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UNITED STATES DEPARTMENT OF ENERGY 

ENERGY EFFICIENCY AND RENEWABLE ENERGY 

OFFICE OF BUILDING TECHNOLOGIES 

- - - - - - - - - - - - - - - X 

 : 

ASRAC FANS AND BLOWERS : 

WORKING GROUP MEETING : 

 : 

- - - - - - - - - - - - - - - X 

A meeting in the above-entitled matter was held on 

Wednesday, June 3, 2015, commencing at 9:06 a.m., at 950 

L'Enfant Plaza, Seventh Floor, Room 7140, Washington, D.C. 

20585-0121. 
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 P R O C E E D I N G S 

 MS. ARMSTRONG: So, we'd like to welcome you guys

again today. Are we ready on the Webinar and the 

transcript? 

 COURT REPORTER: Yes. 

 MS. ARMSTRONG: We're good? Okay. So we're in a

small room today as you might have noticed. We're going to 

make new friends and share new ideas. It's going to be good 

for all of us and fun. And there's no Internet too, so we 

can all really focus on fans and DOE regulations and how 

they might work together. We're going to go around the room 

real quick just for the transcript and everyone say their 

name and their affiliation. We'll start with this back 

corner. But I will say there's not microphones above you 

like there is in the other room, so speak loud, please, just 

so she can hear you for the record. There are some mini 

microphones around, but it would be most helpful if you 

could do that. 

 MR. STEVENS: Sure. I'm Mark Stevens. I'm with 

the Air Movement and Control Association. 

 MS. ARMSTRONG: Great. Thanks. 

 MR. TEAKELL: Kevin Teakell with AAON. 

 MR. BOTELER: Robert Boteler, Nidec Motor. 

 MR. MAGILL: John Magill with Howden. 

 MR. MORRISON: Frank Morrison with Baltimore 
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Aircoil Company, alternate member for the cooling 

technology. 

 UNIDENTIFIED MALE: Thank you. 

 MS. ARMSTRONG: You're welcome. 

 MR. ERNST: Skip Ernst, Daikin Applied. 

 MR. WHITWELL: Bob Whitwell, Carrier. 

 MR. DYGERT: Ryan Dygert, Carrier. 

 MS. PETRILLO: Laura Petrillo-Groh, AirConditioning, Heating and Refrigeration Institute. 

 MR. FLY: Mark Fly, AAON. 

 MR. WINNINGHAM: Dave Winningham, Allied Air. 

 MR. DELANEY: Dan Delaney, Regal-Beloit 

representing NEMA. 

 MR. LIN: Paul Lin with Regal-Beloit representing

NEMA. 

 MS. DAVIDSON-HOOD: Caroline Davidson-Hood, AHRI.

 MR. JOHNSON: David Johnson, Berner International. 

 MS. MAUER: Joanna Mauer, Appliance Standards 

Awareness Project. 

 MR. DIKEMAN: Steve Dikeman, AcoustiFLO. 

 MR. FERNSTROM: Gary Fernstrom representing the 

California Investor-Owned Utilities, which would be Pacific 

Gas and Electric, Southern California Edison, San Diego Gas 

and Electric and the Southern California Gas Company. 

 MR. SMILEY: Bill Smiley representing Trane. 
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 MR. SMITH: Wade Smith with the Air Movement and 

Control Association. 

 MR. BURDICK: Larry Burdick, SPX Technologies 

representing Cooling Technology Institute. 

 MR. HAUER: Armin -- 

 UNIDENTIFIED FEMALE: No. Go. Sorry. 

 MR. HAUER: Sorry. Armin Hauer of ebm-pabst in 

Connecticut. 

 MR. DADDIS: Duane Daddis, Carrier. 

 MR. BUBLITZ: Mark Bublitz, The New York Blower 

Company. 

 MR. HOWE: Nick Howe, Carnes Company. 

 MR. PERSFUL: Trinity Persful, Twin City Fan 

Companies. 

 MR. WOLF: Mike Wolf, Greenheck. 

 MR. ROY: Aniruddh Roy, Goodman. 

 MR. MCCABE: Michael McCabe, consultant to Trane. 

 MS. ARMSTRONG: Ashley Armstrong, DOE. 

 MS. IYAMA: Sanaee Iyama, Lawrence Berkeley 

National Lab. 

 MR. COCHRAN: Pete Cochran, DOE. 

 MR. JASINSKI: Sam Jasinski, Navigant consultant.

 MR. WIGGINS: Steve Wiggins, Newcomb and Boyd. 

 MS. SHEPHERD: Amy Shepherd, Air-Conditioning, 

Heating and Refrigeration Institute. 
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 MR. CATANIA: Tom Catania, alternate for the Air 

Movement and Control Association. 

 MR. MATHSON: Tim Mathson, Greenheck Fan. 

 MR. FINE: Steve Fine from the Office of Hearings

and Appeals. 

 MR. BOSWELL: Wade Boswell from DOE's Office of 

Hearings and Appeals. 

 MS. PONTILLO: Pam Pontillo, Department of Energy, 

Office of Conflict Prevention and Resolution. 

 UNIDENTIFIED MALE: Okay. And I understand that 

there are two members of the Working Group online with open 

mics, if they could introduce themselves? 

 MS. JAKOBS: Diane Jakobs from Rheem. 

 UNIDENTIFIED MALE 1: And is Greg, is Greg Wagner

still online? 

 IT SPECIALIST: He is, but he needs to enter his 

audio again. 

 UNIDENTIFIED MALE 1: Okay. Any other Working 

Group members online at this point? So, once again, welcome 

to the fifth meeting of the ASRAC Fan Working Group. 

Ashley, were there other housekeeping matters, or did you 

want to go into the status of homework and the updates 

there? 

 MS. ARMSTRONG: Yeah, so I guess this would be a 

good time just to talk about the agenda really quick, to 
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touch base on a few things. I, I do want to go through the 

list of homework items that we had sent out like right 

after, couple days after the previous meeting, and see where 

we are on each of those. I know we had a handful of 

requests to speak. I tried to catch them all last night 

before I, when I was writing this agenda, but I might have 

missed some. If, if anybody else would like to speak, 

you're welcome to do so. If you have a presentation or a 

file that you would like to share, either it's with regards 

to detailed responses to homework, or specific items that 

the committee's been grappling with, Alex is happy to load 

that if you have a, you know, little disk, any, load that so 

that everyone can see it. I didn't print out the individual 

presentations though. 

 Does that sound generally good for the morning 

part of the discussion? Additional issues? Yes, no, 

feedback? Silence? Okay. Silence is happiness, so. 

That's how we do things in this committee. So, one of the 

things I wanted to bring up also. After the break, I think 

we plan to, or at least after lunch, plan to do two things. 

 One is, DOE is going to give our presentation of 

the NODA in terms of how the analyses were conducted, what 

types of data sources were used, let each of us kind of walk 

you through what we've already published with regards to the 

analysis for fans and blowers to date. One of the things 
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that I also wanted to do, and it's kind of, we touched on 

this a little bit last meeting, but it's kind of a new, new 

subject to this group. It's discuss representations and, 

and kind of how you make representations, what does it mean 

to come up with a representative value or a rated value for 

your fan or blower, you know, how does that work typically 

with DOE regs, what are some options on the table here and 

then what does that mean in terms of certification and 

ultimately enforcement of those rated values. And that's 

just more of to give you a sense of what we do to date, 

generally speaking for all products. I think it might be 

helpful to inform you about that aspect of our regulations 

as we move forward. So that's more of a, I'm doing that ad 

hoc. I didn't actually come up with a presentation in the 

middle of the night last night. But hopefully we can have 

that dialogue towards the end of the day. 

 Were there any other items that people see that 

are missing that they'd like to bring up to actually discuss 

or try to come to a resolution? I mean, we're going to walk 

through some of the homework items. Some of them may be 

more detailed than others but. Yeah? 

 MR. SMITH: There's been a lot of work done on 

definitions. 

 MS. ARMSTRONG: Yes. 

 MR. BUBLITZ: Okay. Can we identify ourselves on
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the record as we speak? 

 MS. ARMSTRONG: That's fine. 

 MR. SMITH: This is Wade Smith. 

 MR. BUBLITZ: Thank you. Mark Bublitz is saying 

it to Wade Smith. 

 MR. SMTIH: This is Wade Smith. 

 MR. BUBLITZ: Wade. 

 MR. SMITH: The AMCA Fan Committee has done some 

additional work on definitions and we submitted, actually 

during the last meeting, work that had been done previously 

between the advocates and, and the AMCA members. And you 

know, some of those definitions I think we could close the 

door on with the consensus of the group. I don't think 

there's much controversy in other words. And some of them 

are still a work in progress, but we'll continue to beaver 

away at it. And I guess the question is, how actually you 

and or the Working Group wants to see this as, as it 

develops? Do you want it, in other words, do you want to 

see the debate as it unfolds or do you just want to see the 

end result? I don't, I, I don't, we don't really care. 

We'll be happy to share whatever the group wants here. 

 MS. ARMSTRONG: So that's really up to the Working 

Group. I think at some point it would be helpful for 

someone from AMCA, or whomever at that point, to present the 

definitions to the Working Group to get the Working Group's 
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feedback before you present. I mean, obviously. 

 MR. SMITH: Well, we'd, we'd be happy to do that 

now, I mean -- 

 MS. ARMSTRONG: Yes. So, perhaps we can put that 

as an agenda item. If you have a file that you want to work 

off of, if it's not the file you've, you've already sent 

out, if you have a -- 

 MR. SMITH: Right. 

 MS. ARMSTRONG: -- a more revised one, you can 

just get it to me on a flash drive? 

 MR. SMITH: Sure. 

 MS. ARMSTRONG: We can get it to Alex. But I 

think the committee would benefit from hearing where you are 

now, kind of some of the ones. That could help shape the, 

some of the discussions moving along. So, yeah, let's, that 

would be great. 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: Anybody else? 

 MR. HAUER: I have a question. 

 MS. ARMSTRONG: Yes. 

 MR. HAUER: Armin Hauer of ebm-pabst. I was 

wondering, is the Department obligated to, to any 

international commonization of standards? Obviously, all 

the trans, the trans-Pacific trade deals going on and the 

Atlantic trade deal, do we have to commonize (phonetic sp.) 
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any of that standards or can we reinvent the wheel here? 

 MS. ARMSTRONG: That's a loaded question so early

in the morning. Have is probably a, a bit strong of a word 

there, but I would say the Department's intent is to 

obviously work on harmonization where it makes sense. We 

have separate statutory obligations and in some cases there 

are statutes written very differently, so we have found 

cases where we have tried to harmonize as much as possible 

for other products, but it's not an identical one-to-one. 

Because, but yes, I mean, we should be working towards with 

that in mind, but we don't have to isn't the right word, I 

would say. We have to meet our statutory obligations. So 

if there's a conflict there. Fair enough? 

 MR. HAUER: That's fair enough. 

 MS. ARMSTRONG: So that can definitely be part of

the discussion. Does anybody else want to bring anything up 

at the outset? 

 MR. FERNSTROM: So this is Gary. When we did the

introductions, Meg from NRDC was on mute, but she's on the 

Webinar now. 

 MS. ARMSTRONG: Great. Meg, welcome. And can you 

unmute her, because she's an actual voting member too? 

 UNIDENTIFIED MALE: Yeah, I did it. 

 MS. ARMSTRONG: Great. Anybody else? All right. 

We're going to go through the list of homework items. And 
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I'm just going to go through them one by one. I don't have 

them on the board, but so one of the things I said we'd do 

is schedule meeting times, location. Everybody has those 

now and we've updated our website. We should all have where 

the meeting is, what, all the various times it starts and 

ends and all the various places that we could be meeting. 

Everyone have those that need that information? We're good? 

Okay. Check. Amber will provide feedback on the compressor 

cutoff definition on a fan. I think you provided something 

about her and I wonder if you want to just give a high level 

explanation of what you provided in case anybody has any 

other feedback they'd like to. 

 UNIDENTIFIED MALE 1: The question was whether or

not 25, is it kilograms per joule or joules per kilogram? 

 UNIDENTIFIED MALE 2: Oh, joules per kilogram. 

 UNIDENTIFIED MALE 1: Or joules per kilogram. Is

it appropriate to cutoff distinguishing between fans and 

compressors? And the answer is that we agree that, that, 

that's the right answer. It, it appears in both European 

and American standards and it's widely accepted and it makes 

perfect sense, so, it's easy to agree. 

 MS. ARMSTRONG: Okay. Does anybody else have any

feedback on that item? We're in general agreement on that 

one? Okay. Great. So that saying, I said we'd send out 

redline to the presentation. Everyone got the 
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presentations, they were submitted, they were sent out a 

couple days after the last Working Group meeting, so 

hopefully they helped you in advance. 

 Next is the Working Group will review the 

definitions of each equipment cost to ensure they are 

mutually exclusive and then the associated testable

configurations. So we got a variety of feedback on that 

one. I don't know if we want to, do you want me to load 

those slides and go through them again or, Wade, do you want 

to use this as your opportunity to present the definitions 

to your group? I know I may need some facts and feedback as 

well. So, I don't know if you want to, how you want to 

handle that with the group. 

 MR. SMITH: I accept it. I would answer 

questions, but I'm not prepared to. 

 MS. ARMSTRONG: Okay. Sounds good. So do you 

guys want to start and just dive in the definitions now? 

No, you don't. Okay. 

 You want to do opening presentations first? 

 UNIDENTIFIED MALE: I, I, I'd rather get, get you, 

the, the slide and, and put the slide up and go through it. 

 MS. ARMSTRONG: All right. So let's kind of do it 

after lunch or after break when -- 

 UNIDENTIFIED MALE: Okay. 

 MS. ARMSTRONG: -- we can do that. Okay. Sounds
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good. Next is AHRI will provide some type of proposal to 

the Working Group regarding the scope that attempts to 

address the concerns voiced within the working group 

regarding delineation and how, how it expands use and data 

and energy use. So I think, Laura, you have the 

presentation loaded, or do you want to -- 

 MS. PETRILLO-GROH: Our presentation's loaded. I

think we had, the order of our presentations makes a little 

bit more sense. I basically got it on, on the, on the board 

right now. 

 MS. ARMSTRONG: Okay. Great. 

 MS. PETRILLO-GROH: And you know, we started 

sending out data surveys for each of the different equipment 

types. We're getting a lot of feedback, but the answers 

were very varied, so it's going to take a little while to 

finish that analysis. It is (indiscernible). 

 MS. ARMSTRONG: So when do you think you'll be 

able to have that? 

 MS. PETRILLO-GROH: For the next meeting. 

 MS. ARMSTRONG: So that's the June, mid-June 

meeting? End of June meeting? 

 MS. PETRILLO-GROH: At least some -- 

 MS. ARMSTRONG: Twenty something? 

 MS. PETRILLO-GROH: -- at some of we'll be able to 

have for that. 
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 MS. ARMSTRONG: Okay. So the other thing we did, 

before we jump into the presentations, was we had asked 

about specific items for feedback regarding the test 

procedure. We had listed a bunch of test procedure items 

with regards to AMCA 210. Have you guys had a chance to 

look at some of those questions? 

 UNIDENTIFIED MALE: Yes. 

 MS. ARMSTRONG: Do you want us to tee it up for 

you when you're prepared? Why don't we let them do their 

presentations -- 

 UNIDENTIFIED MALE: I didn't have a presentation. 

 MS. ARMSTRONG: -- and then we'll tee up the 

definitions and then we'll tee up the test procedure 

questions and we'll march through all, each of those. Does 

that sound okay? 

 MR. SMILEY: Yeah, it's Bill Smiley, Trane. In, 

in the presentation I have like, I have -- 

 MS. ARMSTRONG: Some -- 

 MR. SMILEY: -- reviewed several classes of 

embedded products and also reviewed test methodologies for 

those. 

 MS. ARMSTRONG: Great. 

 MR. SMILEY: So -- 

 MS. ARMSTRONG: So with that, would you like to 

take the floor? 
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 MR. SMILEY: Well, I thought we were going to 

do -- 

 UNIDENTIFIED MALE: Skip, do you want to go first? 

 MR. ERNST: Yeah, okay. 

 MS. ARMSTRONG: Oh, Skip, I'm sorry. 

 MR. ERNST: Thank you. Just go up to the front? 

 MS. ARMSTRONG: Yeah, absolutely. So there should 

be a keyboard over there. 

 MR. ERNST: Is there a dancing bit? 

 UNIDENTIFIED MALE: No. 

 UNIDENTIFIED FEMALE: No. 

 MS. ARMSTRONG: Are you going to have to open 

that? Well, let's get yours then. 

 UNIDENTIFIED MALE: Do you want to explain that? 

 MS. ARMSTRONG: So he is the (indiscernible)? 

 UNIDENTIFIED MALE: No, no, no, no. 

 MS. ARMSTRONG: None of those. The first -- 

 MR. ERNST: Preso. 

 MS. ARMSTRONG: Oh, up front. Weren't those 

cleaned up? 

 UNIDENTIFIED MALE 1: No. That one was like -- 

 UNIDENTIFIED MALE 2: The first one was -- 

 UNIDENTIFIED MALE 1: (Indiscernible). 

 MR. ERNST: That, that, that'll work. 

 MS. ARMSTRONG: All right. 
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 MR. ERNST: Well, Skip Ernst with Daikin Applied. 

Thank you for taking this time to discuss some issues and 

opportunities. The, my presentation and some of the other 

AHRI presentations will have a common theme. And that is, 

there's lots of end uses for fans. And, and some of these 

are going to need some special consideration. 

 UNIDENTIFIED MALE: Mr. Ernst, could you speak up

a little bit? 

 MR. ERNST: Okay. 

 UNIDENTIFIED MALE: Okay. Thank you. 

 MR. ERNST: Return fans and exhaust fans are very

important to building owners and designers. They basically 

allow proper building pressurization control, as well as and 

if you do not do proper building pressure control and 

ventilation control, you'll waste a lot of energy, among 

other problems. Return, also, return fans and exhaust fans, 

just by their application and their nature, are going to be 

less efficient than the supply fan in a given unit. So we'd 

ask, you know, again, that regulations would consider these 

issues. As I go through the presentation, these are some of 

the acronyms that you'll see. Some of you, again, they're 

at the bottom of the screen, maybe you've seen them before. 

 UNIDENTIFIED MALE: Yes. 

 MR. FERNSTROM: So this is Gary for the California 

IOUs. I presume we can ask questions as you go through? 
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 MR. ERNST: Please. 

 MR. FERNSTROM: And, and my question would be why

fundamentally are return and exhaust fans less efficient? 

 MR. ERNST: Yeah, I'll show you that. That'll be

towards the end of the presentation. 

 MR. FERNSTROM: Okay. 

 MR. ERNST: I'll first go through why -- 

 MR. FERNSTROM: Thank you. 

 MR. ERNST: -- building pressure controls are 

important and why return fans and exhaust fans are important 

for that. The, first of all, building pressure typical 

values that you would want to see are very slightly

positive. Again, numbers that are pretty hard to measure 

with normal instrumentation, 0.5s, 0.1 positive pressure is 

what you typically would want to see with building pressure. 

Listed some of the problems you have here if you do not 

properly maintain building pressure control. The doors are 

going to be difficult to open and close. You'll end up 

with poor ventilation control, which is either going to be 

one of two things. You're either going to have too much 

ventilation and waste energy or too little and your indoor 

air quality is going to suffer. And again, you'll have poor 

perimeter comfort control and you can, with negative 

pressure especially, have problems with condensation inside 

the walls of the building if you're pulling in moist 
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summertime air. 

 Now rooftops, especially multi-story rooftops, 

very often require powered return fans and exhaust fans in 

order to achieve proper building pressure control. The, and 

what I'm going to go through now on these next few slides is 

to show you why. But again, and I'm going to give you an 

example where we're talking about a multi-story application 

with a ducted return typical of two, three, four stories 

with variable volume. The, the issue becomes most clear 

when you look at that application and I think you'll, as we 

look at the numbers and the science, you'll see it applies 

to other applications too, to either a greater or a lesser 

extent. But this one's a pretty common one that really 

illustrates the issues. If you take a look at that rooftop 

unit and the application, let's say your desired space 

pressure control is at a tenth of an inch and on this ducted 

return you have an inch of air pressure drop. Again, the 

fan has to generate an inch of, of pressure to force the air 

through that return ductwork. So, if again, if you're 

having it, this is a, the basic parameters that we're going 

to be looking at in this example. Now if you start with a 

tenth of an inch of pressure drop here and a one inch 

pressure drop loss, then you're going to end up with a 

negative pressure of about nine-tenths in the back end of 

the, of that rooftop unit in the economizer section, the 
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return air section, whatever you want to call it. 

 Now taking a closer look at that section again, 

this is, you would typically have your exhaust air dampers, 

your return air dampers, your outdoor air dampers and, 

again, in this section right here you have, again, ninetenths of an inch of negative pressure. Otherwise, the air 

isn't going to flow. The, the air isn't going to flow back 

from the space to the, to the return part of the unit with 

that sort of return duct pressure drop that I showed you. 

So this is, again, this is important. Hopefully we're all 

together at this point, because this is, you've got to 

understand this to go, as we go through the rest of the 

presentation. 

 Now, the first problem that you're going to have 

on a supply fan only system, with a negative pressure here, 

atmospheric pressure here, you can't exhaust air. Right? 

Negative pressure here. This is zero pressure or 

atmospheric pressure. There's no exhaust from this supply 

fan only system from the back, from the rooftop exhaust 

section. That's a problem. That's the first problem and a 

big one. And again, this is, now when that happens, when 

you, if you end up with no exhaust from the unit, then the 

supply fan starts, it starts pulling air through two paths. 

The planned air path is back through the return air portion 

of the unit. But it's also pulling in outdoor air for 
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ventilation. And that ventilation air can't exhaust here. 

What it does is it builds up pressure in the space so that 

the air goes out through the walls of the building and then 

back through the outdoor air. Those are the two air paths 

that you will start generating on that supply fan only 

system. And again, whenever you have two parallel air flow 

paths, you get equal pressure drops through each path, it's 

just the air will, you know, adjust itself until you get 

equal air pressure drops. 

 So, now what happens on a tight building when all

the doors are closed? What's going to happen? You've got 

this outdoor air, air damper open, the fan is going to be 

trying to draw in some outdoor air, but that outdoor air has 

to go someplace. The only way is to build up a big positive 

pressure in the space so that it goes out through the walls 

and that's why you often will walk into a building and open 

the door and you'll feel a blast of air in the face, because 

the door was shut and it built up this positive pressure. I 

bet everybody has experienced that. And again, that's 

typical of a supply fan only system where, again, you're 

having trouble exhausting air through the intended exhaust 

path. Instead, you're exhausting through the building. Now 

when the doors open, then you have this wide open path of 

outdoor air into the building and then out through that door 

and you get all sorts of ventilation air. Way more than was 
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intended. So you get, that's where you start wasting 

energy. Now when the doors shut, it's a tight building. 

You get very little ventilation control and there you get 

your problems with insufficient ventilation and poor indoor 

air quality. At the end of the day, you've had no control 

is really what you have. It just depends on what happened 

is when, you know, people go in and out of the building you 

go from excess positive pressure to all sorts of, you know, 

excess outdoor air when the, when the doors open. 

 Now, the, the typical pressure drop through the 

return air damper, again, if we're nine-tenths of an inch in 

this portion of the unit with a little bit of air pressure 

drop through the open return air dampers, you're about one 

inch negative in the, that outdoor air intake section. 

 UNIDENTIFIED MALE: That's a problem. 

 MR. ERNST: Now this is where you end up with a 

second problem. You have this big negative pressure trying 

to pull air in through this outdoor air damper. As we said, 

whenever that, those door open, you get an, all sorts of air 

coming in because you have this big suction pressure at this 

point. The, so again, at, this is, you're going to end up 

with very poor ventilation control is the second problem. 

And I'll show you a little bit about dampers. You can even 

quantify this to some extent. I can't reach to all portions 

of the screen. But this is, your dampers, as damp, this is 
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as your dampers open and close. This is zero percent open. 

This is 100 percent open and then that, this would be zero 

percent air flow and 100 percent air flow. And this would 

be typical damper operation. And this is where you have 

very little pressure, suction pressure across the damper in 

a closed position. And this is where you have tremendous 

pressure across that damper. What happens in this scenario, 

you open the damper just a very slight amount and you get 

all sorts of air, because you've got all that suction 

pressure on the damper when it's closed. Now, that's the 

poorer control situation. 

 The good control situation is you have very little 

suction pressure on the damper when it's closed. You open 

the damper, you get a little bit of air. You open it more 

and you get a little more and you can have very good control 

in this situation. So then, yes? 

 MR. STARR: What kind of damper is that? Is it 

opposed blade or parallel of what you're showing there the 

operation of those? 

 MR. ERNST: There's, I don't know if I remember 

for sure which one this is. 

 UNIDENTIFIED MALE: Remember, identify yourself. 

 MR. STARR: Oh, Louis Starr of NEEA. I'm sorry. 

 MR. FLY: This is Mark Fly from AAON and that 

looks like an opposed blade damper. I mean, if you look, 
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the opposed blade damper will have a more linear effect than 

a, than a parallel blade (indiscernible). 

 MR. ERNST: Okay. 

 MR. SMILEY: This is Bill Smiley with Trane. It 

really doesn't matter to the point you're trying to make. 

 MR. ERNST: Yeah. 

 MR. SMILEY: What type of damper it is. 

 MR. ERNST: Yeah. 

 MR. SMILEY: Opposed blade damper you get more 

linear. 

 UNIDENTIFIED MALE: Let's go. 

 MR. ERNST: Right. Then again the, with, you also 

get better control if you have a low suction pressure on 

that damper when it's closed. Again, with either type 

pressure that's going to be the situation. It's some kind 

of code. So, we've identified two problems that a supply 

fan only system has. And in each case you end up with poor 

building pressure control. You get excess outdoor air which 

wastes energy or insufficient outdoor air energy, 

insufficient outdoor air you get, you know, poor ventilation 

control and, and you have trouble controlling the 

ventilation period with the dampers. So this is the supply 

fan only system. 

 This would be the, adding a return fan to that, to 

that unit. Now you set up the return fan, you draw this, 
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the suction, you drawn the negative pressure right here at 

the inlet of the unit and the, the supply fan would be sized 

for that one inch air pressure drop in the return so you'd 

have essentially your slight positive pressure here in the 

exhaust section of the unit. And basically, you've solved 

that problem of no exhaust. You cannot exhaust from this 

negative pressure. This with some relief dampers works very 

well. The return fan, adding it in that way and sizing it 

for the return pressure drop makes that problem, that 

problem number one go away. 

 I can feel you're nodding yes. Is any 

disagreement or questions? Yes? 

 MR. WIGGINS: Yeah, I have a major disagreement 

with what you've shown because you're assuming that you 

don't know how to design a system properly, you don't know 

how to set the controls up to make it work. You can design 

a supply only system and select your duct design properly, 

select your dampers properly, install your controls properly 

and make a supply only system work with a variable exhaust. 

Can it work the way you've shown it? Well, the sad

statement is, the vast majority of them that are installed 

today work exactly like you showed because they're not set 

up properly. They're not designed properly. But you can 

take a supply only system and make it work. I set them up 

all day, every day and make them work. So, what your 
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example is, is right. That's how we typically see them in 

buildings today, but I can design the system with only a 

supply fan and set it up and make it work, because the Navy 

in 1978, '74 through '78, did a research project on over 

1,500 buildings that were designed with return fans and 

supply fans to determine why they were having so many 

problems with fan tracking and what, and how it's 

controlled. And they determined that, I'm sorry, my name is 

Steve Wiggins. I forgot to say that when I started talking. 

They determined that in 99 percent of those cases, with 

proper design, they could have completely eliminated the 

return fan. In some of the cases, they felt like they 

needed a relief fan, but not a return fan. And so, with 

proper design, I can do everything you're talking about 

without having a return fan. I may be limited on space and 

configuration to be able to size the return ductwork 

properly and be forced to make a return, return fan

selection and make it work. But let's get it on the record 

that I can design supply only fans, set it up, make it work 

and it'll work well. 

 MR. ERNST: What are the key aspects when you, you 

say proper design? 

 MR. WIGGINS: Sizing of return ductwork is the key 

element of it. The size of the dampers, the type of the 

dampers you talked about, the controllability is a key 
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element. Where am I going to monitor my building pressure 

and how I'm going to control the dampers has a key part of 

it? But I can set relief up and do all of that and make it 

work. We do it every day, all day long. 

 MR. ERNST: Now, if, if you have, if you do end up 

with a one inch return pressure drop, what, how would you 

handle a system like that? 

 MR. WIGGINS: I would say the designer should have 

done something different if he could have. 

 MR. ERNST: Okay. 

 MR. WIGGINS: But they shouldn't have a one inch 

drop. 

 MR. ERNST: And I would agree if you, as you 

reduce the return pressure, these issues do go away. 

 MR. WIGGINS: Exactly. Exactly. 

 MR. ERNST: I agree with that, but I, again, most, 

on multi-story buildings with ducted returns, this is what 

our customers typically ask from us on that return fan. 

 MR. WIGGINS: Well, it, it, it and, and I never 

said, but all I want to get on the record is -- 

 MR. ERNST: Uh-huh. 

 MR. WIGGINS: -- with proper design, and I don't 

even have to have a return fan in a lot of applications. I 

personally feel like the vast majority. When I do need a 

return fan, even sizing the ductwork can minimize the impact 
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you talk and other control strategies can help them get what 

you're talking about. 

 MR. ERNST: Yeah, you, if you can, you can over, 

if you get the ductworks large enough, get the pressure 

drops down. That's the general approach. 

 MR. WIGGINS: If I stood for design and all of 

those things and I tied my hands, your example's perfect. 

 MS. ARMSTRONG: Okay. 

 MR. ERNST: Yes? 

 MR. SMITH: This is Wade Smith with AMCA. The 

system you're describing can also be handled either with a 

modulating exhaust in the unit or with exhaust removed from 

the unit. 

 MR. ERNST: I'll show you an exhaust fan, what I 

will view as an exhaust fan example in a second. Is that 

okay? And then come back to that? 

 MR. SMITH: Yeah. I'm just, I'm just saying the 

return fan modulating exhaust or exhaust from the building 

that is not part of the unit are all options. 

 MR. ERNST: Uh-huh. Agreed. Yeah. 

 MR. FLY: Mark Fly with AAON. One of the things I 

think we ought to point out for those of us that don't live, 

live with fans and rooftop units every day, is that given 

this poorly designed system, if the building's sealed up and 

the doors aren't opened, that supply fan is carrying the 
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whole load that the supply and the return fan would be 

carrying. 

 MR. ERNST: Right. 

 MR. Fly: So that, you know, that one inch of, of

negative pressure in a supply only system ends up on the 

supply fan. So, there's really no, we can talk about 

efficiency, but there's no less air horsepower being used by 

having a supply fan or not having a supply, or having a 

return fan or not having a return fan. Because you're going 

to carry that load somewhere. 

 MR. WIGGINS: If you've got bad design, poor 

design on that, I wholeheartedly concur. As I said, I agree 

with the examples. Steve Wiggins again. I agree with the 

example as long as I'm assuming I've got a poor design on my 

return and I have to use that brake horsepower. If I can 

design that brake horsepower out, by simply changing my 

ductwork design, then I don't need to expend that energy at 

all. That's actually the best action. 

 MR. STARR: So this is Louis Starr of NEEA. So I

just came off of the commercial air handler rulemaking where 

AHRI provided shipments and they looked at it. And I can 

tell you what we were using in the static were 7 and a half, 

15 and 30 tons, which covers, you know, a certain size range 

of air handlers. We were using one inch static pressure for 

the whole system. That's supply and return. That's the 
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external static pressure, so. Kind of going into what Steve 

Wiggins said, and also if you look at where the, that the 

kind of units, there's a surprising, a lot of constant air 

volume units, so they're actually pretty simple systems. 

What, what you're showing here is, is a more complex system, 

but what it, it doesn't really capture much of the 

population is what I would say. And that's right off, it 

shouldn't, I was surprised too. I would think there would 

be lot more kind of VAVs, stuff with VAV boxes and 

distributed air systems, but a lot of it is just kind of 

your plain, simple retail-type stuff with a, you know, a 20 

ton unit on a large box retail store and, you know, you've 

got to drop, drop a supply only unit and the return's kind 

of right there, so. 

 MR. ERNST: That is where the biggest portion of 

the rooftop market exists in quantity of units. But there 

are quite a few large units with, one, two, three, four, 

five story buildings with ducted returns. And that's where 

-- 

 MR. STARR: Right. 

 MR. ERNST: -- this issue -- 

 MR. STARR: Well -- 

 MR. ERNST: -- comes into play. 

 MR. STARR: And that's what I'm saying. What, if

you back and you, those are public record. When you'll see 
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exactly how many of them are and it's surprisingly, it's not 

that many units, but I mean, I think it's an important issue 

and it's worth talking about, but in, in the scope of how 

much energy and how much is related to these units, we 

should definitely take a look at that and I think it would 

be worthwhile to understand the, the effect of what you're 

describing to us. 

 MR. WHITWELL: Bob Whitwell from Carrier. I'm 

also with a, in the same group that Louis is and I just want 

to color Louis's remarks a little bit, because it's true 

that if you look at the rooftop from 6 ton up to 63 ton, the 

majority of those units are still constant air volume. But 

that, that's mostly in the, in the less than 20 ton range, 

which is where the majority of the products are. If you 

look at the, the very large, which is the 20 ton and above, 

it's a much larger percentage that are VAV -- 

 UNIDENTIFIED MALE: What's the -- 

 MR. WHITWELL: -- which are going to be more 

complex like this. 

 UNIDENTIFIED MALE: Wasn't it 24 percent? 

 MR. WHITWELL: It was 24 percent of -- 

 UNIDENTIFIED MALE: Is that a lot? 

 MR. WHITWELL: -- that includes a large volume in

the 20 to 30 ton. If you look at the 30 ton and above, the, 

the numbers are more like 75 percent. Okay? Now you won't 
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see that in the data, but, but that's, that is the case. 

And what Skip is describing here is not only equipment up to 

63 ton, but this is equipment that is above 63 tons has 

these same, has these issues as well. So, we're talking 

about -- 

 MR. STARR: Yeah, okay. 

 MR. WHITWELL: -- Louis, we're talking about the 

complete rooftop product range, which goes beyond what we've 

talked about in the, in the (indiscernible) Workgroup 

Meeting. 

 MR. STARR: So this is Louis. Do you have any 

idea of how big that second segment of the market is or does 

it, or I should say, do you know relevant, I mean, these are 

the type of things that would help in sort of a -- 

 UNIDENTIFIED FEMALE: Limited might be the right 

word. 

 MR. FLY: Part of what they're, they asked, this 

is Mark Fly of AAON. This is part of what they ask is and 

that we're working on and, and AHRI is trying to find out 

what percentage of the population has return and which 

percentage of the population has exhaust and I don't know 

that, that's been collected. 

 MR. WHITWELL: No, that was not -- 

 UNIDENTIFIED MALE: Yeah. 

 MR. WHITWELL: -- part of that -- 
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 UNIDENTIFIED MALE: No. 

 MR. WHITWELL: -- because those are not part of 

the test procedure. 

 MR. STARR: I'm just talking about the sales 

volume. Not -- 

 UNIDENTIFIED MALE: Right. And that's what we're

working on. 

 MR. STARR: I mean, not whether it has a return 

fan or not, but the 63 is a larger, you probably didn't 

collect that information. Correct? 

 UNIDENTIFIED MALE: We had no reason to collect -- 

 MR. STARR: Right. 

 UNIDENTIFIED MALE: --that list. It's not a part

of that rulemaking group. 

 MR. STARR: But when you subtract it out of the, 

no, you couldn't actually just subtract that from the total 

sales. 

 MR. ERNST: We don't have the -- 

 MR. WHITWELL: AHRI does not collect that data 

normally. 

 UNIDENTIFIED FEMALE: No, that's, that's part of 

what we're collecting of this, for this effort. 

 UNIDENTIFIED MALE: Okay. 

 MR. ERNST: Now, again, let's look at -- 

 MR. WHITWELL: And, and, I'm sorry, this is Bob. 
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Just one more thing. And, and, you know, I want to also 

make it clear that the design issues that you're talking 

about are, are the building and the ductwork design issues. 

It's not related to the equipment. The equipment that we're 

talking about here, the rooftops, air handlers and that, 

they are designed to make up for those building and ductwork 

design issues. If the building and ductwork was done right, 

we wouldn't need these return air fans. But since they're 

not, I mean, what Skip is describing here is the, the 

industry's response or how we help our customers in order to 

overcome those problems. 

 MR. ERNST: And -- 

 MR. WIGGINS: Yeah. This is Steve Wiggins. I 

would agree with that exact statement. 

 MR. FLY: This is Mark Fly of AAON. And I, you 

know, I want to throw in, which I keep doing, but you've got 

to remember that a huge part of all our markets in the 

packaged equipment business is replacement. And so these 

are design faults that may have happened decades ago that we 

really can't overcome. It's nothing that you're going to 

fix. 

 MR. WIGGINS: This is Steve Wiggins again. We're

actively, we're in the business of going out and fixing 

that. 

 MR. ERNST: Yeah. 
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 MR. WIGGINS: So we, we actually were doing. 

 MR. ERNST: But it takes a lot of work and a lot 

of money. 

 MR. WIGGINS: Yeah. We actually are doing that on 

many cases, you know, something that really where our big 

energy consumption's at. 

 MR. ERNST: Yeah. 

 MR. WIGGINS: So we really should focus on it. 

 MR. ERNST: So, looking at how, going to get to 

problem number two with how return fans fix this. But 

again, look, you can compare the pressures of the supply fan 

only system and adding a return fan. And again, you can see 

there is a big difference in the negative pressure at the 

outdoor air inlet of the unit. And you have the low suction 

with the return fan and you have the high suction pressure 

with the supply fan only. 

 So, again, when you add that return fan, you get 

the desired pressures that you want on your upper air damper 

and, again, you can greatly improve your ventilation 

control. And again, in the examples that I've been showing 

you. 

 Now, if you add an exhaust fan to the unit, things 

work a little differently. The, you can, again, add an 

exhaust fan, draw the negative pressure at the inlet of the 

unit and the fan provides the exhaust pressure that you 
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need. So that the exhaust fan takes care of that no exhaust 

problem. Takes care of this no exhaust problem. Just like 

the return fan did. However, the, you still have this big 

negative pressure at the outdoor air intake, so you still 

have that same potential problem, you can't control your 

ventilation air as well with a, an exhaust fan on this type 

of application as you can with a return fan. The, now the 

exhaust fans can be applied to save energy compared to a 

return fan. They, they don't maybe do as well on the 

ventilation control on that high ducted pressure return, but 

the more, the supply fan, as someone already mentioned, the 

supply fan is doing more of the duty. The exhaust fan is 

only sized to handle your maximum exhaust air flow. 

 The VAV systems may only need 60 to 80 percent of

design air flow during economizer operation. And if so, the 

exhaust fan motor and fan and motor can be downsized. You 

can save some first costs there and especially when you're 

working with airfoil supply fans, you can, the more

efficient the supply fan will do more of the work. It 

actually handles that much of that return duct pressure and 

I'll show you later on why the supply fan is typically a 

little bit more efficient than the exhaust fan. 

 So, with all that, I, this was the thought that I

wanted to leave you with. The, I mean, we focused on a 

rooftop with a ducted return with a fairly good sized 
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pressure drop. The issues apply, it's just a matter of how 

big is that return pressure drop. That tells you the 

magnitude of the problem. The problem's very big on the 

application I showed you and I can assure you on 40, 50 and 

large ton rooftops, this is your typical example. Almost 

every one of our orders comes in with a return fan or 

exhaust fan and they're all sized for about an inch of 

pressure. That is your typical value on the orders we 

receive. The, the, when you add the return fans and the 

exhaust fans, you can properly control building pressure and 

you're going to need that as you get pressure drops larger 

than this. But, and return fans and exhaust fans, they 

perform differently. The, you size them differently. They 

perform differently. It, the building designer has to 

choose, they, this is, these are valuable tools for the 

designer and they're in the best position to decide. Do you 

need one of these fans and which one? Agree? Little bit? 

 Okay. The, now if you look at a, if you put a 

supply fan and a return fan in a box, the, you put the same 

fan, both your supply fan and your return fan in that same 

air handler, in that same rooftop, in that same box, here's 

what's going to happen. You're typically going to see a 

peak efficiency line somewhere like this. Your supply fan 

is going to have about two or three times more static 

pressure than the return exhaust fan, so it relatively is 
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going to be much closer to the peak efficiency line and, and 

much, and more efficient. The, again, AHRI is collecting 

data on this and we'll see what all the manufacturers 

submit. But what we submitted to AHRI would show that what 

we typically see is the exhaust fan, return fan is about 

one-half or two-thirds the efficiency of the supply fan on 

our typical applications. 

 MR. STARR: So I, I have a question. This is 

Louis with NEEA. So in the case of the return fan, you're 

saying it's, I'm, I'm trying to understand is the return fan 

you're saying is less efficient? Why? Is it because you're 

selecting it to be less efficient or what's, I was trying 

to -- 

 MR. ERNST: Right. 

 MR. STARR: -- pick up what the point of the -- 

 MR. ERNST: If you put the same fan, if, if your 

exhaust fan and your supply fan are the same size and you 

put them in a, in a given air handler and they're each, 

let's say, they each fill up all the space and you put in 

your biggest fan, the supply fan is typically going to be a 

little bit to the right of peak efficiency so that it's 

stable. You get this as efficient as possible and this fan, 

because it's at less static pressure in the same CFM, is at 

a much less, much farther from peak efficiency. It's a much 

more efficient selection. 
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 UNIDENTIFIED MALE: So why do you do it? 

