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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 

Thursday, June 4, 2015, commencing at 8:10 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 

 MR. BOSWELL: So it's a little bit after 8:00 and

we're going to go ahead and get started. And welcome to Day 

6 of the ASRAC Working Group on Fans. 

 For the record, we're going to go ahead and have 

everyone introduce themselves like we did yesterday. After 

we do that, Wade Smith is going to give the presentation 

that we did not get to yesterday on definitions. 

 Just for kind housekeeping, again if when you'd 

speak if you'd remember to say your name for the record that 

would be great. 

 We, as part of the ground rules we established, 

we're not reserving separate time for public comments. The 

people that are here from the public are able to speak as we 

go through the day. Also, for those on the WebEx, the 

committee members -- 

 IT SPECIALIST: They're not actually dialed in 

yet. 

 MR. BOSWELL: -- oh, do you want to go ahead and,

sorry. 

 IT SPECIALIST: Yeah. 

 [WebEx call initiated.] 

 MR. BOSWELL: Okay, so I think we're now connected 

to the web. As I was saying, as part of our ground rules 

here we decided that comments from the public would be 
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accepted during the course of the meetings. If people are 

participating by webinar, there are three working group 

members on the webinar. They will hopefully all have open 

mics today. I know Greg Wagner had problems with that 

yesterday. 

 If there are other people from the public with 

comments, they can send a message to the web facilitator who 

will deliver that message to us in the room. 

 So, like we did yesterday, I'm going to ask if 

everyone could identify themselves by name and organization, 

starting with the far corner there and going around the 

room. 

 MR. MAGILL: John Magill with Howden. 

 MR. BOTELER: Rob Boteler, Nidec Motor 

Corporation. 

 MR. MCCABE: Michael McCabe, Consultant with 

Trane. 

 MR. ERNST: Skip Ernst, Daikin Applied. 

 MR. TEAKELL: Kevin Teakell, AAON. 

 MR. DYGERT: Ryan Dygert, Carrier. 

 MR. STEVENS: Mark Stevens, Air Movement and 

Control Association. 

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

Conditioning, Heating and Refrigeration Institute. 

 MR. FLY: Mark Fly, AAON. 
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 MR. WHITWELL: Bob Whitwell, Carrier. 

 MR. MCNEIL: Don McNeil, Buffalo Air Handling. 

 MR. LIN: Paul Lin with Regal Beloit, representing 

NEMA (phonetic sp.). 

 MR. DELANEY: Dan Delaney, Regal Beloit. 

 MR. JOHNSON: David Johnson with Berner 

International. 

 MS. MAUER: Joanna Mauer, Appliance Standards 

Awareness Project. 

 MR. DIKEMAN: Steve Dikeman with AcoustiFLO. 

 MR. FERNSTROM: Gary Fernstrom with the longest 

introduction, representing the California Investor Owned 

Utilities, Pacific Gas & Electric, Southern California 

Edison San Diego Gas & Electric, a Southern California Gas 

Company. 

 MR. STARR: Louis Starr, Northwest Energy 

Efficiency Alliance. 

 MR. SMITH: Wade Smith with the Air Movement and 

Control Association. 

 MR. BURDICK: Larry Burdick, SPX Cooling 

Technologies, representing Cooling Technology Institute. 

 MR. HAUER: Armin Hauer, ebm-papst, Incorporated.

 MR. DADDIS: Duane Daddis, Carrier. 

 MR. BUBLITZ: Mark Bublitz, The New York Blower 

Company. 
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 MR. HOWE: Nick Howe, Carnes Company. 

 MR. PERSFUL: Trinity Persful, Twin City Fans. 

 MR. WOLF: Mike Wolf, Greenheck. 

 MR. ROY: Aniruddh Roy, Goodman. 

 MS. IYAMA: Sanaee Iyama, Lawrence Berkeley 

National Laboratory. 

 MR. JASINSKI: Sam Jasinski, Navigant Consulting.

