enclosure categories and [eta]IE3 is the IE3 full load
efficiency at the same horsepower and pole configuration.
\42\ Two percent lower on average for 4 poles motors at 1, 10,
15, 25, 75, and 200 hp for loads between 0.25 and 1.
---------------------------------------------------------------------------
Therefore, DOE proposes to reduce test burden by adding a combined
motor and controller efficiency calculation to allow establishing the
FEI of fans sold with a regulated polyphase motor and a motor
controller based on a shaft-to-air test and calculated motor and
controller efficiency. DOE proposes that the performance of the motor
and motor controller combination be allowed for certain electric motors
and controller combinations that meet the requirements in sections
6.4.1.3 and 6.4.1.4 of AMCA 214-21, which specify that the motor must
be polyphase regulated motor (i.e., an electric motor subject to energy
conservation standards at 10 CFR 431.25). To support this approach, DOE
proposes that the performance of the motor and motor controller
combination be calculated in accordance with the model described in IEC
61800-9-2:2023 and the calculation in IEC TS 60034-31: 2016, and
assuming a regulated polyphase motor that exactly meets the standards
at 10 CFR 431.25 and a baseline IE2 motor controller. For the final
rule, DOE may also consider an approach where the calculation of AMCA
214-21 would be preserved but adjusted (i.e., same equations but with
different coefficients) to align with the results of the IEC 61800-9-
2:2023 model as proposed.
DOE requests comments and feedback on the proposed methodology and
calculation of motor and motor controller losses as well as potentially
using an alternative calculation based on adjusted AMCA 214-21
equations.
2. Air Circulating Fans
In the October 2022 NODA, DOE used FEI as the metric for ACFs in
its analysis. DOE requested feedback on the FEI values that it
determined and its approach for estimating FEI values for ACFs. 87 FR
62038, 62050.
AHAM commented that FEI is not an appropriate metric to use for
residential ACFs because the reference fan used for FEI is based on a
commercial fan. (AHAM, No. 123 at p. 7) Furthermore, AHAM commented
that the AMCA 214-21 test procedure, which DOE proposed to incorporate
by reference in the July 2022 TP NOPR, is not applicable to residential
ACFs. (AHAM, No. 123 at p. 6) DOE notes that, as discussed in section
III.B.2 of this document, ACFs with an input power of less than 125 W
are excluded from the scope of the rulemaking.
The CA IOUs and AMCA commented that the reason FEI values are much
higher for ACFs at diameters less than 20 in. is because the airflow
constant in the FEI calculation (3,210 CFM) is more impactful for ACFs
with lower CFM. (CA IOUs, No. 127 at pp. 4-5; AMCA, No. 132 at pp. 10-
11, 19) To support their comment, the CA IOUs provided data
demonstrating how, at lower airflows, there is a ``bonus'' value added
to reference shaft input power as a result of the airflow constant. (CA
IOUs, No. 127 at pp. 4-5) Ultimately, the CA IOUs recommended that DOE
consider using a different airflow constant for lower airflow fans to
counter this effect. Id. Greenheck explained that the airflow constant
in AMCA 214-21 is higher than the 12-in. representative unit can
generate; therefore, Greenheck would expect that efficiencies of the
12-in. representative unit would be greater than the efficiencies of
larger units, which is why AMCA 214-21 limits the application of FEI to
fans with airpowers of at least 125 W. (Greenheck, No. 122 at p. 2)
NEEA suggested that DOE review and confirm the increases in FEI for
ACFs at diameters of 20 in. or less. (NEEA, No. 129 at p. 4) AMCA
commented that there was a discrepancy between the airflow constant
defined for ACFs in the July 2022 TP NOPR (3,210 CFM) and the airflow
constant that DOE used in the October 2022 NODA (3,201 CFM). (AMCA, No.
132 at p. 10) In response, DOE confirms that the airflow constant used
in the October 2022 NODA is consistent with that in the July 2022 TP
NOPR (3,210 CFM) and that the value of 3,201 CFM was a typographical
error in the October 2022 NODA. Greenheck commented that using the FEI
metric for both GFBs and ACFs would cause confusion regarding which
constants should be used for GFBs and which constants should be used
for ACFs. (Greenheck, No. 122 at p. 1)
Based on additional evaluation and stakeholder feedback on the
airflow constant in the FEI calculation, DOE has adopted the efficacy
metric in terms of CFM/W at maximum speed for ACFs in appendix B to
subpart J of 10 CFR part 431 (see section 2.2). In the May 2023 TP
Final Rule, DOE explained that it has concerns over the readiness of an
FEI metric for ACFs and acknowledged the uncertainty regarding the
airflow and pressure constant values that should be used when
calculating FEI for ACFs. Additionally, the efficacy metric is
consistent with the metric used in the ACF industry. 88 FR 27312,
27371. Therefore, DOE conducted its analysis for this NOPR and is
proposing standards in efficacy in terms of CFM/Wat maximum speed.
D. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the equipment that is the subject of the rulemaking. As
the first step in such an analysis, DOE develops a list of technology
options for consideration in consultation with manufacturers, design
engineers, and other interested parties. DOE then determines which of
those means for improving efficiency are technologically feasible. DOE
considers technologies incorporated in commercially available equipment
or in working prototypes to be technologically feasible. 10 CFR 431.4;
10 CFR part 430, subpart C, appendix A, section 6I(3)(i) and 7(b)(1)
(``Process Rule'').
[[Page 3748]]
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; (3) adverse impacts on
health or safety, and (4) unique-pathway proprietary technologies. 10
CFR 431.4; Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of the Process
Rule. Section IV.B of this document discusses the results of the
screening analysis for fans and blowers, particularly the designs DOE
considered, those it screened out, and those that are the basis for the
standards considered in this rulemaking. For further details on the
screening analysis for this rulemaking, see chapter 4 of the NOPR
technical support document (``TSD'').
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a standard for a type or class of
covered equipment, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such equipment. (42 U.S.C. 6316(a); 42 U.S.C. 6295(p)(1))
Accordingly, in the engineering analysis, DOE determined the maximum
technologically feasible (``max-tech'') improvements in energy
efficiency for fans and blowers, using the design parameters for the
most efficient products available on the market or in working
prototypes. The max-tech levels that DOE determined for this rulemaking
are described in section IV.C of this proposed rule and in chapter 5 of
the NOPR TSD.
E. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to fans and blowers purchased in
the 30-year period that begins in the first full year of compliance
with the proposed standards (2030-2059).\43\ The savings are measured
over the entire lifetime of fans and blowers purchased in the previous
30-year period. DOE quantified the energy savings attributable to each
TSL as the difference in energy consumption between each standards case
and the no-new-standards case. The no-new-standards case represents a
projection of energy consumption that reflects how the market for
equipment would likely evolve in the absence of energy conservation
standards.
---------------------------------------------------------------------------
\43\ Each TSL is composed of specific efficiency levels for each
product class. The TSLs considered for this NOPR are described in
section V.A of this document. DOE conducted a sensitivity analysis
that considers impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (``NIA'') spreadsheet model
to estimate national energy savings (``NES'') from potential new
standards for fans and blowers. The NIA spreadsheet model (described in
section IV.I of this document) calculates energy savings in terms of
site energy, which is the energy directly consumed by equipment at the
locations where they are used. For electricity, DOE reports national
energy savings in terms of primary energy savings, which is the savings
in the energy that is used to generate and transmit the site
electricity. DOE also calculates NES in terms of FFC energy savings.
The FFC metric includes the energy consumed in extracting, processing,
and transporting primary fuels (i.e., coal, natural gas, petroleum
fuels), and thus presents a more complete picture of the impacts of
energy conservation standards.\44\ DOE's approach is based on the
calculation of an FFC multiplier for each of the energy types used by
covered products or equipment. For more information on FFC energy
savings, see section IV.H.2 of this document.
---------------------------------------------------------------------------
\44\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (August 18, 2011), as
amended at 77 FR 49701 (August 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended standards for covered equipment, DOE
must determine that such action would result in significant energy
savings. (42 U.S.C. 6316(a); (42 U.S.C. 6295(o)(3)(B))
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\45\ For
example, some covered equipment have most of their energy consumption
occur during periods of peak energy demand. The impacts of these
equipment on the energy infrastructure can be more pronounced than
equipment with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis, taking into
account the significance of cumulative FFC national energy savings, the
cumulative FFC emissions reductions, and the need to confront the
global climate crisis, among other factors. DOE has initially
determined the energy savings from the proposed standard levels are
``significant'' within the meaning of 42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(3)(B).
---------------------------------------------------------------------------
\45\ The numeric threshold for determining the significance of
energy savings established in a final rule published on February 14,
2020 (85 FR 8626, 8670), was subsequently eliminated in a final rule
published on December 13, 2021 (86 FR 70892).
---------------------------------------------------------------------------
F. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides seven factors to be evaluated in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has
addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential new standard on
manufacturers, DOE conducts an MIA, as discussed in section IV.J of
this document. DOE first uses an annual cash flow approach to determine
the quantitative impacts. This step includes both a short-term
assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period. The industry-wide impacts analyzed include (1) INPV, which
values the industry on the basis of expected future cash flows, (2)
cash flows by year, (3) changes in revenue and income, and (4) other
measures of impact, as appropriate. Second, DOE analyzes and reports
the impacts on different types of manufacturers, including impacts on
small manufacturers. Third, DOE considers the impact of standards on
domestic manufacturer employment and manufacturing capacity, as well as
the potential for standards to result in plant closures and loss of
capital investment. Finally, DOE takes into account cumulative impacts
of various DOE regulations and other regulatory requirements on
manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and PBP associated with new standards. These measures
are discussed further in the following section. For consumers in the
aggregate, DOE also calculates the national net present value of the
consumer costs and benefits expected to result from particular
standards. DOE also evaluates the impacts of potential standards on
identifiable subgroups of consumers that may be affected
disproportionately by a standard.
[[Page 3749]]
b. Savings in Operating Costs Compared To Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered equipment in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered equipment
that are likely to result from a standard. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC
and PBP analysis.
The LCC is the sum of the purchase price of equipment (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the equipment. The LCC analysis requires a variety of inputs, such as
equipment prices, equipment energy consumption, energy prices,
maintenance and repair costs, equipment lifetime, and discount rates
appropriate for consumers. To account for uncertainty and variability
in specific inputs, such as equipment lifetime and discount rate, DOE
uses a distribution of values, with probabilities attached to each
value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of more efficient equipment through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered equipment in the first full year of compliance
with new standards. The LCC savings for the considered efficiency
levels are calculated relative to the case that reflects projected
market trends in the absence of new or amended standards. DOE's LCC and
PBP analysis is discussed in further detail in section IV.F of this
document.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(III)) As discussed in section III.E, DOE uses the NIA
spreadsheet models to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing equipment classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered equipment. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards
proposed in this document would not reduce the utility or performance
of the equipment under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from a proposed standard. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to
determine the impact, if any, of any lessening of competition likely to
result from a proposed standard and to transmit such determination to
the Secretary within 60 days of the publication of a proposed rule,
together with an analysis of the nature and extent of the impact. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy
of this proposed rule to the Attorney General with a request that the
Department of Justice (``DOJ'') provide its determination on this
issue. DOE will publish and respond to the Attorney General's
determination in the final rule. DOE invites comment from the public
regarding the competitive impacts that are likely to result from this
proposed rule. In addition, stakeholders may also provide comments
separately to DOJ regarding these potential impacts. See the ADDRESSES
section for information to send comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water
conservation in determining whether a new or amended standard is
economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VI)) The energy savings from the proposed standards
are likely to provide improvements to the security and reliability of
the Nation's energy system. Reductions in the demand for electricity
also may result in reduced costs for maintaining the reliability of the
Nation's electricity system. DOE conducts a utility impact analysis to
estimate how standards may affect the Nation's needed power generation
capacity, as discussed in section IV.M of this document.
DOE maintains that environmental and public health benefits
associated with the more efficient use of energy are important to take
into account when considering the need for national energy
conservation. The proposed standards are likely to result in
environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases (``GHGs'') associated with energy
production and use. DOE conducts an emissions analysis to estimate how
potential standards may affect these emissions, as discussed in section
IV.K; the estimated emissions impacts are reported in section V.B.6 of
this document. DOE also estimates the economic value of emissions
reductions resulting from the considered TSLs, as discussed in section
V.C.1 of this document.
g. Other Factors
In determining whether an energy conservation standard is
economically justified, DOE may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VII)) To the extent DOE identifies any relevant
information regarding economic justification that does not fit into the
other categories described previously, DOE could consider such
information under ``other factors.''
2. Rebuttable Presumption
EPCA creates a rebuttable presumption that an energy conservation
standard is economically justified if the additional cost to the
equipment that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. (42 U.S.C. 6316(a);
42 U.S.C. 6295(o)(2)(B)(iii)) DOE's LCC and PBP analyses generate
values used to calculate the effects that proposed energy conservation
standards would have on the payback period for consumers. These
analyses include, but are not limited to, the 3-year payback period
contemplated under the rebuttable-presumption test. In addition, DOE
routinely conducts an economic analysis that considers the full range
of impacts to consumers, manufacturers, the Nation, and the
environment, as required under 42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i). The results of this analysis serve as the basis for
DOE's evaluation of the economic justification for a potential standard
level (thereby supporting or rebutting the results of any preliminary
determination of
[[Page 3750]]
economic justification). The rebuttable presumption payback calculation
is discussed in section V.B.1.c of this proposed rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
rulemaking with regard to fans and blowers. Separate subsections
address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential new energy
conservation standards. The national impacts analysis uses a second
spreadsheet set that provides shipments projections and calculates
national energy savings and net present value of total consumer costs
and savings expected to result from potential energy conservation
standards. DOE uses the third spreadsheet tool, the Government
Regulatory Impact Model (``GRIM''), to assess manufacturer impacts of
potential standards. These three spreadsheet tools are available on the
DOE website for this proposed rulemaking: www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=51&action=viewlive. Additionally, DOE used
output from the latest version of the Energy Information
Administration's (``EIA's'') Annual Energy Outlook (``AEO''), a widely
known energy projection for the United States, for the emissions and
utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the equipment
concerned, including the purpose of the equipment, the industry
structure, manufacturers, market characteristics, and technologies used
in the equipment. This activity includes both quantitative and
qualitative assessments, based primarily on publicly available
information. The subjects addressed in the market and technology
assessment for this rulemaking include (1) determination of equipment
classes, (2) scope of the analysis and data availability, and (3)
technology and design options that could improve the energy efficiency
of fans and blowers. The key findings of DOE's market assessment are
summarized in the following sections. See chapter 3 of the NOPR TSD for
further discussion of the market and technology assessment.
1. Equipment Classes
When evaluating and establishing energy conservation standards, DOE
is required to establish separate standards for a group of covered
equipment (i.e., establish a separate equipment class) based on the
type of energy used. DOE may also establish separate standards if DOE
determines that an equipment's capacity or other performance-related
feature that other equipment lacks justifies a different standard. (42
U.S.C. 6316(a); 42 U.S.C. 6295(q)) In making a determination whether a
performance-related feature justifies a different standard, DOE must
consider such factors as the utility of the feature to the consumer and
other factors DOE determines are appropriate. (Id.)
a. General Fans and Blowers
As discussed, DOE develops equipment classes based on specific
performance-related features that impact utility and may necessarily
impact efficiency in serving that utility. For GFBs, DOE identified the
direction of airflow through the fan, the outlet configuration of the
fan, housing features, and impeller features as characteristics that
may justify establishing separate equipment classes. DOE also
considered the presence of motor controllers as an additional factor
for developing equipment classes.
Based on the direction of airflow through a fan impeller, the
classification of a fan may be either axial or centrifugal. Axial fans
move air parallel to their axis of rotation and are suitable for
applications requiring high airflow at relatively low pressures.
Alternatively, centrifugal fans move air radially outward from the axis
of rotation, resulting in a change in direction of the air from the
inlet of the fan to the impeller edge occurring at or close to 90
degrees. This air is often redirected by a housing, which may
concentrate the airflow into a perpendicular outlet, as in the case of
a scroll housing, or again redirect the air to move parallel to the
inlet flow, as in the case of an inline fan. Centrifugal fans can
overcome much higher pressures than axial fans, but operate at lower
airflow, resulting in a difference in utility where different airflows
and pressures are required. DOE has tentatively determined that the
differences between axial- and centrifugal-flow fans result in a
difference in utility based on the pressure and airflow ranges under
which they are able to operate. For example, an axial fan may be better
suited for a general-purpose ventilation application, in which large
volumes of air are required at low pressure, whereas a centrifugal fan
may be more appropriate for an air conditioning application, which may
require a greater operating pressure than could be achieved by an axial
fan. Mixed-flow fans utilize a combination of axial and centrifugal
flows to provide similar pressures at higher airflows compared to
centrifugal fans where the outlet flow is parallel to the inlet flow.
Based on a review of the market, DOE has tentatively determined that
mixed-flow fans do not provide a unique utility from centrifugal fans
in similar arrangements, due to their similar operating pressure and
airflow ranges. Therefore, DOE separated GFBs into equipment classes
based on whether they utilize an axial or centrifugal airflow in this
NOPR.
The outlet configuration of a fan can also affect its efficiency.
In the DOE test procedure, DOE established test configuration and
measurement requirements based on whether the immediate outlet of a fan
is ducted or not ducted.\46\ See appendix A to subpart J of 10 CFR part
431. For GFBs, ducted fans may be utilized to move air directly from
the outlet of the fan through HVAC ducting internal to a building,
while not ducted fans discharge air into a plenum or open space. For
example, not ducted fans may be utilized to exhaust large quantities of
air from a building. Not ducted fans are also better suited for
applications in which the fan discharge needs to split into multiple
directions, such as ventilation systems which recirculate air from one
room to other parts of a building via multiple branching outlets. When
a fan outlet is ducted, the outlet air moves through the duct system,
and the velocity pressure associated with that air can be regained as
static pressure as it travels through the ducting. In this case, FEI is
calculated based on a total pressure basis accounting for both the
static pressure and the pressure associated with the speed of the
outlet air of the fan.\47\ When a fan outlet is not ducted,
[[Page 3751]]
the outlet air is immediately released into the surroundings, and the
velocity pressure of this air is lost to its surroundings. In this
case, FEI is calculated only on a static pressure basis since the
pressure associated with the outlet speed of the air is not aiding the
system. Because these outlet configurations have different utilities,
and in providing this utility the efficiency is calculated differently
according to the DOE test procedure, DOE is proposing to separate GFBs
into equipment classes based on their outlet configuration.
---------------------------------------------------------------------------
\46\ For the purposes of DOE's test procedure, ducting refers to
the immediate discharge of a fan and not the fan's application. For
example, a centrifugal unhoused fan which exhausts air in all
directions into a plenum or open space would be considered not
ducted, and tested via the corresponding test configuration, even if
that fan is ultimately installed in ducted ventilation system.
\47\ Static pressure is defined as the pressure exerted by a
fluid that is not in motion. Total pressure is defined as the sum of
the static pressure and the pressure that arises from the movement
of a fluid, or the velocity pressure. A fan's static pressure is the
static pressure at the outlet of the fan minus the total pressure at
the inlet of the fan. The total pressure of a fan is the total
pressure at the outlet of the fan minus the total pressure at the
inlet of the fan.
---------------------------------------------------------------------------
DOE has determined that a fan's housing may also impact utility. A
fan housing is the structure that encloses and guides the airflow of a
fan. Fans require certain housing features for specific utilities. For
example, PRVs require a special housing to prevent precipitation from
entering buildings. Further, different fan housings result in different
outlet directions for airflow. For example, centrifugal fans with a
scroll-shaped housing redirect airflow perpendicular to the fan inlet,
while centrifugal fans with a cylindrical or inline housing have
parallel inlet and outlet airflow. In applications that require
continuous airflow in a single direction, such as in a long ventilation
duct, a centrifugal fan with inline housing could be directly placed in
the duct to push air along the single direction. Inserting a
centrifugal fan with a scroll housing in the same application, however,
would create unnecessary complexity because it would create multiple
changes of direction of airflow, may require changes to the ducting
work, and could lead to reduced performance in a space-constrained
environment. Because the described housings have specific utilities and
DOE has observed different FEI ranges for fans with the described
housings, DOE is proposing to separate GFBs into separate equipment
classes by whether they are housed or unhoused, and to further separate
GFBs by the types of housings described.
DOE also considered impeller features for separating fans into
equipment classes. DOE identified that radial impellers as defined in
AMCA 214-21 offer unique self-cleaning characteristics that allow them
to be utilized with significantly less maintenance in airstreams with a
high density of particulate matter, such as fume exhaust from a
mine.\48\ However, these impellers are also less efficient than other
centrifugal impellers. Therefore, DOE is proposing a separate equipment
class for fans that use a radial impeller.
---------------------------------------------------------------------------
\48\ AMCA 214-21 defines a radial impeller as a form of
centrifugal impeller with several blades extending radially from a
central hub. Airflow enters axially through a single inlet and exits
radially at the impeller periphery into a housing with impeller
blades; the blades are positioned so their outward direction is
perpendicular within 25 degrees to the axis of rotation.
---------------------------------------------------------------------------
The last feature that DOE evaluated for separating GFBs into
equipment classes was the use of motor controllers, which allow a fan
to adapt to changing load requirements. This enables a fan to run at
lower speed when the system requirements allow, thus saving energy.
While this may result in energy savings during operation, the DOE test
procedure for fans does not account for these possible changes in
operation and energy savings. Furthermore, FEI is a wire-to-air metric,
as discussed in section III.C.1 of this document, which means that the
use of a motor controller would act to reduce the FEI of a fan at each
of its individual operating points. Any efficiency standard set without
consideration of the motor controller would be more stringent. DOE
recognizes the energy savings benefits of using a motor controller with
a fan to allow the energy consumption of fan to be adjusted based on
the changing load requirements of the system; therefore, to avoid
penalizing the use of such technology, DOE proposes to create equipment
classes for GFBs sold with and without motor controllers.
In the DOE Test Procedure, DOE adopted definitions consistent with
AMCA 214-21 for several categories of fans and blowers that are within
the scope of this NOPR. See 10 CFR 431.172. DOE also established a
modified definition for axial-panel fans to distinguish these fans from
ACFs. Id. Table IV-1 presents the fan categories and corresponding
definitions adopted by DOE.
BILLING CODE 6450-01-P
[[Page 3752]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.019
During its analysis, DOE tentatively determined that additional
definitions would help to clarify certain fan equipment classes. DOE is
proposing in this NOPR to adopt the definitions for ``radial
impeller'', ``mixed-flow impeller'' and ``housing'' presented in Table
IV-2. DOE notes that these proposed definitions are consistent with
those in AMCA 214-21, with some minor modifications for clarity.
---------------------------------------------------------------------------
\49\ AMCA 214-21 defines fan flow angle as the angle of the
centerline of the air-conducting surface of a fan blade measured at
the midpoint of its trailing edge with the centerline of the
rotation axis in a plane through the rotation axis and the midpoint
of the trialing edge.
[GRAPHIC] [TIFF OMITTED] TP19JA24.020
DOE found some fans are sold as radial fans but have impellers that
incorporate both radial and non-radial features, such as blades with a
slight backward-inclined design or blades with both straight and
backward-curved portions. To ensure that these fans are properly and
consistently classified as either radial or centrifugal housed, DOE
[[Page 3753]]
is proposing a definition for ``radial impeller''.
Additionally, DOE is proposing to define ``mixed flow impeller'' to
distinguish mixed flow impellers from axial and centrifugal impellers
and to ensure that fans sold with a mixed flow impeller are correctly
classified. DOE notes that, as defined in Table IV-1, inline fans with
mixed flow impellers are considered in the centrifugal inline equipment
class.
Lastly, DOE is proposing to define ``fan housing'' since housing is
a criterion used to separate equipment classes. In its evaluation of
the market, DOE found some fans that may not be easily classified
without a clear and consistent definition for housing. For example,
cabinet fans are sold with an enclosure surrounding their internal
moving components and an additional enclosure further directing
airflow. DOE has observed that cabinet fans are commonly marketed as
inline fans since the outermost enclosure directs the airflow to be
inline; however, the internal enclosure, which directs airflow into and
out of the impeller, directs airflow at a 90-degree angle, which would
be consistent with a centrifugal housed fan. Based on DOE's proposed
definitions, cabinet fans would be part of the centrifugal housed
equipment class.
DOE evaluated each of the fan categories defined in the DOE test
procedure using the identified GFB performance features and proposes
that each fan category defined in the test procedure will be evaluated
as a separate equipment class. For PRVs, DOE has found that they can be
either axial or centrifugal, and their outlets can either be ducted or
not ducted. PRVs used for supply will have a ducted outlet, while PRVs
used for exhaust will not have a ducted outlet. DOE notes that while
centrifugal PRVs serve both supply and exhaust functions, DOE did not
find a significant number of axial PRVs being used for supply in the
market. Therefore, DOE is proposing to further divide PRVs into three
distinct equipment classes: axial PRVs, centrifugal PRV exhaust fans,
and centrifugal PRV supply fans. Table IV-3 presents the proposed
definitions for each of the three PRV fan equipment classes, which
align with the definitions in AMCA 214-21.
[GRAPHIC] [TIFF OMITTED] TP19JA24.021
Additionally, DOE is proposing that each GFB equipment class be
split into a class of fans that are sold with motor controllers and a
class of fans that are sold without motor controllers. For example,
there would be two equipment classes for axial PRVs--one for axial PRVs
sold with motor controllers and one for axial PRVs sold without motor
controllers. This would be the same for all remaining proposed GFB
equipment classes.
In summary, DOE is proposing to separate GFBs into 18 equipment
classes in this NOPR. These equipment classes are shown in Table IV-4.
As just discussed, DOE notes that each equipment class shown in the
table has a variable-speed and a constant-speed variant. As mentioned
previously, these equipment classes directly correspond to the GFB fan
categories defined in the DOE test procedure, with the exception of
PRVs.
[[Page 3754]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.022
Although GFBs were not discussed in the October 2022 NODA, DOE
received comment on GFB equipment classes. Specifically, AHRI commented
that forward-curved fans, which are typically used in low-pressure
applications, could be removed from the market by energy conservation
standards. (AHRI, No. 130 at pp. 12-13) AHRI stated that forward-curved
fans should have a separate equipment class because they provide code-
required sound quality in low-pressure and low-speed ranges. Id.
Morrison and AHRI also commented that return or relief fans, which are
commonly used for energy-saving economizer functions in systems, could
be removed from the market if they are regulated by a DOE energy
conservation standard. (Morrison, No. 128 at p. 2; AHRI, No. 130 at p.
2, 13)
DOE notes that the FEI metric is a function of the operating
pressure. As mentioned in section III.C.1 of this document, FEI is the
ratio of the reference FEP to the actual FEP. The reference fan is used
to normalize the FEI calculation by evaluating fan performance compared
to a consistent reference fan at each duty point and configuration.
Evaluating FEI in this manner allows for comparison of different fans
independent of the wide variety of fan types and duty points.
Consequently, a return or relief fan operating at a lower pressure than
a supply fan at a given airflow would be compared to a reference FEP
specific to that duty point, which accounts for the lower operating
pressure and mitigates disproportionate impacts; therefore, DOE has
tentatively concluded that return and relief fans do not need a
separate equipment class.
To address AHRI's comment that forward-curved fans provide code-
required sound quality in low-pressure and low-speed ranges, DOE
evaluated data on inlet and outlet noise obtained from manufacturer fan
selection software for centrifugal-housed fans at low-pressure duty
points. Based on this analysis, DOE observed centrifugal-housed fans
with both backward-inclined and airfoil impellers that provided
equivalent or nearly equivalent noise levels, in A-weighted decibels,
to forward-curved fans operating at the same duty point. Furthermore,
DOE observed that noise levels significantly decreased as the FEI of
the fan increased, indicating that energy conservation standards would
not inhibit fans from complying with sound quality requirements.
Therefore, DOE has tentatively determined that forward-curved fans do
not require a separate equipment class. However, to ensure that
forward-curved fans were adequately evaluated, DOE evaluated a parallel
design path in which it assumed that all forward-curved fans would be
redesigned to meet any proposed energy conservation standards, rather
than replacing the forward-curved impeller with another impeller
topology such as airfoil or backward-inclined. DOE evaluated this
parallel design path to consider the costs required to preserve
forward-curved fans in the market. Additional details on the parallel
design path for forward-curved fans are provided in section IV.C.1.b of
this document and chapter 5 of the NOPR TSD.
DOE received no further comments on GFB equipment classes and is
therefore proposing the equipment classes in Table IV-4.
b. Air Circulating Fans
In response to the October 2022 NODA, AMCA recommended that DOE use
the same ACF definitions as those used in AMCA 230-23. (AMCA, No. 132
at pp. 2, 18) As discussed in the May 2023 Test Procedure Final Rule,
the definitions that DOE adopted for ACF, unhoused air circulating fan
head (``ACFH''), housed ACFH, air circulating axial panel fan, box fan,
cylindrical
[[Page 3755]]
ACF, and housed centrifugal ACF align with the definitions published in
AMCA 230-23. 88 FR 27312, 27339. DOE additionally adopted definitions
for air circulating axial panel fan, box fan, cylindrical ACF, and
housed centrifugal ACF in the DOE test procedure, as defined in Annex B
of AMCA 230-23. See 10 CFR 431.172. These definitions are reproduced
Table IV-5.
[GRAPHIC] [TIFF OMITTED] TP19JA24.023
BILLING CODE 6450-01-C
In the October 2022 NODA, DOE did not evaluate separate equipment
classes for housed and unhoused ACFs and requested comment and
supporting data on whether housed and unhoused ACFs have significant
differences in utility and/or efficiency. 87 FR 62038, 62045. NEEA
stated that DOE should analyze unhoused and housed ACFs separately in
its analysis because the efficiencies of housed and unhoused fans
differ enough that an analysis of both together could result in non-
representative EL values. To support this point, NEEA referenced a plot
that was included in the supplementary spreadsheet for the October 2022
NODA that showed ACF efficiency distribution overlayed on the
efficiency levels analyzed in the NODA \50\ and stated that the
efficiency distributions in the plot were wide for all diameters.
(NEEA, No. 129 at p. 1-2) NEEA commented that, given the many
performance-related features with unquantifiable impacts on the fan
efficiency data DOE used for its analysis, DOE should separate housed
and unhoused ACFs into separate equipment classes to ensure that housed
and unhoused ACFs are fairly analyzed. NEEA added that the separation
of housed and unhoused fans aligns with the approach taken for GFBs in
NODA 3. (NEEA, No. 129 at p. 2-3)
---------------------------------------------------------------------------
\50\ See Docket No. EERE-2022-BT-STD-0002, No. 11 for the
supplementary spreadsheet associated with the October 2022 NODA.
---------------------------------------------------------------------------
The Efficiency Advocates commented that DOE should group ACFHs, box
fans, panel fans, and personnel coolers together into a single axial
ACF class since they are all axial fans that provide directional
airflow and do not differ significantly in FEI. (Efficiency Advocates,
No. 126 at p. 3) They noted that the ACF subcategories in AMCA 230 are
delineated in AMCA 230 primarily for descriptive purposes and not for
regulatory purposes. Id. DOE interprets ACFHs and personnel coolers, as
referenced by the Efficiency Advocates, to align with the definitions
given for unhoused ACFHs and cylindrical ACFs, respectively, in Table
IV-5. DOE therefore interprets the Efficiency Advocates' comment as a
recommendation to combine all axial ACFs into a single equipment class.
DOE's review of the ACF market generally indicated that air
circulating axial panel fans, box fans, cylindrical ACFs, and unhoused
ACFHs could all be used interchangeably for air circulation
applications. DOE did observe that cylindrical ACFs are sometimes
marketed toward high-velocity applications. To verify whether design in
high-velocity applications would warrant separating cylindrical ACFs
into their own equipment class, DOE reviewed available air velocity and
thrust data for air circulating axial panel fans, box fans, cylindrical
ACFs, and unhoused ACFHs. Based on this analysis, DOE did not find a
consistent trend of one or more of these subcategories of ACFs
producing more air velocity or thrust than another, further indicating
that they may be used interchangeably. DOE therefore
[[Page 3756]]
evaluated air circulating axial panel fans, box fans, cylindrical ACFs,
and unhoused ACFHs as a single ``axial ACF'' equipment class in this
NOPR. DOE is therefore proposing that an axial ACF be defined as ``an
ACF with an axial impeller that is either housed or unhoused.'' DOE
considers all fans that meet the axial ACF definition to be subject to
the DOE test procedure, and these fans, unless specifically excluded,
would be subject to any future energy conservation standards.
DOE requests comment on whether there are specific fans that meet
the axial ACF definition that provide utility substantially different
from the utility provided from other axial ACFs and that would impact
energy use. If so, DOE requests information on how the utility of these
fans differs from other axial ACFs and requests data showing the
differences in energy use due to differences in utility between these
fans and other axial ACFs.
In the October 2022 NODA, DOE also requested comment on whether
each of the following design characteristics may impact the utility of
air circulating fans: presence or absence of a safety guard, presence
or absence of housing, housing design, blade type, power requirements,
and air velocity or throw. 87 FR 62038, 62045. Additionally, DOE
requested information on any additional design characteristics that may
impact ACF utility. Id. In response, AMCA commented that all the design
variables on which DOE requested comment are combined to influence an
ACF's performance characteristics. (AMCA, No. 132 at p. 6-7). DOE
reviewed the market and found that adjusting these design variables
while keeping other design parameters constant did not produce a
significant difference in efficiency, impact the operation, or impact
the fan's application. Therefore, DOE has tentatively decided not to
delineate separate equipment classes for axial ACFs based on safety
guards, housing, blade type, power requirements, or air velocity and
throw.
In the October 2022 NODA, DOE additionally requested comment and
supporting data on whether belt-driven and direct-driven ACFs have
significant differences in utility or efficiency. 87 FR 62038, 62045.
The Efficiency Advocates commented that DOE should not consider belt-
driven fans as a separate equipment class because those fans are merely
a low-cost alternative to the more efficient direct-drive fans rather
than a different performance or utility consideration, and that a
separate equipment class for belt-driven ACFs could undermine the
potential energy savings for larger diameter ACFs. (Efficiency
Advocates, No. 126 at p. 3) DOE's review of belt-driven ACFs on the
market indicated that, while belt drives do provide a utility for
adjusting the rotational speed of the ACF, VFDs also allow users to
adjust the rotational speed of the ACF. Therefore, DOE has tentatively
determined that belt drives do not provide a unique utility and DOE did
not treat belt-driven ACFs as an equipment class in its NOPR analysis.
The shift from belt drive to direct drive is instead discussed as a
design option in section IV.C.2.b of this document.
DOE further reviewed the ACF market to determine if additional
equipment classes were appropriate for axial ACFs. DOE observed that
axial ACFs with larger impeller diameters tended to be more efficient
than axial ACFs with smaller impeller diameters. DOE also received
feedback during manufacturer interviews that fans with larger diameters
are generally more efficient. Therefore, DOE considered diameter as a
class-setting variable for axial ACFs in this NOPR. DOE found multiple
efficiency incentive programs that provide rebates to agricultural fan
manufacturers if they meet certain efficiency targets.\51\ For axial
ACFs, these agricultural rebate programs typically define four diameter
ranges to which the rebate efficiency levels applied: ``12-inch to less
than 24-inch diameter range,'' ``24-inch to less than 36-inch diameter
range,'' ``36-inch to less than 48-inch diameter range,'' and ``48-inch
diameter or greater range.'' To align with these programs, DOE
initially considered four different equipment classes for axial ACFs,
one for each diameter range. However, after reviewing efficacy data for
axial ACFs, DOE did not find a significant difference in efficacy
between axial ACFs in the 12-inch to less than 24-inch diameter range
and the 24-inch to less than 36-inch diameter range. Therefore, DOE
combined these two diameter ranges into a single equipment class: the
``12-inch to less than 36-inch diameter axial ACF'' class. DOE assigned
the 36-inch to less than 48-inch diameter range to a ``36-inch to less
than 48-inch diameter axial ACF'' class and the 48-inch diameter or
greater range to a ``48-inch diameter or greater axial ACF'' class.
---------------------------------------------------------------------------
\51\ See cecnet.net/agriculture; www.ecirec.coop/rebate-forms-
and-specifications; and www.tiprec.com/rebates.
---------------------------------------------------------------------------
The term ``diameter'' in the context of fans and blowers refers to
the impeller diameter of a fan. Impeller diameter is typically
determined by measuring the radial distance from the tip of one of the
impeller blades to the center of the impeller hub and doubling that
value. DOE is therefore proposing to define diameter for fans and
blowers as ``the impeller diameter of a fan, which is twice the
measured radial distance between the tip of one of the impeller blades
of a fan to the center axis of its impeller hub.'' DOE notes that
impeller diameter may often be different than nominal diameter.
Additionally, in the October 2022 NODA, DOE summarized a comment
from the Efficiency Advocates stating that portable blowers may require
an equipment class separate from other ACFs because they provide a
unique application (i.e., drying floors), have centrifugal rather than
axial construction, and are relatively low in efficiency. 87 FR 62038,
62045. DOE understands the term ``portable blower'' to be a housed
centrifugal ACF. As discussed in section IV.A.1.a of this document, DOE
tentatively determined that axial and centrifugal fans generally have
different utilities. DOE also reviewed the housed centrifugal ACF
market and found that housed-centrifugal ACFs are used primarily as
carpet dryers. Additionally, DOE observed that housed-centrifugal ACFs
with input powers greater than or equal to 125 W typically have
impeller diameters of 4 in. to 20 in., while axial ACFs with input
powers greater than 125 W often have impeller diameters exceeding 20
in. DOE also reviewed housed centrifugal ACF efficiency data and found
that the most efficient housed centrifugal ACFs can be 3 to 4 times
less efficient than the most efficient axial ACFs with a comparable
diameter. Since housed centrifugal ACFs have a different construction,
are only used as carpet dryers, are smaller, and are less efficient
than axial ACFs, DOE has created a separate equipment class for housed
centrifugal ACFs. DOE did not consider different diameter ranges for
the housed centrifugal ACF equipment class because it did not observe a
significant variation in efficiency for housed centrifugal ACFs with
diameter. The proposed equipment classes for ACFs are summarized in
Table IV-6.
[[Page 3757]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.024
2. Scope of Analysis and Data Availability
a. General Fans and Blowers
DOE conducted the GFB engineering analysis for this NOPR using a
database of confidential sales information provided by AMCA (``AMCA
sales database''), performance data from manufacturer online fan
selection software, and performance data provided from confidential
manufacturer interviews.
In response to the July 2022 TP NOPR, DOE received comments about
the data used in its historical analyses. Specifically, AHRI expressed
concern with DOE's use of the AMCA sales database in the December 2014
NODA, the May 2015 NODA, and the November 2016 NODA, which contains
efficiencies established at a variety of different speeds. (Docket No.
EERE-2021-BT-TP-0021, AHRI, No. 40 at p. 13). AHRI stated that this
approach was inconsistent with the ASRAC Working Group agreement for
establishing product performance and, as disclosed during ASRAC
negotiations, much of the data in the database was not certified
performance and may not be reliable for evaluating the impact of
efficiency standards. (Id.)
With respect to the AMCA sales database providing efficiency data
at a variety of speeds, DOE notes that, in accordance with the DOE test
procedure, fans must be tested at a range of duty points over which
they may operate. Duty points are characterized by a given airflow and
pressure at a corresponding operating speed. In other words, fans could
be tested at a variety of different speeds depending on the duty point
at which the fan is being operated. As discussed in section IV.B of
this document, DOE evaluated the entire range of duty points when
developing the proposed efficiency levels for each class; therefore,
DOE has used the performance data provided in the AMCA sales database
as a basis for its engineering analysis. Furthermore, in response to
the data in the database not being certified performance data, DOE
compared the fan models in the AMCA sales database with the fan models
in the AMCA Certified Rating Program.\52\ DOE found that the fan models
in the AMCA sales database are certified as part of AMCA's Certified
Rating Program.
---------------------------------------------------------------------------
\52\ Detail on AMCA's Certified Ratings Program can be found at
www.amca.org/certify/#about-crp (last accessed September 2022).
---------------------------------------------------------------------------
The AMCA sales database that DOE used in this analysis is the same
database that was used in the May 2015 NODA and the November 2016 NODA.
To validate that the AMCA sales database remains representative of the
current market, DOE verified the data with current manufacture product
literature. DOE selected several fans from the AMCA sales database from
each manufacturer and equipment class and verified that those fans are
currently available with the same performance data. DOE specifically
checked that the model, diameter, operating pressure, airflow, and
brake horsepower (``bhp'') aligned between the AMCA sales database and
current product literature. DOE was able to verify a majority of the
fans selected from each manufacturer and equipment class. Additionally,
DOE obtained recent performance and sales data from confidential
manufacturer interviews and determined that the data were consistent
with the data in the AMCA sales database; therefore, DOE has
tentatively concluded that the AMCA sales database that it uses in its
engineering analysis for this NOPR is representative of the current
market.
DOE notes that it made some updates to the AMCA sales database to
ensure consistency with the proposed scope and equipment classes for
PRVs. The AMCA sales database grouped all centrifugal PRVs together;
however, as discussed in section IV.A.1.a, DOE has separated
centrifugal PRVs by whether they are supply or exhaust (ducted or non-
ducted). To separately analyze the two classes, DOE manually
recategorized the centrifugal PRVs as either supply or exhaust fans
using the manufacturer and model provided in the AMCA sales database
for most fans to identify from manufacturer literature which
centrifugal PRVs were supply and which were exhaust. Centrifugal PRVs
that could not be identified by their model name were left categorized
as exhaust for the analysis since, based on data collected during
confidential manufacturer interviews, DOE believes that there are more
centrifugal PRV exhaust fan product lines and models than centrifugal
PRV supply fans.
Additionally, DOE determined that the AMCA sales database included
many radial fans that are considered out of scope in the DOE test
procedure. 10 CFR 431.174((a)2)(i). As discussed in section III.B.1,
radial fans that are unshrouded and have an impeller diameter less than
30 in. or a blade width of less than 3 in. are excluded from the scope
of the DOE test procedure. DOE identified these radial fans by looking
up each model in manufacturer product literature to determine whether
it contained a shrouded impeller. Some fans in the database could not
be identified by model, or the impeller characteristics could not be
determined from their catalogs. DOE opted to include these fans in the
database for analysis because including them likely results in a more
conservative estimate of FEI since DOE has found that unshrouded
impellers typically have lower FEI.
DOE acknowledges that there are limitations to the data provided in
the AMCA sales database. For example, factors such as drive type, motor
horsepower, and the presence of motor controllers were not specified in
the AMCA sales database, unless indicated by the model number.
Additionally, DOE estimates that AMCA members make up 60 percent of fan
manufacturers. DOE understands that the AMCA sales database includes
only a portion of the sales data from AMCA members; however, given the
range in equipment classes, FEIs, and costs in the AMCA sales database,
DOE believes that the data are representative of the U.S. GFB market.
Furthermore, to supplement the data from the AMCA sales database, DOE
also pulled
[[Page 3758]]
performance data from online fan manufacturer selection software. DOE
notes that it did not select representative units, such as a particular
fan model, to conduct its analysis since fan performance relies on fan
diameter and operating point. Instead, DOE identified between three and
ten representative diameters and operating points for each equipment
class in the AMCA sales database and pulled additional performance data
for these operating points from manufacturer fan selection software.
Each representative operating point was defined by equipment class,
diameter, operating pressure, and airflow. DOE analyzed data points
from multiple fan models and manufacturers for each representative
diameter and operating point representing a variety of fan designs and
efficiencies. Using the data from manufacturer fan selection software,
DOE was able to identify the drive type, motor horsepower, and whether
or not motor controllers were present for each evaluated fan.
More detail on the databases DOE used in its analyses can be found
in chapter 5 of the NOPR TSD.
b. Air Circulating Fans
During manufacturer interviews conducted prior to the October 2022
NODA, manufacturers recommended that DOE use ACF data from a publicly
available database provided by the Bioenvironmental and Structural
Systems Laboratory associated with the University of Illinois-Champaign
(``BESS Labs database'').\53\ Based on this feedback, DOE conducted its
October 2022 NODA analyses using data from the BESS Labs database and
data collected from ACF testing performed by DOE at BESS Labs. DOE
referred to this collective database as the ``BESS Labs combined
database'' in the October 2022 NODA. DOE notes that, although BESS Labs
uses the test setups defined in the 2012 edition of AMCA 230 for its
testing, BESS Labs does not apply standard air density conversions to
its measurements, which are required by the DOE test procedure. See
section 2.2.2 of appendix B to subpart J to 10 CFR part 431. Therefore,
in the October 2022 NODA, DOE applied conversion formulas to the BESS
Labs combined database performance data to align the airflow and input
power calculations with the DOE test procedure. Details on these
conversions can be found in chapter 5 of the TSD.
---------------------------------------------------------------------------
\53\ BESS Labs is a research, product testing, and educational
laboratory. BESS Labs provides engineering data to aid in the
selection and design of agricultural buildings and assists equipment
manufacturers in developing better products. Test reports for ACFs
are publicly available at bess.illinois.edu/searchc.asp.
---------------------------------------------------------------------------
As discussed in section III.B.2, all ACFs with input power less
than 125 W are outside the proposed scope of this rulemaking.
Therefore, DOE removed all ACFs with input powers less than 125 W from
the BESS Labs combined database prior to its analysis for this NOPR.
In the October 2022 NODA, DOE requested comment on whether the BESS
Labs combined database was representative of the performance of the
entire ACF market. 87 FR 62038, 62045. In response, AMCA commented that
it expects the fan efficiencies reported in the BESS Labs database to
be higher than the typical efficiencies seen on the market for ACFs.
AMCA stated that this is because the fans in the BESS Labs database are
typically agricultural fans, and these fans are the subject of utility
rebates to encourage the production of higher-efficiency fans. AMCA
further stated that it is unlikely performance data for a fan was
voluntarily added to the public BESS Labs database unless the fan was
eligible for these utility rebates. (AMCA, No. 132 at p. 4-5) Greenheck
also commented that the ACF efficiencies in the BESS Labs database
would generally be higher than typical ACFs on the market because of
their participation in rebate efficiency incentive programs, and
Greenheck suggested that DOE utilize more data sources than just the
BESS Labs combined database. (Greenheck, No. 122 at p. 2)
In the October 2022 NODA, DOE also requested information on ACF
performance data. 87 FR 62038, 62045. In response, AMCA commented that
ACF catalog data is publicly available. However, AMCA also stated that
it believes that public performance data for fans not listed in the
BESS Labs database was likely either not collected using the most
recent version of AMCA 230 or not collected using any version of AMCA
230 at all. AMCA further commented that testing of ACFs at an AMCA-
accredited facility yielded performance data that was inconsistent with
the performance data published in catalogs for certain tested fans, and
because of this, AMCA cautioned DOE on the use of catalog data that has
not been certified by a third party. (AMCA, No. 132 at p. 5-6)
Similarly, Greenheck recommended that DOE only use ACF data that has
been certified by an independent performance certification program to
ensure that the data are accurate. (Greenheck, No. 122 at p. 2) In the
October 2022 NODA, DOE discussed a comment from AMCA stating that ACF
product literature may advertise performance calculated using outdated
versions of AMCA 230 and that all versions aside from AMCA 230-15 had
at least one error pertaining to the calculations of thrust, airflow,
or input power. 87 FR 62038, 62043-62044. A table summarizing these
errors can be found in the October 2022 NODA. Id.
In the October 2022 NODA, DOE also requested comment on whether the
fan affinity laws could be used to extrapolate ACF performance data to
smaller and larger diameters to increase the size of its ACF dataset.
87 FR 62038, 62045. In response, NEEA stated that since the fan
affinity laws assume that efficiency remains constant, utilizing them
for determining efficiency gains would be incorrect. Instead, NEEA
recommended that DOE obtain data on smaller- and larger-diameter ACFs
by either testing additional smaller- and larger-diameter ACFs or by
using empirical relationships to extrapolate data to smaller and larger
diameters. (NEEA, No. 129 at p. 3-4) AMCA stated that the fan affinity
laws require knowledge of the impeller shaft power, which is often not
measured for ACFs. AMCA added that electrical input power, which is
often measured for ACFs, cannot be scaled to obtain reasonable
estimates. (AMCA, No. 132 at p. 6) In response to this feedback, DOE
did not utilize the fan affinity laws to extrapolate fan performance
data to different diameters and instead included catalog data in its
dataset for this NOPR.
DOE acknowledges that the BESS Labs combined database likely
contains higher efficiency fans than the overall ACF market, since many
agricultural incentive programs require that fans be tested at BESS
Labs and meet certain performance requirements. Additionally, DOE notes
that the BESS Labs combined database contains data on axial ACFs only.
Therefore, to supplement the BESS Labs combined database and gain
additional information representative of the ACF market, DOE collected
ACF catalog data from manufacturer and distributor websites. DOE did
not consider catalog data in the October 2022 NODA because catalog data
did not include information on the air density measured during testing,
which is required to calculate FEI. Since DOE updated the ACF metric to
be efficacy instead of FEI, DOE was able to use catalog data for this
NOPR. In response to AMCA and Greenheck's concerns about the accuracy
of catalog data that have not been certified by a third party, DOE
notes that, while the catalog data it collected is not certified by a
third party, there were no ACFs listed in AMCA's certified product
[[Page 3759]]
database at the time of DOE's market review,\54\ and DOE is not aware
of any other certification programs for ACFs.
---------------------------------------------------------------------------
\54\ AMCA's certified product database for ACFs can be found at
www.amca.org/certify/certified-product-search/product-type/air-circulating-fan.html (last accessed 4/10/23).
---------------------------------------------------------------------------
In response to AMCA's concerns about manufacturers' use of outdated
and inaccurate versions of AMCA 230 to generate catalog data, DOE
applied a correction factor to some catalog data. DOE is aware that
many ACF manufacturers may use an outdated version of AMCA 230 and that
the calculation methods used in these older versions do not align with
AMCA 230-15 or with AMCA 230-23, which is referenced by the DOE test
procedure. See section 2.2.2 of appendix B to subpart J of 10 CFR part
431. In DOE's review of the ACF market and product literature, it
observed that the 1999 edition of AMCA 230 (``AMCA 230-99'') was the
most common test method manufacturers cited in their product literature
for measurement of ACF performance data, while a small number of
manufacturers cited AMCA 230-15. DOE did not find any other methods
that manufacturers cited for measuring ACF performance. Therefore, for
all manufacturers that did not explicitly state in their product
literature that they collected their ACF performance data using AMCA
230-15, DOE applied a correction factor to the catalog data to account
for differences in the calculation methods between AMCA 230-99 and the
DOE test procedure. DOE acknowledges that this approach may result in
lower efficacy values for ACFs where a correction factor was already
applied; however, DOE notes that it lacks other sources of ACF
performance data aside from the BESS Labs combined database and this
catalog data. DOE combined the corrected catalog data and the BESS Labs
data, herein referred to as the ``updated ACF database,'' and used this
database for its analysis of ACFs in this NOPR.
DOE also removed outliers from the dataset using a box plot
approach. For axial ACF catalog data, DOE removed extremely high-
efficacy outliers and did not identify any extremely low-efficacy
outliers. For axial ACFs from the BESS Labs combined database, DOE only
removed extremely high-efficacy outliers because ACFs in the BESS Labs
combined database are generally expected to have higher efficacies than
the overall ACF market. DOE did not remove outliers for housed
centrifugal ACFs.
3. Technology Options
In the February 2022 RFI, DOE identified five technology options
that would be expected to improve the efficiency of ACFs, as expected
to be measured by a future DOE test procedure. These technology options
were improved aerodynamic design, blade shape, more efficient motors,
material selection, and variable-speed drives (``VSDs''). 87 FR 7048,
7052. In the October 2022 NODA, DOE focused its analyses on aerodynamic
redesign and more efficient motors. 87 FR 62038, 62042. In response to
the October 2022 NODA, the CA IOUs suggested that DOE investigate
individual components of improved aerodynamic design so that
incremental efficiency levels could be evaluated in the engineering
analysis. (CA IOUs, No. 127 at p. 2) DOE has since identified several
additional technology options that would be expected to improve the
efficiency of GFBs and ACFs, including options that are components of
aerodynamic design. The technology options that DOE considered for this
NOPR are:
Improved housing design;
Reduced manufacturing tolerances;
Addition of guide vanes;
Addition of appurtenances;
Improved impeller design;
Impeller topology;
Increased impeller diameter;
Impeller material;
More efficient transmissions;
More efficient motors; and
Motor controllers.
DOE notes that not every technology option listed above will be
analyzed for each equipment class in this NOPR. For example, DOE did
not analyze increased impeller diameter for ACFs because impeller
diameter is used to separate ACF equipment classes (see section
IV.A.1.b). The following discussion provides a brief overview of the
technology options under consideration and addresses stakeholder
comments that DOE has received on the October 2022 NODA.
Improved housing design includes any changes to the enclosure of a
fan, such as modifying the volute \55\ for centrifugal fans or reducing
the blade-to-housing clearance for axial fans. In response to the
October 2022 NODA, the CA IOUs stated that a fan's blade-to-housing
clearance determines its static pressure capabilities and efficiency,
and fans with larger clearances generally have lower efficiency. They
also stated that the use of a wall ring can improve the efficiency of
an ACF. (CA IOUs, No. 127 at pp. 2-3) DOE has considered the addition
of a wall ring under the ``improved housing design'' technology option.
Additionally, DOE considered the effects of reduced running clearances
as a component of the ``reduced manufacturing tolerances'' technology
option. During manufacturer interviews, manufacturers stated that
reducing the manufacturing tolerances for fan components can increase
efficiency. Therefore, DOE considered reduced manufacturing tolerances
as a technology option for this NOPR.
---------------------------------------------------------------------------
\55\ A volute is a spiral or scroll-shaped housing used with
centrifugal fans.
---------------------------------------------------------------------------
The addition of guide vanes reduces pressure loss by directing and
smoothing airflow as it exits a fan. DOE observed in its market
research that the integration of guide vanes into the outlet of a fan
can improve efficiency by over 10 percent. For example, DOE observed
that vane axial fans can achieve up to 20-percent higher FEIs than
similarly sized tube axial fans. Appurtenances are similar to guide
vanes but are not integral to the fan--rather, appurtenances can be
added to change the performance of a fan and fans may be sold with
different appurtenances to provide the end user with the desired
effect. In the October 2022 NODA, DOE summarized a comment from ebm-
papst stating that the use of outlet guide vanes or appurtenances, such
as inlet cones on housings or winglets on impellers, could improve the
fan efficiency. 87 FR 62038, 62042. DOE recognizes that the addition of
appurtenances described by ebm-papst has the potential to increase fan
efficiency. Therefore, DOE considered the addition of guide vanes and
appurtenances as technology options in this NOPR.