 MR. STARR: Yeah, I was thinking why would you 

put the same -- 

 MR. ERNST: I'll, I'll show you in a second, a 

little bit more why that happens. Okay? 

 MR. FERNSTROM: So, so this is Gary for the 

California IOUs. I understand the point you're making 

relative to the way we conventionally measure efficiency and 

peak efficiency. However, the, the return fan operating at 

a lower static pressure or a head, wouldn't it, wouldn't it 

have a higher system efficiency, in that facing a lower head 

it would move more air for less energy consumed? 

 MR. ERNST: It might consume less energy, but it's 

going to be less efficient. Just by the, on the, the way 

fan selection works and efficiency lines work. 

 MR. FERNSTROM: Well, well, you see I don't care 

whether it's less efficient or not in that classic way of 

thinking. What I care about is how much air it moves as a 

function of the energy it uses. So, yes, it's less

efficient, but from a system perspective, it's more

efficient because you're getting more air for less energy. 

 MR. ERNST: No, I, I wouldn't agree with how you 

said that. The, there, let me go a couple more slides and 

build on why this is how the selections often fall and then 

we can come back. 
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 MR. FERNSTROM: Okay. Thank you. 

 MR. FLY: This is Mark Fly with AAON. Can you 

define efficiency as watts per CFM? Gary's right. 

 MR. SMILEY: Yeah. 

 MR. ERNST: That’s true, but, but again -- 

 MR. SMILEY: Yeah, for the most part. 

 UNIDENTIFIED MALE: Yeah. 

 MR. FLY: But it's -- 

 MR. ERNST: -- again, it depends on the 

application. 

 MR. SMILEY: Depends on the application. 

 MR. ERNST: But in general you're right. 

 MR. SMILEY: Well, that's your opinion. 

 UNIDENTIFIED MALE: That was Bill Smiley talking. 

 MR. SMILEY: Sorry. 

 MS. PETRILLO-GROH: Gary, the metric as we 

discussed it, would that reflect the way you're interpreting 

efficiency or the conventional one. 

 UNIDENTIFIED FEMALE: Speak up, please. 

 MS. PETRILLO-GROH: Sorry. Laura Petrillo-Groh, 

AHRI. I was wondering if the metric as we define it here 

would measure energy in the way that you're describing it 

versus the way that the metric describes? 

 MR. FERNSTROM: So Laura, it admittedly I'm 

thinking about efficiency a little different way than our 
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conventional metrics -- 

 MS. PETRILLO-GROH: Right. 

 MR. FERNSTROM: -- think about it. So there's, 

there's no question that in terms of the conventional 

metrics the point that's being made is correct. 

 MS. PETRILLO-GROH: And with the metric we're 

discussing for fans also? 

 MR. FERNSTSROM: Yes. 

 MS. PETRILLO-GROH: Okay. 

 MR. ERNST: Yes? 

 MR. SMITH: Yeah, this is, this is Wade Smith. 

Listen, you fast forward when we were developing the metric 

that's being proposed. There's a pressure constant and a 

flow constant that go to the formula and the pressure 

constant is there to, as a gift. Because low pressure 

applications where fans are, by their very nature, less 

efficient. A fan operating at 0.4 inches of static would 

require half the efficiency by virtue of the 0.4 included in 

the equation. So, the need to accommodate fans that are 

operating at low pressure has been, has been accommodated 

basically in the proposed metric. 

 MR. FERNSTROM: So this is Gary. Laura, does 

that, does that answer your question? It sounds like it's a 

little different answer than the one that I gave you. 

 MS. PETRILLO-GROH: Yeah, let's, could we return
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to this when we, once he finishes, because I'd like to talk 

through it a little bit more? 

 UNIDENTIFIED MALE: Sure. 

 MS. PETRILLO-GROH: Thank you. 

 MR. ERNST: And we, just in our discussions we've

kind of hit on some of these issues. But again, the supply 

fan is closer to the, this, you know, these are constant 

efficiency lines. A supply fan is operating on this in, in 

a much more efficient mode of operation than the return fan. 

Again, because it has a lot more static, it maybe draws more 

energy. But it is, this is a more efficient point of 

operation. And if you were going to try to bring these fans 

to peak efficiency, you've got a lot farther to go with a 

return fan, exhaust fan because of that lower static 

pressure and the fact that they both are going to handle 

about the same CFM, roughly speaking. 

 Now this is why the return fan is not sized near 

peak efficiency. The, this would be your typical, it's one 

way of designing an air handler or a rooftop, the air 

handler portion of a rooftop. The, looking at a plenum fan, 

again, this would be looking at an elevation use with return 

air coming back in this direction to a plenum return fan and 

your plenum supply fan being down at the discharge end of 

the unit. Your filters and coils are typically sized for 

about 500 feet per minute. The, that's because you don't 
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want to blow water off the cooling coil and it's, again, 

where, at least where your, some, a lot of your filters are, 

depending on the type of filter you're choosing, it is a 

fairly common arrangement to see this arrangement with about 

a 500 foot per minute velocity. Now your outdoor air 

dampers, return air dampers, exhaust air dampers all work 

pretty well at 1000 feet per minute. At double the velocity 

and what happens is the designers are able to downsize this 

portion of the unit. You kind of put the return air fan, 

your return air fan needs to go into this return section and 

you can set up and design and, a unit like this in this 

configuration. But again, there's more room for the supply 

fan than there is for the return fan. And as we saw in the 

last example, this fan actually has to be bigger to have the 

same efficiency than the supply fan. So this is how your, 

this would be the typical designs as you see them today. 

There's other arrangements that you typically will see. 

This part of the return, the return economizer section, 

outdoor air section, has been sized smaller and the return 

fan has been squeezed into it and this has been going on for 

20 or 30 years, 40, 40 years. 

 UNIDENTIFIED MALE: So this of course, would be a

sort of the driving factor really to make, in other words, 

you're, you're pumping up your base velocity so that the 

exhaust air and, what the other one? The return air, you're 
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pulling up? 

 MR. ERNST: Exhaust air, return air, outdoor air. 

This would be your typical double mixing box. 

 UNIDENTIFIED MALE: Okay. So you're, you're 

moving that velocity up because you can, whereas if you blew 

it, if you ran that air across the coil, you'd have water 

going down the ductwork and that would be a problem. So, 

you have a performance problem. 

 MR. ERNST: Right. 

 UNIDENTIFIED MALE: As opposed to the other, you 

just have, your burn up more energy, but you move the air. 

The pressure drop is directly proportional to velocity. 

Right? So the faster you run the air, the more pressure 

drop you have and -- 

 MR. ERNST: Uh-huh. 

 UNIDENTIFIED MALE: -- that's how you size your 

fans. You're trying to keep the box in certain size 

footprints, so it's forcing everything into a smaller box, 

except where there's design consideration such as water 

carryover over the supply coils. That's kind of what's 

driving that more or less then. Summation, correct

summation? 

 MR. ERNST: Yes, I agree. 

 UNIDENTIFIED MALE: Okay. 

 MR. ERNST: Now this is what you'd have to do to 
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put in a return fan of equal efficiency. It's going to not 

have to be bigger than the supply fan, because it's applied 

at, at a lower static pressure for the same CFM. And you 

can see, the unit is going to have to grow tremendously, and 

you completely redesign to put in a return fan in the same, 

it's going to be analogous for an exhaust fan too. The, the 

units as they exist today will have to be completely 

redesigned. They will not work on replacement applications, 

especially on indoor applications where you're especially 

space constrained, but you also have flatbed sized 

limitations and so on. Yes. 

 UNIDENTIFIED MALE: Have you evaluated the formula 

that was proposed to see whether or not you have to increase 

the size of your return fans? 

 UNIDENTIFIED FEMALE: You shouldn't have to do 

that. 

 MR. ERNST: Well, this would be to get equal 

efficiency to the supply fan, so I, that's, I, so I don't 

know the answer to your question. I haven't fully evaluated 

our units on that basis. 

 MR. FLY: Yeah. This is Mark Fly of AAON. I 

don't think we can because we really, this is not data that, 

that we have typically collected. And I know for my 

company, we're, it's, it's painful that we're going back and 

basically looking at every order to extract this data, 
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because this is not something that we collect, on what size 

supply fan and steady pressure was, was selected with, with 

the supply and the return. So, I think the push-back you're 

seeing is yes, I know that you guys have, have a, has, have 

attempted to accommodate it. I don't think we know at this 

point whether it's sufficient or not. And that's -- 

 UNIDENTIFIED FEMALE: That's the -- 

 Mr. FLY: -- that's the truth. 

 UNIDENTIFIED MALE: I think the data will tell us. 

 MR. Fly: Well -- 

 UNIDENTIFIED FEMALE: -- and so I think that's one 

of the reasons from the outset we asked for data and we 

appreciate that you guys are working on that. But I think 

just fundamentally we would disagree with that first 

statement on there. Because that's exactly what we did and 

tried to do. 

 MR. ERNST: Uh-huh. 

 MR. FLY: Well -- 

 UNIDENTIFIED FEMALE: But in the premise -- 

 MR. FLY: -- what you, what you did was -- 

 UNIDENTIFIED MALE: Well -- 

 MR. FLY: -- well, I, I think this was, it's a 

different deal. 

 UNIDENTIFIED MALE 1: -- by their training. I 

think the analysis has been today is really more fan 
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standalone and not embedded fans and products. Because the 

cost increase of the product if you put a bigger fan in, I 

don't think is included in your analysis. I don't know for 

a fact, but I suspect that. And that's what we're trying to 

work towards. 

 UNIDENTIFIED MALE 2: Well, as, as opposed to me,

and until you do what Wade does, you don't know whether the 

unit's being larger. I suspect you are probably right if I 

had to guess. 

 MR. ERNST: All right. 

 UNIDENTIFIED MALE 1: What he's talking about is 

absolutely correct. If you want a fan that is absolute 

efficiency number -- 

 UNIDENTIFIED MALE 2: Right. But the 

regulation -- 

 UNIDENTIFIED MALE 1: -- is equal. 

 UNIDENTIFIED MALE 2: -- we're talking about -- 

 UNIDENTIFIED MALE 1: What Wade's talking about 

is -- 

 UNIDENTIFIED MALE 2: -- does not have that. 

 UNIDENTIFIED MALE 1: -- is the proposed 

methodology -- 

 UNIDENTIFIED MALE 2: Right. 

 UNIDENTIFIED MALE 1: -- of measuring. The metric 

to measure torques. 
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 UNIDENTIFIED MALE 2: Right. Right. 

 UNIDENTIFIED MALE 1: -- we haven't done that 

analysis. 

 UNIDENTIFIED FEMALE: Right. 

 UNIDENTIFIED MALE 1: We don't know. 

 UNIDENTIFIED FEMALE: So what -- 

 UNIDENTIFIED MALE 2: Yeah, but you don't 

necessarily, I mean, you're right -- 

 UNIDENTIFIED MALE 3: All he's saying here is to 

get the same efficiency, you've got to go bigger because 

you're the high flow low pressure. 

 MR. SMITH: This is, this is Wade Smith. It's a 

strawman and it's not correct. The metric that is proposed 

would not require you to increase the fans. It would be 

just as efficient with a supply fan. So it's a false 

premise. 

 UNIDENTIFIED MALE: Correct. 

 UNIDENTIFIED FEMALE: Right. 

 UNIDENTIFIED MALE: And you need to evaluate it 

based on what is proposed. 

 UNIDENTIFIED FEMALE: Right. 

 MR. SMITH: Maybe -- 

 MR. ERNST: Well, we wanted to make sure that you

understood -- 

 UNIDENTIFIED MALE: Wait. Wait. One person speak 
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at a time. 

 MR. SMITH: -- maybe is what I'm saying. 

 MR. ERNST: --that this needs to be done. This is 

a situation we need to avoid and, and perhaps has been -- 

 UNIDENTIFIED MALE: And have done. 

 UNIDENTIFIED FEMALE: I, I think that's what we 

tried to do. I think that's we're trying to tell you. We 

tried to already take that step -- 

 UNIDENTIFIED MALE: So -- 

 UNIDENTIFIED FEMALE: -- so, and our analysis to 

Bill's point about what is our analysis and what is the 

cost, we didn't run into any cases where the fan inside was, 

had to change because we believe that the metric properly 

accounts for that, because it derates based on the 

pressures. That's what we were trying to explain to you 

guys at the last meeting. So, you have to take it a step 

further and talk about what you're seeing, what you think 

potentially might happen and then overweigh. The approach 

we're trying to take to actually avoid this from really 

happening. That's where the disconnect is. And we actually 

tried to do this. Tried to avoid this happening. 

 MR. WHITWELL: Right. So actually I think, you 

know, the manufacturers are working -- 

 UNIDENTIFIED MALE: Please identify yourself. 

 MR. WHITWELL: Bob Whitwell, Carrier. 
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 UNIDENTIFIED MALE: Thanks. 

 MR. WHITWELL: So, the industry is working to, to

understand whether this is an issue or not. What Skip is 

explaining is what, what happens in the design, so now we've 

got to, we've got to dig. We've got to do some, some 

analysis to understand what these fans are actually doing, 

because it's not, it's not data that we normally would 

collect. So there's some work we have to do and then we'll 

determine whether the, the constants that are included in 

the formula are adequate or not. So we've got work to do. 

 UNIDENTIFIED FEMALE: Right. 

 MR. WHITWEll: And I don't know, I mean, you may 

did, maybe did some analysis, but I'm not sure that you had 

the data that we don't have in order to do the correct 

analysis. So that's got to be determined. 

 MR. STARR: So this is Louis from NEEA. Just, 

hopefully this will be helpful. So it sounds like the 

manufacturers are taking some particular air handlers or 

sampling of air handlers and the flow and pressure and 

sticking it into the proposed metric to see if that changes 

the size of the fan. Is that kind of what's happening or 

not? 

 UNIDENTIFIED MALE 1: Not yet. 

 UNIDENTIFIED MALE 2: Not, but that's the intent. 

Right? 
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 UNIDENTIFIED MALE 1: That's the intent. 

 UNIDENTIFIED MALE 2: Oh sure. Yes. 

 MR. ERNST: That's really the gist of my 

presentation. Last couple slides, pretty much say what you 

all have just well. Here we go. Okay. This is just the 

summary slide. And again, it was saying please consider 

these, these fans. They need some allowance so that they 

are not forced to be too big. 

 MR. STARR: Sorry. This is Louis Starr again. So 

I was waiting until you go to the end. So, why are the 

supply fans and your, your return fans the same size? Is 

that because when you exhaust a building it has, it's, it 

seems like the different flow of pressure? 

 MR. ERNST: I think they typically today, exhaust

fan return fans are a smaller diameter. 

 MR. STARR: Right. I'm saying though, but why are 

you making the assumption it's the same size fan? I'm, I'm 

trying, I would think, okay, when you go into economizer 

mode, you have to exhaust all the air in the building. 

Right? But you're at a lower static than you would. The 

supply fan you would have a higher static pressure. You've 

got ductwork and evidence downstream of it. On the return, 

you just have to blow the air out the damper and the return 

ductwork. So I was trying to figure out, I was thinking 

that's why, I understand that they would be the same flow, 
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but it seems like it would be a different static pressure. 

 MR. FLY: This is Mark Fly with AAON. Let me, let 

me address it a little different way. From a design 

standpoint, not looking at regulations with what's happened 

in the past, for example, your, your supply fan might be a 

20 horsepower motor. Your return fan, with this reduced 

size smaller than the supply fan, is a one horsepower motor. 

So, I mean, it was an economic and energy issue, it, you 

know, it didn't make, it was one-twentieth of the energy 

consumed by the fan system. 

 UNIDENTIFIED MALE: Right. 

 MR. FLY: And yes we were selecting at a lower 

horsepower, but it was so much less, or your watts per CFM 

that the, the consideration was from an economic standpoint, 

it didn't pay to put, you know, a, a 30 inch supply fan and 

a 60 inch return fan. Because that's the kind of things we 

were talking about to get, and -- 

 UNIDENTIFIED MALE: To get equal efficiency, it 

could happen. 

 MR. FLY: Or something that was just going to 

save, you know, 20 percent of one horsepower as opposed to 

putting your money into saving, you know, 20 percent of 20 

horsepower. 

 UNIDENTIFIED MALE: So if the metric in theory 

captures this change in size, that would take care a little 
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bit, but, but then you're saying it wouldn't be the economy, 

it doesn't make sense to chase after one watt -- 

 MR. FLY: Right. 

 UNIDENTIFIED MALE: -- a unit when you've got 500

that you can save -- 

 MR. ERNST: That you can chase somewhere else. 

So, the question is, when you get the return fans then 

what's economically justified on the return fan, besides on 

efficiency. And it may be a different answer than the 

supply fan. 

 MR. STARR: So, I guess if you do your analysis 

and there's, there is no change in your fans, then you won't 

have to really go any further. Right? 

 MR. FLY: Right. 

 MR. STARR: Okay. And so, if, if you do find that 

there is a difference, then that would be like, then we can 

get into discussion is -- 

 UNIDENTIFIED MALE 1: Well, how big do they -- 

 MR. STARR: -- does this work well -- 

 UNIDENTIFIED MALE 1: -- have to grow? 

 UNIDENTIFIED MALE 2: Yeah, or are the constants 

differing? 

 UNIDENTIFIED FEMALE: Yeah. Exactly. 

 UNIDENTIFIED MALE 1: But as, as you, as you 

increase the size of that return fan, you increase the 
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length and the width of the units and at some point -- 

 UNIDENTIFIED MALE 2: Yeah. 

 UNIDENTIFIED MALE 1: -- you may get something 

that you can't -- 

 MR. ERNST: On some of our larger units, we 

probably couldn't get it on a truck. 

 UNIDENTIFIED MALE 1: Yeah. I mean, essentially 

what this slide show is about is, is as you go smaller in 

powers or replacement blades or fan wheels, essentially your 

efficiency inherently decreases. And in theory that's what 

AMCA has developed their metric around, which is now the 

basis of the thing was, and to account for that. And the 

question is, is have they done a good enough job with the 

equipment that they're (indiscernible). 

 UNIDENTIFIED MALE 2: So in general for the same 

flow and lower static, you have to spin a larger fan at a 

lower speed? That's, that's where you get your efficiency 

at. 

 MR. ERNST: Thank you very much. That, any other

question or comments? That's everything I had. 

 MS. ARMSTRONG: Thank you. No questions about it. 

 UNIDENTIFIED MALE 1: Go ahead and load that. 

 UNIDENTIFIED MALE 2: Easy act to follow. 

 MR. SMILEY: Yeah. You guys are a tough crowd. 

 UNIDENTIFIED MALE 3: We're safe. We're waiting 
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on you. 

 MR. SMILEY: You're warming up for me. I have one 

more file. It's in that same directory. So probably bring 

up the air handler one. If I get this all figured out. 

 UNIDENTIFIED MALE 4: Air handler open? 

 MR. SMILEY: Yeah. Now, basically I just wanted 

to spend a few minutes going over a fairly large product 

grouping in the industry for HVAC applications called an air 

handler. Typically, an air handler is a big box with a fan. 

And typically a water coil unit. So there is no direct 

refrigeration system inside the unit itself. It could be a 

rooftop. It could sit on a rooftop or it could sit, most of 

them are actually inside a building. So when you fit them 

inside a building, you have to have an equipment room or 

some space to put it in that ends up being not rentable or 

useable space for the occupants of the building. 

 It can be a fixed geometry design with very 

limited variability or it can be structured like building 

blocks to create a custom one of-a-kind unit for any 

particular application. And most air handlers today have a 

catalog. Most of the catalog air handlers, but they're set 

up that you can configure them in a variety of ways

depending on the application and the need. It could be 

horizontal, vertical. They have different types of fans 

that are used in them. Typically housed centrifugal fans, 
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single-width, double-width, BI, BC, airfoil, FC, un-housed 

fans like plenum fans. Typically BI, BC, airfoil type fans. 

Or you can have multiple fans. 

 In this particular picture right here shows what 

we would call a fan array or a fan wall where there are 

multiple un-housed centrifugal fans. But you could have 

multiple housed fans as well. You can use vane axial fans. 

You could use any type of fan. Typically, the fan draws or 

blows the air through the coil and distributes it through 

the building. So the fan has to have pressure capabilities 

to push the air through the whole building, return it to 

the, to, to the unit and provide all those functions. 

 MR. FERNSTROM: This, this is Gary. 

 MR. SMILEY: Yes. 

 MR. FERNSTROM: I have a question on your previous 

slide? 

 MR. SMILEY: Yes. 

 MR. FERNSTROM: In the multiple fan picture -- 

 MR. SMILEY: Yes. 

 MR. FERNSTROM: -- where is the fan blade? Is it

on the end of the motor shaft? 

 MR. SMILEY: Yeah. 

 MR. FERNSTROM: It's -- 

 MR. SMILEY: It's direct, direct drive mounted 

right on the other end of the motor. 
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 MR. FERNSTROM: Okay. So -- 

 UNIDENTIFIED MALE: It, it's spinning. 

 MR. FERNSTORM: -- so I'd, yeah, so I'd make the 

observation, that's a real big motor with a real small fan 

blade. 

 MR. SMILEY: Could be. Depends on the speed, you

know, variable speed a lot of times they're inverter-driven 

and, and the design speed is higher than synchronous on the 

motor, so, yeah. 

 MR. FERNSTROM: I'm just looking at the physical 

size of the motor. 

 MR. SMILEY: Yeah. 

 MR. FERNSTROM: Not its horsepower rating 

necessarily. 

 MR. SMILEY: Right. And I think this is the wheel 

here -- 

 MR. FERNSTROM: Yes. 

 MR. SMILEY: -- being powered. 

 MR. FERNSTROM: Thank you. 

 MR. STARR: This is Louis with NEEA. Maybe you 

could explain why someone would use, use a fan wall instead 

of, of, what Gary's getting at is he's thinking the fans are 

probably inefficient because you have a whole bunch of 

little small fans rather than one bigger fan. But in fan 

wall applications, there's, there's application reasons why 
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they do that. 

 MR. SMILEY: Yeah. 

 MR. FERNSTROM: Well, well, this is Gary. I'm 

thinking it's inefficient because you've got a great big 

motor and a teeny tiny fan. 

 MR. STARR: My understand of why you have a fan 

wall -- 

 MR. SMILEY: I did not design this, so I can't 

answer, I cannot answer the specific numbers. 

 MR. STARR: Well, that's his, that's his 

competitor's view. 

 MR. SMILEY: Yeah. 

 MR. STARR: I think the reason they have a fan 

wall is because they want redundancy, like for clean rooms 

and -- 

 MR. SMILEY: Right. 

 MR. STARR: -- some other things. 

 MR. SMILEY: There's a -- 

 MR. STARR: -- and, and if one fan fails, you 

have -- 

 MR. SMILEY: -- there are a lot of reasons. 

 MR. STARR: -- it's easy to replace it. 

 MR. SMILEY: Yeah. You can cycle fans on and off

for modulation if you want. 

 MR. STARR: It's never usually for efficiency so 
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much or, I mean, you can state that the air flow rights that 

may be off. 

 MR. SMILEY: You, you, there, there are a lot of 

reasons. You can save space in the longitudinal direction 

of the unit, because you have a whole bunch of little bitty 

fans this way rather than one big fan this way. You can 

cycle fans on and off, which gives you the A, B or 

modulating capabilities. You have, like you said, 

redundancy. 

 UNIDENTIFIED FEMALE: Thank you. 

 MR. SMILEY: There, there are lot of marketing 

reasons for doing this. Okay? 

 UNIDENTIFIED MALE: And, and application reasons 

as well. 

 MR. SMILEY: Right. Well, yeah. Yeah, 

application reasons. Okay. Definition of an air handler. 

AHRI is an industry organization that is supported by a 

large number of air conditioning manufacturers. They're an 

international organization. They're well-known and, and 

respected around the world for the technical aspects, much 

similar or similar AMCA is on fans and ASHRAE is on overall 

systems. For AHRI, we have a large number of air 

conditioning equipment already defined and regulated per 

AHRI standards for testing and performance reporting and 

certification. We have and definitions of these equipment 
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as well. Definition of an air handler is basically a 

factory-made encased assembly consisting of a supply fan in 

parallel, which may also include other necessary equipment 

to perform one or more of the functions of circulating, 

cleaning, heating, cooling, humidifying, dehumidifying and 

mixing of air. It shall not contain a source of mechanical 

cooling. So, it's, it's a box with a fan and a coil in it 

and other types of things in it, filters, et cetera, that 

provides the air that supplies an occupied space with 

comfort and with the opt for ventilation to provide healthy 

air. 

 Fan types typically used, we saw some pictures of

the fan types typically used, but just to review them real 

quick. A double-width or double-inlet housed centrifugal 

fans. It could be either forward-curved, BC, BI, backward 

inclined, airfoil. Single-width centrifugal fans. The same 

type. Just a single-width instead of a double-width, which 

would just be half of a double-width. And the single-width, 

single-inlet un-housed centrifugal fan, plenum fans. 

Typically BC, BI or airfoil. 

 Not as prevalent, but sometimes used, housed axial 

fans, vane axial or tube axial. Housed centrifugal fans of 

the mixed flow, flow type, usually single-width. And there 

may be some others, but probably not as popular in the 

overall population of air handlers. 
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 Typical applications that I mentioned earlier, you 

can have, have them mounted on a roof and they can bring in 

outside air, return air and supply the building. Or, you 

can mount them indoors, which the majority of air handlers 

are actually installed indoors. Where, again, they get the 

return air and some outside air, maybe from a connection to 

the outside or a fresh air type unit that pre-conditions the 

outside air. And then provides air and comfort to the 

occupied space. It can be a VAV system. It can be a 

constant volume system. There are a variety of ways you can 

apply these and each type of application can have a lot of 

different variables or components in the unit. You could 

have just a single unit or you could have two that are 

connected together. Here you might have an air handler or 

some type of unit pre-conditioning the outdoor air or the 

ventilation fresh air coming in and supplied to the indoor 

air handler. So, as opposed to the return air exhaust fan, 

a return fan exhaust fan sample, this could be two separate 

units. 

 A typical application, you could have either a 

draw thru where the fan draws the air through the coil and 

the filters or you could have a blow thru where the fan 

blows the air through the coil. Or you could have vertical. 

You could have just about any configuration where the fan's 

on top, fan's on the bottom. Because you create this unit 
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with basically building blocks of the different components 

you can arrange in a lot of different ways. And the way it, 

it's arranged is a function of the application and what the 

customer orders or wants. We don't dictate that it has to a 

specific design. 

 It could have energy recovery. It could have a 

ERV wheel or return air heat exchanger applied in it. It 

could have ventilation. It could have both. It could have 

exhaust. It could have return and it could have all of 

those, or it could have none of them. But it's always going 

to have a supply air fan and a, and a coil. And they'll be 

in a box. And that's the way it's supplied. 

 It can get a lot more complicated. Here's one 

with a heat recovery wheel. Another one down here with 

exhaust and return fans. So you can see, you can start out 

simple and you can make it as complicated, complex as you 

want. 

 The one thing they all have in common is a fan. 

The fan is in a box and the box is the minimum configuration 

when trying to assess the fan performance. And that's the 

way the AHRI standards are, are written, is you take the 

bare basic configuration, which is a fan in a box and that's 

how you test it. That's how you rate it. Because the box 

can make the fan work differently than the fan works all by 

itself. It can change the way the fan performs. 
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 The industry generally, sort of, kind of knows 

what the ideal pressure drop of all the components they 

offer for sale are. Because in, in configuring one of these 

units, you need to know what the component pressure drops 

are and the application external pressure requirements are 

in order to size the fan, the motor and the RPM so you match 

what the customer needs. 

 Standalone fan by an AMCA 210 type test versus 

same fan in a typical air handler cabinet. They do not 

perform the same. There are two, possibly two things going 

on. One is, you have the pressure drop of the, of the box 

and then you have a change, potential change in the fan's 

capability by the way the fan or the box influences the way 

the air goes into the fan. If you have a one mile wide box, 

and a little bitty fan sticking in it, there's probably not 

going to be any interaction between the box and the fan. 

But you can't sell a one mile wide box. And a more

practical size and application assessed, a more optimized 

efficiency, you would have a box of some size with a little 

bit smaller fan inside. That, that variation changes. But 

it does change the way the fan works. So, you can't tell me 

what that fan's going to do in a box by giving me the fanonly performance. Unless you tell me what the box is, what 

the box is doing and I understand that interaction. Is 

there a question? 
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 MR. STARR: Yes. This is Louis from NEEA. So I 

don't, I don't spend all day looking at fan curves. But the 

red and blue one -- 

 MR. SMILEY: You're good. 

 MR. STARR: I can imagine that. 

 MR. SMILEY: That's good. 

 MR. STARR: It doesn't look all that different and 

I, I'm sort of wondering, I was thinking, is the blue one 

the one that was actually tested and you predicted the red 

one or did you actually do a test on both of those? Was 

there a, a fan test? 

 MR. SMILEY: This, this relationship was developed 

based on testing a fan only by itself in the AMCA 210 and 

testing that same fan in a box with a coil and without a 

coil per AMCA or AHRI 430. 

 MR. STARR: Do you have a mathematical 

relationship between those two or not? I mean, is it -- 

 MR. SMILEY: It will -- 

 MR. STARR: -- I can look at it if I multiply it 

by .9 when you look, you're about right. 

 MR. SMILEY: Yeah, but that's going to be a 

function of the geometric variation between the box and the 

fan. The fan type -- 

 MR. STARR: Yes, but -- 

 MR. SMILEY: -- the fan type, where it's 
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positioned in the box, how close the sidewalls are, how 

close the coil is, whether it's blow thru or draw thru, 

whether it's ducted or not. But yes. 

 MR. STARR: And it's substantially different with

all, all of those items? 

 MR. SMILEY: And also configuration of the coil. 

It could be a deeper coil versus -- 

 MR. STARR: Right. Right. 

 MR. SMILEY: -- versus a mere over coil. 

 MR. FLY: This is Mark Fly with AAON. I, you 

know, I think that there, there is kind of a few sides to 

this. The people that build lots of boxes that have the 

same cross-sectional area and the standardized fan head, did 

a lot of testing and test, test this stuff and, and do that. 

But there's another whole section that market custom air 

handlers, people where the cabinet changes on one inch 

increments on width and height. And then you have to come 

up with a rather sophisticated ADM computer model of, of the 

best guess you can of, of what it's going to do. 

 MR. SMILEY: And, and we'll stand manufacturing -- 

 MR. FLY: And you do that with a lot of testing. 

 MR. SMILEY: Yeah. What most air handler unit 

manufacturers, the bigger ones, have that long term

proprietary database that they use. The AHRI 430 allows 

some of that modeling where you don't have to test every 
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cabinet of every fan. You can predict, much like AMCA 

allows with using fan laws. You can use fan laws and 

cabinet effects that a lot of manufacturers develop their 

own proprietary relationship. There's, there's not a, an 

industry-defined relationship that I'm aware of. 

 MR. FLY: As, so if you knew, so I, I would guess

most of the time the manufacturers end up knowing the red 

line up there. Right? They've -- 

 MR. SMILEY: Yeah. 

 MR. FLY: -- in order to do their equipment -- 

 UNIDENTIFIED MALE: Well, what are catalog -- 

 MR. FLY: -- catalog goes out the door, they have

to -- 

 MR. SMILEY: For, for catalog, the standard 

equipment in general, most large manufacturers do know that. 

Yes. 

 MR. FLY: So in theory, these red, red lines -- 

 MR. SMILEY: I, I can only speak for one company. 

I can speculate what the other companies do. 

 MR. FLY: In theory you can take that red line and 

stick it into the, the metric and just, I mean, I know it's 

a couple steps down, but that's what would sort of be the 

next step to do. 

 MR. SMILEY: If, yeah. 

 UNIDENTIFIED FEMALE: Just from, this is just for
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a central stationary? 

 MR. SMILEY: Right. Yeah. Yeah. 

 UNIDENTIFIED FEMALE: But they don't have all the

-- 

 MR. SMILEY: That, that, that would be -- 

 MS. ARMSTRONG: Side comments won't make it on the 

record. Just so you know. 

 MS. PETRILLO-GROH: I, this is Laura Petrillo-Groh 

from AHRI, and I was mentioning that this is just for 

central station air handling units and Louis said that 

relationship (indiscernible) all the types of equipment are. 

 MR. STARR: Well, I just meant if, if you could 

accurately predict it for each kind of equipment and it's 

really, you're getting that information on particular 

equipment and then you're, you're applying it into the fan 

metric -- 

 MS. PETRILLO-GROH: And -- 

 MR. FLY: This, this is Mark Fly with AAON. I 

think the answer to your question is no, there is not a 

defined standardized method for applying a fan in a box. 

And there'll be, I mean, some people do CMD computations 

with aerodynamics, there's all kinds of approaches that, 

that all of us manufacturers in the group, you know, have 

done. Some of it's experience. Some of it's, you know, 

I've sold 10,000 units and measured 5,000 of them and I know 
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what those 5,000 did. So, it's not, it's, it's all very 

proprietary and no two people does it, do it the same. But, 

regardless, we have to know the red line to sell a product. 

 MR. SMILEY: Wade, hi. 

 MR. SMITH: So this is Wade Smith. Just a couple

of comments. One comment is that all fans perform 

differently than their rating curve when they're finally 

applied in the field. Whether they're in an air handling 

unit or not in an air handling unit, because they are 

subjected to system effects and pressure losses in and 

around the fan. And so, the difference I would say is that 

somebody who makes an air handling unit takes on the 

obligation, at least this is the way it has been in the 

marketplace, takes on the obligation to describe the air 

performance of their box. 

 MR. SMILEY: Uh-huh. 

 MR. SMITH: Whereas when the customer buys a bare

fan, the consulting engineer or the system designer takes on 

the obligation to describe the performance of the fan in the 

system. So he has to account for the system effects, 

whereas in this case they're incorporated into the rating of 

a box. Right? 

 MR. SMILEY: Right. That's correct. 

 UNIDENTIFIED FEMALE: And that also changes, but 

then just like that bare fan, when you apply the air handler 
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in the field, there's also a system effect, the building on 

the air handler. 

 MR. SMILEY: Well, you know, no. 

 UNIDENTIFIED MALE: No, not -- 

 MR. SMILEY: You know, as well as I do AMCA has 

four application manuals that address these issues very 

well. 

 MR. SMITH: All right. So this is Wade Smith. So

I would say that the system effects associated in and around 

the fan are incorporated into the air handler rating. 

 MR. SMILEY: Uh-huh. 

 MR. SMITH: But they are not incorporated into the 

fan rating, units purchased standing alone and so that's, 

that's one principal difference. You know, the, the 

question on the table is, what air handling unit 

manufacturers want to, how they want to draw the testable 

configuration. 

 MR. SMILEY: Well, and that's what I'm leading up

to. 

 MR. SMTIH: I know you are. 

 MR. SMILEY: Okay. 

 MR. SMITH: But if you, if you, if you want to 

wrap the circle around the fan, right? Then the casing 

effects are external to the rating of the product and the 

certification of the fan performance. And the important 
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point that I want to make is that, that's no different than 

the rating of the fan which goes into the field. So it is 

an option. It may not be the option you choose. It's 

totally up to you. It is an option and it does work. If 

you instead choose to draw the circle around the box, then 

those casing effects are incorporated into the certification 

that you have made to the Department of Energy. 

 MR. SMILEY: Uh-huh. 

 MR. SMITH: So in one case the air handling unit 

manufacturer who purchases a certified fan may not have to 

certify. In the other case, if you draw the circle around 

the box, they clearly do have to certify, regardless of 

whether or not they buy a certified fan. Again, it's your 

decision. Whatever you guys want. But you know, the 

challenge here going forward is to really understand what 

your advocacy is. 

 MR. SMILEY: I know. I, I think that's exactly 

what we know, Wade. And you know, I, I agree with you. 

Exactly what we know is what you just said. 

 MR. SMITH: Yeah, you can have it either way is my 

point. 

 MR. SMILEY: Uh-huh. 

 MR. SMTIH: Okay. 

 MR. SMILEY: And we have a recommendation. 

 MR. STEVENS: Well, I don't know if that's, this 
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is Mark, Mark Stevens for AMCA. And there's actually two 

effects that are going on. You, you mentioned it -- 

 MR. SMILEY: Yes. 

 MR. STEVENS: -- in the narrative in the bottom. 

But I think the two, the two effects are kind of muddled 

together in the top. And that's the system effect and then 

this pressure drop into the, whatever purposes are attached. 

 MR. SMILEY: Right. 

 MR. STEVENS: So I think if you took out the 

pressure drop or actually added the pressure drop to the 

coil or the pressure drop to the filter or what have you, 

and is added back into that system effect -- 

 MR. SMILEY: Uh-huh. 

 MR. STEVENS: -- those, that the system effect 

defined it a lot smaller than what you're depicting it. 

 MR. SMILEY: Oh yeah. 

 MR. STEVENS: You know, you would have the red 

curve, if you took the coil out or subtracted the coil airside pressure drop out, you would have the red curve. 

 MR. SMILEY: Uh-huh. You're absolutely right. 

 MR. STEVENS: But you, you, you alluded to the 

fact that there were system effects. What I'm saying is, is 

that this exaggerates that point. But as, I don't, I don't 

think that, that delta you're showing is all system effect. 

Most of it's pressure drop. 
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 MR. SMILEY: No. 

 MR. STEVENS: Which would explain red and blue. 

 MR. SMILEY: No. There's the fan only. Here's 

the fan only, Mark. Here's the fan in a box. Here's the 

fan in a box and a coil. 

 MR. STEVENS: Uh-huh. 

 MR. SMILEY: I'm sorry if I misled you. This is 

the box effect on the fan's performance capability. This is 

the coil pressure drop on the fan in a box. This from here 

to here is the combined of those two. 

 MR. STEVENS: Yeah, it's all -- 

 MR. SMILEY: If I said, okay, I want to test this

without a coil, I would get the red curve. Now in there, in 

the outside chance that having a coil in there affects the 

way the fan performs a little bit more than just the box, 

the test methodology that I'm going to describe, you test 

the, the box with a fan and a coil in its standard 

configuration. Then you mathematically remove the coil from 

that measured performance to get the fan in a box 

performance. The reason we do that is because we have 

multiple rows of coil we could use. We have infinite 

variation in fin series we could use. We have different 

tube diameters in the coil we could use. So every order 

could have a different pressure drop coil applied. But we 

can't test every, every one of those configurations. So we 
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make an assumption. And we've been doing this for 50 years. 

 MR. STEVENS: Understand that. 

 MR. SMILEY: Yeah. 

 MR. STEVENS: It, it, at AMCA we, we've done some

research projects for ASHRAE on system effects. And part of 

the last group was exactly, exactly this. 

 MR. SMILEY: Now, and you know, depending on what

your box design is, this could be a bigger difference or a 

lesser difference. It, it could, the red curve could lie 

right on top of the blue curve. I've seen that. I've also 

seen it be a lot worse than that. So, you know, it, it, it 

depends because the geometric relationship. And if you have 

a unit where you're inducing pre-swirl, you can have a huge 

difference, where your spin and the, the air spins before it 

goes into the fan. 

 MR. DYGERT: This is Ryan Dygert with Carrier. 

One thing that's not showing here too is the downstream 

resistance behind the fan. So if you put a coil or a heat 

pack downstream of the fan, we often see fairly large gains 

in the fan performance, usually a positive effect. And 

that's something that you would not get from a, a standalone 

versus in situ tests. 

 MR. SMILEY: Well, this, this is an example. 

 MR. DYGERT: Yeah, I agree. 

 MR. SMILEY: Based on real test data, but there's
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no data on there. 

 MR. DYGERT: No. Yeah, I'm just adding -- 

 MR. SMILEY: Yeah. 

 MR. DYGERT: -- another example -- 

 MR. SMILEY: Yeah. 

 MR. DYGERT: --that goes to the point as well. 

 MR. SMILEY: Well, yeah. If you go back to, where 

is it, these different types of configurations, each one of 

those, the same size box, same size fan, each one of those 

configurations will give you a different red curve. 

 MR. DYGERT: Agreed. 

 MR. SMILEY: They'd all have the same blue curve,

but they'd all have a different red curve. Good. 

 MR. DYGERT: So I have, I, this is information 

correct on your, your slide with the three color lines. So, 

between the red, so the one on the left, the red and green, 

so the system is affect, the system is affected you're 

talking about is, so it's, it's not necessarily a bad system 

effect, in other words, when you wrap air in the wrong 

direction. It could be that or it could just be the fact 

that you have pressure drops. So it's not, the terminology 

system effect doesn't necessarily refer to fan system 

effect, or is it, I'm just trying to understand the

terminology to make sure. The difference between the red is 

not necessarily a fan system effect. It's just a system 
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effect of having maybe a pressure drop in there and

potentially could have a fan system effect -- 

 MR. SMILEY: Yeah. You can't -- 

 MR. DYGERT: -- if you had to move the air in a 

direction that's not so great. 

 MR. SMILEY: -- the key which I always look for to 

determine if it's having a true effect on the way the fan's 

actually performing, or it's just acting as a pressure drop, 

is looking at the horsepower change. If you check the same 

CFM and if you change the fan's horsepower, brake 

horsepower, horsepower, you change the way the fan is 

operating. The aerodynamic operation of the fan has 

changed. 

 MR. DYGERT: Okay. 

 MR. SMILEY: If there were, if those two 

horsepower curves were the same, and that's what these are, 

these are, this is an FC fan by the way. These are

horsepower curves, constant speed. If the horsepower curves 

change, you change the way the fan's operating. It's not 

just a pressure drop. 

 MR. DYGERT: Okay. So in this case there is a 

system effect? It's your horsepower is 1 and now 1.2? 

 MR. SMILEY: Well, it went down, because part of 

this difference here is not only a cabinet pressure drop, 

but a reduction in the fan's pressure rise probably, because 
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there is a reduction in the fan brake horsepower for this 

particular example. 