 MR. WIGGINS: Steve Wiggins, Newcomb & Boyd. 

 MR. SMILEY: Bill Smiley, Trane. 

 MR. CATANIA: Tom Catania, also for the Air 

Movement and Control Association. 

 MR. MATHSON: Tim Mathson, Greenheck. 

 MR. FINE: Steve Fine, Office of Hearings and 

Appeals. 

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

Hearings and Appeals. 

 MS. PONTILLO: Pam Pontillo, Department of Energy, 

Office of Hearings and Appeals. 

 MR. BOSWELL: Okay and Pete and John are here. If 

you could just introduce yourselves. 

 MR. COCHRAN: Pete Cochran, DOE. 

 MR. CYMBALSKY: John Cymbalsky, DOE. 

 MR. BOSWELL: And for the Committee Working Group

members that are online, if you could introduce yourselves. 

 MR. WAGNER: Greg Wagner, Morrison Products. 
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 MS. WALTNER: Meg Waltner, NRDC. 

 MR. BOSWELL: And is Diane Jakobs online? 

 Okay, so where we're going to start this morning 

Wade Smith is going to give his presentation on definitions 

that we had not quite gotten to yesterday. So we talked 

about that being the starting point. 

 John, do you have any comments that you wanted to

make before we get started? 

 MR. CYMBALSKY: No, that's my understanding as 

well. 

 MR. BOSWELL: Okay, great. So, Wade the floor is

yours. 

 MR. SMITH: Okay, so this is a file which was sent 

to the, included with the minutes for today's meeting. And 

it's, when you deal with definitions, you deal at a very 

detailed level and you have to think very, very carefully 

about the intent and the expectation, loopholes, things like 

that. 

 So I think the way to go through this with the 

group is to invite your questions, and a modest level of 

discussion, but I think it would be far better if you had a 

chance to study this document after the, after the meeting 

and prepare, if you see concerns, or you have problems or 

you want to make changes to try to bring those to the 

surface at that time, because getting to this point has been 
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lots of committees working for many, many, many hours. Days 

really. 

 And this started back and forth between ASRAC and

the efficiency advocates; Meg Waltner, who is on the phone, 

as the lead person for the group that worked on it. And at 

AMCA, we ran this through our Fan Engineering Committee. 

 And so I'm going to read these and this is an 

iteration of the framework document, the advocate proposal, 

the AMCA proposed changes, comments and concerns, DOE 

proposal that appears in the ASRAC, and the question that 

was answered last week actually by the Fan Engineering 

Committee. 

 So these essentially came through this working 

group and ended up with questions, you know, in this case, 

are you okay with the new DOE definition of Fan Committee 

responses. Yes, so that definition is a fan is a rotarybladed machine used to convert power, meaning flying power 

to air power with an energy output limited to 25 kilojoules 

per kilogram of air, typically consisting of an impeller, a 

shaft, bearings, a structure or housing and transmission and 

driver, transmission driver and controls, if included by the 

manufacturer at the time of sale. 

 So -- 

 MR. BURDICK: Wade, do you want comments on this 

now or do you want -- 
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 MR. SMITH: Sure, why not? 

 MR. BURDICK: Okay, well one of the things that -- 

oh, Larry Burdick, SPX, and one of the things that was 

commented on by one of my colleagues on this particular 

definition was that bearing, structure or housing, after 

that we put separately testable. You know, this maybe 

implies that you're going to test it, you know, in the 

housing or in the embedded configuration. 

 MR. SMITH: Could I ask someone to take notes? So 

if you want to just throw that, throw that out there. 

 MR. BURDICK: Yeah, and I can email that to you, 

too, Mark or Wade. 

 MR. FERNSTROM: So this is Gary for the California 

IOU's. What you have in the definition so far is clearly 

identifiable as part of the piece of equipment as offered 

for sale by the manufacturer. If separately testable is a 

judgment, and I think introduces some uncertainty or a 

little less confidence in the definition. 