Regarding impeller design, DOE considered any aerodynamic
improvement of an impeller that does not include a change to its
topology under the impeller design technology option. This includes
modifications, such as incorporating beneficial ridges into the blade
surface as well as improving impeller blade surface quality. DOE
observed the presence of these modifications to blade design during
teardowns of GFBs and ACFs. Therefore, DOE considered improved impeller
design as a technology option in this NOPR.
Regarding fan impeller topology, DOE considered changes in the
orientation or basic shape of the blades, such as switching from a
backward-curved blade to an airfoil blade. In the October 2022 NODA,
DOE summarized a comment from the Joint Commenters encouraging DOE to
evaluate more efficient blade designs as a technology option because of
their energy savings potential. The Joint Commenters added that the use
of advanced blade designs,
[[Page 3760]]
such as airfoil blades, can improve the efficiency of a fan relative to
traditional single-thickness blades. 87 FR 62038, 62042. In addition,
DOE received comment from the CA IOUs in response to the October 2022
NODA stating that impeller blades may have either a ``true'' or
``progressive'' pitch, and that the pitch of the blades will affect
efficiency. (CA IOUs, No. 127 at p. 2) DOE's research and feedback
received during manufacturer interviews also indicated that certain
impeller topologies can be more efficient than others. Therefore, DOE
considered impeller topology as a technology option.
In response to the October 2022 NODA, AHAM commented that DOE's use
of general blade design as a technology option for ACFs did not factor
in specific differences in application of different blade shapes
between unique fan configurations, including ACFs with horizontal axes,
ACFs with vertical axes, or bladeless ACFs. AHAM added that DOE has not
tested these different fan configurations. (AHAM, No. 123 at p. 8) DOE
notes that the DOE test procedure specifies testing ACFs only in a
horizontal configuration. DOE also notes that bladeless fans are
excluded from the proposed scope for ACFs, as discussed in section
III.B.2 of this document. Therefore, DOE did not consider differences
in axis orientation or bladeless fans in its evaluation of ACF impeller
topology or improved impeller design.
DOE received feedback during confidential GFB manufacturer
interviews that increasing the diameter of a fan impeller can improve
the efficiency of a fan. Additionally, when comparing fans on the
market with different diameters and otherwise similar characteristics,
DOE observed that fans with larger diameters were typically more
efficient for certain equipment classes; therefore, DOE considered
increased impeller diameter as a technology option in this NOPR.
When reviewing available data from the market, its databases, and
information received during confidential manufacturer interviews, DOE
could not distinguish between the effects of improved housing design,
reduced manufacturing tolerances, addition of appurtenances, and
improved impeller design on the performance of GFBs; therefore, DOE has
grouped these technology options together and collectively refers to
them as ``aerodynamic redesign'' for GFBs in the remainder of this
document. For ACFs, DOE additionally lacked quantitative efficiency
data regarding specific impeller topologies and the addition of guide
vanes, and therefore grouped the addition of guide vanes as well as any
blade adjustments that improve the efficiency of ACFs, such as the
curvature or pitch, along with improved housing design, reduced
manufacturing tolerances, addition of appurtenances, and improved
impeller design under the umbrella of aerodynamic redesign for ACFs in
the remainder of this document. The technology options considered under
aerodynamic redesign for both GFBs and ACFs are summarized in Table IV-
7.
DOE previously considered ``material selection'' in general as a
technology option in the February 2022 RFI. 87 FR 7048, 7052. For this
NOPR, DOE is clarifying that material selection is specific to impeller
materials. DOE did not receive comments from stakeholders pertaining to
material selection for either the February 2022 RFI or the October 2022
NODA; however, during confidential interviews, manufacturers stated
that minimal efficiency gains would be achieved by changing the blade
material. When reviewing manufacturer fan selection software data, DOE
identified similar fans with different blade materials and investigated
the impact of different materials on FEI. Consistent with manufacturer
feedback, DOE found that material selection of the impeller had minimal
or no impact on efficiency for either GFBs or ACFs. Therefore, DOE did
not consider material selection as a technology option in this NOPR.
With regard to transmissions, DOE notes that the DOE test procedure
includes a loss factor associated with belt-drive transmissions, while
direct-drive transmissions are treated as having no loss when
calculating efficiency. This indicates that replacing a belt-drive with
a direct-drive transmission can improve efficiency. For ACFs, DOE
considered the change from belt-drive to direct-drive as a technology
option. For GFBs, as discussed in section IV.A.1.a, DOE is proposing to
establish separate equipment classes for GFBs sold with or without
motor controllers to account for the added utility provided by GFBs
with motor controllers (i.e., variable-speed operation to allow a fan
to adapt to changing load requirements). Belt-drive transmissions can
be manually adjusted during installation to achieve all airflow and
pressure operating requirements in a fan's operating range for
different field applications, whereas direct-drive fans would only be
able to achieve all operating points within the fan's operating range
if paired with a motor controller. As a result, DOE did not consider
the shift from belt-drive to direct-drive transmission as a technology
option for GFBs to maintain the added utility provided by belt-drive
transmission.
Regarding motors, motor efficiency can depend on motor topology as
well as the individual design features of a single motor topology. For
example, most motors used in ACFs are permanent split capacitor
(``PSC'') motors, and these motors have a wide range of operating
efficiencies. In addition, some ACFs use electronically commutated
motors (``ECMs''). ECMs operate in a higher efficiency range than PSC
motors, so using an ECM may improve the overall efficiency of an ACF.
In this NOPR, DOE considers both switching to a more efficient motor
topology and improved efficiency of a single motor topology in the more
efficient motors technology option.
For GFBs, DOE learned from confidential manufacturer interviews
that motors are not always sold as integral parts of a fan. Many sales
of GFBs do not include a motor and require the customer to provide this
part. Furthermore, the motors used for GFBs are nearly all 3-phase
induction motors currently regulated by DOE, including motors between
100 and 150 hp. See 10 CFR 431.25. On June 1, 2023, DOE published an
energy efficiency standards direct final rule for these electric
motors. 88 FR 36066. In this rule, DOE increased the minimum required
efficiency of induction motors between 100 and 250 hp from IE 3 to IE
4. 88 FR 36066, 36144. IE 3 and IE 4 motor efficiencies are defined in
IEC 60034-30-1:2014: ``Rotating Electrical Machines--Part 30-1:
Efficiency classes of line operated AC motors (IE code),'' (``IEC
60034-30-1:2014'') published by the International Electrotechnical
Commission. The compliance date of this rule is June 1, 2027 and any
standards promulgated as a result of this fans rulemaking would take
effect after that date.
Because of the new 2027 electric motor standards, there will be
impacts on the motor market from a product availability, size, and
technology standpoint as the efficiency moves from IE 3 to IE 4. These
changes would need to be considered in this rulemaking, but electric
motor manufacturers are still in the design and planning process to
migrate their product offerings to be in compliance with the 2027
electric motors standards recently adopted. If DOE were closer to the
2027 compliance date or this was a first-time regulation for these
induction motors, DOE would be able to better understand how
manufacturers were going to fully
[[Page 3761]]
respond and the innovations that may be introduced into the market to
be able to carefully consider how the motors offerings could be
considered as part of the CIFB designs affecting the fan efficiencies.
At this time, DOE does not have sufficient data to fully evaluate the
impact of those efficiency and technology changes on the proposed
efficiency levels (``ELs''). DOE has therefore not evaluated more
efficient motors as a technology option for GFBs in this NOPR; however,
DOE may consider more efficient motors as a viable technology option
for improving GFB efficiency in a future rulemaking.
DOE evaluated more efficient motors for ACFs in the October 2022
NODA. 87 FR 62038, 62042. DOE also assumed that all ACFs are sold with
a motor. Id. Furthermore, DOE requested comment on its estimated base
manufacturer production cost for ACFs excluding motors. 87 FR 62038,
62053. In response, AMCA commented that, to the best of its knowledge,
ACFs are always sold with motors. (AMCA, No. 132 at p. 12) In this
NOPR, DOE therefore continued with its assumption that all ACFs are
sold with motors.
In the October 2022 NODA, DOE assumed that most motors paired with
ACFs are lower efficiency induction motors that were not regulated by
DOE and requested comment on that assumption. 87 FR 62038, 62042. DOE
also requested data on the percentage of ACFs sold with split-phase,
PSC, shaded-pole and ECMs. 87 FR 62038, 62049. In response, AMCA
commented that some of its members sell ACFs with shaded-pole motors,
PSC motors, polyphase motors, or ECMs. (AMCA, No. 132 at p. 3) NEMA
commented that, depending on the horsepower requirements, a split-
phase, shaded-pole, capacitor start/capacitor run, or three-phase motor
could be used for ACFs. NEMA added that shaded-pole motors are often
used at 0.1 hp and under for ACFs, while PSC motors are very common for
1 hp and under. (NEMA, No. 125 at p. 3) In response to this feedback,
DOE conducted a review of its updated ACF database (discussed further
in section IV.A.2.b) and identified ACFs sold with multiple different
motor topologies, including PSC, polyphase, and EC motors.
Additionally, DOE identified many ACFs using PSC motors at high and low
motor efficiencies. Because DOE has identified that ACF motor
efficiency may be improved through changing motor topology as well as
improving efficiency within a single motor topology, it considered both
switching to a more efficient motor topology and improving efficiency
within a single motor topology as components of the more efficient
motors technology option for ACFs.
Regarding motor controllers, motor controllers are used to change
the operating point of fans by altering their motor speed. This allows
a fan to operate at a lower speed when possible, which can result in a
reduction of power consumption. In response to the October 2022 NODA,
the Efficiency Advocates encouraged DOE to evaluate fans that operate
at multiple speeds, rather than just the highest speed, because
lowering the fan speed can significantly reduce the amount of power
used by a fan. (Efficiency Advocates, No. 126 at p. 2-3) Conversely,
AMCA stated that the utility of ACFs to provide the necessary air-throw
distance and air velocity may be diminished or removed entirely by
reducing the fan speed with motor controllers, which is a negative
impact on product utility. (AMCA, No. 132 at p. 3) While DOE
acknowledges that fan power consumption can be reduced by lowering the
speed of a fan, it notes that the DOE test procedure for ACFs specifies
testing and reporting efficacy for ACFs at the maximum speed of the
fan. See appendix B to subpart J of 10 CFR part 431, section 2.2.1.
DOE's analysis in this NOPR remains consistent with the DOE test
procedure for ACFs, so DOE did not evaluate efficiencies at less than
maximum speed. Therefore, DOE did not consider motor controllers as a
technology option for ACFs in this NOPR.
In response to the October 2022 NODA, the CA IOUs commented that
choosing a low-speed range for a particular impeller improves its
efficiency. (CA IOUs, No. 127 at p. 2) DOE notes the speed and
operating point of a fan are strongly related and that any change to
the speed of a fan will likely change the utility of that fan.
Therefore, DOE did not consider reduced speed as a technology option
for this NOPR.
As discussed in section IV.A.1.a, GFBs with motor controllers allow
a fan to adapt to changing load requirements. While this may result in
energy savings during application, the DOE test procedure for fans does
not account for these possible changes in operation and energy savings.
As a result, DOE is proposing to establish separate equipment classes
for GFBs sold with and without motor controllers and is not considering
motor controllers as a technology option.
Table IV-7 lists the technology options for GFBs and ACFs that DOE
evaluated in its screening analysis. Both GFBs and ACFs include an
aerodynamic redesign technology option, which contains technology
options that DOE determined to be viable, but for which DOE lacked
sufficient data to fully analyze individually.
[GRAPHIC] [TIFF OMITTED] TP19JA24.025
[[Page 3762]]
Further details on technology options that DOE considered for this
NOPR can be found in chapter 3 of the NOPR TSD.
B. 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. Technologies that are not
incorporated in industrial equipment or in commercially viable,
existing prototypes will not be considered further.
(2) Practicability to manufacture, install, and service. If it is
determined that mass production of a technology in industrial equipment
and reliable installation and servicing of the technology could not be
achieved on the scale necessary to serve the relevant market at the
time of the projected compliance date of the standard, then that
technology will not be considered further.
(3) Impacts on product utility. If a technology is determined to
have a significant adverse impact on the utility of the equipment to
subgroups of consumers, or results in the unavailability of any covered
equipment type with performance characteristics (including
reliability), features, sizes, capacities, and volumes that are
substantially the same as products generally available in the United
States at the time, it will not be considered further.
(4) Safety of technologies. If it is determined that a technology
would have significant adverse impacts on health or safety, it will not
be considered further.
(5) Unique-pathway proprietary technologies. If a technology has
proprietary protection and represents a unique pathway to achieving a
given efficiency level, it will not be considered further, due to the
potential for monopolistic concerns.
10 CFR 431.4; 10 CFR part 430, subpart C, appendix A, sections
6(c)(3) and 7(b).
In summary, 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.
Through a review of each technology, DOE tentatively concludes that
the technologies listed in Table IV-7 of this document met all five
screening criteria to be examined further as design options in DOE's
NOPR analysis. Comments DOE received regarding screening for these
technologies are discussed below.
In response to the October 2022 NODA, DOE received several comments
pertaining to how the screening criteria apply to aerodynamic redesign,
blade shape, and motors. AMCA stated that aerodynamic efficiency
improvements can often lead to an increase in the cost and complexity
of manufacturing, which can have an adverse impact on the
practicability of manufacturing. AMCA added that some ACF components
that can be adjusted to improve efficiency are patentable, including
impellers, impeller blades, impeller rings, housings, outlet
appurtenances, and motors, which relates to the screening criteria for
unique-pathway proprietary technologies. (AMCA, No. 132 at p. 3). AMCA
also commented that the removal of a safety guard on an ACF to increase
its efficiency would decrease the safety of an ACF, which is an adverse
impact on health or safety. Id.
Regarding AMCA's comment on the potential for increased cost or
complexity of manufacturing associated with an aerodynamic redesign,
DOE notes that it accounted for this increased cost and complexity
through conversion costs, which are discussed in section IV.J.
Regarding patentable technologies, DOE notes that in manufacturer
interviews, it specifically asked about whether patentable technologies
could pose a problem in meeting energy conservation standards. In
response, no GFB or ACF manufacturers expressed concerns regarding
patents. Therefore, DOE has tentatively concluded that none of the
proposed design options meet the unique pathway-proprietary
technologies screening criteria.
In terms of safety guards, DOE agrees that the removal of a safety
guard would compromise the safety of a fan.
DOE notes that the motor efficiency technology options are based on
general industry standards rather than specific motor designs that
could be patented; therefore, DOE has tentatively concluded that the
unique-pathway proprietary technologies screening criterion does not
apply to the more-efficient motor technology option.
DOE did not receive comment related to screening for any other
technology options. The remaining technology options that DOE did not
screen from its analysis are listed in Table IV-8.
[GRAPHIC] [TIFF OMITTED] TP19JA24.026
DOE has initially determined that these technology options are
technologically feasible because they are being used or have previously
been used in commercially available equipment or working prototypes.
DOE also finds that all of the remaining technology options meet the
other screening criteria (i.e., practicable to manufacture, install,
and service and do not result in adverse impacts on consumer utility,
product availability, health, or safety, unique-pathway proprietary
technologies). For additional details, see chapter 4 of the NOPR TSD.
[[Page 3763]]
C. Engineering Analysis
The purpose of the engineering analysis is to establish the
relationship between the efficiency and cost of fans and blowers. There
are two elements to consider in the engineering analysis; the selection
of efficiency levels to analyze (i.e., the ``efficiency analysis'') and
the determination of equipment cost at each efficiency level (i.e., the
``cost analysis''). In determining the performance of higher-efficiency
equipment, DOE considers technologies and design option combinations
not eliminated by the screening analysis. For each equipment class, DOE
estimates the baseline cost, as well as the incremental cost for the
equipment at efficiency levels above the baseline. The output of the
engineering analysis is a set of cost-efficiency ``curves'' that are
used in downstream analyses (i.e., the LCC and PBP analyses and the
NIA).
1. General Fans and Blowers
a. Baseline Efficiency
For each equipment class, DOE generally selects a baseline model as
a reference point for each class, and measures changes resulting from
potential energy conservation standards against the baseline. The
baseline model in each equipment class represents the typical
characteristics of that class (e.g., capacity, physical size).
Generally, a baseline model is one that just meets current energy
conservation standards, or, if no standards are in place, the baseline
is typically the most common or least efficient unit on the market.
As discussed in section II.B.1, there are currently no energy
conservation standards for GFBs. In this analysis, DOE set the baseline
efficiency as the lowest reasonable efficiency on the market after
removing potential outliers for each analyzed equipment class.
DOE established baseline ELs using performance data in the AMCA
sales database. DOE filtered the database by equipment class and
evaluated the fan performance range for each equipment class.
Additionally, as described in section IV.A.3, DOE based its GFB
analysis on design options that specifically improve fan performance.
DOE did not consider improvements to the motor, transmission, or motor
controllers. Therefore, for this analysis, DOE calculated FEI according
to the bare shaft method described in the DOE Test Procedure. See
sections 2.2 and 2.6 of appendix A to subpart J of 10 CFR part 431. For
both the AMCA sales database and any manufacturer fan selection
software data, DOE recalculated FEI on a bare shaft basis. Accordingly,
the standards proposed in this notice are based only on fan design and
exclude any impact that the motor, transmission, or motor controllers
may have on fan efficiency.
Based on a review of the market, DOE tentatively determined that
the FEI values corresponding to the 5th percentile in the AMCA sales
database were generally representative of baseline efficiency across
all diameters and duty points within a given equipment class. Defining
baseline efficiency at the 5th percentile enabled DOE to remove
potential outlier fans and fans that may no longer exist on the market.
DOE compared the 5th percentile for each equipment class to data
retrieved from manufacturer fan selection software to ensure that
baseline efficiencies were representative of the current market. In
instances where the 5th percentile removed a substantial number of
models that had FEI values consistent with what was seen on the market,
DOE adjusted the baseline efficiency to align with the distribution of
FEIs observed in the manufacturer fan selection software. Additional
details on the development of baseline efficiency levels for each
equipment class are included in chapter 5 of the NOPR TSD.
b. Selection of Efficiency Levels
DOE typically uses one of two approaches to develop energy
efficiency levels for the engineering analysis: (1) relying on observed
efficiency levels in the market (i.e., the efficiency-level approach),
or (2) determining the incremental efficiency improvements associated
with incorporating specific design options to a baseline model (i.e.,
the design-option approach). Using the efficiency-level approach, the
efficiency levels established for the analysis are determined based on
the market distribution of existing equipment (in other words, based on
the range of efficiencies and efficiency level ``clusters'' that
already exist on the market). Using the design option approach, the
efficiency levels established for 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. DOE may also rely on
a combination of these two approaches. For example, the efficiency-
level approach (based on actual equipment on the market) may be
extended using the design option approach to ``gap fill'' levels (to
bridge large gaps between other identified efficiency levels) and/or to
extrapolate to the max-tech level (particularly in cases where the max-
tech level exceeds the maximum efficiency level currently available on
the market).
In this NOPR, DOE relied on a combination of the efficiency level
and design-option approaches. DOE used the efficiency level approach to
determine the baseline, max-tech, and aerodynamic redesign efficiency
levels and used the design-option approach to gap fill intermediate
efficiency levels.
General Approach
DOE applied design options to the initial efficiency levels
evaluated above baseline for each equipment class. As discussed in
section IV.A.3, DOE has identified the following design options for
GFBs:
Impeller topology;
Addition of guide vanes;
Increased impeller diameter; and
Aerodynamic redesign (improved housing design, reduced
manufacturing tolerances, addition of appurtenances, improved impeller
design).
For each equipment class, DOE evaluated both the AMCA sales
database as a whole and data from manufacturer fan selection software
for specific representative diameters and operating points to set the
efficiency levels and associated design options for its analysis. DOE
used data pulled from manufacturer fan selection software to understand
the incremental impact of design options on fan performance and cost.
DOE then applied these incremental FEI increases to the baseline fan
for each equipment class to set intermediate efficiency levels.
To estimate the incremental increases in FEI, DOE first selected
between three and six representative operating points based on the fan
diameters, operating pressures, and airflows that were most common for
each equipment class in the AMCA sales database, as discussed in
section IV.A.2.a. DOE then used manufacturer fan selection software to
obtain data for each representative operating point at a specific
diameter, airflow, and pressure. From the manufacturer fan selection
software, DOE evaluated how FEI changed as various design options were
applied while holding constant the diameter (for all equipment classes
except PRVs) and duty point. DOE calculated bare shaft FEI for fans
evaluated using manufacturer fan selection software to eliminate the
effects of transmission on the efficiency. Additional details on how
manufacturer fan selection software was evaluated and used in the
development of intermediate efficiency levels are included in chapter 5
of the NOPR TSD.
[[Page 3764]]
DOE recognizes that relying on data from fans at representative
diameters and operating points to characterize efficiency improvements
may not sufficiently account for the entire range of duty points and
diameters typical for each equipment class. Therefore, after
determining the impact of potential design options on fan efficiency
using the manufacturer fan selection software, DOE used the AMCA sales
database to validate the estimated incremental FEI increases for each
design option. In its review of the market, DOE found that most
manufacturer model numbers correspond to a specific impeller type and
design. To make comparisons between fan models in the AMCA sales
database, DOE used the model numbers included in the AMCA sales
database to characterize each fan's impeller. DOE then evaluated the
potential efficiency gain of each design option across the entire range
of operating points in the AMCA sales database. For example, for
centrifugal housed fans, DOE calculated the average increase in FEI
that would be observed for a fan with a backward-inclined impeller at a
given diameter compared to a fan with a forward-curved impeller at the
same diameter. DOE evaluated the AMCA sales database in this way to
confirm that its estimated increases in FEI seemed feasible across the
range of operating duty points, since the AMCA sales database contains
data points at a variety of duty points for each equipment class.
In response to the July 2022 TP NOPR, AHRI commented that fan
performance in the AMCA sales database was never confirmed to be
reflective of embedded fans, including system effect, and that
finalizing the determination using the analysis conducted to date,
especially if embedded fans are within the scope, would be
inappropriate. (Docket No. EERE-2021-BT-TP-0021, AHRI, No. 40 at p. 13)
DOE notes that, as discussed in III.B.1, embedded fans listed in Table
III-1 are outside the scope of this analysis. All other fans within the
scope of this rulemaking would be tested in accordance with the DOE
test procedure, which reflects performance of fans outside of equipment
into which they may be installed and does not evaluate system effects.
Additionally, in response to the October 2022 NODA, Morrison
suggested that the data evaluation and analysis conducted in the 2016
NODA should be restarted to address current stakeholder concerns and
account for changes in the market environment, including widespread
adoption of building codes and use of the FEI metric. (Morrison, No.
128 at p. 3) In response to the July 2022 TP NOPR, AHRI commented that
it is not reasonable to assume that substitutions can be made for any
fan within 20 percent of static pressure or airflow requirements and
within two inches of the original diameter tolerances. AHRI stated that
selecting a fan that two inches larger in diameter would translate to a
four-inch increase in housing size. Additionally, AHRI commented that
commercial heating, ventilation, and air conditioning (``HVAC'')
equipment fan selection requires design to a specific airflow and
static pressure and that in virtually all cases, a two-percent
selection window is required so the 20 percent selection window would
not satisfy the heating, cooling or ventilation needs for the
application. (Docket No. EERE-2021-BT-TP-0021, AHRI, No. 40 at p. 12-
13) Furthermore, AHRI commented that variable air volume systems and
systems with economizers need to operate over a range of airflow. Low
static, high airflow fans (forward-curved fans) are used in these
applications; therefore, the number of fans that would require redesign
is closer to 100 percent than the 30 percent included in the NODA 3
(2016 NODA) analysis. (Id.)
DOE notes that all analyses from the 2016 NODA have been
reevaluated in this NOPR to reflect current market trends and industry
standards. While DOE maintained some structural elements from the 2016
NODA, such as some equipment classes and use of the AMCA sales
database, DOE updated its efficiency levels and cost analyses based on
manufacturer feedback from recent interviews, publicly available sales
data, and a thorough review of the current market. Additionally, in
this analysis, DOE did not assume that static pressure or airflow could
vary by 20 percent or that the diameter of embedded fans could increase
by any amount. In its analysis for this NOPR, DOE evaluated efficiency
increases with operating point and diameter remaining constant for fan
equipment classes that could be embedded in equipment, which is
discussed in more detail in section IV.C.1.b (subsection Determination
of Efficiency Levels). Additionally, DOE's analysis reflects that
forward-curved fans should be preserved in the market and would likely
be redesigned to do so. In section IV.C.1.b (see subsection Parallel
Design Path for Forward-curved Fans), DOE describes how it analyzed
forward-curved fans. DOE also evaluated the potential impact of duty
point on whether a fan could be redesigned to higher FEI levels. Using
the AMCA sales database, DOE developed FEI distributions for each
equipment class to evaluate how FEI varied with specified design
pressure, airflow, and diameter. Based on these FEI distributions, DOE
was not able to identify any duty point ranges with disproportionately
lower fan availability at higher FEI values for any equipment class.
DOE has tentatively determined that the efficiency relationships it
developed based on the selected representative operating points could
be applied to fans at other diameters and duty points; therefore, there
is only one set of efficiency levels for each equipment class.
Determination of Efficiency Levels
The first design option that DOE evaluated for most equipment
classes was changing the fan impeller. Based on its review of the
market, DOE determined that manufacturers often have a variety of
impeller topologies available for each fan class. For example, some
manufacturers have economy impellers, which are less efficient and less
expensive than other available impellers. DOE also found that
manufacturers may have impellers that are designed to operate at
different duty points, such as high-pressure impellers. These impellers
achieve different levels of performance based on blade shape, blade
pitch, number of blades, etc. Therefore, rather than attempt to
characterize each of these individual impellers and how they may impact
FEI, DOE evaluated manufacturer fan selection software to estimate the
average increase in FEI for a typical impeller change for each
equipment class and then used the AMCA sales database to validate that
these increases are applicable to the broader fans market. DOE notes
that the centrifugal housed equipment class is the only equipment class
for which specific impeller changes were characterized. This is because
DOE was able to identify distinct differences in efficiency between
forward-curved, backward-inclined or backward-curved,\56\ and airfoil
impellers for centrifugal housed fans. The impeller change design
options were either applied to the baseline fan or applied successively
to a previous impeller change.
---------------------------------------------------------------------------
\56\ In reviewing both the AMCA sales database and manufacturer
fan selection software, DOE was unable to distinguish between
backward-inclined and backward-curved impellers for many fan models.
It is also DOE's understanding that both backward-inclined and
backward-curved impellers perform similarly regarding fan
efficiency. Therefore, DOE considered both backward-inclined and
backward-curved impellers together as a single design option.
---------------------------------------------------------------------------
[[Page 3765]]
DOE followed a similar method of analyzing both the manufacturer
fan selection software and the AMCA sales database to estimate the
increase in FEI that could be achieved for design options other than
impeller changes, including substituting a tube axial fan for a vane
axial fan, substituting a mixed flow fan for a centrifugal inline fan,
and increasing the PRV fans diameter. Additional details on how DOE
estimated the incremental increases in FEI for each design option and
for each equipment class are included in chapter 5 of the NOPR TSD.
For many categories of fans, increasing the diameter of a fan could
increase efficiency when a fan operates at the same duty point;
however, during manufacturer interviews, DOE received feedback that
increasing the diameter of a fan is only applicable to certain fan
classes. Specifically, DOE learned that increasing the diameter of a
fan that would be embedded in OEM equipment could impact the overall
performance of the equipment, could impact its utility for use in
space-constrained OEM equipment, and would substantially increase OEM
redesign costs. Alternatively, for fan types that do not have space-
constraints, a fan could typically be increased by one or two sizes
without impacting the utility of the fan.
For fan equipment classes that could be embedded, either into other
equipment or into spaced constrained applications, such as ducted
ventilation systems, DOE did not consider increased impeller diameter
as a design option. These types of fans include axial inline, panel,
centrifugal housed, centrifugal unhoused, and centrifugal inline fans.
For radial fans, DOE analyzed the diameter increase design option
since this fan class is typically not used in space-constrained
applications; However, DOE did not observe consistent efficiency
changes with increased diameter for radial fans; therefore, DOE did not
consider larger fan diameter as a design option for radial fans.
In general, PRVs (axial PRV, centrifugal PRV exhaust, and
centrifugal PRV supply) are not subject to the same size and weight
constraints experienced by other embedded fan classes. These units are
placed in open air environments to supply or exhaust air from the top
of a building, which enables them to increase in size. DOE found that
increasing PRV diameter consistently increases the efficiency;
therefore, DOE considered diameter increase as a design option for
axial and centrifugal PRVs.
DOE requests comment on its understanding that the diameter
increase design option could be applied to non-embedded, non-space-
constrained equipment classes.
In its analysis for axial and centrifugal PRVs, DOE used an 18-
percent increase in diameter to represent a diameter increase and
rounded the impeller diameter to the nearest whole number, since DOE
found that the 18-percent increase was representative of the fan sizes
available on the market. For example, the increased diameter design
option for a 15-in. diameter fan would increase the fan diameter to 18-
in. and a 36-in. diameter fan would increase to a 42-in. diameter fan.
When analyzing its data sources, DOE found that this 18 percent
diameter increase when maintaining the operating point could result in
a range of FEI increases, from as low as 4-percent to as high as 30-
percent, corresponding to a FEI increase of approximately 0.03 to 0.30.
For this NOPR analysis, DOE assumed that a diameter increase for
centrifugal PRV exhaust and supply fans would result in a 0.03 increase
in FEI and a diameter increase for axial PRV fans would result in a
0.09-0.10 increase in FEI. DOE recognizes that initial diameter size,
operating airflow, and operating pressure may impact how effective an
impeller diameter increase is for increasing FEI. Specifically, the
duty points that DOE chose to evaluate may be duty points where a
diameter increase is very effective at increasing fan efficiency or may
be duty points where a diameter increase has minimal impact on fan
efficiency. DOE could adjust the efficiency gains from an impeller
diameter increase in its analysis so that there is a larger FEI gain
for all PRVs, and where PRVs could reach higher FEI values for a lower
cost. Alternately, DOE could decrease the FEI gain for axial PRVs from
an impeller diameter increase, allowing axial PRVs to reach higher FEI
values for a higher cost since the impeller diameter increase would no
longer provide such a large increase in FEI.
DOE requests comment on whether the FEI increases associated with
an impeller diameter increase for centrifugal PRVs and for axial PRVs
are realistic. Specifically, DOE requests comment on whether it is
realistic for axial PRVs to have a FEI increase that is 3 times greater
than that for centrifugal PRVs when starting at the same initial
diameter. Additionally, DOE requests comment on the factors that may
impact how much an impeller diameter increase impacts a FEI increase.
In its analysis, DOE applied the impeller changes and aerodynamic
redesigns for PRVs to the baseline fan such that PRVs could reach
higher efficiency levels while maintaining the baseline impeller
diameter. While manufacturers would have the option of achieving higher
efficiencies by increasing fan diameter, DOE assumed that if
manufacturers were to change the impeller or redesign a PRV,
manufacturers would apply these design changes to their entire diameter
range, enabling the baseline diameter fan to reach the higher
efficiency levels.
The design path for all PRVs is shown in Table IV-11. For the PRV
equipment classes, the impeller change(s) and diameter increase(s) are
ordered by FEI increase, where the design option with the smallest FEI
increase is ordered first. DOE could consider an analysis with a
different ordering of design option based on MSP increase or cost-
effectiveness. Alternately, DOE could consider an analysis that does
not include increased fan diameter as a design option. In this
alternative analysis, DOE could consider an additional impeller change
as a design option to increase FEI. However, based on its analysis, DOE
expects that removing increased fan diameter as a design option in its
analysis would increase the cost to achieve a higher efficiency of a
PRV.
DOE requests comment on the ordering and implementation of design
options for centrifugal PRV exhaust and supply fans and axial PRV fans.
DOE additionally determined that manufacturers may improve
efficiency through aerodynamic redesign, as described in section IV.A.3
of this document. It is DOE's understanding that aerodynamic redesign
may require significant product and capital investment. Accordingly,
DOE only applied aerodynamic redesign after applying the design options
DOE expected would be less cost-intensive for manufacturers.
Additionally, the impact of aerodynamic redesign on efficiency is
expected to vary significantly depending on the design choices made by
the manufacturer. Therefore, DOE determined that the design option
approach would not be appropriate for evaluating efficiency
improvements for aerodynamic redesign. Instead, DOE evaluated
aerodynamic redesign using the efficiency level approach. Generally,
DOE set the FEIs for aerodynamic redesigns by assigning evenly spaced
FEIs between the highest non-redesign EL (i.e., the EL immediately
before the first aerodynamic redesign) and the max-tech EL. A numerical
example
[[Page 3766]]
demonstrating how FEIs were assigned to the aerodynamic redesign ELs
for the centrifugal PRV exhaust equipment class is provided in the
following section.
Existing Efficiency Standards
DOE also evaluated other efficiency programs to inform the
development of its efficiency levels. Energy efficiency provisions for
commercial fans are prescribed in U.S. building codes, primarily
developed by the International Code Council and specified in the
International Energy Conservation Code (``IECC''). The IECC was most
recently updated in 2021 (``IECC-2021'') and specifies that commercial
buildings shall comply with the requirements of ASHRAE 90.1.\57\ The
most recent edition of ASHRAE 90.1 was published in September 2022, and
sets an FEI target of 1.00 for all fans within the scope of ASHRAE
90.1.\58\ While the standards established under IECC and ASHRAE 90.1
are not federally mandated, they are used by individual States and
municipalities to support the development of local building codes. DOE
is also aware that the CEC has finalized a rulemaking, which requires
manufacturers to report fan operating boundaries that result in
operation at an FEI of greater than or equal to 1.00 for all fans
within the scope of that rulemaking.\59\ Furthermore, during
confidential manufacturer interviews, DOE received feedback that an FEI
of 1.00 is a realistic efficiency target and DOE does not have any
indication that an FEI of 1.00 would not be achievable for all fan
equipment classes.
---------------------------------------------------------------------------
\57\ International Code Council. ``2021 International Energy
Conservation Code Chapter 4: Commercial Energy Efficiency''.
September 2021. Available at codes.iccsafe.org/content/IECC2021P2/chapter-4-ce-commercial-energy-efficiency.
\58\ ASHRAE. ``Standard 90.1-2022--Energy Standard for Sites and
Buildings Except Low-Rise Residential Buildings.'' September 2022.
Available at www.ashrae.org/technical-resources/bookstore/standard-90-1.
\59\ California Energy Commission. Commercial and Industrial
Fans and Blowers. Docket No. 22-AAER-01. Available at
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
---------------------------------------------------------------------------
Based on this feedback and to align with the aforementioned
standards, DOE elected to evaluate an efficiency level at an FEI of
1.00 for all fan classes. The efficiency level and design option that
corresponds to an FEI of 1.00 differs for each equipment class
depending on the FEI difference between the baseline and max-tech
efficiency levels for each equipment class and the efficiency gain
identified for each design option. For the axial inline, centrifugal
inline, and centrifugal unhoused equipment classes, DOE determined that
an FEI of 1.00 could be achieved using the identified design options.
Therefore, each of these equipment classes has specific design options
associated with the EL set at an FEI of 1.00. For example, for the
centrifugal inline equipment class, DOE tentatively determined through
the design option approach that an FEI of 1.00 could be achieved by
using a mixed flow impeller (EL 3). For all other equipment classes,
DOE assumed that manufacturers could achieve an FEI of 1.00 through an
aerodynamic redesign.
For equipment classes that had an aerodynamic redesign assigned at
an EL with an FEI of 1.00, DOE evenly spaced all other aerodynamic
redesign ELs at FEIs above and below a value of 1.00, where applicable.
For example, the centrifugal PRV exhaust equipment class has a total of
four aerodynamic redesign ELs, with the second aerodynamic redesign (EL
4) corresponding to an FEI of 1.00. The highest non-redesign EL occurs
at EL 2, corresponding to an FEI of 0.76, and max- tech occurs at EL 6,
corresponding to an FEI of 1.37. Therefore, the first aerodynamic
redesign was set at the midpoint between EL 2 and EL 4, corresponding
to an FEI of 0.88, and the third aerodynamic redesign was set as the
midpoint between an FEI of 1.00 and the max-tech EL, corresponding to
an FEI of 1.19.
Parallel Design Path for Forward-Curved Fans
DOE received feedback during interviews that forward-curved
impellers should be preserved in the market because they offer distinct
utility over backward-inclined or airfoil impellers and typically
operate at lower pressures where efficiency is inherently lower.
However, as discussed in section IV.A.1.a, DOE has tentatively
determined that forward-curved fans do not require a separate equipment
class since the FEI metric is a function of operating pressure and
accounts for the inherently lower efficiency at lower pressures.
Instead, to assess any costs associated with preserving forward-
curved fans, DOE evaluated two parallel design paths for centrifugal
housed fans. DOE used the first design path (hereafter referred to as
the ``primary design path'') to evaluate all fans with impellers other
than forward-curved impellers. For the primary design path, DOE
observed a significant number of fans with backward-inclined impellers
that exhibited FEIs similar to those with forward-curved impellers,
despite backward-inclined impellers generally being more efficient.
Therefore, DOE assigned the same baseline FEI to both design paths and
assumed baseline efficiency on the primary design path to be
represented by an inefficient backward-inclined fan which would meet EL
1 via aerodynamic redesign of the backward-inclined impeller. EL 2 on
the primary design path represents substituting a more typical
backward-inclined impeller with an airfoil impeller to achieve an FEI
of 1.00.
For the second design path (hereafter referred to as the ``forward-
curved design path''), DOE assumed that the baseline efficiency was
represented by a forward-curved fan that would meet all subsequent ELs
via aerodynamic redesign while maintaining a forward-curved impeller.
The design options for both design paths are summarized in Table IV-9
and additional details on how DOE defined the efficiency levels for the
separate centrifugal housed design paths are provided in chapter 5 of
the NOPR TSD.
Additionally, for the forward-curved design path, EL 4 approaches
max-tech for forward-curved fans. Although DOE identified fans with
forward-curved impellers above this EL, DOE could not confirm that
forward-curved fans could be designed above this EL at all duty points.
Therefore, DOE defined the third aerodynamic redesign on the forward-
curved design path (EL 4) as the max-tech for forward-curved impellers
and assumed that any fans above this FEI would need to transition to a
backward-inclined or airfoil impeller. As such, all fans above EL 4
were analyzed using the primary design path.
DOE notes that, in practice, manufacturers may substitute forward-
curved impellers with a backward-inclined or airfoil impeller to
improve efficiency. However, based on DOE's review of the market and
stakeholder feedback on the importance of maintaining fans with
forward-curved impellers, DOE could not determine a representative
percentage of forward-curved fans that would be redesigned versus
substituted with a different impeller. Therefore, to avoid
underestimating the costs required to preserve forward-curved
impellers, DOE assumed that all forward-curved fans currently on the
market would maintain their impellers and follow the forward-curve
design path.
DOE utilized a dual-design path approach for centrifugal housed
fans to consider the fact that manufacturers may be required to incur
higher conversion costs to maintain use of forward-curved impellers.
DOE estimated the costs associated with redesigning forward-curved fans
using
[[Page 3767]]
the same method used to estimate aerodynamic redesign conversion costs
for all other equipment classes and product types, as discussed in
section IV.J.2.c. However, DOE may revise its analysis to consider
additional conversion costs for forward-curved fans if sufficient data
is provided to demonstrate that these fans may experience unique
challenges in meeting higher FEI values.
DOE requests comment on its approach for estimating the industry-
wide conversion costs that may be necessary to redesign fans with
forward-curved impellers to meet higher FEI values. Specifically, DOE
is interested in the costs associated with any capital equipment,
research and development, or additional labor that would be required to
design more efficient fans with forward-curved impellers. DOE
additionally requests comment and data on the percentage of forward-
curved impellers that manufacturers would expect to maintain as a
forward-curved impeller relative to those expected to transition to a
backward-inclined or airfoil impeller.
[GRAPHIC] [TIFF OMITTED] TP19JA24.027
Efficiency Levels for General Fans and Blowers Sold With a Motor
As discussed in the May 2023 TP Final Rule, DOE adopted the FEP and
FEI calculations specified in AMCA 214-21, which provides a method for
calculating the FEI of fans sold with motors based on a table of
polyphase regulated motors (See Annex A of AMCA 214-21). 88 FR 27312,
27348. However, as discussed in the May 2023 TP Final Rule, the DOE
test procedure replaces Annex A of AMCA 214-21 with a reference to the
current energy conservation standards for polyphase regulated motors in
10 CFR 431.25, with the intention that the values of regulated
polyphase motor efficiencies would remain up to date with any potential
future updates established by DOE. 88 FR 27312, 27349.
In a final rule published on June 1, 2023, DOE finalized amended
energy conservation standards for electric motors. These standards
adopted amended efficiency requirements for motors rated at or between
100 hp and 250 hp. Therefore, for GFBs sold with a motor rated at or
between 100 hp and 250 hp, FEI would be evaluated using the amended
efficiencies specified in table 8 of 10 CFR 431.25, in accordance with
the DOE test procedure. However, the motor efficiencies used to
calculate the reference fan FEP have not been similarly updated based
on the amended standards for electric motors. Therefore, the reference
fan FEP for GFBs with a motor rated at or between 100 hp and 250 hp
would be calculated using a motor efficiency that would not be
compliant with the adopted energy conservation standards for electric
motors and would no longer be available on the market. In other words,
the reference fan used in the FEI calculation would have a lower
efficiency than that required for electric motors, resulting in an
inappropriately greater FEI for the tested fan.
To avoid providing an unintended advantage to these GFBs, DOE
proposes that the FEI level for GFBs sold with a motor rated at or
between 100 hp and 250 hp would be calculated by applying a correction
factor to the FEI standard for GFBs sold with any other sized motor.
This correction factor would be designed to offset the difference in
motor efficiencies specified for the reference fan versus the amended
motor efficiency standards. DOE found that, at a given duty point, the
correction factor, A, can be expressed as a function of the motor
efficiency as follows:
[GRAPHIC] [TIFF OMITTED] TP19JA24.028
Where [eta]mtr,2023 is the motor efficiency in
accordance with table 8 at 10 CFR 431.25, and [eta]mtr,2014
is the motor efficiency in accordance with table 5 at 10 CFR 431.25 and
Annex A of AMCA 214-21, and FEPact is determined according to the DOE
test procedure in appendix A to subpart J of part 431. The FEI in
accordance with the proposed TSL would be multiplied by this correction
factor to result in the FEI standard. For fans with motors rated below
100 hp, the correction factor, A, would be equal to 1.00. DOE is also
proposing to add the motor efficiency requirements specified in Table 5
at 10 CFR 431.25 for motors rated at or between 100 hp and 250 hp in 10
CFR 431.175 and reference these values for the correction factor
calculation to ensure that these motor efficiency values are not
inadvertently removed in any separate motors rulemakings.
Efficiency Levels for General Fans and Blowers With a Motor Controller
As discussed in the May 2023 TP Final Rule, DOE adopted the FEP and
FEI calculation as specified in AMCA 214-21 but did not develop a
control credit for fans with a controller to offset
[[Page 3768]]
the losses inherent to the motor controller when calculating the FEI of
these fans at a given duty point. In the May 2023 TP Final Rule, DOE
stated that, to the extent use of a controller impacts the energy use
characteristics of a fan or blower, the test procedure should account
for such impact and that appropriate consideration of any such impact
would be part of the evaluation of potential energy conservation
standards. 88 FR 27312, 27371. DOE further stated that the FEP [and
FEI] metric penalizes the use of VFDs (variable speed drives which are
a category of motor controller), since these metrics incorporate the
losses from the VFD and that appropriate consideration of any such
impact would be part of the evaluation of potential energy conservation
standards. 88 FR 27312, 27372.
To avoid penalizing GFBs sold with a motor controller, DOE proposes
that the FEI standard for GFBs sold with a motor controller be
calculated by applying a credit to the FEI standard for GFBs sold
without a motor controller, where the credit is designed to offset the
losses inherent to the motor controller. To determine the credit, DOE
compared the FEP values of fans with a motor controller (FEPact,mc) to
the FEP values of the same fans without a motor controller, as
calculated in accordance with section 6.4.2.4 of AMCA 214-21 which
represents typical motor and motor controller performance, and using
the fan selection duty points provided in the sample of consumers.\60\
(See section IV.E.1). DOE found that, at a given duty point, the credit
can be expressed as a function of the FEP, in kW, as follows:
---------------------------------------------------------------------------
\60\ For this calculation, DOE used the AMCA 214-21 equations
for the motor and motor controller which are representative of the
losses of typical variable frequency drives instead of equations
discussed in section III.C.1 which were developed as representative
of less efficient, baseline, motor and motor controller combinations
(i.e., representative of lowest market efficiency).
[GRAPHIC] [TIFF OMITTED] TP19JA24.029
Where FEPact is the actual fan electrical input power of the fan
with a motor controller at the given duty point.
To convert the credit into a multiplier to the FEI and to calculate
the FEI values at each efficiency level considered for GFBs with a
motor controller, DOE relied on the following equation:
[GRAPHIC] [TIFF OMITTED] TP19JA24.030
Where FEIEL\no\mc is the FEI value at a given EL for a fan without
a motor controller.
When applying this equation, DOE observed that for GFBs with a
motor controller and with FEP values above 20 kW, the value of the
multiplier to the FEI is approximately constant and equal to 0.966.
Therefore, DOE proposes to simplify the calculation of FEI standards
for fans with motor controllers as follows:
[GRAPHIC] [TIFF OMITTED] TP19JA24.031
Further, considering the proposed addition of default calculation
methods to represent the combined motor and motor controller efficiency
(see section III.C.1.b), in the final rule, DOE may also consider an
alternative credit calculation based on the proposed equations in
section III.C.1.b which represent baseline (and not typical) motor and
motor controller performance, and would potentially result in a higher
credit.
DOE requests comment on the equations developed to calculate the
credit for determining the FEI standard for GFBs sold with a motor
controller and with an FEPact less than 20 kW and on
potentially using an alternative credit calculation based on the
proposed equations in section III.C.1.b of this document. Additionally,
DOE requests comment on its use of a constant value, and its proposed
value, of the credit applied for determining the FEI standard for GFBs
with a motor controller and an FEPact of greater than or
equal for 20 kW.
[[Page 3769]]
c. Higher Efficiency Levels
As part of DOE's analysis, the maximum available efficiency level
is the highest efficiency unit currently available on the market. DOE
also defines a ``max-tech'' efficiency level to represent the maximum
possible efficiency for a given product. Similar to the baseline
efficiency levels, DOE established max-tech efficiency levels by
reviewing the performance data in the AMCA sales database. DOE
initially evaluated max-tech for each class using the FEI corresponding
to the 95th percentile (i.e., the FEI resulting in a 5-percent pass
rate). DOE used the 95th percentile instead of the absolute maximum FEI
observed in the AMCA sales database to avoid setting a max-tech FEI
that may not be achievable across most of a fan's operating range. DOE
further refined these levels based on manufacturer fan selection
software performance data collected at the representative diameters and
operating points for each class. Additional details on the selection of
max-tech efficiency levels can be found in chapter 5 of the NOPR TSD.
As previously described, DOE assigned design options and
corresponding FEIs to each equipment class based on the analysis
described in sections IV.C.1.a-b. DOE conducted this analysis up to a
max-tech EL for each equipment class. Final results are shown in Table
IV-11. These results were used in all downstream analyses for this
NOPR.
BILLING CODE 6450-01-P
[GRAPHIC] [TIFF OMITTED] TP19JA24.032
[[Page 3770]]
Potential Adjustments to Efficiency Levels Based on AMCA 211 Tolerances
GFBs can be certified by AMCA to bear the AMCA certified ratings
seal. AMCA publishes a manual prescribing the technical procedures to
be used in connection with the AMCA Certified Ratings Program for fan
air performance: ``AMCA 211-22 (Rev. 01-23)--Certified Ratings
Program--Product Rating Manual for Fan Air Performance'' (``AMCA 211-
22'')
Certified AMCA GFBs are subject to precertification and periodic
check tests as defined in section 10 of AMCA 211-22. When products are
check tested, the check test performance must be within the tolerance
for airflow, pressure, and power when compared with the manufacturer's
catalog data. Specifically, section 10 of AMCA 211-22 allows for a 5
percent tolerance on the fan shaft power when conducting a
precertification check test and a 7.5 percent tolerance when conducting
a periodic check test.
As discussed in section IV.A.2.a, DOE conducted the GFB engineering
analysis for this NOPR primarily using a database of confidential sales
information provided by AMCA, which includes AMCA certified data
related to fan shaft power at a given duty point. DOE also relied on
manufacturer fan selection software from manufacturers that are AMCA
members, which frequently provided data that was AMCA certified.
DOE understands that it may be common practice for manufacturers to
include the AMCA 211-22 tolerance when submitting performance data to
AMCA. As a result, the fan shaft power data included in the AMCA sales
database and manufacturer fan selection software may include a 5 to
7.5-percent tolerance and may be underestimated.\61\ For the final
rule, DOE is considering adjusting the fan shaft power values included
in the performance data used in its analysis to account for this
tolerance. In the final rule, DOE is also considering adjusting the
values of FEI associated to each efficiency level analyzed to account
for this tolerance.
---------------------------------------------------------------------------
\61\ For example, a manufacturer may report a value of 92.5
instead of 100 to incorporate a 7.5 percent tolerance.
---------------------------------------------------------------------------
DOE may consider revising the brake horsepower values in the AMCA
sales database and from manufacturer fan selection software by
increasing each value by 5 percent. DOE used the 5-percent
precertification check test tolerance for the adjustments, as DOE
expects this would be the tolerance applied to any ratings certified to
AMCA. This would result in lower FEI values for each data point and
could result in lower FEI values associated with each EL.
To determine how this may impact the analysis, DOE increased the
brake horsepower values in the AMCA sales database by 5 percent and
recalculated the bare shaft FEIs of all fans in the database. As
discussed in section IV.C.1, the baseline and max-tech FEIs of all
equipment classes were determined based on percentiles in the AMCA
sales database. DOE used the same percentiles to determine the baseline
and max-tech for each equipment class using the recalculated bare shaft
FEIs. For efficiency levels that were based on the design option
approach (e.g., impeller changes), DOE maintained the percent increases
in FEI associated with each design option to determine the adjusted
FEI. For ELs that were based on the efficiency level approach (i.e.,
aerodynamic redesigns), DOE adjusted the FEI levels to maintain the
same percentage of models that meet each aerodynamic redesign
efficiency level (i.e., pass rate). The FEI values in Table IV-12 show
what the results of the engineering analysis may look like if the
tolerance that is allowed in AMCA 211-22 is considered in the
databases.
[[Page 3771]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.033
BILLING CODE 6450-01-C
DOE requests comments on whether it should apply a correction
factor to the analyzed efficiency levels to account for the tolerance
allowed in AMCA 211-22 and if so, DOE requests comment on the
appropriate correction factor. DOE requests comment on the potential
revised levels as presented in Table IV-12. Additionally, DOE requests
comments on whether it should continue to evaluate an FEI of 1.00 for
all fan classes if it updates the databases used in its analysis to
consider the tolerance allowed in AMCA 211-22.
Additionally, DOE does not anticipate that the efficiency levels
captured in Table IV-12 would impact the cost, energy, and economic
analyses presented in this document. As such, DOE considers the results
of these analyses presented throughout this document applicable to the
efficiency levels with a 5% tolerance allowance. DOE seeks comment on
the analyses as applied to the efficiency levels in Table IV-12.
d. Cost Analysis
The cost analysis portion of the engineering analysis is conducted
using one or a combination of cost approaches. The selection of cost
approach depends on a suite of factors, including the availability and
reliability of public information, characteristics of the regulated
equipment, and the availability and timeliness of purchasing the
equipment on the market. The cost approaches are summarized as follows:
Physical teardowns: Under this approach, DOE physically
dismantles commercially available equipment, component-by-component, to
develop a detailed bill of materials for the equipment.
Catalog teardowns: In lieu of physically deconstructing
equipment, DOE identifies each component using parts diagrams
(available from manufacturer websites or appliance repair websites, for
example) to develop the bill of materials for the equipment.
Price surveys: If neither a physical nor catalog teardown
is feasible (for example, for tightly integrated products such as
fluorescent lamps, which are infeasible to disassemble and for which
parts diagrams are unavailable) or cost-prohibitive and otherwise
impractical (e.g., large commercial boilers), DOE conducts price
surveys using publicly available pricing data published on major online
retailer websites and/or by soliciting prices from distributors and
other commercial channels.
In the present case, DOE conducted its analysis for GFBs using a
combination of price surveys from manufacturer fan selection software,
the AMCA sales database, and physical teardowns. DOE notes that due to
time constraints and the variety of fans available in the market (e.g.,
commercial or industrial application, construction class, equipment
class), DOE was unable to conduct sufficient teardowns to rely solely
on a manufacturer production cost (``MPC'') approach informed by
physical teardowns. Therefore, DOE used manufacturer sales prices
(``MSP'') for its cost analysis since DOE had substantially more MSP
data than MPC data available for GFBs. When DOE pulled data from
manufacturer fan selection software, the fan MSP was typically
included; if the MSP was not included, DOE requested quotes to obtain a
sales price. The AMCA sales database includes confidential total sales
value and total sales volume for each fan model. DOE divided the total
sales value by the sales volume to calculate the MSP for a single fan.
MSPs from the AMCA sales database were
[[Page 3772]]
adjusted to 2022 dollars to account for inflation.\62\
---------------------------------------------------------------------------
\62\ DOE used the Federal Reserve Economic Data's ``Producer
Price Index by Industry: Fan, Blower, Air Purification Equipment
Manufacturing'' to account for inflation to 2022 dollars. DOE used a
multiplication factor of 1.4 to convert from 2012 dollars to 2022
dollars. (fred.stlouisfed.org/series/PCU333413333413)
---------------------------------------------------------------------------
DOE recognizes that fan costs would not follow a simple scaling
model as there are several factors that could impact the sales price of
a fan, including construction class,\63\ drive assembly, production
volume, manufacturer purchasing power, mark-up, commercial or
industrial application, etc. To account for these factors, DOE averaged
MSPs from the AMCA sales database at each diameter for each fan
equipment class to conduct its cost analysis. Average MSPs were
obtained at a range of duty points that DOE determined to be reflective
of the entire market, rather than only at the specific representative
operating points that DOE selected. Additionally, based on its analysis
of manufacturer fan selection software, DOE determined that fans may be
sold with a variety of motors, each with a distinct cost that
contributes to the overall selling price. Therefore, DOE decided to use
average MSPs to account for the variety of motors on the market, rather
than attempt to evaluate fan costs without a motor by subtracting an
assumed unique motor cost from each fan in the AMCA sales database.