 MR. DYGERT: It, it could make sense in a, if you

were talking about backward curve, but forward curve's a 

little bit different animal, because it's got that rising 

pressure drop. The, the rising power -- 

 MR. SMILEY: It doesn't matter. It's the same 

CFM. If you change the way that fan's performing by 

changing the way the air goes into that fan, pre-swirl is a 

good example. You could swirl with the fan, power will go 

down, pressure will go down. If you swirl against the 

rotation, power go up, pressure may go up a little bit. It 

doesn't matter what kind of fan it is. 

 MR. DYGERT: Yeah, but we're not talking swirl 

here. Right? We're talking a coil and a pressure -- 

 MR. SMILEY: It could be anything. It could be 

the air all comes in the back of the fan. It doesn't come 

in this way. It comes in this way. It comes in this way. 

 MR. STARR: You know, I was, this is Louis with 

NEEA, I was just thinking, you could -- 

 MR. SMILEY: I, I can show you real data if you 

want to see real data if you don't believe me. 

 UNIDENTIFIED FEMALE: Well, you, well -- 

 MR. SMILEY: It's an example. 

 UNIDENTIFIED MALE: Please identify yourselves. 
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 MS. PETRILLO-GROH: Laura Petrillo-Groh, AHRI. So 

where, where you have the horsepower curves, is that where 

the blue, is that for the fan -- 

 MR. SMILEY: Yeah. 

 MS. PETRILLO-GROH: -- only? And then the -- 

 MR. SMILEY: Red is -- 

 MS. PETRILLO-GROH: -- fan in a box and the coil.

 MR. SMILEY: Right. 

 MS. PETRILLO-GROH: No filter? Nothing else? 

 MR. SMILEY: Well, and it turns out that with the

fan in a box with a coil, it's the red horsepower curve as 

well. 

 MS. PETRILLO-GROH: Okay. 

 MR. SMILEY: So the inclusion of the coil did not

change the horsepower consumption of the fan. The coil 

acted like a pure pressure drop. 

 MR. STARR: This is Louis. I, so this is not, you 

know, I'm, I'm just trying to understand. 

 MR. SMILEY: I, I hope we're not going way off 

track. 

 MR. STARR: No, no. I just, I, I'm trying, so are 

we, so it seems like you had a pressure drop in there and 

you apparently would need more horsepower to overcome that 

pressure drop. But you're saying not necessarily? 

 MR. SMILEY: Uh-huh. 
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 MR. STARR: Because you're saying it's just a pure 

pressure drop, you wouldn't -- 

 MR. SMILEY: Well -- 

 MR. STARR: -- see a change between your red and 

blue lines. 

 MR. SMILEY: -- if this is the designed pressure 

and here's where it is with the coil, or here's where it is 

in the box, I have to speed that fan up to recover that 

pressure decrease that the fan is now seeing. Or I use a 

bigger fan. Have to, have to increase the test speed of the 

fan somehow to get the pressure back up to where I need it. 

So the fan in a box with the coil at 6,000 CFM would operate 

right there. But if I need it at that much pressure, or 

that much pressure, I would have to speed the fan up which 

will take the horsepower curve up as well. So, you see it 

in the efficiency curves. This is the fan only efficiency 

curve and this is static efficiency. This would be the fan 

in a box efficiency curve. So the efficiency went down. 

The effect of the box on the fan caused the fan's efficiency 

to go down. So we may or may not know what the real applied 

pressure drop is of the components. What the real fan 

performance, or what the real fan performance is inside the 

unit. The industry has developed over many years of test 

and rating methodology for commercial cataloged air

handlers. Performance in that box. The test methodology 
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and data analysis presents presentation are defined in the 

AHRI standard 430. Methodology is well accepted in the 

industry. It's used by most of the major manufacturers. 

AHRI can speak to, to that. Throughout the commercial air 

handling industry, product specifications, applications, 

building codes and customer bases. So when we get 

specification and an order for an air handling unit, it 

usually defines, so it has to meet AHRI 430 performance 

certification industry standard. You take, here are the, 

the standard test configurations. Now before everybody 

jumps all over me, I understand that we don't really have a 

fan wall for a mobile fan test methodology defined yet for 

430. 

 UNIDENTIFIED FEMALE: That's right. But this is 

what -- 

 MR. SMILEY: So don't jump on me because I show it 

up here, because it's just my thought of what it might be -- 

 UNIDENTIFIED FEMALE: Yeah. Well, (indiscernible) 

major fan, multiple fans and air handlers is a, a situation, 

but we're not incorporating the standard right now.

 MR. SMILEY: Well, it's not, you could have 

multiple housed fans and you would connect the discharges 

into a common duct to do testing, so that's already covered. 

 UNIDENTIFIED FEMALE: Yes. 

 MR. SMILEY: This is, would be indicative of 
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what's called a fan wall or -- 

 UNIDENTIFIED MALE: Fan arrays. 

 MR. SMILEY: -- fan array. Yeah. I guess fan 

array is probably the more industry -- 

 UNIDENTIFIED MALE: Correct. 

 MR. SMILEY: -- term. Fan wall is a trademark or

something. 

 UNIDENTIFIED MALE: Right. 

 MR. SMILEY: Anyway, basically you set up a fan in 

a box with a coil. You attach it to a wind tunnel or a test 

facility, which is usually AMCA 210 certified. That's the 

type of facility you would really want to use or most people 

do use because it's certified by a well-known -- 

 UNIDENTIFIED MALE: Accredited. 

 MR. SMILEY: -- organization. Accredited. Excuse 

me. Accredited. And that's well-accepted as well. I don't 

know if there's, I don't think there's an AHRI test facility 

accreditation. I think it goes by AMCA and ASHRAE. 

 UNIDENTIFIED FEMALE: Yeah, AHRI only has a test 

facility on standards percent. 

 MR. SMILEY: Yeah. So you basically connect the,

the box and coil and the fan to that test facility and run 

an air flow test. You measure the power in the motor, bring 

horsepower into the fan and you develop the performance map. 

Blow thru, draw thru, vertical, doesn't matter. It's a bare 
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configuration for the testable configuration for an air 

handler fan. Test methodology defined in AHRI 430. So, 

what we have is a test method that's technically-based, 

well-defined and proven. It's been around a long time. We 

have a way to determine fan in a box performance 

experimentally. Manufacturers have developed over the years 

methodology to predict things that they don't test. What we 

don't have is an efficiency metric that would be applicable 

to fan in a box. So we don't have a metric right now as far 

as I know, as far as I'm concerned. I don't know what value 

we need to shoot for. We recommend using the air handler 

performance determination based on the AHRI standard 430 as 

the test methodology and the testable configuration

definition for air handlers. The performance-based and 

efficiency ratio methodology, similar but may be different 

from that developed and presented by the current industry 

through AMCA. It seems to be a reasonable approach for air 

handlers. Maybe a low pressure, a medium pressure and a 

high pressure application point for basing the efficiency 

ratio might be a better one to use for air handlers. I 

don't know. We need to look at the data and do the

analysis. The required efficiency levels are yet to be 

determined and will need to be adjusted to accommodate the 

fan in a box configuration, since that's how the product is 

tested and applied. We're interested in the energy, the 
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unit consumes in its application, not some number in an 

ideal situation. We are collecting the data to help assess 

what levels we think that metric should be based on what 

they are and what the values in the data tells us they are 

now. If we don't have cabinet fan testing, we may want to 

consider some way of taking a fan standalone results, like a 

certified fan and applying some sort of a cabinet de-rate to 

it, similar to what we're, what we were working on for 

motors and drives and controls. I think we want to leave 

that open as a, as an item to think about and discuss. 

 So, I don't know if you want to go through any of

this or not, but, you know, I've, I've got, okay VAV 

systems, sound, specific speed, why you might use one fan 

versus another. It may not be the most efficient fan in the 

world, but for the application it is. That type of stuff. 

Size, relationships and so on. Paul? 

 UNIDENTIFIED MALE: Maybe the specific speed would 

maybe be good though or that discussion. But it's 

understanding why it might make sense to use a forward curve 

fan instead of an air flow. Is that what you would cover in 

that slide? It -- 

 MR. SMILEY: Yeah, a little bit. 

 UNIDENTIFIED MALE: -- it might be worthwhile, but 

it should still -- 

 UNIDENTIFIED FEMALE: Go ahead. 
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 UNIDENTIFIED MALE: Go ahead. 

 MR. SMILEY: Okay. I know in terminal machinery,

specific speed in the old days was used a lot from a design 

standpoint. And we never really used it that much in the 

fan industry. Although I have, and I know a lot of you guys 

have as well. In trying to understand why you would design 

or select or pick a fan of one type versus another, and it's 

a function of diameter, operating conditions, et cetera. 

Specific speed is a dimensional relationship that is a 

function of CFM, pressure and RPM. And this representation 

is using cubic feet per minute, inches of water and RPM. 

Now coupled with that's another dimensional relationship 

called specific diameter, which is a function of pressure in 

inches of water, CFM and cubic feet per minute and the 

diameter in inches in, in the particular relationship that I 

show for the value of the numbers. And what you see on this 

plot is a variety of fan types and low specific speed is 

basically low flow, high pressure or low RPM. High specific 

speed is high CFM, low pressure or, I, a high RPM. And any 

combination of those metrics. So, the different fan classes 

or types, like a FC fan, the red curve. Airfoil fan, the 

blue curve, double-width. The single-width airfoil fan, the 

green curve. A plenum fan or plug fan, which would be an 

un-housed centrifugal, usually single-width fan, BI, 

airfoil. A prop fan, a high efficiency prop fan and a, kind 
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of a standard efficiency prop fan. Or a panel, panel axial 

fan. So they all have different peak efficiency 

capabilities. And these are static efficiency, not total 

efficiency. They all have different characteristic shapes. 

They're all located in a different location as that, that 

particular fan type on a specific speed curve. Specific 

diameters is the same way. Panel axial fan is the highest 

specific speed. The very first specific diameter, which 

means for the same CFM static pressure, you need a big one 

of those suckers. And double-width FC fan is a red curve, 

which means for the same CFM, static pressure, you'd use a 

small. So when you look at this, you go, okay, I've got to 

design CFM static pressure of some value. I can look at any 

speed I want, any diameter I want and you can use this type 

of relationship to zero in on, based on the design criteria, 

how much space you have, what type efficiency you're trying 

to get to, where are you on that efficiency curve? You can 

see what the relationship is for speed and diameter to hit 

that same CFM static pressure with different fan types. So 

you might take a small FC fan and run it at a low speed or a 

big BI fan, running it at a higher speed or a huge prop 

running at a very high speed. 

 MR. STARR: So this is Louis with NEEA. So in 

theory, you can't just say you were designing an air 

handler, handler from scratch. You had to make some design 
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decisions, you would first go to the first, the first chart 

there and look at your flow and pressure. Right? That your 

design requirements -- 

 MR. SMILEY: If you, you were going to use this to 

do a very crude rough first shot at what types of fan should 

I consider. 

 MR. STARR: Correct. 

 MR. SMILEY: This could be one way of doing it. 

Yes. 

 MR. STARR: So that would, you know, depending on

where you ended that specific curve, you'd look at all of 

the different colored curves there and make the choice of 

the fan. And then you go down to the next one, help you 

decide the fan or that fan, but in reality you're, you have 

space limitations that might affect all the decisions you 

made -- 

 MR. SMILEY: Right. 

 MR. STARR: -- that are -- 

 MR. SMILEY: So then you might start at the size 

and then go up to the fan type. 

 MR. STARR: You could work backwards. 

 MR. SMILEY: I mean, you, you could do it either 

way or you could iterate on it. 

 MR. STARR: I mean, in general isn't there, so I 

imagine space has a lot of, or a pretty controlling factor. 
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The document goes the way I described it. Right? 

 MR. SMILEY: Well, this is just one, one initial 

way, very crude, kind of a one dimensional rough estimate of 

what fan type should I consider. Then you need to start 

looking at the specific application, the fan map, how it 

will operate around that operating point, what type app? If 

you're going to do VAV, do you have to worry about stall, 

surge, you know, have you got enough range to cover the 

range you want for the product? You know, on and on and on. 

This, you know, it's. Wade? 

 MR. SMITH: Yeah, so there was in the first, the 

very first note out, there was a lot of talk about using a 

specific speed and it was used in the pump rule as well. 

And the membership of AMCA looked at using specific speed. 

The thing that is attractive is that it invites product 

substitution. So if somebody is making the wrong decision, 

and they're mis-applying a fan where a different type of fan 

would be a better choice, a metric that, that incorporates 

specific speed drives those product substitution ideas. And 

so, we had some of our members, relatively late in the 

process, arguing for a metric that incorporated specific 

speed. 

 MR. SMILEY: That's not what I'm doing. 

 MR. SMITH: I know. I, I just want, I just want 

to, I want to give this a little history because I think 
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it's important for folks to understand. And at the end of 

the day, the membership came back around to, to advocate, to 

decide upon, to build a consensus around a scheme in which 

the requirement, the DOE requirement, develops a maximum 

horsepower for a given flow and pressure. And coalesced, 

the membership coalesced around a single number for ducted 

fans, a different number and a different basis for un, nonducted fans. Fans that didn't have ducts on the outlet. 

And the, one of the attributes of that approach that our 

membership liked is that within the ducted fan category, it 

encourages sub, product substitution. And one of our 

observations, as we looked at the actual selections that 

were made in 2012, is there were a lot of bad selections. 

Meaning they picked the wrong fan. And when we tried to 

evaluate the impact of correcting those selections, many, in 

many, many individual cases, and this is not a general 

statement that, that should be applied as an average, but in 

many cases we found a more efficient, lower priced, lower 

horsepower fan, because they had picked the wrong fan type. 

Right? And so this idea of choosing of, of inviting, right? 

A regulation that says, look, you've got this flow, you've 

got this pressure, this is the maximum horsepower. Figure 

it out. Invites product substitution and does for the 

regulatory environ what a specific speed would do and I 

think it's actually what the consultants were trying to get 
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at with this specific speed-based metric. 

 So, as you pointed out, very few people in the 

industry deal with specific speed. It's done with quite a 

bit actually on the industrial side, with custom fans and 

it's dealt with by fan designers like yourself working 

inside a major company, you know, responsible for fan 

engineering. But it's, it's not part of the vernacular that 

exists within the industry in the field and taking the 

benefits of specific speed and masking it in this other 

approach that's more easily understood and more approachable 

is basically what we did, what we ended up with. We, we, we 

spent a lot of time on the subject and ended, well, we ended 

up for reasons I described. 

 MR. SMILEY: The, the main reason I, I put this in 

was to, to try to help non-fan design experts understand why 

you have different types of fans, why you might pick one 

versus the other. The other thing about this, this plot is, 

if you took all the data that's out there, you don't get a 

single curve, you get a, you get a half inch wide band. You 

know, these are or this is not the absolute every fan -- 

 MR. SMITH: Right. 

 MR. SMILEY: -- that's, that type's out there 

falls on that curve. There's a band around that. That's 

just kind of a, an average accepted static efficiency, not 

total. You know, Armin I'm sure has one that's based on 
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total efficiency that, that historically we've never really 

worked at total from an application or design standpoint. 

Well, from a design standpoint I do all the time, but 

anyway. So, I, I hope this helped a little bit. You know, 

it doesn't answer all the questions. It, it points to 

different designs of fans work differently. You pick one 

versus another for a lot of reasons. 

 MR. SMITH: One, one last question. In general, 

when a quick air handlers are getting designed, I mean, is 

it ending up that they're sort of trying to use the, I 

realize they're not actually using the service, but you end 

up using the best fan for the application? In other words, 

you look at your flow and pressure and do you end up 

choosing either the red, blue, or black fan that makes sense 

for that application or does it start down at the bottom 

with like, we've got this small box, where do we go? 

 MR. SMILEY: It, it becomes an optimization 

process. Speaking from my experience and not for other 

manufacturers, and I don't want to tell you proprietary 

design information, but the products that the company that I 

work for, Trane, produces, we would have, we size the air 

handlers based on coil square footage. And that implies a 

certain capacity of heating and cooling. And based on that, 

there's a design CFM, 500 feet per minute, 550, 450, 

whatever you want, and that's usually an optimization of 
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heat transfer, air-side pressure drop, cost and also there's 

a limit as to how high a velocity you can go so you don't 

blow water off the coil, you know, which nobody wants rain 

in, in their building. Because of the air or moisture 

condensing on the coil, which is part of the heat transfer 

process. We know that, that capacity can be applied to an 

occupied space. It could have a very wide range of static 

pressure requirements. This building needs four inches of 

static because of the way the, the, or the consultant 

designed the ductwork. This building might need six. This 

building might need two. Well, in order to allow an optimum 

selection based on whatever criteria the customer has, we 

may have four or five different fan selections, fan types 

for that one box. We may have an FC fan. We may, you know, 

we, we probably have an FC fan. We probably have a doublewidth airfoil fan. We might have two or three different 

diameters of each one of those. We could have a singlewidth airfoil plenum fan and we have a fan array. So we 

might have, you know, six or seven different fan options for 

that one cabinet size. Cabinet size based on how big the 

box is to contain that square footage base area of the coil. 

And there's an optimum aspect ratio of the coil design from 

a cost heat transfer optimization. So, it, it's kind, to 

answer your question, it's oh yeah, yeah, sir, but well, no, 

not really, but yeah, sort of. You know? But it, the neat 
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thing about the custom air handler, the, the air handlers is 

there's a lot of flexibility. You know, from a 

manufacturing standpoint, you try to minimize the 

manufacturing cost and you've got money made and space and 

everything to build this equipment. But you want to give 

the customer the biggest amount of flexibility so you don't 

have to do a modification switch to the equipment, which 

would cost him more money. Or you might have to, it might 

restrict how he designs his equipment room or his ductwork. 

So, you know, over a hundred years you try to, you know, and 

all the manufacturers do that. They try to accommodate what 

the customer will pay you for. And if the customer comes to 

us and says I'm only going to pay for the, for the highest 

efficiency product in the world, we've got it and we can 

give it to you. But you know, there's a lot of decisions 

that go on in the customer's mind. Same way with a

standalone fan, you know? I want 90 percent efficient fan. 

Well, we've got it. Here's, here it is. If you want to pay 

for it, here's how big it is. Now it's, so. 

 Anyway, there's a variety of available fan types,

including variable frequency drives and other methods of 

variable air volume, control of the fan performance either 

by a standalone fan or a fan in a box, any, any type of fan. 

So you can, you can best fit not only the air flow and 

pressure requirements, but also acoustics which are
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important, efficiency and discharge requirements in an 

efficient and cost-effective package, so. 

 UNIDENTIFIED MALE: There's also a lot of motor 

types too. Right? 

 MR. SMILEY: And only we have, you know, what 

motor do you want? Okay, we-- 

 UNIDENTIFIED MALE: ECM one. 

 MR. SMILEY: Yeah. We, we have, you know, 

premium, we've got high efficiency, we have VAV motors, we 

have ECM motors. We can give you the, the variable speed 

controller on the unit. All the controls are in it. It's a 

package drop-in. You hook the water up and the power. 

Yeah. So, built that's -- 

 MR. BUBLITZ: Mark Bublitz, New York Blower. For

our edification, can you describe what comes out of a 430 

test to get, if you wanted to do a single curve, for the 

system effects, wouldn't you need to map a whole range -- 

 MR. SMILEY: What you get is similar to what you 

get from 210. You get a map. 

 MR. BUBLITZ: For, for one speed or? 

 MR. SMILEY: No. 

 MR. BUBLITZ: You did a whole series of? 

 MR. SMILEY: No. If, if, if you had, if people 

still printed the catalog, you'd have a fan map with 

variable speed or various constant speed curves, constant 
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horsepower curves and lines of constant efficiency, sort of. 

You know, I mean, you know, usually you don't take speed and 

diameter until effect of changes to efficiency. Well, 

speed, I mean. But the same sort of rules at, at 210. 

 MR. HAUER: I feel, I think it, it's Armin Hauer 

speaking. I think 430 doesn't have the wire to air aspect 

with that. 

 MR. SMILEY: No, it's fan brake horsepower. So 

you use a calibrated motor or you use a torque meter. 

 MR. HAUER: Why is it's not accelerated? 

 MR. SMILEY: Pardon? 

 MR. HAUER: Why is it not accelerated? Because 

there is some savings potential -- 

 MR. SMILEY: Accelerated? 

 MR. HAUER: The development of the AHRI 430 to 

have the wire to air metric. 

 MR. SMILEY: Because what motor, that air handler

has four motor options. Okay? So, if you want to take the 

wire to air power, you have to specifically define what 

motor that is. Well, we've got other motors we'll sell you 

with that unit. We'll sell you an ECM motor. We'll sell 

you a premium motor. We'll sell you a high efficiency 

motor. We'll sell you an inverter-duty motor. What motor 

do you want? We'll sell you a motor that's twice as big as 

what you need. 
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 MR. HAUER: But the customer, the electric 

utility, they are interested in the power consumption. They 

are not interested in horsepower. 

 MR. SMILEY: Right. 

 MR. HAUER: So, how, how do you do the modeling in 

the, for your building, and aren't you modeling if you don't 

have the wire to air metric? 

 MR. SMILEY: The, when we design the units, we 

don't do building modeling for that. So if you, if you know 

the motor you want, I can apply that motor efficiency to the 

fan brake horsepower. Or, you have a default motor drive 

control value that you'd use. You know, I mean, it, you 

can't test every configuration of every fan and every motor 

that you could put together for this type of equipment any 

more than you could do that for a standalone fan. Now you 

guys sell a fan and a motor combined. You can do that. So 

if you had five different motors, you could sell with that 

fan, it would be a little bit tougher. It would require 

more testing, more some, some calculation method. 

 Where's Ashley? So, I got one just like that for

fan coils if you're, if anybody's interested. 

 UNIDENTIFIED FEMALE: No. 

 MR. SMILEY: And I've got another one for testable 

configurations. And then I've got another one for -- 

 MS. ARMSTRONG: How about a break? 
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 MR. SMILEY: -- this fan versus that fan. 

 UNIDENTIFIED MALE: Yes. 

 MS. ARMSTRONG: Thanks. 

 UNIDENTIFIED MALE: All right. Yes. Break. It's 

almost not needed. 

 MR. SMILEY: You need that stuff? 

 UNIDENTIFIED FEMALE: No. 

 MS. ARMSTRONG: Thank you. Put your next one 

down. 

 UNIDENTIFIED MALE 1: Let's take like a 15 minute

break. 

 (Whereupon, a brief recess was taken.) 

 MS. ARMSTRONG: Anyway. But yeah. Okay. We're 

going to start back up here. 

 UNIDENTIFIED MALE: All right, people. Back to 

your seats, please. 

 MS. ARMSTRONG: So I do want to make one 

announcement before we move on to our third presentation. 

And I meant to do it this morning, so it was an oversight on 

my part and I apologize. So, we do have a new member of the 

Working Group, because we had somebody drop off. Debra 

Miller dropped off. She was one of the ASRAC reps. So we 

now we still have two people from ASRAC on the committee, 

but she dropped off because she couldn't, couldn’t commit to 

attend for the rest of the meetings and follow, a lot of 
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schedule, conflicts, et cetera. So, we had a 26th person 

that had previous applied that wasn't able to join the 

Working Group previously, so we have added them as a formal 

voting member. There sitting behind you from Regal Beloit, 

Paul, he's representing NEMA as a motor guy. So good 

vision. We welcome you. You will, you noticed my e-mail 

last night had him on it. So now if we work off my latest 

group e-mail, it has his additional e-mail address as part 

of the group. So, welcome. 

 MR. LIN: Thank you. Thank you. 

 MS. ARMSTRONG: And with that, passing it to 

Laura. 

 UNIDENTIFIED MALE: If he wants to (indiscernible)

on that. 

 MS. PETRILLO-GROH: It ends with LPG. 

 UNIDENTIFIED MALE: Are you going to get a copy of 

this presentation, Laura? 

 MS. PETRILLO-GROH: Yeah, I'll send this all out.

 UNIDENTIFIED MALE: It's in the record. Right? 

 MS. PETRILLO-GROH: Kind of hard to see the 

screen. Did you pull it off my computer? Can you make the 

file names bigger? 

 UNIDENTIFIED MALE: Yes, ma'am. 

 MS. PETRILLO-GROH: No, that's not it. Oh, does,

that could be it. 
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 UNIDENTIFIED MALE: Are we also getting the other

presentations? 

 MS. ARMSTRONG: Yeah. So -- 

 UNIDENTIFIED MALE 1: Because last there were some 

presentations on this computer. 

 UNIDENTIFIED MALE 2: Yeah, I talked to Tim and 

I -- 

 MS. ARMSTRONG: Oh, Tim's. I have Tim's. I can, 

yeah, we'll send them all out. 

 MS. PETRILLO-GROH: Did you, did you pull two off

that, the key drive? 

 MS. ARMSTRONG: They also have to go in the 

docket, so. 

 UNIDENTIFIED MALE: Could I just get that? 

 MS. ARMSTRONG: Sure. Yes. Thank you. 

 MS. PETRILLO-GROH: It ends with LPG. 

 UNIDENTIFIED MALE: No pictures of the family 

vacation. 

 MS. PETRILLO-GROH: I haven't even started yet. 

 UNIDENTIFIED MALE 1: That's not an illness. The

last two days, that was enough. 

 UNIDENTIFIED MALE 2: Is this it? 

 MS. PETRILLO-GROH: Yeah, there we go. Hi. So, 

I'm Laura Petrillo-Groh from AHRI and we've put together 

just a short presentation to sort of go over some of the 
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equipment that's impacted by this regulatory, this 

rulemaking and sort of talk through some of the issues that 

we see, both legal and non-legal. And you know, as much as 

we can discuss the resolutions. We've also included that in 

this presentation. You can go to the next. Thanks. So 

one, we've got two buckets of equipment really that we've 

been focusing on. One are fans and EPCA covered equipment. 

And we have that listed on our screen. And then we've got 

fans and non-covered equipment. So to start off with some, 

you know, covered equipment, we've got the packaged unitary 

equipment category and we look, we looked at the different, 

you know, common names for this type of equipment. We've 

got several different classes of equipment even within the 

packaged unitary class, including packaged terminal units, 

mini-splits, multi-splits, VRF. We've got water source heat 

pumps, single package vertical units and then your 

traditional packaged ACs, heat pumps and rooftops and split 

systems. On a, you know, as we've heard in earlier

presentations, all of those fans definitely have a supply 

fan. And depending on the manufacturer, the type of product 

it's in, it could be any of these type of fans. So any of 

the centrifugal housed or un-housed, axial housed, mixed 

flow or crossflow. So some of them are more common than 

others, but we have, you know, there are cases where we're 

seeing in some of the data collection that we're doing and 
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feedback from the manufacturers, that these are all fans 

that could be represented in each of these unit types. We 

also have some fans on the condenser, condenser and

evaporator and those are typically axial panel fans. And 

then if you're using a return fan or an exhaust fan in the 

unit, it could be one of the types of units, the fans listed 

on the screen. 

 And to go along with what Bill was discussing, 

depending on the type of unit that you're using, you could 

be using a completely different type of fan and you would be 

using an, something that looked similar but was being used 

for another application. 

 And from our testing, we know about these units, 

the CFM, the unit input power and the external static 

pressure. And we know it using, you know, the different, 

the appropriate test of the unit. So, right here we have 

one, two, three, four, five, you know, at least six

different types of tests that you would be testing each of 

these different types of equipment to. So there's one 

specific to the packaged terminal units. There's one 

specific to the VRF units and so on and so forth. 

 But from these testing of equipment, using the 

appropriate equipment test, we don't know a lot of things 

about the, about the fan. We don't know the fan total 

static pressure, the fan or motor input power, cabinet 
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effect, fan-only applied efficiency, end-use static pressure 

and CFM. And Skip really went over the cabinet, Skip went 

over the cabinet effect really well, but what we're talking 

about is the overall influence of surrounding components, 

structure and casing, which causes changes to air flow and 

pressure drop and influences how the fan can, the fan 

performance is and where it's going to operate. 

 So, we've also got another covered type of 

product. Commercial refrigeration equipment. And that 

would be in bucket, walk-in coolers or freezers, 

refrigerator display cases, reach-ins, et cetera. So we've 

got the supply fans which could be similar to what we 

discovered, packaged unitary equipment. One of several 

different types of fans and, but the heat rejection is 

typically the axial panel fan. 

 And for the test of the equipment, by and large, 

we know the fan or motor input power, the unit, and the unit 

external static pressure. But what we don't know are the 

fan CFM, fan total static pressure, cabinet effect, fan-only 

applied efficiency. 

 We've got several different types of heating 

equipment we've kind of grouped together just for this first 

slide. They include warm air furnaces, unit heaters, 

boilers and water heaters. And they have different types of 

fans than we've seen previously including the power burner 
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and the inducer draft fan. And some of these may or may not 

be included in the scope, depending on where we draw the 

line. 

 Can you hear me? 

 UNIDENTIFIED MALE: Yes. People are having a hard 

time on the phone hearing. 

 MS. PETRILLO-GROH: Okay. I'll speak up. 

 UNIDENTIFIED MALE: You have a microphone right 

there. It should be. 

 MS. PETRILLO-GROH: Can we ask them? Or ask -- 

 UNIDENTIFIED MALE: You, you just need to speak 

louder. 

 MS. PETRILLO-GROH: Okay. 

 UNIDENTIFIED MALE: Or use the microphone. 

 MS. PETRILLO-GROH: All right. Is that better? 

So we also have axial panel fans and centrifugal housed or 

un-housed fans in this type of equipment. For the boilers 

and water heaters specifically, we know the unit power 

consumption by testing the unit and we don't know anything 

else related to the fans. 

 So for air handling equipment, which is not a 

covered product, we've grouped a bunch of different types of 

equipment into this, into this category, including room fan 

coils, unit ventilators, fan-powered terminal, terminal 

units, constant volume or variable air volume, fan-assisted 
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chill beams and then we've also got what you would typically 

think of air handling units. It's central station air 

handling units, custom air handlers make up air handling 

units, outdoor air handlers, and dedicated outdoor air 

systems. And the blower coil and low pressure air handlers 

as well. 

 And the supply fan, we also see that same 

variation of different types of supply fans in, that can be 

embedded in this type of equipment. And for the return 

fans, again, centrifugal housed, un-housed and axial housed. 

Exhaust fans, we also have the addition of the axial panel 

fan that you could see and these type of air handling 

applications. 

 For the air handling equipment, we typically know

its CFM, the fan or motor input power in some equipment, but 

not in all the type, types of equipment I listed previously, 

unit input power and external static pressure. We know this 

by testing the unit or fan or fan cabinet. So, as Bill 

described for the 430 test, while you could add a lot of 

other features that make the air handler specific to that 

application, in the 430 test, we're looking at only the fan 

in the box with the coil. But we, and, and that can be 

predicted to some other configurations, but we, you know, 

typically do that using some variation of fan laws. 

 We don't know the fan total static pressure, 
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cabinet effect, fan-only applied efficiency, fan or motor 

input power in some types of equipment, end-use CFM and 

static pressure. And Bill really covered very well the 

variability of custom air handling units makes it difficult 

to define and test. So the port, the world of central 

station air handling units and what can be tested and what 

can be certified through the air, the air, the AHRI program 

is much smaller than the world of air handling units that is 

currently out there. While the custom air, air handling 

unit manufacturers are very small businesses, they're 

regionally located. 

 Now, to the chillers and condensers and heat 

reject, and heat rejection products, these are also not 

covered products. They're typically called air cooled 

chillers, air cooled condensers, evaporative condensers, and 

we also have hybrid or adiabatic condensers. And their fans 

are typically limited to heat rejection and in the condenser 

fan they can use axial panel or centrifugal housed and unhoused fans for the, for that type of equipment. 

 And we know, what we know is the unit input power

and the external static pressure. We know it by testing the 

unit and predicting that, that test to different, to other 

sizes and configurations. And we don't know the fan CFM, 

fan or motor input power, fan total static pressure, cabinet 

effect or fan-only applied efficiency. 
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 For cooling towers, the common, this is not, also

not a covered product. We have packaged cooling towers, 

packaged evaporative condensers and field-erected mechanical 

draft cooling towers. We've got CTI representing on that 

later today. So, the typical fan types, again as, as, as is 

written on every side, these fans can be single or they 

could be multiple fans. But we have the heat rejection fans 

will be axial or centrifugal. 

 So for the cooling towers we know the motor output 

power, the unit external static pressure sometimes, fan CFM, 

fan total static pressure, fan or motor input power and 

motor efficiency. We know this by testing the unit and 

predicting the, that testing to other configurations and 

also through modeling. And we don't -- 

 MR. HAUER: Laura? 

 MS. PETRILLO-GROH: Yes? 

 MR. HAUER: It's Armin Hauer speaking. So you do

know the fans CFM on such a large cooling tower? 

 MS. PETRILLO-GROH: Yes. 

 MR. BURDICK: There is, there is a predicted value 

or there is a, a modeled value for it. 

 UNIDENTIFIED MALE: Please identify yourself, Mr.

Burdick. 

 MR. BURDICK: Larry Burdick, SPX. There's a, 

there is a model, there is a number for the fan CFM that we 
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use in our prediction model. 

 MR. HAUER: Only in prediction. Okay. That's how 

you know by your prediction. 

 MR. BURDICK: Right. 

 MR. HAUER: Okay. Thank you. 

 MS. PETRILLO-GROH: And we don't know the fan-only 

applied efficiency for the cooling towers. 

 For the energy recovery ventilators, commonly 

known as ERVs, they have, they use their fans for heat 

recovery. And they can be axial panels, centrifugal housed 

or un-housed, axial housed or mixed flow fans. 

 They know the fan CFM, fan or motor input power, 

energy recovery effectiveness and unit external static 

pressure. They know this by testing the unit and predicting 

the test data to other unit sizes and configurations. And 

they don't know the fan total static pressure, cabinet 

effect and the fan-only applied efficiency. 

 Amy's going to step in here. 

 MS. SHEPHERD: I'm going to join Laura at the 

podium, but for the record, no one in my life has ever told 

me I need to speak louder. So you listen to her. 

 UNIDENTIFIED MALE: But you also need to identify

yourself. 

 MS. SHEPHERD: And that was Amy Shepherd from 

AHRI. 
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 UNIDENTIFIED MALE: Thank you. 

 MS. SHEPHERD: Okay. So basically for covered 

products, we think that the approach that DOE articulated in 

the framework document is the right one. And again, this is 

for covered product. And that is that those fans that are a 

component and regulated commercial products or covered 

products under EPCA would not be within the scope of this. 

And this is for both sort of practical, real world, the 

issues that have been described and also for legal reasons. 

So sort of talking about this in, in the real word practical 

application for these plan fans as they are applied in these 

systems, the system energy for these covered products is 

subject to a DOE efficiency standard or DOE has the

authority to develop one. And that covers the energy use of 

that system. And EPCA is about energy savings. So that is 

within that. To the extent that metric or that test method 

does not adequately cover something that DOE feels it needs 

to cover, DOE has the authority to remedy that through the 

notice and process common in rulemaking. And as we

discussed earlier today, the components affect the 

performance of other components in the system. So, you 

know, we think that as these fans are applied and that's, 

you know, the universe that we're talking about here, it's 

not going to be the same result. It also avoids difficult 

issues about double counting of energy savings in separate 
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rulemakings for one system. 

 Now we know yesterday there's a different 

negotiated rulemaking going on that's been referenced. And 

dealing with the same function or the same issue in two 

separate rulemakings with two separate test methods, with 

two separate economic analyses and technical justifications, 

is very complicated. And we think a lot of these practical 

reasons are why EPCA legally is set up that it's set up. 

So, what this does, it would allow DOE to look at the entire 

system when it's doing this and recognize the energy use 

within that system, rather than having to coordinate 

multiple rulemakings to get at the use of that one system. 

 It also avoids multiple testing of the covered 

equipment. So, there is a testing burden. Any test 

procedure that DOE develops under EPCA can't have an undue 

testing burden. So that's something else that's addressed 

by the exemption of a product that uses applied in covered 

equipment. Because there's a test procedure and a test 

that's run on that system to develop an energy metric. And 

something that underlies the entire statute is this idea 

that what matter is the energy savings and there's a metric 

that's developed for that, and a standard that's developed 

to that. And then it's up to the manufacturers to look at 

the technology that's feasible, their customers, their 

market, their expertise, you know, their, their 
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marketability to compete and develop the optimal design for 

that system at the cost that is the lowest. So, all of that 

is baked into the statutory framework and that's important 

and it's something that you lose when you go in and start to 

regulate these components of the covered product. And 

that's why EPCA avoids that, which we'll talk about on the 

next slide. 

 And then the last point is that because you're 

talking about a system and the system's energy use,

regulating the components are not going to promote energy 

savings because of the bullet we just discussed where 

manufacturers have to adjust all the other elements to get 

those energy savings while minimizing costs. So all of that 

is factored into, I mean, the basic premise of EPCA. And 

those are very practical reasons that led us to the

regulatory structure as it is. 

 So, I know you all want to move on to the real 

legal side, so let's do it. All right. 

 So we believe that EPCA allows one standard for 

covered products and DOE also articulated this view in 2009 

in the Federal Register when it was talking about, it was 

commercial equipment, commercial warm, warm air furnaces, I 

believe. But it talked about the fact that the DOE is 

authorized to establish a performance standard or a single 

design standard. And therefore, a standard that had both or 
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that had multiple design requirements was beyond the scope 

of DOE's legal authority. We agree with this statement and 

we think that's why the framework approach was correct, 

because it's, it's in accordance with this. And I think, 

you know, as I mentioned, when you look at EPCA and you look 

at the fact that it's designed to set these energy savings, 

it's designed, the idea behind is that you give 

manufacturers the goal of this energy savings and you say, 

let the market work it out at the lowest cost to reach that. 

And the need to have the technology and the design 

flexibility to do that. And that's why there is this one 

standard. 

 Now, covered equipment is also, when you look, I'm 

not going to bore you with, I could have lots of slides too, 

just like Bill. But there's different sections of EPCA and 

they talk about things like energy standards, energy use, 

energy metrics, covered products and they're all singular. 

Sorry, I know that's boring. That's what lawyers do. But 

it talks about one of the following types of equipment and 

it talks about a performance standard, which is why DOE 

concluded in the rulemaking before that, that's what we're 

talking about. And so everything is singular and when they 

do, when EPCA does address components, there's a very 

specific language in the statute that addresses component 

regulation. And again, there's several places in there that 
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does that. But there isn't a general presumption that DOE 

can regulate all the different components of a covered 

product or these specific sections that talked about the 

regulation of components wouldn't be necessary. But where 

that has occurred, for example, on the residential side with 

the fan furnace efficiency those, you know, those were 

statutory changes that happened in order to enable that. 

 So that's why we think if there's an energy 

efficiency standard for this covered equipment, you can't 

have additional design requirements on top of that. And we 

also think, there's another thing that runs through the 

commercial section for specific types of equipment for, you 

know, commercial package AC and heating, PTACs, heat pumps, 

warm air furnaces which is that DOE needs to follow ASHRAE 

90.1 and that, when that is amended on those covered 

products, DOE evaluates that amendment and determines 

whether or not they're going to adopt it or whether they're 

going to go beyond it. And when they do that, they have to 

meet a specific statutory burden of showing clear and 

convincing evidence that they should do that. That's 

different than the standard they have on the residential 

side. So, that's something that's also built into the 

statute that DOE doesn't have the authority to just exceed 

ASHRAE without going through that process and making that 

showing. 
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 So, those are reasons why we think for covered 

equipment DOE has to meet its statutory obligations and 

that's where, that's where we think DOE can do that. 

 Any questions or thoughts? 

 UNIDENTIFIED MALE: We're on day 6 of meetings and 

we're still talking about whether we should be doing this? 

I need to make my flights for the next set, so I mean, it -- 

 MS. ARMSTRONG: The Working Group can have that 

discussion about whether to continue. 

 MS. PETRILLO-GROH: Well, I think we need to hear

from DOE if DOE has a different opinion than what it has 

stated on this issue. 

 UNIDENTIFIED MALE: Or, or do we need a vote from

the working group to exclude covered products? 

 MS. PETRILLO-GROH: I mean, so this is our 

position and we're basing it both on our reading of the 

statute and what DOE has said. 

 MR. COCHRAN: Yeah, this is Pete Cochran from DOE, 

General Counsel's Office. We have a different reading of 

the statute in this. 

 MS. PETRILLO-GROH: Than the one that was in the 

Federal Register? 

 MR. COCHRAN: The Federal Register I don't think 

is a reading of the statute. I think that was a position. 

Are you talking about the 2009 or -- 
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 MS. PETRILLO-GROH: Yes. 

 MR. COCHRAN: -- or the 2013 framework document? 

 MS. PETRILLO-GROH: I'm talking about 2009. 

 MR. COCHRAN: Okay. 

 MS. ARMSTRONG: 2009 stated that it had, and just 

to clarify for Pete, because what it actually did, it, it 

talked about how DOE considered a standard for a 

single -- 

 MR. COCHRAN: Yeah. 

 MS. ARMSTRONG: -- covered product. Just to make 

that distinction, because it is important. 

 MR. COCHRAN: What I think that, I think we're 

making a distinction. You're saying that this would be two 

standards for one product, where DOE's position is we had 

the authority to regulate fans and blowers based on the 

statute. We also have the authority to regulate the 

regulated products based on those provisions. We're not 

looking at that as we're taking two standards under one 

product. 

 MS. PETRILLO-GROH: But it's a component. 

 MR. COCHRAN: We're taking separate -- 

 UNIDENTIFIED FEMALE: It's a covered product. 

 MR. COCHARN: And I think all that is, if you 

want, maybe when we get into that, maybe if you get into 

more of the testable configuration where you're defining it. 
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And that's stuff that the Working Group has to work through. 