 MR. MCNEIL: Don McNeil, do you think this is 

going to become our testable configuration when we refer to 

fans? 

 MR. SMITH: Yes. I think when we refer to fans 

this is the definition that will apply. 

 MR. MCNEIL: Testable. 

 MR. SMITH: Well, I think if you want to make, if
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there was a statement in the regulation that talks about 

testable configuration of a fan. So, you know, you know, 

can you make a case that there's a subset of this structure, 

a subset of impeller, shaft, bearings and structure, or 

housing, testable, that's an argument that could be made. 

This is a fan. Okay? 

 MS. WALTNER: This is Meg. Wouldn't the testable

configuration be defined in the test procedure? I guess 

that's a question for John who is actually not here yet. 

 MR. SMITH: John is here. 

 MR. CYMBALSKY: I'm here but that's not a question 

for me. Honestly, I don't manage the test procedure part of 

the program. 

 MR. SMITH: Yes. 

 MR. CYMBALSKY: So the answer is yes, Meg. 

 MS. WALTNER: Thanks. 

 MR. SMITH: So what was your question again? 

 MS. WALTNER: So we were talking about the 

testable configuration. I don't think that's something we 

need to deal with in the definition of a fan. That seems 

like a test procedure question not sort of a fundamental 

definition of what is a fan as a covered product. 

 MR. FERNSTROM: So Meg, this is Gary. If I could

follow along, I recognize the concern and the interest of 

some in the group of wanting to add that, but I agree with 
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you, that issue ought to come up under testable 

configuration and not under the definition. 

 MR. SMITH: Dan, go ahead. 

 MR. DELANEY: So one question, I know we had -- 

Dan Delaney, Regal. One question we had, we discussed the 

driver definition and we talked about, oh, do we really want 

to get into the engine or steam control. Did we decide 

those are still viable, that a fan would be that? Or did we 

want to change driver just to say electric motor? 

 MR. BUBLITZ: Mark Bublitz, I do not believe we 

said electric motor. There were questions about being 

connected to the grid. 

 MR. DELANEY: We didn't take it off the table, did 

we? 

 MR. FERNSTROM: Well, whether it were measuring 

the shaft brake horsepower or the electrical input depends 

upon whether this product is sold with a motor or not. And 

if it's not sold with a motor -- 

 MR. SMITH: Or whether there is gas in the engine. 

 MR. FERNSTROM: Well, I think early on in the 

discussion between you and the advocates we felt that market 

share of engine-driven fans was small enough we didn’t need 

to deal with that. Thinking about what the Edison Electric 

Institute would have to say, I think they would want to 

include natural gas pipeline-supplied engines in the mix, 
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but I don't think they would care about fuel engines because 

they're concerned about the gas versus electric implications 

of this. 

 MR. SMITH: So in the marketplace they are varied

in the 100 to 200 horsepower range. There are very few fans 

driven by anything other than electric motor. And in the 

discussions that we had with the advocates, there was 

generally agreement around the table to restrict the 

regulation to grid-connected electric-driven fans. And the 

reason I use grid-connected is because we have electricdriven fans that are in locomotive engines that are used on 

trains. We have other electric-driven fans that are not 

grid-connected. 

 MR. FERNSTROM: But again, this is Gary, we want 

to be sure to accommodate the situation where we have a bare 

shaft fan. 

 MR. SMITH: Yes. 

 MR. FERNSTROM: And that's what's being tested. 

So if a motor is included it's probably going to be an 

electric motor. And if it isn't, there's probably some good 

reason why it isn't. 

 MR. SMITH: Well, the question on the table is do

we want to change the word driver to electric motor? 

 MR. FERNSTROM: I think we need to leave it driver 

to accommodate the situation where we're looking for the 
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shaft horsepower. 

 MR. WHITWELL: I'm sorry. Yeah, this is Bob 

Whitwell. Carrier, United Technologies, and Sikorsky 

helicopter, and Pratt and Whitney jet engines, which maybe 

are considered fans, I don't know. But I think we should 

limit it to electric on the grid. 