This process was completed to ensure that all fan design options were
evaluated with constant motor and motor controller cost estimates and
DOE notes that the MSP change from EL to EL ultimately drives the
downstream analyses. While DOE recognizes that an average is not
representative of all fan designs, DOE had limited data and therefore
determined that an average would provide the most representative
estimate based on the data available.
---------------------------------------------------------------------------
\63\ Fans can be grouped into three AMCA construction classes
(Class I-III) based on operation static pressure and outlet
velocity. A Class I fan would have a lower operating static pressure
and outlet velocity than a Class III fan. As a result, Class I fans
tend to have a less-rugged construction than Class II-III fans.
---------------------------------------------------------------------------
DOE used data from both the AMCA sales database and sales data
pulled from manufacturer fan selection software to create an MSP versus
diameter curve for each equipment class. First, DOE averaged the MSPs
in the AMCA sales database, as discussed earlier, to generate an MSP-
versus-diameter curve. DOE then calibrated this curve with MSPs from
manufacturer fan selection software. DOE used the MSP-versus-diameter
curves to determine the baseline MSP for each equipment class at a
given diameter.
As discussed in section IV.C.1.b, DOE used individual design
options for the lower ELs in each class and aerodynamic redesign for
the higher ELs. To determine the incremental costs associated with the
design option ELs above baseline, DOE compared the MSPs of similarly
constructed fans operating at the same duty point. For example, DOE
evaluated the increase in MSP for impeller changes by calculating the
percentage change in MSP for two fans operating at the same duty point
and with similar housings, but different impeller designs. DOE averaged
changes in MSP for each analyzed fan within each equipment class to
obtain typical incremental costs for each design option, which were
applied above baseline to obtain MSPs for each efficiency level. For
fans where diameter increases were evaluated as a design option, DOE
used the diameter-versus-MSP curves to estimate the increase in MSP
relative to the baseline fan. As discussed in section IV.C.1.b, DOE
used an 18-percent increase as the standard value for each impeller
diameter increase. MSPs corresponding to each EL assume no change in
motor or drive costs since DOE kept the motor and drive costs constant
over all ELs; therefore, the change in MSP at each design option EL is
reflective of the cost of incorporating the corresponding design
option.
DOE additionally conducted teardowns to validate the MSPs applied
to each EL. For axial inline fans, DOE initially estimated a high MSP
from manufacturer fan selection software for replacing a tube axial fan
with a vane axial fan; however, teardown data suggested that a lower
MSP would be more realistic. DOE believes this discrepancy is due to
differences in production volume between tube axial and vane axial
fans, with vane axial fans having lower production volumes in the
current market. In the presence of energy conservation standards,
however, DOE expects that production volumes for vane axial fans would
increase, reducing this price difference. Therefore, DOE adjusted the
MSP for substituting a tube axial fan with a vane axial fan assuming
equivalent production volumes in the presence of energy conservation
standards.
Similarly, for centrifugal inline fans, DOE found that the average
MSP when substituting a centrifugal inline impeller with a mixed-flow
impeller was higher than would have been expected based on the teardown
data. DOE believes this may be due to a mix of lower production volumes
in the current market, underlying conversion costs, and increased
markups for mixed-flow fans in the current market. Therefore, DOE
reduced the MSP when substituting a centrifugal inline impeller with a
mixed-flow impeller. To account for any costs associated with
redesigning a centrifugal inline fan, DOE modelled most costs for
applying a mixed-flow impeller as conversion costs, similar to those
applied for aerodynamic redesigns.
As discussed, DOE evaluated aerodynamic redesigns as the final ELs
for all equipment classes. DOE assumed a constant MSP for each
aerodynamic redesign EL, with no change in MSP from the last design
option EL to the first aerodynamic redesign EL. DOE assumed that the
redesign, reengineering, and new production equipment required for
aerodynamic redesign efficiency levels would result in significant one-
time capital and product conversion costs. To account for expected
manufacturer markups at these ELs, DOE applied a conversion cost markup
that increases as capital costs increase. Aerodynamic redesign
conversion costs are further discussed in section IV.J.2.c of this
NOPR.
DOE assumed that shipping costs remained constant over all analyzed
ELs for all equipment classes except for PRVs, where the increased
diameter design options are expected to have a substantial impact on
equipment dimensions and weight. To estimate shipping costs for PRVs,
DOE used data from product teardowns and product literature for the
representative operating points. DOE compared measured shipping
dimensions from physical teardowns with listed unit dimensions in
manufacturers' product literature and extrapolated the difference
between them to estimate representative shipping dimensions for the
units that DOE did not tear down. These dimensions were then used to
estimate the number of PRVs that could be shipped per truck load. Based
on this analysis, an additional shipping cost for each individual PRV
was then applied to DOE's estimated MSPs.
DOE requests comment on its method to use both the AMCA sales
database and sales data pulled from manufacturer fan selection data to
estimate MSP. DOE also requests comment on the use of the MSP approach
for its cost analysis for GFBs or whether an MPC-based approach would
be appropriate. If interested parties believe an MPC-based approach
would be more appropriate, DOE requests MPC data for the equipment
classes and efficiency levels analyzed, which may be confidentially
[[Page 3773]]
submitted to DOE using the confidential business information label.
2. Air Circulating Fans
In the following sections, DOE discusses the engineering analysis
performed to establish a relationship between ACF efficacy and MPC.
a. Representative Units
When performing engineering analyses for energy conservation
standards rulemakings, rather than model every possible set of
characteristics an equipment could have, DOE often evaluates the
efficiency and cost of specific units that are most representative of
the equipment. These representative units are typically chosen based on
size or performance-related features. In the October 2022 NODA, DOE
modeled five ACF representative units: a 12-in. ACF with a 0.01 hp
motor; a 20-in. ACF with a 0.33 hp motor; a 24-in. ACF with a 0.5 hp
motor, a 36-in. ACF with a 0.5 hp motor; and a 50-in. ACF with a 1 hp
motor. 87 FR 62038, 62046. In the October 2022 NODA, DOE requested
comment on whether the motor hp it has associated with each
representative diameter (i.e., 0.1 hp for 12 in., 0.33 hp for 20 in.,
0.5 hp for 24 in. and 36 in., and 1 hp for 50 in.) appropriately
represented the motor hp for fans sold with those corresponding
diameters. Id.
In response to the October 2022 NODA, AMCA commented that DOE
should consider decoupling fan size and motor nameplate hp for its
representative units because the motor nameplate hp is not always
representative of how much loading is placed on the motors and may
therefore mislead any estimates of efficiency. (AMCA, No. 132 at p. 7)
In response to stakeholder concerns about establishing
representative motor powers for the engineering analysis, DOE
reevaluated its approach. After reviewing the updated ACF database,
which contains catalog data not included in the October 2022 NODA
analysis, DOE found that motor nameplate power may vary too much from
fan to fan to establish a single representative motor power for a given
fan diameter. Instead, for this NOPR analysis, DOE used the
distribution of motor nameplate powers for each representative diameter
to determine weighted averages for motor efficiency and motor costs.
Further details on these distributions and their use can be found in
chapter 5 of the NOPR TSD.
For this NOPR, DOE evaluated slightly different representative
units than it evaluated in the October 2022 NODA analysis. DOE did not
consider a 12-in. representative unit for the NOPR because ACFs with
input powers less than 125 W were excluded from the scope, which
significantly reduced the number of in-scope 12-in. ACFs in DOE's
updated ACF database. As discussed in section IV.A.1.b, DOE identified
three equipment classes for axial ACFs, a 12-in. to less than 36-in.
diameter axial ACF class, a 36-in. to less than 48-in. diameter axial
ACF class, and a 48-in. diameter or greater axial ACF class. DOE
defined a single representative unit for each axial ACF equipment
class. DOE reviewed ACF diameters in its updated ACF database and
determined that the most common diameters for the 12-in. to less than
36-in. diameter range, the 36-in. to less than 48-in. diameter range,
and the 48-in. diameter or greater range were 24 in., 36 in., and 52
in., respectively. Therefore, DOE used these three diameters as its
representative units for the ACF analysis. DOE did not consider the 20-
in. or 50-in. representative units included in the October 2022 NODA
because neither of these sizes were the most common diameter for axial
ACFs in the corresponding diameter range. For housed centrifugal ACFs,
DOE chose 11 in. as the representative unit, since it is the most
common diameter for housed centrifugal ACFs in the updated ACF
database, Further details regarding the selection of representative
units can be found in chapter 5 of the NOPR TSD.
b. Baseline Efficiency and Efficiency Level 1
Motors
As discussed in section IV.C.1.a, baseline models are typically
either the most common or the least efficient units on the market. In
the October 2022 NODA, DOE assigned split-phase motors to be the
baseline technology option for ACFs because split-phase motors are the
least efficient type of motor used for ACFs. 87 FR 62038, 62048. As
discussed in the October 2022 NODA, the BESS Labs combined database
contained ACFs sold with PSC motors, polyphase motors, and ECMs, but no
split-phase motors. Id. Therefore, DOE used the lowest efficiencies
observed in the BESS Labs combined database, associated with low-
efficiency PSC motors, to establish EL 1. To estimate baseline
efficiencies from EL 1, DOE applied an efficiency loss associated with
switching from a low-efficiency PSC motor to a split-phase motor. 87 FR
62038, 62049.
In the October 2022 NODA, DOE requested feedback on the methodology
used to determine the baseline efficiency values for the representative
units and on the expected average improvement in ACF efficiency when a
split-phase motor is replaced by a low-efficiency PSC motor. 87 FR
62038, 62049. In response, the Efficiency Advocates stated that, since
DOE utilized the BESS Labs combined database to determine efficiency in
the October 2022 NODA, that baseline efficiency could be higher than
the actual least efficient ACFs on the market. (Efficiency Advocates,
No. 126 at p. 1) In response to stakeholder feedback and after
reviewing its updated ACF database, DOE utilized a different
methodology for determining baseline efficiency in this NOPR. Rather
than determining EL 1 and back-calculating baseline from EL 1, DOE
defined the baseline efficiencies for each representative unit using
the minimum efficiency values in its updated ACF database.
Additionally, as discussed in section IV.A.3 of this NOPR, additional
review of the ACF market indicated that very few ACFs use split-phase
motors compared to the number of ACFs that use PSC motors. Therefore,
DOE decided to consider low-efficiency PSC motors as a baseline design
option for ACFs in this NOPR.
As discussed in section IV.A.2.b, DOE included catalog data in its
updated ACF database to supplement the BESS Labs combined database. DOE
did not consider catalog data in the October 2022 NODA because catalog
data did not include information on the air density measured during
testing, which is required when calculating FEI. Since DOE updated the
ACF efficiency metric to be efficacy instead of FEI, DOE was able to
use catalog data for efficiency information for this NOPR. Therefore,
DOE expects the minimum efficacy values used in this NOPR analysis to
be more representative of the baseline fans on the market than those
used in the October 2022 NODA.
Transmission
In the October 2022 NODA, since DOE did not consider more efficient
transmissions as a design option, the baseline fan was not defined by a
transmission type. However, in this NOPR analysis, DOE is considering
more-efficient transmissions as a design option for ACFs. As discussed
in section IV.A.3, using a direct-drive transmission instead of a belt-
drive transmission can increase the efficiency of a fan. Manufacturers
also indicated in interviews that the fan industry is transitioning
away from using belt-drive transmissions in favor of direct-drive
transmissions. Therefore, DOE decided to assign a belt-drive
transmission as a
[[Page 3774]]
baseline design option and tentatively determined that a change from
belt-drive to direct-drive would be the first design change ACF
manufacturers would make to improve efficiency. Therefore, DOE chose a
direct-drive transmission as the EL 1 design option. DOE notes,
however, that not all the equipment classes it analyzed typically use
belt drives. DOE reviewed the housed centrifugal ACF market and
concluded that belt drives are not used for housed centrifugal ACFs.
Additionally, DOE's review of the axial ACF market indicated that belt
drives are not commonly used for axial ACFs less than 36 in. in
diameter. DOE found that only 2 percent of ACF models in its updated
ACF database with a diameter less than 36 in. had belt drives, while 66
percent of ACF models in its updated ACF database with a diameter of 36
in. or larger had belt drives. Therefore, DOE has determined that a
direct-driven fan is representative of both the baseline and EL 1 for
the 24-in. axial ACF and centrifugal housed ACF representative units.
For the 36-in. and 52-in. axial ACF representative units, DOE
determined EL 1 by applying an efficacy delta to the baseline efficacy
representing a transition from a belt-drive transmission to a direct-
drive transmission. To estimate this incremental impact on efficacy
when transitioning from a belt-drive transmission to a direct-drive
transmission, DOE used the equations defined in sections 6.3.1 and
6.3.2 of AMCA 214-21. The equations in section 6.3.1 of AMCA 214-21
define the efficiency of direct-drive transmissions as 100 percent and
define the efficiency of belt-drive transmissions based on the shaft
power of the fan. Since shaft powers are generally unknown for ACFs,
DOE used the equation defined in section 6.3.2 of AMCA 214-21 to
determine theoretical motor output powers associated with given shaft
powers and transmission efficiencies. DOE then plotted a curve to
estimate belt-drive transmission efficiency as a function of motor
output power, which was used to estimate the belt-drive efficiencies
for all motor hp values in its updated ACF database. To account for the
range of motor hp values that could be used in ACFs for each
representative unit, DOE determined the percentage of fans in its
updated ACF database that corresponded to each motor hp in the
database. DOE then used these percentages as weights to calculate a
weighted-average belt-drive efficiency for each motor hp.
DOE evaluated the relationship between transmission efficiency and
fan efficacy and determined that transmission efficiency and fan
efficacy are directly proportional. Therefore, the percent increase in
fan efficacy associated with using a more efficient transmission is
equal to the percent increase in transmission efficiency. Further
details of this analysis can be found in chapter 5 of the NOPR TSD. DOE
applied the percent increase in efficiency when transitioning from a
belt-drive transmission to a direct-drive transmission to the baseline
efficacies for the 36-in. axial ACF and 52-in. axial ACF representative
units to determine EL 1. DOE used the resulting weighted-average belt-
drive efficiency to determine the percent difference in efficiency
between a belt-drive transmission and a direct-drive transmission.
Based on this approach, DOE estimated 13.5-percent and 10.4-percent
improvements in efficacy when changing from a belt-drive transmission
to a direct-drive transmission for the 36-in. axial ACF and 52-in.
axial ACF representative units, respectively.
As mentioned previously, DOE defined both the baseline fan and EL 1
as direct driven for the 24-in. axial ACF and the housed centrifugal
ACF representative units. Therefore, for these two representative
units, DOE set EL 1 equal to the baseline efficacy to account for the
fact that there would be no efficacy gain associated with the more-
efficient transmission design option. This was done to maintain
consistent design options for each EL for all ACF equipment classes.
Further discussion of DOE's methodology for determining baseline
efficiency and EL 1 can be found in chapter 5 of the NOPR TSD.
c. Selection of Efficiency Levels
In this section, DOE discusses comments it received on its ACF
efficiency analysis in the October 2022 NODA and describes the
efficiency analysis methodology it used for this NOPR. As discussed in
section IV.C.1.b, DOE typically uses either an efficiency-level
approach, a design-option approach, or a combination of the two for its
efficiency analysis. In this NOPR, DOE used a combination efficiency-
level and design-option approach for its analysis of ACFs. DOE used the
efficiency-level approach to determine the baseline and aerodynamic
redesign ELs and used the design-option approach to gap fill
intermediate ELs. For the design-option approach, DOE used the
efficiencies determined for the baseline design options and more-
efficient design options to assign incremental efficiency gains for
each EL.
General Approach and Related Comments
In the October 2022 NODA, DOE evaluated more-efficient motors and
aerodynamic redesign as options for increasing ACF efficiency. 87 FR
62038, 62048. DOE did not conduct a formal screening analysis in the
October 2022 NODA; however, as discussed in section IV.B, DOE conducted
a formal screening analysis for this NOPR, and screened in the
following design options for ACFs:
Aerodynamic redesign (improved housing design, reduced
manufacturing tolerances, addition of appurtenances, improved impeller
design, addition of guide vanes, impeller topology);
Increased impeller diameter;
More-efficient transmissions (belt drive and direct
drive); and
More-efficient motors.
DOE did not evaluate the efficiency impacts of all these design
options in the engineering analysis for ACFs. Specifically, DOE did not
consider the efficiency impacts of increased impeller diameter since
DOE defined equipment classes based on diameter in section IV.A.1.b.
Therefore, when developing the proposed ELs, DOE only considered more-
efficient transmissions, more-efficient motors, and aerodynamic
redesign as design options for its analysis of ACFs in this NOPR. More-
efficient transmissions were associated with EL 0 and EL 1, which were
discussed in section IV.C.2.b.
Regarding motors, DOE evaluated multiple motor options for ACFs in
the October 2022 NODA, specifically split-phase motors at baseline, PSC
1 motors at EL 1, PSC 2 motors at EL 2, and ECMs at EL 3. 87 FR 62038,
62048. PSC 1 motors were defined as basic PSC motors, while PSC 2
motors were defined as ``more efficient PSC motors''. Id. In this NOPR,
DOE refers to basic PSC motors as ``low-efficiency PSC motors'' and
refers to more-efficient PSC motors as ``high-efficiency PSC motors.''
In the October 2022 NODA, DOE also assumed that airflow, pressure,
motor speed, and motor inrush current remained constant when replacing
a less-efficient motor with a more-efficient motor and requested
feedback on these assumptions. 87 FR 62038, 62049.
In response, AMCA commented that, provided the shaft speed does not
change much, the fan affinity laws can be used to predict airflow and
total pressure. However, AMCA added that there can be discrepancies
between the torque required by the load and the torque produced by the
motor for low-power motors. AMCA further stated that, given the very
low starting torque
[[Page 3775]]
of ACFs, inrush current is likely insignificant for ACF motors. (AMCA,
No. 132 at p. 9) NEMA stated that while motor performance can be
optimized, changing the motor may impact other aspects of fan
performance. NEMA specifically stated that more-efficient motors will
typically have higher speeds, which may require a redesign of the fan.
(NEMA, No. 125 at p. 5) AMCA also stated that motors with higher
rotational speeds will generally be more efficient. (AMCA, No. 132 at
pp. 16-17) NEMA commented that changing the efficiencies of motors used
for ACFs could require the use of a larger, heavier motor and could
therefore require other design changes to the fan. (NEMA, No. 125 at p.
2) AMCA also stated that replacing a motor with a more-efficient motor
may result in the need for aerodynamic redesign or redesign of the
mounting and supports of an ACF because of differences in motor size,
shape, or weight. (AMCA, No. 132 at p. 12)
DOE investigated the issue of higher-efficiency motors having
higher speeds in the December 2023 ESEMs NOPR TSD.\64\ For the typical
motor types and sizes used in ACF applications,\65\ DOE found only a
0.5-percent to 0.7-percent increase from the minimum full-load speed to
the maximum full-load speed. Given the relatively small speed changes
between ESEMs with different efficiencies, DOE has tentatively
concluded that increases in motor speed associated with transitioning
to more-efficient motors would be insignificant and would not require
additional changes to fan design.
---------------------------------------------------------------------------
\64\ The ESEMs NOPR TSD can be found at www.regulations.gov/document/EERE-2020-BT-STD-0007-0056.
\65\ DOE's review of the ACF market indicated that low-torque,
6-pole, air-over ESEMs are the most commonly used motor types for
ACFs. Table 5.4.2 of the December 2023 ESEM NOPR TSD shows the full-
load speeds for these motors at different efficiency levels.
---------------------------------------------------------------------------
DOE requests feedback on whether using a more efficient motor would
require an ACF redesign. Additionally, DOE requests feedback on what
percentage of motor speed change would require an ACF redesign.
Regarding stakeholder feedback that ACFs may need to be redesigned
to accommodate differences in motor size or shape when changing to
more-efficient motors, DOE expects this type of redesign could be done
with minimal efficiency impact because it expects that only motor
supports would be redesigned. As discussed in section IV.C.2.d, DOE
found that there is sufficient space for an increase in motor volume
without needing to redesign other fan components, such as housing or
safety guards. Consequently, DOE assumed that the only redesign
required for an ACF when switching to a larger motor would be to
increase the weight of the motor supports to accommodate an increase
motor weight. Therefore, DOE assumed that when changing to a more-
efficient motor, the only significant impact to the efficiency of an
ACF was the efficiency gained from the motor.
Additionally, AMCA commented in response to the October 2022 NODA
that motor nameplate information is generally not very relevant for
ACFs because ACF manufacturers often use motors in power ranges outside
those listed on motor nameplates. AMCA stated that operating motors
above their nameplate load may provide the best material efficiency and
that this is possible for ACFs because motors are very well ventilated
when used for ACFs. AMCA also stated that the use of a flatter pitch
blade may not load a fan to its listed motor horsepower, while a
steeper pitch blade may load the motor past its listed horsepower.
(AMCA, No. 132 at pp. 6-8) Further, AMCA stated that motor nameplate
efficiencies depend on the number of phases and the synchronous speed
of the motors and that the actual motor efficiency would be different
since motors are used at higher power ratings than their nameplate
power ratings for ACFs. (AMCA, No. 132 at pp. 16-17)
In consideration of AMCA's comments, DOE analyzed confidential ESEM
testing data to examine how motor efficiency is impacted when motors
are operated at loads above their nameplate rating. DOE compared the
efficiencies of motors tested at nameplate load, 115 percent of
nameplate load, and 125 percent of nameplate load. Through its
analysis, DOE found that, on average, motor efficiency increased by a
percent change of 1.01 percent for motors tested at 115 percent of
nameplate load and motor efficiency increased by a percent change of
1.23 percent for motors tested at 125 percent of nameplate load. DOE
notes that these percentages represent percentage changes, rather than
nominal changes in motor efficiency. For example, a 0.25 hp motor might
have an efficiency of 72.84 percent when tested at 100 percent load
compared to an efficiency of 73.54 percent when tested at 115 percent
load, representing a percentage increase in efficiency of 0.96 percent
(i.e., [73.54-72.84]/72.84 = 0.96%). The positive percentage change
found for motors tested at both 115 percent and 125 percent of rated
load indicates that, up to 125 percent rated load, efficiency generally
increases for motors operated at loads above their nameplate rating.
Hence, representations of motor efficiency calculated at nameplate load
may provide a more conservative estimate of motor efficiency. For the
motors that exhibited a decrease in efficiency at 125 percent of rated
load, DOE further investigated the percentage change in motor
efficiency. For these motors, the average percentage change in motor
efficiency remained under 1.5 percent for motors tested at both 115
percent and 125 percent of their rated load, with a maximum percentage
change in efficiency of 2.3 percent. Since the average percentage
change in motor efficiency from the rated efficiency is small when
motors are operated at above their rated loads, DOE has tentatively
determined that motor efficiencies calculated at rated load represent
adequate estimates of true motor efficiency, even if those motors are
operated above their rated loads.
As discussed in section IV.A.3, DOE considered split-phase motors,
low-efficiency PSC motors, high-efficiency PSC motors, and ECMs in its
October 2022 NODA analysis. 87 FR 62038, 62048. DOE has since reviewed
its updated ACF database in response to comments from AMCA and NEMA
about motors used in ACFs. Based on the distribution of motor types in
the database, DOE tentatively concluded that very few ACFs use shaded-
pole, split-phase, or capacitor start/capacitor run motors. Rather, DOE
found that the most common motors used in ACFs are PSC motors, and that
some ACFs utilize polyphase motors and ECMs. Specific percentages of
ACFs in the updated ACF database with each motor type can be found in
Chapter 5 of the NOPR TSD.
Furthermore, in the October 2022 NODA, DOE requested comment on
whether ACFs with single-phase motors and polyphase motors would be
used for different utilities or have different efficiencies because of
their end-use applications. 87 FR 62038, 62045. In response, NEMA
stated that three-phase motors typically have slightly higher
efficiencies than single-phase motors but added that if only a single-
phase power supply is available, a three-phase motor could not be used
in place of a single-phase motor. NEMA added that at higher motor
powers (1.5 hp and above), three-phase motors tend to be equally as or
slightly less expensive than single-phase motors. (NEMA, No. 125 at p.
4). DOE's review of motor literature and testing data for motors used
in ACFs indicated that polyphase motors are generally more efficient
than PSC motors, as stated by NEMA.
[[Page 3776]]
Additionally, DOE acknowledges that, as NEMA stated, in situations
where only single-phase power is available, a polyphase motor could not
be used in place of a single-phase motor without the use of additional
electronics, such as a phase converter. As such, DOE did not consider a
change from PSC motor to polyphase motor as a design option for
improving efficiency. Additionally, as discussed above, the majority of
the ACFs in DOE's updated ACF database utilize PSC motors; therefore,
DOE used PSC motors to generally model the efficiencies of induction
motors used in ACFs. DOE notes that this approach provides conservative
estimates of induction motor efficiency relative to an approach that
includes polyphase motor efficiencies since polyphase motors are
generally more efficient than PSC motors. DOE considered low-efficiency
PSC motors and high-efficiency PSC motors as induction motor design
options. Additionally, DOE considered ECMs as a motor design option
since they are the most efficient type of motor used in ACFs.
Determination of Efficiency Levels
As discussed in section IV.C.2.b, DOE considered low-efficiency PSC
motors and belt-drive transmissions as baseline design options and
considered direct-drive transmissions as the design option for EL 1.
DOE received feedback during confidential manufacturer interviews
that ACF manufacturers were more likely to improve the efficiency of a
motor before performing an aerodynamic redesign. Therefore, DOE
considered a high-efficiency PSC motor as the design option for EL 2,
prior to considering aerodynamic redesign. DOE modeled the efficiency
gain associated with changing from a low-efficiency PSC motor to a
high-efficiency PSC motor. DOE determined the efficacy for EL 2 for all
equipment classes by estimating efficiencies for low-efficiency PSC
motors and high-efficiency PSC motors, determining the efficiency delta
between them, and applying that efficiency delta to EL 1. In the
October 2022 NODA, DOE estimated the efficiencies of low-efficiency PSC
motors and high-efficiency PSC motors using DOE's database of catalog
motor data (``motors database''). 87 FR 62038, 62049. DOE associated
low-efficiency PSC motors with EL 1 and high-efficiency PSC motors with
EL 2 in the October 2022 NODA analysis. DOE estimated the increase in
FEI from EL 1 to EL 2 by applying the percent increase in efficiency
from a low-efficiency PSC motor to a high-efficiency PSC motor directly
to the EL 1 FEI value. DOE requested comment on its determined
efficiency gains when replacing a low-efficiency PSC motor with a high-
efficiency PSC motor and whether catalog performance data for PSC
motors were representative of the performance of motors used in ACFs.
Id.
In response, NEEA commented that it agreed with DOE's approach to
model the efficiency improvements for the overall fan as equal to the
motor efficiency improvements when only the motor is changed and
nothing else, such as the duty point, motor speed, drive type, etc.
(NEEA, No. 129 at p. 3) Greenheck expressed concern that the motor
efficiencies used by DOE in its analysis may not have been accurate and
stated that Greenheck could not confirm the accuracy of the
efficiencies used since the motor database was not included with the
supplementary information. Greenheck also requested clarity on which
motors were included in DOE's analyses of low-efficiency PSC and high-
efficiency PSC motors. Specifically, Greenheck stated motors that DOE
deemed low-efficiency PSC motors should be analyzed as a separate
dataset from high-efficiency PSC motors, rather than determining low-
efficiency PSC motor performance from the average efficiency of all PSC
motors. (Greenheck, No. 122 at p. 2) AMCA commented that determining
general values for the change in efficiency between one motor type and
another is difficult to do with confidence because motors with the same
topology and power rating can have different efficiencies. (AMCA, No.
132 at p. 8-9) NEMA commented that the efficiencies of fan motors are
often not quantified and that it is incorrect to assume that all ACFs
use low-efficiency motors. (NEMA, No. 125 at p. 3) NEMA added that the
source of DOE's ESEM catalog data is unclear, given that most motor
manufacturers do not publish performance information for the fractional
horsepower, single-phase motors that DOE assumed were used for ACFs in
its October 2022 NODA analysis. NEMA further stated that catalog motors
typically meet or exceed the ratings listed for them in catalogs.
(NEMA, No. 125 at p. 3)
In response to stakeholder feedback, DOE adjusted its methodology
for determining efficiencies associated with low-efficiency PSC motors
and high-efficiency PSC motors in this NOPR. In the October 2022 NODA,
DOE determined low-efficiency PSC motor efficiency from the average of
all air-over PSC motors in the motors database. 87 FR 62038, 62049. For
this NOPR, DOE instead determined low-efficiency PSC motor efficiency
from the minimum efficiency of all 6-pole, fan-specific motors in the
motors database. The use of the minimum efficiency, rather than the
average efficiency, produced a more conservative estimate for low-
efficiency PSC motor efficiency. DOE analyzed 6-pole motors
specifically because DOE's review of the ACF market indicated that 6-
pole motors are most common for ACFs. DOE determined low-efficiency PSC
motor efficiencies at all motor powers in its updated ACF database and
calculated a weighted average efficiency using the distribution of
motor powers for each representative unit. Regarding Greenheck and
NEMA's concerns about the accuracy of the motor data in the motors
database, DOE acknowledges that the motors in the database are
unregulated and therefore the data may be inaccurate. However, DOE
notes that it received no additional information on ACF motor
efficiencies from stakeholders that it could use instead of the
information in the motors database. Regarding NEMA's concerns about the
source of the PSC motor data in the motors database, DOE notes that the
information it compiled from the database for fan-specific, 6-pole PSC
motors consisted of published catalog data from four different motor
brands. In response to AMCA's concerns about variations in motor
efficiency with the same topology and power rating, DOE acknowledges
that motors with the same topology and power rating can have different
efficiencies. Therefore, DOE used weighted-average motor efficiencies
in this NOPR analysis, which allowed DOE to consider the effects of a
wide range of motor efficiencies across many power ratings for a
particular motor topology.
Unlike low-efficiency PSC motors, DOE did not use the motors
database to determine efficiencies for high-efficiency PSC motors in
this NOPR. As part of the electric motors rulemaking, stakeholders made
a joint recommendation for the efficiencies at which they believe the
standards for ESEMs should be set. (Docket No. EERE-2020-BT-STD-0007,
Joint Stakeholders, No. 38 at p. 6, Table 2) The joint recommendation
represented the motors industry, energy efficiency organizations and
utilities (collectively, ``the Electric Motors Working Group'') and
addressed energy conservation standards for high-torque, medium-torque,
low-torque, and polyphase ESEMs that are 0.25-3 hp and polyphase, and
air-over ESEMs. In reference to this ongoing rulemaking, DOE has
tentatively defined its high-efficiency PSC motor efficiencies using
the efficiencies recommended by the
[[Page 3777]]
ESEM Joint Stakeholders. DOE used the average of the recommended
efficiencies for enclosed and open 6-pole PSC motors since DOE's review
of the ACF market indicated that both enclosed and open motors are used
for ACFs. DOE then calculated weighted-average high-efficiency PSC
motor efficiencies using the average recommended efficiencies at
different motor powers for each representative unit. DOE then
determined the percent difference in efficiency between high-efficiency
PSC motors and low-efficiency PSC motors.
DOE evaluated the relationship between motor efficiency and fan
efficacy and determined that motor efficiency and fan efficacy are
directly proportional. Therefore, the percent increase in efficacy
associated with changing to a more efficient motor is equal to the
percent increase in motor efficiency. Further details of this analysis
can be found in chapter 5 of the NOPR TSD. DOE applied the percent
increase in motor efficiency when transitioning from a low-efficiency
PSC motor to a high-efficiency PSC motor to EL 1 to determine EL 2 for
each representative unit.
DOE recognizes that if it sets a standard at the recommended ESEM
efficiencies, high-efficiency PSC motors would effectively become the
baseline motor for ACFs. DOE performed a sensitivity analysis to
evaluate the impact of setting ESEM standards at the recommended
efficiencies on its ACF analysis. DOE found that, given the small
number of shipments at EL 0 and EL 1 for ACFs, if EL 2 were set as the
baseline EL, there would be a minimal impact on proposed ACF standards
due to the low shipments below EL2 (see IV.F.8). DOE notes that if it
sets a standard in the ESEM rulemaking at the recommended ESEM levels,
DOE may consider using EL2 proposed in this NOPR as baseline for ACFs
in a future final rule.
In response to the October 2022 NODA, NEEA commented that DOE's
assumption that the least-efficient fans in the BESS Labs combined
database used the least-efficient motors may be incorrect, since these
fans could instead have non-motor-related performance features that
caused them to have low efficiencies. NEEA added that this could cause
non-representative ELs in DOE's analysis since some of DOE's ELs are
based on motor efficiency increases. (NEEA, No. 129 at p. 2) DOE notes
that information on the specific motor models integrated into ACFs,
including motor efficiency, is not often publicly available. DOE also
notes that it requested quantitative efficiency data on ACF motors in
the October 2022 NODA, and it has not received any quantitative
information on motor efficiency from stakeholders. 87 FR 62038, 62063.
As discussed in section IV.A.2.b, DOE's dataset now includes catalog
data in addition to the BESS Labs combined database. Therefore, as
discussed in section IV.C.2.b, DOE expects the baseline efficacies that
it used in this analysis to be more representative of the least
efficient ACFs on the market than the baseline used in the October 2022
NODA. Additionally, as previously discussed, DOE updated its
methodology for determining motor efficiencies for low-efficiency and
high-efficiency PSC motors. Given these adjustments, DOE expects that
the EL 2 efficacies are representative of ACFs with high-efficiency PSC
motors.
In the October 2022 NODA, DOE considered ECMs as the design option
for EL 3 and considered aerodynamic redesign as the design option for
EL 4. In response, the CA IOUs commented that DOE should consider
aerodynamic efficiency improvements at ELs lower than max-tech because
they expect that manufacturers would consider aerodynamic redesigns
before switching to ECMs. The CA IOUs also recommended that DOE
consider intermediate aerodynamic redesign levels rather than a single
``maximum'' option. (CA IOUs, No. 127 at p. 2) The Efficiency Advocates
recommended that DOE consider more ELs in its efficiency analysis to
better represent the range of ACF efficiencies presented in its
analysis, and that DOE specifically consider aerodynamic redesign. The
Efficiency Advocates stated that additional ELs could be used to bridge
the large gap between EL 3 and EL 4 in the October 2022 NODA.
(Efficiency Advocates, No. 126 at p. 2)
In response to this feedback, DOE did not consider ECMs as a design
option immediately after considering high-efficiency PSC motors in this
NOPR; rather, DOE evaluated three aerodynamic redesign ELs--EL 3, EL 4,
and EL 5--and considered ECMs as the max-tech design option at EL 6.
DOE assumed that more complex aerodynamic redesign would be needed for
EL 4 compared to EL 3 and for EL 5 compared to EL 4.
In response to the October 2022 NODA, NEEA stated that the wide
distribution of efficiencies in the BESS Labs combined database was
likely due to factors other than variation in motor efficiency since
the database consists of fans that use the same kind of motor (PSC).
DOE infers from this comment that variations in ACF efficiency in the
updated ACF database, which, like the BESS Labs combined database,
contained many ACFs with PSC motors, can largely be attributed to
differences in aerodynamic efficiency between fans. Therefore, although
DOE could not relate specific design options to a given efficacy for
its three aerodynamic redesign levels, DOE defined aerodynamic redesign
levels using an efficiency-level approach from its updated ACF
database. Since DOE anticipated that more complex redesigns would be
required at EL 4 than EL 3, DOE defined EL 3 as 33 percent of the way
between EL 2 and EL 4 for all equipment classes.
DOE took different approaches for establishing EL 4 for axial ACFs
and housed centrifugal ACFs. For axial ACFs, DOE referenced
agricultural fan efficiency incentive programs to set the efficacies at
EL 4. All agricultural fan efficiency incentive programs that DOE found
use units of thrust per kilowatt (``thrust/kW'') to define minimum
performance targets to qualify for the incentives. DOE converted these
targets into units of CFM/W. Details of this conversion can be found in
chapter 5 of the NOPR TSD. As discussed in section IV.C.2.a of this
NOPR, ACF performance targets are defined by diameter. To be consistent
with its lowest-diameter equipment class, DOE averaged the incentive
program performance targets for the 12-in. to less than 24-in. diameter
range and the 24-in. to less than 36-in. diameter range to estimate EL
4 for the 24-in. axial ACF representative unit. DOE used the
performance targets for the 36-in. to 48-in. diameter range and 48-in.
or greater diameter range to estimate EL 4 for the 36-in. axial ACF and
52-in. axial ACF representative units, respectively.
For housed centrifugal ACFs, DOE could not use the agricultural fan
efficiency incentive programs to define EL 4 because housed centrifugal
ACFs are not used in agricultural applications. Since DOE assumed that
more complex redesigns would be required at EL 5 than EL 4, DOE also
assumed that the efficiency gain between EL 5 and EL 4 would be greater
than the efficiency gain between EL 4 and EL 3. To reflect this
assumption, DOE defined EL 4 as halfway between EL 2 and EL 5 for
housed centrifugal ACFs.
DOE defined EL 5 for each equipment class based on the maximum
efficacies in the updated ACF database. DOE used the maximum efficacies
in the updated ACF database to define EL 5 since DOE found that the
maximum efficacy ACFs in the updated ACF database did not have ECMs.
Therefore, these ACFs did not correspond to the max-tech level, and DOE
instead assumed that these ACFs utilized highly efficient
[[Page 3778]]
aerodynamic designs to achieve high efficacies. As discussed in section
IV.A.2.b, DOE removed some high-efficacy outliers from the ACF database
prior to determining the maximum efficacies for EL5.
As discussed previously, DOE considered an ACF with an ECM and a
highly efficient aerodynamic design to be the max-tech design option.
DOE's research indicated that ECMs are the most efficient type of motor
used in ACFs, and, as indicated in the CA IOUs' comment on aerodynamic
redesign, ACF manufacturers may consider implementing aerodynamic
redesign prior to switching to an ECM. To determine the max-tech
efficiency, DOE applied an incremental efficiency gain associated with
changing from a high-efficiency PSC motor to an ECM to EL 5 for each
equipment class.
In the October 2022 NODA, DOE used a database of dedicated-purpose
pool pump (``DPPP'') motors to determine efficiencies for ECMs and
high-efficiency PSC motors and the efficiency gain expected when
switching from a high-efficiency PSC motor to an ECM. 87 FR 62038,
62050. DOE requested comment on its use of DPPP motors for comparing
efficiencies of PSC motors and ECMs. Id. In response, NEMA commented
that DPPP motor efficiency levels should not be used to compare PSC to
ECM motor efficiency. NEMA stated that the DPPP efficiency regulations
define system (motor and pump) efficiency levels and not standalone
motor efficiencies. NEMA also stated that it had concerns with applying
a market like DPPP, which has a dedicated purpose and experiences less
variety of designs and manufacturers, to the much more diverse market
of fans and blowers. (NEMA, No. 125 at p. 5)
In response to NEMA's concerns about its use of DPPP motors to
model the efficiencies of ECMs, DOE adjusted its methodology for
determining ECM efficiencies. To determine the efficiencies of ECMs,
DOE first considered the motor efficiencies specified in IEC 60034-30-
1:2014. The motor efficiencies defined in the IE code are intended to
serve as reference points for governments to use when defining
efficiency standards. DOE understands that the current IE 1 through IE
4 efficiencies defined in IEC 60034-30-1:2014 are intended to represent
induction motor efficiencies. DOE also understands that, should a
higher IE motor efficiency, IE 5, be defined in a future standard, the
IE 5 efficiencies would likely align with ECM efficiencies. DOE used
theoretical IE 5 efficiencies to estimate the efficiencies of ECMs and
assumed that the efficiencies included the effects of ECM controllers.
The IE 1 through IE 4 levels defined in IEC 60034-30-1:2014 are based
on a 20-percent reduction in power losses going from one IE level to
the next. For example, IE 4-level efficiency is determined from IE 3-
level efficiency by assuming a 20-percent reduction in power losses.
Therefore, DOE estimated IE 5 efficiency by assuming a 20-percent
reduction in power losses from the IE 4 efficiency. DOE determined the
percent difference between the estimated IE 5 efficiency and the
estimated high-efficiency PSC motor efficiency. As discussed
previously, DOE determined that a percent increase in motor efficiency
corresponds to an equal percent increase in efficacy. Therefore, DOE
applied the percent increase in motor efficiency when transitioning
from a high-efficiency PSC motor to an ECM to EL 5 to determine EL 6.
Further details on the methodology DOE used to determine the efficacies
for each EL can be found in chapter 5 of the NOPR TSD. The efficacies
determined for each EL and representative unit and design options
associated with each EL are shown in Table IV-13.
[GRAPHIC] [TIFF OMITTED] TP19JA24.034
As discussed in section V.C.1.b, DOE notes that the standards it is
proposing for axial ACFs are discrete efficacy values in CFM/W. This
approach aligns with the method used by agricultural fan efficiency
incentive programs, where performance targets are specified for certain
diameter ranges. However, DOE notes that setting a standard for
efficacy in this way may not fully incorporate the effect of diameter
on the ACF efficacy. Setting a standard using this approach could also
make it easier for larger diameter fans to meet the standard and more
difficult for smaller diameter fans to meet the standard. DOE
recognizes that there is generally a linear relationship between
efficacy in CFM/W and fan diameter. DOE notes that it is additionally
considering setting efficacy standards for axial ACFs as a linear
function of diameter, similar to the approach used for ceiling fans
(see 10 CFR 430.32(s)(1)). To establish a linear equation for efficacy
as a function of diameter, DOE may consider in the final rule, for
example, plotting efficacies for each representative unit versus the
representative unit diameters and determining a best-fit line through
[[Page 3779]]
these points. The efficacy standard would then change continuously as a
function of diameter. While this approach would not align with the
approach used by agricultural fan efficiency incentive programs, it
might better incorporate the effect of diameter when setting standards
for ACFs, specifically for ACFs with diameters at the periphery of the
diameter range.
DOE requests feedback on whether setting an ACF standard using
discrete efficacy values over a defined diameter range appropriately
represents the differences in efficacy between axial ACFs with
different diameters, and if not, would a linear equation for efficacy
as a function of diameter be appropriate.
Input Power Estimation
In addition to determining efficacy values associated with each EL,
DOE also developed estimates of input power associated with each EL.
These input power estimates were used in the LCC and PBP analyses,
discussed in section IV.F. For each representative unit, DOE developed
input power versus efficacy curves based on the data in the updated ACF
database and then estimated the input powers associated with each
efficiency level. Further details on DOE's methodology for estimating
input powers are discussed in chapter 5 of the NOPR TSD.
d. Cost Analysis
In this section, DOE discusses its approach to estimating MPCs for
ACFs in this NOPR and discusses comments relating to its cost analysis
in the October 2022 NODA. As discussed in section IV.C.1.d, the cost
analysis portion of the engineering analysis is conducted using
physical teardowns, catalog teardowns, price surveys, or a combination
of these approaches. In the case of ACFs, DOE conducted its analysis
using physical teardowns, which involve deconstructing equipment and
recording every part and material used to make them. The resulting bill
of materials (``BOM'') provided the basis for DOE's MPC estimates. DOE
builds these MPCs based on the cumulative estimated cost of materials,
labor, depreciation, and overhead for each equipment. Further details
on these cost inputs can be found in chapter 5 of the NOPR TSD.
To support the October 2022 NODA, DOE estimated the MPCs of
unhoused and housed ACFs across all efficiency levels and
representative diameters using data gathered from teardowns of nine
ACFs. 87 FR 62038, 62052. In the October 2022 NODA, DOE assumed that
all ACFs were manufactured in China and that all materials and parts
were sourced from China. DOE used the BOMs developed for each ACF and
catalog teardowns to estimate MPCs for baseline ACFs. DOE then used
incremental MPCs estimated for each design option to estimate MPCs for
higher efficiency levels. Id.
DOE made several updates to its MPC estimation approach pertaining
to axial ACFs in this NOPR. First, DOE adjusted how it considered ACF
housings compared to the October 2022 NODA. As discussed in section
IV.A.1.b, DOE considered air circulating axial panel fans, box fans,
cylindrical ACFs, and unhoused ACFHs under the axial ACFs class. To
account for the different housing configurations used in these four
subcategories, DOE developed separate MPC estimates for housed ACFs
with panel housing, housed ACFs with cylindrical housing, and unhoused
ACFHs. DOE assumed that the costs of box housing and panel housing were
comparable; therefore, DOE did not generate separate MPC estimates for
ACFs with box housing. DOE averaged the MPCs of air circulating axial
panel fans (and box fans), cylindrical ACFs, and unhoused ACFHs to
estimate an overall MPC for axial ACFs. DOE did not include the cost of
mounting gear, casters, or wheels in its MPC estimates for any
equipment class because these features do not affect the efficacy of an
ACF. Second, based on information received during confidential
manufacturer interviews and further review of the ACF market, DOE
updated its assumptions about manufacturing location and the source of
purchased parts for this NOPR. Specifically, DOE concluded that most
ACFs are made in the United States and that most ACF manufacturers
source parts from suppliers in the United States and abroad. DOE
understands that there are variations between OEMs in the ACF industry
and chose production factors and modeling methods to reflect the range
of OEMs. Further details on the development of the MPC estimates for
axial ACFs can be found in chapter 5 of the NOPR TSD.
DOE did not evaluate housed centrifugal ACFs in the October 2022
NODA. To develop the MPC estimates for housed centrifugal ACFs, DOE
performed teardowns on three housed centrifugal ACFs and created BOMs
for each. DOE assumed that all housed centrifugal ACFs are manufactured
in China and that all parts were purchased in China based on its review
of the housed centrifugal market. DOE used these BOMs and catalog
teardowns to estimate MPCs for housed centrifugal ACFs. Further details
of the development of the MPC estimates for housed centrifugal ACFs can
be found in chapter 5 of the NOPR TSD.
In the October 2022 NODA, DOE assumed that motors included in ACFs
are purchased parts and determined the incremental MPCs associated with
changing from a split-phase motor to a low-efficiency PSC motor, high-
efficiency PSC motor, or ECM using data in its internal parts database.
87 FR 62038, 62053. DOE did not have sufficient pricing information for
split-phase motors, so DOE approximated the split-phase motor MPC using
prices for shaded-pole motors for the October 2022 NODA. Id. DOE
estimated low-efficiency PSC motor MPCs by developing a best-fit line
for motor price as a function of motor power and used this line to
estimate low-efficiency PSC motor MPCs at the representative motor
powers. DOE estimated high-efficiency PSC motor MPCs by determining the
95th percentile PSC motor MPC of the data it had available for each
representative motor power and establishing a best-fit line for the
95th percentile MPCs as a function of motor power. DOE estimated ECM
MPCs by establishing a best-fit line for the MPCs of ECMs as a function
of motor power. 87 FR 62038, 62053. Id.
In response to the October 2022 NODA, NEMA commented that DOE's
estimated motor costs were lower than actual motor costs. NEMA further
stated that the cost of motors for commercial applications would
generally be lower than those for industrial applications. (NEMA, No.
125 at p. 6) In response to this feedback, DOE reevaluated its motor
costs for this NOPR. DOE's research indicates that most ACFs are sold
in higher volumes, which suggests a commercial market, rather than an
industrial market. In general, DOE finds that industrial equipment is
sold in lower volumes and is manufactured for specific applications,
and DOE has not observed that ACFs are typically sold or manufactured
in this way. Therefore, DOE did not consider a separate MPC for
industrial ACFs in this NOPR. DOE reviewed market information for fan
motors and determined current fan motor sales prices. As such, DOE
believes that its updated motor costs are more representative of the
current fan motor market than those estimated in the October 2022 NODA.
In this NOPR, DOE also reevaluated how it estimated motor costs.
For both low-efficiency PSC motors and high-efficiency PSC motors, DOE
identified specific PSC fan motors and used the costs of these motors
to estimate MPCs. Rather than using a single motor cost, DOE determined
a weighted-average motor cost at each hp in its updated
[[Page 3780]]
ACF database. As discussed in section IV.C.2.c, DOE determined the
percentage of motor hp values in the updated ACF database for each
representative unit. DOE used these percentages and the MPCs determined
for each motor type to calculate the weighted-average motor MPCs for
each representative unit. Further details of DOE's modeling of ACF
motor costs can be found in chapter 5 of the NOPR TSD.
Additionally, as discussed in section IV.C.2.c of this NOPR, DOE
received feedback from NEMA and AMCA that changing to a more-efficient
motor could also require changes to fan design. Specifically, NEMA
commented that changing ACF motor efficiencies could require the use of
a larger, heavier motor and could therefore require other design
changes to the fan. (NEMA, No. 125 at p. 2) AMCA stated that replacing
a motor with a more-efficient motor may result in the need for
aerodynamic redesign or redesign of a fan's mounting and supports
because of differences in motor size, shape, or weight. (AMCA, No. 132
at p. 12)
To evaluate these concerns, DOE estimated costs to redesign an ACF
if a larger motor replaced a smaller motor. DOE evaluated the effects
of motor volume and motor weight when considering a change from a
smaller motor to a larger motor. DOE found during ACF teardowns that
there is sufficient space for an increase in motor volume without
needing to redesign other fan components, such as housing or safety
guards. Therefore, DOE assumed that the only redesign required for an
ACF when switching to a larger motor would be to increase the weight of
the motor supports to accommodate an increased motor weight, which is
consistent with what DOE has observed in teardowns. DOE used data
gathered during ACF teardowns to approximate a relationship between
motor weight and the cost of motor support materials. DOE used this
relationship to estimate the increase in cost that would be expected
for a given increase in motor weight. DOE found that even for a 100-
percent increase in motor weight, which DOE believes is highly
conservative, motor support costs increased fan MPC by 1.5 percent or
less. Therefore, DOE has tentatively concluded that additional material
costs would be minimal if a manufacturer incorporated a heavier motor
into an ACF.
For this NOPR, DOE evaluated belt drives and low-efficiency PSC
motors as the baseline design options, as discussed in section
IV.C.2.c. To determine the baseline costs, DOE first determined the
cost of a baseline ACF without a motor or transmission (``bare-shaft
ACF'') for each representative unit. Then, DOE added the costs
determined for a belt drive and a low-efficiency PSC motor to the base-
shaft ACF to calculate the MPC of the baseline ACF for each
representative unit. DOE did not find a significant difference in MPC
between belt drives associated with different motor hp, so DOE chose a
single belt drive cost for each representative unit. Further details on
belt drive costs and baseline MPCs can be found in chapter 5 of the
NOPR TSD.
For this NOPR, DOE assigned a direct-drive transmission as the
design option for EL 1. DOE assumed that a change from a belt-drive
transmission to a direct-drive transmission would involve the removal
of the belt drive with no other adjustments to the ACF. Therefore, for
the 36-in. and 52-in. axial ACF representative units, DOE estimated the
cost associated with this design option by subtracting the belt drive
MPC from the baseline MPC. For the 24-in. axial ACF and housed
centrifugal ACF representative units, DOE set the EL 1 MPC equal to the
baseline MPC.
DOE assigned a high-efficiency PSC motor as the ACF design option
for EL 2 in this NOPR. For all equipment classes, DOE determined the EL
2 MPC by adding the estimated cost difference between a high-efficiency
PSC motor and a low-efficiency PSC motor to the EL 1 MPC. The MPCs DOE
estimated for low-efficiency PSC motors and high-efficiency PSC motors
are included in chapter 5 of the NOPR TSD.
DOE associated EL 3, EL 4, and EL 5 in this NOPR with three
different levels of aerodynamic redesign. In the October 2022 NODA, DOE
defined a single aerodynamic redesign level at max-tech. DOE assumed
that the redesign, reengineering, and new equipment that could be
required for the aerodynamic redesign would result in a significant
one-time conversion cost, such that aerodynamic redesigns would have a
significantly greater impact on conversion costs than they would on
MPCs. Therefore, DOE assumed that the change in MPC associated with the
aerodynamic redesign was negligible compared to the conversion costs
incurred by the manufacturer to implement this redesign. In this NOPR,
DOE assumed that MPCs for EL 3, EL 4, and EL 5 were equal to the MPC
for EL 2 for all equipment classes. DOE assumed that the complexity of
ACF redesign would increase as ELs increase; therefore, DOE estimated
that manufacturer investment in engineer time and equipment would
increase with each EL. Information on DOE's estimated conversion costs
can be found in section IV.J.2.c of this NOPR and in chapter 12 of the
NOPR TSD.
DOE defined an ECM as the design option for EL 6. For all equipment
classes, DOE determined the EL 6 MPC by adding the estimated cost delta
between an ECM and a high-efficiency PSC motor to the EL 5 MPC. The
MPCs DOE estimated for high-efficiency PSC motors and ECMs can be found
in chapter 5 of the NOPR TSD.
To account for manufacturers' non-production costs and profit
margin, DOE applies a multiplier (the manufacturer markup) to the MPC.
The resulting manufacturer selling price (``MSP'') is the price at
which the manufacturer distributes a unit into commerce. DOE developed
an average manufacturer markup by examining the annual Securities and
Exchange Commission (SEC) 10-K reports filed by publicly traded
manufacturers primarily engaged in air circulating fan manufacturing.
DOE then adjusted these manufacturer markups based on feedback
manufacturers during interviews. DOE used a manufacturer markup of 1.5
in this NOPR analysis. The manufacturer markups used in this NOPR are
discussed in more detail in section IV.J.2.a of this document and in
chapter 12 of the NOPR TSD. The MSPs determined for ACFs are shown in
Table IV-14.
[[Page 3781]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.035
3. Cost-Efficiency Results
The results of the engineering analysis are reported as cost-
efficiency data (or ``curves'') in the form of FEI versus MSP (in
dollars) for GFBs or efficacy versus MSP for ACFs.
For GFBs, as discussed in section IV.C.1.d, DOE developed baseline
MSP versus diameter curves and incremental costs for each design option
for each equipment class. DOE used these correlations to estimate the
MSP at each EL for each equipment class at all nominal impeller
diameters. As such, each equipment class has multiple MSP versus FEI
curves representing the range of impeller diameters that exist on the
market. As discussed in section IV.C.1.b, the FEIs at each EL remain
constant for each equipment class, regardless of impeller diameter.