But from an authority and statutory position, DOE's position 

is, we have authority to regulate fans and blowers. We have 

authority to regulate the other products. This Working 

Group is going to work through all the details and I think 

at this time, I guess, our opinion, if you guys -- 

 MS. PETRILLO-GROH: But there -- 

 MR. COCHRAN: -- come back with a more detailed 

position -- 

 MS. PETRILLO-GROH: -- you know, there's, there is 

specific language and within, in the statute of the

commercial provision that talks about regulating covered 

product components if they're components of residential 

equipment. 

 MS. ARMSTRONG: So I -- 

 MS. PETRILLO-GROH: There's nothing that talks 

about regulation -- 

 MR. COCHRAN: Uh-huh. 

 MS. PETRILLO-GROH: -- components of commercial 

equipment. So, we're really asking DOE for its statutory 

opinion. Like on what basis, based on the language that's 

in the statute is DOE concluding this? 

 MS. ARMSTRONG: So, I think Pete articulated DOE's 

authority position. We believe we have the authority to 

cover fans and blowers. DOE did not set up a Working Group 
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to discuss its authority. We set up a Working Group to 

negotiate definitions, task procedures and standards and 

scope of those potential regulations for fans and blowers. 

So I, I think that's where were are at this. I mean, the 

authority is something that the Department has articulated 

and it will articulate it further as it moves through the 

process. You join the Working Group to negotiate aspects 

of those potential regulations in good faith. But 

fundamentally arriving and questioning DOE's authority was 

not within the purview of this Working Group and really is 

not why you were nominated to be on it. 

 MS. PETRILLO-GROH: I fundamentally disagree. DOE 

can't take an action in a rulemaking that exceeds the scope 

of its authority. And I think that, that, that is our 

position and I think even putting that position aside, we 

think that the fact that these products are covered

equipment and that they have a standard or DOE can develop a 

standard is the right approach. As we say in the previous 

light, it avoids a lot of the complexity, that you capture 

the total energy use of that system and we think that in 

terms of enforcement that, you know, we can come up with 

something that, that works in terms of allowing DOE to 

identify abuses of any exception for things that are 

components of cover, covered product. And we, we don't have 

that fully fleshed out yet, because we're thinking about it 
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and we also need to get a little bit more information I 

think about the distribution chain here. But I think we 

have, we think that there are some lessons that can be 

learned from what happened on the residential side with 

regional standards for air conditioning. Because we had a 

bit of a similar issue there where manufacturers are, were 

allowed to produce basically two products. Some are 

compliant in one installation and some are not. That's 

different because that specific statutory provision has 

language that addresses things further down the supply chain 

and this doesn't. But one of the key facts for that was 

labeling and we think labeling can work here and we just 

need to think about the best way for DOE to identify that, 

which we're still doing. And we recognize that and we're, 

you know, we're looking at the options there. So, that's 

one thing that, that we're looking at to recognize this. 

But -- uh-huh. 

 MR. FERNSTROM: This is Gary for the California 

Investor-Owned Utilities. It seems to me there are two 

issues here. One is the debate between you all and DOE 

about whether or not DOE has the regulatory authority to 

address this. DOE says it does. You say it doesn't. Now I 

don't think that's something the Working Group can address. 

My opinion is that we have to presume that DOE is correct 

and the Working Group then will go from there with respect 
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to its development of a recommendation as to whether unitary 

equipment should be covered or not, with respect to the 

fans, of course. I think we need to look at the data that 

is being collected in order to establish that recommendation 

and at least speaking for the California utilities and 

perhaps the environmental advocacy group within this Working 

Group, we're not convinced at this point that the fans 

utilized in unitary equipment should be exempted yet. So, I 

would propose that we go ahead, gather the data, look at it, 

understand the energy savings and then the environmental 

representatives in this Working Group can make a decision as 

to whether it wants to agree to exempt this equipment or 

not. 

 MS. SHEPHERD: Well, and I think as Laura 

mentioned, you know, we are gathering that data, but I think 

that what we wanted to flag it, I, I do not believe that 

this issue is clear, however, I mean, you don't necessarily 

have to get to that point if we can agree and we reach a 

consensus that this exemption is, would work in terms of 

energy savings. 

 MR. FERNSTROM: So, so speaking for the California 

IOUs, we are not prepared to agree to that at this point 

until we see the data and I believe that the other 

environmental advocate representatives in this Working Group 

have a similar view. 
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 MS. SHEPHERD: Right. And I'm not suggesting 

that, that we're looking for your agreement on this today, 

obviously. I mean, we recognize that there's additional, 

that there's additional information that can be informative 

on this issue. 

 MR. FERNSTROM: Well, we keep coming back to this

point over and over and over again. And both sides have 

made their positions quite clear. So, why don't we proceed 

with the process of looking at the data and then we can make 

a decision? 

 MR. WINNINGHAM: This is David Winningham with, 

with Allied Air. Gary, I appreciate your, your position on 

this, but the prior two days we have been negotiating in a 

similar forum on commercial packaged equipment group, 

equipment, which at the present time is taking into account 

fan energy use in ventilation mode outside of the current 

test procedure and in an applied manner well beyond the 

current test procedure. So, we need to, from a 

manufacturer's perspective, we need to account for that 

performance in one place. And if we are going to be held to 

that in multiple situations, then I think that is very 

problematic for the manufacturers. 

 MR. FERNSTROM: This is Gary. I understand that. 

 MS. PETRILLO-GROH: And I think that there's 

another, there's another issue too that if, for, for Dave's 
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point, if you have that being accounted in two places, your 

fan has two standards. It has a fan standard and it has the 

standard that's being applied as it's, as it's applied to 

the covered product. And you can't have two standards for 

one covered product. So, I, I think that, that, I mean, 

that's exactly why this interpretation of EPCA that, that, 

you know, I, meaning is clear from the statute and the fact 

that there are specific provisions that talk about component 

regulation. And even a component has to be a covered 

product before it can be regulated as a component. 

 MR. FERNSTROM: So this is Gary. You said we 

can't have two standards for a covered product. Do we not 

have standards for electric motors? 

 MS. SHEPHERD: There's an entire statutory 

provision for that. 

 MS. PETRILLO-GROH: That's Caroline Davidson-Hood. 

 MS. SHEPHERD: Yeah, AMCA was amended so that that 

could happen. And that's different than fans. 

 UNIDENTIFIED MALE: Well, yes. 

 MR. FERNSTROM: But it is a situation. 

 MS. ARMSTRONG: Okay. So, I, I'm just going to 

reiterate. This is, the, the Working Group should not be 

discussing, it is not within the purview of the Working 

Group to discuss DOE's authority and interpretations of the 

statute. That being said, you're well within your right to 
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submit comments outside this process whatever. That was not 

what ASRAC charged this Working Group to do. That's not in 

the scope of the, the ground rules that we negotiated at the 

beginning. That was not in the scope that ASRAC asked you 

to do. So that being said, I'm going to bring back the 

discussion to kind of scope of, we're talking about

standards. We're not talking about authority. That's off 

the table. We're talking about standards and what's 

potentially in and out and whether we should report. And, 

and at this point it goes to Gary's comment that he just 

stated that he would like to see data before he is in a 

position as a Working Group voting member to vote. I don't 

know how other people around the table feel, but that's 

really where we are. I mean, for someone to vote on scope, 

they, they're asking for more information to better inform 

them, to better inform their vote. Talking, you know, the 

authority is just off here. 

 MS. PETRILLO-GROH: Ashley, I fundamentally 

disagree with that. You can't consider options that, that 

you can't consider options that DOE doesn't have the 

authority to do. And I, and I don't want to, I don't want 

to belabor this point. I think we can move on and get, and 

move to the data and talk about other things, but 

recognizing that in the, in other ASHRAE negotiated

rulemakings, they are discussions about what DOE has the 
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authority to do and what not. And sometimes, you know, when 

we did it last summer, the attorney for DOE would have to go 

upstairs and confer and come back and said that's not going 

to be on the table because we don't have the authority to do 

that. So, I, I think that is an issue. It's a fundamental 

issue for us. But again, as I said, I think that we can 

have other discussions about options and this still I think 

can be a very viable option regardless of whether we address 

that issue directly. 

 UNIDENTIFIED MALE: What I'm basically hearing is, 

you know, from there is this issue that's being raised about 

authority. I think DOE is being fairly clear that the issue 

could relate to scope and that, that's what this group was 

chartered to look at was scope. And that although, you 

know, authority might be an issue for people as they 

evaluate scope and it's not really a direct issue for the 

Working Group itself. 

 MS. PETRILLO-GROH: It, it is a direct issue for 

the Working Group in the sense that we can't reach consensus 

on something we think is outside DOE's legal authority. 

 MS. ARMSTRONG: The Working Group is not allowed -- 

 MS. PETRILLO-GROH: I'm not going to speak for all 

the manufacturers. That's just AHRI. 

 UNIDENTIFIED MALE: Yeah, I -- 

 MS. ARMSTRONG: -- to work on this, on, the 
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Working Group, it is not in the ground rules for the Working 

Group to discuss DOE's authority as it relates or, or vote 

on a position about it. So, to the extent somebody wants to 

discuss the applicability of potential standards or how 

certain types of equipment should be tested, that's well 

within the purview. But it was definitely in ASRAC's 

charter, nor was it in the ground rules. 

 UNIDENTIFIED MALE: Yeah, AS, ASRAC committee was

chartered under the Negotiated Rulemaking Act and the, the 

other statute. That Negotiated Rulemaking Act and the, you 

know, and FACA, yeah, and they can't sit around and, we 

can't negotiate the law. The law, the statute's the 

statute. 

 MS. PETRILLO-GROH: But isn't it important for 

everyone here to know that there are limitations on DOE's 

authority when you're moving forward and you're making 

decisions on what this regulation is going to look like? 

 UNIDENTIFIED MALE: But they're, that's -- 

 MS. PETRILLO-GROH: I mean, it's important for 

you -- 

 UNIDENTIFIED MALE: -- that's for a different 

board. 

 MS. PETRILLO-GROH: It's not, I mean -- 

 UNIDENTIFIED MALE: Well, I can't argue with you 

now. 
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 MS. PETRILLO-GROH: -- these people need to make a 

decision about, you know, what this rule's going to look 

like and if it's going to have legal problems, at the end of 

the day that's an important factor to consider. 

 MS. SHEPHERD: But I, I, I think that the key 

decision here is that for, it is extremely difficult for us 

to agree to something that we feel is beyond DOE's legal 

authority. 

 MS. ARMSTRONG: So but -- 

 MS. SHEPHERD: And -- 

 MS. ARMSTRONG: -- I go back to Trinity is, I 

think, point about, should we proceed with the working 

group. I mean, that's essentially what he was asking and 

that's something that's within this Working Group to decide. 

Should be keep continuing to meet if you're, I mean, what 

I'm hearing and, and I hope this isn't the case, because I 

think the last meeting we were making pretty good progress 

and I thought this morning we were making good progress, 

until we got here. Was the fact that we were talking about, 

you know, the details and those types of things or what 

potential regulations might look like and, and how that 

things might be tested and the details that are within the 

scope of the Working Group. But it really comes to the 

heart of, you know, if you're telling us there's a subset of 

this Working Group that believes that they can't proceed 
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without articulating or voting on opinions of DOE's

authority -- 

 MS. PETRILLO-GROH: That's not what -- 

 MS. ARMSTRONG: -- and I think we're at the point 

of, of try, having a discussion about do we proceed or not? 

And that's really, you know, this Working Group can ask 

ASRAC to suspend. 

 MS. PETRILLO-GROH: That, Ashley, that is not what 

we're asking. What we're trying to do is explain our 

position. And this is our position on the issue of covered 

products and exemption for covered products. We are not 

asking for a vote on whether DOE has legal authority. We 

understand that is DOE's determine to make, determination to 

make. What we are saying, we're trying to explain our 

position on this particular issue and we think that

practically, as we talked about in the previous slide, this 

can be a working resolution that works very well and 

maintains the flexibility and avoids this issue. So, 

that's, that's what we're talking about. And we do think 

that we can move over be, forward because this is an option. 

And we want to further explore this option and put it forth 

in front of the Working Group for consideration with further 

information. And there's a, and this is just for covered 

products that we're talking about. We're not talking about 

non-covered products, which is what we talked about this 
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morning. 

 MR. FERNSTROM: This, this is Gary. A 

recommendation for process. Maybe we ought to vote on this 

recommendation now and set it aside. So that is, is the 

willing, the Working Group willing to take off the table fan 

coverage for those fans that go into unitary equipment? 

 MS. ARMSTRONG: Okay. 

 MR. FERNSTROM: If we vote on that now, we'll have 

a resolution. We can, we can go ahead either developing 

more information and retaining this possibility on the table 

or we can just take it off the table. But it, it will 

mitigate the need for continued discussion of this. And I 

suggest if the group is willing to take a vote on that, we 

need to have a little caucus ahead of time. 

 UNIDENTIFIED MALE: That's over lunch? 

 MS. ARMSTRONG: I'm fine with taking a vote. 

Others? 

 MR. FERNSTROM: Yeah, get a, get a very clear 

written resolution put together -- 

 UNIDENTIFIED MALE: How long a caucus do you want

Gary? 

 MR. FERNSTROM: I think it'll take the -- 

 UNIDENTIFIED MALE: Want to do the caucus? 

 MR. FERNSTROM: -- environmental crew maybe two or 

three minutes. To all be on the same page with this. 
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 MS. PETRILLO-GROH: So what would be the out, so 

if, what are the alternative outcomes? So if, if we had 

this vote and it came out one way, what would be path 

forward and on the other way what would be the path forward? 

 UNIDENTIFIED MALE 1: What's the resolution? 

Let's -- 

 MR. FERNSTROM: Gary. The vote, the -- 

 UNIDENTIFIED MALE 1: -- just be very -- 

 MR. FERNSTROM: -- vote would be can we take fans

that go into unitary equipment off the table now --

 UNIDENTIFIED MALE 1: Regulated. 

 UNIDENTIFIED MALE 2: Current, currently regulated 

products. 

 MR. FERNSTROM: Will you forget currently 

regulated? Or, or we don't. 

 MS. ARMSTRONG: They're not all regulated on that 

slide. 

 MS. PETRILLO-GROH: They're covered products. 

That's what listed. That was pulled from the DOE website. 

 MS. ARMSTRONG: They are not all regulated. 

 MS. PETRILLO-GROH: They're, are they covered 

products though? 

 MS. ARMSTRONG: The way you have them, generally 

speaking is that -- 

 MS. PETRILLO-GROH: This was, I pulled that off of 
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the, you know, the part of the EER website that says 

commercial? 

 MS. ARMSTRONG: Fine. 

 UNIDENTIFIED MALE: What other sites were used? 

 MS. PETRILLO-GROH: That's so, that's where it 

came from. Right there. 

 UNIDENTIFIED MALE: What other (indiscernible) -- 

 MS. PETRILLO-GROH: Sorry. 

 MR. FERNSTROM: It doesn't matter to me whether, 

this is Gary again, whether we address covered products or 

regulated products. I think the outcome of the vote's going 

to be the same either way. 

 MR. CATANIA: Gary can I offer a suggestion before 

you caucus here. Tom Catania. Couple of thoughts. You 

know, to me the more significant vote is, is whether or not 

AHRI's position is that if these products are included, that 

they cannot vote in favor of, of any proposed regulation. 

Because to me, that's much more important. You know, it 

would be a very quick vote. My sense is of whether these 

products should be excluded and it would fail. But so, then 

the question becomes, does, does the process go forward in 

bad faith if you're going to take the position that any 

agreement that includes covered products you will vote no 

on? 

 MS. PETRILLO-GROH: No, I think that the, the key, 
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I think the key concern are the practical issues that we 

outlined. So I think there are -- 

 MR. CATANIA: No, no, no. We didn't hear 

practical issues -- 

 MS. PETRILLO-GROH: Yeah, it was the slide before

the -- 

 MR. CATANIA: -- we had -- 

 MS. PETRILLO-GROH: -- the legal one. 

 MR. CATANIA: Yeah, it, it was but the dispositive 

issue are your fundamental legal position -- 

 MS. PETRILLO-GROH: No but we think -- 

 MR. CATANIA: -- that they can't be covered. 

 MS. PETRILLO-GROH: Okay. But we think the, what, 

what we think the benefits of this approach are, are those 

things that are listed there. So I think there are other, 

there are other paths and I honestly think that we would 

have to go back and decide whether or not at this point on 

that particular issue that's something that, that we could 

say right now. But I think that there are other, in terms 

of the definitions, and, and things like that, there are 

other things that can get us to the same results or that we 

may be able to be comfort, comfortable with. 

 MR. FERNSTROM: So this is Gary again. Tom, I 

think AHRI is saying, listen to our recommendation and make 

a determination on it. And I'm just calling for the 
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determination now. 

 MR. CATANIA: Well, the, the determination is just 

on the point of whether the products should be excluded and 

it fails, we're back, we're back in exactly the same place. 

 MR. FERNSTROM: We are, but I think it will 

preclude AHRI coming back again and saying over and over 

again, listen to our proposal. 

 MR. CATANIA: Well -- 

 MR. FERNSTROM: Which is what has been happening 

for the past two or three meetings and gets to Trinity's 

point about where we go from here. Now where AHRI goes in 

the future, that's up to them. But at least it will resolve 

this issue now. 

 MR. WHITWELL: So this, this is Bob Whitwell from

Carrier and I think I'm speaking, I hope I'm speaking for 

the rest of the AHRI members when I say, really what we're 

looking for is exemption of the condenser fan and the supply 

air fan on covered products, because those are included in 

the efficiency metric and they already have for, for this, 

this equipment. It's included in the, in the EER or the 

IEER metrics that exist today, or the EER that exists today 

and the IEER metric that we're negotiating currently in the 

other rulemaking process. And in fact, if you look at the 

energy savings that, we, we, we have each, the manufacturers 

and the energy advocates presented positions yesterday. 
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We're, we're narrowing in on a, on an agreement, I believe, 

in that other rulemaking and there's a significant amount of 

energy savings with this, with the proposed vote positions. 

A good portion of that energy savings is due to the fan 

energy. And it's, it's the fan energy during the cooling 

operation, within the heating operation and during the 

ventilation op, operation. It's (indiscernible). 

 UNIDENTIFIED MALE: Okay. And all the implied 

static. 

 MR. WHITWELL: And, and that applied static is all 

in there. So, what we're looking for is exemption of the 

supply air fan and the condenser fan in those covered 

products because it's built into the energy metric that 

we're already, that we're certifying and will continue to 

certify to DOE. 

 MR. CATANIA: So, can I ask a clarifying question

in response to that? Tom Catania again. So of the total 

horsepower that we were looking at in the original kind of 

broad conversations, there was about a 50, 50 split between 

a gross look at fans and covered products and not. You 

know, it was a few million on each side. The exemption as 

you just more narrowly describe it, how much of that 

horsepower are we talking about? 

 MR. WHITWELL: I, I don't know the answer to that. 

But I do -- 
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 MR. CATANIA: (Indiscernible). 

 MR. WHITWELL: -- I, I -- 

 UNIDENTIFIED MALE: I do. 

 MR. CATANIA: Well, if it's covered. 

 MR. WHITWELL: But -- 

 MR. CATANIA: It's counted. I'll answer the 

question. The connected load, right? Just back of the 

envelope calculation, of AHRI regulated products is above 

one horsepower or one horsepower and above is about two 

million horsepower. And below one horsepower is about two 

and half million horsepower. Put that in perspective, the 

fan products, if you will, that are represented by the 

database that we produced, which includes some embedded 

fans, is about 3.6 million horsepower. So basically you've 

got four and a half million horsepower in regulated

equipment and you've got three and a half million horsepower 

in unregulated equipment. So it's not a small amount of 

connected load. 

 MR. WHITWELL: So let me add one other aspect of 

this, this is what's going on, on the commercial air 

conditioning side. 

 MS. ARMSTRONG: Hold on one second. With what you 

just said though, I don't think that equates to what Bob's 

saying either. Right? I mean, he's talking about -- 

 MR. CATANIA: That's the, that's the, that's the 
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fan power at the wire. That's the connected load in BHP -- 

 MS. ARMSTRONG: But not all AHRI parts to me. If 

I am understanding you. And perhaps I'm not. You're 

asking, if you're just talking about that other rule, you're 

asking small, large, very large condenser fan, other size 

fan for air cooled only and only for those? 

 MR. CATANIA: Supply air fans. 

 MR. WHITWELL: Well, certainly for those I think 

the other -- 

 MR. CATANIA: My, it was my -- 

 MS. ARMSTRONG: I mean, that is very different 

than -- 

 MR. CATANIA: Are you asking him or are you asking 

me? 

 MS. ARMSTRONG: From behind you. 

 MR. CATANIA: Okay. 

 MS. ARMSTRONG: That's very different than what's 

on this slide. I mean, what you're arguing with the other 

rule is limited solely to, greater than 65,000 all the way 

up to bare wires, so 70 some tons, 70 tons-ish. Air cooled 

only, split and packaged. 

 MR. WHITWELL: Yeah. That is the, that's today. 

 MS. ARMSTRONG: That's what the other rule -- 

 MR. WHITWELL: That's, that's the other rule. 

 MS. ARMSTRONG: -- I mean, if you're using that as 
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your argument, that is what the other rule is. And if 

that's your ask, I think that's a very different ask of the 

people around the table that -- 

 MR. WHITWELL: Okay. Well, let's start -- 

 MS. ARMSTRONG: -- would split everything on the 

slide by way. 

 MR. WHITWELL: -- let's, let's, let's start with 

that part. Okay? Let's start with that part. Because 

that's what's going on today. Now what's going to happen in 

the future, I expect that we're going to see the other 

products move to the same type of metric. Right? I would 

expect that, that's the direction that -- 

 MS. ARMSTRONG: So, do you want some time to think 

about what you're asking the group to potentially consider 

voting on? 

 MR. WHITWELL: I, I guess I would like to make 

sure that I'm in line -- 

 MS. PETRILLO-GROH: Well, we'd like to caucus. 

 MR. WHITWELL: -- with the rest of the AHRI 

members. But -- 

 MR. CATANIA: And can I, can I -- 

 MR. WHITWELL: -- but I -- 

 MR. CATANIA: -- just some other things about 

that? 

 MR. WHITWELL: -- sorry, I just, I'm sorry. I, I
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just wanted to make -- 

 MS. ARMSTRONG: I, I think your argument for that 

is very different than this one. 

 MR. WHITWELL: -- I just wanted to make one other

comment about what's going on in the other rulemaking. So, 

so part of maximizing or improving the energy efficiency 

with the IEER metric, driving the products that have staged 

indoor, inner, staged indoor fans. That's, that's coming 

out complete, and as the IEER metric increases, it's also in 

the, it's in ASHRAE 90.1. It's in California Title 24, as 

requirements to have staged fans in order to comply with 

those standards. So as you move to the lower fan speeds and 

part load, the efficiency of the fan is much less important. 

Right? Because the, the energy used goes with the, the cube 

of the, of the speed. Right? So, you can argue that the 

IEER, increasing the IEER is doing more for saving energy 

than a, an incremental improvement in the energy efficiency 

of the fan itself. So it's just another thing to consider. 

 MS. ARMSTRONG: But that argument is limited too. 

Greater than 65, small, large, very large, air cooled, split 

and packaged. That's a very different ask. 

 MR. WHITWELL: Okay. That's great. Okay. We're

going to talk about that. 

 MS. ARMSTRONG: Okay. 

 MR. CATANIA: Okay. So I guess, this is Tom 
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Catania again, I guess if I was going into your office, one 

of the things I would be thinking about is that at the 

highest level, the DOE's authority to regulate safe energy 

here and the desire on the part of the people who regulate 

power generators around the country, is very broad. And 

you've experienced as an industry watching the salami get 

sliced multiple times and the minute it's made the statutes, 

to cover things where opportunities for savings have been 

missed and then identified subsequently and oh, we're going 

to either have to change the test procedure or the authority 

or something like that. That's what's going to happen again 

if there are millions of, you know, horsepower that in the 

real world are increasingly detected as not being safe. So, 

it's do you want to do it in a comprehensive process that, 

that considers in the proceeding you just described in this 

proceeding an optimization of this, or do you want to fight 

trench, legalistic trench warfare and have, you know, 

difficulty predicting your capital investments and research 

and that spending as the salami keeps getting sliced as 

people go back. Whether it's the advocates or the 

Department directly and says okay. If it'll require us to 

tweak our legislative authority a bit or our interpretations 

and our rules a bit, but this is a big pile of demonstrated 

energy savings opportunities sitting there that's not being 

taken advantage of. And that's the way I would think of it 
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if I was trying to do capital spending plans and investments 

looking out decades where these things get fixed later and 

you guys have had it happen multiple times. Mike. 

 MR. WOLF: This is Mike Wolf, Greenheck. So I 

just have one question here before we break for a caucus 

here. First of all, I, I guess my interpretation of what I 

have heard, is that what Amy -- 

 MS. ARMSTRONG: Uh-huh. 

 MR. WOLF: -- said, and what Bob said, they sound

like different things to me -- 

 MS. ARMSTRONG: They are. 

 MR. WOLF: -- so I think it would be good to get 

that -- 

 MR. PETRILLO-GROH: Yeah, and I -- 

 MR. WOLF: -- cleared up. I'm not looking for a 

response. I just want to get this off my chest today. 

 MR. PETRILLO-GROH: Yeah, go ahead. 

 MR. WOLF: And then the second thing is for every

action there's a reaction. So let's assume for a moment 

that I'm just going through my head here, that we take some 

of the stuff off the table. What will happen then? I'm, 

I'm guessing the process will go on. We'll have AMCA, you 

know, I know my, my initial comments to the NODA. I, I 

suggested the ASRAC process because I'd probably get more, 

excuse me, more people involved and we'd end up with a 
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better rule. Now, to Trinity's point, it's getting a little 

frustrating coming up to Washington every couple of weeks 

and feeling like we're spinning our wheels. And my guess is 

that if we take some of these things off the table and said, 

all right, you know what, they, they don't apply. We're 

going to go back to what we were doing before and, you know, 

time will march on and the, AMCA group or the advocate group 

will just continue on with what we've developed and that's 

what will get probably adopted if it's legally okay to do 

that. And again, I'm kind of thinking ahead in the house 

market, I think, again, it would be better that we include 

all the fans, you know, the manufacturers that, that are 

applying fans, rather than just this kind of relatively 

narrow view of, of AMCA and, and advocates. So, you know, 

you, I don't know if that's a question or a statement. I 

guess I'll ask if the question could actually, if the ASRAC 

were disbanded -- 

 MS. ARMSTRONG: Yes. 

 MR. WOLF: -- what, what would be the future stage 

of this process? 

 UNIDENTIFIED MALE: Statutory. 

 MR. WOLF: Can you answer that or not? 

 MS. ARMSTRONG: Yeah. So, I can, I mean, I'm not 

going to do it from a statutory authority side, but just how 

this will work, more as a process kind of thing. So if this 
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group votes, we would have to vote to disband. We would ask 

ASRAC to disband us, because ASRAC is the one that chartered 

us. So we would have to do that. ASRAC would then disband 

the committee. They would tell DOE it was disbanded and why 

and DOE could march on with its own rule. I mean, at that 

point in time it becomes its normal rulemaking process. We 

would go through our proposal development process and then 

put a proposal and notice and comment. I mean, we've 

already stated a couple of them that we intended to do so 

for fans. So, it would just go through our normal 

rulemaking process that doesn't afford as many of the back 

and forth opportunities with all of us in the room to deal 

with some of the stickier issues that we have been talking 

about. So, but that's what would happen if we disband. 

 MS. SHEPHERD: And this is Amy -- 

 MS. ARMSTRONG: And at that point what, in terms 

of what's, you know, it's informed by the comments we 

receive. It would be informed by the discussions we've had 

to date, but ultimately DOE would be deciding and putting 

out a proposal for comment. 

 MS. SHEPHERD: And this is Amy from AHRI. I mean, 

our intention in presenting this was to just give you the, 

the, explore this as an option and tell you why we thought 

it was a good option. That it, it wasn't our intention to 

bring this to vote today. That's what I said to Gary. When 
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we know there's more information coming. But what I think 

we just want to do is continue to explore this as an option. 

Our intention here was just to give you an explanation of 

what we think the basis for the option would be. And that's 

it. I mean, I, I think there's definitely a benefit to 

moving forward and just continuing to consider this as an 

avenue for these types of products, or some variation on 

this as we have discussed. 

 MR. FERNSTROM: Well, well, this is Gary. Amy, of 

course, this would remain an option as we move forward as is 

consideration of the work that's going on with the Unitary 

Working Group. So, you know, what outcome we ultimately 

come to is dependent on a couple of things. Getting more 

information about this market and seeing how it may or may 

not be treated and other ongoing working groups. 

 MS. MAUER: This is Joanna. Bob, I just wanted to 

push back a little bit on what you said. I, I think I heard 

you say that fan energy is already captured in IEER. And I 

agree that condenser fan energy is captured. Supply fan 

energy is captured to some extent. I haven't been involved 

in the discussion on unitary equipment, but my understanding 

is that there have been discussions in that working group 

about how IEER really is not adequately capturing fan energy 

and there are different ways that, that can be addressed. 

IEER could be revised to better capture fan energy. But I 
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just wanted to -- 

 MR. WHITWELL: Yeah. So -- 

 MS. MAUER: -- point that out. 

 MR. WHITWELL: -- okay, so let me expand on that. 

So, the condenser fan is 100 percent covered. When the 

compressor is on, the condenser fan is on and it's -- 

 MS. MAUER: I think that's what I said. 

 MR. WHITWELL: -- captured 100 percent. 

 UNIDENTIFIED MALE: Yes. 

 MR. WHITWELL: The supply air fan is captured when 

it's running in cooling operation. When the unit is running 

the heating operation, it's actually helping to heat so 

it's, it reduces the heating, the heating requirement for 

the heat pump or for the electric heater or for the gas 

heat, because it, it's, the inefficiency is adding heat to 

the air. Okay? And that's a small part of that total 

operation. The, the ventilation energy is not captured in 

the metric, although it is being captured in the analysis 

and the savings that are being included in the analysis for 

that rulemaking. Furthermore, there was an, an ask or some 

discussion and the industry members need to go back and 

think about this. To consider a revision or tweaking of the 

IEER metric to include ventilation. So that's something 

that we can consider as part of the ongoing negotiations. 

 MS. MAUER: I think that's one component in my 
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understanding. The other significant component is that IEER 

test is using unrealistically low external static. 

 MR. WHITWELL: The IEER test has external statics

that are representative of statics that can be applied in 

applications. I mean, the, the range of applications is so 

broad. Right? 

 MS. MAUER: Right. I understand -- 

 MR. WHITWELL: And -- 

 MS. MAUER: -- but I don't know that it's -- 

 MR. WHITWELL: -- and, and in -- 

 MS. MAUER: -- representative. 

 MR. WHITWELL: -- the energy analysis that's being 

done, statics higher than the test statics are being used. 

So, the analysis is looking at something that's higher than 

what the test standard is, is based upon. So -- 

 UNIDENTIFIED MALE: Because? 

 MR. STARR: Yeah, this is Louis. I mean, that's 

kind of a lot of where I have the heartburn. They're using 

.3 static inches for it, so think of all the ductwork 

systems and the tab guidance beat that. How many of them 

actually hook up and only have .3 inches of static pressure 

loss in the pressure return. And that's what they're using. 

It's owner analysis, they, the consultants went back and 

used what they considered a more realistic number -- 

 MR. WHITWELL: .75 and 1.25. 
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 MR. STARR: Yeah. Depending on the size of the 

equipment. And so that bumped the savings quite a bit. But 

the test procedure itself still is very low -- 

 UNIDENTIFIED MALE: Uh-huh. 

 MR. STARR: -- static pressure and so that's why 

when we're talking about the IEER being more representative, 

using a higher static pressure and it would be one. And 

then the other things that Bob mentioned. 

 MR. WHITWELL: Yeah. So I mean, the test 

procedure is a test procedure to compare different products. 

Right? The, the energy analysis that's being done -- 

 UNIDENTIFIED FEMALE: Prepared by a condenser 

company. 

 MR. WHITWELL: -- is, is looking at what, you 

know, a higher static pressure. So, you know, we're 

getting, we're getting a comparison that's helping us to 

determine, you know, it's giving direction on determining 

what the final level is going to be that's based on higher 

static -- 

 MS. MAUER: This is Joanna. Yeah, I understand 

that the analysis is attempting to reflect actual field 

energy consumption, as it should. I think the, the concern 

is that if the test metric is not appropriately reflecting 

field energy consumption, then it's not adequately kind of 

incentivizing fan energy improvements. 
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 MS. WINNINGHAM: And, and, this is Dave with 

Allied. Joanna, I completely understand what you're stating 

there and that has been asked too. But we are accounting 

for that energy as it's applied, kind of per our discussion, 

beyond what the test procedure, and we are making our 

decisions based upon that, that energy, that energy. What 

we are, what gives us heartburn is we have, we have done 

that and that has significantly changed the fan power in 

that discussion. I mean, it, it has, it's probably -- 

 MR. STARR: So, Dave, the, the concern is not so 

much about the most recent. What's in the future, if you 

have a metric that's not really gearing it toward, I mean, 

to make it a more concrete example, let's take like a dryer 

or a washer where you, you, the, the test product was all 

handkerchiefs. Now how many of us, you know, go there. So 

it's, in other words, if you're applying the test procedure 

around something that's not realistic, it, it designs them 

to, design their equipment around them, and that's what 

really the concern is, not so much is the, the snapshot of 

how much the savings are. But moving forward, are we on the 

right trajectory to get where we're trying to save energy in 

the field? 

 MR. WINNINGHAM: Understand, and I understand what 

the test procedure is and how we're, how we're doing that 

analysis and I think the debate here is, okay, if we're 
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going to account for that energy there, then we can't 

account for it here. 

 MS. MAUER: So this is Joanna. I don't, I don't 

think the analysis is accounting for the analysis is 

sufficient, because in order, what we care about is real low 

energy savings, not, not -- 

 MR. WINNINGHAM: That's what the analysis is 

attempting to end -- 

 MS. MAUER: And I, but I think that -- 

 MR. WINNINGHAM: Go ahead. 

 MS. MAUER: -- the problem is that you can have 

two products at the same IEER that may have significantly 

different real world energy consumption due to, to fan 

energy, and I think that's a problem now, so. 

 MR. STARR: That's the part that we're trying, 

would like to get it fixed at some. The question is, is how 

do you fix that. 

 MS. ARMSTRONG: So can I ask you a question? I 

mean, this is just a question. 

 MR. STARR: No. 

 MS. ARMSTRONG: If the ask then for, for 

potentially, I mean as part of your, as for a lot of people 

here but, Bob had the, I know the Bob again, because you're 

the new spokesman. Uh -- 

 MS. SHEPHERD: You fired me, I know. 
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 MS. ARMSTRONG: No, no, I didn't fire you. I'm 

just not talking authority. So I, so, if, if your ask is to 

the group for us to potentially consider taking off the 

table at this point, small, large, very large, greater than 

65,000, um, air cooled split package, air conditioners and 

heat pumps because of all the aforementioned reasons, um, 

are you willing to also commit to a metric and test

procedure provision as part of that ask. 

 MR. WHITWELL: So again, I think this is the part

of what we've already -- 

 MS. ARMSTRONG: I mean, just wondering. 

 MR. WHITWELL: This is what we've already been 

asked in the other working group to consider. So, I mean 

this was yesterday. So we need some time to think about 

this, and, and develop a response. But I think, Joanna, to, 

to answer your concern, I mean if we were to include in the, 

say as Harvey put it yesterday, to link the IEER test 

procedure to include ventilation, the fan and the fan 

powered during ventilation, I mean I think that goes a long 

way to eliminating the concern that, that you guys would 

have as far as the IEER test procedure. Right? 

 MR. STARR: Well, I think the static pressure, uh, 

for me is probably, you saw the analysis that jumped a 

factor in amount of energy he test -- 

 MR. WINNINGHAM: I, I think that's part of the 
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discussion. 

 MS. ARMSTRONG: So, so can I make a suggestion? 

 MR. STARR: Yes. 

 MS. ARMSTRONG: At this point, it sounds like 

people need to caucus. You need to think about what your 

ask of it is. We need to think about what we may be willing 

to give or whatever with our respective each little groups. 

And clearly you've heard the discussion with regards to 

data, the test procedure changes, metric changes, different 

things, what is your actual scope? This is very broad. And 

I could argue against your fans for a lot of these with 

regards to test procedures and regs right now. So I think 

you need to really figure out what your ask is of this 

group. And with that, who wants to eat. 

 MR. BOTELER: I have one comment. Can I make one

comment and here? 

 MS. ARMSTRONG: Yeah. 

 MR. BOTELER: As a, as a -- 

 MR. STARR: Please identify yourself. 

 MR. BOTELER: Oh, I'm Rob Boteler, I'm the 

Chairman of the Electrical Motor and Section Energy

Management. Yeah, thank you. 

 MR. STARR: Thanks. 

 MR. BOTELER: We've been regulated for about 20 

years now, so we have a little bit of experience here. 
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 MS. ARMSTRONG: And they keep coming back for 

more. 

 MR. BOTELER: We keep coming for more, and it's 

all because of you and now you bring the kid back. Oh my 

gosh. 

 MS. ARMSTRONG: I didn't bring the kid back. 

 MR. BOTELER: Oh, okay. 

 MS. ARMSTRONG: Who's to clarify that one. 

 MR. BOTELER: I would just, I'm not going to be 

part of the caucus, but I, I would just mention that, it was 

mentioned that motors were regulated as a component. And if 

it goes into a piece of equipment, it can also be regulated. 

And that's, that's probably not by accident. One of the 

issues that you're going to face under regulation is a fan 

manufacturer' enforcement. And Ashley and I go back and 

forth on a regular basis for enforcement and issues we have 

with enforcement. And if you think that the market is not 

going to challenge you at every corner and try to take 

advantage of lower cost and get around the regulations, you 

are sadly mistaken. I have examples. We have a small motor 

rule. I got a call the other day from one of my sales 

people. One of his manufacturers is redesigning an entire 

product line, moving millions of dollars' worth of motors to 

another product that's not covered so he can avoid the 

regulation. 
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 So I think when you look at something like this, 

and I understand the issues, you know. If it's covered, 

it's, and you're double counting it, that is definitely an 

issue. But if you're a fan manufacturer and you're creating 

a situation where you regulate not at the point of 

manufacture, but at the point of application, you've created 

a situation where the market is going to take advantage of 

it. So that's, my worse, my worse of what, what occurs in 

the market. 

 MR. WHITWELL: I, I know we're holding up lunch, 

but I, I don't, I'm not sure I quite understand that, 

because how does it, you're saying it creates a problem, 

creates a problem for who? 

 MR. BOTELER: As a, as a manufacturer of the 

regulated equipment, whatever that component is, if it can 

go in two different directions, it has a different 

regulation depending upon the application, then the market 

will see that and, and take advantage of it, and try and 

purchase that product that's not regulated. 

 MR. WHITWELL: But you're talking about a, let's 

say, a, fan blade. 

 MR. BOTELER: Right. If there's a fan blade that

could go two different directions, you will find at some 

point that there's a, it would never happen here, but the 

manufacturer from Southeast Asia somewhere would suddenly go 
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to one of your competitors and find that they're building 

air handlers with some piece of product that, we find motors 

that have no nameplates. 

 MR. WHITWELL: So you're talking about a, an end 

use product that someone would go to China and buy, say like 

an air handler. They would buy an air handler -- 

 MR. BOTELER: No. I'm talking about your 

competing air handler manufacturer here in the U.S. is 

buying those components from somewhere that are not, not 

compliant. 

 MR. WHITWELL: But, but, so I think that problem 

exists here anyway, because as I've sat in on the last few 

meetings, I understand that I will be the fan manufacturer, 

because I'm taking that fan and I'm putting in the housing. 

So -- 

 MS. ARMSTRONG: I don't think we've determined 

that per se -- 

 MR. WHITWELL: That's right. 

 MR. BOTELER: But that's the discussion. 

 MR. WHITWELL: That was the question on the table. 

 MS. SHEPHERD: Okay, I think you may have made 

your point -- 

 MR. BOTELER: Okay. 

 MS. SHEPHERD: That, that any solution has to be a 

solution -- 
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 MR. BOTELER: I just wanted the fan manufacturers

to understand that. 

 MS. SHEPHERD: Yeah, I think everyone has a point

that a solution has to cover all the problems. 

 MR. WHITWELL: Well I think, if I think about the

motor correlation, I mean we have to rearm. I'm not sure 

that we can go buy a motor from somewhere else and use it in 

our equipment if it's not, if it doesn't meet the DOE 

regulatory requirements, because I believe any motor that 

comes into the, into the U.S. has to be, has to meet that 

requirement, right. 

 MS. ARMSTRONG: Oh, I'll, I'll give you -- 

 MR. WHITWELL: And that, that's his point. 

 MS. ARMSTRONG: So I'll give you an example, 

right. Do you remember a couple of years ago when I was 

like this, like crawling around the room -- 

 MR. BOTELER: Yeah, baby number two. 

 MS. ARMSTRONG: -- because I was about to have a 

baby and we were talking about what, you know, we got to the 

point where it was, well what kind of motors are you guys 

using in your HVAC equipment. And there was this big 

discussion. And all of a sudden some people are just 

slapping this thing on them, calling them air over motors, 

because they happen to blow air. And those all of a sudden 

don't have to meet DOE standards. And they don't have a 
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nameplate, because they're not subject to standards right 

now. 