 MR. SMITH: So the helicopter fan is not included. 

 MR. WHITWELL: Nor the tail rotor, nor the fan in

the jet engine. 

 MR. MAGILL: John Magill, I’m on the fan 

committee. If I remember correctly, there is a definition 

much further down the spreadsheet. 

 MR. DELANEY: There is a possible -- it was 

proposed. 

 COURT REPORTER: I can't hear you. 

 MR. DELANEY: There was a proposal, the driver 

definition. It was in the original meeting. It included 

the IC engine. 

 MR. DIKEMAN: We haven't gotten to the driver. 

 MR. DELANEY: Driver is on line 52. 

 MR. DIKEMAN: No, I mean on Wade's thing up here.

 MR. DELANEY: No. 

 MR. SMITH: Mark? 

 MR. BUBLITZ: A question for the regulation 

experts. If you define a fan, do you need to, I mean can't 
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we put the driver part in the scope definition? Does it 

have to be in the definition of the product? 

 MR. DIKEMAN: Driver is coming up after impeller,

isn't it? 

 MR. SMILEY: Well, Bill Smiley, Trane. Driver is

down at the bottom of Wade's spreadsheet and it includes 

every potential driving mechanism, except windmills, which 

you could possibly imagine. But I think your committee said 

they weren't ready to address anything except electric 

motors, and I assume they mean connected to the grid because 

that's the whole purpose of what we're trying to do here. 

 MR. SMITH: Well, do you want to take a thumbs on

that? 

 MR. JASINSKI: So Wade, really quickly before we 

do that, just to put this, maybe make this conversation more 

efficient. I don't think that this conversation is

applicable to that DOE proposed definition that you have up 

there. That definition is a part of the authority 

discussion that we were having yesterday, and if you 

remember from the first meeting, Ashley in DOE said that the 

definition itself is going to be kept broad, the definition 

of a fan, the overarching definition of a fan. 

 MR. SMITH: When we were talking about scope of 

coverage? 

 MR. JASINSKI: We were talking about scope of 
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coverage. So we want to start making a list that says scope 

of coverage, this is in and this is out, which this working 

group wants to set standards, that is perfectly fine. But I 

would say, for the most part, it is not, it is not that 

useful to try to tweak that definition any more than it's 

already been tweaked. I think it's better to make a list of 

the things that the group wants in and what the group wants 

out, which is what it sounds like the group is discussing 

here. 

 MR. MCCABE: Michael McCabe, one thing to point 

out is that the fans, as listed in the legislation fall in 

the section that deals with commercial and industrial 

buildings. So that does limit what is covered. 

 MR. CYMBALSKY: I think we're going to keep, you 

know, we're going to keep this definition broad and I agree 

with Sam. Let's move forward with scope at the appropriate 

time. 

 MR. SMITH: Okay. 

 MR. SMILEY: Bill Smiley, Trane, so does that mean 

we're going to keep a what's in-what's out list, or we're 

not going to keep a what's in-what's out list? 

 MR. CYMBALSKY: Well, that's part of the 

negotiations, right? 

 MR. SMITH: We should keep a list. 

 MR. SMILEY: We should keep a what's in-what's out 
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list? 

 MR. SMITH: Yes, Mr. Bublitz has agreed to -- 

 MR. BUBLITZ: I am logging that. 

 MS. MAUER: This is Joanna Mauer. Wait, how do 

you know the fan is going to be grid-connected? 

 MR. SMITH: So you don't. So the fan which -- 

well, a fan, this definition you don't know and don't care. 

 MS. MAUER: Right, in terms of the -- 

 MR. SMITH: But later on when we talk about scope, 

if the fan is made and it's got a motor attached, then if 

that motor is obviously a grid-connected motor, it doesn't 

matter whether it's attached to the grid, it's covered 

because the fan is covered. It's capable of being connected 

to the grid. 