These FEIs were developed by determining the FEIs for the baseline
equipment and implementing design options above baseline until all
available design options were employed (i.e., at the max-tech level).
In contrast to the ACF analysis which used MPCs, DOE directly estimated
MSPs for GFBs using the AMCA sales database and manufacturer fan
selection software.
For ACFs, DOE developed curves for each representative unit. The
methodology for developing the curves started with determining the
efficacy for baseline equipment and the MPCs for this equipment. Above
the baseline, DOE implemented design options until all available design
options were employed (i.e., at the max-tech level). To convert from
MPCs to MSPs, DOE applied manufacturer markups as described in section
0.
Table IV-15 provides example cost-efficiency results from the GFB
engineering analysis for the axial inline equipment class. Results are
provided at an impeller diameter of 15 in. and an impeller diameter of
48 in.; however, as noted previously, DOE applied the same relative
increases in MSP to obtain results at all impeller diameters for GFBs.
Table IV-16 contains example cost-efficiency results from the ACF
engineering analysis for the 24-in. representative unit. As noted
previously, ACF results were not scaled to all impeller diameters.
Rather, the cost-efficiency results in Table IV-16 are relevant to all
ACFs with an impeller diameter greater than or equal to 12 in. and less
than 36 in.
See chapter 5 of the NOPR TSD for additional detail on the
engineering analysis and appendix 5A of the NOPR TSD for complete cost-
efficiency results.
[GRAPHIC] [TIFF OMITTED] TP19JA24.036
[[Page 3782]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.037
D. 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 the MSP estimates derived in the
engineering analysis to consumer prices, which are then used in the LCC
and PBP analysis and in the manufacturer impact analysis. At each step
in the distribution channel, companies mark up the price of the product
to cover business costs and profit margin.
For GFBs, the main parties in the distribution chain are OEMs,
distributors (including manufacturer in-house distributors), and
contractors. DOE distinguished fan manufacturers in-house by OEMs from
other fans and blowers and identified the distribution channels and
associated fraction of shipments (i.e., percentage of sales going
through each channel) by equipment class.
For ACFs, the main parties in the distribution chain distributors
(including ACF manufacturer in-house distributors) and contractors. In
the October 2022 NODA, DOE identified the distribution channels and
fraction of shipments associated with each channel based on feedback
from manufacturer interviews. 87 FR 62038, 62054. DOE did not receive
any comments on these channels and relied on the same distribution
channels for this NOPR. In addition, as discussed in section IV.F.5 of
this document, DOE included a motor or belt replacement as potential
repairs for ACFs. Therefore, DOE additionally identified distribution
channels associated with the purchase of a replacement motor or belt.
DOE developed baseline and incremental markups for each actor in
the distribution chain. Baseline markups are applied to the price of
equipment 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.\66\
---------------------------------------------------------------------------
\66\ 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 reasonably competitive markets, it
is unlikely that standards would lead to a sustainable increase in
profitability in the long run.
---------------------------------------------------------------------------
DOE relied on economic data from the U.S. Census Bureau as well as
data from RS Means \67\ to estimate average baseline and incremental
markups.
---------------------------------------------------------------------------
\67\ RS Means Electrical Cost Data 2023. Available at:
www.rsmeans.com.
---------------------------------------------------------------------------
Chapter 6 of the NOPR TSD provides details on DOE's development of
markups for fans and blowers.
DOE seeks comment on the distribution channels identified for GFBs
and ACFs and fraction of sales that go through each of these channels.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of fans and blowers at different efficiencies in
representative applications, and to assess the energy savings potential
of increased fan and blower efficiency. The energy use analysis
estimates the range of energy use of fans and blowers in the field
(i.e., as they are actually used by consumers). The energy use analysis
provides the basis for other analyses DOE performed, particularly
assessments of the energy savings and the savings in consumer operating
costs that could result from adoption of amended or new standards.
To characterize variability and uncertainty, the energy use is
calculated for a representative sample of fan and blower consumers.
This method of analysis, referred to as a Monte Carlo method, is
explained in more detail in section IV.F of this document. Results of
the energy use analysis for each equipment class group or
representative unit were derived from a sample of 10,000 consumers.
This section presents DOE's approach to develop consumer samples and
energy use inputs that DOE applied in the energy use analysis.
1. General Fans and Blowers
For GFBs, annual energy use depends on the annual hours of
operation, operating pressure and airflow, and load profile. It
includes the electricity consumed by the motor driving the fan, as well
as losses related to any belts and motor controller (e.g., variable
speed drive or ``VFD'') included in the fan.
Sample of Consumers
DOE developed a consumer sample to represent consumers of GFBs in
the commercial and industrial sectors. DOE used the sample to determine
fan and blower annual energy consumption as well as to conduct the LCC
and PBP analyses.
To develop this sample, DOE used 2012 sales data from AMCA
corresponding to 92,287 units sold
[[Page 3783]]
(``2012 AMCA sales data'').\68\ The data included information on the
design operating flow, operating pressure, and shaft input power for
which each fan was purchased and representative of fans sold as
standalone equipment (i.e., not incorporated in another equipment). In
addition, to represent fans sold incorporated in other equipment (i.e.,
embedded fans manufactured in-house by OEMs or ``OEM fans''), DOE used
data specific to HVAC equipment in which these fans are used to
characterize the fan impeller topology (i.e., category code) typically
used in HVAC equipment and in the scope of this analysis to identify
the range of operating flow, pressure, and shaft input power specific
to these fans. Based on this information, DOE identified fan models
from the 2012 AMCA sales data with the same equipment class, category
code and shaft input power. DOE used these models to develop a sample
representative of OEM fans. DOE then used sales data for the whole U.S.
market to develop weights for each fan model and develop the fan
consumer sample (where each consumer is assigned with a fan model and
associated fan equipment class, category code, power bin, design
operating flow, operating pressure, and shaft input power).
Specifically, DOE developed the weights such that for each equipment
class, the sample included the same proportions of GFBs by market
segment (i.e., fans sold as standalone equipment and OEM fans),
category code, and power bin as in the total U.S. market.
---------------------------------------------------------------------------
\68\ Air Movement and Control Association (AMCA). 2012 Detailed
Confidential Fan Sales Data from 17 Manufacturers. November 2014.
---------------------------------------------------------------------------
In addition, each consumer in the sample was assigned a sector and
a configuration (i.e., direct or belt driven and with or without VFD).
The sector determines the field use characteristics, such as annual
operating hours, load profile, and equipment lifetimes as well as the
economic parameters (i.e., electricity prices and discount rates). To
estimate the percentage of consumers in the industrial and commercial
sectors, DOE primarily relied on data from the DOE-AMO report ``U.S.
Industrial and Commercial Motor System Market Assessment Report Volume
1: Characteristics of the Installed Base'' (``MSMA report'').\69\ To
estimate the percentage of consumers that operate a fan with or without
belts, and with or without VFDs, DOE relied on information from
manufacturer interviews.
---------------------------------------------------------------------------
\69\ Prakash Rao et al., ``U.S. Industrial and Commercial Motor
System Market Assessment Report Volume 1: Characteristics of the
Installed Base,'' January 12, 2021. Available at: doi.org/10.2172/1760267.
---------------------------------------------------------------------------
Annual Operating Hours
To develop distributions of annual operating hours, DOE relied on
information from the MSMA report, which provides distributions of
annual operating hours for fans used in the commercial and industrial
sector.
Load Profiles
DOE relied on the design flow and pressure, associated shaft input
power, and fan configuration information of each fan in the sample to
characterize the operating flow and pressure and associated shaft input
power. DOE further relied on information from manufacturer interviews
to estimate the share of fans that operate at constant load or at
variable load by equipment class.\70\ Based on this information, DOE
estimated the percentage of fans operating at variable load as shown in
Table IV-17.
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\70\ DOE also reviewed information from the MSMA report.
However, the information provided in the MSMA report did not
differentiate fans by equipment class, and DOE therefore relied on
the information collected during manufacturer interviews instead.
[GRAPHIC] [TIFF OMITTED] TP19JA24.038
For fans operating at constant load, DOE reviewed information from
the MSMA report which indicates that the majority of constant load fans
operate at or above 75 percent of the motor full load.\71\ This
indicates that constant load fans primarily operate near the design
point. Therefore, in this NOPR, for both the commercial and industrial
sectors, DOE assumed that all constant load fans operate at the design
point.\72\
---------------------------------------------------------------------------
\71\ See: motors.lbl.gov/analyze/kb-0q19q1M.
\72\ Based on typical motor sizing practices, which suggest a
motor horsepower equal to 1.2 (i.e., the design fan shaft input
power), DOE believes that the design point represents 1/1.2 = 83
percent of the motor full load. The 1.2 sizing factor is based on
input from the Working Group (Docket No. EERE-2013-BT-STD-0006; No.
179, Recommendation #10 at p. 6).
---------------------------------------------------------------------------
For fans used at variable load, in the commercial sector, DOE
relied on information previously provided by AHRI to develop a variable
load profile (Docket No. EERE-2013-BT-STD-0006, AHRI, No. 129, at p.
2). In the industrial sector, DOE did not find any data to characterize
the typical load profile and given the wide range of possible
applications, DOE assumed equal weights at each of the considered load
points.\73\ DOE has tentatively determined that while DOE has not found
data to characterize the field operating loads of GFBs used in the
industrial sector, using a weighted-average across multiple load points
and weighting all those points equally is a more representative load
profile when compared to calculating the efficiency at a single point.
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\73\ The load profile is represented by four load points defined
as 25, 50, 75, and 100 percent of the design flow as well as the
percentage annual operating hours spent at each of these points
(i.e., weights).
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[[Page 3784]]
NEEA commented that the assumptions made for the load profiles
presented in the 2016 NODA LCC are outdated and that DOE should collect
additional information on load profiles for fans and blowers.\74\ NEEA
recommended that DOE collect end-user data, use information on fan
loading information from the MSMA report, or reach out to fan operation
professionals in order to update DOE's load profile assumptions. (NEEA,
No. 129 at p. 7) DOE reviewed the energy use data provided in the MSMA
report. However, DOE notes that the load fraction provided in the MSMA
report are in terms of average fraction of motor full load output power
and are not expressed in terms of percentage time spent at a given
percentage of design flow.\75\ Therefore, DOE could not use this
information to develop the load profiles for variable load fans. In
addition, DOE did not receive any data on load profile in response to
the February 2022 RFI.\76\ Instead, as previously stated, in this NOPR,
for fans used in the commercial sector with VFDs, DOE relied on
information previously provided by AHRI to develop a variable load
profile in the commercial sector (Docket No. EERE-2013-BT-STD-0006,
AHRI, No. 129, at p. 2). In the industrial sector, as stated
previously, DOE did not find any information to help characterize the
load profile and assumed equal weights at each of the considered load
points.
---------------------------------------------------------------------------
\74\ NEEA cited: 2016 NODA Life-Cycle Cost (LCC) and Payback
Period (PBP) Analyses Spreadsheet, Tab ``Sectors and Applications,''
Notes cell B49. Available at: www.regulations.gov/document/EERE-2013-BT-STD-0006-0190.
\75\ See for example: motors.lbl.gov/analyze/3-0819.
\76\ DOE notes that although the February 2022 RFI did not
specifically request feedback on such load profiles, DOE stated that
it received written comments from the public on any subject within
the scope of this document (including those topics not specifically
raised in the RFI), as well as the submission of data and other
relevant information. 87 FR 7048.
---------------------------------------------------------------------------
In response to the October 2022 NODA, NEEA commented that DOE
should account for different power load relationships associated with
different fan control methods. NEEA stated that fans can operate below
100 percent of the design flow. NEEA noted that DOE captured this
operation in its 2016 NODA analysis through the use of load
profiles.\77\ NEEA noted that in its previous annual energy use
calculation, DOE relied on the affinity laws as representative of the
power load relationship for all fans, regardless of the control method.
NEEA added that while the installation of variable speed control can
dramatically reduce a fan's energy consumption, in DOE's analysis its
power load relationship (and therefore energy use) is assumed to be
equal to that of the same fan operating with a more consumptive control
strategy. NEEA commented that using the fan laws is an unreasonable
proxy for other power load relationships. Instead, NEEA commented that
various equipment and appurtenances allow fans to meet reduced flow
rates, and the relationship between the required flow and a fan's power
draw is unique to each equipment or ``control method'' (e.g., the use
of outlet vanes, disc throttle, inlet vanes, and controllable pitch
blades). NEEA provided further examples of such relationships and
associated references.\78\ NEEA added that the installation of a drive
is often considered an energy efficiency opportunity for fan systems.
NEEA stated that the installation of VFDs has been identified as the
measure with the largest savings opportunity for industrial fans and
the second largest savings for commercial fans.\79\ NEEA commented that
the savings associated with installing a VFD are directly related to a
more efficient power-load relationship, and that assuming all load
control methods follow the fan laws would understate the energy use of
fans without VFDs. Therefore, NEEA commented that DOE should account
for the different power-load relationships associated with different
load control methods and applying different power-load relationships
based on the distribution of flow control methods seen in the market.
In addition, NEEA recommended that DOE consider the power-load
relationship for fans operating without a load control method by
developing ``representative'' fan performance curves to model the
energy consumption of fans that do not have load control. NEEA
recommended that DOE develop representative fan curves, similar to
those developed for the energy use analysis in the December 2015 Pumps
Final Rule,\80\ which would enable DOE to account for fan-specific
performance. NEEA noted that this performance curve method was used in
DOE's first NODA \81\ but was removed in the second NODA.\82\ Lastly,
NEEA recommended that DOE utilize published power load equations to
determine energy uses for fans with non-VFD controls.\83\ (NEEA, No.
129 at pp. 4-7)
---------------------------------------------------------------------------
\77\ NEEA cited the November 2016 NODA Life-Cycle Cost (LCC) and
Payback Period (PBP) Analyses Spreadsheet. Available at:
www.regulations.gov/document/EERE-2013-BT-STD-0006-0190.
\78\ Improving Fan System Performance: A Sourcebook for
Industry, Figure 2-20, Page 43. May 2014. Available at:
www.energy.gov/sites/default/files/2014/05/f16/fan_sourcebook.pdf;
and The Uniform Methods Project: Methods for Determining Energy
Efficiency Savings for Specific Measures. Chapter 18: Variable
Frequency Drive Evaluation Protocol, Table 1, Page 12. Available at:
www.nrel.gov/docs/fy17osti/68574.pdf.
\79\ NEEA cited: U.S. Industrial and Commercial Motor System
Market Assessment Report Volume 3: Energy Saving Opportunity, 7/
2022, Figure 17 and Figure 18. Available at: eta-publications.lbl.gov/sites/default/files/u.s._industrial_and_commercial_motor_system_market_assessment_report_volume_3_energy_saving_opportunity_p_rao.pdf.
\80\ NEEA referenced: 2015-12-30 Final Rule Technical Support
Document: Energy Efficiency Program for Consumer Products and
Commercial and Industrial Equipment: Pumps. NEEA commented that
section 7.2.1.3 outlined the process to develop representative
performance curves. Available at: www.regulations.gov/document/EERE-2011-BT-STD-0031-0056.
\81\ NEEA cited: 2014-12-03 NODA Life-Cycle Cost (LCC)
Spreadsheet. Available at: www.regulations.gov/document/EERE-2013-BT-STD-0006-0034.
\82\ See: 2015-04-21 NODA Life-Cycle Cost (LCC) Spreadsheet.
Available at: www.regulations.gov/document/EERE-2013-BT-STD-0006-0060.
\83\ NEEA referenced this study: The Uniform Methods Project:
Methods for Determining Energy Efficiency Savings for Specific
Measures. Chapter 18: Variable Frequency Drive Evaluation Protocol,
Table 1, Page 12. Available at: www.nrel.gov/docs/fy17osti/68574.pdf.
---------------------------------------------------------------------------
As noted by NEEA, different categories of controls result in
different energy savings, which do not always follow the fan affinity
laws. However, based on the MSMA report, DOE estimates that the
majority of fans do not have load control (88 percent), and that the
majority of fans with load control utilize VFDs (9 percent), while 1
percent of fans with load control rely on other categories of controls
and another 1 percent of fans had an unknown configuration.\84\
Therefore, in this NOPR, for fans with load control (and operating at
variable load) DOE only considered VFDs as the primary load control
equipment and applied the affinity laws when calculating the resulting
savings. For fans without load control and operating at constant load,
as stated earlier, DOE believes the majority of these fans operate near
the design point. In addition, although DOE developed information on
typical fan curves as part of previous analysis as noted by NEEA, the
AMCA data did not provide sufficient information to relate the design
point to a location on the fan curve. Therefore, for constant load
fans, DOE was unable to utilize this information in combination with
the 2012 AMCA data to estimate the energy use at a reduced flow and
thus assumed operation at the design point.\85\
---------------------------------------------------------------------------
\84\ See: motors.lbl.gov/analyze/4b-0j0Bd0.
\85\ As noted by NEAA, DOE updated its methodology between its
first NODA and second NODA in order to enable the utilization of the
AMCA 2012 data which represented thousands of fan selection data.
While the first NODA relied on representative units and
representative fans curves, as well as confidential data from a
single manufacturer to develop distributions of operating points,
the second NODA relies on fan selection data and sales data from 17
manufacturers to inform the LCC sample and location of the operating
points.
---------------------------------------------------------------------------
[[Page 3785]]
Drive Components
The fan energy use calculation includes motor, VFD (if present) and
transmission (i.e., belt) losses. To represent the performance of the
motor and belts, DOE used the mathematical models from the DOE test
procedure (See 87 FR 27312) which assumes the motor is compliant with
the upcoming DOE standard for electric motors at 10 CFR 431.25 and
characterizes belt efficiency based on a model published in AMCA 214-21
as referenced in the DOE test procedure.\86\ To represent the
performance of the motor combined with a VFD, DOE used the mathematical
models from section 6.4 of AMCA 214-21 which is representative of
typical motor and VFD combinations, as referenced in the DOE test
procedure. DOE further relied on information from manufacturer
interviews to estimate the share of belt-driven fans.
---------------------------------------------------------------------------
\86\ ANSI/AMCA Standard 214-21 ``Test Procedure for Calculating
Fan Energy Index (FEI) for Commercial and Industrial Fans and
Blowers.''
---------------------------------------------------------------------------
2. Air-Circulating Fans
DOE calculated the energy use of ACFs by combining ACF input power
consumption from the engineering analysis with annual operating hours.
For each consumer in the sample, DOE associates a value of ACF annual
operating hours drawn from statistical distributions as described in
the remainder of this section.
Sample of Consumers
In the October 2022 NODA, DOE included commercial, industrial, and
agricultural applications in the energy use analysis of ACFs with input
power greater than or equal to 125 W. 87 FR 62038, 62056. DOE did not
receive any comments on this approach. Accordingly, in the NOPR, DOE
created a sample of 10,000 consumers for each representative unit to
represent the range of air-circulating fan energy use in the
commercial, industrial, and agricultural sectors.
Annual Operating Hours
In the October 2022 NODA, 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.\87\ To
represent a range of possible operating hours around this
representative value, DOE relied on 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). 87 FR
62038, 62056-62057
---------------------------------------------------------------------------
\87\ See section 7.4.2 of Chapter 7 of the Ceiling Fan
Preliminary Analysis Technical Support Document. Available at:
www.regulations.gov/document/EERE-2021-BT-STD-0011-0015.
---------------------------------------------------------------------------
In response to the October 2022 NODA, ebm-papst stated that the
usages 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) AMCA commented that ACFs and ceiling fans in
commercial and industrial buildings serve similar functions during
warmer months, which is to provide a low-energy method for cooling.
AMCA added however that ACFs are often not used during cooler months,
while ceiling fans are either used in a reversed direction mode or run
at a lower speed. Therefore, only ceiling fan usage during warmer
months can be used as a proxy for ACF usage, and the annual operating
hours of ceiling fans will be greater than those of ACFs. AMCA added
that ACFs used for horticulture applications may have different usage
hours than that of other ACFs or ceiling fans. (AMCA, No. 132 at p. 13)
DOE established the annual operating hours as the product of the
daily operating hours and the number of operating days per year. In
line with the information presented in the October 2022 NODA, for all
ACFs except centrifugal housed ACFs, DOE assumed average daily
operating hours of 12 hours per day. To reflect the variability in
usage by application as noted by ebm-papst, DOE relied on a uniform
distribution between 6 and 18 hours per day. For centrifugal housed
ACFs, DOE relied on lower operating hours as these fans are primarily
used for carpet drying applications and are less likely to operate 12
hours per day on average. DOE did not receive any feedback on daily
operating hours and assumed average daily operating hours of 6 hours
per day. To represent a range of possible operating hours around this
representative value, DOE relied on a uniform distribution between 0
hours per day and 12 hours per day.
With the exception of centrifugal housed ACFs, ACFs are primarily
used for cooling purposes in the commercial sector (e.g., to cool
people in loading docks, warehouses, gyms, etc.), in the industrial
sector, (e.g., to cool people in factory workstations, etc.), and in
the agricultural sector (e.g., to reduce livestock heat stress). To
establish the number of annual operating days for ACFs other than
centrifugal housed ACFS, and to reflect AMCA's note that these ACFs are
not used in cooler months, DOE relied on weather data to estimate a
distribution of annual operating days for ACFs. While some ACFs may
also be used for non-cooling purposes,\88\ DOE did not find any data to
establish the market share of such applications and assumed all ACFs
are used for cooling purposes, as this is the primary application of
ACFs. Based on input from manufacturer interviews, DOE further
estimated that 20 percent of ACFs are used in the commercial sector, 20
percent in the industrial sector, and 60 percent in the agricultural
sector. In the case of centrifugal housed ACFs, which are primarily
used for carpet drying, DOE assumed these are exclusively used in the
commercial sector and throughout the year.
---------------------------------------------------------------------------
\88\ This include fans that are also used for cooling and may be
left on during cooler months as they are also used for non-cooling
applications (e.g., ACFs used for reducing foul odors/manure gases/
moisture/dust, drying, cooling machinery).
---------------------------------------------------------------------------
Input Power
In the October 2022 NODA, DOE described that 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
and assuming an equal amount of time spent at each tested speed. 87 FR
62038, 62055-62057. Consistent with the May 2023 TP Final Rule, DOE
estimates that these fans are primarily used at high speed and assumed
operation at high speed only.
Chapter 7 of the NOPR TSD provides details on DOE's energy use
analysis for fans and blowers.
DOE seeks comment on the overall methodology and inputs used to
estimate GFBs and ACFs energy use. Specifically, for GFBs, DOE seeks
feedback on the methodology and assumptions used to determine the
operating point(s) both for constant and variable load fans. For ACFs,
DOE requests feedback on the average daily operating hours, annual days
of operation by sector and application, and input power assumptions. In
addition, DOE requests feedback on the market share of GFBs and ACFs by
sector (i.e., commercial, industrial, and agricultural).
[[Page 3786]]
F. Life-Cycle Cost and Payback Period Analyses
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual consumers of potential energy conservation standards for
fans and blowers. The effect of new or amended energy conservation
standards on individual consumers usually involves a reduction in
operating costs and an increase in purchase cost. DOE used the
following two metrics to measure consumer impacts:
The LCC is the total consumer expense of the equipment
over the life of that equipment, 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 equipment.
The PBP is the estimated amount of time (in years) it
takes consumers to recover the increased purchase cost (including
installation) of more efficient equipment 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 fans and blowers in the absence of
new or amended energy conservation standards. The PBP for a given
efficiency level is also measured relative to the no-new-standards case
efficiency distribution.
For each considered TSL in each equipment class, DOE calculated the
LCC and PBP for a nationally representative set of consumers. As stated
previously, DOE developed consumer samples from a variety of data
sources as described in section IV.F of this document. For each sample
consumer, DOE determined the energy consumption for the fans and
blowers and the appropriate energy price. By developing a
representative sample of consumers, the analysis captured the
variability in energy consumption and energy prices associated with the
use of fans and blowers.
Inputs to the calculation of total installed cost include the cost
of the equipment--which includes MPCs, manufacturer markups (including
the additional manufacturer conversion cost markups where appropriate),
retailer and distributor markups, and sales taxes--and installation
costs. Inputs to the calculation of operating expenses include annual
energy consumption, energy prices and price projections, repair and
maintenance costs, equipment lifetimes, and discount rates. DOE created
distributions of values for equipment lifetime, discount rates, and
sales taxes, with probabilities attached to each value, to account for
their uncertainty and variability.
The computer model DOE uses to calculate the LCC 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 fan and blower user samples. The
model calculates the LCC for equipment at each efficiency level for
10,000 consumers per simulation run and equipment class. 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 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.
DOE calculated the LCC and PBP for consumers of fans and blowers as
if each were to purchase new equipment in the expected year of required
compliance with new or amended standards. New standards would apply to
fans and blowers manufactured 5 years after the date on which any new
standard is published. (42 U.S.C 6316(a); 42 U.S.C. 6295(l)(2)) At this
time, DOE estimates publication of a final rule in the second half of
2024. Therefore, for the purposes of its analysis, DOE used 2030 as the
first full year of compliance with any new standards for fans and
blowers.
Table IV-18 Summary of Inputs and Methods for the LCC and PBP
Analysis* summarizes the approach and data DOE used to derive inputs to
the LCC and PBP calculations. The subsections that follow provide
further discussion. Details of the spreadsheet model, and of all the
inputs to the LCC and PBP analyses, are contained in chapter 8 of the
NOPR TSD and its appendices.
[[Page 3787]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.039
In response to the October 2022 NODA, AMCA commented that DOE
should refer to interviews with individual manufacturers for feedback
on the inputs and considered methods used for the LCC and PBP analyses.
(AMCA, No. 132 at p. 14) As noted throughout this section, DOE relied
on input from manufacturer interviews where available.
1. Equipment Cost
To calculate equipment costs, DOE multiplied the MSPs developed in
the engineering analysis by the distribution channel markups described
previously (along with sales taxes). DOE used different markups for
baseline equipment and higher-efficiency equipment because DOE applies
an incremental markup to the increase in MSP associated with higher-
efficiency equipment. Further, as described in section IV.C of this
document, at ELs with associated manufacturer conversion costs, DOE
applied a manufacturer conversion markup when calculating the equipment
price of re-designed units.
Economic literature and historical data suggest that the real costs
of many products may trend downward over time according to ``learning''
or ``experience'' curves. Experience curve analysis implicitly includes
factors such as efficiencies in labor, capital investment, automation,
materials prices, distribution, and economies of scale at an industry-
wide level.
For GFBs, to develop an equipment price trend for the NOPR, DOE
derived an inflation-adjusted index of the Producer Price Index (PPI)
for industrial and commercial fans and blowers equipment over the
period 2003-2022.\89\ These data show a general price index increase
from 2003 through 2009, a slower growth trend over the period 2009-
2020, and a high increase since 2020. However, the outbreak of COVID-19
pandemic caused immense uncertainties in global supply chain and
international trade resulting in price surges across all sectors since
2020. DOE believes that the extent to which these macroeconomic trends
will continue in the future is very uncertain. Therefore, DOE used a
constant price assumption as the default trend to project future fan
prices. Thus, for GFBs, prices projected for the LCC and PBP analysis
are equal to the 2022 values for each efficiency level in each
equipment class.
---------------------------------------------------------------------------
\89\ Series ID PCU3334133334132. Available at: www.bls.gov/ppi/.
---------------------------------------------------------------------------
For ACFs, DOE did not find PPI data specific to ACFs, and instead,
DOE adopted a component-based approach to develop a price trend by
identifying ACF components most likely to undergo a price variation
over the forecast period. Using this approach, the price trend only
applies to the cost of the component and not to the total cost of the
ACF. For EL0 through EL5, which are efficiency levels that assume AC
induction motors, DOE determined that ACF motors are the most likely
component to undergo price variation over time and analyzed long-term
trends in the integral and fractional horsepower motors PPI series.\90\
The deflated price index for integral and fractional horsepower motors
was found to align with the copper, steel, and aluminum deflated price
indices. DOE believes that the extent to which these commodity price
trends will continue in the future is very uncertain and therefore does
not project commodity prices. In addition, the deflated price index for
fractional horsepower motors was mostly flat during the entire period
from 1967 to 2020. Therefore, DOE relied on a constant price assumption
as the default price factor index to project future ACF prices at EL 0
through EL 5. At EL 6, which assumes an ECM motor, DOE did not find any
historical data specifically regarding ECM motors. For its analysis,
DOE assumed that the circuitry and electronic controls associated with
ECM motors would potentially be the most affected by price trends
driven by the larger electronics industry as a whole. DOE obtained PPI
data on ``Semiconductors and related
[[Page 3788]]
device manufacturing'' \91\ between 1967 and 2022 to estimate the
historic price trend in electronic components. These data show a price
decline over the entire period. Therefore, DOE applied a decreasing
price trend for the controls portion of the ECM price. See chapter 8
for more details on the price trends.
---------------------------------------------------------------------------
\90\ Series ID PCU3353123353123 and PCU3353123353121. Available
at: www.bls.gov/ppi/.
\91\ Series ID: PCU334413334413. Available at www.bls.gov/ppi/.
---------------------------------------------------------------------------
DOE requests feedback on the price trends developed for GFBs and
ACFs.
2. Installation Cost
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the equipment.
For GFBs, DOE found no evidence that installation costs would be
impacted with increased efficiency levels and did not include
installation costs in its analysis, except at efficiency levels where
an increase in size is assumed (i.e., for PRVs). In this case, DOE
incorporated higher installation (i.e., shipping) costs due to the
change in size.
For ACFs, DOE stated in the October 2022 NODA that it found no
evidence that installation costs would be impacted with increased
efficiency levels and, as a result, DOE was not planning on including
installation costs in the LCC. 87 FR 62038, 62058. DOE did not receive
any comments to the October 2022 NODA related to installation costs and
continued with this approach for ACFs.
DOE requests feedback on the installation costs developed for GFBs
and on whether installation costs of ACFs may increase at higher ELs.
3. Annual Energy Consumption
For each sampled consumer, DOE determined the energy consumption
for a fan at different efficiency levels using the approach described
previously in section IV.E of this document.
4. Energy Prices
Because marginal electricity prices more accurately capture the
incremental savings associated with a change in energy use from higher
efficiency, they provide a better representation of incremental change
in consumer costs than average electricity prices. Therefore, DOE
applied average electricity prices for the energy use of the equipment
purchased in the no-new-standards case, and marginal electricity prices
for the incremental change in energy use associated with the other
efficiency levels considered.
DOE derived electricity prices in 2022 using data from EEI Typical
Bills and Average Rates reports. Based upon comprehensive, industry-
wide surveys, this semi-annual report presents typical monthly electric
bills and average kilowatt-hour costs to the customer as charged by
investor-owned utilities. For the commercial and industrial sector, DOE
calculated electricity prices using the methodology described in
Coughlin and Beraki (2019).\92\
---------------------------------------------------------------------------
\92\ Coughlin, K. and B. Beraki. 2019. Non-residential
Electricity Prices: A Review of Data Sources and Estimation Methods.
Lawrence Berkeley National Lab. Berkeley, CA. Report No. LBNL-
2001203. Available at: ees.lbl.gov/publications/non-residential-electricity-prices.
---------------------------------------------------------------------------
DOE's 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 analysis. For fans
and blowers, DOE considered sector-specific electricity prices. See
chapter 8 of the NOPR TSD for details.
To estimate energy prices in future years, DOE multiplied the 2022
energy prices by the projection of annual average price changes from
the Reference case in AEO2023, which has an end year of 2050.\93\ To
estimate price trends after 2050, the 2050 prices were held constant.
---------------------------------------------------------------------------
\93\ EIA. Annual Energy Outlook 2023 with Projections to 2050.
Washington, DC. Available at: www.eia.gov/forecasts/aeo/ (last
accessed June 6, 2023).
---------------------------------------------------------------------------
5. Maintenance and Repair Costs
Repair costs are associated with repairing or replacing equipment
components that have failed in an appliance; maintenance costs are
associated with maintaining the operation of the equipment. Typically,
small incremental increases in equipment efficiency entail no, or only
minor, changes in repair and maintenance costs compared to baseline
efficiency equipment.
For GFBs, DOE found no evidence that maintenance and repair costs
would be impacted with increased efficiency levels. Therefore, because
DOE expresses results in terms of LCC savings, DOE did not account for
maintenance and repair costs in the LCC.
For ACFs, in the October 2022 NODA, DOE stated that it did not find
any information supporting changes in maintenance costs as a function
of efficiency. 87 FR 62038, 62058. DOE did not receive any comments in
response to the October 2022 NODA related to maintenance costs; DOE
continues to believe these do not vary by efficiency and did not
include maintenance costs in its analysis.
In the October 2022 NODA, DOE identified the motor replacement as a
potential repair for ACFs. DOE requested feedback on its assumptions
about repair practices of ACFs. 87 FR 62038, 62058.
In response, AMCA commented that belt replacement could be the only
significant maintenance or repair necessary for ACFs. AMCA added that
DOE should reference manufacturer interviews for further information.
AMCA added that ACFs are often used in environments with harsher
conditions than other fans and experience higher temperatures, higher
moisture content, higher particulate concentrations, and more power
source fluctuations than do other fans. Because of this, AMCA stated
that ACF repairs and replacements are more frequent than for other
fans. (AMCA, No. 132 at pp. 14-15)
For ACFs, DOE found no evidence that maintenance costs would be
impacted with increased efficiency levels and did not include
maintenance costs in its analysis. However, DOE did include repair
costs associated with belt repair at EL 0, which represents belt driven
ACFs as appropriate. In addition, although stakeholder feedback did not
indicate the possibility of a motor repair for ACFs, DOE identified
several ACF manufacturers offering replacement motors. DOE assumed such
repair is not frequent as it was not identified as a potential repair
by stakeholders. Therefore, DOE assumed that only 5 percent of ACFs
include a motor repair and estimated the repair costs associated with
motor replacement. In order to calculate these repair costs, DOE relied
on inputs from the engineering analysis.
DOE requests feedback on whether the maintenance and repair costs
of GFBs may increase at higher ELs. Specifically, DOE requests comments
on the frequency of motor replacements for ACFs. DOE also requests
comments on whether the maintenance and repair costs of ACFs may
increase at higher ELs and on the repair costs developed for ACFs.
6. Equipment Lifetime
For GFBs, in the NODA DOE used average lifetimes of 30 years in the
industrial sector based on input from a subject matter expert, and 15
years in the commercial sector based on the expected lifetimes of HVAC
equipment. Across all sectors and equipment classes, the average
lifetime for GFBs is 16 years. To characterize the range of possible
lifetimes, DOE developed Weibull distributions of equipment lifetimes.
[[Page 3789]]
For ACFs, in the October 2022 NODA, DOE stated that it did not find
lifetime data specific to ACFs and was considering using 30 years,
similar to GFBs lifetimes in a previous DOE analysis. (November 2016
NODA)
In response to the October 2022 NODA, AMCA commented that DOE
should assume a lifetime of 10 years instead of 30, because ACFs often
are used in non-conditioned spaces or agricultural environments that
expose them to dust, debris, moisture, and other debilitating factors.
In addition, AMCA stated that in a previous report,\94\ DOE estimated
average lifetimes of fractional (i.e., less than 1 horsepower) electric
motors to 10 to 15 years. AMCA added that ACFs are typically used in
areas without air conditioning and experience higher air temperatures,
higher humidity, higher concentrations of particulate matter in the
air, and greater fluctuations in power quality, compared to fans in
buildings with full HVAC systems and tight envelopes. For these
reasons, AMCA stated that it is unlikely for an ACF to have a lifetime
of 30 years. Instead, AMCA recommended using a value of 10 years, which
is the lower end of the motor life expectancy in the DOE report. (AMCA,
No. 132 at pp. 2, 18-19)
---------------------------------------------------------------------------
\94\ AMCA referenced the following study: 1980. ``Classification
and evaluation of electric motors and pumps.'' United States.
Available at: doi.org/10.2172/6719781.
---------------------------------------------------------------------------
In this analysis, as suggested by AMCA, DOE relied on separate
lifetimes for ACFs and GFBs. DOE considered two separate lifetimes for
ACFs depending on whether the lifetime included a motor replacement or
not. For ACFs that do not include a motor replacement, DOE assumed the
average lifetime was equal to the estimated average motor lifetime of 6
years based on input from manufacturer interviews. DOE believes this
value is more representative of ACF motor lifetimes as it is more
recent and specific to the ACFs compared to the estimate provided by
AMCA, which relied on a general motor and pump study published in 1980.
For ACFs that include a motor replacement, DOE assumed an average
lifetime of 12 years (i.e., twice the motor lifetime). DOE further
assumed 5 percent of ACFs have a motor repair (see section IV.F.5 of
this document), while 95 percent of ACFs do not, resulting in an
overall average lifetime of 6.3 years. To characterize the range of
possible lifetimes, DOE developed Weibull distributions of equipment
lifetimes.
DOE requests comments on the average lifetime estimates used for
GFBs and ACFs.
7. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
for consumers to estimate the present value of future operating cost
savings. DOE estimated a distribution of discount rates for fans and
blowers 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.\95\ The LCC analysis estimates net present value over the
lifetime of the 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 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.
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\95\ 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 commercial, industrial, and agricultural discount
rates for fans and blowers, DOE estimated the weighted-average cost of
capital using data from Damodaran Online.\96\ 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 discount rates in the commercial,
industrial, and agricultural sectors are 6.77, 7.25, and 7.15 percent,
respectively.
---------------------------------------------------------------------------
\96\ Damodaran Online, Data Page: Costs of Capital by Industry
Sector (2021). Available at: pages.stern.nyu.edu/~adamodar/(last
accessed April 22, 2022).
---------------------------------------------------------------------------
DOE did not receive any comments related to discount rates.
See chapter 8 of the NOPR TSD for further details on the
development of discount rates.
8. Energy 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 considered the projected
distribution (market shares) of equipment efficiencies under the no-
new-standards case (i.e., the case without new energy conservation
standards).
To estimate the energy efficiency distribution of GFBs for 2030,
DOE relied on the 2012 AMCA sales data from the sample (see section
IV.E.1 of this document). DOE notes that since 2012, the ASHRAE
Standard 90.1-2010 Energy Standard for Buildings Except Low-Rise
Residential Building (``ASHRAE Standard 90.1'') includes limits on the
FEI of certain fans and has been adopted in some States.\97\ In
addition, the California Energy Commission recently finalized reporting
requirements to promote fan selections at duty points with FEI ratings
greater than or equal to 1.00.\98\ However, DOE reviewed recent
manufacturer catalogs and found that the market has not changed
significantly since 2012 (see detailed discussion in section IV.A.2.a
of this document). Therefore, in this NOPR, DOE relied on the 2012
efficiency distributions to characterize the no-new-standards case in
2030. The estimated market shares for the no-new-standards case for
GFBs are shown in Table IV-19.
---------------------------------------------------------------------------
\97\ See 2020 Florida Building Code, Energy Conservation, 7th
edition--Section C403.2.12.3 Fan Efficiency, effective December 31,
2020; 2021 Oregon Efficiency Specialty Code (OEESC): The 2021 OEESC,
based on ASHRAE Standard 90.1-2019, effective April 1, 2021.
\98\ These requirements take effect in November 2023. See
www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-20/appliance-efficiency-proceedings-11.
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[[Page 3790]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.040
In the October 2022 NODA, DOE stated that it would rely on
information from the BESS Labs dataset to develop efficiency
distribution and that it would randomly assign an equipment efficiency
to each consumer drawn from the consumer samples. 87 FR 62038, 62060.
DOE did not receive any comments on this topic.
For ACFs, DOE collected model performance data from the BESS Labs
database as well as information from manufacturer catalogs. As noted in
section IV.A.1.a, the BESS Labs database contains fans with higher
efficiencies than the overall ACF market and is not representative of
the ACF market as a whole. DOE collected catalog data from manufacturer
and distributor websites to supplement the BESS Labs database. DOE
relied on the performance data from both datasets establish the no-new-
standards case efficiency distribution of ACFs in 2030 and used a
weighted average when calculating the overall efficiency distributions
to reflect that fact that the models in the BESS Labs database are
representative of the top of the market in terms of efficiency.\99\ DOE
did not find historical performance data for ACFs and assumed the
efficiency distribution would remain the same over time. The resulting
market shares for the no-new-standards case for ACFs are shown in Table
IV-20.
---------------------------------------------------------------------------
\99\ Specifically, to reflect that the BESS data is not
representative of the majority of the ACF market, DOE assumed that a
quarter of ACFs are represented by the BESS labs data and applied a
weight of 0.25 to the BESS Labs database and a weight of 0.75 to the
catalog data collected from manufacturer and distributor websites.
[GRAPHIC] [TIFF OMITTED] TP19JA24.041
See chapter 8 of the NOPR TSD for further information on the
derivation of the efficiency distributions.
The LCC Monte Carlo simulations draw from the efficiency
distributions and randomly assign an efficiency to the fans and blowers
purchased by each sample consumer in the no-new-standards case. The
resulting percentage shares within the sample match the market shares
in the efficiency distributions.
DOE requests feedback and information on the no-new-standards case
efficiency distributions used to characterize the market of GFBs and
ACFs. DOE requests information to support any efficiency trends over
time for GFBs and ACFs.
9. Payback Period Analysis
The payback period is the amount of time (expressed in years) it
takes the consumer to recover the additional installed cost of more-
efficient equipment, compared to the no-new-standards case equipment,
through energy cost savings. Payback periods that exceed the life of
the equipment mean that the increased total installed cost is not
recovered in reduced operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the equipment and the change in the
first-year annual operating expenditures relative to the baseline. DOE
refers to this as a ``simple PBP'' because it does not consider changes
over time in operating cost savings. The PBP calculation uses the same
inputs as the LCC analysis when deriving first-year operating costs.
As noted previously, EPCA establishes a rebuttable presumption that
a standard is economically justified if the Secretary finds that the
additional cost to the consumer of purchasing equipment complying with
an energy conservation standard level will be less than three times the
value of the first year's energy savings resulting from the standard,
as calculated under the applicable test procedure. (42 U.S.C
[[Page 3791]]
6316(a); 42 U.S.C. 6295(o)(2)(B)(iii)) For each considered efficiency
level, DOE determined the value of the first year's energy savings by
calculating the energy savings in accordance with the applicable DOE
test procedure, and multiplying those savings by the average energy
price projection for the year in which compliance with the standards
would be required.
G. Shipments Analysis
DOE uses projections of annual equipment shipments to calculate the
national impacts of potential amended or new energy conservation
standards on energy use, NPV, and future manufacturer cash flows.\100\
The shipments model takes an accounting approach, tracking market
shares of each equipment class and the vintage of units in the stock.
Stock accounting uses equipment shipments as inputs to estimate the age
distribution of in-service equipment stocks for all years. The age
distribution of in-service equipment stocks is a key input to
calculations of both the NES and NPV, because operating costs for any
year depend on the age distribution of the stock.
---------------------------------------------------------------------------
\100\ DOE uses data on manufacturer shipments as a proxy for
national sales, as aggregate data on sales are lacking. In general,
one would expect a close correspondence between shipments and sales.
---------------------------------------------------------------------------
1. General Fans and Blowers
DOE first estimated total shipments in the base year. For fans sold
as a standalone equipment by equipment class, DOE relied on the
estimate in the November 2016 NODA, which relied on a market research
report,\101\ and AMCA confidential sales data from 2012. To estimate
the shipments of fans sold incorporated in other equipment (``OEM
fans''), DOE first identified HVAC equipment that incorporate the
embedded fans in the scope of analysis (i.e., HVAC equipment not listed
in Table III-1). DOE then determined the average quantity of fans used
in each of the identified HVAC equipment and estimated the total number
of HVAC fans as the product of HVAC equipment sales and average number
of fans per equipment. The OEM fan shipments in scope were then
calculated by subtracting the estimated number of standalone fans
purchased by OEMs from the total number of fans in HVAC equipment, to
avoid double counting. See chapter 9 for more details.
---------------------------------------------------------------------------
\101\ IHS Technology (March 2014), Fans and Blowers, World.
---------------------------------------------------------------------------
AHRI provided feedback on shipments values published in the
November 2016 NODA. Specifically, AHRI disagreed with DOE's estimate of
air handling units and estimated the shipments to be 65,000 units per
year. AHRI further commented that 75 percent of these units have
variable air volume (``VAV'') capability, and that 60-70% of those are
equipped with variable speed drives; AHRI questioned whether DOE
accounted for this in its energy use analysis. Finally, AHRI commented
that they identified approximately 40 percent of air handling units
with either a return or an exhaust fan, as opposed to 50 percent
assumed in the November 2016 NODA. (AHRI, No. 130 at pp. 7-8)
DOE reviewed the information provided by AHRI and agrees with the
more recent shipments estimate of 65,000 units per year. In addition,
DOE accounted for variable load operation in its energy use analysis as
described in section IV.E.1 of this document. However, DOE did not
estimate the percentage of VAV units by HVAC equipment but by GFBs
equipment class (up to 65 percent depending on the equipment class).
Finally, for this NOPR, DOE estimated the percentage of air handling
units with either a return or an exhaust fan as 30 percent based on
more recent input from manufacturer interviews.
AHRI disagreed with DOE's estimate of panel fans per air-cooled
water chiller and the number of air-cooled water chillers shipped. AHRI
stated that the average number of panel fans per unit is seven instead
of the DOE estimate of 14 in the November 2016 NODA. AHRI also stated
that the number of air-cooled chillers shipped is 26,000 per year.
(AHRI, No. 130 at pp. 9-10)
DOE reviewed the information provided by AHRI as well as additional
information from previous comments estimating average annual shipments
of air-cooled chillers to 27,000 units per year based on the U.S.
Census MA35M/MA333M series.\102\ DOE agrees with the more recent
shipments estimate of 26,000-27,000 units per year and 7 fans per unit
for air-cooled water chillers. As such, DOE relied on this estimate
(27,000) rather than on the values published in the November 2016 NODA.
---------------------------------------------------------------------------
\102\ See: AHRI data, CEC Docket 17-AAER-06, TN#221201-1, p.10
https://efiling.energy.ca.gov/GetDocument.aspx?tn=221201-1&DocumentContentId=26700.
---------------------------------------------------------------------------
AHRI disagreed with DOE's estimate of commercial unitary air
conditioners and heat pumps with and without return/exhaust fans. AHRI
stated that less than 10 percent of units under 240,000 Btu/h have
return/exhaust fans and about 70 percent of units over 240,000 Btu/h
have return/exhaust fans. AHRI also commented that 80 percent of units
over 240,000 Btu/h have variable speed drives and VAVs. AHRI commented
that these estimates were based on a survey of its members. (AHRI, No.
130 at p. 9)
DOE reviewed the information provided by AHRI and agrees with the
more recent percentage values to estimate the fraction of units with a
return or exhaust fan. As such DOE relied on these estimates rather
than on the values published in the November 2016 NODA to estimate the
number of fans per unit in commercial unitary air conditioners and heat
pumps.
To project shipments of fans in the industrial sector, DOE assumed
in the no-new-standards case that the long-term growth of fan shipments
will be driven by long-term growth of fixed investments in equipment
including fans, which follow the same trend as the gross domestic
product (``GDP''). DOE relied on fixed investment data from the Bureau
of Economic Analysis and AEO2023 forecast of GDP through 2050 to inform
its shipments projection. For the commercial sector, DOE projected
shipments using AEO2023 projections of commercial floor space. In 2030,
DOE estimates the total shipments of GFBs to 1.38 million units.
DOE also derived high and low shipments projections based on
AEO2023 economic growth scenarios.
DOE further assumed that standards would have a negligible impact
on fan shipments and applied a zero price-elasticity under standards
cases. It is likely that following a standard, rather than foregoing a
fan purchase under a standards case, a consumer might simply switch
brands or fans to purchase a fan that is best suited for their
application. As a result, DOE used the same shipments projections in
the standards case as in the no-new-standards case.
DOE requests feedback on the methodology and inputs used to project
shipments of GFBs in the no-new-standards case. DOE requests comments
and feedback on the potential impact of standards on GFB shipments and
information to help quantify these impacts.
2. Air Circulating Fans
In the October 2022 NODA, DOE estimated total shipments of ACFs to
over 2 million using information from manufacturer interviews
indicating shipments estimates of 494,950 units of unhoused air
circulating fan heads and 255,100 units of cylindrical air circulating
fans and applying expansion factors to determine the shipments of other
categories of ACFs included in the scope. 87 FR 62038, 62061. DOE did
not
[[Page 3792]]
receive any feedback or information on shipments in response to the
October 2022 NODA.
For this NOPR, DOE reviewed the information from manufacturer
interviews and has determined that the shipments estimates provided
were for the total market of axial ACFs (rather than specific to
unhoused air circulating fan heads and cylindrical air circulating fans
only, as previously determined). In addition, DOE estimated that housed
centrifugal ACFs represent one percent of the total ACF market based on
the small number of manufacturers identified in the catalog data
collected by DOE from manufacturer and distributor websites.
In the October 2022 NODA, DOE estimated that shipments of ACFs
follow similar trends as shipments of large-diameter ceiling fans.
Therefore, DOE stated that it was 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.\103\ 87 FR 62038, 62061. In response to the October 2022
NODA, 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,
as well as climate change could all be reasons for possible growth in
the ACFs market. (ebm-papst, No. 8 at p. 4)
---------------------------------------------------------------------------
\103\ See docket No. EERE-2021-BT-STD-0011-0015.
---------------------------------------------------------------------------
DOE agrees with the qualitative comment from ebm-papst regarding
the potential causes for future ACF market growth. However, DOE notes
that this information does not allow for a quantitative estimation of
projected shipments. DOE did not receive any additional feedback on
this approach and applied this methodology in the NOPR. In 2030, DOE
estimates the total shipments of fans to be 1.30 million units.
DOE requests feedback on the methodology and inputs used to
estimate and project shipments of ACFs in the no-new-standards case.
DOE requests comments and feedback on the potential impact of standards
on ACF shipments and information to help quantify these impacts.
H. National Impact Analysis
The NIA assesses the national energy savings (``NES'') and the NPV
from a national perspective of total consumer costs and savings that
would be expected to result from new or amended standards at specific
efficiency levels.\104\ (``Consumer'' in this context refers to
consumers of the equipment being regulated.) 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 fans and blowers sold from 2030 through 2059.\105\
---------------------------------------------------------------------------
\104\ The NIA accounts for impacts in the 50 States and U.S.
territories.
\105\ Because the anticipated compliance date is late in the
year, for analytical purposes, DOE conducted the analysis for
shipments from 2030 through 2059.
---------------------------------------------------------------------------
DOE evaluates the impacts of new or amended standards by comparing
a case without such standards with standards-case projections. 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
(i.e., the TSLs or standards cases) for that class. For the standards
cases, DOE considers how a given standard would likely affect the
market shares of equipment with efficiencies greater than the standard.
DOE uses a spreadsheet model to calculate the energy savings and
the national consumer costs and savings from each TSL. Interested
parties can review DOE's analyses by changing various input quantities
within the spreadsheet. The NIA spreadsheet model uses typical values
(as opposed to probability distributions) as inputs.
Table IV-21 summarizes the inputs and methods DOE used for the NIA
analysis for the NOPR. Discussion of these inputs and methods follows
the table. See chapter 10 of the NOPR TSD for further details.
[[Page 3793]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.042
1. 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. Section IV.F.8 of this document describes how DOE developed an
energy efficiency distribution for the no-new-standards case (which
yields a shipment-weighted average efficiency) for each of the
considered equipment classes for the first full year of anticipated
compliance with an amended or new standard. To project the trend in
efficiency absent amended standards for GFBs and ACFS over the entire
shipments projection period, DOE assumed a constant efficiency trend.
The approach is further described in chapter 10 of the NOPR TSD.
For the standards cases, DOE used a ``roll-up'' scenario to
establish the shipment-weighted efficiency for the first full year that
standards are assumed to become effective (2030). In this scenario, the
market shares of equipment 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 equipment above the standard
would remain unchanged.
To develop standards case efficiency trends after 2030, DOE assumed
a constant efficiency trend, similar to the no-new standards case.
2. National Energy Savings
The national energy savings analysis involves a comparison of
national energy consumption of the considered equipment between each
potential standards case (``TSL'') and the case with no new or amended
energy conservation standards. DOE calculated the national energy
consumption by multiplying the number of units (stock) of each
equipment (by vintage or age) by the unit energy consumption (also by
vintage). DOE calculated annual NES based on the difference in national
energy consumption for the no-new standards case and for each higher
efficiency standard case. DOE estimated energy consumption and savings
based on site energy and converted the electricity consumption and
savings to primary energy (i.e., the energy consumed by power plants to
generate site electricity) using annual conversion factors derived from
AEO2023. Cumulative energy savings are the sum of the NES for each year
over the timeframe of the analysis.
Use of higher-efficiency equipment is sometimes associated with a
direct rebound effect, which refers to an increase in utilization of
the equipment due to the increase in efficiency. For example, when a
consumer realizes that a more efficient fan used for cooling will lower
the electricity bill, that person may opt for increased comfort in the
building by using the equipment more, thereby negating a portion of the
energy savings. In commercial buildings, however, the person owning the
equipment (i.e., the building owner) is usually not the person
operating the equipment (i.e., the renter). Because the operator
usually does not own the equipment, that person will not have the
operating cost information necessary to influence how they operate the
equipment. Therefore, DOE believes that a rebound effect is unlikely to
occur in commercial buildings. In the industrial and agricultural
sectors, DOE believes that fans are likely to be operated whenever
needed for the required application, so a rebound effect is also
unlikely to occur in the industrial and agricultural sectors.
Therefore, DOE did not apply a rebound effect for fans and blowers.
DOE requests comment and data regarding the potential increase in
utilization of GFBs and ACFs due to any increase in efficiency.
In 2011, in response to the recommendations of a committee on
``Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards'' appointed by the National Academy of Sciences,
DOE announced its intention to use FFC measures of energy use and
greenhouse gas and other emissions in the national impact analyses and
emissions analyses included in future energy conservation standards
rulemakings. 76 FR 51281 (Aug. 18, 2011). After evaluating the
approaches discussed in the August 18, 2011 notice, DOE published a
statement of amended policy in which DOE explained its determination
that EIA's National Energy Modeling System (``NEMS'') is the most
appropriate tool for its FFC analysis and its intention to use NEMS for
that purpose. 77 FR 49701 (Aug. 17, 2012). NEMS is a public domain,
multi-sector, partial equilibrium model of the U.S. energy sector \106\
that EIA uses to prepare its
[[Page 3794]]
Annual Energy Outlook. The FFC factors incorporate losses in production
and delivery in the case of natural gas (including fugitive emissions)
and additional energy used to produce and deliver the various fuels
used by power plants. The approach used for deriving FFC measures of
energy use and emissions is described in appendix 10B of the NOPR TSD.