 So you have a situation where, what I think Bob's

trying to explain to you is that people, no one in this 

room, but there are people out there in places that go to 

extreme lengths to find the little avenues to get their 

products in here. And while we do have an enforcement team, 

we do have a very good enforcement team that is, is very 

active and, and engaging them, you know, there are legit 

problems. And what he's trying to tell you is, be careful 

of the loopholes and unintended consequences. 

 MR. WHITWELL: Yes, yes, okay. 

 UNIDENTIFIED FEMALE: Yeah. 

 MR. BOTELER: Last week, last week, last week it 

was 50 hertz motors. The deal with regulations, the dealer 

had 60 hertz last, last week. 

 MS. ARMSTRONG: Last week, that just came in my 

email today. 

 MR. WHITWELL: We had, we had 50, 60 hertz. 

 MR. BOTELER: No. Well, 50, 60 is covered. Okay, 

we know that. We were smart enough to figure that one out. 

But we said, well we won't cover 50 hertz, so we have a 

manufacturer from India importing equipment and all the 

motors are 50 hertz, labeled 50 hertz and they have no 

anomaly efficiency, don't meet anything. And they said, 
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well we didn't have to comply because it's a 50 hertz motor. 

Of course, we're going to run it on 60 hertz. 

 MS. ARMSTRONG: So this goes along with the self 

declarations also idea. Right, these all go hand in hand. 

So, all, all we're trying to say is, think through your ask. 

The Committee is willing to listen, but think through your 

ask, what it exactly it is you're asking. What are all the 

different aspects that are potentially unintended 

consequences that they have had to deal with for a really 

long time and are banging down my door to fix all the time. 

 MR. BOTELER: Yeah, yeah, further to that, you 

know, our first regulation was we, our, our methodology was, 

have the narrowest equipment class you could possibly have, 

you know. We, we sell between 40 and 50 million connected 

horsepower a year. Let's try and narrow it down and 

regulate the least amount. Well, that opened up the door 

that we've regulated general purpose product, but we didn't 

regulate definite special purpose product. So, wow, here's 

a door where I can call it something else and avoid the 

regulation coming up a year from yesterday. And in June of 

2016 essentially covers all those. We, we learned our 

lesson as we say now, almost, almost. 

 MR. DELANEY: They're others still out there. 

 MR. BOTELER: Yeah, yeah. They're others still 

out there. 
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 MR. LEONARD: Dan Leonard, working on that. 

 MR. BOTELER: Wade, Wade, we're working on this 

commerce presentation. 

 MS. ARMSTRONG: Anyway so, and, and with that, I 

think what we're just saying, as you go eat lunch, do we 

have a variety of options down in L'Enfant Plaza, think 

about all the different aspects of your ask. And then we 

come back in an hour, perhaps you can then articulate what 

your ask really might be. 

 MR. FLY: I, I think there's one subtle thing that 

we ought to point out though. A motor hut does not believe 

your regulated point of operation. And in the fans, what 

we're proposing is regulating point of operation. So if 

somebody buys a 145 motor and runs it at 10 horsepower, that 

doesn't necessarily change whether that's a covered motor or 

not a covered motor. So I think that's one, one thing that 

we need to consider as we look at these metrics is that they 

can build a fan that can be rated, that would be a legal fan 

at one point, and I can apply it a different way, and it's 

all of sudden not legal. And for those of us that are in 

the equipment business of applying fans, that is a little 

frightening. 

 MR. WHITWELL: Yeah, and I, I worry about it. 

That's, that's right. I worry about the regulatory burden 

here, because we're already certifying to DOE our cooling 
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performance. We're certifying our heating performance 

separately. Now we're looking at we're being faced with 

certifying the performance of all the fans that we have, 

which could be five fans in one piece of equipment,

different fans. And we're going to -- 

 MR. FLY: With five different motors -- 

 MR. WHITWELL: With different motors. We're going 

to have to certify all that to the, to the DOE. I mean, 

I'm, I'm just, I don't know that we can manage all that. 

 MR. FERNSTROM: Okay, let's go for lunch. 

 OFF THE RECORD. 

 ON THE RECORD. 

 MS. ARMSTRONG: We're going to go on the record 

now. You ready, all right. So welcome back. I guess I 

will give it, the floor over to Bob, since he's the other 

person standing across the room from me, kind of like -- 

 MR. WHITWELL: Yeah. You're looking at me like 

you want me to say something, so I will. 

 MS. ARMSTRONG: So I, I think this is, you know, 

continuing discussion of where we were with regards to the, 

ask of what you want the Committee to consider, and having 

that. And then we'll move on to the, the rest of the 

presentations for the, this afternoon usually, but let's, 

let's hear from you guys. 

 MR. WHITWELL: Okay, so yes, Bob Whitwell, 
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Carrier. So AHRI members spoke over lunch and we're not 

ready at this point for a specific ask. But what we, first 

off, let me say, we do want to work the process and we want 

to get to some kind of consensus, okay. So Ashley, do you 

want to get to a consensus. 

 MS. ARMSTRONG: Actually, I want to get there too, 

Bob. 

 MR. WHITWELL: We, we would like to come back and

we want, we're hoping that we can get agreement on a 

concept. Okay, and the concept is that if the fan energy is 

included in, in an energy metric on a product that's already 

regulated by DOE, that that fan can be exempted. Okay, so 

what we, what we need to do. We, we want to have some more 

time and what we'll do is we'll go through that list of 

products that you saw up there and we'll identify where 

those products, what our ask is as far as what would be 

exempted. For example, I spoke earlier about the 

negotiations that's, that's going on. And parallel to this 

on the, uh, commercial unitary small, large and very large 

equipment for those that, you know, that covers equipment 

from six tons, up to 63 tons, or actually up to 760,000 BTU 

problems, so a lot of roof tops and split air cooler 

equipment. And on those products, the condenser fan, we are 

moving from an energy metric EER, which is a full load 

metric to a part load metric IEER. The part load metric 
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takes into consideration the energy at different load 

points, 175 to 50 and 25. And as the fan stages the 

compressors and the fan stage down for those part load 

points, you get the credit for less energy used at the, at 

the part load conditions. And those equipment, on that 

equipment the condenser fan is on when the compressor is on. 

It's off when the compressor is off. It's 100 percent 

covered in the energy metric. 

 The fan energy, the, the supplier of fan energy is 

in the metric today when the unit isn't cooling, which is 

about half of the time. Then it spends some time in 

heating, and then it spends some time in, in, uh, 

ventilation. The ask, as I mentioned before, yesterday 

during the discussion of levels that we're at in that, in 

that, uh, rulemaking is for us to look at tweaking the IEER 

metric, so that it would include the energy, the fan energy 

during ventilation. And we agreed that we would take a look 

at that. 

 The, the discussion in that rulemaking was that, 

that test procedure would be worked over the next, I don't 

know, maybe it takes a year or two years, and would be 

adopted for the next round of rulemaking, which is going to 

be sometime in the future. Not, not the levels that we're 

talking about right now, but it'll be some time in the 

future. But we, we, the ask is, has been for us to commit 
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to changing the AHRI procedure. And I think that's going to 

happen, but as I said, was just yesterday and we've got to 

consult with the rest of the, uh, AHRI members before we can 

100 percent commit to doing that. 

 So for that equipment, I think it would be 

reasonable then to say that we would exempt the condenser 

fan and the supplier fan, understanding that the exhaust fan 

or the return air fan or other fans that are in the

equipment that aren't part of the test procedure, would be, 

would not necessarily be exempted, like this. There would 

be have to be a separate case made if those are going to be 

exempted. So what we'll do is, over the next, before the 

next meeting or about the, or say by the next meeting, you 

will come back with that list of products that are covered 

by DOE and say specifically what we're asking to be

exempted. Yes? 

 MR. SMITH: I have two questions. The first is -- 

 MR. FERNSTROM: State your name. 

 MR. SMITH: I'm sorry, this is Wade Smith. Do you 

have a proposal for some physical description of a condenser 

fan that would be exempt, rather than, uh, an exemption that 

ties to the application, the use in a particular piece of 

equipment? Or is it some physical description that you can 

use to ask for an exemption of all panel fans that are of 

this, that meet this description, whatever it might be? 
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 MR. WHITWELL: We, we can come up, I'm sure we can 

come up with that. I mean, I -- 

 MR. SMITH: I think that's, I think that's 

important. 

 MR. WHITWELL: Yeah, I, I would say that, I can't

say there are all panel fans, but I, you know, they, they 

definitely, the majority would be panel fans, zero static. 

 MR. SMITH: And then, and then, uh, I, I would 

just say that, uh, in our deliberations, uh, when we, uh, 

settle on a pro forma consensus, right, uh, one horsepower 

and I'll cover one horsepower or another. 

 MR. WHITWELL: So is that, I mean that's one of 

the things that I am little frustrated with is, what is the 

scope? So -- 

 MR. SMITH: Let me finish. If the scope were one

horsepower, and I guess the question is, would, would the 

condenser fans in these units represent 760,000 BTUs be 

exempt or not? And if not, if we tweak that horsepower 

unit, would that solve the problem? 

 MR. WHITWELL: It might take care of the condenser 

fans. Uh, most of them would be under one horsepower. 

 MR. SMITH: So, so that's all. Maybe in the 

future we'll all do it, you know. So that, that's, that's 

the seat of the cockpit. I think you need to come back and 

make a suggestion in terms of how those are, if they want to 
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be exempt then they have to be defined tied into the 

problem. 

 On the supply fans, can you share with us, is 

there full consideration for the cooling mode in the 

economizer operation? 

 MR. WHITWELL: The, unfortunately -- 

 UNIDENTIFIED FEMALE: No. 

 MR. WHITWELL: I mean we've been talking about 

economizer mode and these, this equipment is not part of the 

test procedure, so we are not getting credit for the energy 

that is saved during the economizer mode. 

 MR. SMITH: And consumed. 

 MR. WHITWELL: And consumed. But the, what I've 

talked about, as far as the ventilation energy, that's 

economizer mode or just pure ventilation so that would be 

our position, and -- 

 MR. SMITH: So the operating hours -- 

 MR. WINNINGHAM: The operating hours are in there. 

The consumption is there. The credit is not. 

 MR. WHITWELL: Yeah. 

 MR. SMITH: I got you there, yeah. 

 MR. WHITWELL: Yeah, so. 

 MR. SMITH: Okay, well I, I think that's important 

because, uh -- 

 MS. ARMSTRONG: I don't know whether I agree or 
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not. 

 MR. SMITH: The fan operating hours when the 

compressor is running, the fan operating hours when the 

heater is running, uh, are clearly covered by the IEER. 

 MR. WINNINGHAM: Well, okay, so let me, let me 

correct this. 

 MS. ARMSTRONG: So there's a difference. You're 

talking about the analysis versus IEER. 

 MR. WHITWELL: No, no, no, no. 

 MS. ARMSTRONG: Well they're, they're different 

things. 

 MR. WHITWELL: So on a heat pump, the fan 

operation is included in cooling and heating. If it's 

electric heat or if it's gas heat, the fan energy in heating 

is not included in the metric. Therefore, I said earlier, 

that in heating it's, it's not zero, but it's, it's, it's a, 

maybe negligible because the inefficiency is going into 

heat, so even though it's only at COP1, it's going into the 

air stream, so it is not wasted, okay. 

 MR. SMITH: Right, so what I'm getting at, is if 

the compressor, if you're in cooling mode and the thermostat 

satisfies the compressor in the locked, it'll be on in five 

minutes, but it's off right now. Is that fan only in 

operation part of the -- 

 MR. WHITWELL: That'd be part of the ventilation.
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 MR. SMITH: Okay, that'd be part of ventilation. 

So the operating hours that are here are tied into the fan, 

include that at the end of the operation. 

 MR. WHITWELL: That's right. 

 MR. ERNST: Potentially all operating modes. 

 MS. MAUER: Not today in the metric. 

 MR. SMITH: It's not in the whole load metric 

today. 

 UNIDENTIFIED FALE: Well that, that, that's in the 

ask, that's in the ask of it. 

 MR. WHITWELL: And it's not, it's not totally in 

the IEER metric today, but we have been asked to look at 

including that in there. So what that would mean is it's 

the change in the test procedure. It's going to be a 

different metric, right. It's, we can't call it IEER, 

because -- 

 MR. SMITH: And not in this rule? 

 MR. WHITWELL: Not in this rule. 

 MR. SMITH: At some future date? 

 MR. WHITWELL: It would be for the next 

generation. 

 MR. SMITH: Like six years from now? 

 MR. WHITWELL: Yeah. 

 MR. CATANIA: I have a question. 

 MS. ARMSTRONG: Who is that. 
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 MR. CATANIA: Yeah -- 

 MR. WHITWELL: Yeah, well, who knows when it is, 

right. I mean it could be sooner than, I mean, I mean. I 

mean the other issue we have that we're struggling with, is 

we got a, a refrigerant change coming on down the road. We 

don't know when, right. It depends on when the, the safety 

standards and the building codes are modified to allow the 

low GWP slightly flammable refrigerant. 

 MR. CATANIA: Very slight. 

 MR. CATANIA: Tom Catania. You know, one thing I

think we all need to collectively think about as you're 

going through these decisions about both the timing of the 

rule and the aggressiveness of it and so forth, is that it's 

so tempting to focus on the stick element of regulation and 

ignore the potential current opportunities. And if some 

combination of changing of the test procedures, uh, updating 

them as well as new standards are done well, you know, 

Gary's clients and their sisters around the country are 

already spending billions of dollars incenting more rapid 

adoption of these more energy efficient products. And, you 

know, if regulation want to indeed survive, and even the 

dozens, the projections that I've seen from people who want 

to know these things, does, those numbers that are already 

large today double in the next two years. The extent to 

which some of these advocates here, people like Gary's 
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clients, see real world real energy savings as a result of 

the work that's done here, the potential for carrot and 

incentives for these products getting into the market more 

quickly is going to be profound. 

 I mean, and I saw it happen in the appliance 

industry and it was huge. So you guys are not unfamiliar 

with these things, but this is, you know, this is a

different way to think about how we want to push forth the 

pace of this and the substantive real world observable 

efficiency benefits as we make these changes. So I just, 

you know, that's been animating a lot of the fan industry's 

conversations around this. 

 MR. WHITWELL: So we understand the carrot, and 

then we have, there are incentives for higher than basis 

efficiency levels and, and most manufacturers, and many 

manufacturers have multiple tiers. We have three tiers of 

product. We have good, better, best. 

 The industry overall has been moving, I mean 

ASHRAE, we, we're involved in the ASHRAE 90.1 process and 

that is continuing to push for higher energy efficiency in 

buildings, which includes HVAC equipment. If you look at, 

and we just presented some of the statics to the group the 

other day, one of the things that the industry has done on 

its own, we initiated this IEER metric started in 2010. 

 Too, and, and for the IEER metric, in order to 
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move up in a higher IEER metric, as I mentioned before, one 

of the important things is to reduce the fan energy during 

part load, specifically in part load when you can cut back 

on the fan speed. You don't need to deliver as much for 

staging compressors, when staging the fan energy. 

 And if you look at the data that, uh, and I, I, 

I'll, I may have this wrong, but it's the right, in the 

right range, is in 2011, which is one year after we, after 

the ASHRAE, the IEER metric was adopted by ASHRAE 90.1, 

something like six percent of our equipment from over 65,000 

BTUs per hour to 760,000 BTUs per hour had fans that were 

not just a single speed. So those would run constant, full 

speed year around, right. So it was six percent at, at 

variable or staged fans, or variable they're buying. 

 2014, that number was up to 20 percent, so a 

significant move that industry has moved to different 

technology, reducing fan energy, saving a lot of energy for, 

for consumers, so we understand the carrot part. Uh, and as 

an industry, we are working there, continuing to work 

outside of the regulatory, that the federal regulatory arena 

to improve the efficiency of our equipment, and provide for, 

for our customers, so. Yes? 

 MR. SMITH: Right, so, at this point I just want 

to interject a little pitch for the metric that was

developed in the MCO which the science of maximum horsepower 
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to any and every operating point, which on the surface seems 

like an undue burden. But it has a few very important and 

attractive attributes, especially during manufacture that 

bear pointing out here. 

 The first is that, the great frustration of fan 

manufacturers who care about efficiency is that they can 

make a fan that has a 90 percent efficient potential and see 

it applied in the field of 30 or 35 percent. And that, you 

know, this isn't like going from 90 to 72. This is, it's 

been going from 90 to 30. And the, the step back from 30, 

viewed from 30,000 feet, is that the actual fan efficiency 

varies dramatically, depending upon how the fan is applied 

and how it's liked. And so, so dramatic is this very 

ability, that it has the unwelcomed consequence of being 

able to overwhelm other things they might do to improve fan 

efficiency. 

 Sell a little larger fan. Sell a more efficient 

fan. Did it cost a little more? Our, our expectation is 

the market will respond by compensating and, and selecting a 

less efficient, less expensive fan. So the savings that we 

could produce by taking that approach, by tying the

performance to valuation or regulation to particular test 

bumps, the savings was very uncertain and the fear was that 

it would be nonexistent. So that if we went into the 

utility rebate business, so to speak and promise the utility 
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a gain, I'm not sure that we would deliver. 

 So we went instead to something which is much more 

deterministic, uh, and is, on the surface, much more fair. 

It says, you know, at every operating condition you're 

efficiency is defined by this formula and the maximum points 

card you'll find that this formula and that creates for you 

are compliant in the local operation. And if that envelope 

of operation is adhered to in the field, then the savings 

from this rulemaking get a nice step up. And the use of 

that metric becomes really, really powerful when you sell 

your rebate programs, because the only utility rebates in 

anticipation of a boosted efficiency it's going to happen, 

okay. 

 So the doubt and the statistical evaluation of 

what are the savings 100, you know, I'm going to lose some, 

I'm going to win some, no. In this case, you're going to 

win exactly what you expect. So those are all the benefits 

from an efficiency standpoint, savings standpoint. For the 

manufacturers to produce that savings, in many cases they 

need to make zero investment, because they already make the 

products that are more efficient. And because they already 

made the products that are more efficient, it's not

necessary to develop new, more efficient products. 

 The problem that this metric and this approach 

resolves is it resolves the problem that people aren't 
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buying the more efficient products. It's not that they're 

not available or that, we have to sit down with pencil and 

paper and develop them. It is that people aren't buying 

them. And so, by using an approach that encourages people 

to buy the already better more efficient products that are 

on the market, it reduces the financial and, and human 

resource burden on fan manufacturers to produce the savings 

that are implicit in the rule. 

 And if we had to produce that same amount of 

savings, by instead taking products off the market,

absolutely, positively this fan is coming off the market. 

And it'll have to be replaced by one that is reasonable. 

Then to produce the same savings that impact our, our member 

companies would be far, far greater. And so, there is a 

real benefit to the manufacturers in this, in, in this 

approach. 

 There is also a challenge in that it's a bit more

difficult to evaluate, right. And so, you know, those, 

those of you who, uh, sell products with embedded fans, 

just, just need to go through the evaluation. But if you do 

that and you compare the savings and the investments that 

you have to make in order to comply with a reasonable 

efficiency level as proposed, and then back up and say, no, 

I'm going to use a different metric and a different approach 

that'll actually cause the least efficient products to come 
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off the market, by God. And that's the only way to generate 

savings. And then that begs the question, how much savings 

did I generate and how much did I have to invest to get it. 

You're going to find that this approach is really 

attractive. It's attractive if your motive is to save 

energy. It's attractive if your motive is to sell more 

efficient products that you've already manufactured. 

 And honestly, the jury's still out. You all 

haven't decided exactly what you want, or where you want to 

go with this. But this is my pitch with the approach that 

we took, and I should say also that this isn't where we 

started. You know we started with the single point or a 

multi-point metric, that was defined test scores. And we 

took that way down path. We had a consensus. We had a 

handshake. We even had bargaining authority approved by the 

AMCA Board of Directors to go into these discussions. 

 And when we created the database and tested that 

approach and compared it to the approach that we are now 

advocating, we very quickly shifted, in part because, 

especially in some products, the de-linkage between the 

savings that we could calculate and the metric itself was so 

great that it was, it was a real credibility problem, even 

for our own. So the membership just took a long pause and 

deep breath and went a completely different direction. 

 And the more, the more our membership became 
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familiar with it, uh, and there were some adjustments. 

There were adjustments to the pressure, to the pressure 

constant to accommodate the exhaust fans we talked about 

this morning on which, you know, our members make an awful 

lot of exhaust fans that aren't necessarily inside package 

units. They're sitting on the roof. But there's an awful 

lot of low pressure fans and we had to make an 

accommodation, because they are entirely inefficient as you 

pointed out. And you can't drive it to the peak, because 

you come up with a huge, huge diameter, which is totally 

impractical. So we made the accommodation and -- 

 MR. WHITWELL: Okay, so, so that was a very, very

nice advertisement as you put it -- 

 MR. SMITH: That's what, that would -- 

 MR. WHITWELL: But, I mean, you talked about a lot 

of things that we haven’t gotten to yet. You talked about 

levels. You talked about certification. You talked about 

enforcement and, and we've got a long ways to go, I think, 

in this discussion before we really understand what the, 

what that full picture is going to look like. But we're 

willing to take that road and see how it goes. But we're 

not there yet. 

 MR. SMITH: Yeah, and I wouldn't expect you to. 

 MR. STARR: This is Louis of NEEA. I'm just 

mentioning I was talking to one of the fan manufacturers at 
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lunch that also gets air handling equipment. 

 MR. WHITWELL: But by the way, based on my 

understanding, we are all fan manufacturers. 

 MR. STARR: Oh, yeah, yeah. Oh I mean, more 

thought as a traditional, just, uh, a fan manufacturer, but 

they, they make some of the air conditioning products too. 

They did this on their product line, because obviously here 

in the market, they were concerned about what they found is 

that they didn't have a problem with their, uh, air handling 

products, which you might find that there's a problem with 

the, it may be, it may be something you want to do, rather 

than, I mean I understand the double regulations and why, I 

mean, I would keep that up and explain why they don't like 

that. Oh, I understand that very much, but it may be a good 

option. 

 MR. WHITWELL: Yeah. 

 MR. STARR: I think that's what, so it's just 

getting that. 

 MR. WHITWELL: I don't expect that we're going to

have a lot. I mean I don't know. I, I don't know, but I 

expect as you would suggest, that most of our fans are going 

to be okay. I mean there, there was an example we saw last 

time of this, this bare forward-curved centrifugal in this 

box and how that was a bad fan selection and there was, you 

know, there were ways to, by changing the fan selection, 
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that could be greatly improved. 

 I don't think on the HVAC, you know, if you look 

at the age of our members, I don't think that's 

representative of what we have. So I don't think that we 

are going to have fans. I assume, based on what I'm hearing 

from the AMCA people here, that we're not going to have fans 

that are going to be regulated out of the market at least 

for now. 

 MR. SMITH: Straight talking, right? 

 MR. WHITWELL: No, what? 

 MR. SMITH: Great. 

 MR. WHITWELL: I don't know what's going to happen 

down the road, but still there is a lot of burden that's 

going to be put on the, on the equipment, the fan 

manufacturers who are equipment manufacturers, to test, to, 

that test things that we don't normally test, because it 

doesn't add any value to our customers as far as what they, 

information they need to apply to the equipment. And then 

certify to DOE on an annual basis, right. So, yeah. 

 MR. BOTELER: It's unknown. 

 MR. WHITWELL: Yeah, it's, there's just a lot of 

uncertainty about that. And, and if it was something, and, 

and if, I mean, if I compare it to the motor. 

 MR. SMITH: Let's compare it to the motor. 

 MR. BOTELER: Yeah. 
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 MR. WHITWELL: So the motor rule, unfortunately, 

the burden for you guys, because the burden is really on you 

guys, right? 

 MR. BOTELER: That's right. 

 MR. WHITWELL: We buy the motor and it is, it's -- 

 MS. ARMSTRONG: Not exactly. 

 MR. BOTELER: The magic is in the motor. 

 MR. SMITH: Well then that's, and that's, and 

that's an option for you. 

 MR. WHITWELL: And, and that, if we can figure out 

a way to do that, I think that's something that we would be 

very interested in. 

 MR. BOTELER: Wade, this is Rob Boteler again. 

Electric Motors, again, I'm sorry. We were talking a little 

bit, well I was talking about this young lady, I forgot your 

name, but you haven't gotten to the point to defining basic 

models and what your test -- 

 MS. ARMSTRONG: You didn't bring that up last 

time, did you? 

 MR. BOTELER: I did. Do you want me to 

(indiscernible). 

 MR. WHITWELL: Well actually that was discussed. 

 MR. BOTELER: Oh, sorry. 

 MR. WHITWELL: That was discussed some at the last 

-- 
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 MS. ARMSTRONG: You love it. Other industries 

that are subject to (indiscernible) have not embraced it 

with the same love that you do. 

 MR. BOTELER: Let me tell you why we love the 

basic models. 

 MS. ARMSTRONG: We're getting there. 

 MR. BOTELER: We love basic models because we as 

motor manufacturers make thousands of models, but we 

actually identify the minimum product on, on each, on each 

frame size and, and, and, uh, speed and enclosure. And 

that's what we report to DOE, okay. So we report 113 basic 

models, okay. And then from that, we make electrical 

changes and as long as those electrical changes improve 

efficiency, we do it. We put efficiency on the nameplate, 

but we don't have to report it back to DOE, because we've 

already given them the, the minimum. We make mechanical 

changes. We do that. 

 We have different equipment classes, which I don't 

think you guys have discussed yet. We have things like fire 

pump motors that we hold separate from some of the other 

parts, and we treat it a little bit differently. And I 

think there's options like that, that as you get into the 

ASHRAE, you can, you can maybe address some of these issues 

by putting them in a different equipment class and 

classifying, and we don't call them basic models, whatever 
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we want to call them. 

 MR. WHITWELL: Yeah. No, I mean -- 

 MR. BOTELER: And treating them differently. 

 MR. WHITWELL: As, as equipment manager, we like 

basic models too, because I mean actually how many different 

models do we have? Do you remember? 

 MR. BOTELER: Many. 

 MS. ARMSTRONG: Oh, carrier alone? 

 MR. WHITWELL: Yeah. 

 MS. ARMSTRONG: If my memory serves correctly, one 

trillion. 

 MR. WHITWELL: Six, six trillion, six trillion. 

 MS. ARMSTRONG: Thirty trillion? 

 MR. WHITWELL: So we have six trillion possible 

models, right, but you look at all the options that we have. 

So we love basic models, because we can certify a small 

fraction of that to DOE. So we, we like it. 

 MS. ARMSTRONG: One more time. 

 MR. WHITWELL: For the record? 

 MR. BOTELER: I want to, at this time I -- 

 MR. WHITWELL: So, so, but, uh, sorry. No go 

ahead. I lost my train of thought. 

 MR. BOTELER: Well I was just going to comment on

Tom's, Tom's comments about, you know, some of the 

incentives out there. The utilities right now have $9 
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billion in their war chest that fund high performance 

products. We have an initiative through ACEEE, fan

manufacturers, pump manufacturers and compressor 

manufacturers are all working on identifying the product and 

how to label that product, so that the utilities can use 

that in those incentive programs. 

 Pump manufacturers, as a matter of fact, are on 

the Hill today. They come to Washington en masse to go to 

the Hill and talk about these issues with, with their, with 

their Congressman. Paul and I are going to be on the Hill 

on Friday. We have legislation (indiscernible) that 

incentivizes extended product, and a fan and, uh, motor and 

control is categorized as an extended product, so we have 

that. 

 The last thing we're working on is 111(D) which is 

the regulation that will allow the states to take credit for 

energy efficiency savings through the use of industrial and 

commercial, uh, incentives and products, in which this kind 

of an extended product would fit into. 

 MR. FERNSTROM: So this is Gary. I, I'd like to 

make a comment following up on Rob's and Tom's and Wade's. 

And that is, if the efficiency savings attribute isn't in 

the metric, we can't take credit for it. We can't get 

incentives for it. And I think, uh, Wade and AMCA have come 

up with a very clever approach to a metric that recognizes 
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the system-related savings through the appliance regulations 

that we have not previously been able to recognize. And 

from an incentive's point of view, we will all be so much 

better off if that metric moves forward. 

 MS. MAUER: Bob, this is Joanna. If I can just 

ask a clarifying question about what you said. If I 

understand, commercial unitary manufacturers may in some 

cases be buying a fan that would be considered to already be 

in a testable configuration. In other cases, it may not be, 

uh, in a testable configuration until it's actually

integrated into the equipment. Are you asking for an 

exemption in both cases? 

 MR. WHITWELL: Uh, okay, so that's a question I 

haven't really thought about, but I would say yes. 

 MS. MAUER: Okay. 

 MS. PETRILLO-GROH: If it's covered in the -- 

 MR. WHITWELL: If it's covered in the metric. 

 MR. SMILEY: Well, it's Bill's Smiley of Trane. 

 MS. ARMSTRONG: Well, so -- 

 MR. SMILEY: If, if the fan energy consumption is

covered in the entire unit in a, in a heat consumption, it's 

already counted. It doesn't matter -- 

 MS. ARMSTRONG: Okay, well -- 

 MR. SMILEY: -- where the fan came from or what it 

is. 
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 MS. ARMSTRONG: Do you want to do it, or do you 

want me to do it. We're going to get to the point where, 

you know, we dive away to clearly distinguish it to, to get, 

and the reason why I've asked about specific design

characteristics. I mean, I, I think I said this to a number 

of you individually, but the way DOE looks at this is, if I 

am on, standing on a dock, hopefully looking at a wonderful 

beach, but I happen to also see in my view, you know, a 

cargo ship load of fans, how do I know whether they're going 

into your equipment or not. 

 MR. WHITWELL: So -- 

 MS. ARMSTRONG: And how do I know if that energy 

used is accounted for by my test procedure. I mean, maybe I 

would know, but realistically, I'm not looking at them. 

And, and so I think this gets to my point from day one, 

which is how do you distinguish and I'm not sure that's 

something that, that's actually been answered yet. 

 MR. WHITWELL: So, so let me, I, I may be totally

confused about this whole thing, but and, and, maybe this is 

not the way it's going to turn out, but the last meeting 

when I was here, I was told the fan that you see in the dock 

is not a fan. It's not a fan until it's connected, it's on 

a shaft with bearings, motor and in a, in a housing, right. 

So that fan it may or may not comply, but you don't know, 

there's no way of knowing until somebody takes that and they 
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connect it to a motor and put it in a housing and, and, and 

test it. 

 So that fan may be good when it's put in one 

application and may not be in another, but unless I totally 

am off base with what was being said the other day, I don't 

think you, that's not a regulated component. 

 MS. ARMSTRONG: Oh, I think it depends and this 

gets to our testable. 

 MR. WHITWELL: So, so please, help me understand,

because if I misunderstand this -- 

 MR. SMITH: The fan that she's, the fan that she 

sees in the dock is a testable fan. 

 MR. WHITWELL: So what is that fan then? 

 MR. SMITH: It's a fan. 

 MR. WHITWELL: Okay, well -- 

 MR. FLY: Does it need a motor to be a fan? 

 MR. SMITH: It's not a wheel. No, it doesn't have 

to have motor. It has to have a structure. It has to have 

a wheel. It has to have bearings. It has to have, it's a 

fan. Not a fan wheel. 

 MR. FLY: But if she sees -- 

 MR. SMITH: It is not a fan component. It's a 

fan. 

 MR. FLY: But if she sees an impeller, this is 

Mark Fly with AAON. If she sees an impeller on the dock, 
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that is not a fan? 

 UNIDENTIFIED PERSON: No, it's not a fan. 

 MR. WHITWELL: So it's not a fan that she sees on

the dock. 

 UNIDENTIFIED PERSON: Still no fan. 

 MR. SMITH: Never was a fan. It was an impeller.

 MR. FLY: So it's not a fan until I put a motor, 

until I put it on the shaft. 

 MR. WHITWELL: So Wade -- 

 MS. ARMSTRONG: So this where, this is where that

has the whole configuration. See, we're getting to why we 

did this. Right? 

 MR. WHITWELL: But, but if it's a testable 

configuration, sorry -- 

 MS. ARMSTRONG: This is why that, on the dock. 

 MR. WHITWELL: If it's a testable configuration on 

the dock, then it needs to comply, right. 

 MS. ARMSTRONG: Regardless of whether, whether, 

what happens downstream. 

 MR. WHITWELL: Right. 

 MR. FLY: Right. 

 MS. ARMSTRONG: You agree with that? 

 MR. FLY: I do. 

 MS. ARMSTRONG: Because that's different than what 

you just asked the part for. 
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 MR. FLY: Uh-huh. 

 MR. WHITWELL: Okay, so I. Yeah, okay, so maybe 

that was a leading question. Okay, so, so I would, let me 

rephrase my answer. 

 MS. ARMSTRONG: See how this works? 

 MR. WHITWELL: I would still ask for the exempt, 

even if we buy a fan and it would meet the requirement. I 

would say, I don't have to certify that to DOE because if, 

if it's, if it's exempted in that application. Okay, that's 

what I would say. 

 MS. MAUER: So that maybe the person they're -- 

 MS. ARMSTRONG: Because -- 

 MS. MAUER: -- that's a different buying issue 

from has already been manufactured. 

 MR. WHITWELL: Yeah, right, right, right. And I 

could use that and I don't have to recertify it, right.. 

 MR. ERNST: Well let me, let me suggest something. 

There's, there's two analogies I think. One is, in unitary. 

This is Skip Ernst. There have been unitary equipment, some 

unitary equipment's exempt from 13 SEER for certain reasons 

and they've gotten exemptions from the DOE. Well if a fan 

is going to be exempt, it needs to go through the same 

process and it might be that it's because it's being used in 

an already regulated product. 

 MS. ARMSTRONG: Can I talk to you about that list
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of equipment you think is exempted from 13 SEER? 

 MR. ERNST: I don't make it, but you can try it on 

the Website. You see, it's exempt. 

 MS. MAUER: This is Joanna. I mean I think the 

difference is, I don't know what you're referring to, but 

whatever it is, you can look at it and say this is exempt. 

I think in the case of these fans, Ashley is saying, she'd 

look at it and it would -- 

 MS. ARMSTRONG: It may have been. 

 MS. MAUER: It may be exempt, maybe it wouldn't. 

 MR. WHITWELL: Yeah, yeah. 

 MS. MAUER: But depending on where it's going, I 

think that's what the problem is. 

 MR. WHITWELL: Yeah, so did you understand my 

clarification of what I was, I mean, if, if it's a testable 

configuration on this fan, we would, you know, it should 

already be certified, right. So we would put it in, but if 

it's exempt in that application, then I would say we don't 

need to recertify it, right. It's already certified. 

 UNIDENTIFIED MALE: Prove it. 

 MS. MAUER: That's helpful to understand. 

 MS. ARMSTRONG: Well, so -- 

 MR. WHITWELL: Yeah, that's, that's what I was 

talking about. 

 MR. SMITH: Suppose it's a, goes into a product 
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which is not certified? 

 MR. WHITWELL: Well then it, then it gets 

certified when it goes into the product. 

 MR. SMITH: Why? 

 MR. JOHNSON: It does not need to? 

 MR. SMITH: No. 

 MR. WHITWELL: It's not exempt and it's not -- 

 MR. SMITH: But it's already certified. 

 MR. WHITWELL: Well, if it's already -- 

 MR. SMITH: When she, when she draws a circle 

around the fan -- 

 MS. ARMSTRONG: This is what they understand. 

 MR. SMITH: Your fan is approved. It has the 

(indiscernible). 

 MR. WHITWELL: You know, wait, I mean, you're 

asking questions that I think I need to get answered, but I 

don't know the answers to those questions. 

 MS. ARMSTRONG: Well, one of the -- 

 MR. WHITWELL: It's already figured in this -- 

 MR. SMITH: So this is Wade. I just want you to 

understand that there is more than one answer. And one 

answer that I think would work is an answer that says, I 

make a box. I buy a fan. The people I buy the fan from 

certified it to DOE. I receive the fan. I make no

certification to DOE. That's an option. 
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 MS. ARMSTRONG: That is what you're, okay -- 

 MR. WHITWELL: Yeah, but I don't want to buy, I 

don't want to buy a testable -- 

 UNIDENTIFIED MALE: One person at a time. 

 MS. ARMSTRONG: Just to be clear, as we are asking 

DOE to consider that it is not necessarily how our regs work 

today. 

 MR. SMITH: I, I, I, I understand, I understand 

that that's -- 

 MR. WHITWELL: Can I ask a clarifying question? 

So in that case, Wade, would that always be a testable 

configuration? 

 MR. SMITH: Whoever makes -- 

 MR. WHITWELL: Or, or could it be just a blade? 

 MR. SMITH: No, no. 

 MR. WHITWELL: Yes, so -- 

 MR. SMITH: Whoever, whoever assembles the fan, 

the first point at which it's in a testable configuration, 

that entity would have the responsibility to certify it to 

the DOE. 

 MR. WHITWELL: Yes, so that's a choice 

manufacturers could make. They could make the choice to do 

that. 

 MR. SMITH: They could either do it or not do it.

 MR. WHITWELL: But, in a lot of cases that's not 
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going to be the most economical approach. 

 MR. SMITH: Well, okay. 

 MR. WHITWELL: So -- 

 MR. SMITH: But, but that's an option. 

 MR. WHITWELL: And so, I, I mean it's, it's always 

an option. I mean, we can buy a complete unit from somebody 

and resell it. That's an option too, right, so. 

 MR. WINNINGHAM: What I think the point is, this 

is Dave with Allied, that many of these are going into parts 

that are already regulated. And we all had a discussion 

about, you know, incentives. There are already incentives 

out there for the products that we make. There are ones for 

SER, EER, you know, IEER. And, and to make a case that just 

because I have good fan efficiency, means I'm going to save 

all this energy when you have multi-variables. We have a 

refrigeration system in your moving air, you can push that 

power from one place to another. Just because I have good 

fan efficiency doesn't mean I have a good system efficiency. 

 MS. ARMSTRONG: I think we acknowledge that on day 

one to a certain extent, although they don't necessarily go 

one in one. There are other aspects that affect the system 

efficiency. Having a more efficient fan whether that be a 

different category of fan doesn't necessarily hurt though, 

either. I think what we're asking of you is, you're asking 

the Committee to consider not analyzing or studying
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standards for a subset of the market. So we're really 

asking, what would that look like? 

 MR. WINNINGHAM: That's why we're -- 

 MS. ARMSTRONG: And, and, and so in terms of 

definitions, how would you tell? How would you distinguish 

it? What is the scope we're talking about in terms of 

receiving numbers, shipment numbers? I mean, back it up 

with data and what that regulation would look like and 

present it to us to understand. I mean, is it everything? 

Is it a subset of everything? Is it, those that are just 

embedded when they come in or if they're manufactured 

domestically? If you're otherwise bringing in, fan, 

testable fan configurations and then inviting them on 

equipment, that's a different issue. You know, all these 

things have to, are details that impact the magnitude of 

your ask. 

 MR. WINNINGHAM: Okay. Okay. 

 MS. ARMSTRONG: Where are, where are we? Are we 

going to talk about motors? 

 MR. BURDICK: Well, we're going to have a CTI 

presentation. 

 MS. ARMSTRONG: Sure, you can go next. 

 UNIDENTIFIED PERSON: The CTI? 

 MR. BURDICK: And so, this paper, first of all, I

just appreciate the opportunity to be able to make comments 
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and certainly CTI Group is interested in participating in, 

you know, in this discussion, interested in finding, you 

know an equitable solution and that type of thing. But here 

in this presentation, want to identify many of the issues 

that we have for our industry, to be able to adopt it. And, 

you know, recognizing too that there are probably, there are 

definitely better ways to identify energy savings, rather 

than just with a pure efficiency number, or a fan efficiency 

application point efficiency type situation. And so, 

there's a calling to -- 

 UNIDENTIFIED PERSON: That should be up there. 

 MR. BURDICK: Yeah, I think I see it. And so, I 

have a colleague here on the line too, Paul Lin. And I 

don't know if you'll be able to open the mic for him for 

that type of thing in case he wants to interject something 

here that I miss or don't state properly. 

 So this graph was presented in the CTI Position 

Paper that's posted on the DOE Website. It's been there 

maybe since the first of January or so. And what it's 

showing is the amount of energy that is attributed to 

cooling tower fans shows kind of lower left there, one 

percent is what we're seeing, well, you know, based on this 

published data for energy consumption on building HVAC use. 

 And something that I'd like to clarify too right 

off the front, I don't have as many nice pictures as some of 
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these other folks do. I can add those on later and you can 

look at the SBXCooling.com, Baltimore Aircoil Website, the 

Gapco Website, you know, and start to see, you know, some of 

the configurations, you know, that are possible with these. 

There's really quite a wide variety that's possible there. 

But anyway, so this part or the part that's significant 

about this is that, this is not, we're not dealing with air 

that is circulating through the building. We're dealing 

with air that is solely, its sole purpose is drawing from 

the ambient and rejecting heat to the ambient. 

 It doesn't circulate through the building. Type 

of a situation. So, I wanted to make sure I clarified that. 

 So again, one percent figure is, uh, what we think 

is substantial about that. Then here, talks some more about 

some of the takeaways from the previous slide. Outdoor heat 

rejection equipment, six to seven percent of the total, fan 

energy. Outdoor heat rejection equipment includes ecocondensers, evaporative condensers, open and closed cooling 

towers. It's very important here that a very small unit 

efficiency or unit improvement can be obtained with

increments in fan efficiency. 

 The input power affects very small product energy

than talking about this last few meetings here, uh, product 

energy efficiency is much more affected by the heat

exchanger size of the design. And the pressure drop through 
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the unit. Yes? 

 MR. PERSFUL: Trinity Persful here. When you say

efficiency, are you talking about a, like BTU efficiency or 

-- 

 MR. BURDICK: Exactly. I think the next slide 

gets into that where it's, uh, uh, in actually 90.1, for 

example, uh, opening, open, uh, cooling towers have a figure 

for, uh, gallons of water cool per horsepower applied. Uh, 

and so, the GPM figure there is gallons of water cooled, 

GPM, uh, cooled. 