---------------------------------------------------------------------------
\106\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2009, DOE/EIA-0581(2009), October 2009.
Available at: www.eia.gov/forecasts/aeo/index.cfm (last accessed
April 4, 2023).
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3. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by consumers are (1) total annual installed cost, (2) total
annual operating costs (energy costs and repair and maintenance costs),
and (3) a discount factor to calculate the present value of costs and
savings. DOE calculates net savings each year as the difference between
the no-new-standards case and each standards case in terms of total
savings in operating costs versus total increases in installed costs.
DOE calculates operating cost savings over the lifetime of each
equipment shipped during the projection period.
As discussed in section IV.F.1 of this document, DOE developed
price trends for GFBs and ACFs based on historical PPI data. DOE
applied the same trends to project prices for each equipment class at
each considered efficiency level.
For GFBs, DOE applied constant equipment price trends. For ACFs,
DOE also applied a constant price trend except for ACFs at EL6 where a
declining price trend was used. By 2059, which is the end date of the
projection period, the average ACF price at EL6 is projected to drop 14
percent relative to 2022. DOE's projection of product prices is
described in appendix 10C of the NOPR TSD.
To evaluate the effect of uncertainty regarding the price trend
estimates, DOE investigated the impact of different product price
projections on the consumer NPV for the considered TSLs for GFBs and
ACFs. In addition to the default price trend, DOE considered two
product price sensitivity cases: (1) a high price decline case based on
historical PPI data and (2) a low price decline case based on the
AEO2023 ``deflator--industrial equipment'' forecast for GFBs and
historical PPI data for ACFs. The derivation of these price trends and
the results of these sensitivity cases are described in appendix 10C of
the NOPR TSD.
The energy cost savings are calculated using the estimated energy
savings in each year and the projected price of the appropriate form of
energy. To estimate energy prices in future years, DOE multiplied the
average regional energy prices by the projection of annual national-
average commercial and industrial energy price changes in the Reference
case from AEO2023, which has an end year of 2050. To estimate price
trends after 2050, the 2050 price was used for all years. As part of
the NIA, DOE also analyzed scenarios that used inputs from variants of
the AEO2023 Reference case that have lower and higher economic growth.
Those cases have lower and higher energy price trends compared to the
Reference case. NIA results based on these cases are presented in
appendix 10C of the NOPR TSD.
In addition, for ACFs, the NPV calculation also includes the total
repair costs which are calculated based on the outputs from the life-
cycle analysis.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPR, DOE estimated the NPV of consumer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (``OMB'') to Federal agencies on the development of regulatory
analysis.\107\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
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\107\ Office of Management and Budget. Circular A-4: Regulatory
Analysis. September 17, 2003. Section E. Available at https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf.
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I. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended energy
conservation standards on consumers, DOE evaluates the impact on
identifiable subgroups of consumers that may be disproportionately
affected by a new or amended national standard. The purpose of a
subgroup analysis is to determine the extent of any such
disproportional impacts. DOE evaluates impacts on particular subgroups
of consumers by analyzing the LCC impacts and PBP for those particular
consumers from alternative standard levels. For this NOPR, DOE analyzed
the impacts of the considered standard levels on small businesses. DOE
used the LCC and PBP spreadsheet model to estimate the impacts of the
considered efficiency levels on these subgroups, and used inputs
specific to that subgroup. Chapter 11 in the NOPR TSD describes the
consumer subgroup analysis.
J. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate the financial impacts of new
energy conservation standards on manufacturers of fans and blowers and
to estimate the potential impacts of such standards on employment and
manufacturing capacity. The MIA has both quantitative and qualitative
aspects and includes analyses of projected industry cash flows, the
INPV, investments in research and development (``R&D'') and
manufacturing capital, and domestic manufacturing employment.
Additionally, the MIA seeks to determine how new energy conservation
standards might affect manufacturing employment, capacity, and
competition, as well as how standards contribute to overall regulatory
burden. Finally, the MIA serves to identify any disproportionate
impacts on manufacturer subgroups, including small business
manufacturers.
The quantitative part of the MIA primarily relies on the GRIM, an
industry cash flow model with inputs specific to this rulemaking. The
key GRIM inputs include data on the industry cost structure, unit
production costs, equipment shipments, manufacturer markups, and
investments in R&D and manufacturing capital required to produce
compliant equipment. The key GRIM outputs are the INPV, which is the
sum of industry annual cash flows over the analysis period, discounted
using the industry-weighted average cost of capital, and the impact on
domestic manufacturing employment. The model uses standard accounting
principles to estimate the impacts of new energy conservation standards
on a given industry by comparing changes in INPV and domestic
manufacturing employment between a no-new-standards case and the
various standards cases (i.e., TSLs). To capture the uncertainty
relating to manufacturer pricing strategies following new standards,
the GRIM estimates a range of possible impacts under different markup
scenarios.
The qualitative part of the MIA addresses manufacturer
characteristics and market trends. Specifically, the MIA
[[Page 3795]]
considers such factors as a potential standard's impact on
manufacturing capacity, competition within the industry, the cumulative
impact of other DOE and non-DOE regulations, and impacts on
manufacturer subgroups. The complete MIA is outlined in chapter 12 of
the NOPR TSD.
DOE conducted the MIA for this rulemaking in three phases. In Phase
1 of the MIA, DOE prepared a profile of the fan and blower
manufacturing industry based on the market and technology assessment,
preliminary manufacturer interviews, and publicly available
information. This included a top-down analysis of fan and blower
manufacturers that DOE used to derive preliminary financial inputs for
the GRIM (e.g., revenues; materials, labor, overhead, and depreciation
expenses; selling, general, and administrative expenses (``SG&A''); and
R&D expenses). DOE also used public sources of information to further
calibrate its initial characterization of the fan and blower
manufacturing industry, including company filings of form 10-K from the
SEC,\108\ corporate annual reports, the U.S. Census Bureau's Economic
Census,\109\ and reports from D&B Hoovers.\110\
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\108\ See www.sec.gov/edgar.
\109\ See www.census.gov/programs-surveys/asm/data/tables.html.
\110\ See app.avention.com.
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In Phase 2 of the MIA, DOE prepared a framework industry cash flow
analysis to quantify the potential impacts of new energy conservation
standards. The GRIM uses several factors to determine a series of
annual cash flows starting with the announcement of the standard and
extending over a 30-year period following the compliance date of the
standard. These factors include annual expected revenues, costs of
sales, SG&A and R&D expenses, taxes, and capital expenditures. In
general, energy conservation standards can affect manufacturer cash
flow in three distinct ways: (1) creating a need for increased
investment, (2) raising production costs per unit, and (3) altering
revenue due to higher per-unit prices and changes in sales volumes.
In addition, during Phase 2, DOE developed interview guides to
distribute to manufacturers of fans and blowers in order to develop
other key GRIM inputs, including capital and product conversion costs,
and to gather additional information on the anticipated effects of
energy conservation standards on revenues, direct employment, capital
assets, industry competitiveness, and subgroup impacts.
In Phase 3 of the MIA, DOE conducted structured, detailed
interviews with representative manufacturers. During these interviews,
DOE discussed engineering, manufacturing, procurement, and financial
topics to validate assumptions used in the GRIM and to identify key
issues or concerns. See section IV.J.3 of this document for a
description of the key issues raised by manufacturers during the
interviews. As part of Phase 3, DOE also evaluated subgroups of
manufacturers that may be disproportionately impacted by new energy
conservation standards or that may not be accurately represented by the
average cost assumptions used to develop the industry cash flow
analysis. Such manufacturer subgroups may include small business
manufacturers, low-volume manufacturers (``LVMs''), niche players, and/
or manufacturers exhibiting a cost structure that largely differs from
the industry average. DOE identified one subgroup for a separate impact
analysis: small business manufacturers. The small business subgroup is
discussed in section VI.B, ``Review under the Regulatory Flexibility
Act'' and in chapter 12 of the NOPR TSD.
2. Government Regulatory Impact Model and Key Inputs
DOE uses the GRIM to quantify the changes in cash flow due to new
energy conservation standards that result in a higher or lower industry
value. The GRIM uses a standard, annual discounted cash flow analysis
that incorporates manufacturer costs, markups, shipments, and industry
financial information as inputs. The GRIM models changes in costs,
distribution of shipments, investments, and manufacturer margins that
could result from new energy conservation standards. The GRIM
spreadsheet uses the inputs to arrive at a series of annual cash flows,
beginning in 2024 (the base year of the analysis) and continuing to
2059. DOE calculated INPVs by summing the stream of annual discounted
cash flows during this period. For manufacturers of fans and blowers,
DOE used a real discount rate of 11.4 percent, which was derived from
industry financials and then modified according to feedback received
during manufacturer interviews.
The GRIM calculates cash flows using standard accounting principles
and compares changes in INPV between the no-new-standards case and each
standards case. The difference in INPV between the no-new-standards
case and a standards case represents the financial impact of the new
energy conservation standards on manufacturers. As discussed
previously, DOE developed critical GRIM inputs using a number of
sources, including publicly available data, results of the engineering
analysis, and information gathered from industry stakeholders during
the course of manufacturer interviews and subsequent Working Group
meetings. The GRIM results are presented in section V.B.2. Additional
details about the GRIM, the discount rate, and other financial
parameters can be found in chapter 12 of the NOPR TSD.
a. Manufacturer Production Costs
Manufacturing more efficient equipment is typically more expensive
than manufacturing baseline equipment due to the use of more complex
components, which are typically more costly than baseline components.
The changes in the MPCs of covered equipment can affect the revenues,
gross margins, and cash flow of the industry.
For GFBs, DOE developed baseline MSP versus diameter curves and
incremental costs for each design option for each equipment class. DOE
used these correlations to estimate the MSP at each EL for each
equipment class at all nominal impeller diameters. As such, each
equipment class has multiple MSP versus FEI curves representing the
range of impeller diameters that exist on the market. For ACFs, DOE
developed curves for each representative unit. The methodology for
developing the curves started with determining the efficiency for
baseline equipment and the MPCs for this equipment. Above the baseline,
DOE implemented design options until all available design options were
employed (i.e., at the max-tech level).
For a complete description of the MPCs, see chapter 5 of the NOPR
TSD.
b. Shipments Projections
The GRIM estimates manufacturer revenues based on total unit
shipment projections and the distribution of those shipments by
efficiency level. Changes in sales volumes and efficiency mix over time
can significantly affect manufacturer finances. For this analysis, the
GRIM uses the NIA's annual shipment projections derived from the
shipments analysis from 2024 (the base year) to 2059 (the end year of
the analysis period). See chapter 9 of the NOPR TSD for additional
details.
c. Product and Capital Conversion Costs
New energy conservation standards could cause manufacturers to
incur conversion costs to bring their production facilities and
equipment designs into compliance. DOE evaluated the level of
conversion-related
[[Page 3796]]
expenditures that would be needed to comply with each considered
efficiency level in each equipment class. For the MIA, DOE classified
these conversion costs into two major groups: (1) product conversion
costs; and (2) capital conversion costs. Product conversion costs are
investments in research, development, testing, marketing, and other
non-capitalized costs necessary to make equipment designs comply with
new energy conservation standards. Capital conversion costs are
investments in property, plant, and equipment necessary to adapt or
change existing production facilities such that new compliant equipment
designs can be fabricated and assembled.
In response to the October 2022 NODA, AMCA commented that DOE
should conduct interviews with individual manufacturers to gather
information regarding potential conversion costs for fan and blower
manufacturers. (AMCA, No. 132 at p. 12) DOE conducted manufacturer
interviews with several interested parties, including several fan and
blower manufacturers, after the publication of the October 2022 NODA
and prior to conducting this NOPR analysis. The results and methodology
for estimating conversion costs are described in this section.
DOE used a bottom-up cost estimate to arrive at a total product
conversion cost at each EL for all equipment classes. DOE first
estimated the number of unique basic models for each equipment class
and at each EL using the AMCA sales database for GFBs and the updated
ACF database for ACFs. Next, DOE estimated the percentage of models
that would not meet each analyzed EL based on information from the
appropriate database. DOE also estimated the percentage of failing
models that are assumed to be redesigned at each analyzed EL. DOE then
estimated the amount of engineering time needed to redesign and test a
single non-compliant basic model into a compliant model and the time
necessary to conduct additional air, sound, and certification testing
once the model is redesigned. DOE used data from the U.S. Bureau of
Labor Statistics \111\ (``BLS'') to estimate the total hourly employer
compensation to conduct the redesign and to conduct testing. DOE based
the number of hours associated with a per model redesign and per model
testing estimates on information received during manufacturer
interviews. DOE estimated that longer per model redesign engineering
hours would be required to achieve higher ELs, since more engineering
resources would be required to achieve higher ELs. However, DOE assumed
the same per model testing cost for all ELs, since DOE did not assume
the testing cost will increase at higher ELs. Lastly, DOE multiplied
the per model redesign (for each EL) and per model testing costs by the
number models that are estimated to be redesigned at each EL.
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\111\ See www.bls.gov/oes/current/oes_stru.htm and www.bls.gov/bls/news-release/ecec.htm#current.
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DOE estimated the capital conversion costs based on information
received during manufacturer interviews. During manufacturer
interviews, manufacturers provided estimates on the percentage of total
conversion costs that would be associated with the purchasing on
equipment and machinery (capital conversion costs) and the percentage
of total conversion costs that would be associated with engineering
resources to conduct redesigns and testing (product conversion costs).
In addition to assuming increased product costs at higher ELs, DOE also
assumed that the ratio of product conversion costs to capital
conversion costs would decrease at higher ELs (i.e., higher ELs are
expected to have higher capital conversion costs since manufacturers
would be expected to increase investments in new tooling and
potentially different production processes). In sum, DOE used these
percentage estimates provided during manufacturer interviews and the
product conversion cost estimates previously described to estimate the
total capital conversion costs for each equipment class at each
analyzed EL.
CA IOUs stated that some ACF manufacturers purchase the impellors
that they use rather than design and manufacture them in-house.
Therefore, CA IOUs stated purchasing more efficient impeller designs
may be possible without significant design and capital costs. (CA IOUs,
No. 127 at p.3) DOE conducted manufacturer interviews with a variety of
ACF manufacturers. The cost estimates included in this analysis assume
that ACF manufacturers produce their impellors in-house. While some ACF
manufacturers might purchase impellors from another company, whatever
company that is manufacturing the more efficient impellors is will
incur additional product and capital conversion costs and those costs
will likely be passed on to their customers. Section IV.J.2.d discusses
how an increase in product and capital conversion costs (regardless of
if an impellor manufacturer or an ACF manufacturer incurs them) could
result in an increased ACF MSP that is incorporated into all down-
stream and consumer analyses.
In general, DOE assumes all conversion-related investments occur
between the year of publication of the final rule and the year by which
manufacturers must comply with the new standard. The conversion cost
figures used in the GRIM can be found in section V.B.2 of this
document. For additional information on the estimated capital and
product conversion costs, see chapter 12 of the NOPR TSD.
d. Markup Scenarios
MSPs include direct manufacturing production costs (i.e., labor,
materials, and overhead estimated in DOE's MPCs) and all non-production
costs (i.e., SG&A, R&D, and interest), along with profit. To calculate
the MSPs in the GRIM, DOE applied non-production cost markups to the
MPCs estimated in the engineering analysis for ACFs at each equipment
class and efficiency level. For GFBs, the engineering analysis
estimated the MSPs. Therefore, the MIA did not calculate the MSPs for
GFBs using the MPCs. Instead, the MIA estimated the MPC by dividing the
MSPs, which were estimated in the engineering analysis, by a
manufacturer markup. For GFBs, DOE estimated a manufacturer markup of
1.35 for all equipment classes in the no-new-standards case. This
corresponds to a manufacturer gross margin percentage of approximately
25.9 percent. For ACFs, DOE estimated a manufacturer markup of 1.50 for
all equipment classes in the no-new-standards case. This corresponds to
a manufacturer gross margin percentage of approximately 33.3 percent.
DOE estimated these manufacturers markups based on information obtained
during manufacturer interviews. Modifying these manufacturer markups in
the standards case yields different sets of impacts on manufacturers.
For the MIA, DOE modeled two standards-case markup scenarios to
represent uncertainty regarding the potential impacts on prices and
profitability for manufacturers following the implementation of new
energy conservation standards: (1) a conversion cost recovery markup
scenario; and (2) a preservation of operating profit markup scenario.
These scenarios lead to different manufacturer markup values that, when
applied to the MPCs, result in varying revenue and cash flow impacts.
Under the conversion cost recovery markup scenario, DOE modeled a
scenario in which manufacturers increase their markups in response to
new energy conservation standards. For
[[Page 3797]]
ELs that DOE's engineering analysis assumed would require an
aerodynamic redesign, the engineering analysis assumed there is no
increase in the MPCs (for the ELs that are assumed would require an
aerodynamic redesign). However, DOE did assume that fan and blower
manufacturers will incur conversion costs to redesign non-compliant
models. Therefore, DOE modeled a manufacturer markup scenario in which
fan and blower manufacturers attempt to recover the investments they
must make to conduct these aerodynamic redesigns through an increase in
their manufacturer markup. Therefore, in the standards cases, the
manufacturer markup of models that would need to be re-designed is
larger than the manufacturer markup used in the no-new-standards case.
DOE calibrated these manufacturer markups, in the standards case
conversion cost recovery scenario, for each equipment class at each EL
to cause the manufacturer INPV in the standards cases to be
approximately equal to the manufacturer INPV in the no-new-standards
case. In this markup scenario, manufacturers earn additional revenue in
the standards cases after the compliance date that offsets the
conversion costs that were incurred prior to the compliance date. This
represents the upper-bound of manufacturer profitability, as in this
manufacturer markup scenario as measured by INPV, fan and blower
manufacturers are able to fully recover their conversion costs by the
end of the 30-year analysis period.
Under the preservation of operating profit markup scenario, DOE
modeled a markup scenario where manufacturers are not able to increase
their per-unit operating profit in proportion to increases in MPCs.
Under this scenario, as the MPCs increase, manufacturers reduce their
markups (on a percentage basis) to a level that maintains the no-new-
standards operating profit (in absolute dollars). The implicit
assumption behind this manufacturer markup scenario is that the
industry can only maintain its operating profit in absolute dollars
after compliance with new standards. Therefore, the percentage of the
operating margin is reduced between the no-new-standards case and the
analyzed standards cases. DOE adjusted the manufacturer markups in the
GRIM at each TSL to yield approximately the same earnings before
interest and taxes in the standards case as in the no-new-standards
case. This manufacturer markup scenario represents the lower bound to
industry profitability under new energy conservation standards.
A comparison of industry financial impacts under the two
manufacturer markup scenarios is presented in section V.B.2.a of this
document.
3. Manufacturer Interviews
DOE interviewed a variety of fan and blower manufacturers prior to
conducting this NOPR analysis. During these interviews, DOE asked
manufacturers to describe their major concerns regarding this
rulemaking. The following section highlights manufacturer concerns that
helped inform the projected potential impacts of a new standard on the
industry. Manufacturer interviews are conducted under non-disclosure
agreements (``NDAs''), so DOE does not document these discussions in
the same way that it does public comments in the comment summaries and
DOE's responses throughout the rest of this document.
Embedded Fans
Several fan and blower manufacturers stated that they are concerned
that including fans and blowers that are embedded in other products or
equipment already regulated by DOE creates redundant regulations.
Additionally, manufacturers stated that the electricity used by the fan
or blower in these systems is a relatively insignificant portion of the
energy consumed by the entire system. Lastly, manufacturers stated that
increasing the efficiency of a fan or blower used in a product or
equipment already regulated by DOE could limit the effectiveness of a
future energy conservation standard on the performance of those
products or equipment covered by DOE.
DOE is proposing to exclude fans and blowers that are embedded in
specific types of equipment. Table III-1 lists the embedded fans and
blowers that are excluded from the scope of this energy conservation
standards rulemaking.
Testing Costs and Burden
Several fan and blower manufacturers stated that a concern that
compliance with energy conservation standards would require fan and
blower manufacturers to test all covered fans and blowers.
Manufacturers specifically are concerned that the legacy testing data
that they have already conducted for the AMCA certification testing
program would need to be re-tested to demonstrate compliance with a DOE
energy conservation standard. As stated in the May 2023 TP Final Rule,
DOE understands that manufacturers of fans and blowers likely have
historical test data which were developed with methods consistent with
the DOE test procedure adopted in the May 2023 Final Rule, and does not
expect manufacturers to regenerate all of the historical test data
unless the rating resulting from the historical methods would no longer
be valid. 88 FR 27312, 27378.
Additionally, manufacturers were concerned that requiring a test
sample of two fans or blowers would be overly burdensome for
manufacturers to comply with an energy conservation standard. As stated
in the May 2023 TP Final Rule ``DOE believe it is appropriate to allow
a minimum of one unit for fans and blowers other than air circulating
fans'' to be tested to comply with any DOE energy conservation
standard. 88 FR 27312, 27378.
Lastly, some manufacturers were concerned that if DOE did not allow
the use of an alternative energy determination method (``AEDM'') to
determine fan performance, manufacturers would have to physically test
all covered fans and blowers. Manufacturers stated that physically
testing every fan and blower would place a larger and costly testing
burden on manufacturers. As stated in the May 2023 TP Final Rule, ``DOE
allows the use of an AEDM in lieu of testing to determine fan
performance, which would mitigate the potential cost associated with
having to physically test units.'' 88 FR 27312, 27372.
4. Discussion of MIA Comments
AHRI stated that for end-use products (i.e., a product or equipment
that has a fan or blower embedded in it) testing must take place
following internal component swaps or cabinet redesigns. This testing
could include seismic and wind load testing for HVAC equipment
installed exterior to the building; electric heat, safety, refrigerant,
and sound testing for heating equipment; and transportation, vibration,
and sound testing for most end-use products. AHRI stated that testing
lab availability is limited at this time, given the wide-ranging
changes in refrigerant and safety standards requirements, and standards
that result in a redesign to accommodate a new fan will impact
virtually every model of HVACR product on the market. (AHRI, No. 130 at
pp. 5-6) DOE acknowledges that end-use products may have to be re-test
if the current fan that they use does not meet the adopted energy
conservation standards. However, DOE's engineering analysis primarily
examined replacement fans and blowers with the same diameter and would
not require a cabinet redesign for an end-use product.
[[Page 3798]]
AHRI stated that there is a significant monetary impact for OEMs
for a fan swap, as a significant amount of re-testing and potential re-
certification would need to be conducted for a fan swap, even if the
size of the cabinet does not change. AHRI stated that based on a review
of their AHRI Certification Program they identified approximately 6,000
basic models that have a covered fan embedded in these end-use
products. AHRI continued by stating they estimate it would cost
approximately $300,000 for each end-use product basic model that would
be required to incorporate a new fan if the existing fan used in their
end-use product does not comply with DOE's energy conservation
standards for that fan. (AHRI, No. 130 at p. 6-7) DOE acknowledges that
OEMs may incur re-testing and re-certification costs if the fan used in
their equipment does not meet the adopted energy conservation standard
for fans. The MIA for this rulemaking specifically examines the
conversion costs that fan and blower manufacturers would incur due to
the analyzed energy conservation standards for fans and blowers in
comparison to the revenue and free cash fan and blower manufacturers
receive. The OEM testing and certification costs were not included in
the MIA, and neither were the OEM revenues and free cash flows, as
these costs and revenue are not specific to fan and blower
manufacturers.
MIAQ also stated that redesign of the end-use product to
accommodate a new fan will result in retesting and possible
recertification and model number changes for end-use products, which
will be a massive, costly, and time-consuming undertaking (and could
even cause a disruption in the market) as there would be changes to
electrical, physical, or functional characteristics of the end-use
product that affect energy consumption/efficiency. (MIAQ, No. 124 at
pp. 2-3) DOE is proposing to exclude fans that are embedded in
commercial HVAC equipment that is already covered by DOE energy
conservation standards as well as a variety of other products. The full
list of embedded fans proposed for exclusion from the scope of this
energy conservation standards rulemaking can be found in Table III-1.
DOE requests comment on the number of end-use product (i.e., a
product or equipment that has a fan or blower embedded in it) basic
models that would not be excluded by the list of products or equipment
listed in Table III-1.
MIAQ and AHRI stated that it was not realistic to expect
manufacturers to comply with any energy conservation standards within
180 days. (MIAQ, No. 124 at p. 2-3; AHRI, No. 130 at p. 5) DOE notes
that the May 2023 TP Final Rule stated that beginning 180 days after
the publication of the May 2023 TP Final Rule, any representations made
with respect to energy use or efficiency of fans or blowers must be
made based on testing in accordance with the May 2023 TP Final Rule.
Neither the May 2023 TP Final Rule nor this NOPR requires that fan and
blower manufacturers meet a minimum energy conservation standard 180
days after the publication of the May 2023 TP Final Rule. Compliance
with any energy conservation standards would not be required until 5
years after publication of the energy conservation standard final rule.
AHRI expressed concern about unfair advantage given to imported
HVAC products that may not need to comply with components regulations.
AHRI stated that imported HVAC products with embedded fans are excluded
from the fan and blower energy conservation standard, but fans
assembled into similar equipment manufactured domestically would be
subject to DOE energy conservation standards (AHRI, No. 130, at p. 4)
DOE is proposing to require fans and blowers that are imported in HVAC
products to comply with the energy conservation standards established
in this rulemaking as long as those products or equipment are not
listed in Table III-1. This is the same requirement that applies to
fans and blowers that are assembled into the same equipment
manufactured domestically.
K. Emissions Analysis
The emissions analysis consists of two components. The first
component estimates the effect of potential energy conservation
standards on power sector and site (where applicable) combustion
emissions of CO2, NOX, SO2, and Hg.
The second component estimates the impacts of potential standards on
emissions of two additional greenhouse gases, CH4 and
N2O, as well as the reductions to emissions of other gases
due to ``upstream'' activities in the fuel production chain. These
upstream activities comprise extracting, processing, and transporting
fuels to the site of combustion.
The analysis of electric power sector emissions of CO2,
NOX, SO2, and Hg uses emissions factors intended
to represent the marginal impacts of the change in electricity
consumption associated with amended or new standards. The methodology
is based on results published for the AEO, including a set of side
cases that implement a variety of efficiency-related policies. The
methodology is described in appendix 13A of the NOPR TSD. The analysis
presented in this notice uses projections from AEO2023. Power sector
emissions of CH4 and N2O from fuel combustion are
estimated using Emission Factors for Greenhouse Gas Inventories
published by the Environmental Protection Agency (EPA).\112\
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\112\ Available at: www.epa.gov/sites/production/files/2021-04/documents/emission-factors_apr2021.pdf (last accessed July 12,
2021).
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FFC upstream emissions, which include emissions from fuel
combustion during extraction, processing, and transportation of fuels,
and ``fugitive'' emissions (direct leakage to the atmosphere) of
CH4 and CO2, are estimated based on the
methodology described in chapter 15 of the NOPR TSD.
The emissions intensity factors are expressed in terms of physical
units per MWh or MMBtu of site energy savings. For power sector
emissions, specific emissions intensity factors are calculated by
sector and end use. Total emissions reductions are estimated using the
energy savings calculated in the national impact analysis.
1. Air Quality Regulations Incorporated in DOE's Analysis
DOE's no-new-standards case for the electric power sector reflects
the AEO, which incorporates the projected impacts of existing air
quality regulations on emissions. AEO2023 generally represents current
legislation and environmental regulations, including recent government
actions, that were in place at the time of preparation of AEO2023,
including the emissions control programs discussed in the following
paragraphs.\113\
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\113\ For further information, see the Assumptions to AEO2023
report that sets forth the major assumptions used to generate the
projections in the Annual Energy Outlook. Available at: www.eia.gov/outlooks/aeo/assumptions/ (last accessed February 6, 2023).
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SO2 emissions from affected electric generating units
(``EGUs'') are subject to nationwide and regional emissions cap-and-
trade programs. Title IV of the Clean Air Act sets an annual emissions
cap on SO2 for affected EGUs in the 48 contiguous States and
the District of Columbia (DC). (42 U.S.C. 7651 et seq.) SO2
emissions from numerous States in the eastern half of the United States
are also limited under the Cross-State Air Pollution Rule (``CSAPR'').
76 FR 48208 (Aug. 8, 2011). CSAPR requires these States to reduce
certain emissions, including annual SO2 emissions, and
[[Page 3799]]
went into effect as of January 1, 2015.\114\ AEO2023 incorporates
implementation of CSAPR, including the update to the CSAPR ozone season
program emission budgets and target dates issued in 2016. 81 FR 74504
(Oct. 26, 2016). Compliance with CSAPR is flexible among EGUs and is
enforced through the use of tradable emissions allowances. Under
existing EPA regulations, any excess SO2 emissions
allowances resulting from the lower electricity demand caused by the
adoption of an efficiency standard could be used to permit offsetting
increases in SO2 emissions by another regulated EGU.
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\114\ CSAPR requires States to address annual emissions of
SO2 and NOX, precursors to the formation of
fine particulate matter (PM2.5) pollution, in order to
address the interstate transport of pollution with respect to the
1997 and 2006 PM2.5 National Ambient Air Quality
Standards (``NAAQS''). CSAPR also requires certain States to address
the ozone season (May-September) emissions of NOX, a
precursor to the formation of ozone pollution, in order to address
the interstate transport of ozone pollution with respect to the 1997
ozone NAAQS. 76 FR 48208 (Aug. 8, 2011). EPA subsequently issued a
supplemental rule that included an additional five States in the
CSAPR ozone season program; 76 FR 80760 (Dec. 27, 2011)
(Supplemental Rule).
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However, beginning in 2016, SO2 emissions began to fall
as a result of the Mercury and Air Toxics Standards (``MATS'') for
power plants. 77 FR 9304 (Feb. 16, 2012). In the MATS final rule, EPA
established a standard for hydrogen chloride as a surrogate for acid
gas hazardous air pollutants (``HAP''), and also established a standard
for SO2 (a non-HAP acid gas) as an alternative equivalent
surrogate standard for acid gas HAP. The same controls are used to
reduce HAP and non-HAP acid gas; thus, SO2 emissions are
being reduced as a result of the control technologies installed on
coal-fired power plants to comply with the MATS requirements for acid
gas. In order to continue operating, coal power plants must have either
flue gas desulfurization or dry sorbent injection systems installed.
Both technologies, which are used to reduce acid gas emissions, also
reduce SO2 emissions. Because of the emissions reductions
under the MATS, it is unlikely that excess SO2 emissions
allowances resulting from the lower electricity demand would be needed
or used to permit offsetting increases in SO2 emissions by
another regulated EGU. Therefore, energy conservation standards that
decrease electricity generation would generally reduce SO2
emissions. DOE estimated SO2 emissions reduction using
emissions factors based on AEO2023.
CSAPR also established limits on NOX emissions for
numerous States in the eastern half of the United States. Energy
conservation standards would have little effect on NOX
emissions in those States covered by CSAPR emissions limits if excess
NOX emissions allowances resulting from the lower
electricity demand could be used to permit offsetting increases in
NOX emissions from other EGUs. In such case, NOX
emissions would remain near the limit even if electricity generation
goes down. A different case could possibly result, depending on the
configuration of the power sector in the different regions and the need
for allowances, such that NOX emissions might not remain at
the limit in the case of lower electricity demand. In this case, energy
conservation standards might reduce NOX emissions in covered
States. Despite this possibility, DOE has chosen to be conservative in
its analysis and has maintained the assumption that standards will not
reduce NOX emissions in States covered by CSAPR. Energy
conservation standards would be expected to reduce NOX
emissions in the States not covered by CSAPR. DOE used AEO2023 data to
derive NOX emissions factors for the group of States not
covered by CSAPR.
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would be expected to slightly reduce Hg emissions. DOE
estimated mercury emissions reduction using emissions factors based on
AEO2023, which incorporates the MATS.
L. Monetizing Emissions Impacts
As part of the development of this proposed rule, for the purpose
of complying with the requirements of Executive Order 12866, DOE
considered the estimated monetary benefits from the reduced emissions
of CO2, CH4, N2O, NOX, and
SO2 that are expected to result from each of the TSLs
considered. In order to make this calculation analogous to the
calculation of the NPV of consumer benefit, DOE considered the reduced
emissions expected to result over the lifetime of products shipped in
the projection period for each TSL. This section summarizes the basis
for the values used for monetizing the emissions benefits and presents
the values considered in this NOPR.
To monetize the benefits of reducing GHG emissions, this analysis
uses the interim estimates presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published in February 2021 by the IWG.
1. Monetization of Greenhouse Gas Emissions
DOE estimates the monetized benefits of the reductions in emissions
of CO2, CH4, and N2O by using a
measure of the SC of each pollutant (e.g., SC-CO2). These
estimates represent the monetary value of the net harm to society
associated with a marginal increase in emissions of these pollutants in
a given year, or the benefit of avoiding that increase. These estimates
are intended to include (but are not limited to) climate-change-related
changes in net agricultural productivity, human health, property
damages from increased flood risk, disruption of energy systems, risk
of conflict, environmental migration, and the value of ecosystem
services.
DOE exercises its own judgment in presenting monetized climate
benefits as recommended by applicable Executive orders, and DOE would
reach the same conclusion presented in this proposed rulemaking in the
absence of the social cost of greenhouse gases. That is, the social
costs of greenhouse gases, whether measured using the February 2021
interim estimates presented by the Interagency Working Group on the
Social Cost of Greenhouse Gases or by another means, did not affect the
rule ultimately proposed by DOE.
DOE estimated the global social benefits of CO2,
CH4, and N2O reductions using SC-GHG values that
were based on the interim values presented in the Technical Support
Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim
Estimates under Executive Order 13990, published in February 2021 by
the IWG. The SC-GHGs is the monetary value of the net harm to society
associated with a marginal increase in emissions in a given year, or
the benefit of avoiding that increase. In principle, SC-GHGs includes
the value of all climate change impacts, including (but not limited to)
changes in net agricultural productivity, human health effects,
property damage from increased flood risk and natural disasters,
disruption of energy systems, risk of conflict, environmental
migration, and the value of ecosystem services. The SC-GHGs therefore
reflects the societal value of reducing emissions of the gas in
question by one metric ton. The SC-GHGs is the theoretically
appropriate value to use in conducting benefit-cost analyses of
policies that affect CO2, N2O and CH4
emissions. As a member of the IWG involved in the development of the
February 2021 SC-GHG TSD, DOE agrees that the interim SC-GHG estimates
represent the most appropriate estimate of the SC-GHG until revised
[[Page 3800]]
estimates have been developed reflecting the latest, peer-reviewed
science.
The SC-GHGs estimates presented here were developed over many
years, using transparent process, peer-reviewed methodologies, the best
science available at the time of that process, and with input from the
public. Specifically, in 2009, the IWG, which included the DOE and
other executive branch agencies and offices, was established to ensure
that agencies were using the best available science and to promote
consistency in the social cost of carbon (SC-CO2) values
used across agencies. The IWG published SC-CO2 estimates in
2010 that were developed from an ensemble of three widely cited
integrated assessment models (IAMs) that estimate global climate
damages using highly aggregated representations of climate processes
and the global economy combined into a single modeling framework. The
three IAMs were run using a common set of input assumptions in each
model for future population, economic, and CO2 emissions
growth, as well as equilibrium climate sensitivity--a measure of the
globally averaged temperature response to increased atmospheric
CO2 concentrations. These estimates were updated in 2013
based on new versions of each IAM. In August 2016, the IWG published
estimates of the social cost of methane (SC-CH4) and nitrous
oxide (SC-N2O) using methodologies that are consistent with
the methodology underlying the SC-CO2 estimates. The
modeling approach that extends the IWG SC-CO2 methodology to
non-CO2 GHGs has undergone multiple stages of peer review.
The SC-CH4 and SC-N2O estimates were developed by
Marten et al.\115\ and underwent a standard double-blind peer review
process prior to journal publication. In 2015, as part of the response
to public comments received to a 2013 solicitation for comments on the
SC-CO2 estimates, the IWG announced a National Academies of
Sciences, Engineering, and Medicine review of the SC-CO2
estimates to offer advice on how to approach future updates to ensure
that the estimates continue to reflect the best available science and
methodologies. In January 2017, the National Academies released their
final report, Valuing Climate Damages: Updating Estimation of the
Social Cost of Carbon Dioxide, and recommended specific criteria for
future updates to the SC-CO2 estimates, a modeling framework
to satisfy the specified criteria, and both near-term updates and
longer-term research needs pertaining to various components of the
estimation process (National Academies, 2017).\116\ Shortly thereafter,
in March 2017, President Trump issued Executive Order 13783, which
disbanded the IWG, withdrew the previous TSDs, and directed agencies to
ensure SC-CO2 estimates used in regulatory analyses are
consistent with the guidance contained in OMB's Circular A-4,
``including with respect to the consideration of domestic versus
international impacts and the consideration of appropriate discount
rates'' (E.O. 13783, Section 5(c)). Benefit-cost analyses following
E.O. 13783 used SC-GHG estimates that attempted to focus on the U.S.-
specific share of climate change damages as estimated by the models and
were calculated using two discount rates recommended by Circular A-4, 3
percent and 7 percent. All other methodological decisions and model
versions used in SC-GHG calculations remained the same as those used by
the IWG in 2010 and 2013, respectively.
---------------------------------------------------------------------------
\115\ Marten, A.L., E.A. Kopits, C.W. Griffiths, S.C. Newbold,
and A. Wolverton. Incremental CH4 and N2O mitigation benefits
consistent with the US Government's SC-CO2 estimates.
Climate Policy. 2015. 15(2): pp. 272-298.
\116\ National Academies of Sciences, Engineering, and Medicine.
Valuing Climate Damages: Updating Estimation of the Social Cost of
Carbon Dioxide. 2017. The National Academies Press: Washington, DC.
---------------------------------------------------------------------------
On January 20, 2021, President Biden issued Executive Order 13990,
which re-established the IWG and directed it to ensure that the U.S.
Government's estimates of the social cost of carbon and other
greenhouse gases reflect the best available science and the
recommendations of the National Academies (2017). The IWG was tasked
with first reviewing the SC-GHG estimates currently used in Federal
analyses and publishing interim estimates within 30 days of the E.O.
that reflect the full impact of GHG emissions, including by taking
global damages into account. The interim SC-GHG estimates published in
February 2021 are used here to estimate the climate benefits for this
proposed rulemaking. The E.O. instructs the IWG to update the interim
SC-GHG estimates by January 2022 taking into consideration the advice
of the National Academies of Science, Engineering, and Medicine as
reported in Valuing Climate Damages: Updating Estimation of the Social
Cost of Carbon Dioxide (2017) and other recent scientific literature.
The February 2021 SC-GHG TSD provides a complete discussion of the
IWG's initial review conducted under E.O. 13990. In particular, the IWG
found that the SC-GHG estimates used under E.O. 13783 fail to reflect
the full impact of GHG emissions in multiple ways.
First, the IWG found that the SC-GHG estimates used under E.O.
13783 fail to fully capture many climate impacts that affect the
welfare of U.S. citizens and residents, and those impacts are better
reflected by global measures of the SC-GHG. Examples of omitted effects
from the E.O. 13783 estimates include direct effects on U.S. citizens,
assets, and investments located abroad; supply chains, U.S. military
assets and interests abroad, and tourism; and spillover pathways such
as economic and political destabilization and global migration that can
lead to adverse impacts on U.S. national security, public health, and
humanitarian concerns. In addition, assessing the benefits of U.S. GHG
mitigation activities requires consideration of how those actions may
affect mitigation activities by other countries, as those international
mitigation actions will provide a benefit to U.S. citizens and
residents by mitigating climate impacts that affect U.S. citizens and
residents. A wide range of scientific and economic experts have
emphasized the issue of reciprocity as support for considering global
damages of GHG emissions. If the United States does not consider
impacts on other countries, it is difficult to convince other countries
to consider the impacts of their emissions on the United States. The
only way to achieve an efficient allocation of resources for emissions
reduction on a global basis--and so benefit the United States and its
citizens--is for all countries to base their policies on global
estimates of damages. As a member of the IWG involved in the
development of the February 2021 SC-GHG TSD, DOE agrees with this
assessment and, therefore, in this proposed rule DOE centers attention
on a global measure of SC-GHG. This approach is the same as that taken
in DOE regulatory analyses from 2012 through 2016. A robust estimate of
climate damages that accrue only to U.S. citizens and residents does
not currently exist in the literature. As explained in the February
2021 TSD, existing estimates are both incomplete and an underestimate
of total damages that accrue to the citizens and residents of the U.S.
because they do not fully capture the regional interactions and
spillovers discussed above, nor do they include all of the important
physical, ecological, and economic impacts of climate change recognized
in the climate change literature. As noted in the February 2021 SC-GHG
TSD, the
[[Page 3801]]
IWG will continue to review developments in the literature, including
more robust methodologies for estimating a U.S.-specific SC-GHG value,
and explore ways to better inform the public of the full range of
carbon impacts. As a member of the IWG, DOE will continue to follow
developments in the literature pertaining to this issue.
Second, the IWG found that the use of the social rate of return on
capital (7 percent under current OMB Circular A-4 guidance) to discount
the future benefits of reducing GHG emissions inappropriately
underestimates the impacts of climate change for the purposes of
estimating the SC-GHG. Consistent with the findings of the National
Academies (2017) and the economic literature, the IWG continued to
conclude that the consumption rate of interest is the theoretically
appropriate discount rate in an intergenerational context \117\ and
recommended that discount rate uncertainty and relevant aspects of
intergenerational ethical considerations be accounted for in selecting
future discount rates.
---------------------------------------------------------------------------
\117\ Interagency Working Group on Social Cost of Carbon. Social
Cost of Carbon for Regulatory Impact Analysis under Executive Order
12866. 2010. United States Government. Available at: www.epa.gov/sites/default/files/2016-12/documents/scc_tsd_2010.pdf (last
accessed April 15, 2022); Interagency Working Group on Social Cost
of Carbon. Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866. 2013.
Available at: www.federalregister.gov/documents/2013/11/26/2013-28242/technical-support-document-technical-update-of-the-social-cost-of-carbon-for-regulatory-impact (last accessed April 15, 2022);
Interagency Working Group on Social Cost of Greenhouse Gases, United
States Government. Technical Support Document: Technical Update on
the Social Cost of Carbon for Regulatory Impact Analysis-Under
Executive Order 12866. August 2016. Available at: www.epa.gov/sites/default/files/2016-12/documents/sc_co2_tsd_august_2016.pdf (last
accessed January 18, 2022); Interagency Working Group on Social Cost
of Greenhouse Gases, United States Government. Addendum to Technical
Support Document on Social Cost of Carbon for Regulatory Impact
Analysis under Executive Order 12866: Application of the Methodology
to Estimate the Social Cost of Methane and the Social Cost of
Nitrous Oxide. August 2016. Available at: www.epa.gov/sites/default/files/2016-12/documents/addendum_to_sc-ghg_tsd_august_2016.pdf (last
accessed January 18, 2022).
---------------------------------------------------------------------------
Furthermore, the damage estimates developed for use in the SC-GHG
are estimated in consumption-equivalent terms, and so an application of
OMB Circular A-4's guidance for regulatory analysis would then use the
consumption discount rate to calculate the SC-GHG. DOE agrees with this
assessment and will continue to follow developments in the literature
pertaining to this issue. DOE also notes that while OMB Circular A-4,
as published in 2003, recommends using 3 percent and 7 percent discount
rates as ``default'' values, Circular A-4 also reminds agencies that
``different regulations may call for different emphases in the
analysis, depending on the nature and complexity of the regulatory
issues and the sensitivity of the benefit and cost estimates to the key
assumptions.'' On discounting, Circular A-4 recognizes that ``special
ethical considerations arise when comparing benefits and costs across
generations,'' and Circular A-4 acknowledges that analyses may
appropriately ``discount future costs and consumption benefits . . . at
a lower rate than for intragenerational analysis.'' In the 2015
Response to Comments on the Social Cost of Carbon for Regulatory Impact
Analysis, OMB, DOE, and the other IWG members recognized that
``Circular A-4 is a living document'' and ``the use of 7 percent is not
considered appropriate for intergenerational discounting. There is wide
support for this view in the academic literature, and it is recognized
in Circular A-4 itself.'' Thus, DOE concludes that a 7% discount rate
is not appropriate to apply to value the social cost of greenhouse
gases in the analysis presented in this analysis.
To calculate the present and annualized values of climate benefits,
DOE uses the same discount rate as the rate used to discount the value
of damages from future GHG emissions, for internal consistency. That
approach to discounting follows the same approach that the February
2021 SC-GHG TSD recommends ``to ensure internal consistency--i.e.,
future damages from climate change using the SC-GHG at 2.5 percent
should be discounted to the base year of the analysis using the same
2.5 percent rate.'' DOE has also consulted the National Academies' 2017
recommendations on how SC-GHG estimates can ``be combined in RIAs with
other cost and benefits estimates that may use different discount
rates.'' The National Academies reviewed several options, including
``presenting all discount rate combinations of other costs and benefits
with [SC-GHG] estimates.'' As a member of the IWG involved in the
development of the February 2021 SC-GHG TSD, DOE agrees with the above
assessment and will continue to follow developments in the literature
pertaining to this issue. While the IWG works to assess how best to
incorporate the latest, peer-reviewed science to develop an updated set
of SC-GHG estimates, it set the interim estimates to be the most recent
estimates developed by the IWG prior to the group being disbanded in
2017. The estimates rely on the same models and harmonized inputs and
are calculated using a range of discount rates. As explained in the
February 2021 SC-GHG TSD, the IWG has recommended that agencies revert
to the same set of four values drawn from the SC-GHG distributions
based on three discount rates as were used in regulatory analyses
between 2010 and 2016 and were subject to public comment. For each
discount rate, the IWG combined the distributions across models and
socioeconomic emissions scenarios (applying equal weight to each) and
then selected a set of four values recommended for use in benefit-cost
analyses: an average value resulting from the model runs for each of
three discount rates (2.5 percent, 3 percent, and 5 percent), plus a
fourth value, selected as the 95th percentile of estimates based on a 3
percent discount rate. The fourth value was included to provide
information on potentially higher-than-expected economic impacts from
climate change. As explained in the February 2021 SC-GHG TSD, and DOE
agrees, this update reflects the immediate need to have an operational
SC-GHG for use in regulatory benefit-cost analyses and other
applications that is developed using a transparent process, peer-
reviewed methodologies, and the science available at the time of that
process. Those estimates were subject to public comment in the context
of dozens of proposed rulemakings as well as in a dedicated public
comment period in 2013.
There are a number of limitations and uncertainties associated with
the SC-GHG estimates. First, the current scientific and economic
understanding of discounting approaches suggests discount rates
appropriate for intergenerational analysis in the context of climate
change are likely to be less than 3 percent, near 2 percent or
lower.\118\ Second, the IAMs used to produce these interim estimates do
not include all of the important physical, ecological, and economic
impacts of climate change recognized in the climate change literature
and the science underlying their ``damage functions'' (i.e., the core
parts of the IAMs that map global mean temperature changes and other
physical impacts of climate change into economic (both market and
nonmarket) damages) lags behind the most recent research. For
[[Page 3802]]
example, limitations include the incomplete treatment of catastrophic
and non-catastrophic impacts in the integrated assessment models, their
incomplete treatment of adaptation and technological change, the
incomplete way in which inter-regional and intersectoral linkages are
modeled, uncertainty in the extrapolation of damages to high
temperatures, and inadequate representation of the relationship between
the discount rate and uncertainty in economic growth over long-time
horizons. Likewise, the socioeconomic and emissions scenarios used as
inputs to the models do not reflect new information from the last
decade of scenario generation or the full range of projections. The
modeling limitations do not all work in the same direction in terms of
their influence on the SC-CO2 estimates. However, as
discussed in the February 2021 TSD, the IWG has recommended that, taken
together, the limitations suggest that the interim SC-GHG estimates
used in this proposed rule likely underestimate the damages from GHG
emissions. DOE concurs with this assessment.
---------------------------------------------------------------------------
\118\ Interagency Working Group on Social Cost of Greenhouse
Gases (IWG). 2021. Technical Support Document: Social Cost of
Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive
Order 13990. February. United States Government. Available at:
www.whitehouse.gov/briefing-room/blog/2021/02/26/a-return-to-science-evidence-based-estimates-of-the-benefits-of-reducing-climate-pollution/.
---------------------------------------------------------------------------
DOE's derivations of the SC-CO2, SC-N2O, and
SC-CH4 values used for this NOPR are discussed in the
following sections, and the results of DOE's analyses estimating the
benefits of the reductions in emissions of these GHGs are presented in
section IV.L.1.a of this document.
a. Social Cost of Carbon
The SC-CO2 values used for this NOPR were based on the
values presented for the IWG's February 2021 TSD. Table IV shows the
updated sets of SC-CO2 estimates from the IWG's TSD in 5-
year increments from 2020 to 2050. The full set of annual values that
DOE used is presented in appendix 14-A of the NOPR TSD. For purposes of
capturing the uncertainties involved in regulatory impact analysis, DOE
has determined it is appropriate include all four sets of SC-
CO2 values, as recommended by the IWG.\119\
---------------------------------------------------------------------------
\119\ For example, the February 2021 TSD discusses how the
understanding of discounting approaches suggests that discount rates
appropriate for intergenerational analysis in the context of climate
change may be lower than 3 percent.
[GRAPHIC] [TIFF OMITTED] TP19JA24.043
For 2051 to 2070, DOE used SC-CO2 estimates published by
EPA, adjusted to 2020$.\120\ These estimates are based on methods,
assumptions, and parameters identical to the 2020-2050 estimates
published by the IWG (which were based on EPA modeling). DOE expects
additional climate benefits to accrue for any longer-life fans and
blowers after 2070, but a lack of available SC-CO2 estimates
for emissions years beyond 2070 prevents DOE from monetizing these
potential benefits in this analysis.
---------------------------------------------------------------------------
\120\ See EPA, Revised 2023 and Later Model Year Light-Duty
Vehicle GHG Emissions Standards: Regulatory Impact Analysis,
Washington, DC, December 2021. Available at: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1013ORN.pdf (last accessed January 13, 2023).
---------------------------------------------------------------------------
DOE multiplied the CO2 emissions reduction estimated for
each year by the SC-CO2 value for that year in each of the
four cases. DOE adjusted the values to 2022 dollars using the implicit
price deflator for gross domestic product (``GDP'') from the Bureau of
Economic Analysis. To calculate a present value of the stream of
monetary values, DOE discounted the values in each of the four cases
using the specific discount rate that had been used to obtain the SC-
CO2 values in each case.
b. Social Cost of Methane and Nitrous Oxide
The SC-CH4 and SC-N2O values used for this
NOPR were based on the values developed for the February 2021 TSD.
Table IV-23 shows the updated sets of SC-CH4 and SC-
N2O estimates from the latest interagency update in 5-year
increments from 2020 to 2050. The full set of annual values used is
presented in appendix 14-A of the NOPR TSD. To capture the
uncertainties involved in regulatory impact analysis, DOE has
determined it is appropriate to include all four sets of SC-
CH4 and SC-N2O values, as recommended by the IWG.
DOE derived values after 2050 using the approach described above for
the SC-CO2.
[[Page 3803]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.044
DOE multiplied the CH4 and N2O emissions
reduction estimated for each year by the SC-CH4 and SC-
N2O estimates for that year in each of the cases. DOE
adjusted the values to 2022 dollars using the implicit price deflator
for gross domestic product (``GDP'') from the Bureau of Economic
Analysis. To calculate a present value of the stream of monetary
values, DOE discounted the values in each of the cases using the
specific discount rate that had been used to obtain the SC-
CH4 and SC-N2O estimates in each case.
2. Monetization of Other Emissions Impacts
For the NOPR, DOE estimated the monetized value of NOX
and SO2 emissions reductions from electricity generation
using the latest benefit per ton estimates for that sector from the
EPA's Benefits Mapping and Analysis Program.\121\ DOE used EPA's values
for PM2.5-related benefits associated with NOX
and SO2 and for ozone-related benefits associated with
NOX for 2025, 2030, and 2040, calculated with discount rates
of 3 percent and 7 percent. DOE used linear interpolation to define
values for the years not given in the 2025 to 2040 period; for years
beyond 2040 the values are held constant. DOE combined the EPA benefit
per ton estimates with regional information on electricity consumption
and emissions to define weighted-average national values for
NOX and SO2 as a function of sector (see appendix
14B of the NOPR TSD). DOE multiplied the site emissions reduction (in
tons) in each year by the associated $/ton values, and then discounted
each series using discount rates of 3 percent and 7 percent as
appropriate.
---------------------------------------------------------------------------
\121\ See Estimating the Benefit per Ton of Reducing PM2.5
Precursors from 21 Sectors. Available at: www.epa.gov/benmap/estimating-benefit-ton-reducing-pm25-precursors-21-sectors.
---------------------------------------------------------------------------
M. Utility Impact Analysis
The utility impact analysis estimates the changes in installed
electrical capacity and generation projected to result for each
considered TSL. The analysis is based on published output from the NEMS
associated with AEO2023. NEMS produces the AEO Reference case, as well
as a number of side cases that estimate the economy-wide impacts of
changes to energy supply and demand. For the current analysis, impacts
are quantified by comparing the levels of electricity sector
generation, installed capacity, fuel consumption and emissions in the
AEO2023 Reference case and various side cases. Details of the
methodology are provided in the appendices to chapters 13 and 15 of the
NOPR TSD.
The output of this analysis is a set of time-dependent coefficients
that capture the change in electricity generation, primary fuel
consumption, installed capacity and power sector emissions due to a
unit reduction in demand for a given end use. These coefficients are
multiplied by the stream of electricity savings calculated in the NIA
to provide estimates of selected utility impacts of potential new or
amended energy conservation standards.
N. Employment Impact Analysis
DOE considers employment impacts in the domestic economy as one
factor in selecting a proposed standard. Employment impacts from new or
amended energy conservation standards include both direct and indirect
impacts. Direct employment impacts are any changes in the number of
employees of manufacturers of the equipment subject to standards, their
suppliers, and related service firms. The MIA addresses those impacts.