 MR. PERSFUL: Okay. 

 MR. BURDICK: Uh, and so basically, it turns into

a situation of, uh, kilowatts of heat rejected, BTUs of heat 

rejected, relative to the kilowatts' consent. And, uh, like 

I said there before, uh, the fan efficiency is, uh, uh, far 

from, uh, one of the leaders in being able to improve 

overall system efficiency. We're actually having energy, 

uh, savings, uh, possible. 

 And so, this talks about, uh, heat rejection 

equipment, the metric, uh, BTUs per hour, the horsepower, 

uh, minimum efficiencies are mandated in, uh, 90.1 and IECC, 

uh, you know, uh, maybe, uh, some folks think that's not, 

uh, uh, necessarily enforced everywhere, but it is something 

that's, uh, completely adopted by our industry. Uh, we, uh, 

publicize it, uh, in everyone's, uh, selection software. 
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It's, uh, identified, uh, as a parameter of interest. And, 

uh, folks can make a, make a buy decision, you know, uh, 

based on that. Uh, I've also mentioned at other times too, 

where you can maybe achieve 20, 30 percent energy savings, 

uh, by sizing, by proper sizing that the heat exchanger, uh, 

for, uh, you know, a four or five percent, uh, incremental, 

uh, product cost. Got a question from Louis? 

 MR. STARR: So, on the, uh, I'm not that familiar

with that. These particular things you're talking about 

here. 

 MR. BURDICK: Okay. 

 MR. STARR: Does, so the first one, the, the 

metric that measure the heat injection supplies that energy 

input, so if you had for let's say a really efficient motor, 

that's going to show up there. 

 MR. BURDICK: No, well it, it'll be in the system. 

Yeah, this, this, uh, this metric is about the whole system. 

 MR. STARR: Does it drive people, for instance, to 

use an ECM motor or a, uh, cooling tower? Does it drive 

people to use a VFD? 

 MR. BURDICK: Uh. 

 MR. STARR: Some measure of, of regulating your 

motor based upon outside air conditioners rearranged in 

there. 

 MR. BURDICK: In probably more like the last 10 
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years, that I've been involved with the industry, just about 

every type of one of these units that I've seen is been, uh, 

connected to a VFD, because they recognized, uh, they don't 

need the capability of the cooling tower full speed year 

around. And they can always capitalize on VFD by, uh, 

saving energy. 

 MR. STARR: So one thing for you to consider, if 

they can find a fan, that's being all of those things, a, a, 

uh, propeller, the motor, the drive -- 

 MR. BURDICK: Yeah. 

 MR. STARR: We had a metric around that, if, what

you would sell more of. Your BFD and better motors, so I 

mean, in other words -- 

 MR. BURDICK: Still you can, you know, even on 

motors, uh, you know, you can have a NEMA premium and, uh, 

uh, you know, uh, the next better grade or next lower grade. 

Uh, that's not going to mean dollars per year, you know, 

that somebody's going to take advantage of this, because it 

doesn't run at that main type horsepower, very, a very high 

percentage of the year. 

 MR. STARR: But it -- 

 MR. BURDICK: Pretty low service factor, a duty 

factor on, on -- 

 MR. STARR: VFD mighty woes. 

 MR. BURDICK: Yeah, some -- 
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 MR. STARR: Some guys were, what's the word, 

interested in it because of this, is what I would suggest, 

so. 

 MR. BURDICK: Okay. 

 MR. STARR: It's more, like it's more of your 

products. If you think about it, you have a customer who's 

interested in paying the absolute lowest dollar for

everything he can. He won't make the best decisions about 

whether he should have bought that VFD, or whether he should 

buy the more efficient fan, and you know, so it's get a 

little tricky with regulation, but I would just encourage 

you to -- 

 MR. BURDICK: Yeah. 

 MR. STARR: There could be an upside is what I'm 

what I'm getting at. 

 MR. BOTELER: Your box is due. 

 MR. BURDICK: I, it -- 

 MR. LIN: This is Paul Lin. Do you hear me? 

 MR. BURDICK: Yes, go ahead, thanks. 

 MR. LIN: I thank you. I would just add that, uh, 

in addition to influencing the cooling tower business toward 

compliance, uh, the, uh, by customers, uh, with the, uh, 

minimum efficiency per cooling towers, 90.1 also influences 

adoption of VAV on cooling tower systems. What Larry said, 

just a few minutes ago about the very high percentage of use 
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of VFD's, uh, for cooling towers on HVACs, uh, it, it's 

really because of, of 90.1 and IETT, and the strong trend, 

uh, if not complete trend by the, our tech engineers that do 

these buildings and leaving contractors to use 90.1 as a 

standard of care for system design. 

 MR. MCNEILL: This is Donald McNeill. You might 

think about that whole industrial market. It doesn't have 

to comply with 90.1. It's about how it might affect the 

sales. 

 MR. STARR: Right. 

 MR. LIN: On that side, the industrial market is 

different from HVAC, because the, the applications tend to 

have multiple fans and it's very difficult to justify VFD 

when you have 10 steps of fan control with, with multiple 

cells. You know, industrial cooling towers are much bigger 

than HVAC in general. And things are accomplished by using 

two-speed fans in step-wide control with multiple cells. 

So, uh, VFD is not cost effective. 

 MR. BURDICK: Now, and -- 

 MR. FERNSTROM: And so, so this is Gary for the 

California IOUs. There's a lot of industrial refrigeration 

that falls into the agriculture and food processing markets, 

which isn't, is a large industrial scale that you mentioned. 

And in those markets Beta Culture, for example, there's a 

really good opportunity for VFDs, because we're back down 
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into the commercial refrigeration size equipment again. And 

they don't -- 

 MR. LIN: I'd agree with that. 

 MR. HALL: Solomon Hall speaking. I have a 

question about the definition of horsepower in this case. 

If you cut out the horsepower, does it mean you all must use 

as a general purpose motor that is regulated and that you 

use 100 percent, or are you using a service factor and maybe 

auto motors or a special duty motors? 

 MR. BURDICK: In this case, horsepower, you know,

could be translated into kilowatts power or that type of 

thing instead. Horsepower is just a term that's used here, 

but, uh, it's the, it's the, uh, connected horsepower of the 

motor, because it's nameplate. 

 MR. MORRISON: Frank Morrison, Baltimore Aircoil 

Company. By definition, it's the nameplate, motor nameplate 

in that equipment. 

 MR. HAUER: What was the horsepower output 

(indiscernible). 

 MR. MORRISON: Nameplate. 

 MR. BURDICK: Nameplate. 

 MR. SMILEY: The motor, motor, this Bill Smiley, 

the motor output at design point of motor, that's the 

nameplate. 

 MR. HAUER: But what prevents people from using 
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service factor? You can use, if it looked in NEMA, MG-1, in 

many motors you can use the 1.5. So you can declare 

 MR. BURDICK: Again, VFD, VFD usually takes care 

of that, but it's connected to a VFD. In fact, they're 

always programmed to not allow, uh, uh, consumed kilowatts 

to go above the nameplates, you know. They're limited on an 

(indiscernible) volt to, uh, uh, prohibit that. Uh, it is 

necessary sometimes, uh, actually we still install 115 

service factor motors for situations when you're in very 

cold climates and you run it year round. But typically 

you're able to modulate that with additional number of cells 

or maybe sometimes you have, uh, half speed or so on. 

 MR. HAUER: So that's just, just a good practice,

but it's not standardized. Does it meet that standard? 

 MR. STARR: I mean, this is Louis, and I was just

thinking what would I mean, I'm sure you guys don't sell it 

out though, but keeps someone else from doing that. I mean 

best practices are good, but people could sell less

horsepower and get the job as opposed to, you know, selling, 

you know, get with the program. 

 MR. BURDICK: Well, it, it, it, it's evaluated on

every job. You know, on the industrial jobs even. It's 

often evaluated, you know. What does the client, you know, 

uh, uh, what does the EPC value most? Does he value most 

what was possible cost that he can turn over to the utility, 
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you know, three months from now. Or does he value, you 

know, uh, what it's going to mean to the owner, uh, in the 

long term. 

 MR. MORRISON: The first one. 

 MR. BURDICK: Yeah. 

 MR. HAUER: That leads me to the question. Is it

then always, uh, the general purpose motor that's regulated 

by NEMA or, uh, other motors used in the cooling tower? 

 MR. BURDICK: It's, it's, uh, it's, it's a NEMA 

compliant motor. It's always a NEMA compliant motor. Could 

be premium, could be whichever, whatever grades are

available and that are legal. 

 MS. ARMSTRONG: Is it always DOE regulated? 

They're not, right? 

 MR. BOTELER: They will be June 1st of next year.

 MR. DELANEY: But they could be a, it could be, 

could be advanced technologies too. 

 MR. BURDICK: Right, yeah. 

 MS. ARMSTRONG: We have, we have a combination of

motors that -- 

 MR. DELANEY: Variable speed. 

 MS. ARMSTRONG: -- maybe will be regulated by DOE

in the next year. We'll, standards all accounted, or more 

advanced technology motors, variable speed, (indiscernible), 

et cetera, et cetera, are not regulated by DOE right now. 
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 MR. BOTELER: Or above 500 horsepower. 

 MS. ARMSTRONG: Right, or about 500 horsepower, 

which are not regulated at all. Does that help? 

 MR. HAUER: So basically it proves that the metric 

is not really solid with regard to horsepower. 

 MR. BURDICK: All right, so moving on to the 

bottom part of the, the page here. Uh, example of product 

performance included in, uh, including the 90.1 operating 

point is covered and published by CTI certification, uh, 

through open and close cooling towers, evaporative 

condensers and, uh, programs in, in progress. Or actually, 

I guess the evaporative condenser programs in progress, open 

and closed cooling towers are already in place. And it's 

verifiable, uh, via public, uh, CTI Website as to which 

models, uh, are, uh, certified. 

 And then, uh, issues with fan efficiency focus. 

Uh, I think we've talked about this. A lot of the same 

comments that you've heard before with embedded fans is 

what's important is what the system does to, is what, uh, 

the entire, uh, system responds to, uh, with the fan 

application. And one of the issues with our industry is 

there's relatively low volume of sales. You know we're not 

making 100,000 fans a year or putting out huge numbers of 

products here. 

 The implications of certification for every fan, 
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that has a big number of fans that we make for ourselves. 

You don't go to Grainger and buy these. They have to be 

resilient to the ambient effects when you have a 36 foot 

diameter fan. And it's on your product. You kind of have 

to take ownership of the structural reliability of that 

thing spinning around at 120 miles an hour on the tip, that 

it's not going to fall off, hurt somebody, kill people, 

cause other extraneous damage. 

 There are lots of implications about, you know, 

being able to withstand tornadoes passing by, storms passing 

by, other things that, you know are important for the people 

that are buying them and using them that they have to meet 

these criteria. So they are quite unique. Not something 

you can buy just anywhere. Wide variety of models and fan 

types on the market, there are other situations where there 

are low noise requirements. Those take a special type of 

air flow that have kind of a different efficiency profile 

than what a maximum efficiency capability type can be. You 

know, where it's wide forward swept blades. You end up with 

big tip clearances. You end up with, with other 

inefficiencies in the system in order to be able to run it 

really slow. 

 The talk about the application there a bit with 

the large tip clearance safety being able to withstand the 

sphere of duty that it's in. This might be a geothermal 
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power plant where the circulating water is highly corrosive, 

needs to be a high degree of stainless steel, high degree 

of, uh, corrosion resistant materials. Fiberglass parts, 

uh, you know, since some of these, uh, big fan blades on a 

32-foot, uh, fan that we make. It's got about a, uh, 14-

foot long blade, that's a hollow fiberglass structure, 

specifically designed for, for this application so that, uh, 

water impingement drops, you know, don't bother it. It's 

able to withstand the sunlight, the U.V., the storms and so 

on. 

 So, you know, quite specialized equipment, very 

expensive to release new product into the market or change a 

characteristic about it. 

 MR. LIN: Larry -- 

 MR. BURDICK: Yeah. 

 MR. LIN: There's a slide that was skipped. 

 MR. BURDICK: Sorry, this one? 

 MR. LIN: Yes. 

 MR. BURDICK: Oh, okay. Sorry about that. 

Imposed changes to fan efficiency would, and redesigned 

with, uh, smaller heat exchangers to manage cost and, uh, 

higher actual energy usage. So there's a discussion about 

that, uh, probably in that table, uh, there toward the back. 

Uh, there is some too. Uh, the, the, uh, again, this leads 

to the system approach. It's not always best just to have 
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the biggest fan in and, uh, uh, sometimes, uh, uh, you need 

to do, uh, you know, a complete system evaluation where, uh, 

sometimes the smaller fan is better, but, you know, as 

opposed to maybe some of the traditional thought that the 

larger fan is always better and the larger fan is always 

more efficient. Uh, it depends on how the air is entering 

the, the, uh, fan opening and whether or not you're able to 

fill out the blade tips, uh, or get, uh, optimum air flow, 

uh, through the unit. 

 Uh, so heat rejection equipment amounts to only 

five, five to 10 percent of the total, uh, energy in a 

typical system, you know, relative to the chiller or the 

pump in an HVAC system. The, uh, fan requirement or the fan 

energy requirement for the, uh, cooling equipment, uh, 

fraction, you know, low fraction of, uh, what that, uh, 

power consumption can be. And then actual energy 

consumption is well below, uh, design on annual basis. 

Again, here, we're talking about it's not always a 80 

(indiscernible) of outdoors where the atmospheric heat 

exchanger equipment is designed to be able to take, is 

capable of doing that. You know, you don't want to leave a, 

a hospital, uh, in a bad situation, uh, on a hot day, uh, 

because your cooling tower isn't big enough. It has to be 

big enough from day one, so that it can always hit the peak 

days, always meets the cooling demand for peak days. But, 
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uh, at other times, well they're able to capitalize on 

turning off other cells or going with a VFD arrangement. 

And, uh, so that's the, uh, bottom point there. It talks 

about the VFD. 

 Okay, then, Paul this is something that you put 

together for, uh, the, uh, uh, consideration of a, uh, a met 

or different scenarios with a highly efficient smaller 

diameter fan relative to base size, uh, and so on. I don't 

know if you want to talk about any of that. And then the 

other thing that I prefaced that with, is that, uh, this 

group wasn't involved with, you know, the original, uh, uh, 

AMCA, uh, brainstorm or, uh, the other, you know, the other 

committee work that was done on this. Uh, we tend to use 

total efficiency in our industry, uh, for an evaluation. I 

would like to keep in mind that the exit velocity out the 

fan is important to us, so that we don't recirculate the 

heat that we rejected from the heat exchanger. Uh, but, uh, 

I think, uh, others here, Wade's mentioned, uh, uh, concern 

about this, uh, uh, when you look at it from the static 

efficiency point or the static efficiency prospective. 

 Paul, anything else there? 

 MR. LIN: Uh, not from me. Frank Morrison might 

have some comments. 

 MR. MORRISON: Yeah, I just encourage folks to go

look at the, example on the, that's posted on the DOE 
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Website. But basically, it shows where an unintended 

consequence of actually meeting the, uh, higher efficiency 

with the fan actually lowers the performance of the cooling 

tower. It requires more fan energy to do it, but we comply 

with that, you know. Comply with one requirement that 

actually hurts you in another. So it, it gets very

complicated, because these cooling towers range from about 

as big as the podium that Larry's standing at all the way up 

to four or five times the size of this room, 36 -- 

 MR. BURDICK: That could be the plain area of this 

building. 

 MR. MORRISON: Yeah, you know, and, and you have a 

36-foot diameter fan, so it's a real challenge for an 

industry our size to handle it. So we're not as, as, uh, 

complicated as, as a carrier with six trillion when I think 

we only have a few billion possible combinations of, you 

know, accessories, low sound fans, unit size, and tubercle 

axial. 

 MR. BOTELER: You need a basic model. 

 MR. BURDICK: Yeah, yeah. 

 MR. MORRISON: But it is a challenge, especially 

for an industry of our size. So that's why, you know, this 

is, we want to make the sure the group is informed of, you 

know, the challenges that we, we face and, uh, take that 

into consideration. 
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 MR. BURDICK: All right, Wade has his hand up. 

 MR. LIN: The other, the other point that's, 

that's significant here is that, the discussions that have, 

have taken place, uh, in the, uh, working group meeting here 

pretty much been around commercial and, and what we call 

light industrial type applications. Uh, the way the rule is 

actually written and the way this definition is set up, it 

would also apply to the fans that we use on, uh, power plant 

size cooling towers, which could be a thousand foot long and 

have 30 plus fan cell on each at over 200 horsepower. There 

aren't very many of those around the country, but the thing 

that's important to keep in mind, is that each and every one 

of those field direct cooling towers is custom designed. 

They're not standardized products. So there is no way to 

pretest what would be in the tower, uh, for, for field 

directive service. They're custom designed for like a big 

building. It gets designed for each individual application. 

Um, and the fan gets specifically applied to the customerspecified demo performance duty. 

 There's an optimization process that we go through 

to, to match up the right size heat exchanger and fan, uh, 

to give the customer the most economic combination of, and 

those customers do evaluate fan power for the most part. 

Um, so, um, with all that in mind, I think it's really 

important that we're very, very careful with how the scope 
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is written and the definition, uh, because this could 

accidentally include a lot of products, um, not just cooling 

towers, but also air cool condensers, air cool speed 

condensers, um, for power plants which use big fans. Uh, 

uh, air cool heat exchangers that are used in, uh industrial 

processes, these are thin tube heat exchangers that do 

everything from condense propane to, um, you know, all sorts 

of applications in refineries and petrochemical plants and 

all that 

 Those products all too, also would fall under 

this, um, in this bucket. And they are, they, again, are, 

um, custom designed for each and every application. 

 MR. BURDICK: Okay, so Wade has his hand up. 

 MR. SMITH: Uh, I have a couple of comments and a

question. The first comment is that the efficiency column 

on this chart speaks to fan total efficiency and, uh, 

unintended consequence of driving fan total efficiency up, 

in this case, is an increase in fan housed. And I, I, I 

point this out only because this demonstrates why, um, this 

type of fan we rejected the use of total efficiency. If 

this chart were redone in the column where static 

efficiency, you would find that the static efficiency rating 

of each of these fans would follow the horsepower, so that's 

the first thing is, if you use static efficiency, the 

statement that you use a more efficient fan that consume 
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more horsepower is no longer true. 

 Um, the second thing is to say that, um, AMCA 

members who make fans, um, make fans for, uh, all 

applications industrial and commercial, and many of those 

applications are custom. And, you know, part of the debate 

inside AMCA was, where do we want to cut this off? And our 

answer, which we proposed, is to cut it off at 200 

horsepower. And I presume that that would eliminate, if 

that went into effect that would eliminate a lot of cooling, 

large, very large cooling fans that were, were described. 

 Um, so those are the two comments. The question 

that I have is whether or not the metric that was proposed 

would have any impact on your business. Do, do, do you test 

any of your fans against that metric to determine whether 

any were noncompliant? 

 MR. BURDICK: I've evaluated some of, uh, uh, 

them, uh, the axial fans. I, I, I'm thinking that the axial 

fans are fairly okay with, if I'm using a 58 number, I don't 

know what number we're using, it hasn't been publicized, you 

know, what the targets are or what all of the criteria is. 

No, sir, I, I, I can't state that. 

 MR. SMITH: But at a 58, you didn't have a 

problem? 

 MR. BURDICK: Uh, there are some points with 

blowers, uh, that don't meet that. Uh, you know, and, and 
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actually, uh, EU327 has different figures for forward-curve 

versus axial. Uh -- 

 MR. SMITH: And so, and so, and so -- 

 MR. BURDICK: Oh, and I'm not aware of that. I 

don't know what those numbers are. 

 MR. SMITH: Well, there's two numbers proposed. 

One for ducted and one for non-ducted. 

 MR. BURDICK: And blowers and axial are different? 

 MR. SMITH: Uh, well, uh, yeah, if they don't have 

a duct. 

 MR. SMILEY: No, it's just ducted. 

 MR. BURDICK: It's just ducted and non-ducted. 

 MR. SMITH: Ducted and non-ducted, but if all the

propeller fans -- 

 MR. BURDICK: Okay, um, on some of the -- 

 MR. SMITH: If all the propeller fans, all 

propeller fans -- 

 MR. BURDICK: Well -- 

 MR. SMITH: -- are non-ducted and have a different

metric based on static efficiency, then housed centrifugal 

fans which have a different requirement and metric based on 

total efficiency. 

 MR. WHITWELL: Unless they're unducted. 

 MR. SMITH: No. 

 MR. SMITH: No, no. All housed centrifugal fans,
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the proposal is, to treat them as though they were ducted. 

 MR. WHITWELL: I, I thought, though, sorry Bob 

Whitwell from Carrier. Sorry for interrupting the 

discussion, but I thought at the last meeting there was a 

discussion about different classes for forward, forward 

curved centrifugal, or centrifugal fans, whether they're 

ducted or non-ducted. That was a, that was a recent 

proposal and I thought it was, there were definitions, were 

-- 

 MR. SMITH: Well now the problem, well we can talk 

about definitions, but the problem is that when you make a 

fan, you don't know whether it is, could be ducted or not. 

 MR. WHITWELL: Okay, but when I make a fan I know

whether it's ducted or non-ducted, right, based on the 

discussion. 

 MS. ARMSTRONG: But whether, but I think we're 

trying to move to this testable configuration idea. It 

might be -- 

 MR. WHITWELL: Yeah, so I'm sorry for, I'm sorry 

for, uh, hurting the discussion. 

 MR. SMITH: Well, uh -- 

 MR. WHITWELL: But I just to -- 

 MS. ARMSTRONG: How does it work and vary on a 

high level, before you get into details before Wade does. 

 MR. SMITH: Yeah, the proposal, the proposal is 
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that all housed centrifugal fans are -- 

 MS. ARMSTRONG: Go where you go. 

 MR. SMITH: -- based on a standalone version, I 

mean total efficiency. 

 MR. SMILEY: And that's, Bill Smiley of Trane, and 

when we say, oh, okay for standalone fans, that's okay. 

 MR. SMITH: Okay. 

 MR. SMILEY: But for our applications, centrifugal 

fans can be, housed centrifugal fans can be applied nonduct. 

 MR. WHITWELL: And in most cases, for this, I'll 

say, most cases are. 

 MR. SMITH: Now, I would just encourage to 

evaluate the proposal and then propose changes if you don't 

like the results. 

 MR. SMILEY: We are and that's what we're talking

about. 

 MS. ARMSTRONG: No, I, I think it's just like any

other rating is what you're saying, Bob. I mean what we are 

proposing as first, for a given equipment cost, we are going 

to, or a given category of fans, we are going to tell you 

how it should be tested and rated. 

 MR. WHITWELL: Okay. 

 MS. ARMSTRONG: And that wouldn't include, um, you 

know, necessarily a look. At least what we discussed to 
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date, wouldn't include a declaration by the manufacturer 

about whether it's intended for it to be installed with a 

duct or not. We would normalize that across as part of the 

test procedure. That makes sense? 

 MR. WHITWELL: Well, I guess, I'm, I'm, I'm not 

sure it does, Ashley, but I guess one of the issues that I, 

that keeps coming up is that there's some discussion about, 

that it sounds like things are already determined. 

 MR. SMITH: No, it's just there's a proposal. 

 MR. WHITWELL: And, and then, again, things are 

still moving, so I, I just get real confused about what's, 

what's been agreed to and what isn't. 

 MR. SMITH: Okay, so this is, this is a coolant in 

presentation now, and I suggested. 

 MR. WHITWELL: Yeah, I, I know, I'm sorry for 

diverting you. 

 MR. SMITH: And I, and I suggested that you. The

question -- 

 MR. LIN: Excuse me, Wade -- 

 MR. SMITH: No, no, no -- 

 MR. LIN: This is Paul Lin, for -- 

 MR. SMITH: I asked -- 

 MR. LIN: There's just one more key point about 

the, uh, cooling tower presentation. We apologize that we 

didn't put any pictures of what they look like in this 
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presentation, but, um, but one thing to keep in mind is 

that, uh, the product in the housing, uh, and with this 

product the, there is never a fan in a testable condition in 

its life, uh, from the manufacturer of the impeller to the 

installation of the impeller in the unit, uh, to the sell to 

the customer, it is never in what you would call a testable 

condition. 

 MR. DIKEMAN: The whole time? 

 MR. LIN: So that, that's something that's going 

to have to be dealt with here. It's not a panel fan. 

 UNIDENTIFIED MALE: He's right. 

 MR. MORRISON: This is Frank Morrison with 

Baltimore Aircoil. Just to understand the cooling 

technology is to, also represent air cooled and water cooled 

equipment, and pneumatic equipment. So, you know, what, a 

lot of our comments, they get complicated when you're 

dealing with, uh, evaporative equipment, because you have to 

deal with the water aspects of it, but a lot of our comments 

also apply to the air cool side of it when I mention air 

cool steam condensers and, and things like that. 

 MR. SMITH: So, so my question to you was, whether 

or not you evaluated the metrics in our proposal? And do, 

do you, um -- 

 MR. BURDICK: I think there're some blowers that 

are, that are going to be an issue. 
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 MR. SMITH: I would give you encouragement to do 

that and to base it on what's proposed, which is different 

for centrifugal fans than it is for axials, that's all. 

 MR. BURDICK: Okay. 

 MS. ARMSTRONG: Um, so, in addition to that, I 

would say, you know, if I go back through your slides and, 

um, I just want to say thank you, because I think some of 

the information that we were seeking help in form our 

decision, like shipment. It's like usage number is actually 

in your presentation has been on the record. You submitted 

that before, um, to help us come up with, you know,

potentially the, what we've been asking for, a variety. 

 One thing I think I was going to ask of you is 

that, um, of the fans that we're talking about, um, in heat 

rejection equipment at least the subset of fans we're 

talking about are subject to your presentation, um, how 

would you differentiate them, similar thing here, um, from 

other fans on the markets? That's the last piece, because 

what you, when you ask for an extension and you provide the 

qualifying data in terms of, you know, at least I would 

think that would be helpful for the advocacy community to 

determine impact on, if we were to, then it comes down to 

differentiation. How can we tell your fans apart from the 

broader population of fans? And that's a piece I think that 

it's still outstanding in my mind and that might be because 
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of my lack of expertise in the fan industry as a whole, but 

I think we would welcome that discussion. 

 MR. BURDICK: Right, and, and, and maybe that's a

bit about labeling. Uh, maybe, maybe that's, uh, one of the 

methods is that -- 

 MS. ARMSTRONG: That's a hard sell for DOE. I'll

just tell you that right now. 

 MR. BURDICK: Okay. 

 MS. ARMSTRONG: We're looking for discrete design

characteristics, you know. What types of fans, what are the 

discrete design characteristics? If I walked into your 

facility as compared to Sam's facility, and his are not for 

those applications, but yours are, how do I tell the 

difference? Are they identical or not. Um, you know, 

labeling is a good tool to help. It is not a necessarily a 

differential, a third-party differential factor. Um, that's 

not to say DOE is not open to a label, but I think what we 

try to do when we draw lines between things, especially if 

we draw line between things that are subject to standards 

and those that are not, it is design characteristics. It is 

not a self-declaration. It is not the presence or not 

presence of the label. Um, we are really look, seeking 

design information for you to see, anyone for that matter, 

to be able to draw a line between that for which may be 

subject to standards and that for which may not be. Um, so 
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think about that. 

 MR. BURDICK: Okay. 

 MS. ARMSTRONG: I do acknowledge that you did give 

us a lot of helpful information as well. Thank you. 

 MR. BURDICK: Right. 

 MR. FLY: Ashley, just, just a question and I 

won't try to distract us too much, but you said you don't 

want to do labeling, oh, well, let's -- 

 MS. ARMSTRONG: Exclusively, let's put it that 

way, right, and how that we don't, um, and it's not that we 

won't consider that. And if you guys come back with your 

proposal, I see where this is going, so I'll just go ahead, 

address that right out the gate. 

 MR. FLY: Well, well I don't want you to. Let, 

let me finish, then maybe you'd get it. So you're standing 

on the beach looking at the whales and you see fans come up 

on the dock, right. Um, how do you know what that fan is? 

Are you just looking at it's physical characteristics? 

 MS. ARMSTRONG: Well, it's really easy. All fans

are in, right. 

 MR. FLY: I mean is there -- 

 MS. ARMSTRONG: You're asking me to divide that, so 

I have a lot easier position from DOE's side of things, that 

everything's in. 

 MR. FLY: But does it have to have a model number
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on it? Does it has to have some kind of label that says 

what it is? 

 MS. ARMSTRONG: It depends, right? 

 MR. FLY: Are you going to go up with your ruler 

and say, uh, I see this is coming from so and so and it 

looks like it's about this wide and -- 

 MS. ARMSTRONG: Generally speaking, we like 

definitions to be very clear and unambiguous so it's very 

easy to tell which models fall into our scope of standards, 

right. For commercial equipment, we do have the authority 

to issue or consider labeling rules where for 

(indiscernible), the only one we have so far is for motors. 

They really like it. Um, we have declined to do it for 

other places, um, for a variety of reasons. It, it is a 

tool. It is a tool that help for compliance and 

enforcement, but like the motor's guy would tell you, that's 

not how we differentiate if something is subject to

standards or not. 

 The presence or absence of a label is not part of

the definition that says I'm in. I'm not in. It is the 

characteristics of, um, the motor itself. 

 MR. PERSFUL: This is Trinity from Twin City Fan. 

Maybe another way to ask it is, how do we, how do we keep 

my, my buddy, Nick here, how do you, when we compete in the 

marketplace, what's keeping him from saying, oh, no, this is 
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a cooling tower fan? I'm outside. Like or what's keeping 

me from labeling every one of my fans that I make a cooling 

tower fan? And so however that's defined, if you could say, 

you know, cooling tower fans have this special 

characteristic, whatever it is. 

 MR. BURDICK: Yeah, we rely a lot on, on labeling

in, in CTI, uh, actually. There are, uh, stickers,

certification stickers, uh, that we place on the products, 

you know, to advise, you know, whoever might be walking by 

or that type of thing, that it has a sticker. But it's also 

posted on public Website and if that model number is not on 

the public Website, uh, it's fallacy or, or, uh, it's 

inaccurate, uh. 

 Frank Morrison, Baltimore Aircoil. I think to 

your point, you know, one of the things the cooling towers 

is to do, is deal with basically 100 percent humidity air 

along with some droplets of, of this drip that fell off the 

fill pack or, uh, it's a back condenser or closed circuit, 

off the coil, that the fan has to deal with. And Larry 

talked about the blades have to be protected from erosion 

and things like that. So, so I think there's things that we 

could work on to, to make those definitions, uh, clear to 

everybody and run it by the group. 

 MR. BURDICK: Okay. 

 MR. FLY: Uh, I'll tell you where I was going, 
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was, you know, their cooling towers, my package equipment 

all have a label on them, because they bear the safety 

label, because if we're required to put some kind of label 

that have a model number and certain safety information, 

because under the rules of, of, uh, UL ETL listings -- 

 MR. BURDICK: Uh-huh. 

 MR. FLY: -- you have to do that. I buy a lot of

fans and some of them come in. If, if they don't, if 

they're not an assembled product, I guess I'm asking, do 

those all have a label on them? The stuff, I generally buy 

fan components and none of them have a label on it.

 MS. ARMSTRONG: Right. 

 MR. FLY: So I don't know how you recognize, I 

mean, I may be buying a 21, 20-blade fan, and a 21-blade, 

and are you able to count the blades and figure out which 

model it was and whether that one's actually listed or not. 

They'll take a drawing I think, you know. I don't know how 

we avoid labeling on something. 

 MS. ARMSTRONG: Right. And, and I'm not saying 

that we necessarily avoid labeling. The labeling may be a 

good tool for a variety of, of topics, not only for

compliance-related, but something that, what Tom mentioned, 

for utility and rebate-type purpose for market 

differentiation purposes. 

 MR. FLY: Right. 
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 MS. ARMSTRONG: And perhaps that carrot that he 

was speaking of, that's another tool in that toolbox. I 

mean, labeling we will leave the plan on the table to talk 

about within this group. I'm just saying, it's also not the 

end all, be all. That's not how we, um, I would, that's not 

typically how we write regs to differentiate, um, standards 

applicability. That's, uh, in -- 

 MR. SMILEY: (Indiscernible). 

 MS. ARMSTRONG: So I mean, that's just my ask -- 

 MR. SMILEY: Yeah. 

 MS. ARMSTRONG: -- if, if you don't go back and 

think about that, um, I you, you know, you gave us some 

helpful information. 

 MR. SMILEY: Understood. 

 MS. ARMSTRONG: Potentially inform our decisions 

and I think that's an ask of, of you. 

 MR. SMILEY: This is Bill Smiley of Trane. I have 

a question, ma'am. In other regulated things, whatever they 

may be, how do you distinguish both? 

 MS. ARMSTRONG: Mostly by characteristics. 

 MR. SMILEY: Well, uh, give me an example. I 

don't understand, because they, it, it's blue or green. 

 MR. SMITH: About an air over motor? 

 MS. ARMSTRONG: That is like the worst example. 

 MR. JASINSKI: It doesn't have a fan. 
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 UNIDENTIFIED MALE: It doesn't have a fan cover. 

 MR. JASINSKI: Or furnace. 

 MS. ARMSTRONG: Yeah. 

 MR. JASINSKI: If, if it's a fan in a furnace that 

has a condenser in it, you can identify a secondary heat 

exchanger, so you know that one is subject to the standard 

for the condenser, not, you know, the, the, uh, nonweatherized condenser on a stand rule, standard -- 

 MS. ARMSTRONG: I mean -- 

 MR. JASINSKI: - as opposed to if there is no 

secondary heat exchanger, you know that the fan and that 

non-condensing furnace is subject to the non-condensing 

furnace fan standard. 

 MS. ARMSTRONG: Yeah, I mean for clothes washers,

it is something as simple as, um -- 

 MR. SMILEY: Where the door is or what? 

 MS. ARMSTRONG: Where the door is, is it 

differentiating feature for, for discriminating a standard, 

but for discriminating applicability with our models and its 

size, so certain top loading up to a certain cubic size is 

in, so that's when it gets back to the point of, um, that 

Wade was making earlier, you know, one of, one of the 

pillars, I guess, of the, and for discussion to date for the 

Committee to then think about, the working group to think 

about, is the one to two, four hundred horsepower. And 
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that's pretty easy to figure out. One to two hundred 

horsepower. I mean, it could be a little more, it could be 

a little less. Whatever we decide to go with it, that's up 

for discussion. But that's a discrete characteristic that 

doesn't require a label, that, you know, that's one -- 

 MR. SMILEY: Well, only if there's a motor 

incentive. I mean that's a, that's a counter-example. We'll 

get to that. 

 MS. ARMSTRONG: But you see what I'm saying, I 

mean that's where we're, we're going for a discrete

characterization, so that you can do it the same as Sam, as 

myself. Um, if somebody else wants to come look at it that 

they can figure it out. And, and it, a label can be an 

important tool in that, in helping that, um. 

 MR. SMILEY: I'm just having a hard time trying to 

picture what it could be. 

 MS. ARMSTRONG: Exactly why we're here. 

 MR. SMILEY: And I think, well the first thing 

that comes to mind, of course, is a label, because 

everything you buy has labels on it that define something 

about it. 

 MR. LIN: This is Paul Lin of NEMA. So we've, 

we've had a lot of discussion the past few days and actually 

passed, uh, passed meetings and so forth, and a lot about 

exemptions. We haven't even allowed the process to work 
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out, even to talk about what is included in this, in this 

general work, working group. So we're asking for exemptions 

to things that we don't even know what's included. So let's 

let the process work out and then if you need an exemption 

within that, that, that definition, let's put it in there. 

So if it's a 200 horsepower limit to, to the fan, then let's 

put that in there. We just haven't, I mean, we're, we're 

sitting here arguing about things that we don't even have 

the time to find a definition for. We're just wasting time. 

Let's let the process work it out. 

 MS. ARMSTRONG: With that, do you want, do you 

want to switch the stage? 

 MR. LIN: Let's do it. 

 MS. ARMSTRONG: Sure. 

 MS. ARMSTRONG: Um, so we're going to move off of

scope discussions. I think there's a variety of people in 

the group that have some homework. We'll send out a new 

homework sheet, um, at the end of tomorrow. Um, with that 

being said, we're going to a little bit about motors. One 

of the things we talked about at the last meeting, um, had 

to deal with nominal efficiencies and full load efficiencies 

and nominal values. And if I don't test everything in the 

wired air configuration, um, how will I then get my full 

system efficiency based on nominal buckets. And if I do it 

that way for rating purposes and DOE were to test wire to 
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air and they get a different value, kind of what happen, so 

I don't think Dan's going to address the what happens part, 

but he's going to shed some light on the, uh, motor kind of 

nominal of system approach and, and maybe help all of us 

better understand where the motor regs are based on and then 

if it, how that may translate to this nominal calculation 

approach that I think would be really helpful to you guys, 

so that you don't have to test every configuration. 

 So Alex, can you switch us up. It's the 

presentation that -- 

 UNIDENTIFIED MALE: Yeah, that starts with NEMA. 

 MR. DELANEY: So I'm Dan Delaney, Regal. I'm 

representing NEMA. I'm one of the Section Committee 

Chairmen, okay. 

 So we put together a list of topics here. Uh, 

these are topics apparently we missed, um, an opportunity, 

you ask me, were some good discussions on motors. I think a 

lot of good questions. So I think, I think we got most of 

the slides in. If not, just feel free to interrupt with 

questions again. I'm sure Rob will, as he likes to say, 

pontificate at time to time, and add some more, uh, key 

words and I'm, I'm sure I'll miss. 

 But anyway, the three topics that we thought, one

of them is the concept of a metric that combines this motor 

and control together. Um, so we'll go into that. That's an 
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involving standard. Some of you may be aware of that going 

on in IEC. NEMA membership is active, very active in that 

development, but it addresses a long time issue. We'll talk 

about what we did, um, supplying data to the pump, uh, ASRAC 

Committee, and maybe how we can do something similar like 

that too for, for the fan side here, fan blower. 

 And then lastly, a key topic we're going to talk 

about a lot, air over. The key topic has a lot of these 

points of data. Clearly, it is direct drive fan or air over 

products, so we'll talk a little bit about that. 

 So the first thing we come up to here, uh, this 

is, um, uh, an image that we've been using for some time in, 

um, the IEC. We'll we put boundaries around different 

things. Uh, this term, extended product, came about, if you 

go back, um, right to the very beginning when motors got 

regulated, uh, we were no different than anybody else at the 

table. Hey, you really should be looking at the driven 

system. They're the ones that really are more, uh,

efficient, right. Keep pushing down that way. Well we 

finally got our wish and here we all are, right. 

 So, um, so what we now are finally talking about 

is this driven equipment here on the far right hand, uh, 

side of that slide. But we've been regulated as a motor 

since '92. It was the first EPCA legislation. Really '99 

is when it fully came into compliance. We've been through 
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multiple revisions, noting June 1st, 2016 will be in our, 

our latest one. Well essentially, really cleans the slate, 

as, as Rob pointed out earlier, have a lot of issues with 

compliance. Massive amounts of issues with enforcement, so 

our goal in that last regulation is to simplify as much as 

possible. 

 Basically, you got a very short list of excluded,

if it's not on the list, it's in. It's very simple. Uh, 

but leading up to that point was very complex. Um, so when 

we did a look back, what we're trying to do here with this 

extended product approach was to develop a system. It could 

be variable speed, which more likely it typically is. But 

it combines a, a CDM, a complete drive module in this motor. 

So together they make up this power drive system. This is a 

terminology that was developed, um, by the Europeans. 

 Um, some of you might be familiar with EN 50598. 

That standard is a satellite standard. The European 

standard was developed for the pump regulation 547. And 

what that was done, is, is to develop a, a system where the 

motor and the drive, uh, can be put together. I won't go 

into details here on the bullets, but could be put together, 

uh, to give a nice little package. So there's default 

losses that can be determined, as well as it can be tested 

if you're greater than those and you want to take the 

benefit of the higher PDS system. So maybe you have a less 
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efficient pump or fan, you can take the, the benefits of the 

higher PDS system. So we'll go into detail on a few slides 

on that. 

 But it also, it's, it's a robust enough system 

that allows, that's, let's say, just a straight across the 

line start type product. So at the bottom, you see motor 

system, you know, uh, drawn around the PDS. It can also 

evaluate a straight across the line system against a PDS 

too, which is a nice option, because sometimes a straight 

across the line, uh, fixed speed system is adequate enough. 

But it takes into account the losses of that other system as 

well too. 

 So obviously, on the far right where we've been 

today, um, you know, with fans, there's a lot of metrics 

going on. We don't mess with them, because this is what's 

nice about our system. We give you a nice little package 

that you can pick up, you can use for any, any metric you 

come up with, uh, whether it's an index, whether it's a 

straight, uh, input/output method. Whether it's power, 

static, total, um, it, it allows it to be independent, 

giving you guys the data that's necessary. 

 So I talked a little bit about the history, um, 

talked about the second bullet. 

 Third bullet, now what's nice about this system, 

it's a defined set of test points. So we do an output/input 
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test method. You don't have to do that, but obviously many 

manufacturers, if we have, let's say advanced technologies, 

improved efficiencies of what you buy off the shelf it makes 

sense that we or the controller or maybe even US 

manufacturer would want to do that testing to prove greater 

efficiency. It allows those same base set test points. Um, 

and then next, you guys probably aren't going to really so 

much care about the specific test points. You're going to 

care about your performance point. 

 So it has a defined interpolation, extrapolation 

equation. One that everyone uses to get to points you're 

most interested in, right, to do your own evaluation. And 

then -- 

 MR. BOTELER: Technology neutral. 