Indirect employment impacts are changes in national employment that
occur due to the shift in expenditures and capital investment caused by
the purchase and operation of more efficient appliances. Indirect
employment impacts from standards consist of the net jobs created or
eliminated in the national economy, other than in the manufacturing
sector being regulated, caused by (1) reduced spending by consumers on
energy, (2) reduced spending on new energy supply by the utility
industry, (3) increased consumer spending on the equipment to which the
new standards apply and other goods and services, and (4) the effects
of those three factors throughout the economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (``BLS''). BLS regularly publishes its estimates of
the number of jobs per million dollars of economic activity in
different sectors of the economy, as well as the jobs created elsewhere
in the economy by this same economic activity. Data from BLS indicate
that expenditures in the utility sector generally create fewer jobs
(both directly and indirectly) than expenditures in other sectors of
the economy.\122\ There are many reasons for these differences,
including wage differences and the fact that the utility sector is more
capital-intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic
[[Page 3804]]
activity from a less labor-intensive sector (i.e., the utility sector)
to more labor-intensive sectors (e.g., the retail and service sectors).
Thus, the BLS data suggest that net national employment may increase
due to shifts in economic activity resulting from energy conservation
standards.
---------------------------------------------------------------------------
\122\ See U.S. Department of Commerce-Bureau of Economic
Analysis. Regional Multipliers: A User Handbook for the Regional
Input-Output Modeling System (RIMS II). 1997. U.S. Government
Printing Office: Washington, DC. Available at: https://apps.bea.gov/scb/pdf/regional/perinc/meth/rims2.pdf (last accessed March 27,
2023).
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this NOPR using an input/output model of the U.S.
economy called Impact of Sector Energy Technologies version 4
(``ImSET'').\123\ ImSET is a special-purpose version of the ``U.S.
Benchmark National Input-Output'' (``I-O'') model, which was designed
to estimate the national employment and income effects of energy-saving
technologies. The ImSET software includes a computer-based I-O model
containing structural coefficients that characterize economic flows
among 187 sectors most relevant to industrial, commercial, and
residential building energy use.
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\123\ Livingston, O.V., S.R. Bender, M.J. Scott, and R.W.
Schultz. ImSET 4.0: Impact of Sector Energy Technologies Model
Description and User Guide. 2015. Pacific Northwest National
Laboratory: Richland, WA. PNNL-24563.
---------------------------------------------------------------------------
DOE notes that ImSET is not a general equilibrium forecasting
model, and that the uncertainties involved in projecting employment
impacts especially changes in the later years of the analysis. Because
ImSET does not incorporate price changes, the employment effects
predicted by ImSET may overestimate actual job impacts over the long
run for this rule. Therefore, DOE used ImSET only to generate results
for near-term timeframes (2034), where these uncertainties are reduced.
For more details on the employment impact analysis, see chapter 16 of
the NOPR TSD.
V. Analytical Results and Conclusions
The following section addresses the results from DOE's analyses
with respect to the considered energy conservation standards for GFBs
and ACFs. It addresses the TSLs examined by DOE, the projected impacts
of each of these levels if adopted as energy conservation standards for
GFBs and ACFs, and the standards levels that DOE is proposing to adopt
in this NOPR. Additional details regarding DOE's analyses are contained
in the NOPR TSD supporting this document.
A. Trial Standard Levels
In general, DOE typically evaluates potential standards for
products and equipment by grouping individual efficiency levels for
each class into TSLs. Use of TSLs allows DOE to identify and consider
manufacturer cost interactions between the equipment classes, to the
extent that there are such interactions, and market cross elasticity
from consumer purchasing decisions that may change when different
standard levels are set.
For GFBs, in the analysis conducted for this NOPR, DOE analyzed the
benefits and burdens of 6 TSLs. DOE developed TSLs that combine
efficiency levels for each analyzed equipment class.
Table V-1 presents the TSLs and the corresponding efficiency levels
that DOE has identified for potential new energy conservation standards
for GFBs. TSL 6 represents the max-tech energy efficiency for all
product classes. TSL 5 represents the highest efficiency level with
positive LCC savings. TSL 4 is an intermediate level consisting of the
next level below TSL 5 with positive LCC savings. TSL 3 is an
intermediate level consisting of the same level as TSL 4 or in the next
level below TSL 4 with positive LCC savings and above TSL 2, where
available. TSL 2 represents a combination of efficiency levels that
correspond to a FEI of 1 across all equipment classes as required in
ASHRAE 90.1, except for Axial Power Roof Ventilator--Exhaust, where it
is set one efficiency level lower due to negative LCC savings at the EL
corresponding to a FEI value of 1 (EL 5). TSL 1 represents combination
of efficiency levels that corresponds to one efficiency level below the
efficiency level corresponding to a FEI value of 1.
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DOE constructed the TSLs for this NOPR to include ELs
representative of ELs with similar characteristics (i.e., using similar
technologies and/or efficiencies, and having roughly comparable
equipment availability). The use of representative ELs provided for
greater distinction between the TSLs. DOE did not consider ELs for
which the average LCC savings were negative other than for TSL 6 (max-
tech). While representative ELs were included in the TSLs, DOE
considered all efficiency levels as part of its analysis.\124\
---------------------------------------------------------------------------
\124\ Efficiency levels that were analyzed for this NOPR are
discussed in section IV.C of this document. Results by efficiency
level are presented in NOPR TSD chapter 8.
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[[Page 3805]]
For ACFs, in the analysis conducted for this NOPR, DOE analyzed the
benefits and burdens of six TSLs. DOE developed TSLs that combine
efficiency levels for each analyzed equipment class.
Table V-2 presents the TSLs and the corresponding efficiency levels
that DOE has identified for potential new energy conservation standards
for ACFs. TSL 6 represents the max-tech energy efficiency for all
equipment classes. TSL 5 represents a level corresponding to EL 5 for
all axial ACFs and EL 3 for housed centrifugal ACFs. It represents the
highest EL below max-tech with positive LCC savings. TSL 4 is
constructed with the same efficiency level EL 4 for all axial ACFs and
represents EL 0 for housed centrifugal ACFs. Similarly, TSL 3 through
TSL 1 represent levels corresponding to EL 3 through EL 1 for all axial
ACFs and EL 0 for housed centrifugal ACFs.
[GRAPHIC] [TIFF OMITTED] TP19JA24.046
DOE constructed the TSLs for this NOPR to include ELs
representative of ELs with similar characteristics (i.e., using similar
technologies within similar equipment classes). DOE did not consider EL
1 through EL 2 for housed centrifugal ACFs as the average LCC savings
are negative at these levels for this equipment class. While
representative ELs were included in the TSLs, DOE considered all
efficiency levels as part of its analysis.\125\
---------------------------------------------------------------------------
\125\ Efficiency levels that were analyzed for this NOPR are
discussed in section IV.C.1.b of this document. Results by
efficiency level are presented in NOPR TSD chapters 8.
---------------------------------------------------------------------------
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on fan and blower consumers by
looking at the effects that potential new standards at each TSL would
have on the LCC and PBP. DOE also examined the impacts of potential
standards on selected consumer subgroups. These analyses are discussed
in the following sections.
a. Life-Cycle Cost and Payback Period
In general, higher-efficiency equipment affects consumers in two
ways: (1) purchase price increases and (2) annual operating costs
decrease. Inputs used for calculating the LCC and PBP include total
installed costs (i.e., product price plus installation costs), and
operating costs (i.e., annual energy use, energy prices, energy price
trends, repair costs, and maintenance costs). The LCC calculation also
uses equipment lifetime and a discount rate. Chapter 8 of the NOPR TSD
provides detailed information on the LCC and PBP analyses.
Table V-3 through Table V-20 show the LCC and PBP results for the
TSLs considered for each equipment class for GFBs. Table V-21 through
Table V-28 show the LCC and PBP results for the TSLs considered for
each equipment class for ACFs. The simple payback and other impacts are
measured relative to the efficiency distribution in the no-new-
standards case in the compliance year (see section IV.F.8 of this
document). Because the average LCC savings refer only to consumers who
are affected by a standard at a given TSL, the average savings are
greater than the difference between the average LCC in the no-new-
standards case and the average LCC at each TSL. The savings refer only
to consumers who are affected by a standard at a given TSL. Those who
already purchase equipment with efficiency at or above a given TSL are
not affected. Consumers for whom the LCC increases at a given TSL
experience a net cost.
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[[Page 3806]]
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[[Page 3814]]
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b. Consumer Subgroup Analysis
In the consumer subgroup analysis, DOE estimated the impact of the
considered TSLs on small businesses. Table V-29 and Table V-30 compare
the average LCC savings and PBP at each efficiency level for the
consumer subgroup with similar metrics for the entire consumer sample
for GFBs and ACFs, respectively. In most cases, the average LCC savings
and PBP for small businesses at the considered TSLs are not
substantially different from the average for all consumers. Chapter 11
of
[[Page 3815]]
the NOPR TSD presents the complete LCC and PBP results for the
subgroup.
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[[Page 3816]]
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[[Page 3817]]
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[[Page 3818]]
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c. Rebuttable Presumption Payback
As discussed in section III.F.2, EPCA establishes a rebuttable
presumption that an energy conservation standard is economically
justified if the increased purchase cost for equipment that meets the
standard is less than three times the value of the first-year energy
savings resulting from the standard. In calculating a rebuttable
presumption payback period for each of the considered TSLs, DOE used
discrete values and, as required by EPCA, based the energy use
calculation on the DOE test procedure for fans and blowers. In
contrast, the PBPs presented in section V.B.1.a were calculated using
distributions that reflect the range of energy use in the field.
Table V-31 and Table V-32 present the rebuttable-presumption
payback periods for the considered TSLs for GFBs and ACFs. While DOE
examined the rebuttable-presumption criterion, it considered whether
the standard levels considered for the NOPR are economically justified
through a more detailed analysis of the economic impacts of those
levels, pursuant to 42 U.S.C 6316(a); 42 U.S.C. 6295(o)(2)(B)(i), that
considers the full range of impacts to the consumer, manufacturer,
Nation, and environment. The results of that analysis serve as the
basis for DOE to definitively evaluate the economic justification for a
potential standard level, thereby supporting or rebutting
[[Page 3819]]
the results of any preliminary determination of economic justification.
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[GRAPHIC] [TIFF OMITTED] TP19JA24.078
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of new energy
conservation standards on manufacturers of fans and blowers. The
following section describes the expected impacts on manufacturers at
each considered TSL. Chapter 12 of the NOPR TSD explains the analysis
in further detail.
a. Industry Cash Flow Analysis Results
In this section, DOE provides GRIM results from the analysis, which
examines changes in the industry that would result from new standards.
The following tables summarize the estimated financial impacts
(represented by changes in INPV) of potential new energy conservation
standards on manufacturers of fans and blowers, as well as the
conversion costs that DOE estimates manufacturers of fans and blowers
would incur at each TSL. DOE analyzes the potential impacts on INPV
separately for ACFs and GFBs. To evaluate the range of cash flow
impacts on the fan and blower industry, DOE modeled two manufacturer
markup scenarios using different assumptions that correspond to the
range of anticipated market responses to new energy conservation
standards: (1) the conversion cost recovery markup scenario and (2) the
preservation of operating profit markup scenario.
To assess the less severe end of the range of potential impacts,
DOE modeled a conversion cost recovery markup scenario in which
manufacturers are able to increase their manufacturer markups in
response to new energy conservation standards. To assess the more
severe end of the range of potential impacts, DOE modeled a
preservation of operating profit markup scenario in which manufacturers
are not able to maintain their original manufacturer markup, used in
the no-new-standards case, in the standards cases. Instead,
manufacturers maintain the same operating profit (in absolute dollars)
in the standards cases as in the no-new-standards case, despite higher
MPCs.
Each of the modeled manufacturer markup scenarios results in a
unique set of cash flows and corresponding industry values at the given
TSLs for each group of fan and blower manufacturers. In the following
discussion, the INPV results refer to the difference in industry value
between the no-new-standards case and each standards case resulting
from the sum of discounted cash flows from 2024 through 2059. To
provide perspective on the short-run cash flow impact, DOE includes in
the discussion of results a comparison of free cash flow between the
no-new-standards case and the standards case at each TSL in the year
before new standards take effect.
DOE presents the range in INPV for GFB manufacturers in Table V-33
and Table V-34 and the range in INPV for ACF manufacturers in Table V-
36 and Table V-37.
[[Page 3820]]
General Fans and Blowers
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BILLING CODE 6450-01-C
At TSL 6, for GFB manufacturers, DOE estimates the impacts on INPV
will range from -$2,287 million to $40 million, which represents a
change of -46.4 percent to 0.8 percent, respectively. At TSL 6,
industry free cash flow decreases to -$1,132 million, which represents
a decrease of approximately 336 percent, compared to the no-new-
standards case value of $480 million in 2029, the year before the
modeled compliance year. The negative cash flow in the years leading up
to the modeled compliance date implies that most, if not all, GFB
manufacturers will need to borrow funds in order to make the
investments necessary to comply with standards. This has the potential
to significantly alter the market dynamics as some smaller
manufacturers may not be able to secure this funding and could exit the
market as a result of standards set at TSL 6.
TSL 6 would set energy conservation standards at max-tech for all
GFBs. DOE estimates that approximately 4 percent of the GFB shipments
would already meet the efficiency levels required at TSL 6 in 2030, in
the no-new-standards case. Therefore, DOE estimates that manufacturers
would have to redesign models representing approximately 96 percent of
GFB shipments by the estimated compliance date. It is unclear if most
GFB manufacturers would have the engineering capacity to complete the
necessary redesigns within the 5-year compliance period. If
manufacturers require more than 5 years to redesign their non-compliant
GFB models, they will likely prioritize redesigns based on sales
volume, which could result in customers not being able to obtain
compliant GFBs covering the duty points that they require.
At TSL 6, DOE expects GFB manufacturers to incur approximately $698
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant GFB models.
[[Page 3821]]
Additionally, GFB manufacturers would incur approximately $3,052
million in capital conversion costs to purchase new tooling and
equipment necessary to produce compliant GFB models to meet these
energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 6, the
$3,750 million in conversion costs are fully recovered, over the 30-
year analysis period, causing INPV at TSL 6 to remain approximately
equal to the no-new-standards case INPV in this conversion cost
recovery scenario. Given the large size of the conversion costs,
approximately 1.3 times the sum of the annual free cash flows over the
years between the estimated final rule announcement date and the
estimated standards year (i.e., the time period that these conversion
costs would be incurred), it is highly unlikely that the GFB market
will accept the large increases in the MSPs that would be needed for
GFB manufacturers to fully recover these conversion costs, making the
MSPs that result from this manufacturer markup scenario less likely to
be obtained by manufacturers. This represents the upper-bound, or
least-severe impact, on manufacturer profitability and is the
manufacturer markup scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increases by approximately 2.2
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $3,750 million in conversion costs incurred by manufacturers cause
a significantly negative change in INPV at TSL 6 in this preservation
of operating profit scenario. This represents the lower-bound, or most
severe impact, on manufacturer profitability.
At TSL 5, for GFB manufacturers, DOE estimates the impacts on INPV
will range from -$1,263 million to $11 million, which represents a
change of -25.6 percent to 0.2 percent, respectively. At TSL 5,
industry free cash flow decreases to -$407 million, which represents a
decrease of approximately 185 percent, compared to the no-new-standards
case value of $480 million in 2029, the year before the modeled
compliance year. The negative cash flow in the years leading up to the
modeled compliance date implies that most, if not all, GFB
manufacturers will need to borrow funds in order to make the
investments necessary to comply with standards. This has the potential
to significantly alter the market dynamics as some smaller
manufacturers may not be able to secure this funding and could exit the
market as a result of standards set at TSL 5.
TSL 5 would set energy conservation standards for axial inline fans
at EL 4; axial panel fans at EL 5; centrifugal housed fans at EL 5;
centrifugal inline fans at EL 6; centrifugal unhoused fans at EL 5;
axial PRVs at EL 4; centrifugal PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 6; and radial housed fans at EL 5. DOE estimates
that approximately 7 percent of the GFB shipments would already meet or
exceed the efficiency levels required at TSL 5 in 2030, in the no-new-
standards case. Therefore, DOE estimates that manufacturers would have
to redesign models representing approximately 93 percent of GFB
shipments by the estimated compliance date. It is unclear if most GFB
manufacturers would have the engineering capacity to complete the
necessary redesigns within the 5-year compliance period. If
manufacturers require more than 5 years to redesign their non-compliant
GFB models, they will likely prioritize redesigns based on sales
volume, which could result in customers not being able to obtain
compliant GFBs covering the duty points that they require.
At TSL 5, DOE expects GFB manufacturers to incur approximately $435
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant GFB models. Additionally, GFB manufacturers would
incur approximately $1,640 million in capital conversion costs to
purchase new tooling and equipment necessary to produce compliant GFB
models to meet these energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 5, the
$2,075 million in conversion costs are fully recovered causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. Given the large size of the
conversion costs, approximately 90 percent of the sum of the annual
free cash flows over the years between the estimated final rule
announcement date and the estimated standards year (i.e., the time
period that these conversion costs would be incurred), it is unlikely
that the GFB market will accept the large increases in the MSPs that
would be needed for GFB manufacturers to fully recover these conversion
costs, making the MSPs that result from this manufacturer markup
scenario less likely to be obtained by manufacturers. This represents
the upper-bound, or least-severe impact, on manufacturer profitability
and is the manufacturer markup scenario used in all down-stream
consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increases by approximately 2.2
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $2,075 million in conversion costs incurred by manufacturers cause
a significantly negative change in INPV at TSL 5 in this preservation
of operating profit scenario. This represents the lower-bound, or most
severe impact, on manufacturer profitability.
At TSL 4, for GFB manufacturers, DOE estimates the impacts on INPV
will range from -$455 million to $1 million, which represents a change
of -9.2 percent to less than 0.1 percent, respectively. At TSL 4,
industry free cash flow decreases to $161 million, which represents a
decrease of approximately 66.4 percent, compared to the no-new-
standards case value of $480 million in 2029, the year before the
modeled compliance year.
TSL 4 would set energy conservation standards for axial inline fans
at EL 3; axial panel fans at EL 4; centrifugal housed fans at EL 4;
centrifugal inline fans at EL 5; centrifugal unhoused fans at EL 4;
axial PRVs at EL 4; centrifugal PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 5; and radial housed fans at EL 4. DOE estimates
that approximately 25 percent of the GFB shipments would already meet
or exceed the efficiency levels required at TSL 4 in 2030, in the no-
new-standards case. Therefore, DOE estimates that manufacturers would
have to redesign models representing approximately 75 percent of GFB
shipments by the estimated compliance date.
At TSL 4, DOE expects GFB manufacturers to incur approximately $260
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant GFB models. Additionally, GFB manufacturers would
[[Page 3822]]
incur approximately $510 million in capital conversion costs to
purchase new tooling and equipment necessary to produce compliant GFB
models to meet these energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 4, the
$770 million in conversion costs are fully recovered causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. At TSL 4, conversion costs represent
approximately 33 percent of the sum of the annual free cash flows over
the years between the estimated final rule announcement date and the
estimated standards year (i.e., the time period that these conversion
costs would be incurred). It is possible that the GFB market will not
accept the full increase in the MSPs that would be needed for GFB
manufacturers to fully recover these conversion costs. This represents
the upper-bound, or least-severe impact, on manufacturer profitability
and is the manufacturer markup scenario used in all down-stream
consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increases by approximately 1.1
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $770 million in conversion costs incurred by manufacturers cause a
moderately negative change in INPV at TSL 4 in this preservation of
operating profit scenario. This represents the lower-bound, or most
severe impact, on manufacturer profitability.
At TSL 3, for GFB manufacturers, DOE estimates the impacts on INPV
will range from -$238 million to $1 million, which represents a change
of -4.8 percent to less than 0.1 percent, respectively. At TSL 3,
industry free cash flow decreases to $316 million, which represents a
decrease of approximately 34.3 percent, compared to the no-new-
standards case value of $480 million in 2029, the year before the
modeled compliance year.
TSL 3 would set energy conservation standards for axial inline fans
at EL 3; axial panel fans at EL 3; centrifugal housed fans at EL 3;
centrifugal inline fans at EL 4; centrifugal unhoused fans at EL 3;
axial PRVs at EL 4; centrifugal PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 5; and radial housed fans at EL 4. DOE estimates
that approximately 60 percent of the GFB shipments would already meet
or exceed the efficiency levels required at TSL 3 in 2030, in the no-
new-standards case. Therefore, DOE estimates that manufacturers would
have to redesign models representing approximately 40 percent of GFB
shipments by the estimated compliance date.
At TSL 3, DOE expects GFB manufacturers to incur approximately $154
million in product conversion costs to redesign all non-compliant GFB
models. Additionally, GFB manufacturers would incur approximately $248
million in capital conversion costs to purchase new tooling and
equipment necessary to produce compliant GFB models to meet these
energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 3, the
$402 million in conversion costs are fully recovered, causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. This represents the upper-bound, or
least-severe impact, on manufacturer profitability and is the
manufacturer markup scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increases by approximately 1.1
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $402 million in conversion costs incurred by manufacturers cause a
negative change in INPV at TSL 3 in this preservation of operating
profit scenario. This represents the lower-bound, or most severe
impact, on manufacturer profitability.
At TSL 2, for GFB manufacturers, DOE estimates the impacts on INPV
will range from -$87 million to $5 million, which represents a change
of -1.8 percent to 0.1 percent, respectively. At TSL 2, industry free
cash flow decreases to $420 million, which represents a decrease of
approximately 12.4 percent, compared to the no-new-standards case value
of $480 million in 2029, the year before the modeled compliance year.
TSL 2 would set energy conservation standards for axial inline fans
at EL 2; axial panel fans at EL 2; centrifugal housed fans at EL 2;
centrifugal inline fans at EL 3; centrifugal unhoused fans at EL 1;
axial PRVs at EL 4; centrifugal PRV exhaust fans at EL 4; centrifugal
PRV supply fans at EL 4; and radial housed fans at EL 3. DOE estimates
that approximately 85 percent of the GFB shipments would already meet
or exceed the efficiency levels required at TSL 2 in 2030, in the no-
new-standards case. Therefore, DOE estimates that manufacturers would
have to redesign models representing approximately 15 percent of GFB
shipments by the estimated compliance date.
At TSL 2, DOE expects GFB manufacturers to incur approximately $62
million in product conversion costs to redesign all non-compliant GFB
models. Additionally, GFB manufacturers would incur approximately $86
million in capital conversion costs to purchase new tooling and
equipment necessary to produce compliant GFB models to meet these
energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 2, the
$147 million in conversion costs are fully recovered causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. This represents the upper-bound, or
least-severe impact, on manufacturer profitability and is the
manufacturer markup scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increases by approximately 0.6
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $147 million in conversion costs incurred by manufacturers cause a
slight negative change in INPV at TSL 2 in this preservation of
operating profit scenario. This represents the lower-bound, or most
severe impact, on manufacturer profitability.
At TSL 1, for GFB manufacturers, DOE estimates the impacts on INPV
will range from -$28 million to $13 million,
[[Page 3823]]
which represents a change of -0.6 percent to 0.3 percent, respectively.
At TSL 1, industry free cash flow decreases to $463 million, which
represents a decrease of approximately 3.6 percent, compared to the no-
new-standards case value of $480 million in 2029, the year before the
modeled compliance year.
TSL 1 would set energy conservation standards for axial inline fans
at EL 1; axial panel fans at EL 1; centrifugal housed fans at EL 1;
centrifugal inline fans at EL 2; centrifugal unhoused fans at EL 1;
axial PRVs at EL 4; centrifugal PRV exhaust fans at EL 3; centrifugal
PRV supply fans at EL 3; and radial housed fans at EL 2. DOE estimates
that approximately 91 percent of the GFB shipments would already meet
or exceed the efficiency levels required at TSL 1 in 2030, in the no-
new-standards case. Therefore, DOE estimates that manufacturers would
have to redesign models representing approximately 9 percent of GFB
shipments by the estimated compliance date.
At TSL 1, DOE expects GFB manufacturers to incur approximately $20
million in product conversion costs to redesign all non-compliant GFB
models. Additionally, GFB manufacturers would incur approximately $23
million in capital conversion costs to purchase new tooling and
equipment necessary to produce compliant GFB models to meet these
energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 1, the $43
million in conversion costs are fully recovered causing INPV to remain
approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. This represents the upper-bound, or
least-severe impact, on manufacturer profitability and is the
manufacturer markup scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increases by approximately 0.6
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $43 million in conversion costs incurred by manufacturers cause a
very slight negative change in INPV at TSL 1 in this preservation of
operating profit scenario. This represents the lower-bound, or most
severe impact, on manufacturer profitability.
Air Circulating Fans
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At TSL 6, for ACF manufacturers, DOE estimates the impacts on INPV
will range from -$734 million to $3 million, which represents a change
of -113.1 percent to 0.5 percent, respectively. At TSL 6, industry free
cash flow decreases to -$456 million, which represents a decrease of
approximately 999 percent, compared to the no-new-standards case value
of $51 million in 2029, the year before the modeled compliance year.
The negative cash flow in the years leading up to the modeled
compliance date implies that most, if not all, ACF manufacturers will
need to borrow funds in order to make the investments necessary to
comply with standards. This has the potential to significantly alter
the market dynamics as some smaller manufacturers may not be able to
secure this funding and could exit the market as a result of standards
set at TSL 6.
TSL 6 would set energy conservation standards at max-tech for all
ACFs. DOE estimates that approximately 1 percent of the ACF shipments
would already meet the efficiency levels required at TSL 6 in 2030, in
the no-new-standards case. Therefore, DOE estimates that manufacturers
would have to redesign models representing approximately 99 percent of
ACF shipments by the estimated compliance date. It is unclear if most
ACF manufacturers would have the engineering capacity to complete the
necessary redesigns within the 5-year compliance period. If
manufacturers require more than 5 years to redesign their non-compliant
ACF models, they will likely prioritize redesigns based on sales
volume, which could result in customers not being able to obtain
compliant ACFs covering the duty points that they require.
At TSL 6, DOE expects ACF manufacturers to incur approximately $239
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant ACF models. Additionally, ACF manufacturers would
incur approximately $928 million in capital conversion costs to
purchase new tooling and equipment necessary to produce compliant ACF
models to meet these energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 6, the
$1,167 million in conversion costs are fully recovered causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. Given the large size of the
conversion costs, over 5 times the sum of the annual free cash flows
over the years between the estimated final rule announcement date and
the estimated standards year (i.e., the time period that these
conversion costs would be incurred), it is unlikely that the ACF market
will accept the large increases in the MSPs that would be needed for
ACF manufacturers to fully recover these conversion costs, making the
MSPs that result from this manufacturer markup scenario less likely to
be obtained by manufacturers. This represents the upper-bound, or
least-severe impact, on manufacturer profitability and is the
manufacturer markup scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. In this scenario,
the shipment weighted average MPC increase by approximately 4.7
percent, causing a reduction in the manufacturer margin after the
analyzed compliance year. This reduction in the manufacturer margin and
the $1,167 million in conversion costs incurred by manufacturers cause
an extremely negative change in INPV at TSL 6 in this preservation of
operating profit scenario. This represents the lower-bound, or most
severe impact, on manufacturer profitability.
At TSL 5, for ACF manufacturers, DOE estimates the impacts on INPV
will range from -$633 million to $3 million, which represents a change
of -97.5 percent to 0.5 percent, respectively. At TSL 5, industry free
cash flow decreases to -$400 million, which represents a decrease of
approximately 889 percent, compared to the no-new-standards case value
of $51 million in 2029, the year before the modeled compliance year.
The negative cash flow in the years leading up to the modeled
compliance date implies that most, if not all, ACF manufacturers will
need to borrow funds in order to make the investments necessary to
comply with standards. This has the potential to significantly alter
the market dynamics as some smaller manufacturers may not be able to
secure this funding and could exit the market as a result of standards
set at TSL 5.
TSL 5 would set energy conservation standards at EL 5 for all ACFs,
except housed centrifugal ACFs which are set at EL 3. DOE estimates
that approximately 4 percent of the ACF shipments would already meet or
exceed the efficiency levels required at
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TSL 5 in 2030, in the no-new-standards case. Therefore, DOE estimates
that manufacturers would have to redesign models representing
approximately 96 percent of ACF shipments by the estimated compliance
date. It is unclear if most ACF manufacturers would have the
engineering capacity to complete the necessary redesigns within the 5-
year compliance period. If manufacturers require more than 5 years to
redesign their non-compliant ACF models, they will likely prioritize
redesigns based on sales volume, which could result in customers not
being able to obtain compliant ACFs covering the duty points that they
require.
At TSL 5, DOE expects ACF manufacturers to incur approximately $214
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant ACF models. Additionally, ACF manufacturers would
incur approximately $829 million in capital conversion costs to
purchase new tooling and equipment necessary to produce compliant ACF
models to meet these energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 5, the
$1,043 million in conversion costs are fully recovered causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. Given the large size of the
conversion costs, over 4.5 times the sum of the annual free cash flows
over the years between the estimated final rule announcement date and
the estimated standards year (i.e., the time period that these
conversion costs would be incurred), it is unlikely that the ACF market
will accept the large increases in the MSPs that would be needed for
ACF manufacturers to fully recover these conversion costs, making the
MSPs that result from this manufacturer markup scenario less likely to
be obtained by manufacturers. This represents the upper-bound, or
least-severe impact, on manufacturer profitability and is the
manufacturer markup scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. The $1,043 million
in conversion costs incurred by manufacturers cause a significantly
negative change in INPV at TSL 5 in this preservation of operating
profit scenario. This represents the lower-bound, or most severe
impact, on manufacturer profitability.
At TSL 4, for ACF manufacturers, DOE estimates the impacts on INPV
will range from -$71 million to no change, which represents a maximum
possible change of -10.9 percent. At TSL 4, industry free cash flow
decreases to $1 million, which represents a decrease of approximately
99.0 percent, compared to the no-new-standards case value of $51
million in 2029, the year before the modeled compliance year.
TSL 4 would set energy conservation standards at EL 4 for all ACFs,
except housed centrifugal ACFs which would not have any energy
conservation standard. DOE estimates that approximately 36 percent of
the ACF shipments would already meet or exceed the efficiency levels
required at TSL 4 in 2030, in the no-new-standards case. Therefore, DOE
estimates that manufacturers would have to redesign models representing
approximately 64 percent of ACF shipments by the estimated compliance
date.
At TSL 4, DOE expects ACF manufacturers to incur approximately $27
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant ACF models. Additionally, ACF manufacturers would
incur approximately $91 million in capital conversion costs to purchase
new tooling and equipment necessary to produce compliant ACF models to
meet these energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 4, the
$118 million in conversion costs are fully recovered causing INPV to
remain approximately equal to the no-new-standards case INPV in this
conversion cost recovery scenario. At TSL 4, conversion costs represent
approximately 50 percent of the sum of the annual free cash flows over
the years between the estimated final rule announcement date and the
estimated standards year (i.e., the time period that these conversion
costs would be incurred). It is possible that the ACF market will not
accept the full increase in the MSPs that would be needed for ACF
manufacturers to fully recover these conversion costs. This represents
the upper-bound, or least-severe impact, on manufacturer profitability
and is the manufacturer markup scenario used in all down-stream
consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. The $118 million in
conversion costs incurred by manufacturers cause a moderately negative
change in INPV at TSL 4 in this preservation of operating profit
scenario. This represents the lower-bound, or most severe impact, on
manufacturer profitability.
At TSL 3, for ACF manufacturers, DOE estimates the impacts on INPV
will range from -$4 million to no change, which represents a maximum
change of -0.6 percent. At TSL 3, industry free cash flow decreases to
$48 million, which represents a decrease of approximately 6.2 percent,
compared to the no-new-standards case value of $51 million in 2029, the
year before the modeled compliance year.
TSL 3 would set energy conservation standards at EL 3 for all ACFs,
except housed centrifugal ACFs which would not have any energy
conservation standard. DOE estimates that approximately 84 percent of
the ACF shipments would already meet or exceed the efficiency levels
required at TSL 3 in 2030, in the no-new-standards case. Therefore, DOE
estimates that manufacturers would have to redesign models representing
approximately 16 percent of ACF shipments by the estimated compliance
date.
At TSL 3, DOE expects ACF manufacturers to incur approximately $1.9
million in product conversion costs to conduct aerodynamic redesigns
for non-compliant ACF models. Additionally, ACF manufacturers would
incur approximately $5.5 million in capital conversion costs to
purchase new tooling and equipment necessary to produce compliant ACF
models to meet these energy conservation standards.
In the conversion cost recovery markup scenario, manufacturers
increase their manufacturer markups to fully recover the conversion
costs they incur to redesign non-compliant equipment. At TSL 3, the
$7.4 million in conversion costs are fully recovered causing INPV to
remain equal to the no-new-standards case INPV in this conversion cost
recovery scenario. This represents the upper-bound, or least-severe
impact, on manufacturer profitability and is the manufacturer markup
scenario used in all down-stream consumer analyses.
Under the preservation of operating profit scenario, manufacturers
earn the same per-unit operating profit as would be earned in the no-
new-standards case, but manufacturers do not earn additional profit
from their investments or potentially higher MPCs. The $7.4 million in
conversion costs incurred by
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manufacturers cause a slight negative change in INPV at TSL 3 in this
preservation of operating profit scenario. This represents the lower-
bound, or most severe impact, on manufacturer profitability.
At TSL 2, for ACF manufacturers, DOE estimates there will be no
substantive change to INPV. At TSL 2, industry free cash flow sightly
decreases by approximately 0.1 percent in 2029, the year before the
modeled compliance year.
TSL 2 would set energy conservation standards at EL 2 for all ACFs,
except housed centrifugal ACFs which would not have any energy
conservation standard. DOE estimates that approximately 96 percent of
the ACF shipments would already meet or exceed the efficiency levels
required at TSL 2 in 2030, in the no-new-standards case. Therefore, DOE
estimates that manufacturers would have to redesign models representing
approximately 4 percent of ACF shipments by the estimated compliance
date.
At TSL 2, DOE expects ACF manufacturers to incur approximately $0.2
million in product conversion costs to redesign the few non-compliant
ACF models. DOE estimates that ACF manufacturers would not incur any
capital conversion costs, as manufacturers already have the tooling and
production equipment necessary to produce ACF models that meet these
energy conservation standards.
The conversion costs incurred by manufacturers, which are
relatively minor due to the majority of shipments already meeting the
energy conservation standards, and changes in MPCs at TSL 2 are not
severe enough to have a significant impact on ACF manufacturers in
either of the manufacturer markup scenarios.
At TSL 1, for ACF manufacturers, DOE estimates the impacts on INPV
will range from no change to an increase of $0.5 million, which
represents a maximum change of 0.1 percent. At TSL 1, industry free
cash flow sightly decreases by less than 0.1 percent in 2029, the year
before the modeled compliance year.
TSL 1 would set energy conservation standards at EL 1 for all ACFs,
except housed centrifugal ACFs which would not have any energy
conservation standard. DOE estimates that approximately 96 percent of
the ACF shipments would already meet or exceed the efficiency levels
required at TSL 1 in 2030, in the no-new-standards case. Therefore, DOE
estimates that manufacturers would have to redesign models representing
approximately 4 percent of ACF shipments by the estimated compliance
date.
At TSL 1, DOE expects ACF manufacturers to incur approximately $0.1
million in product conversion costs to redesign the few non-compliant
ACF models. DOE estimates that ACF manufacturers would not incur any
capital conversion costs, as manufacturers already have the tooling and
production equipment necessary to produce ACF models that meet these
energy conservation standards.
The conversion costs incurred by manufacturers, which are
relatively minor due to the majority of shipments already meeting the
energy conservation standards, and the change in MPCs at TSL 1 are not
severe enough to have a significant impact on ACF manufacturers in
either of the manufacturer markup scenarios.
b. Direct Impacts on Employment
To quantitatively assess the potential impacts of new energy
conservation standards on direct employment in the fan and blower
industry, DOE used the GRIM to estimate the domestic labor expenditures
and number of direct employees in the no-new-standards case and in each
of the standards cases during the analysis period.
Production employees are those who are directly involved in
fabricating and assembling equipment within manufacturer facility.
Workers performing services that are closely associated with production
operations, such as materials handling tasks using forklifts, are
included as production labor, as well as line supervisors.
DOE used the GRIM to calculate the number of production employees
from labor expenditures. DOE used statistical data from the U.S. Census
Bureau's 2021 Annual Survey of Manufacturers \126\ (``ASM'') and the
results of the engineering analysis to calculate industry-wide labor
expenditures. Labor expenditures related to product manufacturing
depend on the labor intensity of the product, the sales volume, and an
assumption that wages remain fixed in real terms over time. The total
labor expenditures in the GRIM were then converted to domestic
production employment levels by dividing production labor expenditures
by the annual payment per production worker.
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\126\ See www.census.gov/programs-surveys/asm/data/tables.html.
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Non-production employees account for those workers that are not
directly engaged in the manufacturing of the covered equipment. This
could include sales, human resources, engineering, and management. DOE
estimated non-production employment levels by multiplying the number of
fan and blower production workers by a scaling factor. The scaling
factor is calculated by taking the ratio of the total number of
employees, and the total production workers associated with the
industry North American Industry Classification System (``NAICS'') code
333413, which covers fan and blower manufacturing.
Using the GRIM, DOE estimates that there would be approximately
13,819 domestic production workers, and 6,091 non-production workers
for GFBs in 2030 in the absence of new energy conservation standards.
DOE estimates that there would be approximately 648 domestic production
workers and 286 non-production workers for ACFs in 2030 in the absence
of new energy conservation standards. Table V-39 shows the range of the
impacts of energy conservation standards on U.S. production of GFBs and
Table V-40 shows the range of the impacts of energy conservation
standards on U.S. production of ACFs.
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The direct employment impacts shown in Table V-39 and Table V-40
represent the potential changes in direct employment that could result
following the compliance date for GFBs and ACFs. Employment could
increase or decrease due to the labor content of the various equipment
being manufactured domestically that meet the analyzed standards or if
manufacturers decided to move production facilities abroad because of
new standards. At one end of the range, DOE assumes that all
manufacturers continue to manufacture the same scope of equipment
domestically after new standards are required. However, since the labor
content of GFBs and ACFs vary by efficiency level, this can either
result in an increase or decrease in domestic employment, even if all
domestic production remains in the U.S.
The lower end of the range assumes that some domestic manufacturing
either is eliminated or moves abroad due to the analyzed new standards.
DOE assumes that for TSL 1 and TSL 2 ACF and GFB manufacturers already
have the tooling and production equipment necessary to produce ACF and
GFB models that meet these energy conservation standards, making it
unlikely that manufacturers would move any domestic product abroad at
these analyzed TSLs. At TSL 3 through TSL 6, DOE conservatively
estimates that some domestic manufacturing could move abroad as these
TSLs require manufacturers to make larger investments in production
equipment that could cause some manufacturers to consider moving
production facilities to a lower-labor cost country.
c. Impacts on Manufacturing Capacity
During manufacturer interviews most manufacturers stated that any
standards set at max-tech would severely disrupt manufacturing
capacity. Many fan and blower manufacturers do not offer any GFB or ACF
models that would meet these max-tech efficiency levels. Based on the
shipments analysis used in the NIA, DOE estimates that approximately 4
percent of all GFB shipments and approximately 1 percent of ACF
shipments will meet max-tech efficiency levels, in the no-new-standards
case in 2030, the modeled compliance year of new energy conservation
standards. Manufacturers stated that they do not have the necessary
engineers that would be required to convert models that represent
approximately 96 percent of GFB shipments and approximately 99 percent
of ACF shipments into compliant models.
Additionally, most manufacturers stated they would not be able to
provide a full portfolio of fans and blower, covering their current
offering of operating pressure and airflow ranges, for any equipment
class that required max-tech efficiency levels. Most manufacturers
stated that they do not currently have the machinery, technology, or
engineering resources to manufacture these fans and blowers.
Additionally, the few manufacturers that do have the capability of
producing max-tech fans and blowers are not able to produce these fans
and blowers for all necessary operating pressures and airflows that the
market requires and in the volumes that would fulfill the entire fan
and blower markets. Lastly, most
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manufacturers stated that they would not be able to ramp up those
production volumes over the five-year compliance period.
For fan and blower manufacturers to either completely redesign
their fan and blower production lines to be capable of producing max-
tech fans and blowers or to significantly expand their limited max-tech
fan and blower production lines to meet larger production volumes would
require a massive retooling and engineering effort, which would take
more than the five-year compliance period.
DOE estimates there is a strong likelihood of manufacturer capacity
constraints for any equipment classes that require max-tech efficiency
levels.
d. Impacts on Subgroups of Manufacturers
As discussed in section IV.J.1 of this document, using average cost
assumptions to develop an industry cash flow estimate may not be
adequate for assessing differential impacts among manufacturer
subgroups. Small manufacturers, niche manufacturers, and manufacturers
exhibiting a cost structure substantially different from the industry
average could be affected disproportionately. DOE used the results of
the industry characterization to group manufacturers exhibiting similar
characteristics. Consequently, DOE considered three manufacturer
subgroups in the MIA: GFB manufacturers, ACF manufacturers, and small
manufacturers as a subgroup for a separate impact analysis. DOE
discussed the potential impacts on GFB manufacturers and ACF
manufacturers separately in sections V.B.2.a and V.B.2.b.
For the small business subgroup analysis, DOE applied the small
business size standards published by the Small Business Administration
(``SBA'') to determine whether a company is considered a small
business. The size standards are codified at 13 CFR part 121. To be
categorized as a small business under NAICS code 333413, ``industrial
and commercial fan and blower and air purification equipment
manufacturing,'' a fan and blower manufacturer and its affiliates may
employ a maximum of 500 employees. The 500-employee threshold includes
all employees in a business's parent company and any other
subsidiaries. For a discussion of the impacts on the small manufacturer
subgroup, see the Regulatory Flexibility Analysis in section VI.B.
e. Cumulative Regulatory Burden
One aspect of assessing manufacturer burden involves looking at the
cumulative impact of multiple DOE standards and the equipment-specific
regulatory actions of other Federal agencies that affect the
manufacturers of a covered product or equipment. While any one
regulation may not impose a significant burden on manufacturers, the
combined effects of several existing or impending regulations may have
serious consequences for some manufacturers, groups of manufacturers,
or an entire industry. Assessing the impact of a single regulation may
overlook this cumulative regulatory burden. In addition to energy
conservation standards, other regulations can significantly affect
manufacturers' financial operations. Multiple regulations affecting the
same manufacturer can strain profits and lead companies to abandon
product lines or markets with lower expected future returns than
competing products. For these reasons, DOE conducts an analysis of
cumulative regulatory burden as part of its rulemakings pertaining to
appliance efficiency.
DOE requests information regarding the impact of cumulative
regulatory burden on manufacturers of fans and blowers associated with
multiple DOE standards or product-specific regulatory actions of other
Federal agencies.
DOE evaluates product-specific regulations that will take effect
approximately 3 years before or after the estimated 2030 compliance
date of any new energy conservation standards for fans and blowers.
This information is presented in Table V-41.
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MIAQ and AHRI expressed concerns about the HVAC industry burden of
multiple DOE energy conservation standards and safety standards being
passed in close succession, requiring significant retesting to be
performed on equipment. (MIAQ, No. 124 at p. 3-4) and (AHRI, No. 130 at
p.13-14) DOE conducts a cumulative regulatory burden on the
manufactures of the products or equipment that is being regulated, so
for this rulemaking that is a cumulative regulatory burden on fan and
blower manufacturers. Table V-41 lists other products or equipment that
fan and blower manufacturers make that also have a potential DOE energy
conservation standard required within 3 years of the compliance date
for this rulemaking, modeled to be 2030. Additionally, Table III-1
listed products and equipment, including several HVAC equipment that if
they have a fan embedded in the equipment, the fans would be excluded
for this energy conservation standard, if finalized as proposed.
3. National Impact Analysis
This section presents DOE's estimates of the national energy
savings and the NPV of consumer benefits that would result from each of
the TSLs considered as potential amended standards.
a. Significance of Energy Savings
To estimate the energy savings attributable to potential standards
for fans and blowers, DOE compared their energy consumption under the
no-new-standards case to their anticipated energy consumption under
each TSL. The savings are measured over the entire lifetime of products
purchased in the 30-year period that begins in the first full year of
anticipated compliance with new standards (2030-2059). Table V-42 and
Table V-43 present DOE's projections of the national energy savings for
each TSL considered for GFBs and ACFs. The savings were calculated
using the approach described in section IV.H of this document.
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OMB Circular A-4 \127\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis using 9 years, rather than 30
years, of product shipments. The choice of a 9-year period is a proxy
for the timeline in EPCA for the review of certain energy conservation
standards and potential revision of and compliance with such revised
standards.\128\ The review timeframe established in EPCA is generally
not synchronized with the equipment lifetime, equipment manufacturing
cycles, or other factors specific to fans and blowers. Thus, such
results are presented for informational purposes only and are not
indicative of any change in DOE's analytical methodologies. NES
sensitivity analysis results based on a 9-year analytical period are
presented in Table V-44 and Table V-45 for GFBs and ACFs. The impacts
are counted over the lifetime of equipment purchased in 2030-2038.
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\127\ Office of Management and Budget. Circular A-4: Regulatory
Analysis. September 17, 2003. Available at https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf.
\128\ EPCA requires DOE to review its standards at least once
every 6 years, and requires, for certain products, a 3-year period
after any new standard is promulgated before compliance is required,
except that in no case may any new standards be required within 6
years of the compliance date of the previous standards. While adding
a 6-year review to the 3-year compliance period adds up to 9 years,
DOE notes that it may undertake reviews at any time within the 6-
year period and that the 3-year compliance date may yield to the 6-
year backstop. A 9-year analysis period may not be appropriate given
the variability that occurs in the timing of standards reviews and
the fact that for some products, the compliance period is 5 years
rather than 3 years.
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b. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
consumers that would result from the TSLs considered for fans and
blowers. In accordance with OMB's guidelines on regulatory
analysis,\129\ DOE calculated NPV using both a 7-percent and a 3-
percent real discount rate. Table V-46 and Table V-47 show the consumer
NPV results with impacts counted over the lifetime of equipment
purchased in 2030-2059 for GFBs and ACFs.
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\129\ Office of Management and Budget. Circular A-4: Regulatory
Analysis. September 17, 2003. Available at https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf.
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The NPV results based on the aforementioned 9-year analytical
period are presented in Table V-48 and Table V-49 for GFBs and ACFs.
The impacts are counted over the lifetime of products purchased in
2030-2038. As mentioned previously, such results are presented for
informational purposes only and are not indicative of any change in
DOE's analytical methodology or decision criteria.
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The previous results reflect the use of a default trend to estimate
the change in price for fans and blowers over the analysis period (see
section IV.F.1 of this document). DOE also conducted a sensitivity
analysis that considered one scenario with a lower rate of price
decline than the reference case and one scenario with a higher rate of
price decline than the reference case. The results of these alternative
cases are presented in appendix 10C of the NOPR TSD. In the high-price-
decline case, the NPV of consumer benefits is higher than in the
default case. In the low-price-decline case, the NPV of consumer
benefits is lower than in the default case.
c. Indirect Impacts on Employment
It is estimated that new energy conservation standards for fans and
blowers would reduce energy expenditures for consumers of those
products, with the resulting net savings being redirected to other
forms of economic activity. These expected shifts in spending and
economic activity could affect the demand for labor. As described in
section IV.N of this document, DOE used an input/output model of the
U.S. economy to estimate indirect employment impacts of the TSLs that
DOE considered. There are uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Therefore, DOE generated results for near-term timeframes
(2030-2035), where these uncertainties are reduced.
The results suggest that the proposed standards would be likely to
have a negligible impact on the net demand for labor in the economy.
The net change in jobs is so small that it would be imperceptible in
national labor statistics and might be offset by other, unanticipated
effects on employment. Chapter 16 of the NOPR TSD presents detailed
results regarding anticipated indirect employment impacts.
4. Impact on Utility or Performance of Products
As discussed in section III.F.1.d of this document, DOE has
tentatively concluded that the standards proposed in this NOPR would
not lessen the utility or performance of the fans and blowers under
consideration in this rulemaking. Manufacturers of these equipment
currently offer units that meet or exceed the proposed standards.
5. Impact of Any Lessening of Competition
DOE considered any lessening of competition that would be likely to
result from new or amended standards. As discussed in section
III.F.1.e, the Attorney General determines the impact, if any, of any
lessening of competition likely to result from a proposed standard, and
transmits such determination in writing to the Secretary, together with
an analysis of the nature and extent of such impact. To assist the
Attorney General in making this determination, DOE has provided DOJ
with copies of this NOPR and the accompanying NOPR TSD for review. DOE
will consider DOJ's comments on the proposed rule in determining
whether to proceed to a final rule. DOE will publish and respond to
DOJ's comments in that document. DOE invites comment from the public
regarding the competitive impacts that are likely to result from this
proposed rule. In addition, stakeholders may also provide comments
separately to DOJ regarding these potential impacts. See the ADDRESSES
section for information to send comments to DOJ.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the Nation's energy security, strengthens the economy, and reduces the
environmental impacts (costs) of energy production. Reduced electricity
demand due to energy conservation standards is also likely to reduce
the cost of maintaining the reliability of the electricity system,
particularly during peak-load periods. Chapter 15 in the NOPR TSD
presents the estimated impacts on electricity generating capacity,
relative to the no-new-standards case, for the TSLs that DOE considered
in this rulemaking.
Energy conservation resulting from potential energy conservation
standards for fans and blowers is expected to yield environmental
benefits in the form of reduced emissions of certain air pollutants and
greenhouse gases. Table V-50 and Table V-51 provide DOE's estimate of
cumulative emissions reductions expected to result from the TSLs
considered in this rulemaking for GFBs and ACFs, respectively. The
emissions were calculated using the multipliers discussed in section
IV.K of this document. DOE reports annual emissions reductions for each
TSL in chapter 13 of the NOPR TSD.
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As part of the analysis for this rulemaking, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2
that DOE estimated for each of the considered TSLs for GFBs and AFCs.
Section IV.L of this document discusses the SC-CO2 values
that DOE used. Table V-52 and Table V-53 present the value of
CO2 emissions reduction at each TSL for each of the SC-
CO2 cases for GFBs and ACFs, respectively. The time-series
of annual values is presented for the proposed TSL in chapter 14 of the
NOPR TSD.
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[[Page 3834]]
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As discussed in section IV.L.2, DOE estimated the climate benefits
likely to result from the reduced emissions of methane and
N2O that DOE estimated for each of the considered TSLs for
GFBs and ACFs. Table V-54 and Table V-55 present the value of the
CH4 emissions reduction at each TSL for GFBs and ACFs,
respectively, and Table V-56 and Table V-57 present the value of the
N2O emissions reduction at each TSL for GFBs and ACFs,
respectively. The time-series of annual values is presented for the
proposed TSL in chapter 14 of the NOPR TSD.
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DOE is well aware that scientific and economic knowledge continues
to evolve rapidly about the contribution of CO2 and other
GHG emissions to changes in the future global climate and the potential
resulting damages to the global and U.S. economy. DOE, together with
other Federal agencies, will continue to review methodologies for
estimating the monetary value of reductions in CO2 and other
GHG emissions. This ongoing review will consider the comments on this
subject that are part of the public record for this and other
rulemakings, as well as other methodological assumptions and issues.
DOE notes that the proposed standards would be economically justified
even without inclusion of monetized benefits of reduced GHG emissions.
DOE also estimated the monetary value of the health benefits
associated with NOX and SO2 emissions reductions
anticipated to result from the considered TSLs for GFBs and ACFs. The
dollar-per-ton values that DOE used are discussed in section IV.L of
this document. Table V-58 and Table V-59 present the present value for
NOX emissions reduction for each TSL calculated using 7-
percent and 3-percent discount rates, for GFBs and ACFs, respectively;
and Table V-60 and Table V-61 present similar results for
SO2 emissions reductions for GFBs and ACFs, respectively.
The results in these tables reflect application of EPA's low dollar-
per-ton values, which DOE used to be conservative. The time-series of
annual values is presented for the proposed TSL in chapter 14 of the
NOPR TSD.
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Not all the public health and environmental benefits from the
reduction of greenhouse gases, NOX, and SO2 are
captured in the values above, and additional unquantified benefits from
the reductions of those pollutants as well as from the reduction of
direct PM and other co-pollutants may be significant. DOE has not
included monetary benefits of the reduction of Hg emissions because the
amount of reduction is very small.
7. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C 6216(a); 42 U.S.C.
6295(o)(2)(B)(i)(VII)) No other factors were considered in this
analysis.
8. Summary of Economic Impacts
Table V-62 and Table V-63 presents the NPV values that result from
adding the estimates of the potential economic benefits resulting from
reduced GHG and NOX and SO2 emissions to the NPV
of consumer benefits calculated for each TSL considered in this
rulemaking, for GFBs and ACFs, respectively. The consumer benefits are
domestic U.S. monetary savings that occur as a result of purchasing the
covered GFBs and ACFs, and are measured for the lifetime of equipment
shipped in 2030-2059. The climate benefits associated with reduced GHG
emissions resulting from the adopted standards are global benefits, and
are also calculated based on the lifetime of GFBs and ACFs shipped in
2030-2059.
[[Page 3837]]
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[GRAPHIC] [TIFF OMITTED] TP19JA24.109
C. Conclusion
When considering new or amended energy conservation standards, the
standards that DOE adopts for any type (or class) of covered equipment
must be designed to achieve the maximum improvement in energy
efficiency that the Secretary determines is technologically feasible
and economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(A)) In determining whether a standard is economically
justified, the Secretary must determine whether the benefits of the
standard exceed its burdens by, to the greatest extent practicable,
considering the seven statutory factors discussed previously. (42
U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)) The new or amended standard
must also result in significant conservation of energy. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(3)(B))
For this NOPR, DOE considered the impacts of new standards for GFBs
and ACFs at each TSL, beginning with the max-tech feasible level, to
determine whether that level was economically justified. Where the max-
tech level was not justified, DOE then considered the next most
efficient level and undertook the same evaluation until it reached the
highest efficiency level that is both technologically feasible and
economically justified and saves a significant amount of energy.
To aid the reader as DOE discusses the benefits and/or burdens of
each TSL, tables in this section present a summary of the results of
DOE's quantitative analysis for each TSL. In addition to the
quantitative results presented in the tables, DOE also considers other
burdens and benefits that affect economic justification. These include
the impacts on identifiable subgroups of consumers who may be
disproportionately affected by a national standard and impacts on
employment.