 MR. DELANEY: Um, that is technology neutral. So

this obviously can be variable speed induction. Certainly, 

it can be PMAC motors, uh, ECM, switch reluctant, 

synchronous. Anything we can dream up in the future, um, 

it'll be in there, because it just evaluates performance at 

the set points, and then can be obviously interpolated or 

extrapolated to the key points you want. 

 And then lastly, it does have what's a big benefit 

in ADM method. The Europeans were very much against, uh, 

the concept of a math model for many years. It just, their 

concept of it was, uh, just test it if there's a question. 
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You know, we validate that it meets the levels and you just 

test it. Well they got, I started to understand this basic 

model concept when you have proof of product line, you're 

not going to test that, right. You use a math model to 

validate, like everyone in the room. If you're six trillion 

and our, I, I guess an infinite number, because there is, 

somebody's always coming out with another product, you slap 

on a motor a vibration sensor, a chaff seal, so, um, 

infinite numbers. So in the motor industry, creation of 

models happens obviously, hundreds even a day can occur. 

Um, so let's talk a little bit about a couple little details 

of these. 

 So the test points, um, on the left here, you see

the EN standard. I didn't mention this before, but the EN 

standard obviously is based in 50 hertz, who support pump 

regulation, euro pump, picked it up. They used it for the 

MEI metric, uh, that's regulated. Now they're in their 

second phase of their, um, of their index level now. But 

they have eight points. And they had, uh, um, a crane 

manufacturer, a guy who made, made cranes and he wanted 

three zero speed points, right, so, because he does constant 

torque type of applications. We don't. We're not looking 

to use that in, in the U.S., or I should say with the IEC 

version. So obviously, we've harmonized that to include 60 

hertz efficiency levels reference tables. But we've also 
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taken away those zero points, um, and given a random 

sampling. 

 Um, we have a gentleman. His name is Mark 

Dopplebuyer [sp]. He works a university in Germany, uh, but 

he used to be with, uh, a motor manufacturer and he did an 

extensive, uh, statistical evaluation between 20 points and 

all the way down to at least five points and found literally 

no difference in the end value interpolation/extrapolation. 

So, um, a lot of, a lot of information and work was put into 

validating these five points are good, are accurate and can 

be extrapolated, interpolated, uh, with good accuracy. 

 Um, as I mentioned before, obviously, both 

methods, um, allow for you then to take that with a defined 

equation, that would be provided in a, let's say, a set 

Excel spreadsheet, a locked out Excel spreadsheet. Anybody 

can take the number, put your values in, pop out those 

performance points that you care about, uh, for the

reference losses. And then obviously manufacturer can 

provide, let's say, if you wanted to test a higher PDS 

rather than the references losses that are given in a 

standard, that can also be done there as well too. 

 MR. HAUER: Hello, Dan. 

 MR. DELANEY: Yeah, sure. 

 MR. HAUER: I'm Armin Hauer. 

 MR. DELANEY: Yeah. 
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 MR. HAUER: What's in the graph there, the X-axis

and Y-axis. That is the torque or the? 

 MR. DELANEY: The speed torque. Yes, speed 

torque, yeah. 

 MR. HAUER: Not constant power or anything? 

 MR. DELANEY: That's correct, yeah. Yeah, so it's 

just, it's just points, points of operation on a speed 

torque, correct, yeah. What I wanted to mention before, 

this isn't the first time this has been developed back in, 

um, I guess somewhere around 2007, uh, '06. At CSA, we 

developed a standard that had 20 points. And the concept 

there is, let's not do interpolation/extrapolation. Let's 

just do 20 points or the closest, using next closest, um, 

and basically, if you look on the left, 20 points across the 

grid, right. For every low point, you had five points 

across. Well you had four points across, five different, 

uh, points. 

 Um, so the concept here is let's reduce the burden 

of number of tests and just use interpolation/extrapolation 

since they use a mathematical version. So basically, you 

get the same result, whether you test 20, 30 points or you 

test these five. 

 MR. HAUER: I'm bringing that up because I've got

to a seven we have that's based on constant power, so 

there'll be a X-axis or a Y-axis for the power into the 
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torque. 

 MR. DELANEY: Okay. Yeah, this has, this has been 

torque speed from beginning. This is, um, I'm trying to 

remember if this is in the 61800-9-2. So that's the, that's 

the new name of the standard. I don't think I mentioned 

that. I do here, right here. Um, but, yeah, it's always 

represented in a torque speed relationship like this, but 

obviously depending on, obviously what you see on the right 

is more of a, let's say, variable torque relationship. 

Obviously, that's a points of concern for a pump and a fan. 

And on the left there, on this, on the zero axis of, of, uh, 

speed it's a constant torque application. 

 MR. FERNSTROM: And this is Gary. For those of us 

that aren't familiar with it, what do you mean when you say 

torque speed? 

 MR. DELANEY: Yeah. 

 MR. FERNSTROM: Those are two different things. 

 MR. DELANEY: Yeah, yeah. So, so when we, as 

motor guys, we talk in relationship. I should probably just 

brought a, a typical, but I'll just use my hand here to, to 

demonstrate. 

 When we talk about the characteristic of a motor,

right, from its locked rotor, it's up here high on its zero 

speed, up here. So it's in locked, or when it first starts 

or gets in locked or a situation that's very high, it 
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usually dips. And there's a breakdown point. That's where 

you guys really care about, making sure your fan point is 

within that knee of the curve that we typically talk about, 

so that we're always operating within the performance torque 

of the characteristic and it drops off. 

 So when we talk about the characteristic of a 

motor, we're talking about how the envelope, uh, works. If 

your operating point's outside of that, you can't run it. 

 MR. FERNSTROM: So, just let me. 

 MR. DELANEY: Yeah. 

 MR. FERNSTROM: You're talking about a graph where 

on one axis, its torque, and the other is speed. 

 Uh-huh, uh-huh, right. 

 MR. DELANEY: Correct, yeah. The Y-axis torque,

sorry, yeah, X-axis speed. 

 MR. SMILEY: Here's what, here's what it fits in a 

motor curve looks like. 

 MR. FERNSTROM: Yeah, I, okay, I understand now. 

Thank you. 

 MR. DELANEY: There you go. Thank you. 

 MS. MAUER: Dan, this is Joanna. I just try and 

understand kind of where you're going with this. Do you 

have concerns with the NODA approach in terms of --

 MR. DELANEY: Yeah. 

 MS. MAUER: Are you looking for -- 
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 MR. DELANEY: That's a good question, yeah. 

 MS. MAUER: -- default values or -- 

 MR. DELANEY: So, so what, on the motor, I'm 

sorry, on the pump side it was concern that, look, they're 

going to go ahead and, they recreated this for us now, so 

whether it was, um, with PNNL, essentially used this EN50598 

as the, as the version. You see AMCA and others try to 

recreate this. It's done. What we're trying to tell you, 

it's done. We'd like you just sit there and adopt this. 

 MS. MAUER: And you say it's done, um, do you 

fault -- 

 MR. DELANEY: Here we go. We got a couple of more 

stuff, yeah, a couple of more slides, you'll see, see what 

I'm talking about here, okay. So yeah, the, the whole point 

of this is to introduce this power drive system, this motor 

and control. They don't really want, um, the fan groups or 

anyone else to start redeveloping something that's already 

done for you, define losses. Now we understand the issues 

of, of efficiency and try to use that. So what are we 

talking about in really reducing kilowatt. 

 MR. SMILEY: Dan, this Bill Smiley of Trane. 

This, this assumes a specific type of inverter or speed 

control variable frequency drive and a specific type of 

motor combination, correct? 

 MR. DELANEY: No, not really. 
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 MR. SMILEY: Or is this based on kind of an 

average of everybody in the world's inverter and everybody 

in the world's motor and you get a real wide banner of data. 

 MR. DELANEY: Yeah, let's just look at that. 

Let's just, yeah, exactly right. So that's what, that's 

what these two tables are. So the top table here, um, is, 

is just taking the, we've already defined that, right. We 

already have international efficiency levels. No reason to 

survey that. It's already defined for us. We're regulating 

that in the United States and Europe and others. So we 

already know the defined motor losses. You can pick any 

motor up today, IEC 36 hertz equal a NEMA, premium 12, 12 

tables on and on, right. 

 So we can, those are set for us, right. So that's 

not terribly difficult. Uh, down here though, drives never 

have. So drives did go together and did collect data and 

did define a minimum loss, reference loss for the drives. 

 MR. SMILEY: Okay. 

 MR. DELANEY: Yes, so that was really a, a big 

development on that side. 

 MR. PERSFUL: Trinity Persful, Twin City Fan, when 

you say, or when you talk efficiency, are you, you're 

talking minimum efficiencies or nominal efficiencies? 

 MR. DELANEY: Good, good question. We're not 

talking about efficiencies anymore. We're talking about 
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basically index levels and losses. So we're no longer 

talking about efficiencies in this metric, because what 

we're trying to do with variable speed systems, we're trying 

to reduce kilowatts, right. That's the whole goal of this 

program, is to stop talking efficiency, right, and start 

talking reduced kilowatts. So in all this is loss, so it's 

kilowatts of loss, okay. Let's back up for a second. 

 MR. PERSFUL: So is that, okay, and maybe another

way to ask the question. 

 MR. DELANEY: Yeah. 

 MR. PERSFUL: Trinity Persful, Twin City Fan. 

 MR. DELANEY: Uh-huh. 

 MR. PERSFUL: The actual loss or nominal loss. 

 MR. DELANEY: So we'll, we'll get to that. We'll

get to that, okay. So, so basically -- 

 MR. DIKEMAN: Are you talking to Ashley. 

 MR. DELANEY: You guys are trying to, uh, to, uh,

gang up here, aren't you. We're going to get, we're going 

to, we're going to, let's, let's hold off on nominal, 

because I got that in the air, air over and some of the 

other slides. Because it's, it's important. I do want you 

to understand that. It is, it is a little more complicated 

to somebody who obviously, where you don't read nominal or 

you do it the first time you assume that that's one number. 

There's test method of banding. There's a lot of things 
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that go into it, rather than just a point, right. So we'll, 

we'll get into that when we get through this, and then we'll 

come back to that. 

 MS. ARMSTRONG: Let me make a point. 

 MR. DELANEY: It is a testable configuration for 

Ashley. 

 MS. ARMSTRONG: That you get a point. 

 MR. DIKEMAN: It is a point. 

 MR. DELANEY: We'll, we'll come back to it. The 

calculation method, this is one way to look at this. So I 

found my motor manufacturer. If I'm a drive manufacturer, I 

don't make a motor. I don't make a drive. You're a fan 

guy. I can pick up the set defined loss tables and I can 

put together a system, a PDS. That's definable loss. If 

that's acceptable to you with your high efficiency fan, 

you're set and ready to go. You already got your defined 

loss tables. 

 Now if you need more. Let's say you're pushing 

the limit of that fan. You want to keep that fan market, 

you may want to go to manufacturer and decide can I get a 

more efficient PDS, right. So that's an option. So this 

system allows you to say I can use my default losses for 

motor control. I don't have to talk to a motor guy. I just 

got to know that those products are those default reflective 

losses of that product, or I can go to a drive manufacturer 
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or motor manufacturer and have them provide those points and 

get a more efficient PDS that's necessary. 

 MS. MAUER: Points that are certified to DOE? 

 MR. DELANEY: Points that are defined for a test 

standard that obviously would need to be accepted. Just 

like Sara Widder did in, in the pump rulemaking, they did 

their own definition. She has the exact same similar points 

that we have in, within this method. This is, think about 

what was done in the pump -- 

 MS. ARMSTRONG: Direct measure is not necessarily. 

It depends on what type of motor are we're talking about, 

because not all of them are -- 

 MS. MAUER: Right. 

 MR. DELANEY: Well let's just back up for a 

second. Nothing is regulated in this market, because this 

is an unregulated market. This is variable speed motor 

control product, right. So this is unregulated period. 

 MS. MAUER: So we don't need a DOE test procedure

in order to test. 

 MR. DELANEY: And we're saying when we have it, we 

want you to adopt it. That's what, that's our proposal 

here, is saying, well this is an international method that's 

being stamped by international. This is just a small, this 

is like 30 manufacturers of motors and drives here. Um, 

the, some of the largest would probably provide the list. I 
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think we've provided the draft to where it's at now. John? 

 MR. BOTELER: Let your mind, let your mind wonder

to NEMA premium PDS. 

 MR. DELANEY: It allows, let's say, regional 

acceptance of this, and let's say regional marketing of that 

program like that too, right, because there's base levels. 

It's defined standard. Now, we want to incentivize the 

premium. People over these defined minimum losses, right. 

So it gives the metric for this PDS for the first time. 

 MR. BOTELER: So if Gary had a NEMA premium PDS, 

what would he do on it? 

 MR. DELANEY: Don't answer that, Gary. 

 MR. FERNSTROM: I'd probably punt on 4th down. 

 MR. DELANEY: So, well as, as we go back and we 

look at these defined losses -- yeah, oh, sorry, Bob. 

 MR. FLY: What does PDS stand for? 

 UNIDENTIFIED MALE: Power drive system. 

 MR. FLY: Okay, thank you. 

 MR. DELANEY: Yeah, yeah, so back, just, just, I,

I know I throw these terms back at you again, inside the 

red, red circle, the motor plus that control, okay.

 MR. FLY: Got it. 

 MR. DELANEY: Okay. 

 MR. FLY: Thank you. 

 MR. FERNSTROM: So, so this is Gary. What's the 
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association of electrical and mechanical imaging equipment 

manufacturers? 

 MR. DELANEY: That's our NEMA. They're selling 

their imaging greatest. 

 MR. FERNSTROM: Imaging? 

 MR. DELANEY: Yeah, yeah, yeah. 

 MR. BOTELER: Yeah, that's us too. 

 MR. DELANEY: Yeah. 

 MR. BOTELER: You're in medical, you didn't know 

that, huh? 

 MR. FERNSTROM: No. 

 MR. DELANEY: Yeah, sometimes we found that out 

two weeks ago. We said the same thing. Hey, how did they 

get up there? We should have a motor up there. Jumped 

ahead a little bit. 

 Um, again, the biggest, probably newest thing 

that's in the standard is this defined control losses, okay. 

Very set parameters, so if when they're doing testing, then 

let's have greater. Have less losses than this motor, than 

I have a defined set of setup parameters and test 

parameters. It's essentially a glorified input/output, 

because there's no better way to do that at this point, when 

you do a system. But essentially, um, that's what is being 

used as the reference losses mean, the minimum. You can 

count on your drive being more efficient than that, that 
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product when your manufacturer says, yep, you're good. Um, 

and that is, that is what you would use as your minimum 

losses. 

 MR. SMILEY: Dan, I have a, Bill Smiley of Trane. 

I have a quick question. Is, is that the drive inefficiency 

or the losses of the drive, plus the effect that drive has 

on the motor efficiency? 

 MR. DELANEY: So they are separate. 

 MR. SMILEY: Combined or are they separate? 

 MR. DELANEY: They're separate. They are separate 

entities. 

 MR. SMILEY: Because if you have a, if you have a

-- 

 MR. DELANEY: You would only see that when you do

the PDS five point test. Then you would see the 

calibration. We're saying that the losses together it is, 

is really an individual item that can be paired together, 

yeah, yeah. There's no way to do this, we'll say, 

definable, um, uh, loss that has all the, let's say

accessory items and everything in it. So it had to be, do 

it individually as it reference losses. 

 MR. HAUER: Armin Hauer speaking. Do you go above 

60 hertz, 60 hertz speed on that induction motor? 

 MR. DELANEY: I'm sorry. Does it go above? No it 

does not. So that was one of the contentions that, so we, 
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we debated this. We wanted to include a, let's say, a 

constant horsepower, but unfortunately, we just ran, ran out 

of time, because we wanted this in 2016. We wanted a lot of 

things, right, but in order to get the standard out there to 

try to help influence all this system regulation, we really 

thought, okay, that's, we're going to immediately start 

adding things like constant horsepower above, you know, 

base, um, frequency. We were going to add, uh, an attached 

Excel spreadsheet that you'll be able to run your equations, 

defines. So you don't do your own Excel spreadsheet with 

your own equation in it, using it. You'll have one that'll 

attach to the standard, and you'll be able to use that as a 

referee method. Wade. 

 MR. SMITH: Well I, I thought I was tracking you 

until Bill asked that question. 

 MR. DELANEY: Sure. 

 MR. SMITH: I thought that this, I thought that 

you really, it was impractical for rate the performance of, 

um, variable speed drive, unless you couple it with a motor. 

And so that's what I thought this was. 

 MR. DELANEY: So -- 

 MR. SMITH: But if you separate it from the motor, 

don't you get a different performance level, depending (a) 

on which motor you attach it to, and (b) on how it's 

configured? 
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 MR. DELANEY: So the concept here -- 

 MR. SMILEY: (Indiscernible)the harder it is. 

 MR. DELANEY: So, let me, let me tell you what our 

concept here is, is defining the worst case setup that you 

have for losses, so the whole concept is the worst case 

position that that motor and drive would produce. Now is it 

perfect in every case, no. 

 MR. SMITH: So, so if I were to test them all, the 

worst one is the one that's represented. 

 MR. DELANEY: No, no. The idea is, is a worst 

case setup on a drive and a worst case setup on a motor the 

least inefficient. Not, not how you repair this worst case, 

because, you know, many manufacturers, many and if you setup 

something wrong, it's going to give you a completely 

erroneous result, yeah. 

 MR. SMITH: Okay, forget about those setups. 

 MR. DELANEY: Yeah. 

 MR. SMITH: Don't different motors have different

performance when coupled with a VFD? 

 MR. DELANEY: Yes. It, it, it definitely is the 

case. Now as one of the things that is a side project of 

this, is actually to develop a separate motor IEC standard 

that'll address the details. 

 MR. SMITH: A standard what? 

 MR. DELANEY: Uh, so this is, lives inside of the
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61800 series, the, the drive standards. 61800 is the drive. 

60034 series is the motors. 

 MR. SMITH: Tell me what you said before so I can

understand that. 

 MR. DELANEY: 61800, that's the drive standards. 

 MR. SMITH: And before that. 

 MR. SMILEY: Before you start giving us the 

standards. 

 MR. SMITH: Yeah, I'm not interested in that. 

 MR. DELANEY: No, come back, come back to your 

question here. 

 MR. SMITH: My question is, aren't different 

motors, don't they behave differently, -- 

 MR. DELANEY: Yeah. 

 MR. SMITH: - when coupled with a VFD? 

 MR. DELANEY: Yeah, so -- 

 MR. SMITH: How did you account for that? 

 MR. DELANEY: Yeah, so the only way you can do 

this, you can do this logically from a base set of losses is 

a definable set of losses. So no one really knows what that 

is specifically. That's why there's efficiency level. So 

every manufacturer is still going to have to define that 

says, I have a losses that meet that table. You're going to 

still use that definable losses, if it still validate with 

them. Does your motor meet these losses at that I2, I3 
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table. 

 MR. SMITH: The manufacturer of the motor is going 

to tell us how their motors perform to the VFD? 

 MR. DELANEY: Yep. 

 MR. SMITH: And VFD manufacturers are going to 

tell us how their VFD performs with the motors. 

 MR. DELANEY: And that's done by our calculation,

our, our, basically what we're saying, is we have an 

approved AEDM just like the Department of Energy does for 

this. The approved calculation method allows them to. Yes, 

those tests involved to calibrate it, but -- 

 MR. SMITH: So if I, if I, if I, if I take those 

two numbers. 

 MR. DELANEY: Yep. 

 MR. SMITH: And it happens to be the particular 

combination that I'm shipping out today. I can calculate 

from those two numbers the efficiency of the PDS. 

 MR. DELANEY: Yeah. 

 MR. SMITH: The full, the full motor drive system. 

I can add that to the inefficiency or efficiency of the fan 

and get a wire to air. 

 MR. DELANEY: Very good, yeah. 

 MR. SMITH: And, and, and you believe that if I 

test them, the wire to air, that I'll get the same result. 

 MR. FLY: Or better. 
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 MR. DELANEY: You should be better, that the whole 

concept of this is the worst case losses, right. That you 

can count on, that if you test the PDS with the combination 

that you purchased, it should be there or better. 

 MR. SMITH: And why should it be more better? 

 MR. DELANEY: And the whole concept is the drives

has the worst case losses and the manufacturers calculation 

method here is guaranteeing they have minimally that those 

losses are maximum those losses, I should say it that way, 

yeah. 

 That's the whole, that's the whole pretense of 

this. And it's, as, as you see from the standard, it 

started very thin. It's a very thick standard. It's a, 

it's a tough read at this point. It really needs a

simplification. It's, it reads more as equation to

equation. That's why the second revision is really going to 

take it down to a, let's say, a layman's working document 

that can be used almost as an Excel spreadsheet so you can 

run through the equation. But this first one is very 

technical. 

 MR. PERSFUL: Trinity Persful, Twin City Fan. 

The, what's the order of magnitude from say this is the 

worst case to, uh, something that we may test? Is it, are 

we talking, is it five percent, eight percent, ten percent? 

What's that? Just not pulling anything. 
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 MR. DELANEY: Yeah, um, I can't even talk in those 

terms because of the loss. I'd have to back work, you know, 

so I'd really have to give specific examples. We've done 

some test data. Um, man, I, it's tough without having, 

because you have a, you have a set of 20 points, right. And 

have a bunch test data, a bunch of drive data. We're 

comparing those. I don't know if we have a lot of, you 

know, uh, best cases. There isn't quite a few presentations 

that are out there, been done some, but -- 

 MR. PERSFUL: It's, it's, the reason I ask, if, IF 

we're to consider using this, I would want to know what that 

is, -- 

 MR. DELANEY: Yeah. 

 MR. PERSFUL: -- because if I'm also interested in 

testing and, and doing something better or more aggressive, 

I would like to know is the effort worth it at the end of 

the day. 

 MR. DELANEY: So, so what the problem that's most

interestingly about this standard, um, which is, you know, 

it has the typical IC format. You got to the base. It has 

the tolerance limit there. The tolerance is, uh, pretty, 

pretty wide in this. It's going to be, it's going to be at 

10 percent. It's at 15 percent I think below, um, 90 

kilowatt. I think the 90 is where they picked the point for 

this one and above. Uh, it's 10 percent above 90 kilowatts, 
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uh, 15 percent below. It follows the same method that the, 

uh, the motor side does. So it's a pretty, that's your, 

that's your gap that you're going to play with. That's your 

tolerance. And you can count it being in that tolerance, 

right. You're not going to count on the high end of that 

tolerance. You're going to count it in the middle or down 

at the bottom of that tolerance. 

 For a manufacturer to hold it, we're going to have 

to have a nominal minimally in the middle of that to 

guarantee that tail never leaves the bottom end of that 

tolerance. So it's probably at least, uh, seven and a half 

to 10 percent tolerance probably within those numbers. 

 MR. CATANIA: So just to follow-up on that -- Tom

Catania. So you said that the test is designed, um, to, to 

model the worst case, the worst result. 

 MR. DELANEY: So the test, the test is the worst 

case if the actual. The, the, uh, calculation method is the 

worst case, yes. 

 MR. CATANIA: So how does the calculation method,

how is it affected by the manufacturing, or did it 

manufacture tolerance? 

 MR. DELANEY: I would say it this way. Um, just 

like any AEDM method, it, and again, this is an IC test 

method, so there is, today, you know, in the beginning there 

is no third-party approval. It's, it's a manufacturer. 
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It's, it's how Europe operate, right. It's, it's your, it's 

your, it's your name on the mark, right. 

 MR. CATANIA: Sound certification, no markets 

around. 

 MR. DELANEY: Exactly. That's our standard. What 

we're saying here when we put this inside the DOE and other 

things, that's the robustness. It gets added. It gets 

added as a result of the regulation, whatever it said on top 

of that. 

 MR. CATANIA: I'm just wondering if there's a, if

the manufacturing tolerance applied at the bottom end of the 

range has a multiplier effect when you add, when you add 

equipment in. 

 MR. DELANEY: It's a good question. I'll say 

this. It's a little early for me to really give some good, 

good definitions, because what I have is, I have test data, 

uh, that I can speak to specific points. I can't talk about 

populations yet. It's still too early for me really to give 

you, say, hey, this is what. We're just still finishing the 

standard still. It's just actually, uh, it goes out for a 

vote, because it just got translation. Actually it just 

went out for a vote I think last week. Um, and that's two 

months, and then, um, September we'll come back with 

comments. And we hope to have, we can hopefully not have 

any major technical time that we have to revise the
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standard. If so, it'll go for at least by December of this 

year. 

 MR. SMITH: Is this in the public domain where we

can go find it? 

 MR. DELANEY: We can certainly, um, ask the 

convener, it's our NEMA, um, 1MGTC, uh, Chair. So I can 

certainly ask if we can post this and have it accessible to 

the, the whole ASRAC. I know we provided it to the

Department of Energy, so we just have to ask to make sure we 

could provide that to the whole ASRAC as well. 

 MR. SMILEY: Uh, Bill Smiley of Trane. It would 

be interesting to see sort of a statistical distribution of 

what the true values are to show where you're locating the 

minimum. 

 MR. DELANEY: Yeah, yeah. 

 MR. SMILEY: So, so we, you know, I mean, you may

be quite a ways from being able to get to that point. 

 MR. DELANEY: We have some, we have some charts 

that were done in development. I know, I remember it, yeah. 

 MR. SMILEY: But you could, you know, if we're 

going to pick something to use to represent a motor or a 

motor variable speed drive, I don't want to always pick the 

lowest possible that could never be any lower than that, 

because I might have to make up for that low value by 

adjusting my fan efficiency. 
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 MR. DELANEY: So, so the whole key is that you 

guys can count on that as a minimum, right. You need to use 

the minimums, right. For, for the defined references you 

got to use the minimums, right? You might if you really 

want to say, well I think that's better and you're confident 

you have the ability to test, you'll have the data, you can 

extrapolate to the key points that, let's say, are the, you 

know, we have to negotiate with those test configurable 

points are. But those are the kind of points you would 

interpolate and extrapolate at those points that are key to 

you. 

 MR. SMILEY: Well the other problem that I might 

run into is locate and I've done inverters whose sole 

purpose is to reduce tremendously the amount of energy I'm 

using blowing air around, because I can take the diversity 

of the system and the requirements of the occupied space 

when blowing lot less air. But I'm going to start out at a 

disadvantage, because the components I use to be able to do 

that and use less and less and less energy starts out at a 

lower efficiency. 

 MR. DELANEY: Yeah. 

 MR. SMILEY: So, and, and maybe it's probably not

really the right place to be talking about it, but I just 

want to bring it up, is we might need a little relief when 

talking about VAV create a variable speed system, because I 
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could have add a low efficiency fan -- 

 MR. DELANEY: Yeah. 

 MR. SMILEY: -- with just a motor and not a VFD. 

 MR. DELANEY: Right. 

 MR. SMILEY: And, you know, that meet the 

(indiscernible). 

 MR. DELANEY: And you still might, and you still 

might be able to do it. 

 MR. SMILEY: Yeah. 

 MR. SMITH: The, the idea is to give an allowance

-- 

 MR. SMILEY: Yeah. 

 MR. SMITH: -- when these things are added, so 

that you aren't penalized. 

 MR. SMILEY: Right. 

 MR. SMITH: As he just described. 

 MR. SMILEY: Right, right. 

 MR. DELANEY: The question is what, what, what 

that allowance should be. 

 MS. ARMSTRONG: Wait a minute, wait a minute. 

Explain that? 

 MR. DELANEY: You, you -- 

 MR. SMITH: It's from your charts. 

 MS. ARMSTRONG: No, explain that. 

 MR. SMITH: Okay, you got a fan shaft and the fan
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meets the requirement. The fan meets the requirement with 

default values from wire to air meets the requirement. 

 MS. ARMSTRONG: Yeah. 

 MR. SMITH: Because the default values are in the

numerator and the denominator, the fan meets the 

requirement. The calculated wire to air meets the 

requirement, right. 

 MS. ARMSTRONG: Yeah. 

 MR. SMITH: Right, okay. So the point is that in

that default values that get you wire to air -- 

 MR. DELANEY: Yeah. 

 MR. SMITH: if you have a speed control, it's in 

there, in the numerator and the denominator. It's not 

material. 

 MR. DIKEMAN: It was --. 

 MR. SMILEY: Or you're saying, you're saying the -

- 

 MR. SMITH: No, it's, it's the efficiency 

requirement is diminished by the default loss. 

 MR. SMILEY: You're adjust, you're adjusting the 

target to compensate for the additional inefficiency of the 

components. 

 MR. SMITH: Exactly, exactly. 

 MR. SMILEY: Because you don't want it discourage

the AD. 
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 MR. SMITH: Right, exactly. 

 MR. DELANEY: Well, I'd say this. I'd say this. 

I'd say this. When you look at your metric, that's what you 

want to have your metric take account for. You want duty 

cycling in there, right. You want to have that ability, if 

it's variable speed you want to be able to count that. 

You'll have the losses. You can use them now, right. That 

decision how you want her to use in your metric. 

 MR. SMITH: Well, that's something we want to talk 

about. 

 MR. DELANEY: Yeah, back in the back, yeah. You 

have a question back there? 

 MR. MATHSON: Tim Mathson, Greenheck Fan. I want

to ask a question about 360 hertz, so and you don't have 

that covered. 

 MR. DELANEY: Yeah. 

 MR. MATHSON: I'm assuming everything under 60 is

like, you got a 10 horse motor, 20 horse drive, 45 hertz and 

only three break horsepower, you can tell what the 

efficiency is. 

 MR. DELANEY: Yeah, correct. 

 MR. MATHSON: And everything under 60 is losses. 

 MR. DELANEY: Zero, yeah, the losses is of each of 

those operating points -- 

 MR. MATHSON: Below that constant torque curve, 
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everything below that can occur. 

 MR. SMILEY: What about 160 or 120 hertz? 

 MR. DELANEY: So, no, no. So nothing above base,

nothing above base, but it'll be added. It'll be, it'll 

just have to go back. You have to create it, because it 

doesn't exist in the marketplace today. There's no

efficiency level for that. 

 MR. PERSFUL: Trinity Persful, Twin City Fan. 

Would an EC motor be considered a PDS? 

 MR. DELANEY: So that's, that's one of those 

areas. Yes, so yes is the, is the quick answer. It wasn't 

designed around that, meaning we did not go to ECM, uh, type 

of manufacturers and get their losses, right, to determine 

those. So that is one area that the ECM market, um, and it, 

it varies all over the place. 

 As it goes smaller, it's gets, as it goes really 

small, it gets really difficult for some of them to get to 

those. They may have to always do the test. It'll

differentiate themselves because their control may wag 

behind reference losses. So they may have to test as a 

result. So as a control gets really small, the 

inefficiencies reasonably pretty small, and that losses are 

there. I just don't want to say across the board, yes. 

Many of them will say yes. Be above and beyond. Because 

let's say, let's say, if I give you a generic number, such 
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about 95 percent efficient. That's pretty conservative for 

most drives. So that's kind of the drive. Now when you 

take that and divide the losses by the different points, 

it's about 95 percent efficient, give or take. 

 MR. SMILEY: Bill Smiley of Trane. If I used an 

ECM motor on a product, I'd have to test the motor in there 

because we're aren't going to have a usable default number 

to use. 

 MR. DELANEY: But you won't have to do it. You go 

to your EC manufacturer and say give it to me. 

 MR. SMILEY: It's got to be done. 

 MS. MAUER: That's in the DOE test procedure, 

right? And the tested according to the DOE test procedure? 

 MR. DELANEY: Well, of, of course, that's, that’s

why we're proposing this in there, but, but even if it's, 

well something's going to have to be in there for variable 

speed, right. I mean, if we're going to have, we're not 

doing this at just fixed frequency right. We're saying 

variable speed is part of that. That's what we've been 

discussing. There has to be a test method. There has to be 

something that accounts for multiple points that will end. 

 MR. SMILEY: Well, Bill Smiley of Trane again. 

If, it got to be some encouragement to use ECM motors too, 

because they're typically more efficient than typical 

(indiscernible) motors. 
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 MR. DELANEY: Especially at the below one 

horsepower, yeah. 

 MR. SMILEY: So if we don't have some mechanism 

that, uh, shows the benefit of that, you know. It could be 

you'll have a problem with it. 

 MR. DELANEY: Keep moving along here, um, 

following the model as the, the motor side, so obviously our 

European, um, I shouldn't say European, IEC counterparts, 

uh, developed IU. IU levels based upon the NEMA levels, uh, 

creating their own 50 hertz versions off a smooth curve. 

They used their 60 hertz versions for a step curve for pull 

counts. So there're identical to 60 hertz, um, but they've 

now created an IUL for inverters, what they call converters, 

what we call inverters or VFDs, right, on the left-hand 

side. And then translating that into a power drive system, 

you'll notice there's, there's a reference underneath on the 

equation, right. So greater than one would be the greater 

than, than, um, than the base reference losses, so that's 

what you'd be after if you did a PDS test the greater than 

one factor on that. 

 So those are defined. This will, will be 

released. That is pretty new to the standard you can see. 

It only does I-2 right now, so many drives just would 

normally just probably fall into I-2. There is I-1 drives. 

I don't want to say there isn't, but I'd say they're much 
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more specialty drives. 

 MR. PERSFUL: Two quick questions: One, I'm 

thinking about. This is Trinity, Twin City Fan. Thinking 

about the ECM motor piece, so not picking on Armin, but this 

technology where he has the, uh, the motor drive and fan 

are, are one unit, or -- 

 MR. DELANEY: All integral, yeah. 

 MR. PERSFUL: -- are all integral. Would that, 

uh, would that be considered, you know, his, uh, where you 

draw the box. 

 MR. DELANEY: Yeah. 

 MR. PERSFUL: Would that be considered a, a PDS, 

or in your mind would, um, could him or one of his 

competitors use this? You know, let's say if this is, uh, 

he gets a better result than what he normally would. And I 

don't know if hat would be the case or not. Could, would 

he, in your mind, would, would he -- 

 MR. DELANEY: So he would have the same decision 

any manufacturer of a supply control motor think separately 

or an ECM motor with a fan, or any other situation. He 

would still have to decide, is my base motor and drive 

together, greater than those reference losses. Do I want to 

take advantage of that? Do I want to test that and give 

that to another guy who says, hey, my efficiency's great. 

My losses are less than, than the other ones. So if he 
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wants to compare himself to a PDS, because it, you know, he 

can certainly use the full metric too. He could say wire. 

You know, he could either one on that, depending on which 

metric you're going to go to, right. Every, every corner of 

the world has a little different metric on this, so he could 

do either one or both. But yeah, yeah, it, take, take any 

configuration. Obviously, it can be more difficult to 

couple up, but you have to be at a, obviously, a low source 

dynamometer typically. 

 MR. LIN: So, this Paul Lin with, with NEMA, so on 

the pump rulemaking from the working group, they allow for 

the default calculations. And then you also allow to test 

it. Do you believe that your, your, your system is going to 

beat that calculated method as well. So there's two paths 

to that. 

 MS. MAUER: This is Joanna. I believe the 

proposal if you're selling a pump with an ECM motor was that 

you have to do a wire to water test, because of default. 

 MR. LIN: Because there's no default because of 

that, so you always get a test option to, to, so that you 

can show that there's differences in your efficiencies. 

 MR. SMILEY: This is Bill Smiley of Trane. Let me 

ask, uh, think it was some question. I'm not trying to be a 

troublemaker. But if you, uh, add a fan assembly with a 

motor and drive and you test it, and it was a, it was 
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basically the motor and drive that was used to develop the 

standard default metric. 

 MR. DELANEY: Okay. 

 MR. SMILEY: And your testing showed that it 

worked better than the default metric, are you going to be 

held to use the default metric, because the next top, the 

next, uh, one of exactly those same things you don't test, 

but the motor efficiency's a little lower or the drive 

efficiency's a little lower. And that's what gets tested. 

Are you going to get hooked for that, or what? 

 MS. ARMSTRONG: Let's table that discussion for 

the next agenda item -- 

 MR. SMILEY: Okay. 

 MS. ARMSTRONG: -- which is how do we come up with 

ratings and kind of -- 

 MR. DELANEY: Yeah. 

 MS. ARMSTRONG: I was thinking about discussing it 

at more about high level. 

 MR. SMILEY: Okay. 

 MS. ARMSTRONG: But obviously, that, because I 

want you guys to understand what we were, will require of 

you and what the different components of that are. And then 

opposite of that, kind of what it looks like on the back end 

when we do starting doing some market surveillance type 

things. And so let's have that discussion there, because it 
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might inform the options you want to consider for how you 

test, how you come up with ratings, you know, the nominal 

approach versus a tested approach. The, what I would call 

manufacturing production line variations that a bunch of, 

you know, so let's table that for a second and let him get 

through this and then we're going to talk about it in a 

broader sense. 

 MR. DELANEY: So, what's nominal about this, 

obviously, it follows the same kind of method that's already 

out there in the marketplace today, and allows the ability 

to now, you know, let's say incentivize greater than, let's 

say your, you know, let's say your default losses, which are 

basically represented by IE-2 and IES-2 levels. 

 So most drives and most motors today that you can

buy on the market, European or U.S. regulatory, are going to 

meet that level or greater. So you're going to feel pretty 

confident, if you're buying, excluding the products that 

we're going to talk about next, air over, right, you're 

going to expect obviously that those efficiencies be 

greater. 

 So to back it up, this is where we'll talk about 

some of the NEMA nominal stuff, but as a part of some of 

this discussion. So, as part of the pump ASRAC we supported 

them with, some part load loss data. And pump's a little 

different the way they run their set points. I think it was 
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75 to 100 and 115 to 125, I can't remember. So we supported 

them with what is part load loss data. They had some very 

old data, so we gave them some more recent data to update 

them. Basically, they were using pre-EPCA type data, pre-

'92. We gave them, let's say, 2013-type data representing 

what motors today are. And that was two and four pole. 

That's really what they care about. Just at fixed speed, 

though. So this isn't variable speed type of information 

that's out here. 

 So we talk about how we come up with test data. 

We have a very specific test method. IEEE 112, method B. 

That's a segregated loss method, very different than the 

input/output method. Its accuracies obviously are very 

repeatable, even between laboratories, whether it's, you 

know, competitors or third-party labs. That's our methods 

used by the Department of Energy. Then 25 years mature, 

continues to keep going through revisions and improvements, 

through the years, the newest one will be out here in a few 

months. 

 But NEMA provides the metric. The metric being 

NEMA nominal, okay. NEMA nominal is a definition that says, 

the large population of motors, what is that? Well, it's 

kind of defined by that manufacturer. You build five of 

those a year, 10 a year, thousands, it depends, right. So 

the large population is really determined by what the 
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manufacturers determines as a large population, but that 

population has to be within the nominal or what kind of, 

what's, if you will, like an average. 

 Now, that doesn’t mean, though, that they're all 

within there. There's a band, okay. And just like any, you 

know, average or statistical, you have standard deviations, 

right. Well, NEMA has a 20 percent of losses, okay. So 

there's, each band in NEMA, if you go to our table, is 10 

percent of losses. So that that nominal 10 percent of 

losses is one band, two bands being 20 percent. That's NEMA 

a minimum guaranteed. 

 So you pick up a motor, you test that motor, every 

one of those motors, if you ever found a motor that's below 

that, then you have a motor that's does not meet regs. It 

would be in violation. I would challenge you to find one in 

the marketplace today. Maybe not with a reputable 

manufacturer, but I would say, that would be very difficult. 

I would say that would be very difficult, because if you 

find one like that, don't get me wrong, they can exist, 

right. Statistical anomalies can exist, but with -- 

 MR. BUBLITZ: Time-out. This is Mark Bublitz with 

New York Blower. 

 MR. DELANEY: Sure. 

 MR. BUBLITZ: What statistical process method are

you using to guarantee that the lower limit of that
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manufacturing deviation is within that second band.

 MR. DELANEY: So, a lot of that is obviously the 

manufacturer's experience. 

 MR. BUBLITZ: You'll find that with every 

single -- 

 MR. DELANEY: Oh, no, absolutely not, of course, 

not. I mean, we're talking about thousands and thousands of 

motors a month. And, you know, to test a motor it's almost 

a day, you know, it's at least a day usually, to 

thermocouple and by the time you test it, yeah. 

 MR. BUBLITZ: So that's my question. How do you 

guarantee that distribution of product that's produced in 

some statistical distribution is guaranteed to be above a 

threshold. 

 MR. DELANEY: Well, our DOE did that for us. They 

defined what a ADM method is. 

 MR. BUBLITZ: No, you didn't answer the question. 

How did you do it? 

 MR. DELANEY: But if we want to go back to what 

each manufacturer does. 

 MR. BUBLITZ: I want to (indiscernible). You just 

said -- 

 MR. DELANEY: Yeah. 

 MR. BUBLITZ: -- I can't find a motor in the 

market that is below that second band. Prove it. 
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 MR. DELANEY: You, you mean the NEMA nominal, or 

minimum guarantee? 

 MR. BUBLITZ: I don't know what you just asked. 

 MR. DELANEY: Okay. 

 MR. BUBLITZ: But you, didn't you just say that 

there's two bands of error, there's a minimum efficiency or 

whatever loss is. And I cannot find a motor in the 

market -- 

 MR. DELANEY: Yeah. 

 MR. BUBLITZ: -- that's below that. 

 MR. DELANEY: Yeah. 

 MR. BUBLITZ: How do you prove that? 

 MR. DELANEY: Well, but the, how do I prove it? 

You just go test it. I mean, I guess, you'd have to find 

it. But how do I prove it? It'd be a matter of, so every 

manufacturer have to have its tolerances. 

 MR. BUBLITZ: Why is this hard to -- 

 MR. WOLF: Maybe you better rephrase. 

 MR. DELANEY: Okay. Maybe -- I'm not there to --

 MR. WOLF: How are you so confident in that 

statement? 

 MR. DELANEY: So every manufacturer, it has 

typical, a calculation, but not every manufacturer. There 

are some that choose just to do tests, right. So I don't 

want to speak for every manufacturer, but most of us have a 
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calculation method. And you have to have a buffer of this 

calculation. Not only does that calculation have to 

guarantee that you're always within the legal requirement, 

right. But it also has to guarantee that you're within 10 

percent of what you estimate. So it has to guarantee two 

things, okay, when you go through that. 

 Now, I'm not sure where you're testing motors -- 

 MR. BUBLITZ: We're not, we're not even on the 

same planet, I mean. 

 MR. DELANEY: Okay. 

 MR. WOLF: Let me -- 

 MR. DELANEY: Go ahead. 

 MR. WOLF: Mike Wolf, Greenheck. So, I think 

maybe what Mark is driving at is, how do you, how does that 

tie back to manufacturing tolerances and your testing 

tolerances to come up some statistical significance in your 

confidence, you know, 98 percent confidence level, 99 

percent, whatever. 

 MR. DELANEY: So every manufacturer has a 

different method to ensure, but in the end that calculation 

by which is proprietary to every manufacturer, that what's 

responsible for them. Just like ever math model that's DOEapproved in the system, they come and actually evaluate your 

program with a number of tests and actual evaluation. 

 MR. WOLF: So, Mike Wolf, again, just because 
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Mark's probably still going. So it's really up to the 

manufacturer to set their own tolerance levels. 

 MR. DELANEY: oh, absolutely. 

 MR. WOLF: And you're -- 

 MS. ARMSTRONG: Can I cut in? 

 MR. WOLF: Sure, go ahead. 

 MS. ARMSTRONG: For a second. So the way that 

(indiscernible) talk about. But, the way this works is that 

DOE dictates the types of representations motor 

manufacturers and, to that extent, other manufacturers must 

meet. And the DOE system, I would argue, I might also take 

issue with that statement, but that being said, the way this 

in theory works is, DOE has confidence limits and sets up a 

way that you are supposed to making representation of your 

model's efficiency. One, so for example, let's just say 

your motor -- 

 MR. PERSFUL: They can't hear you right now. 

 MS. ARMSTRONG: Seriously, okay. I'm just going 

to make numbers for a second. Say, I'm Ashley, and I said I 

tested out at 10. And if I run typically DOE requires a 

multi-unit sample to be tested to come up with a rating. 

And say because of the rating statistics, the confidence 

limits which will be influenced by the production variations 

that you feel are appropriate for your industry, say I make 

you de-rate to an eight, where consumers would favor higher 
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values. So I won't let you rate above an eight. 

 It is then your responsibility to make sure that 

the things coming off your line are that or better. So we 

make manufacturers, when they certify ratings, 

conservatively rate. We do it the opposite on enforcement. 

 Enforcement, we put the burden on us. We make 

sure that we test a multi-unit sample, except there are some 

provisions that'll allow us to test the single unit sample 

for custom equipment. But we make sure we are absolutely 

certain that your product is non-compliant with standards. 

So when you're asking him, I mean this may not answer 

specifically your question, but we basically make you derate. And then from that, the production variances, which 

are within your purview, it's up to you to make sure your 

units, your population, we understand every unit may not, 

but that population coming off that line, that number 

represented by that model complies with the number actually 

that you generated. 

 MR. BUBLITZ: A hundred percent of the time. 

That's interesting for a mass-produced manufacturing -- 

 MS. ARMSTRONG: So I understand some nuances, 

which is why I wanted to start the discussion of how we do 

things and then let's talk about how it may apply to fans, 

because I get that there may be nuances. And to answer your 

question, we get, no, the answer is no. We understand that 
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every single unit doesn't always hit the rating, but if we 

pull a unit. I know this is going to, this is coming -- 

 MR. BUBLITZ: It's got to hit the rating. 

 MS. ARMSTRONG: Well if we put, it doesn't always. 

Let's be honest. Every unit that I test doesn't always come 

up with the same number that's on the rating. In fact, it's 

probably, most of the units I test, of the hundreds I tested 

last year, most of them, they fall above, they fall below. 

It really depends on how, the manufacturer's strategic 

decision on how they rate. Some people rate very 

conservatively. Other's do not. They push the limits. We 

allow, within a certain range, we allow that to be the 

discretion of the manufacturer. That being said, if we pull 

a unit, and I'm not speaking necessarily for our enforcement 

team, but the way this in theory works is, we pull a unit 

and we have test data from a single unit test that gives us 

reason to believe that either your rating may not be quite 

what it's, you know, chalked up to be. We'd probably say, 

hey, we tested your product. Look at our test data, check 

yours. 

 Because you're required to maintain records and 

you're required to maintain your testing or your 

calculations or your AEDM or whatever the, the basis for 

your rating, you're required to maintain that and you better 

have those records if DOE asks. 
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 MR. SMITH: So on the motors, there is the minimum 

and the nominal? 

 MS. ARMSTRONG: Oh, here we go. 

 UNIDENTIFIED MALE: Just think of it as banding. 

 MR. DELANEY: As banding. You have a minimum and

you have a nominal. 

 MR. SMITH: Can I ask you a question? 

 MR. DELANEY: The motor's going to 

(indiscernible). Yes. 

 MR. SMITH: Thank you. So there's a minimum and a 

nominal. And the minimum you've already explained what that 

is and how that's enforced and, so that's what we can count 

on basically, right. Do you define what the manufacturer 

can say or represent as nominal? 

 MS. ARMSTRONG: No. 

 MR. DELANEY: No, short answer, no. You provide 

levels for them. That's it, yeah. 

 MS. ARMSTRONG: Motors, motors is not necessarily

a good example of this. 

 MR. DELANEY: Well, we're talking about motors, 

though, right, so. 

 MS. ARMSTRONG: No, I mean, he's asking with 

respect to fans. 

 MR. DELANEY: Generically. 

 MS. ARMSTRONG: Right? 
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 MR. DELANEY: Okay. 

 MS. ARMSTRONG: I mean so really there's not going 

to be a minimum and a nominal for fans. You're going to end 

up with a rating. 

 MR. DELANEY: Yeah. 

 MS. ARMSTRONG: And that rating has to be, has to

be developed pursuant to our procedures. You're not going 

to have this idea of minimum and nominal. Motors are the 

only product where we have this kind of hand we've been 

dealt with by statute, which is a little different than the 

rest of the world. The other 60-plus products, we define 

how you make ratings. And those ratings govern 

representation, and it's going to be a single point number. 

And we're going to discuss how we get there and what that 

means. But once we say this is how you find your ratings, 

we're going to say, this is the upper end. And, I guess you 

can call it a range. You can always conservatively rate 

back down from that, if you wanted to. 

 MR. SMITH: Upper it. 

 UNIDENTIFIED MALE: With losses. 

 MR. DELANEY: Upper end of losses, lower end of 

efficiency, is that what you mean? 

 MS. ARMSTRONG: So I was talking efficiency, but 

that's fine. You can't overrate, in other words. You can't 

say, you can't claim a higher efficiency than what we're 
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allowing you to claim. 

 MR. SMITH: And my, and my point is that that 

number, that one number for any given point -- 

 MS. ARMSTRONG: That number, yes. 

 MR. SMITH: -- is, I mean, we have to meet it. 

You pull a product, it's got to meet it. And the fact, the 

fact that that is, okay -- 

 MR. DELANEY: Yeah, because your ratio, because 

these are ratios. It's built all into the ratio. 

 MR. SMITH: Okay, so now, before we talk about 

manufacturing tolerances, because I think what you said is, 

manufacturing tolerances are on us, is that right? 

 MR. DELANEY: Think about this way, think about 

this way. 

 MR. SMITH: I'm asking Ashley. Manufacturing 

tolerances are -- 

 MS. ARMSTRONG: So we have what we call 

certification statistics built in that are supposed to 

account for the variations you would typically see in fan 

manufacturing. So if you come back and tell me you surveyed 

your AMCA members, blah, blah, blah, and typically they 

experience a five percent range, blah, blah, blah, we'll 

throw on there a 97 and a half or something like that 

confidence level. 

 MR. SMITH: Is that right, okay. 
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 MS. ARMSTRONG: And we'll make you rate with that

in mind. And it's, what it's going to do is push your 

ratings down. But that, what it's going to protect you 

against is if I spot check your product. 

 MR. SMITH: Okay, so now -- 

 MS. ARMSTRONG: That's how it works. 

 MR. SMITH: -- the following question is this. 

How do you deal with measurement uncertainty? So in the, in 

the, in the lab, in the lab, right, we're measuring flow, 

pressure and power. 

 MS. ARMSTRONG: Correct. 

 MR. SMITH: Right. So the power meter that's 

specified in 210 is plus or minus one percent. The flow and 

the pressure uncertainty is also graphically displayed 

inside at the 210. And it is the standard against which we 

accredit laboratories. They have to be able to measure that 

close. The point is it's not zero, and so how are those 

measurement uncertainties dealt with? 

 MS. ARMSTRONG: Okay, so I would say the 

certification tolerance should take into account 

manufacturing variability and test tolerances when testing 

with, by a manufacturer with his technicians in his lab. 

That's what the stats should take care of, stuff within your 

control. So whatever the cumulative effects of that, we 

should talk about it. 
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 Fast-forward, because this is always what 

everybody cares about. Fast-forward to the other side, 

regulations are in. DOE pulls a product, or we tell you you 

have to ship a product to X-lab, a third-party lab 

typically. And you're not allowed to be there, and you're 

not allowed to run the test. We're having someone else run 

the test. 

 I'm talking to you and those behind you. 

 MR. SMITH: No, no, I know. 

 MR. WHITWELL: Been there, done that. 

 MS. ARMSTRONG: So fast-forward. We have an 

additional tolerance on the enforcement side that 

acknowledges that when you take a unit and you test it at a 

different lab, when you test it with different people, you 

may introduce another level of variability, test to test. 

 MR. SMITH: Test tolerance. 

 MS. ARMSTRONG: And essentially, if you fail that

test, it's built that way to protect you. If we're going to 

define something that ends up being non-compliant and there 

are associated penalties, et cetera, with that, we want to 

make sure we're right. So on the enforcement side, the 

tolerances work against DOE and in your favor, or some may 

say to make sure that we've accounted for things that are, 

one could argue, beyond your control. Does that answer? 

 MR. MATHSON: Uh-huh. 
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 MS. ARMSTRONG: So that was my ratings 

presentation. We can just -- 

 MR. SMILEY: I'd like to do it again, I don't 

understand. 

 MS. ARMSTRONG: We can do it again. How about 

that? 

 MR. DELANEY: With slides. 

 MS. ARMSTRONG: Why don't you finish the motor 

stuff. 

 MR. DELANEY: Okay, one more. 

 MS. ARMSTRONG: But, ultimately, when we come, I 

mean, the reason why the minimum or the conservative 

approach is important is, you are going to be held 

responsible for that fan system rating. And so, once you 

add the pieces together, motor, drives, et cetera, whether 

you use the nominal approach or the wire to air approach, 

the responsibility is on the fan manufacturer. 

 MR. SMITH: And the representation that's in 

question here is the efficiency? 

 MS. ARMSTRONG: So we can have that discussion 

too. I know you guys are also concerned because you want to 

be able to make other representations, things that you 

normally do. 

 MR. SMITH: Flow and pressure -- 

 MS. ARMSTRONG: Exactly. 
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 MR. SMITH: -- and speed. 

 MS. ARMSTRONG: So -- 

 MR. SMITH: And power. 

 MS. ARMSTRONG: Correct. Right. Typically, the 

way we do this is to say your energy efficiency 

representations are made by blah. That being said, or in 

accordance with whatever we spell out in the regs, right. 

There are certain instances where there are certain pieces 

of information that impact our standards, or that impact our 

product. So, for example, for those in the room, cooling 

capacity. Sometimes we've gone as far as to say, you know, 

representations of those need to be made in accordance with, 

you know, but typically it's the efficiency. 

 So we would have those, I mean, that's part of 

what this is all about. Let's get around a table and figure 

it out. But part of that, driving that discussion is going 

to be what are your actual production variations on an 

aggregate. I know that's something that no manufacturer is 

going to disclose, especially not to disclose to DOE. On an 

aggregate basis, are we talking 99 percentile, like we are 

about certain lighting products, are we talking 90th 

percentile for confidence limits. And that should encompass 

test variability when testing with your own technicians in 

your own lab. 

 MR. CATANIA: So before we leave this topic and at 
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the risk -- 

 MS. ARMSTRONG: Did I explain it -- 

 MR. CATANIA: Tom Catania. 

 MS. ARMSTRONG: -- close enough? 

 MR. CATANIA: At the risk of freaking people out,

those principles, when applying to a standard, relatively 

straightforward, maybe not so easy to achieve, but 

relatively straightforward. But when they're tied to a 

voluntary market transformation program with financial 

incentives or other benefits, and commercial settings may be 

a little different than consumer settings, there is

additional complexity and additional discretion, correct, on 

the part of whoever the Government is overseeing the 

program, whether it's something like Energy Star or utility 

rebate programs and so forth, so. It, and it's not without 

precedent that more discretion has been exercised in 

remedies and so forth and how you respond to violations, 

where you're claiming performance above the standard, but 

the basis for calculating it is the standard. 

 MS. ARMSTRONG: Right, I mean clearly, I think 

what you can tell by, so I'm not here in an enforcement 

capacity as a lawyer to speak about the Department's 

discretion and, you know, all that kind of stuff when it 

goes into enforcement cases. But that being said, I think 

what you would see if you look back at what cases the 
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Department has brought or has settled, they surround 

standards. I mean, we're worrying about people complying 

with standards. That's not to say that if we test your 

product and we get something that's 20 percent off its 

rating, we won't knock on your door and say, hey, what's 

going on, let's have a conversation. But you're also not, 

it's unlikely that, we would probably say, look at our test 

data and reexamine yours, something's not quite right. But 

if you're 30 percent more efficient than the standard, we're 

also not going to send you a test note and say, cough over 

units in five days. There are different processes for 

handling that. 

 MR. CATANIA: Thank you. 

 MR. FERNSTROM: So, Tom, this is Gary. If I 

understood your point correctly, it was that if you're doing 

better than the DOE standard and maybe utilities are 

responding to that with incentives, there might be a little 

more discretion involved in finding you guilty of not doing 

what you say you're doing. 

 MR. CATANIA: Correct. 

 MR. FERNSTROM: And I've got tell you that our 

public utilities commission, anyway, has been driving us to 

use more and more creditable information. When we started 

doing rebates, we just based them on manufacturers'

specifications. And we found out maybe in some cases that 
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wasn't adequate. So, now we're being asked more and more to 

cite a report to a Government agency, the California Energy 

Commission, DOE. And I'm sure that the PUC would have the 

expectation that if it's reported, it is going to be just as 

accurate as anything else that's reported, without any 

additional discretion. 

 MR. SMITH: Yeah, I think, this is Wade Smith. I

think the, this is a sobering discussion for our members, 

because so many of the products that are going to be covered 

by this regulation are so seldom manufactured. In other 

words, we got some members sitting here in a room who 

actually never make a product that they've ever made before. 

Every unit is peculiar. And they use AEDMs to rate these 

units, but the subject of manufacturing tolerances is 

interesting because it's one thing to maintain a tight 

manufacturing tolerance on a production line of similar 

products, dimensionally similar products. It's quite 

another thing to maintain that dimensional similarity with a 

unit that, you know, with a rating basis, the rating test 

unit. And so I think each manufacturer is going to come to 

this subject with a different answer. 

 MS. ARMSTRONG: Okay. 

 MR. SMITH: And I think what I heard you say is, 

if I'm a manufacturer and I'm making a stamp them out 

product and I do statistical analysis of my production and I 
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know what the performance is on a statistically significant 

distributive basis, I got the bell-curve. And I think I can 

be within two percent, just pick a number, you know, I'm 

taking, I'm taking two percent and that's it. And the next 

guy says, I'm going to be lucky to get 15, they're going to 

have to take 15. And you're not going to tell them whether 

they have to take 15 or two. You're just going to tell them 

if I pull a unit and test it, it's got to be right. Am I 

correct in that? 

 MS. ARMSTRONG: So the answer is mostly. I'm 

going to bound that range. I'm going to tell you what the 

lowest number you can rate at, which is going to be the 

standard. And I'm going to tell you what the highest 

number. Within that range, it's on you. But when I pick a 

unit -- 

 MR. SMITH: Well okay, here's the issue. 

 MS. ARMSTRONG: I, I get everyone -- 

 MR. SMITH: With the proposed rule, we're not 

talking about a single point of test. 

 MS. ARMSTRONG: Uh-huh. 

 MR. SMITH: We're talking about a complete range. 

So the description that you're making applies to an infinite 

number of operating points for any particular fan, right? 

 MS. ARMSTRONG: I understand. 

 MR. SMITH: So it's a sobering challenge to 
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contemplate all this at one point, or three test points. 

But it's a much more challenging subject when you say, no, 

it's the range. 

 MS. ARMSTRONG: So I'm not saying range is the 

same way you're saying range, I don't think. 

 MR. SMITH: (Indiscernible). 

 MS. ARMSTRONG: Take a single point in your range. 

 MR. SMITH: Yeah. 

 MS. ARMSTRONG: Um -- 

 MR. CATANIA: There's a range in that. 

 MS. ARMSTRONG: There's a range in that single 

point value. If you were to make more than one of them. I 

get that some of these are custom built you'll never make 

but one of them, we have other regs to deal with that. We 

can talk about those. But let's say you decide to make a 

hundred and we can all, I think, agree that not a hundred 

are going to test out identical, right. 

 MR. SMITH: Sure. 

 MS. ARMSTRONG: That's the range I'm talking 

about. So what should that one point be represented as? 

 MR. SMITH: Right. So what I'm going to suggest 

to you is that the deviation from the norm in certain parts 

of the performance map are going to be much tighter than the 

deviation from the norm in other parts of the performance 

map. 
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 MS. ARMSTRONG: Okay. 

 MR. SMITH: And the measurement tolerance varies 

across the performance range and is documented in the 210, 

never mind the fan's performance. 

 MS. ARMSTRONG: Yes. 

 MR. SMITH: So this becomes a subject that has an

extra dimension of complexity because of the way we propose 

to have the regulation. 

 MS. ARMSTRONG: Fair enough. And so I think it 

would be, you know, it is, let's see, what time is it? It's 

4:30 now. We're wrapping up at 5:00 today. I think it 

would be good if you finish, Dan finishes his thing

(indiscernible). No more talking about ranges and, and 

stuff with motors. 

 MR. DELANEY: I'd talk about it all night. 

 MS. ARMSTRONG: Perhaps give me some time to come

up with an example of what this would look like and just 

kind of walk you through. If we were to do things the way 

we do normal business today, and overlay the potential 

regulatory approach as it is set out in the second NODA, how 

would, what would ratings look like? 

 MR. DELANEY: Uh-huh. 

 MS. ARMSTRONG: How would those ratings for each 

of those points be developed? And what information from you 

will we need. That way you can understand kind of how this 
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would work. But when you make a certified rating to the 

Department, I mean, we understand every test point isn't 

going to come out identical. 

 But, let's just say that, you know, we've done it

in a manner that we think the consumer, or the commercial 

customer in this case, should get that or better performance 

for the most part. Otherwise, there's something off with 

your methodology or rating. 

 MR. SMITH: Dan, Bill Smiley, Trane, I have one 

real quick -- 

 MS. ARMSTRONG: So that's generally the high 

level. 

 MR. SMILEY: -- question. 

 MR. DELANEY: Sure. 

 MR. SMILEY: And it surely has to do with what 

you're talking about. 

 MR. DELANEY: Sure. 

 MR. SMITH: Yes, sir. 

 MR. SMILEY: If you go back, well -- 

 MR. DELANEY: Which one? 

 MR. SMILEY: -- back to that chart that had all 

the yellow on it -- 

 MR. DELANEY: Yeah. 

 MR. SMILEY: -- which was your -- 

 MR. DELANEY: Yeah, yeah, the motor, yeah. 
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 MR. SMILEY: Your motor efficiency at various load 

points. And two things, one is, that's two pole and four 

pole, but we used a lot of six and eight pole as well. 

 MR. DELANEY: Yeah, and that's what I've noted 

here. 

 MR. SMILEY: And do you have that information? 

 MR. DELANEY: Yeah, yeah, absolutely. So what I 

was thinking before we even go do that. Let's really talk 

about what we really want. Do you really want fixed speed. 

What's really needed there. So before we go crazy, go 

getting it, we're ready need to talk about what's beneficial 

and got to get the metric. Got to do a lot of other 

decisions. Absolutely, we can go back maybe and deal with 

this. 

 MR. SMILEY: No, this is very good when you don't

have a variable speed drive. 

 MR. DELANEY: Yup, correct. 

 MR. SMILEY: This is extremely good information 

and necessary. The question I have is, is this old motor 

data that's run like in 30 seconds on a whole speed work 

curve -- 

 MR. DELANEY: No, sir, this is stabilized. 

 MR. SMILEY: -- or is this? Stabilized at some 

operating temperature that's -- 

 MR. DELANEY: Full load. 
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 MR. BOTELER: -- per DOE test methods. 

 MR. DELANEY: Yes, per DOE test method. 

 MR. SMILEY: I don't know what that is. 

 MR. BOTELER: IEEE 112 method. 

 MR. DELANEY: All you need to know is that's what

we're regulated at. Right, that's the regulated method. 

That's what, that's what this all this data is provided at. 

Okay, last topic I had. This is the one, the only one I 

thought would be controversial. 

 MR. PERSFUL: This is Trinity, Twin City Fan. I 

just want to make sure I understand that last point you just 

said. So this, this table is at a 100 percent load. 

 MR. DELANEY: No, no. 

 MR. DELANEY: Yeah. So we go from a hundred to 25 

percent at fixed speed, at fixed speed, because that's what 

was desired by the pump guys 

 MR. PERSFUL: Well, I mean at, at -- 

 MR. DELANEY: At 60 hertz or whatever your base 

frequency is, yeah. 

 MR. PERSFUL: And so, so let's, I'm just trying to 

think this in my head, so let's say if we're at 40 hertz. 

 MR. DELANEY: And change, and the efficiency would 

less than comparing it to this, yes. 

 MR. PERSFUL: Correct -- 

 MR. DELANEY: Yeah. 
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 MR. PERSFUL: But is that going to be annotated? 

I mean, do we have a chart that goes, you know, 40, 41, 42? 

 MR. DELANEY: Right, so that's where the PDS 

discussion when you want that information, that's where 

that, that's where the reference loss is. That's where the 

equation. That's where I can test it. I can, then you can 

extrapolate it yourself. We can do it for you, right, so. 

 MR. PERSFUL: So we use the equations, so in cases 

where we just sell a bare fan, without the motor and drive, 

but it gets, let's say it gets tested with a, at least going 

to get tested with a motor. 

 MR. DELANEY: Yeah. 

 MR. PERSFUL: Is it, is it the, the, the thought 

of the working group that it, it's going to be tested using 

-- 

 MR. DELANEY: So, I don't want to jump to that 

conclusion, because that is -- 

 MR. PERSFUL: Will this equal value. 

 MR. DELANEY: -- that is certainly some of the 

discussion that needs to be still had here, but it, it 

certainly can be, right. It can be like the motor, like the 

pump guys decided. They just did equalized points; so they 

have a base, which was, like I said my memory, 75, 100, 125, 

just equally loaded at 33 percent each. Right, it's due to 

-- 
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 MR. PERSFUL: Because I'm, I'm thinking if I sell

a fan at 40 hertz and so the DOE is going to survey that, 

that product to me at that point, you know, then do they 

reference a, a calculated method. 

 MR. DELANEY: We would have to have a table that 

would back that up; so whether that we provide that, whether 

we use that IC, right, we'd, one would have to be given 

this, because you always have to have a reference, right? 

You have to have a minimum that says you can't go below that 

for the motor. So how that would look, I, I don't want to 

jump to conclusions how it would look. Certainly, we could, 

we could come up with something, but we need to decide a lot 

of other things about how the metric and, you know, and then 

we certainly can put together some data to support that for 

you. 

 MR. SMILEY: Real quick, Ashley, Bill Smiley, 

Trane. Can you guys provide a link to the DOE motor test 

standard that defines the temperature and the process that 

you go through for that? I'd appreciate it, rather than try 

to find it myself. 

 MS. ARMSTRONG: Uh-huh. 

 MR. DELANEY: I'm surprised they didn't put it on

there. Okay. 

 So, the last topic which, early on in this, you 

know, when I first came into this I assumed we had a lot of 
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continuous motors. Right, then I heard earlier on from AMCA 

and Wade most of, most of the motors are one horsepower and 

below. It's mainly air over direct drive motors, if you 

will, right? 

 So this is a product that has been on our radar 

for many years. It's out of the regulations. It's not 

going to be covered June 1st, 2016 either, okay? A lot of 

difficulties in doing this, if it was easy it would have 

been done long ago, okay? I'm sure many of you are familiar 

why it's difficult. And I'll just walk through a couple of 

items just for discussion. By no means are we giving up on 

this. This is an item that we're working on for our next 

regulation, which is small motors. And certainly, probably 

we'll have to work on it to support this regulation as well 

too. That's our hopes. 

 So just, just some of the reasoning, you know, and 

going to nameplate rating alone, that doesn't mean that much 

in the air motors. I'm sure a lot of you are shaking your 

heads yes; you understand that. It doesn't mean much. It's 

a current type thing. We give a sample. It's tested. I 

want to see that current within X amount, whatever your 

percentage is you want to see, they got, I got the right 

motor. Horsepowers don't mean nothing. What they do mean 

is at cold, we test them. They're assigned from the NEMA, 

break down torque. That's how we get the horsepower. It 
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means nothing. It's almost like a frame assignment to you, 

half with a half, a three quarter with a three quarter, 

right. It's almost like a substitution number. It's not 

really. It doesn't mean much. You don't care so much 

about. You care, does it move my fan within the operating 

parameter I need, okay? And that's why much of the air over 

market is sample. 

 And this isn't totally closed air. This is more,

it includes that product. But I would say it's more of the 

open air over type product direct drive. Certainly

centrifugal but it could be any prop fan or other. 

Certainly a lot of rooftop use, that's why there's belted or 

direct drive. 

 Obviously most people understand it doesn't have a 

fan on the back. It will overheat without that fan. 

Obviously the driven fan that's providing the cooling, some 

of the belted product works that way as well too. There is 

such a thing as, you know, they're kind of, they're created 

in the marketplace, so we can get continuous air over. 

Sometimes that's mean belted. You'll see a fan duty 

sometimes. It used to mean things in the past. It really 

doesn’t mean anything anymore. It's legacy terms that kind 

of got carried over, but fan duty is to mean draft-induced 

or sometimes. It used to mean, used to mean belted in the 

past too. But the end result is, obviously at the air of 
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that product it's not that. It's not going to stay within 

that and get a good efficiency point, right? It’s very 

difficult to do that on a dime. 

 Where does this all originate. You all understood 

this many, many years back. So they just do a cold point. 

Literally, it's the shortest time you can get that motor on 

the die now, get the current to stabilize. Done, you're 

done with the rating. Wherever you want assign? Whatever 

that torque does, that's the assignment of horsepower. It 

doesn't really mean anything. It doesn't mean anything to 

us. It doesn't really mean much to you, motor sampled. You 

want to make sure that current is repeatable, but when you 

put it in your fan, it's not within whatever your 

percentage. Usually 10 percent is the UL rule. And that's 

probably, probably similar to what you guys use to ensure I 

got the right motor or my motor's operating as it should be. 

 Test method, obviously there is none. No industry 

test method. The CSA C747, as a result of small motor rule, 

NEMA manufacturer revised that standard dramatically. Just 

improved, you know, many of the, we talk about power, you 

know, quality. There's really no good term for this. It's 

accuracy requirement says, what's your policy supply end has 

to be. It’s what your torque requirement is. It's your 

accuracy haul, your measuring equipment. That's a lot of 

money. Motor manufacturers invest massive amounts of money 
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in our, in our motor test labs. And if you had do wire to 

air, you'd have to do very similar major upgrades. And I 

think some of you mentioned before, pump guy certainly saw 

it at the end of the rule and we're very concerned with 

that. You know, that's a major investment for you to have 

to measure both amp watts at the levels necessary to get the 

accuracies. 

 But, yeah, many, many issues and many, many costs, 

but even if they did, okay, so what is mainly the issue 

here. What we can't decide how you do the air over test. 

So if we're going to do it just air over motor, do a CFM at 

a static pressure. None of us like to do that, even though 

most of us can do it. It's not something we really want to 

do, is doing a bunch of blower testing or air chamber 

testing. Air velocity at a specific point, you know, we can 

put an manometer at a certain point on the motor and define 

it within a certain position. Then that let’s the 

manufacturers do all kinds of crazy things on the fan and 

air, and that's probably not very good. 

 Another way to do it, you can do temperature 

stabilization. You can just say every motor has to

stabilize at this point. That's not great, because then it 

makes the horsepower throw off as well too. A lot of air 

over motors are very cool, 45 C range. You would, you would 

penalize it by running that high, some a little higher than 
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that. Not many though. Many, many air over motors run very 

cool. 

 And then as far as classification at the bottom, 

air over motors, they're, they're probably the least 

efficient in the motor marketplace. There is no regulation 

on them today. Down and dirty as we've heard most of this 

marketplace is, right? Some PSCs are very efficient 

product, but cap start induction run product is definitely 

on the lower end of efficiencies. There’s even shaded pole 

and some, not much, on the very, very low end. I saw the 

120 watts hovering around there, but mainly below 120 watts. 

 The technologies obviously in the less than one 

horsepower. Many are single-phased and many are, as I 

mentioned, shaded pole. There's, there's still a 

significant number of split phase, PSCs certainly and the 

cap start induction run, which obviously are, are less 

efficient than the regulation for small motor today. And 

none of those motors could ever reach the small motor rule 

levels without growing a frame maybe even two frame sizes. 

It makes it uncompetitive, so it would essentially push many 

of those technologies, if we use that as a baseline. Or as 

we said here, maybe we just define a whole new efficiency 

level as a result of this committee that makes sense, that 

drives what's necessary, or maybe, if you'd like, maybe we 

have to develop our own set of efficiency levels based on 
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whether it's a certain type of single-phased technology. 

 Obviously, I didn't include the ECM. That is a 

higher efficiency product that obviously can meet many of 

the products, but complicated because you, you can't really 

use the test methods. It's not for an ECM motor to define 

the losses. You can do it. Don't get me wrong, but it's 

not intended for that use. 

 So that completes my stuff. Any questions about 

it? 

 MS. ARMSTRONG: No, just one comment. 

 MR. DELANEY: Yeah. 

 MS. ARMSTRONG: So Paul, welcome. Last meeting, 

DOE presented nominal values for TEAO motor. If you could 

look at them -- 

 MR. DELANEY: Yeah, I -- 

 MS. ARMSTRONG: -- and give us some feedback on 

them. You know, we have, I don't think I as a committee 

we've decided or made any decisions or expressed any level 

of comfort with these nominal values or even a nominal 

approach yet, but I think having some feedback, or we at 

least attempted to do it. We assigned some more of the 

catalog information we were able to collect. I think, you 

know, having your spin on what that might look like would be 

helpful. 

 MR. LIN: Okay. Now, now that last, I noticed 
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when I tried to go back and pull some of the other 

information. I was able to find the last, but it did get 

out on the, the -- 

 MR. DELANEY: It didn't. 

 MS. ARMSTRONG: It may not be on the docket. I'm

not really sure what parts of that I’ve been sending out. I 

sent it out, but it hadn't made it to the docket, but I'll 

send it again. 

 MR. DELANEY: Okay, I don't think. 

 MS. ARMSTRONG: No problem. But it’s in the slide 

document -- 

 MR. DELANEY: Yeah, absolutely. 

 MS. ARMSTRONG: -- you nominal values based on 

regulatory and then obviously nominal value. We attempted 

to do nominal values for these. We did not go further for a 

more, I would guess, the beginning part of your, what your 

beginning part of you representation will take care of, but, 

and that would be helpful. 

 MR. HAUER: I have a question back on the PDS. 

It's Armin Hauer speaking. 

 MR. DELANEY: Yeah. 

 MR. HAUER: Are there any electrical procedures 

included load side or line side on variable speed drive? 

 MR. DELANEY: It goes back to the PDS concept. 

 MR. HAUER: Yeah. 
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 MR. DELANEY: The input/output is you're measuring 

input of a control, output of the, of the motor. 

 MR. HAUER: All right. But would you not be able

to fetch your, basically artificially increase where 

efficiencies if you neglected to use load side filters? 

 MR. DELANEY: Yes, so, let's go back to that, yep. 

So that is accounted for in the test, in the test, obviously 

not reference, right. So obviously losses of the, I took 

that one slide out. It actually showed all the measurement 

points. It just got, I didn't want to get into too many 

things, but you see what that dotted line is. That's 

actually where we'll be polling voltage watts from as well 

to during the test. I know this isn't the representation of 

that, but it's measuring both in front and behind. It's 

isolating the CDM when you do the test. You have to know it 

includes any auxiliaries or filters upstream or downstream 

in the CDM. 

 So the CDM is the one that's penalized for it, 

because obviously they're the ones necessary probably to 

have the filtering, you know. So it's incorporated into the 

CDM test. 

 MR. HAUER: But okay some manufacturer will be 

here for AHRI 1210 certification. Now, one manufacturer so 

far has certified their products. And AHRI 1210 also judges 

about specs on the motor, and it also judges about how long 
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it's induced in the, into the line. And so you could 

basically boost your efficiency in the PDS if you left you 

left out the filters, so how would this change? 

 MR. DELANEY: Good question. So there is a base 

line test point set of carrier frequencies, a base setup 

that has to be repeated each time on the test. So it says 

regardless of what you want to use it and this is the same 

test. So if I go from one place to the next, this is the 

test setup that has to be done on the drive each time. So 

that's, that's the only way to make it fair, is to make a 

setup that each person has to repeat. So that's how it 

deals with that, okay. 

 MR. BUBLITZ: I have a question. Mark Bublitz, 

New York Blower. So there's DOE standard losses that were 

published, you know, published. And then there's this 

approach, right. Is this working group supposed to pick 

which one and what's that, what's the action? 

 MR. DELANEY: But we don't, we don't have a 

proposal, so I, I, just to make that clear. I don't have 

any proposal for air over. 

 MS. ARMSTRONG: No, no, but you have for the 

other, the rest of them. 

 MR. BUBLITZ: No, I'm talking about the whole 

product. 

 MR. DELANEY: I don't know. 
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 MS. ARMSTRONG: We do. 

 MR. DELANEY: Do, for, you mean for this, for the

PDS, yeah, yeah. 

 MS. ARMSTRONG: Yeah. So, yeah, and we would have 

to have that discussion about where we want to go. Do we 

want to do something like, and I'm not sure they are that 

different, but I think there are some, some differences in 

terms of for the nominal approach, do we would want to use 

something setup like this. I'm not sure Dan's process will 

actually be done in order for us just to point to by the 

time they may need it in the test procedure hearing. So we 

may have some timing issues there. But do you want it to 

move to an approach like this or do we want to do our own 

thing similar to what we did in pumps? And pumps used 

aspect of this, so they're not completely off and they're 

not different. They're pretty similar, but they're not 

exact. 

 MR. SMITH: Is this to set the default values? 

 MS. ARMSTRONG: It's to set the default values. 

It's not the nominal values. And maybe you don't care, as 

long as you have that ability. 

 MR. SMITH: No, I don't care. 

 MS. ARMSTRONG: You care as long as you have that

ability and care as long as they're setup in a way that, I 

think, A, provides you meaning results, but B, they also 
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protects you if DOE were to test, do actual testing that the 

rating is still, is equitable as being a nominal method and 

tested method. Anyway, you can hold that it, the answer, 

simple answer to your question is yes, that it’s open to 

discussion and building on whatever else you want to do. 

 MR. DELANEY: It's a little complicated by the 

fact that if we said a majority of it is air over and you 

don't have an efficiency level, then you make big assumption 

to I3 or NEMA premium, and that's a big assumption that 

changed the motors you get today would dramatically change 

for you. 

 MS. ARMSTRONG: That's why that table is pretty 

important. 

 MR. DELANEY: It is, it's very important, yeah. 

That's very important. If we use that reference loss. 

 MS. ARMSTRONG: You could also say for certain 

types of motors, do they always have to get tested. And 

that's the other options. It's also, it's within your 

purview to have that kind of discussion here, depending on 

what you may want. So that's why some of the questions we 

had teed up from the last set of, and I know you guys both 

had some of them, but some of the questions we had teed up 

with regards to the last set - how do you test some of the 

answers to your questions and then nominal approach versus, 

um, wire to air approach. That’s why some of those are 
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important. It gets to the heart of which way we want to go. 

 MR. SMITH: So let me ask you a question. Say 

I've got a fan that has maximum speed and sort of a worst 

case scenario, it, it carries 75 horse motor, but in its 

performance map it has, demands that drop all the way down 

to one, to one horse, right? 

 MS. ARMSTRONG: What do you do? Yeah. 

 MR. SMITH: So now I'm making that product and I'm 

selling it as a bare shaft band and I choose to, for those 

that ask, and they certainly will, I choose to use the 

default value to determine the wire to air efficiency of 

assembly. It has my fan and I don't know whose motor, so 

it's not my, not my problems. 

 MS. ARMSTRONG: Right. 

 MR. SMITH: Customer buys that stuff, packages it. 

He wants to know what the wire to air is. I give him the 

answer, life goes on. Is the default values used in that 

computation to a one horse motor since this fan can be 

applied with a one horse motor, and it's catalogued with a 

one horse motor? 

 So, so I, I mean -- 

 MS. ARMSTRONG: Go ahead. 

 MR. SMITH: Or is this, uh, is this a matter that

we'd have to debate and decide upon, or it, okay. 

 MS. ARMSTRONG: This was one of our items of 
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feedback, that we had to decide. 

 MR. DELANEY: So a key is that duty cycle. What 

do you want in that metric, right. 

 MR. SMITH: No, you're, you're not on the same 

wave length here because -- 

 MS. ARMSTRONG: Motor -- 

 MR. SMITH: We're proposing that, that -- 

 MS. ARMSTRONG: It's motor -- right. I mean 

that's really what you're asking. 

 MR. DELANEY: No, that's independent -- 

 MS. ARMSTRONG: It's just sizing. 

 MR. SMITH: I'm sorry? 

 MS. ARMSTRONG: It's sizing and we kind of -- 

 MS. IYAMA: So I think what you're asking is what

size motor do I pick when I'm calculating my rating. 

 MR. SMITH: As a default value. 

 MS. IYAMA: As the default value. And I think --

 MR. SMITH: And I'm going to say that the only 

time this matters is, is when I want to represent a

particular motor and drive combination that carries the 

default. 

 MS. IYAMA: Right, so I think here is the 

different, different situation. 

 MR. SMITH: Because the default value in my 

calculation shows up in both the numerator and the 
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denominator -- 

 MS. IYAMA: Right. 

 MR. SMITH: It doesn't actually matter 

 MS. IYAMA: Right, so the -- . 

 MR. SMITH: The time that it matters, right, is 

when I certify a particular motor and drive with efficiency 

I'm going to claim is above the default, right. 

 MS. ARMSTRONG: So I, the answer is yes, but I 

actually will go as far as I think it does matter, because 

I'm not sure we're going to end up at an index. And even if 

we did end up at an index, I'm not sure that index is a 

moving index, in which case they would always cancel out, 

depending on how we go with this. So I think we should 

assume it does matter -- 

 MR. SMITH: Well, it matters -- 

 MS. ARMSTRONG: -- because I think that's the 

better way to go. That it could matter. 

 MR. SMITH: It could matter even in the default 

calculation? 

 MS. ARMSTRONG: Correct. Because I'm not sure 

we're going to end up with an index. I mean, I know you 

guys want an index for purposes of making representation, 

but the standard's not an index. 

 MR. SMITH: Whether or not, whether, whether or 

not it's an index, Ashley, if I'm a manufacturer and I'm 
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making a product and selling it with bare shaft, I do not 

want to be tested or held responsible for the performance of 

the things that I didn't make or sell. 

 MS. ARMSTRONG: Right, so I understand. You don't 

want to be held responsible for, I'll just say it, an 

underperforming motor, got it. 

 MR. SMITH: Well I don't sell motors. 

 MS. ARMSTRONG: Got it, that being said, that's 

why these issues are important. That's why the nominal 

values and the way they are constructed are important. 

That's why some of the questions we had teed up previously 

and the way we're trying to construct the nominal values are 

conservatives because of this issue specifically. 

 MR. SMITH: But when are we going to talk about 

the pros, cons and difficulties and challenges associated 

with the ratio FDIs? 

 MS. ARMSTRONG: So I guess this is a good time to

talk about what may come tomorrow because it's almost 5:00 

and what topics does the working group really want to talk 

about tomorrow in this room again. So, you know, be 

prepared, mentally and otherwise. 

 MR. SMITH: And we’re here at 8:00 in the morning. 

 MS. ARMSTRONG: We are. 

 MR. BOTELER: It's 8:00 to 3:00. 

 MS. ARMSTRONG: You can go off record now. We're
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good. Thank you. 

 (Whereupon, the meeting was concluded.) 
298 

% Digitally signed by Robin Conover 

 ELECTRONIC CERTIFICATE 

DEPOSITION SERVICES, INC., hereby certifies that 

the attached pages represent an accurate transcript of the 

electronic sound recording of the proceedings before the 

United States Department of Energy in the matter of: 

ASRAC FANS AND BLOWERS 

WORKING GROUP MEETING 

By: 

 

 

 Robin Conover, Transcriber