1. Benefits and Burdens of TSLs Considered for Fans and Blowers
Standards
a. General Fans and Blowers
Table V-64 and Table V-65 summarize the quantitative impacts
estimated for each TSL for GFBs. The national impacts are measured over
the lifetime of GFBs purchased in the 30-year period that begins in the
anticipated first full year of compliance with new standards (2030-
2059). The energy savings, emissions reductions, and value of emissions
reductions refer to full-fuel-cycle results. The efficiency levels
contained in each TSL are described in section V.A of this document.
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BILLING CODE 6450-01-C
DOE first considered TSL 6, which represents the max-tech
efficiency levels. At TSL 6, DOE expects all equipment classes would
require the highest tier aerodynamic redesign.
TSL 6 would save an estimated 25.3 quads of full-fuel cycle energy,
an amount DOE considers significant. Under TSL 6, the NPV of consumer
benefit would be $15.8 billion using a discount rate of 7 percent, and
$49.3 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 6 are 439.4 Mt of
CO2, 134.1 thousand tons of SO2, 827.9 thousand
tons of NOX, 0.9 tons of Hg, 3,811.3 thousand tons of
CH4, and 4.2 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 6 is $21.4 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 6 is $14.8 billion using a 7-percent discount rate and $42.4
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 6 is $52.0
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 6 is $113.2 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 6, for the largest equipment classes, which are represented
by axial panel fans, centrifugal housed fans, and centrifugal unhoused
fans--which together represent approximately 85 percent of annual
shipments--there is a life-cycle cost savings of $1,902, $2,398, and
$2,004 and a payback period of 2.5 years, 3.1 years, and 1.0 years,
respectively. For these equipment classes, the fraction of customers
experiencing a net LCC cost is 29.9 percent, 41.5 percent, and 13.7
percent due to increases in total installed cost of $618, $1,090 and
$215, respectively. The life-cycle costs savings are negative for axial
inline fans, axial PRV, and centrifugal PRV exhaust, and equal to -
$2,169, -$9,470, and -$1,992. For these equipment classes the payback
is 17.9, 32.9 and 22.8 years and the fraction of customers experiencing
a net LCC cost is 79.4 percent, 89.0 percent, and 84.7 percent. The
life-cycle costs savings for centrifugal inline, centrifugal PRV
supply, and radial housed fans are positive and equal to $335, $1,126,
and $5,391, respectively. For these equipment classes the payback is
9.1, 2.8, and 2.2 years and the fraction of customers experiencing a
net LCC cost is 66.7 percent, 32.3 percent, and 24.4 percent. At TSL 6,
the shipments-weighted average LCC is equal to $1,751, the payback
period is equal to 3.8 and the fraction of customers experiencing a net
LCC cost is 32.8 percent.
At TSL 6, the projected change in INPV ranges from a decrease of
$2,287 million to an increase of $40 million, which corresponds to a
decrease of 46.4 percent and an increase of 0.8 percent, respectively.
DOE estimates that
[[Page 3841]]
industry must invest $3,750 million to conduct aerodynamic redesigns on
all equipment classes to comply with standards set at TSL 6. An
investment of $3,750 million in conversion costs represents
approximately 1.3 times the sum of the annual free cash flows over the
years between the estimated final rule announcement date and the
estimated standards year (i.e., the time period that these conversion
costs would be incurred) and represents over 75 percent of the entire
no-new-standards case INPV over the 30-year analysis period.\130\
---------------------------------------------------------------------------
\130\ The sum of annual free cash flows is estimated to be
$2,348 million for 2025-2029 in the no-new-standards case and the
no-new-standards case INPV is estimated to be $4,935 million.
---------------------------------------------------------------------------
In the no-new-standards case, free cash flow is estimated to be
$480 million in 2029, the year before the modeled compliance date. At
TSL 6, the estimated free cash flow is -$1,132 million in 2029. This
represents a decrease in free cash flow of 336 percent, or a decrease
of $1,612 million, in 2029. A negative free cash flow implies that
most, if not all, manufacturers will need to borrow substantial funds
to be able to make investments necessary to comply with energy
conservation standards at TSL 6. The extremely large drop in free cash
flows could cause some GFB manufacturers to discontinue certain
products offerings and shift their resources to other business units
not impacted by this rule, even though recovery may be possible over
the 30-year analysis period. DOE is concerned about the uncertainty of
the market that may exists at TSL 6 if manufacturers choose not to
maintain their full product offerings in response to the investments
needed to support TSL 6. Additionally, most small businesses will
struggle to secure this funding, due to their size and the uncertainty
of recovering their investments. At TSL 6, models representing 4
percent of all GFB shipments are estimated to meet the efficiency
requirements at this TSL in the no-new-standards case by 2030, the
modeled compliance year. Therefore, models representing 96 percent of
all GFB shipments will need be remodeled in the 5-year compliance
period.
Manufacturers are unlikely to have the engineering capacity to
conduct this massive redesign effort in 5 years. Instead, they will
likely prioritize redesigns based on sales volume, which could leave
market gaps in equipment offered by manufacturers and even the entire
industry. The resulting market gaps in equipment offerings could result
in sub-optimal selection of fan duty points (airflow, pressure, speed
combination) for some applications, potentially leading to a reduction
in the estimated energy savings, and estimated consumer benefits, at
this TSL. Most small businesses will be at a competitive disadvantage
at this TSL because they have less technical and financial resources
and the capital investments required will be spread over fewer units.
The Secretary tentatively concludes that at TSL 6 for GFBs, the
benefits of energy savings, positive NPV of consumer benefits, emission
reductions, and the estimated monetary value of the emissions
reductions would be outweighed by the economic burden on many
consumers, and the impacts on manufacturers, including the extremely
large conversion costs (representing approximately 1.3 times the sum of
the annual free cash flows during the time period that these conversion
costs will be incurred and are approximately equal to 75 percent of the
entire no-new-standards case INPV), profitability impacts that could
result in a large reduction in INPV (up to a decrease of 46.4 percent),
the large negative free cash flows in the years leading up to the
compliance date (annual free cash flow is estimated to be -$1,132
million in the year before the compliance date), the lack of
manufacturers currently offering equipment meeting the efficiency
levels required at this TSL (models representing 96 percent of
shipments will need to be redesigned to meet this TSL), including most
small businesses, and the likelihood of the significant disruption in
the GFB market. Due to the limited amount of engineering resources each
manufacturer has, it is unclear if most manufacturers will be able to
redesign models representing on average 96 percent of their GFB
shipments covered by this rulemaking in the 5-year compliance period.
Consequently, the Secretary has tentatively concluded that TSL 6 is not
economically justified.
DOE then considered TSL 5, which represents a combination of the
highest efficiency levels resulting in positive life-cycle costs
savings. At TSL 5, DOE expects all equipment classes, except for axial
PRVs, would require an aerodynamic redesign. Axial panel, centrifugal
housed, centrifugal inline, centrifugal unhoused, centrifugal PRV
supply, and radial housed fans would all require the highest tier
aerodynamic redesign. Axial inline and centrifugal PRV exhaust fans
would require the second to highest tier aerodynamic redesign. Axial
PRV fans would require two size increases in diameter.
TSL 5 would save an estimated 23.7 quads of energy, an amount DOE
considers significant. Under TSL 5, the NPV of consumer benefit would
be $19.2 billion using a discount rate of 7 percent, and $54.8 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 5 are 411.5 Mt of
CO2, 125.6 thousand tons of SO2, 775.1 thousand
tons of NOX, 0.9 tons of Hg, 3,567.0 thousand tons of
CH4, and 3.9 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 5 is $20.2 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 5 is $14.0 billion using a 7-percent discount rate and $39.9
billion using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 5 is $53.4
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 5 is $115.0 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 5, for the largest equipment classes (which are represented
by axial panel fans, centrifugal housed fans, and centrifugal unhoused
fans) the standards are set at the max-tech EL as with TSL 6. There is
a life-cycle cost savings of $1,902, $2,398, and $2,004 and a payback
period of 2.5 years, 3.1 years, and 1.0 years, respectively. For these
equipment classes, the fraction of customers experiencing a net LCC
cost is 29.9 percent, 41.5 percent, and 13.7 percent due to increases
in total installed cost of $618, $1,090 and $215, respectively. The
life-cycle costs savings for axial inline, centrifugal inline, and
radial housed fans are positive and equal to $670, $335, and $5,391,
respectively. For these equipment classes the payback is 9.8, 9.1, and
2.2 years and the fraction of customers experiencing a net LCC cost is
51.3 percent, 66.7 percent, and 24.4 percent. The life-cycle costs
savings for axial PRVs, centrifugal PRV exhaust, and centrifugal PRV
supply fans are positive and equal to $945, $154, and $1,126,
respectively. For these equipment classes the payback is 7.0, 8.9, and
2.8 years and the fraction of customers
[[Page 3842]]
experiencing a net LCC cost is 14.3 percent, 25.8 percent, and 32.3
percent. At TSL5, the shipments-weighted average LCC is equal to
$2,030, the payback period is equal to 2.9 and the fraction of
customers experiencing a net LCC cost is 30.2 percent.
At TSL 5, the projected change in INPV ranges from a decrease of
$1,263 million to an increase of $11 million, which corresponds to a
decrease of 25.6 percent and an increase of 0.2 percent, respectively.
DOE estimates that industry must invest $2,075 million to conduct
aerodynamic redesigns on all equipment classes except axial PRVs and to
increase the diameter by two sizes for axial PRVs to comply with
standards set at TSL 5. An investment of $2,075 million in conversion
costs represents approximately 90 percent of the sum of the annual free
cash flows over the years between the estimated final rule announcement
date and the estimated standards year (i.e., the time period that these
conversion costs would be incurred) and represents over 42 percent of
the entire no-new-standards case INPV over the 30-year analysis
period.\131\
---------------------------------------------------------------------------
\131\ The sum of annual free cash flows is estimated to be
$2,348 million for 2025-2029 in the no-new-standards case and the
no-new-standards case INPV is estimated to be $4,935 million.
---------------------------------------------------------------------------
In the no-new-standards case, free cash flow is estimated to be
$480 million in 2029, the year before the modeled compliance date. At
TSL 5, the estimated free cash flow is -$407 million in 2029. This
represents a decrease in free cash flow of 185 percent, or a decrease
of $887 million, in 2029. A negative free cash flow implies that most,
if not all, manufacturers will need to borrow substantial funds to be
able to make investments necessary to comply with energy conservation
standards at TSL 5. The large drop in free cash flows could cause some
GFB manufacturers to exit the GFB market entirely, even though recovery
may be possible over the 30-year analysis period. Additionally, most
small businesses will struggle to secure this funding due to their size
and the uncertainty of recovering their investments. At TSL 5, models
representing 7 percent of all GFB shipments are estimated to meet or
exceed the efficiency requirements at this TSL in the no-new-standards
case by 2030, the modeled compliance year. Therefore, models
representing 93 percent of all GFB shipments will need to be remodeled
in the 5-year compliance period.
Manufacturers are unlikely to have the engineering capacity to
conduct this massive redesign effort in 5 years. Instead, they will
likely prioritize redesigns based on sales volume, which could leave
market gaps in equipment offered by manufacturers and even the entire
industry. The resulting market gaps in equipment offerings could result
in sub-optimal selection of fan duty points (airflow, pressure, speed
combination) for some applications, potentially leading to a reduction
in the estimated energy savings, and estimated consumer benefits, at
this TSL. Most small businesses will be at a competitive disadvantage
at this TSL because they have less technical and financial resources
and the capital investments required will be spread over fewer units.
The Secretary tentatively concludes that at TSL 5 for GFBs, the
benefits of energy savings, the economic benefits on many consumers,
positive NPV of consumer benefits, emission reductions, and the
estimated monetary value of the emissions reductions would be
outweighed by the impacts on manufacturers, including the extremely
large conversion costs (representing approximately 90 percent of the
sum of the annual free cash flows during the time period these
conversion costs will be incurred and are approximately equal to 42
percent of the entire no-new-standards case INPV), profitability margin
impacts that could result in a large reduction in INPV (up to a
decrease of 25.6 percent), the large negative free cash flows in the
years leading up to the compliance date (annual free cash flow is
estimated to be -$407 million in the year before the compliance date),
the lack of manufacturers currently offering equipment meeting the
efficiency levels required at this TSL (models representing 93 percent
of all GFB shipments will need to be redesigned to meet this TSL),
including most small businesses, and the likelihood of the significant
disruption in the GFB market. Due to the limited amount of engineering
resources each manufacturer has, it is unclear if most manufacturers
will be able to redesign models representing on average 93 percent of
their GFB shipments covered by this rulemaking in the 5-year compliance
period. Consequently, the Secretary has tentatively concluded that TSL
5 is not economically justified.
DOE then considered TSL 4, which represents an intermediate level
that is one efficiency level below TSL 5 for each equipment class. At
TSL 4, DOE expects all equipment classes, except for axial PRVs, would
require an aerodynamic redesign. Axial panel, centrifugal housed,
centrifugal inline, centrifugal unhoused, centrifugal PRV supply, and
radial housed fans would all require the second highest tier
aerodynamic redesign. Axial inline fans would require the lowest tier
aerodynamic redesign. Centrifugal PRV exhaust fans would require the
second to lowest tier aerodynamic redesign. Axial PRV fans would
require one size increase in diameter.
TSL 4 would save an estimated 13.8 quads of energy, an amount DOE
considers significant. Under TSL 4, the NPV of consumer benefit would
be $13.7 billion using a discount rate of 7 percent, and $36.9 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 4 are 239.4 Mt of
CO2, 73.1 thousand tons of SO2, 450.9 thousand
tons of NOX, 0.5 tons of Hg, 2,073.9 thousand tons of
CH4, and 2.3 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 4 is $11.9 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 5 is $8.2 billion using a 7-percent discount rate and $23.4 billion
using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 4 is $33.8
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 4 is $72.2 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 4, for the largest equipment classes which are represented
by axial panel fans, centrifugal housed fans, and centrifugal unhoused
fans; there is a life-cycle cost savings of $1,702, $2,423, and $1,170;
and a payback period of 1.7 years, 0.6 years, and 1.2 years,
respectively. For these equipment classes, the fraction of customers
experiencing a net LCC cost is 19.5 percent, 12.9 percent, and 10.5
percent due to increases in total installed cost of $293, $134 and
$135, respectively. The life-cycle costs savings for axial inline,
centrifugal inline, and radial housed fans are positive and equal to
$550, $955, and $3,714, respectively. For these equipment classes the
payback is 9.6, 6.1, and 1.7 years and the fraction of customers
experiencing a net LCC cost is 23.6 percent, 49.2 percent, and
[[Page 3843]]
13.3 percent. The life-cycle costs savings for axial PRVs, centrifugal
PRV exhaust, and centrifugal PRV supply fans are positive and equal to
$945, $154, and $973, respectively. For these equipment classes the
payback is 7.0, 8.9, and 1.7 years and the fraction of customers
experiencing a net LCC cost is 14.3 percent, 25.8 percent, and 24.9
percent At TSL 4, the shipment-weighted average LCC is equal to $1,694,
the payback period is equal to 1.8 and the fraction of customers
experiencing a net LCC cost is 15.7 percent.
At TSL 4, the projected change in INPV ranges from a decrease of
$455 million to an increase of $1 million, which corresponds to a
decrease of 9.2 percent and an increase of less than 0.1 percent,
respectively. DOE estimates that industry must invest $770 million to
comply with standards set at TSL 4. An investment of $770 million in
conversion costs represents approximately 33 percent of the sum of the
annual free cash flows over the years between the estimated final rule
announcement date and the estimated standards year (i.e., the time
period that these conversion costs would be incurred) and represents
over 15 percent of the entire no-new-standards case INPV over the 30-
year analysis period.\132\
---------------------------------------------------------------------------
\132\ The sum of annual free cash flows is estimated to be
$2,348 million for 2025-2029 in the no-new-standards case and the
no-new-standards case INPV is estimated to be $4,935 million.
---------------------------------------------------------------------------
In the no-new-standards case, free cash flow is estimated to be
$480 million in 2029, the year before the modeled compliance date. At
TSL 4, the estimated free cash flow is $161 million in 2029. This
represents a decrease in free cash flow of 66.4 percent, or a decrease
of $319 million, in 2029. Annual cash flows remain positive for all
years leading up to the modeled compliance date. At TSL 4, models
representing 25 percent of all GFB shipments are estimated to meet or
exceed the efficiency requirements at this TSL in the no-new-standards
case by 2030, the modeled compliance year. Therefore, models
representing 75 percent of all GFB shipments will need to be remodeled
in the 5-year compliance period. DOE estimates that while this
represents a significant redesign effort, most GFB manufacturers will
have the engineering capacity to complete these redesigns in a 5-year
compliance period.
After considering the analysis and weighing the benefits and
burdens, the Secretary has tentatively concluded that a standard set at
TSL 4 for GFBs would be economically justified. At this TSL, the
average LCC savings for all GFB equipment class consumers is positive.
An estimated 15.7 percent of consumers experience a net cost. The FFC
national energy savings are significant and the NPV of consumer
benefits is positive using both a 3-percent and 7-percent discount
rate. Notably, the benefits to consumers vastly outweigh the cost to
manufacturers. At TSL 4, the NPV of consumer benefits, even measured at
the more conservative discount rate of 7 percent is over 30 times
higher than the maximum estimated manufacturers' loss in INPV. The
standard levels at TSL 4 are economically justified even without
weighing the estimated monetary value of emissions reductions. When
those emissions reductions are included--representing $11.9 billion in
climate benefits (associated with the average SC-GHG at a 3-percent
discount rate), and $23.4 billion (using a 3-percent discount rate) or
$8.2 billion (using a 7-percent discount rate) in health benefits--the
rationale for setting standards at TSL 4 for GFBs is further
strengthened. Additionally, the impact to manufacturers is
significantly reduced at TSL 4. While manufacturers have to invest $770
million to comply with standards at TSL 4, annual free cash flows
remain positive for all years leading up to the compliance date.
Lastly, DOE estimates that most GFB manufacturers will have the
engineering capacity to complete these redesigns in a 5-year compliance
period.
As stated, DOE conducts the walk-down analysis to determine the TSL
that represents the maximum improvement in energy efficiency that is
technologically feasible and economically justified as required under
EPCA. The walk-down is not a comparative analysis, as a comparative
analysis would result in the maximization of net benefits instead of
energy savings that are technologically feasible and economically
justified, which would be contrary to the statute. 86 FR 70892, 70908.
While DOE recognizes that TSL 4 is not the TSL that maximizes net
monetized benefits, DOE has weighed other non-quantified and non-
monetized factors in accordance with EPCA in reaching this
determination. DOE notes that as compared to TSL 5 and TSL 6, TSL 4 has
significantly smaller percentages of GFBs consumers experiencing a net
cost, a lower simple payback period, a lower maximum decrease in INPV,
lower manufacturer conversion costs, and significantly less likelihood
of a major disruption to the GFB market, as DOE does not anticipate
gaps in GFB equipment offerings at TSL 4.
Although DOE considered proposed new standard levels for GFBs by
grouping the efficiency levels for each equipment class into TSLs, DOE
evaluates all analyzed efficiency levels in its analysis. For all
equipment classes, TSL 4 represents the maximum energy savings that
does not result in significant negative economic impacts to GFB
manufacturers. At TSL 4 conversion costs are estimated to be $770
million, significantly less than at TSL 5 ($2,075 million) and at TSL 6
($3,750 million). At TSL 4 conversion costs represent a significantly
smaller size of the sum of GFB manufacturers' annual free cash flows
for 2025 to 2029 (33 percent), than at TSL 5 (90 percent) and at TSL 6
(130 percent) and a significantly smaller portion of GFB manufacturers'
no-new-standards case INPV (15 percent), than at TSL 5 (42 percent) and
at TSL 6 (75 percent). At TSL 4, GFB manufacturers will have to
redesign a significantly smaller portion of their GFB models to meet
the ELs set at TSL 4 (models representing 75 percent of all GFB
shipments), than at TSL 5 (93 percent) and at TSL 6 (96 percent).
Lastly, GFB manufacturers' free cash flow remains positive at TSL 4 for
all years leading up to the compliance date. Whereas at TSL 5 annual
free cash flow is estimated to be -$407 million and at TSL 6 annual
free cash flow is estimated to be -$1,132 million in 2029, the year
before the modeled compliance year. The ELs at the proposed TSL result
in average positive LCC savings for all equipment classes,
significantly reduce the number of consumers experiencing a net cost,
and reduce the decrease in INPV and conversion costs to the point where
DOE has concluded they are economically justified, as discussed for TSL
4 in the preceding paragraphs.
Therefore, based on the previous considerations, DOE proposes to
adopt the energy conservation standards for GFBs at TSL 4. The proposed
energy conservation standards for GFBs, which are expressed as FEI
values, are shown in Table V-66.
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[[Page 3844]]
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[GRAPHIC] [TIFF OMITTED] TP19JA24.114
[[Page 3845]]
DOE is proposing an FEI level of 0.85 (EL4) for axial PRVs. In
section IV.C.1.b, DOE developed the MSP-efficiency relationship based
on data from the AMCA sales database as well as performance data from
manufacturer fan selection software and performance data provided from
confidential manufacturer interviews. From its analysis, DOE estimated
that EL4 for axial PRVs would be achieved by implementing two impeller
diameter increases. Based on the MSP-efficiency results, EL4 for axial
PRVs is the highest level with positive life-cycle costs savings.
Furthermore, as discussed in section IV.C.1.b, ASHRAE 90.1-2022 set an
FEI target of 1.00 for all fans within the scope of that standard,
which includes axial PRVs. CEC requires manufacturers to report fan
operating boundaries that result in operation at a FEI of greater than
or equal to 1.00 for all fans within the scope of that rulemaking,
which includes axial PRVs. DOE also notes that, based on its shipments
analysis, 50-percent of axial PRVs have an FEI of at least 1.00.
Additionally, based on its review of the market, DOE has found that
most manufacturers offer models of APRVs that have an FEI of at least
1.00 at a range of diameters. Based on this, DOE expects that the
market is already shifting towards an FEI of 1.00 for axial PRVs and
that this level may not be unduly burdensome for manufacturers to
achieve.
DOE requests comment on the proposed standard level for axial PRVs,
including the design options and costs, as well as the burdens and
benefits associated with this level and the industry standards/
California regulations FEI level of 1.00.
b. Air Circulating Fans
Table V-68 and Table V-69 summarize the quantitative impacts
estimated for each TSL for ACFs. The national impacts are measured over
the lifetime of ACFs purchased in the 30-year period that begins in the
anticipated first full year of compliance with new standards (2030-
2059). The energy savings, emissions reductions, and value of emissions
reductions refer to full-fuel-cycle results. The efficiency levels
contained in each TSL are described in section V.A of this document.
[[Page 3846]]
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[[Page 3847]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.116
BILLING CODE 6450-01-C
DOE first considered TSL 6, which represents the max-tech
efficiency levels. At TSL 6, DOE expects all equipment classes would
require an
[[Page 3848]]
ECM. TSL 6 would save an estimated 7.2 quads of energy, an amount DOE
considers significant. Under TSL 6, the NPV of consumer benefit would
be $5.7 billion using a discount rate of 7 percent, and $14.5 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 6 are 125.8 Mt of
CO2, 31.5 thousand tons of SO2, 237.2 thousand
tons of NOX, 0.2 tons of Hg, 1,100.4 thousand tons of
CH4, and 1.0 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 6 is $7.1 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 6 is $5.0 billion using a 7-percent discount rate and $13.1 billion
using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 6 is $17.7
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 6 is $34.7 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 6, for the largest equipment classes, which are represented
by ACF1, ACF2, and ACF3--which together represent approximately 99
percent of annual shipments--there is a life-cycle cost savings of
$126, $346, and $630 and a payback period of 3.1 years, 1.9 years, and
1.4 years, respectively. For these equipment classes, the fraction of
customers experiencing a net LCC cost is 45.1 percent, 23.6 percent,
and 11.3 percent due to increases in total installed cost of $187, $201
and $222, respectively. For the remaining equipment class (ACF4), the
average LCC savings are -$1,210, a majority of consumers (99.7 percent)
would experience a net cost and the payback period is 25.0 years.
At TSL 6, the projected change in INPV ranges from a decrease of
$734 million to an increase of $3 million, which corresponds to
decreases of 113.1 percent and an increase of 0.5 percent,
respectively. DOE estimates that industry must invest $1,167 million to
conduct aerodynamic redesigns on all equipment classes and to implement
ECMs for all equipment classes to comply with standards set at TSL 6.
An investment of $1,167 million in conversion costs represents over 5
times the sum of the annual free cash flows over the years between the
estimated final rule announcement date and the estimated standards year
(i.e., the time period that these conversion costs would be incurred)
and represents approximately 1.8 times the entire no-new-standards case
INPV over the 30-year analysis period.\133\
---------------------------------------------------------------------------
\133\ The sum of annual free cash flows is estimated to be $227
million for 2025-2029 in the no-new-standards case and the no-new-
standards case INPV is estimated to be $649 million.
---------------------------------------------------------------------------
In the no-new-standards case, free cash flow is estimated to be $51
million in 2029, the year before the modeled compliance date. At TSL 6,
the estimated free cash flow is -$456 million in 2029. This represents
a decrease in free cash flow of 999 percent, or a decrease of $507
million, in 2029. A negative free cash flow implies that most, if not
all, manufacturers will need to borrow substantial funds to be able to
make investments necessary to comply with energy conservation standards
at TSL 6. The extremely large drop in free cash flows could cause some
ACF manufacturers to exit the ACF market entirely, even though recovery
may be possible over the 30-year analysis period. Additionally, most
small businesses will struggle to secure this funding, due to their
size and the uncertainty of recovering their investments. At TSL 6,
models representing 1 percent of all ACF shipments are estimated to
meet the efficiency requirements at this TSL in the no-new-standards
case by 2030, the modeled compliance year. Therefore, models
representing 99 percent of all ACF shipments will need to be remodeled
in the 5-year compliance period.
Manufacturers are unlikely to have the engineering capacity to
conduct this massive redesign effort in 5 years. Instead, they will
likely prioritize redesigns based on sales volume, which could leave
market gaps in equipment offered by manufacturers and even the entire
industry. The resulting market gaps in equipment offerings could result
in sub-optimal selection of fan duty points (airflow, pressure, speed
combination) for some applications, potentially leading to a reduction
in the estimated energy savings, and estimated consumer benefits, at
this TSL. Most small businesses will be at a competitive disadvantage
at this TSL because they have less technical and financial resources
and the capital investments required will be spread over fewer units.
The Secretary tentatively concludes that at TSL 6 for ACFs, the
benefits of energy savings, the economic benefits on many consumers,
positive NPV of consumer benefits, emission reductions, and the
estimated monetary value of the emissions reductions would be
outweighed by the impacts on manufacturers, including the extremely
large conversion costs (representing approximately 5 times the sum of
the annual free cash flows during the time period that these conversion
costs will be incurred and are approximately equal to 1.8 times the
entire no-new-standards case INPV), profitability impacts that could
result in a large reduction in INPV (up to a decrease of 113.1
percent), the large negative free cash flows in the years leading up to
the compliance date (annual free cash flow is estimated to be -$456
million in the year before the compliance date), the lack of
manufacturers currently offering equipment meeting the efficiency
levels required at TSL 6 (models representing 99 percent of all ACF
shipments will need to be redesigned to meet this TSL), including most
small businesses, and the likelihood of the significant disruption in
the ACF market. Due to the limited amount of engineering resources each
manufacturer has, it is unclear if most manufacturers will be able to
redesign models representing on average 99 percent of their ACF
shipments covered by this rulemaking in the 5-year compliance period.
Consequently, the Secretary has tentatively concluded that TSL 6 is not
economically justified.
DOE then considered TSL 5, which represents the highest EL below
max-tech with positive LCC savings and is a combination of efficiency
level 5 for axial ACFs and efficiency level 3 for housed centrifugal
ACFs. At TSL 5, DOE expects that axial ACFs would require the highest
tier of aerodynamic redesign and housed centrifugal ACFs would require
the lowest tier of aerodynamic redesign. TSL 5 would save an estimated
6.5 quads of energy, an amount DOE considers significant. Under TSL 5,
the NPV of consumer benefit would be $5.2 billion using a discount rate
of 7 percent, and $13.1 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 5 are 112.6 Mt of
CO2, 28.2 thousand tons of SO2, 212.2 thousand
tons of NOX, 0.2 tons of Hg, 984.6 thousand tons of
CH4, and 0.9 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated
[[Page 3849]]
with the average SC-GHG at a 3-percent discount rate) at TSL 5 is $6.3
billion. The estimated monetary value of the health benefits from
reduced SO2 and NOX emissions at TSL 5 is $4.5
billion using a 7-percent discount rate and $11.7 billion using a 3-
percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 5 is $16.0
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 5 is $31.1 billion. The estimated total
NPV is provided for additional information, however DOE primarily
relies upon the NPV of consumer benefits when determining whether a
proposed standard level is economically justified.
At TSL 5, for the largest equipment classes, which are represented
by ACF1, ACF2, and ACF3--which together represent approximately 99
percent of annual shipments--there is a life-cycle cost savings of
$141, $341, and $613 and a payback period of 2.8 years, 1.6 years, and
1.1 years, respectively. For these equipment classes, the fraction of
customers experiencing a net LCC cost is 40.4 percent, 22.7 percent,
and 9.3 percent due to increases in total installed cost of $148, $156
and $155, respectively. For the remaining equipment class (ACF4), the
average LCC savings are $18 and 14.1 percent of consumers would
experience a net cost and the payback period is 4.8 years.
At TSL 5, the projected change in INPV ranges from a decrease of
$633 million to an increase of $3 million, which corresponds to a
decrease of 97.5 percent and an increase of 0.5 percent, respectively.
DOE estimates that industry must invest $1,043 million to conduct
significant aerodynamic redesigns for non-compliant axial ACFs and
minor aerodynamic redesign for non-compliant housed centrifugal ACFs to
comply with standards set at TSL 5. An investment of $1,043 million in
conversion costs represents over 4.5 times the sum of the annual free
cash flows over the years between the estimated final rule announcement
date and the estimated standards year (i.e., the time period that these
conversion costs would be incurred) and represents approximately 1.6
times the entire no-new-standards case INPV over the 30-year analysis
period.\134\
---------------------------------------------------------------------------
\134\ The sum of annual free cash flows is estimated to be $227
million for 2025-2029 in the no-new-standards case and the no-new-
standards case INPV is estimated to be $649 million.
---------------------------------------------------------------------------
In the no-new-standards case, free cash flow is estimated to be $51
million in 2029, the year before the modeled compliance date. At TSL 5,
the estimated free cash flow is -$400 million in 2029. This represents
a decrease in free cash flow of 889 percent, or a decrease of $451
million, in 2029. A negative free cash flow implies that most, if not
all, manufacturers will need to borrow substantial funds to be able to
make investments necessary to comply with energy conservation standards
at TSL 5. The large drop in free cash flows could cause some ACF
manufacturers to exit the ACF market entirely, even though recovery may
be possible over the 30-year analysis period. Additionally, most small
businesses will struggle to secure this funding, due to their size and
the uncertainty of recovering their investments. At TSL 5, models
representing 4 percent of all ACF shipments are estimated to meet or
exceed the efficiency requirements at this TSL in the no-new-standards
case by 2030, the modeled compliance year. Therefore, models
representing 96 percent of all ACF shipments will need to be remodeled
in the 5-year compliance period.
Manufacturers are unlikely to have the engineering capacity to
conduct this massive redesign effort in 5 years. Instead, they will
likely prioritize redesigns based on sales volume, which could leave
market gaps in equipment offered by manufacturers and even the entire
industry. The resulting market gaps in equipment offerings could result
in sub-optimal selection of fan duty points (airflow, pressure, speed
combination) for some applications, potentially leading to a reduction
in the estimated energy savings, and estimated consumer benefits, at
this TSL. Most small businesses will be at a competitive disadvantage
at this TSL because they have less technical and financial resources
and the capital investments required will be spread over fewer units.
The Secretary tentatively concludes that at TSL 5 for ACFs, the
benefits of energy savings, the economic benefits on many consumers,
positive NPV of consumer benefits, emission reductions, and the
estimated monetary value of the emissions reductions would be
outweighed by the impacts on manufacturers, including the extremely
large conversion costs (representing approximately 4.5 times the sum of
the annual free cash flows during the time period that these conversion
costs will be incurred and are approximately equal to 1.6 times the
entire no-new-standards case INPV), profitability impacts that could
result in a large reduction in INPV (up to a decrease of 97.5 percent),
the large negative free cash flows in the years leading up to the
compliance date (annual free cash flow is estimated to be -$400 million
in the year before the compliance date), the lack of manufacturers
currently offering equipment meeting the efficiency levels required at
TSL 5 (models representing 96 percent of all ACF shipments will need to
be redesigned to meet this TSL), including most small businesses, and
the likelihood of the significant disruption in the ACF market. Due to
the limited amount of engineering resources each manufacturer has, it
is unclear if most manufacturers will be able to redesign models
representing on average 96 percent of their ACF shipments covered by
this rulemaking in the 5-year compliance period. Consequently, the
Secretary has tentatively concluded that TSL 5 is not economically
justified.
DOE then considered TSL 4, which represents efficiency level 4 for
axial ACFs and efficiency level 0 for housed centrifugal ACFs (no new
standards for housed centrifugal ACFs). DOE expects that the second
highest tier of aerodynamic redesign would be required for axial ACFs
at TSL 4 would save an estimated 4.5 quads of energy, an amount DOE
considers significant. Under TSL 4, the NPV of consumer benefit would
be $5.3 billion using a discount rate of 7 percent, and $12.6 billion
using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 4 are 78.5 Mt of
CO2, 19.7 thousand tons of SO2, 148.0 thousand
tons of NOX, 0.1 tons of Hg, 686.7 thousand tons of
CH4, and 0.6 thousand tons of N2O. The estimated
monetary value of the climate benefits from reduced GHG emissions
(associated with the average SC-GHG at a 3-percent discount rate) at
TSL 4 is $4.4 billion. The estimated monetary value of the health
benefits from reduced SO2 and NOX emissions at
TSL 4 is $3.1 billion using a 7-percent discount rate and $8.2 billion
using a 3-percent discount rate.
Using a 7-percent discount rate for consumer benefits and costs,
health benefits from reduced SO2 and NOX
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated total NPV at TSL 4 is $12.8
billion. Using a 3-percent discount rate for all benefits and costs,
the estimated total NPV at TSL 4 is $25.2 billion. The estimated total
NPV is provided for
[[Page 3850]]
additional information, however DOE primarily relies upon the NPV of
consumer benefits when determining whether a proposed standard level is
economically justified.
At TSL 4, for the largest equipment classes, which are represented
by ACF1, ACF2, and ACF3--which together represent approximately 99
percent of annual shipments--there is a life-cycle cost savings of
$327, $478, and $668 and a payback period of 0.5 years, 0.2 years, and
0.1 years, respectively. For these equipment classes, the fraction of
customers experiencing a net LCC cost is 0.2 percent, 0 percent, and 0
percent due to increases in total installed cost of $16, $14, and $15,
respectively. For the remaining equipment class (ACF4), the considered
TSL would not set any energy conservation standards.
At TSL 4, the projected change in INPV ranges from a decrease of
$71 million to an increase of less than $0.1 million, which correspond
to a decrease of 10.9 percent and an increase of less than 0.1 percent,
respectively. DOE estimates that industry must invest $118.1 million to
implement the second highest tier of aerodynamic redesign for axial
ACFs to comply with standards set at TSL 4. An investment of $118.1
million in conversion costs represents approximately 50 percent of the
sum of the annual free cash flows over the years between the estimated
final rule announcement date and the estimated standards year (i.e.,
the time period that these conversion costs would be incurred) and
represents over 18 percent of the entire no-new-standards case INPV
over the 30-year analysis period.\135\
---------------------------------------------------------------------------
\135\ The sum of annual free cash flows is estimated to be $227
million for 2025-2029 in the no-new-standards case and the no-new-
standards case INPV is estimated to be $649 million.
---------------------------------------------------------------------------
In the no-new-standards case, free cash flow is estimated to be $51
million in 2029, the year before the modeled compliance date. At TSL 4,
the estimated free cash flow is $1 million in 2029. This represents a
decrease in free cash flow of 99.0 percent, or a decrease of $50.2
million, in 2029. Annual cash flows remain positive for all years
leading up to the modeled compliance date. At TSL 4, models
representing 36 percent of all ACF shipments are estimated to meet or
exceed the efficiency requirements at this TSL in the no-new-standards
case by 2030, the modeled compliance year. Therefore, models
representing 64 percent of all ACF shipments will need to be remodeled
in the 5-year compliance period. DOE estimates that while this
represents a significant redesign effort, most ACF manufacturers will
have the engineering capacity to complete these redesigns in a 5-year
compliance period.
After considering the analysis and weighing the benefits and
burdens, the Secretary has tentatively concluded that at a standard set
at TSL 4 for ACFs would be economically justified. While DOE recognizes
that TSL 4 is not the TSL that maximizes net monetized benefits, DOE
has weighed other non-quantified and non-monetized factors in
accordance with EPCA in reaching this determination. At this TSL, the
average LCC savings for all ACF consumers are positive. An estimated
0.1 percent of consumers experience a net cost. The FFC national energy
savings are significant and the NPV of consumer benefits is positive
using both a 3-percent and 7-percent discount rate. Notably, the
benefits to consumers vastly outweigh the cost to manufacturers. At TSL
4, the NPV of consumer benefits, even measured at the more conservative
discount rate of 7 percent is over 74 times higher than the maximum
estimated manufacturers' loss in INPV. The standard levels at TSL 4 are
economically justified even without weighing the estimated monetary
value of emissions reductions. When those emissions reductions are
included--representing $4.4 billion in climate benefits (associated
with the average SC-GHG at a 3-percent discount rate), and $8.2 billion
(using a 3-percent discount rate) or $3.1 billion (using a 7-percent
discount rate) in health benefits--the rationale for setting standards
at TSL 4 for ACFs is further strengthened. Additionally, the impact to
manufacturers is significantly reduced at TSL 4. While manufacturers
have to invest $118.1 million to comply with standards at TSL 4, annual
free cash flows remain positive for all years leading up to the
compliance date. Lastly, DOE estimates that most ACF manufacturers will
have the engineering capacity to complete these redesigns in a 5-year
compliance period.
As stated, DOE conducts the walk-down analysis to determine the TSL
that represents the maximum improvement in energy efficiency that is
technologically feasible and economically justified as required under
EPCA. The walk-down is not a comparative analysis, as a comparative
analysis would result in the maximization of net benefits instead of
energy savings that are technologically feasible and economically
justified, which would be contrary to the statute. 86 FR 70892, 70908.
Although DOE has not conducted a comparative analysis to select the
proposed energy conservation standards, DOE notes that as compared to
TSL 5 and TSL 6, TSL 4 has higher average LCC savings, significantly
smaller percentages of GFBs consumers experiencing a net cost, a lower
simple payback period, a lower maximum decrease in INPV, lower
manufacturer conversion costs, and significantly less likelihood of a
major disruption to the ACF market, as DOE does not anticipate gaps in
ACF equipment offerings at TSL 4.
Although DOE considered proposed new standard levels for ACFs by
grouping the efficiency levels for each equipment class into TSLs, DOE
evaluates all analyzed efficiency levels in its analysis. For all
equipment classes, TSL 4 represents the maximum energy savings that
does not result in significant negative economic impacts to ACF
manufacturers. At TSL 4 conversion costs are estimated to be $118.1
million, significantly less than at TSL 5 ($1,043 million) and at TSL 6
($1,167 million). At TSL 4 conversion costs represent a significantly
smaller size of the sum of ACF manufacturers' annual free cash flows
for 2025 to 2029 (50 percent), than at TSL 5 (450 percent) and at TSL 6
(500 percent) and a significantly smaller portion of ACF manufacturers'
no-new-standards case INPV (18 percent), than at TSL 5 (161 percent)
and at TSL 6 (180 percent). At TSL 4, ACF manufacturers will have to
redesign a significantly smaller portion of their ACF models to meet
the ELs set at TSL 4 (models representing 64 percent of all ACF
shipments), than at TSL 5 (96 percent) and at TSL 6 (99 percent).
Lastly, ACF manufacturers' free cash flow remains positive at TSL 4 for
all years leading up to the compliance date. Whereas at TSL 5 annual
free cash flow is estimated to be -$400 million and at TSL 6 annual
free cash flow is estimated to be -$456 million in 2029, the year
before the modeled compliance year. The ELs at the proposed TSL result
in average positive LCC savings for all equipment classes,
significantly reduce the number of consumers experiencing a net cost,
and reduce the decrease in INPV and conversion costs to the point where
DOE has concluded they are economically justified, as discussed for TSL
4 in the preceding paragraphs.
Therefore, based on the previous considerations, DOE proposes to
adopt the energy conservation standards for ACFs at TSL 4. The proposed
new energy conservation standards for ACFs,
[[Page 3851]]
which are expressed as efficacy in CFM/W, are shown in Table V-70.
BILLING CODE 6450-01-P
[GRAPHIC] [TIFF OMITTED] TP19JA24.117
Table V-71 summarizes the quantitative impacts estimated at the
proposed TSLs for GFBs and ACFs. The quantitative impacts estimated for
each TSL for GFBs and ACFs are discussed in sections V.C.1.a and
V.C.1.b and of this document.
[[Page 3852]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.118
[[Page 3853]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.119
2. Annualized Benefits and Costs of the Proposed Standards
This section presents the combined results for GFBs and ACFs.
Specific results for GFBs and ACFs are also discussed in section
V.C.2.a and V.C.2.b, respectively.
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized net benefit is
(1) the annualized national economic value (expressed in 2022 dollars)
of the benefits from operating products that meet the proposed
standards (consisting primarily of operating cost savings from using
less energy, minus increases in product purchase costs, and (2) the
annualized monetary value of the climate and health benefits from
emission reductions.
Table V-72 shows the annualized values for GFBs and ACFs under TSL
4, expressed in 2022 dollars. The results under the primary estimate
are as follows.
Using a 7 percent discount rate for consumer benefits and costs and
health benefits from reduced NOX and SO2
emissions, and the 3 percent discount rate case for climate benefits
from reduced GHG emissions, the estimated cost of the standards
proposed in this rule is $360 million per year in increased equipment
costs, while the estimated annual benefits are $2,506 million in
reduced equipment operating costs, $963 million in monetized climate
benefits, and $1,285 million in monetized health benefits. In this
case, the monetized net benefit would amount to $4,394 million per
year.
Using a 3 percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $374 million per year in
increased equipment costs, while the estimated annual benefits are
$3,302 million in reduced operating costs, $963 million in monetized
climate benefits, and $1,869 million in monetized health benefits. In
this case, the monetized net benefit would amount to $5,760 million per
year.
[[Page 3854]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.120
[[Page 3855]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.121
a. General Fans and Blowers
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized net benefit is
(1) the annualized national economic value (expressed in 2022 dollars)
of the benefits from operating products that meet the proposed
standards (consisting primarily of operating cost savings from using
less energy, minus increases in product purchase costs, and (2) the
annualized monetary value of the climate and health benefits from
emission reductions.
Table V-73 shows the annualized values for GFBs under TSL 4,
expressed in 2022 dollars. The results under the primary estimate are
as follows.
Using a 7-percent discount rate for consumer benefits and costs and
NOX and SO2 reduction benefits, and a 3-percent
discount rate case for GHG social costs, the estimated cost of the
proposed standards for GFBs is $329 million per year in increased
equipment costs, while the estimated annual benefits are $1,880 million
from reduced equipment operating costs, $703 million in climate
benefits, and $932 million in health benefits. In this case, the net
benefit amounts to $3,185 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards for GFBs is $340 million per
year in increased equipment costs, while the estimated annual benefits
are $2,524 million in reduced operating costs, $703 million in
monetized climate benefits, and $1,384 million from in monetized health
benefits. In this case, the net benefit amounts to $4,271 million per
year.
[[Page 3856]]
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[[Page 3857]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.123
b. Air Circulating Fans
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized net benefit is
(1) the annualized national economic value (expressed in 2022 dollars)
of the benefits from operating products that meet the proposed
standards (consisting primarily of operating cost savings from using
less energy, minus increases in product purchase costs, and (2) the
annualized monetary value of the climate and health benefits from
emission reductions.
Table V-74 shows the annualized values for ACFs under TSL 4,
expressed in 2022 dollars. The results under the primary estimate are
as follows.
Using a 7-percent discount rate for consumer benefits and costs and
NOX and SO2 reduction benefits, and a 3-percent
discount rate case for GHG social costs, the estimated cost of the
proposed standards for ACFs is $31 million per year in increased
equipment costs, while the estimated annual benefits are $626 million
from reduced equipment operating costs, $261 million from GHG
reductions, and $353 million from reduced NOX and
SO2 emissions. In this case, the net benefit amounts to
$1,209 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards for ACFs is $34 million per
year in increased equipment costs, while the estimated annual benefits
are $778 million in reduced operating costs, $261 million in monetized
climate benefits, and $485 million in monetized health benefits. In
this case, the net benefit amounts to $1,489 million per year.
[[Page 3858]]
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[[Page 3859]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.125
BILLING CODE 6450-01-C
D. Reporting, Certification, and Sampling Plan
Manufacturers, including importers, must use equipment-specific
certification templates to certify compliance to DOE. For fans and
blowers, the certification template reflects the general certification
requirements specified at 10 CFR 429.12 and the product-specific
requirements specified at 10 CFR 429.69. DOE is not proposing to amend
the product-specific certification requirements for this equipment. DOE
may consider certification reporting requirements for GFBs in a
separate rulemaking.
E. Representations and Enforcement Provisions
1. Representations for General Fans and Blowers
In the May 2023 TP Final Rule, DOE summarized stakeholder comments
related to FEI representations at compliant and non-compliant duty
points. DOE stated that it was not establishing energy conservation
standards for fans and blowers and therefore, the May 2023 TP final
rule would not result in any compliant or non-compliant operating
points. DOE further stated that it would consider representations and
any issues related to compliance with any potential energy conservation
standard in a separate energy conservation standards rulemaking. 88 FR
27312, 27369.
In response to the October 2022 NODA, the CA IOUs recommended that
DOE consider allowing representations at all duty points for fans
designed for low-pressure, space-constrained applications. (CA IOUs,
No. 127 at pp. 6-7) The CA IOUs stated that for a low-pressure
application fan to meet an energy conservation standard, a consumer
would have to either increase the diameter of the fan, which would
result in a costly redesign of the system, or the consumer would have
to replace the non-compliant fan with a compliant fan of the same
diameter running at a higher pressure, which could result in greater
power consumption of the system. Id. Furthermore, the CA IOUs
encouraged DOE to discuss the issue of whether to allow the publication
of non-compliant, low-pressure duty points with manufacturers. Id.
Damas and Boldt commented that they disagree with DOE's proposal to
restrict the publication of fan and blower performance data at duty
points that do not comply with a proposed energy conservation standard
and recommended that DOE instead require that any non-compliant duty
points be highlighted. (Damas and Boldt, No. 131 at pp. 1, 5) They
provided several example scenarios where a fan may be selected for use
that is outside its compliant range: space-constrained low-flow high-
pressure applications, space-constrained low-pressure applications,
retrofitted systems, VAV systems that require operation over a wide
range of duty points, systems with pressure consuming elements that may
vary in their pressure consumption such that a fan must be selected for
a worst case scenario instead of an average use scenario, and
situations where the system that a fan is operating in changes. (Damas
and Boldt, No. 131 at pp. 2-4) Furthermore, Damas and Boldt commented
that they are concerned that designers may artificially increase the
pressure consumption of a system by closing dampers to allow the fan to
operate at a compliant duty point, which could ultimately increase
energy consumption. (Damas and Boldt, No. 131 at pp. 3-4) Additionally,
Damas and Boldt stated that there may be safety issues when a fan
operates near its highest efficiency duty point, which is often near
the unstable region of a fan. (Damas and Boldt, No. 131 at p. 4) Damas
and Boldt commented that system engineers need full fan
[[Page 3860]]
performance data to ensure that a system design does not push the fan
into its unstable operating region. Id.
As discussed in detail in section IV.C.1, DOE evaluated improved
efficiency options while maintaining constant diameter and duty point
(i.e., air flow and operating pressures remained constant as efficiency
increased); therefore, DOE has tentatively concluded that a compliant
fan of the same equipment class, diameter, and duty point would be
available.
As discussed in section III.C.1 of this document, the FEI metric is
evaluated at each duty point as specified by the manufacturer as
required by the DOE test procedure. If adopted, the proposed energy
conservation standards would have to be met at each duty point at which
the fan is sold.
Consistent with stakeholder feedback from the CA IOUs and Damas and
Boldt, DOE recognizes that not allowing representations of a fan's
entire performance map could result in increased energy consumption or
potential unintended consequences. Therefore, DOE proposes that a
manufacturer could make representations at non-compliant duty points
provided representations include a disclaimer; however, the
manufacturer would be responsible for ensuring that the fan is not sold
and selected at the non-compliant duty points. To ensure this, a
manufacturer could, for example: (1) choose to make representations of
non-compliant duty points and identify those duty points as non-
compliant, but would need to know the duty point(s) for which the fan
was selected and sold; or (2) choose to only make representations at
compliant duty points in the case where the manufacturer does not know
the duty point(s) for which the fan is selected and sold.
In accordance with 42 U.S.C. 6295(r), energy conservation standards
may include any requirement which the Secretary determines is necessary
to assure that each covered product to which such standard applies
meets the required minimum level of energy efficiency. As such, to
assure that each GFB to which the proposed standard would apply meets
the required FEI specified in such standard, and in accordance with 42
U.S.C. 6295(r), DOE proposes to additionally require that all
representations at non-compliant duty points would be (1) identified by
the following disclaimer: ``Sale at these duty points violates
Department of Energy Regulations under EPCA'' in all capital letters,
red, and bold font; and (2) grayed out in any graphs or tables in which
they are included.
2. Enforcement Provisions for General Fans and Blowers
Subpart C of 10 CFR part 429 establishes enforcement provisions
applicable to covered products and covered equipment, including fans
and blowers. General enforcement provisions are established in 10 CFR
429.110. Various provisions in 10 CFR 429.110 specify when DOE may test
for enforcement, how DOE will obtain units for enforcement testing,
where selected units will be tested, and how DOE will determine basic
model compliance, both in general and for specific products and
equipment. DOE is proposing to add specific enforcement testing
provisions for GFBs at 10 CFR 429.110(e).
As previously stated, the FEI metric would be evaluated at each
duty point as specified by the manufacturer and, if adopted, the
proposed energy conservation standards would have to be met at each
duty point at which the fan is sold. Therefore, while DOE requires GFBs
to follow the basic model structure outlined in the May 2023 TP Final
Rule, DOE proposes that GFB compliance will be determined by duty point
offered for sale. In other words, if DOE finds that one or more duty
point(s) certified as compliant by a manufacturer is not compliant with
proposed energy conservation standards, if adopted, the basic model
would be considered non-compliant.
Pursuant to 10.CFR 429.104, DOE may, at any time, test a basic
model to assess whether the basic model is in compliance with the
applicable energy conservation standard(s). If DOE has reason to
believe that a basic model is not in compliance it may test for
enforcement pursuant to 10 CFR 429.110. To verify compliance of GFBs,
DOE proposes to add the following enforcement testing approach at 10
CFR 429.110(e).
When conducting assessment and enforcement testing, DOE proposes to
test each basic model according to the DOE test procedure, using the
test method specified by the manufacturer submitted in their
certification report (i.e., based on section 6.1, 6.2, 6.3 or 6.4 of
AMCA 214-21) pursuant to 10 CFR 429.69. When conducting enforcement
testing, DOE proposes that it may choose to test either one fan at
multiple duty points or multiple fans at one or more duty points to
evaluate compliance of a certified basic model at each certified duty
point.
a. Testing a Single Fan at Multiple Duty Points
When testing a single fan at multiple duty points, DOE proposes to
first determine either bhp or FEP, dependent on the test method
specified by the manufacturer, for the range of certified airflow,
pressure, and speed (duty points) according to appendix A of subpart J
to 10 CFR part 431. DOE acknowledges that it may not be feasible to
exactly replicate the measurements at the certified duty points, or
within the certified range of duty points; therefore, DOE will verify
that, at a given speed, the airflow at which the test is being
conducted is within 5-percent of the certified airflow and the pressure
is within between P x (1-0.05)\2\ and where P is the certified static
or total pressure. If DOE is unable to verify some or all certified
duty points (i.e., the fan is unable to perform at airflows and
pressures at a given speed that are within the prescribed margin of the
certified airflows and pressures), the certified rating cannot be used
to determine compliance. DOE will consider the certified rating to be
invalid and DOE will rely on the measured duty point (i.e., measured
flow and pressure at the given speed) to determine compliance. If DOE
is able to verify the certified duty points (i.e., DOE is able to test
the fan at airflows and pressures at a given speed that are within the
prescribed margin of the certified airflows and pressures), DOE will
convert the tested bhp or FEP at the tested airflow to the certified
airflow and use the converted bhp or FEP calculate the corresponding
FEI at each certified duty point, in accordance with the DOE test
procedure. To convert the tested bhp or FEP at the tested airflow to
the certified airflow DOE will use the following equations:
For fan shaft power:
[GRAPHIC] [TIFF OMITTED] TP19JA24.126
[[Page 3861]]
For fan electrical power:
[GRAPHIC] [TIFF OMITTED] TP19JA24.127
DOE proposes that if the FEI calculated at the certified or
measured duty point is greater than or equal to the minimum required
FEI, then testing would be complete and DOE would consider the
certified duty point to be compliant. If the FEI calculated at a
certified or measured duty point is less than the minimum required FEI,
DOE may make a determination of noncompliance based on that single test
or may select no more than three additional identical model numbers and
evaluate (a) specific duty point(s) according to the procedure just
described to further determine whether (a) specific duty point(s) is/
are compliant based on the average FEI of all units tested when
multiple units are tested.
DOE also proposes to add the provisions related to the verification
of duty points at 10 CFR 429.134.
b. Testing Multiple Fans at One or Several Duty Points
If the FEI calculated at a certified or measured duty point is less
than the minimum required FEI, DOE may make a determination of
noncompliance based on that single test or may select no more than
three additional units of a certified basic model for testing. For each
of the units tested, if the duty point can be verified, DOE proposes to
then follow the approach described in the preceding paragraph, to
determine the converted FEP or bhp and the associated FEI at certified
duty point(s). Similarly, DOE proposes to determine compliance at each
duty point using the average FEI for each certified duty point. If the
duty point(s) cannot be verified, DOE proposes to use the same approach
as in the sampling provisions (see 10 CFR 429.69) to determine the
average FEP or bhp and the associated average FEI at measured duty
point(s).
3. Enforcement Provisions for Air Circulating Fans
For air circulating fans, DOE proposes to follow the general
enforcement testing provisions at 10 CFR 429.110.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866, 13563, and 14094
Executive Order (``E.O.'') 12866, ``Regulatory Planning and
Review,'' as supplemented and reaffirmed by E.O. 13563, ``Improving
Regulation and Regulatory Review,'' 76 FR 3821 (Jan. 21, 2011) and
amended by E.O. 14094, ``Modernizing Regulatory Review,'' 88 FR 21879
(April 11, 2023), requires agencies, to the extent permitted by law, to
(1) propose or adopt a regulation only upon a reasoned determination
that its benefits justify its costs (recognizing that some benefits and
costs are difficult to quantify); (2) tailor regulations to impose the
least burden on society, consistent with obtaining regulatory
objectives, taking into account, among other things, and to the extent
practicable, the costs of cumulative regulations; (3) select, in
choosing among alternative regulatory approaches, those approaches that
maximize net benefits (including potential economic, environmental,
public health and safety, and other advantages; distributive impacts;
and equity); (4) to the extent feasible, specify performance
objectives, rather than specifying the behavior or manner of compliance
that regulated entities must adopt; and (5) identify and assess
available alternatives to direct regulation, including providing
economic incentives to encourage the desired behavior, such as user
fees or marketable permits, or providing information upon which choices
can be made by the public. DOE emphasizes as well that E.O. 13563
requires agencies to use the best available techniques to quantify
anticipated present and future benefits and costs as accurately as
possible. In its guidance, the Office of Information and Regulatory
Affairs (``OIRA'') in the Office of Management and Budget (``OMB'') has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. For the reasons stated in the preamble,
this proposed regulatory action is consistent with these principles.
Section 6(a) of E.O. 12866 also requires agencies to submit
``significant regulatory actions'' to OIRA for review. OIRA has
determined that this proposed regulatory action constitutes a
``significant regulatory action'' within the scope of section 3(f)(1)
of E.O. 12866. Accordingly, pursuant to section 6(a)(3)(C) of E.O.
12866, DOE has provided to OIRA an assessment, including the underlying
analysis, of benefits and costs anticipated from the proposed
regulatory action, together with, to the extent feasible, a
quantification of those costs; and an assessment, including the
underlying analysis, of costs and benefits of potentially effective and
reasonably feasible alternatives to the planned regulation, and an
explanation why the planned regulatory action is preferable to the
identified potential alternatives. These assessments are summarized in
this preamble and further detail can be found in the technical support
document for this proposed rulemaking. Finally, in accordance with 5
U.S.C. 553(b)(4), a summary of this proposed rule may be found at
www.regulations.gov/docket/EERE-2020-BT-STD-0007.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (``IRFA'')
for any rule that by law must be proposed for public comment, unless
the agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by E.O. 13272, ``Proper Consideration of Small Entities in
Agency Rulemaking,'' 67 FR 53461 (Aug. 16, 2002), DOE published
procedures and policies on February 19, 2003, to ensure that the
potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's website (www.energy.gov/gc/office-general-counsel). DOE has
prepared the following IRFA for the industrial equipment that is the
subject of this rulemaking.
[[Page 3862]]
1. Description of Reasons Why Action Is Being Considered
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. 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)) DOE is undertaking this NOPR pursuant to its
obligations under EPCA to propose standards for covered industrial
equipment.
2. Objectives of, and Legal Basis for, Rule
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered equipment, including fans and blowers.
Any new or amended standard for a covered product must be designed to
achieve the maximum improvement in energy efficiency that the Secretary
of Energy determines is technologically feasible and economically
justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(3)(B))
3. Description on Estimated Number of Small Entities Regulated
For manufacturers of fans and blowers, the SBA has set a size
threshold, which defines those entities classified as ``small
businesses'' for the purposes of the statute. DOE used the SBA's small
business size standards to determine whether any small entities would
be subject to the requirements of the rule. (See 13 CFR part 121.) The
size standards are listed by North American Industry Classification
System (``NAICS'') code and industry description and are available at
www.sba.gov/document/support-table-size-standards. Manufacturing of
fans and blowers is classified under NAICS 335220, ``Industrial and
Commercial Fan and Blower and Air Purification Equipment
Manufacturing.'' The SBA sets a threshold of 500 employees or fewer for
an entity to be considered as a small business for this category.
DOE conducted a focused inquiry of the companies that could be
small businesses that manufacture fans and blowers covered by this
rulemaking. DOE used data from the AMCA sales database; from the BESS
Labs database; and from ENERGY STAR's certified product database to
create a list of companies that potentially sell fans and blowers
covered by this rulemaking. Additionally, DOE received feedback from
interested parties in response to previous stages of this rulemaking.
DOE contacted select companies on its list, as necessary, to determine
whether they met the SBA's definition of a fan and blower small
business. DOE screened out companies that did not offer equipment
covered by this rulemaking, did not meet the definition of a ``small
business,'' or are foreign owned and operated.
Using these data sources, DOE identified 91 manufacturers of fans
and blowers. DOE then referenced D&B Hoovers reports,\136\ as well as
the online presence of identified businesses in order to determine
whether they might the criteria of a small business. DOE screened out
companies that do not offer products covered by this rulemaking, do not
meet the definition of a ``small business,'' or are foreign owned and
operated. Additionally, DOE filters out businesses that do not directly
produce fans and blowers, but instead relabel fans and blowers or
integrate them into a different product.
---------------------------------------------------------------------------
\136\ D&B Hoovers reports require a subscription to D&B Hoovers
and can be accessed at: app.dnbhoovers.com.
---------------------------------------------------------------------------
From these sources, DOE identified 46 unique businesses
manufacturing at least one covered fan or blower product family and
that also fall under SBA's employee threshold for this rulemaking. Of
the 46 small businesses, 41 manufacture at least one model of a covered
GFB and 15 of these small businesses additionally manufacture at least
one model of a covered ACF. Lastly, there are five small businesses
that only manufacture ACF models (and do not manufacture any GFB
models).
DOE requests comment on the number of small business OEMs
identified that manufacture fans and blowers covered by this
rulemaking.
4. Description and Estimate of Compliance Requirements Including
Differences in Cost, if Any, for Different Groups of Small Entities
In section IV.J.2.c of this NOPR, DOE reviews the methodology used
to calculate conversion costs, this is further elaborated in chapter 12
of the NOPR TSD. DOE used the same methodology to estimate per small
business conversion costs as with the broader industry--developing
estimates of the number of product families for each small business
using their websites and product catalogs. DOE was also able to find
revenue estimates for each small business identified.
Across the identified small businesses, DOE identified 457 covered
GFB product families and 97 ACF product families. DOE evaluated how
many of each type for each small business would be compliant with TSL 4
based on the shipments analysis efficiency level estimates. Then, DOE
assumed that all non-compliant product families would be redesigned and
calculated the appropriate conversion costs. DOE estimates that the
total cost to all small businesses to redesign GFB product families
would be approximately $233.0 million and to redesign ACF would be an
additional $29.1 million. DOE provides estimates of conversion costs
for each small business in the following tables for small businesses
that manufacture both GFBs and ACFs, GFBs only, and ACFs only.
BILLING CODE 6450-01-P
[[Page 3863]]
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[[Page 3864]]
[GRAPHIC] [TIFF OMITTED] TP19JA24.129
[GRAPHIC] [TIFF OMITTED] TP19JA24.130
BILLING CODE 6450-01-C
Costs as a percentage of revenue vary significantly across the
small businesses. For small manufacturers that make both GFBs and ACFs,
median costs as a percentage of revenue are 10.8 percent. For small
manufacturers that only make GFBs, median costs as a percentage of
revenue are 5.3 percent. For small businesses that only make ACFs, most
small businesses are expected to incur zero redesign costs, the highest
cost estimated represents 6.9 percent of the affected small business'
compliance period revenue. Small businesses that experience high
conversion costs as a percentage of revenue will likely need to seek
outside capital to finance redesign efforts and or prioritize
redesigning product families based on sales volume.
DOE requests comment on the estimated small business costs and how
those may differ from the costs incurred by larger manufacturers.
5. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any other rules or regulations that duplicate,
overlap, or conflict with the rule being considered today.
6. Significant Alternatives to the Rule
The discussion in the previous section analyzes impacts on small
businesses that would result from DOE's proposed rule, represented by
TSL 4. In reviewing alternatives to the proposed rule, DOE examined
energy conservation standards set at lower efficiency levels. While
selecting TSLs 1, 2, or 3 would reduce the possible impacts on small
businesses, it would come at the expense of a significant
[[Page 3865]]
reduction in energy savings and consumer NPV.
For GFBs, TSL 1 achieves 88 percent lower energy savings and 90
percent lower consumer net benefits compared to the energy savings and
consumer net benefits at TSL 4. TSL 2 achieves 78 percent lower energy
savings and 80 percent lower consumer net benefits compared to the
energy savings and consumer net benefits at TSL 4. TSL 3 achieves 44
percent lower energy savings and 49 percent lower consumer net benefits
compared to the energy savings and consumer net benefits at TSL 4.
For ACFs, TSL 1 achieves 98 percent lower energy savings and 96
percent lower consumer net benefits compared to the energy savings and
consumer net benefits at TSL 4. TSL 2 achieves 96 percent lower energy
savings and 94 percent lower consumer net benefits compared to the
energy savings and consumer net benefits at TSL 4. TSL 3 achieves 73
percent lower energy savings and 71 percent lower consumer net benefits
compared to the energy savings and consumer net benefits at TSL 4.
Based on the presented discussion, establishing standards at TSL 4
for GFBs and for ACFs balances the benefits of the energy savings and
consumer benefits with the potential burdens placed on manufacturers
and small businesses better than alternate standard levels.
Accordingly, DOE does not propose one of the other TSLs considered in
the analysis, or the other policy alternatives examined as part of the
regulatory impact analysis and included in chapter 17 of the NOPR TSD.
C. Review Under the Paperwork Reduction Act
Under the procedures established by the Paperwork Reduction Act of
1995 (``PRA''), a person is not required to respond to a collection of
information by a Federal agency unless that collection of information
displays a currently valid OMB Control Number.
OMB Control Number 1910-1400, Compliance Statement Energy/Water
Conservation Standards for Appliances, is currently valid and assigned
to the certification reporting requirements applicable to covered
equipment, including fans and blowers.
DOE's certification and compliance activities ensure accurate and
comprehensive information about the energy and water use
characteristics of covered products and covered equipment sold in the
United States. Manufacturers of all covered products and covered
equipment must submit a certification report before a basic model is
distributed in commerce, annually thereafter, and if the basic model is
redesigned in such a manner to increase the consumption or decrease the
efficiency of the basic model such that the certified rating is no
longer supported by the test data. Additionally, manufacturers must
report when production of a basic model has ceased and is no longer
offered for sale as part of the next annual certification report
following such cessation. DOE requires the manufacturer of any covered
product or covered equipment to establish, maintain, and retain the
records of certification reports, of the underlying test data for all
certification testing, and of any other testing conducted to satisfy
the requirements of part 429, part 430, and/or part 431. Certification
reports provide DOE and consumers with comprehensive, up-to-date
efficiency information and support effective enforcement.
Certification data would be required for fans and blowers were this
NOPR to be finalized as proposed; however, DOE is not proposing
certification or reporting requirements for fans and blowers in this
NOPR. Instead, DOE may consider proposals to establish certification
requirements and reporting for fans and blowers under a separate
rulemaking regarding appliance and equipment certification. DOE will
address changes to OMB Control Number 1910-1400 at that time, as
necessary.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
DOE is analyzing this proposed regulation in accordance with the
National Environmental Policy Act of 1969 (``NEPA'') and DOE's NEPA
implementing regulations (10 CFR part 1021). DOE's regulations include
a categorical exclusion for rulemakings that establish energy
conservation standards for consumer products or industrial equipment.
10 CFR part 1021, subpart D, appendix B5.1. DOE anticipates that this
rulemaking qualifies for categorical exclusion B5.1 because it is a
rulemaking that establishes energy conservation standards for consumer
products or industrial equipment, none of the exceptions identified in
categorical exclusion B5.1(b) apply, no extraordinary circumstances
exist that require further environmental analysis, and it otherwise
meets the requirements for application of a categorical exclusion. See
10 CFR 1021.410. DOE will complete its NEPA review before issuing the
final rule.
E. Review Under Executive Order 13132
E.O. 13132, ``Federalism,'' 64 FR 43255 (Aug. 10, 1999), imposes
certain requirements on Federal agencies formulating and implementing
policies or regulations that preempt State law or that have federalism
implications. The Executive order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE has examined this proposed rule and has
tentatively determined that it would not have a substantial direct
effect on the States, on the relationship between the national
government and the States, or on the distribution of power and
responsibilities among the various levels of government. EPCA governs
and prescribes Federal preemption of State regulations as to energy
conservation for the equipment that are the subject of this proposed
rule. States can petition DOE for exemption from such preemption to the
extent, and based on criteria, set forth in EPCA. (42 U.S.C. 6316(a)
and (b); 42 U.S.C. 6297) Therefore, no further action is required by
Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of E.O. 12988, ``Civil
Justice Reform,'' imposes on Federal agencies the general duty to
adhere to the following requirements: (1) eliminate drafting errors and
ambiguity, (2) write regulations to minimize litigation, (3) provide a
clear legal standard for affected conduct rather than a general
standard, and (4) promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Regarding the review required by section 3(a),
section 3(b) of E.O. 12988 specifically requires that Executive
agencies make every reasonable effort to
[[Page 3866]]
ensure that the regulation: (1) clearly specifies the preemptive
effect, if any, (2) clearly specifies any effect on existing Federal
law or regulation, (3) provides a clear legal standard for affected
conduct while promoting simplification and burden reduction, (4)
specifies the retroactive effect, if any, (5) adequately defines key
terms, and (6) addresses other important issues affecting clarity and
general draftsmanship under any guidelines issued by the Attorney
General. Section 3(c) of Executive Order 12988 requires Executive
agencies to review regulations in light of applicable standards in
section 3(a) and section 3(b) to determine whether they are met or it
is unreasonable to meet one or more of them. DOE has completed the
required review and determined that, to the extent permitted by law,
this proposed rule meets the relevant standards of E.O. 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (``UMRA'')
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, section 201 (codified at 2 U.S.C.
1531). For a proposed regulatory action likely to result in a rule that
may cause the expenditure by State, local, and Tribal governments, in
the aggregate, or by the private sector of $100 million or more in any
one year (adjusted annually for inflation), section 202 of UMRA
requires a Federal agency to publish a written statement that estimates
the resulting costs, benefits, and other effects on the national
economy. (2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal
agency to develop an effective process to permit timely input by
elected officers of State, local, and Tribal governments on a proposed
``significant intergovernmental mandate,'' and requires an agency plan
for giving notice and opportunity for timely input to potentially
affected small governments before establishing any requirements that
might significantly or uniquely affect them. On March 18, 1997, DOE
published a statement of policy on its process for intergovernmental
consultation under UMRA. 62 FR 12820. DOE's policy statement is also
available at www.energy.gov/sites/prod/files/gcprod/documents/umra_97.pdf.
Although this proposed rule does not contain a Federal
intergovernmental mandate, it may require expenditures of $100 million
or more in any one year by the private sector. Such expenditures may
include: (1) investment in research and development and in capital
expenditures by fans and blowers manufacturers in the years between the
final rule and the compliance date for the new standards and (2)
incremental additional expenditures by consumers to purchase higher-
efficiency fans and blowers, starting at the compliance date for the
applicable standard.
Section 202 of UMRA authorizes a Federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the proposed rule. (2 U.S.C. 1532(c)) The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. This
SUPPLEMENTARY INFORMATION section of this NOPR and the TSD for this
proposed rule respond to those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. (2 U.S.C. 1535(a)) DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the proposed rule unless DOE publishes
an explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C 6316(a);
42 U.S.C. 6295(m), this proposed rule would establish energy
conservation standards for fans and blowers that are designed to
achieve the maximum improvement in energy efficiency that DOE has
determined to be both technologically feasible and economically
justified, as required by 42 U.S.C 6316(a); 42 U.S.C. 6295(o)(2)(A) and
(o)(3)(B). A full discussion of the alternatives considered by DOE is
presented in chapter 17 of the NOPR TSD for this proposed rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
Pursuant to E.O. 12630, ``Governmental Actions and Interference
with Constitutionally Protected Property Rights,'' 53 FR 8859 (Mar. 15,
1988), DOE has determined that this proposed rule would not result in
any takings that might require compensation under the Fifth Amendment
to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for Federal agencies to review
most disseminations of information to the public under information
quality guidelines established by each agency pursuant to general
guidelines issued by OMB. OMB's guidelines were published at 67 FR 8452
(Feb. 22, 2002), and DOE's guidelines were published at 67 FR 62446
(Oct. 7, 2002). Pursuant to OMB Memorandum M-19-15, Improving
Implementation of the Information Quality Act (April 24, 2019), DOE
published updated guidelines which are available at www.energy.gov/sites/prod/files/2019/12/f70/DOE%20Final%20Updated%20IQA%20Guidelines%20Dec%202019.pdf. DOE has
reviewed this NOPR under the OMB and DOE guidelines and has concluded
that it is consistent with applicable policies in those guidelines.
K. Review Under Executive Order 13211
E.O. 13211, ``Actions Concerning Regulations That Significantly
Affect Energy Supply, Distribution, or Use,'' 66 FR 28355 (May 22,
2001), requires Federal agencies to prepare and submit to OIRA at OMB,
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgates or is expected to lead to promulgation of a
final rule, and that (1) is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
[[Page 3867]]
DOE has tentatively concluded that this regulatory action, which
proposes energy conservation standards for fans and blowers, is not a
significant energy action because the proposed standards are not likely
to have a significant adverse effect on the supply, distribution, or
use of energy, nor has it been designated as such by the Administrator
at OIRA. Accordingly, DOE has not prepared a Statement of Energy
Effects on this proposed rule.
L. Information Quality
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (``OSTP''), issued its Final Information
Quality Bulletin for Peer Review (``the Bulletin''). 70 FR 2664 (Jan.
14, 2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as ``scientific information
the agency reasonably can determine will have, or does have, a clear
and substantial impact on important public policies or private sector
decisions.'' 70 FR 2664, 2667.
In response to OMB's Bulletin, DOE conducted formal peer reviews of
the energy conservation standards development process and the analyses
that are typically used and has prepared a report describing that peer
review.\137\ Generation of this report involved a rigorous, formal, and
documented evaluation using objective criteria and qualified and
independent reviewers to make a judgment as to the technical/
scientific/business merit, the actual or anticipated results, and the
productivity and management effectiveness of programs and/or projects.
Because available data, models, and technological understanding have
changed since 2007, DOE has engaged with the National Academy of
Sciences to review DOE's analytical methodologies to ascertain whether
modifications are needed to improve DOE's analyses. DOE is in the
process of evaluating the resulting report.\138\
---------------------------------------------------------------------------
\137\ The 2007 ``Energy Conservation Standards Rulemaking Peer
Review Report'' is available at the following website: energy.gov/eere/buildings/downloads/energy-conservation-standards-rulemaking-peer-review-report-0 (last accessed December 5, 2023).
\138\ The report is available at www.nationalacademies.org/our-work/review-of-methods-for-setting-building-and-equipment-performance-standards.
---------------------------------------------------------------------------
M. Description of Materials Incorporated by Reference
In this NOPR, DOE proposes to incorporate by reference the
following test standards published by the IEC.
IEC 61800-9-2:2023 specifies test methods to determine the
efficiency of motor controllers as well as the efficiency of motor and
motor controller combinations. It also establishes efficiency
classifications for this equipment.
IEC TS 60034-30-2:2016 establishes efficiency classifications for
motors driven by motor controllers.
IEC TS 60034-31:2021 provides a guideline of technical and
economical aspects for the application of energy-efficient electric AC
motors and example calculations.
IEC 61800-9-2:2023, IEC TS 60034-30-2:2016, and IEC TS 60034-
31:2021 are available for purchase from the International
Electrotechnical Committee (IEC), Central Office, 3, rue de
Varemb[eacute], P.O. Box 131, CH-1211 GENEVA 20, Switzerland; + 41 22
919 02 11; webstore.iec.ch.
The following standards appear in the amendatory text of this
document and have already been approved for the locations in which they
appear: AMCA 210-16, AMCA 214-21, and ISO 5801:2017.
VII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the public meeting are listed in
the DATES and ADDRESSES sections at the beginning of this document. If
you plan to attend the public meeting, please notify the Appliance and
Equipment Standards staff at (202) 287-1445 or
[email protected].
Please note that foreign nationals visiting DOE Headquarters are
subject to advance security screening procedures which require advance
notice prior to attendance at the public meeting. If a foreign national
wishes to participate in the public meeting, please inform DOE of this
fact as soon as possible by contacting Ms. Regina Washington at (202)
586-1214 or by email ([email protected]) so that the
necessary procedures can be completed.
DOE requires visitors to have laptops and other devices, such as
tablets, checked upon entry into the Forrestal Building. Any person
wishing to bring these devices into the building will be required to
obtain a property pass. Visitors should avoid bringing these devices,
or allow an extra 45 minutes to check in. Please report to the
visitor's desk to have devices checked before proceeding through
security.
Due to the REAL ID Act implemented by the Department of Homeland
Security (``DHS''), there have been recent changes regarding ID
requirements for individuals wishing to enter Federal buildings from
specific States and U.S. territories. DHS maintains an updated website
identifying the State and territory driver's licenses that currently
are acceptable for entry into DOE facilities at www.dhs.gov/real-id-enforcement-brief. A driver's license from a State or territory
identified as not compliant by DHS will not be accepted for building
entry and one of the alternate forms of ID listed below will be
required. Acceptable alternate forms of Photo-ID include U.S. Passport
or Passport Card; an Enhanced Driver's License or Enhanced ID-Card
issued by States and territories as identified on the DHS website
(Enhanced licenses issued by these States and territories are clearly
marked Enhanced or Enhanced Driver's License); a military ID or other
Federal government-issued Photo-ID card.
In addition, you can attend the public meeting via webinar. Webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants will be
published on DOE's website at www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=51. Participants are
responsible for ensuring their systems are compatible with the webinar
software.
B. Procedure for Submitting Prepared General Statements for
Distribution
Any person who has plans to present a prepared general statement
may request that copies of his or her statement be made available at
the public meeting. Such persons may submit requests, along with an
advance electronic copy of their statement in PDF (preferred),
Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to
the appropriate address shown in the ADDRESSES section at the beginning
of this document. The request and advance copy of statements must be
received at least one week before the public meeting and are to be
emailed. Please include a telephone number to enable DOE staff to make
follow-up contact, if needed.
[[Page 3868]]
C. Conduct of the Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also use a professional facilitator to aid discussion. The
meeting will not be a judicial or evidentiary-type public hearing, but
DOE will conduct it in accordance with section 336 of EPCA. (42 U.S.C.
6306) A court reporter will be present to record the proceedings and
prepare a transcript. DOE reserves the right to schedule the order of
presentations and to establish the procedures governing the conduct of
the public meeting. There shall not be discussion of proprietary
information, costs or prices, market share, or other commercial matters
regulated by U.S. anti-trust laws. After the public meeting, interested
parties may submit further comments on the proceedings, as well as on
any aspect of the proposed rulemaking, until the end of the comment
period.
The public meeting will be conducted in an informal, conference
style. DOE will present a general overview of the topics addressed in
this proposed rulemaking, allow time for prepared general statements by
participants, and encourage all interested parties to share their views
on issues affecting this proposed rulemaking. Each participant will be
allowed to make a general statement (within time limits determined by
DOE), before the discussion of specific topics. DOE will allow, as time
permits, other participants to comment briefly on any general
statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly. Participants should
be prepared to answer questions by DOE and by other participants
concerning these issues. DOE representatives may also ask questions of
participants concerning other matters relevant to this rulemaking. The
official conducting the public meeting will accept additional comments
or questions from those attending, as time permits. The presiding
official will announce any further procedural rules or modification of
the previous procedures that may be needed for the proper conduct of
the public meeting.
A transcript of the public meeting will be included in the docket,
which can be viewed as described in the Docket section at the beginning
of this document and will be accessible on the DOE website. In
addition, any person may buy a copy of the transcript from the
transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. 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 of 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. DOE will make
its own determination about the confidential 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
[[Page 3869]]
information deemed to be exempt from public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
(1) DOE requests comment on its proposed clarification for fans
that create a vacuum. Specifically, DOE requests comment on whether
fans that are manufactured and marketed exclusively to create a vacuum
of 30 inches water gauge or greater could also be used in positive
pressure applications. Additionally, DOE requests information on the
applications in which a fan not manufactured or marketed exclusively
for creating a vacuum would be used to create a vacuum of 30 inches
water gauge or greater.
(2) DOE requests comments and feedback on the proposed methodology
and calculation of motor and motor controller losses as well as
potentially using an alternative calculation based on adjusted AMCA
214-21 equations.
(3) DOE requests comment on whether there are specific fans that
meet the axial ACF definition that provide utility substantially
different from the utility provided from other axial ACFs and that
would impact energy use. If so, DOE requests information on how the
utility of these fans differs from other axial ACFs and requests data
showing the differences in energy use due to differences in utility
between these fans and other axial ACFs.
(4) DOE requests comment on its understanding that the diameter
increase design option could be applied to non-embedded, non-space-
constrained equipment classes.
(5) DOE requests comment on whether the FEI increases associated
with an impeller diameter increase for centrifugal PRVs and for axial
PRVs are realistic. Specifically, DOE requests comment on whether it is
realistic for axial PRVs to have a FEI increase that is 3 times greater
than that for centrifugal PRVs when starting at the same initial
diameter. Additionally, DOE requests comment on the factors that may
impact how much an impeller diameter increase impacts a FEI increase.
(6) DOE requests comment on the ordering and implementation of
design options for centrifugal PRV exhaust and supply fans and axial
PRV fans.
(7) DOE requests comment on its approach for estimating the
industry-wide conversion costs that may be necessary to redesign fans
with forward-curved impellers to meet higher FEI values. Specifically,
DOE is interested in the costs associated with any capital equipment,
research and development, or additional labor that would be required to
design more efficient fans with forward-curved impellers. DOE
additionally requests comment and data on the percentage of forward-
curved impellers that manufacturers would expect to maintain as a
forward-curved impeller relative to those expected to transition to a
backward-inclined or airfoil impeller.
(8) DOE requests comment on the equations developed to calculate
the credit for determining the FEI standard for GFBs sold with a motor
controller and with an FEPact less than 20 kW and on potentially using
an alternative credit calculation based on the proposed equations in
section III.C.1.b of this document. Additionally, DOE requests comment
on its use of a constant value, and its proposed value, of the credit
applied for determining the FEI standard for GFBs with a motor
controller and an FEPact of greater than or equal for 20 kW.
(9) DOE requests comments on whether it should apply a correction
factor to the analyzed efficiency levels to account for the tolerance
allowed in AMCA 211-22 and if so, DOE requests comment on the
appropriate correction factor. DOE requests comment on the potential
revised levels as presented in Table IV-12. Additionally, DOE requests
comments on whether it should continue to evaluate an FEI of 1.00 for
all fan classes if it updates the databases used in its analysis to
consider the tolerance allowed in AMCA 211-22.
(10) Additionally, DOE does not anticipate that the efficiency
levels captured in Table IV-12 would impact the cost, energy, and
economic analyses presented in this document. As such, DOE considers
the results of these analyses presented throughout this document
applicable to the efficiency levels with a 5% tolerance allowance. DOE
seeks comment on the analyses as applied to the efficiency levels in
Table IV-12.
(11) DOE requests comment on its method to use both the AMCA sales
database and sales data pulled from manufacturer fan selection data to
estimate MSP. DOE also requests comment on the use of the MSP approach
for its cost analysis for GFBs or whether an MPC-based approach would
be appropriate. If interested parties believe an MPC-based approach
would be more appropriate, DOE requests MPC data for the equipment
classes and efficiency levels analyzed, which may be confidentially
submitted to DOE using the confidential business information label.
(12) DOE requests feedback on whether using a more efficient motor
would require an ACF redesign. Additionally, DOE requests feedback on
what percentage of motor speed change would require an ACF redesign.
(13) DOE requests feedback on whether setting an ACF standard using
discrete efficacy values over a defined diameter range appropriately
represents the differences in efficacy between axial ACFs with
different diameters, and if not, would a linear equation for efficacy
as a function of diameter be appropriate.
(14) DOE seeks comment on the distribution channels identified for
GFBs and ACFs and fraction of sales that go through each of these
channels.
(15) DOE seeks comment on the overall methodology and inputs used
to estimate GFBs and ACFs energy use. Specifically, for GFBs, DOE seeks
feedback on the methodology and assumptions used to determine the
operating point(s) both for constant and variable load fans. For ACFs,
DOE requests feedback on the average daily operating hours, annual days
of operation by sector and application, and input power assumptions. In
addition, DOE requests feedback on the market share of GFBs and ACFs by
sector (i.e., commercial, industrial, and agricultural).
(16) DOE requests feedback on the price trends developed for GFBs
and ACFs.
(17) DOE requests feedback on the installation costs developed for
GFBs and on whether installation costs of ACFs may increase at higher
ELs.
(18) DOE requests feedback on whether the maintenance and repair
costs of GFBs may increase at higher ELs. Specifically, DOE requests
comments on the frequency of motor replacements for ACFs. DOE also
requests comments on whether the maintenance and repair costs of ACFs
may increase at higher ELs and on the repair costs developed for ACFs.
(19) DOE requests comments on the average lifetime estimates used
for GFBs and ACFs.
(20) DOE requests feedback and information on the no-new-standards
case efficiency distributions used to characterize the market of GFBs
and ACFs. DOE requests information to support any efficiency trends
over time for GFBs and ACFs.
(21) DOE requests feedback on the methodology and inputs used to
project shipments of GFBs in the no-new-standards case. DOE requests
comments and feedback on the potential impact of standards on GFB
shipments and
[[Page 3870]]
information to help quantify these impacts.
(22) DOE requests feedback on the methodology and inputs used to
estimate and project shipments of ACFs in the no-new-standards case.
DOE requests comments and feedback on the potential impact of standards
on ACF shipments and information to help quantify these impacts.
(23) DOE requests comment and data regarding the potential increase
in utilization of GFBs and ACFs due to any increase in efficiency.
(24) DOE requests comment on the number of end-use product (i.e., a
product or equipment that has a fan or blower embedded in it) basic
models that would not be excluded by the list of products or equipment
listed in Table III-1.
(25) DOE requests information regarding the impact of cumulative
regulatory burden on manufacturers of fans and blowers associated with
multiple DOE standards or product-specific regulatory actions of other
Federal agencies.
(26) DOE requests comment on the proposed standard level for axial
PRVs, including the design options and costs, as well as the burdens
and benefits associated with this level and the industry standards/
California regulations FEI level of 1.00.
(27) DOE requests comment on the number of small business OEMs
identified that manufacture fans and blowers covered by this proposed
rulemaking.
(28) DOE requests comment on the estimated small business costs and
how those may differ from the costs incurred by larger manufacturers.
Additionally, DOE welcomes comments on other issues relevant to the
conduct of this rulemaking that may not specifically be identified in
this document.
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this notice of
proposed rulemaking and announcement of public meeting.
List of Subjects
10 CFR Part 429
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Reporting and
recordkeeping requirements.
10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation test procedures, Incorporation by
reference, Reporting and recordkeeping requirements.
Signing Authority
This document of the Department of Energy was signed on December
28, 2023, by Jeffrey Marootian, Principal Deputy 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 December 29, 2023.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
For the reasons set forth in the preamble, DOE proposes to amend
parts 429 and 431 of chapter II, subchapter D, of title 10 of the Code
of Federal Regulations, as set forth below:
PART 429--CERTIFICATION, COMPLIANCE, AND ENFORCEMENT FOR CONSUMER
PRODUCTS AND COMMERCIAL AND INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 429 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C. 2461 note.
0
2. Amend Sec. 429.69 by adding paragraph (a)(3) to read as follows:
Sec. 429.69 Fans and blowers.
(a) * * *
(3) Required Disclaimer at Non-Compliant Duty Points.
Representation of fan performance at duty points with FEI that are not
compliant with the energy conservation standards at Sec. 431.175 of
this chapter is allowed and must be identified by the following
disclaimer: ``Sale at these duty points violates Department of Energy
Regulations under EPCA'' in red and bold font; and (2) duty points must
be grayed out in any graphs or tables in which they are included.
* * * * *
0
3. Amend Sec. 429.110 by redesignating paragraphs (e)(7), (8), and (9)
as paragraphs (e)(8), (9), and (10), respectively, and adding a new
paragraph (e)(7) to read as follows:
Sec. 429.110 Enforcement testing.
* * * * *
(e) * * *
(7) For fans and blowers other than air circulating fans, DOE will
use an initial sample of one unit to determine compliance at each duty
point for which the fan basic model is distributed in commerce. If one
or more duty points is determined to be non-compliant, the fan basic
model is determined to be non-compliant.
(i) When testing a single unit, DOE will first determine either fan
shaft input power or FEP, dependent on the test method specified by the
manufacturer, for the range of certified duty points according to
appendix A to subpart J of part 431 of this chapter. For each point in
the certified operating range (i.e., each certified duty point), DOE
will conduct a verification of the duty points as described in Sec.
429.134(bb)(2) and determine the FEI at the certified duty point or at
the measured duty point. If the FEI calculated at the certified or
measured duty point is greater than or equal to the minimum required
FEI, then testing is complete and the certified or measured duty point
is compliant. If the FEI calculated at a certified or measured duty
point is less than the minimum required FEI, DOE may select additional
units to test in accordance with this paragraph (e)(7)(ii) of this
section.
(ii) When testing more than one unit, DOE will select no more than
three additional units of a certified basic model for testing and test
each one at one or several duty points within the range of certified
duty points. For each unit and at each certified duty point, DOE will
conduct a verification of the duty points as described in Sec.
429.134(bb)(2) and determine the FEI at the certified duty point or at
the measured duty point. In the case where the certified duty point can
be verified, DOE will calculate the average FEI of all units tested for
each certified duty point. If the duty point cannot be verified, DOE
will follow the sampling procedures at Sec. 429.69 to determine the
average FEI of all units tested at the measured duty point. If the
average FEI calculated at the certified or measured duty point is
greater than or equal to the minimum required FEI, then testing is
complete and the certified or measured duty point is compliant. If the
average FEI calculated at a certified or measured duty point is less
than the minimum required FEI, then testing is complete
[[Page 3871]]
and the certified or measured duty point is not compliant.
* * * * *
0
4. Amend Sec. 429.134 by adding paragraph (gg) to read as follows:
Sec. 429.134 Product-specific enforcement provisions.
* * * * *
(gg) Fans and blowers. (1) Testing. For fans and blowers other than
air circulating fans, DOE will test each fan or blower basic model
according to the test method specified by the manufacturer (i.e., based
on the method listed in table 1 to appendix A to subpart J of part 431
of this chapter).
(2) Verification of duty points. For fans and blowers other than
air circulating fans, at a given speed within the certified operating
range, the pressure and flow of a duty point in the certified range of
operation (i.e., certified duty point) will be determined in accordance
with appendix A to subpart J of part 431 of this chapter. At a given
speed, the certified duty point will be considered valid only if the
measured airflow is within five percent of the certified airflow and
the measured static or total pressure is between P x (1-0.05)\2\ and P
x (1 + 0.05)\2\ where P is the certified static or total pressure.
(i)(A) If the certified duty point is found to be valid, the
certified duty point will be used as the basis for determining
compliance. DOE will convert the measured fan shaft power or FEP at the
measured airflow to the certified airflow using the following
equations:
For fan shaft power:
[GRAPHIC] [TIFF OMITTED] TP19JA24.131
For fan electrical power:
[GRAPHIC] [TIFF OMITTED] TP19JA24.132
(B) DOE will use the converted fan shaft power or FEP to calculate
the corresponding FEI at the certified duty point, in accordance with
the DOE test procedure.
(ii) If the certified duty point is found to be invalid, the
measured flow and pressure will be used as the basis for determining
compliance. DOE will use the measured fan shaft power or FEP to
calculate the corresponding FEI at the measured duty point, in
accordance with the DOE test procedure.
PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
5. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C. 2461 note.
0
6. Amend Sec. 431.172 by adding in alphabetical order definitions for
``Axial air circulating fan'', ``Axial power roof ventilator'',
``Centrifugal power roof ventilator--exhaust'', ``Centrifugal power
roof ventilator--supply'', ``Diameter'', ``Fan housing'', ``Mixed flow
impeller'', and ``Radial impeller'' to read as follows:
Sec. 431.172 Definitions.
* * * * *
Axial air circulating fan means an air circulating fan with an
axial impeller that is either housed or unhoused.
* * * * *
Axial power roof ventilator means a PRV with an axial impeller that
either supplies or exhausts air to a building where the inlet and
outlet are not typically ducted.
* * * * *
Centrifugal power roof ventilator--exhaust means a PRV with a
centrifugal or mixed-flow impeller that exhausts air from a building
and which is typically mounted on a roof or a wall.
Centrifugal power roof ventilator--supply means a PRV with a
centrifugal or mixed-flow impeller that supplies air to a building and
which is typically mounted on a roof or a wall.
* * * * *
Diameter means the impeller diameter of a fan, which is twice the
measured radial distance between the tip of one of the impeller blades
of a fan to the center axis of its impeller hub.
* * * * *
Fan housing means any fan component(s) that direct(s) airflow into
or away from the impeller and/or provide protection for the internal
components of a fan or blower that is not an air circulating fan. A
housing may serve as a fan's structure.
* * * * *
Mixed flow impeller means an impeller featuring construction
characteristics between those of an axial and centrifugal impeller. A
mixed-flow impeller has a fan flow angle greater than 20 degrees and
less than 70 degrees. Airflow enters axially through a single inlet and
exits with combined axial and radial directions at a mean diameter
greater than the inlet.
* * * * *
Radial impeller means a form of centrifugal impeller with several
blades extending radially from a central hub. Airflow enters axially
through a single inlet and exits radially at the impeller periphery
into a housing with impeller blades; the blades are positioned so their
outward direction is perpendicular within 25 degrees to the axis of
rotation. Impellers can have a back plate and/or shroud.
* * * * *
0
7. Amend Sec. 431.173 by redesignating paragraphs (c) and (d) as
paragraphs (d) and (e), respectively, and adding a new paragraph (c) to
read as follows:
Sec. 431.173 Materials incorporated by reference.
* * * * *
(c) IEC. International Electrotechnical Committee, Central Office,
3, rue de Varemb[eacute], P.O. Box 131, CH-1211 GENEVA 20, Switzerland;
+ 41 22 919 02 11; webstore.iec.ch.
[[Page 3872]]
(1) IEC 61800-9-2:2023, Adjustable speed electrical power drive
systems (PDS)--Part 9-2: Ecodesign for motor systems--Energy efficiency
determination and classification, Edition 2.0, 2023-10; IBR approved
for appendix A to this subpart.
(2) IEC TS 60034-30-2:2016, Rotating electrical machines--Part 30-
2: Efficiency classes of variable speed AC motors (IE-code), Edition
1.0, 2016-12; IBR approved for appendix A to this subpart.
(3) IEC TS 60034-31:2021, Rotating electrical machines--Part 31:
Selection of energy-efficient motors including variable speed
applications--Application guidelines, Edition 2.0, 2021-03; IBR
approved for appendix A to this subpart.
* * * * *
0
8. Section 431.175 is added to read as follows:
Sec. 431.175 Energy conservation standards and compliance dates.
(a) Each fan and blower, other than an air circulating fan
manufactured starting on [DATE FIVE YEARS AFTER DATE OF PUBLICATION OF
FINAL RULE] that is subject to the test procedure in Sec. 431.174(a),
must have a FEI value at each duty point for which the fan is
distributed in commerce, that is equal or greater than the value in
table 1 of this section. The manufacturer is responsible for ensuring
that each fan and blower, other than an air circulating fan
manufactured starting on [DATE FIVE YEARS AFTER DATE OF PUBLICATION OF
FINAL RULE] that is subject to the test procedure in Sec. 431.174(a),
is sold and selected at compliant duty points.
Table 1 to Paragraph (a)--Energy Conservation Standards for Fans and Blowers Other Than Air Circulating Fans
----------------------------------------------------------------------------------------------------------------
Equipment class With or without motor controller Fan energy index (FEI) *
----------------------------------------------------------------------------------------------------------------
Axial Inline............................ Without........................... 1.18 * A.
Axial Panel............................. Without........................... 1.48 * A.
Axial Power Roof Ventilator............. Without........................... 0.85 * A.
Centrifugal Housed...................... Without........................... 1.31 * A.
Centrifugal Unhoused.................... Without........................... 1.35 * A.
Centrifugal Inline...................... Without........................... 1.28 * A
Radial Housed........................... Without........................... 1.17 * A.
Centrifugal Power Roof Ventilator-- Without........................... 1.00 * A.
Exhaust.
Centrifugal Power Roof Ventilator-- Without........................... 1.19 * A.
Supply.
Axial Inline............................ With.............................. 1.18 * A * B.
Axial Panel............................. With.............................. 1.48 * A * B.
Axial Power Roof Ventilator............. With.............................. 0.85 * A * B.
Centrifugal Housed...................... With.............................. 1.31 * A * B.
Centrifugal Unhoused.................... With.............................. 1.35 * A * B.
Centrifugal Inline...................... With.............................. 1.28 * A * B.
Radial Housed........................... With.............................. 1.17 * A * B.
Centrifugal Power Roof Ventilator-- With.............................. 1.00 * A * B.
Exhaust.
Centrifugal Power Roof Ventilator-- With.............................. 1.19 * A * B.
Supply.
----------------------------------------------------------------------------------------------------------------
* A is a constant representing an adjustment in FEI for motor hp, which can be found in table 2 of this section.
B is a constant representing an adjustment in FEI for motor controllers, which can be found in table 2 of this
section.
[GRAPHIC] [TIFF OMITTED] TP19JA24.133
[[Page 3873]]
Table 3 to Paragraph (a)--2014 Motor Efficiency Values, [eta]mtr,2014
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full-load efficiency (%)
---------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt equivalent 2 Pole 4 Pole 6 Pole 8 Pole
---------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
100/75.......................................................... 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1
125/95.......................................................... 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1
150/110......................................................... 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1
200/150......................................................... 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1
250/186......................................................... 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
(b) Each air circulating fan manufactured starting on [DATE FIVE
YEARS AFTER DATE OF PUBLICATION OF FINAL RULE] that is subject to the
test procedure in Sec. 431.174(b), must have an efficacy value in CFM/
W at maximum speed that is equal or greater than the value in table 4
to this paragraph (b).
Table 4 to Paragraph (b)--Energy Conservation Standards for Air
Circulating Fans
------------------------------------------------------------------------
Efficacy at maximum speed
Equipment class * (CFM/W)
------------------------------------------------------------------------
Axial Air Circulating Fans; 12'' <= D < 12.2
36''......................................
Axial Air Circulating Fans; 36'' <= D < 17.3
48''......................................
Axial Air Circulating Fans; 48'' <= D...... 21.5
Housed Centrifugal ACFs.................... N/A
------------------------------------------------------------------------
* D: diameter in inches.
N/A means not applicable as DOE is not proposing to set a standard for
this equipment class.
0
9. Amend appendix A to subpart J of part 431 by:
0
a. Revising the section 0 introductory text and paragraph 0.2.(h);
0
b. Redesignating section 0.3 as 0.6;
0
c. Adding new section 0.3, and sections 0.4 and 0.5;
0
d. Revising section 2.2.1;
0
e. Redesignating section 2.6 as 2.7; and
0
f. Adding new section 2.6.
The revisions and additions read as follows:
Appendix A to Subpart J of Part 431--Uniform Test Method for the
Measurement of Energy Consumption of Fans and Blowers Other Than Air
Circulating Fans
* * * * *
0. Incorporation by reference.
In Sec. 431.173, DOE incorporated by reference the entire
standard for AMCA 210-16, AMCA 214-21, IEC 61800-9-2:2023, IEC TS
60034-30-2:2016, IEC TS 60034-31:2021, and ISO 5801:2017; however,
only enumerated provisions of those documents are applicable as
follows. In cases where there is a conflict, the language of this
appendix takes precedence over those documents.
* * * * *
0.2 * * *
(h) Section 6.4, ``Fans with Polyphase Regulated Motor'' as
referenced in sections 2.2 and 2.6 of this appendix;
* * * * *
0.3 IEC 61800-9-2:2023:
(a) Section 6.2 as referenced in section 2.6.2.2 of this
appendix;
(b) Table A.1 as referenced in section 2.6.2.2 of this appendix;
and
(c) Table E.4 as referenced in 2.6.1.2.1. of this appendix; and
(d) Section F.2.1 as referenced in section 2.6.2.2 of this
appendix.
0.4 IEC TS 60034-30-2:2016:
(a) Section 4.7 as referenced in section 2.6.1.2.2 of this
appendix; and
(b) Table 4 as referenced in section 2.6.1.2.2 of this appendix.
0.5 IEC TS 60034-31:2021:
(a) Section A.3 as referenced in section 2.6.1.2.1 of this
appendix; and
* * * * *
2. * * *
2.2 * * *
2.2.1. General. The fan electrical power (FEPact) in kilowatts
must be determined at every duty point specified by the manufacturer
in accordance with one of the test methods listed in table 1, and
the following sections of AMCA 214-21: Section 2, ``References
(Normative)''; Section 7, ``Testing,'' including the provisions of
AMCA 210-16 and ISO 5801:2017 as referenced by Section 7 and
implicated by sections 2.2.2 and 2.2.3 of this appendix; Section
8.1, ``Laboratory Measurement Only'' (as applicable); and Annex J,
``Other data and calculations to be retained.'' In addition, the
provisions in this appendix apply.
Table 1 to Appendix A to Subpart J of Part 431
----------------------------------------------------------------------------------------------------------------
Motor controller Transmission Applicable section(s)
Driver present? configuration? Test method of AMCA 214-21
----------------------------------------------------------------------------------------------------------------
Electric motor................. Yes or No........ Any.............. Wire-to-air...... 6.1 ``Wire-to-Air
Testing at the
Required Duty
Point''.
Electric motor................. Yes or No........ Any.............. Calculation based 6.2 ``Calculated
on Wire-to-air Ratings Based on Wire
testing. to Air Testing''
(references Section
8.2.3, ``Calculation
to other speeds and
densities for wire-to-
air testing,'' and
Annex G, ''Wire-to-
Air Measurement--
Calculation to Other
Speeds and Densities
(Normative)'').
[[Page 3874]]
Regulated polyphase motor...... Yes or No........ Direct drive, V- Shaft-to-air..... 6.4 ``Fans with
belt drive, Polyphase Regulated
flexible Motors,'' *
coupling or (references Annex D,
synchronous belt ``Motor Performance
drive. Constants
(Normative)'').
None or non-electric........... No............... None............. Shaft-to-air..... Section 6.3, ``Bare
Shaft Fans''.
Regulated polyphase motor...... No............... Direct drive, V- Calculation based Section 8.2.1, ``Fan
belt drive, on Shaft-to-air laws and other
flexible testing. calculation methods
coupling or for shaft-to-air
synchronous belt testing'' (references
drive. Annex D, ``Motor
Performance Constants
(Normative),'' Annex
E, ``Calculation
Methods for Fans
Tested Shaft-to-
Air,'' and Annex K,
``Proportionality and
Dimensional
Requirements
(Normative)'').
None or non-electric........... No............... None............. Calculation based Section 8.2.1, ``Fan
on Shaft-to-air laws and other
testing. calculation methods
for shaft-to-air
testing'' (references
Annex E,
``Calculation Methods
for Fans Tested Shaft-
to-Air,'' and Annex
K, ``Proportionality
and Dimensional
Requirements
(Normative)'').
----------------------------------------------------------------------------------------------------------------
* With the modifications in section 2.6 of this appendix.
Testing must be performed in accordance with the required test
configuration listed in table 7.1 of AMCA 214-21. The following
values must be determined in accordance with this appendix at each
duty point specified by the manufacturer: fan airflow in cubic feet
per minute; fan air density; fan total pressure in inches of water
gauge for fans using a total pressure basis FEI in accordance with
table 7.1 of AMCA 214-21; fan static pressure in inches of water
gauge for fans using a static pressure basis FEI in accordance with
table 7.1 of AMCA 214-21; fan speed in revolutions per minute; and
fan shaft input power in horsepower for fans tested in accordance
with sections 6.3 or 6.4 of AMCA 214-21.
In addition, if applying the equations in section E.2 of annex E
of AMCA 214-21 for compressible flows, the compressibility
coefficients must be included in the equations as applicable.
All measurements must be recorded at the resolution of the test
instrumentation and calculations must be rounded to the number of
significant digits present at the resolution of the test
instrumentation.
In cases where there is a conflict, the provisions in AMCA 214-
21 take precedence over AMCA 210-16 and ISO 5801:2017. In addition,
the provisions in this appendix apply.
* * * * *
2.6. Calculation based on Shaft-to-air testing for Fans with
Motors and Motor Controllers. The provisions of section 6.4 of AMCA
214-21 apply except that the instructions in section 6.4.2.4.1 of
AMCA 214-21 are replaced by section 2.6.1 of this appendix, and the
instructions in section 6.4.2.4.2. of AMCA 214-21 are replaced by
section 2.6.2 of this appendix.
2.6.1 Motor efficiency if used in combination with a VFD. This
section replaces section 6.4.2.4.1 of AMCA 214-21 and provides
methods to calculate the efficiency of the motor if it is combined
with a VFD.
2.6.1.1 Motor efficiency Calculation, if used in combination
with a VFD. The efficiency of the motor if it is combined with a VFD
is calculated as follows:
[GRAPHIC] [TIFF OMITTED] TP19JA24.134
Where:
hmtr',act is the actual motor efficiency if used in combination with
a VFD.
Lm is the is motor load ratio calculated per section 6.4.2.4.1.3 of
AMCA 214-21
p'L are the relative losses of a motor of if used in combination
with a VFD that that exactly meets the applicable standards at Sec.
431.25 per section 2.6.1.2. of this appendix.
2.6.1.2. Relative losses of the actual motor if used in
combination with a VFD. This section provides the methods to
calculate the relative losses P'L of a motor that exactly meets the
applicable standards at Sec. 431.25, if used in combination with a
VFD:
[GRAPHIC] [TIFF OMITTED] TP19JA24.135
Where:
pL(n,T) are the relative losses of an IE3 motor if used in
combination with a VFD calculated per section 2.6.1.2.1 of this
appendix.
hr nominal full load efficiency per section 6.4.2.4.1.1 of AMCA 214-
21
hIE3 is nominal full load efficiency of an IE3 motor per section
2.6.1.2.2. of this appendix.
2.6.1.2.1. Relative losses of an IE3 motor if used in
combination with a VFD. The relative losses of an IE3 motor if used
in combination with a VFD, pL(n,T) are based on the actual motor
nameplate rated speed and the motor nameplate output power and must
be calculated per section A.3 of IEC TS 60034-31:2021, using the
coefficients in table E.4 of IEC 61800-9-2:2023. If the motor
nameplate output power value is not shown in table E.4 of IEC 61800-
9-2:2023, the instructions in section 6.4.2.4.1.1 of AMCA 214-21
must be used.
The calculation of pL(n,T) relies on the relative speed (n) and
relative torque (T) values which are determined for each duty point
as follows:
[GRAPHIC] [TIFF OMITTED] TP19JA24.136
And:
[GRAPHIC] [TIFF OMITTED] TP19JA24.137
Where:
hact is the fan speed in revolutions per minute at the given duty
point;
hr is the nameplate nominal rated speed of the actual motor
revolutions per minute; and
Lm is the motor load ratio calculated per section 6.4.2.4.1.3 of
AMCA 214-21.
2.6.1.2.2. Nominal full load efficiency of an IE3 motor. The
nominal full load efficiency of an IE3 motor must be determined per
section 4.7 of IEC TS 60034-30-2:2016 and is based on the actual
motor nameplate rated speed and the motor nameplate output
[[Page 3875]]
power. If the motor nameplate output power value is not shown in
table 4 of IEC TS 60034-30-2:2016, the instructions in section
6.4.2.4.1.1 of AMCA 214-21 must be used.
2.6.2 VFD efficiency at the required motor electrical power
input. This section replaces section 6.4.2.4.2 of AMCA 214-21 and
provides methods to calculate the efficiency of the VFD at the
required motor electrical power input. A single VFD may operate one
or many motors.
2.6.2.1 VFD efficiency calculation. The efficiency of the VFD at
the required motor electrical power input is calculated as follows:
[GRAPHIC] [TIFF OMITTED] TP19JA24.138
Where:
hVFD is the VFD efficiency at the required motor electrical power
input;
Lc is the is VFD load ratio calculated per section 6.4.2.4.2.2 of
AMCA 214-21; and
pVFD,L(f, iq) are the relative losses of a VFD at IE2 levels per
section 2.6.2.2 of this appendix.
2.6.2.2. Relative losses of a VFD at IE2 levels. The relative
losses of an IE2 VFD, hVFD,L(f, iq) are inter- or extrapolated from
the relative losses in table A.1 of IEC 61800-9-2:2023, adapted for
IE2 in accordance with section 6.2 of IEC 61800-9-2:2023. The
calculations must follow the two-dimensional linear inter- or
extrapolation from neighboring loss points in accordance with
section F.2.1 of IEC 61800-9-2:2023. In addition, the relative
losses of an IE2 VFD, pVFD,L(f, iq), are based on the actual VFD
nameplate rated output power. If the motor nameplate output power
value is not shown in table A.1 of IEC 61800-9-2:2023, the
instructions in section 6.4.2.4.1.1 of AMCA 214-21 must be used.
The calculation of pVFD,L(f, iq) relies on the relative motor
frequency (f) and relative torque current (iq) values which are
determined for each duty point as follows:
f = n
And:
[GRAPHIC] [TIFF OMITTED] TP19JA24.139
Where:
n is the relative speed per section 2.6.1.2.1. of this appendix;
T is the relative torque per section 2.6.1.2.1. of this appendix;
Hmo is motor nameplate output power; and
Hco is rated power output of the VFD.
* * * * *
[FR Doc. 2023-28976 Filed 1-18-24; 8:45 am]
BILLING CODE 6450-01-P