 MR. FERNSTROM: Well, this is Gary. 

 MR. SMITH: Let me, let me just say this. A fan 

which is shifted with a bare shaft, certified with a bare 

shaft, you also don't know, like clearly a bare shaft fan 

can be grid connected. Therefore, it would be covered. 

 MR. FERNSTROM: This is Gary. I think you just 

said the magic words, can be, because I'm worried about the 

renewables application where you might well have an electric 

motor but it's not grid-connected. It's off-grid. 

 MR. SMITH: Yeah. 

 MR. FERNSTROM: And we'd want that covered. 
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 MR. SMITH: Right. 

 MR. SMILEY: Bill Smiley with Trane. Well, what 

he's talking about is definitely true for standalone fans, 

but for virtually every fan that shifts out a product in the 

company that I work for is connected to an electric power 

input device, usually the grid. Every unit that we ship has 

a motor and it's connected electrically. It's not driven by 

a gas engine for a diesel engine or any of that kind of 

stuff that goes into a building or industrial plant. 

 MR. BUBLITZ: Mark Bublitz, there's 57 items on 

the list and I would like to recommend we keep our scope 

discussion on in the scope area and keep going. 

 MR. SMITH: Okay, can we go to the next one? Just 

scroll down to the next one. 

 Okay, here we have impeller, structure and 

housing. And the DOE proposal on the ASRAC and has been 

accepted by our fan committee and is fine with AMCA, so a 

propeller is a rotary bladed aerodynamic component 

responsible for the total energy increase to the airstream 

delivered by the fan. 

 The structure is any integral component of the fan 

necessary to support the impeller. 

 And housing, any integral components of the fan 

that direct flow into or out of the impeller and/or provide 

protection to the internal components. The housing may 
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serve as the fan's structure. 

 It's pretty straight forward. Okay, let's scroll

down. And I’m not trying to cut off discussion here, but I 

think in the interest of time we want to race through these, 

answer your questions and then have you contemplate and 

consider. 

 Okay, here, commercial and industrial, we, our 

members said we don't know what commercial and industrial 

is, but we know what non-residential is. The problem with 

the non-residential name is that there is lots of 

residential commercial buildings, like hospitals are 

residential, hotels are residential, multifamily are 

residential. They often times have larger, central systems. 

So the use of residential and non-residential is problematic 

and we don't know what to do about this. 

 MS. PETRILLO-GROH: Wade? 

 MR. SMITH: Yes. 

 MS. PETRILLO-GROH: Laura Petrillo-Groh, AHRI, can 

you repeat what you were saying about hospitals and

multifamily? 

 MR. SMITH: Well, certainly multifamily is 

considered residential. 

 MS. PETRILLO-GROH: For, by whom? 

 MR. SMITH: ASRAC. 

 MR. ROY: Three stories or less. 
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 MR. SMITH: Okay. 

 MR. ROY: Anything above three stories is 

commercial. 

 MR. SMITH: Okay. And hotels. 

 MS. PETRILLO-GROH: Again, three stories. 

 MS. MAUER: This is Joanna. It seems to me that 

it would be better to avoid defining commercial and

industrial because that gets into application of a 

manufacturer isn't going to know whether their fan is going 

to, or where it's going to go. 

 MR. SMITH: So you'd say don't bother to define 

commercial and industrial? 

 MR. SMILEY: Bill Smiley, Trane, that's part of 

the whole title of what we're working on is 

commercial/industrial, but I don't know what it is. Well, I 

have an idea of what I think it is. 

 MS. MAUER: I think what we're trying to do is 

define the types of fans as a characteristic of those fans 

that would be covered, not how a certain fan would be used. 

 MS. PETRILLO-GROH: Sure, but when we're talking 

about building a fan into a housing unit, if that's where 

we're going with this, we certainly do know where our 

commercial and industrial sectors are versus residential. 

 MS. MAUER: Well, even a piece of equipment we 

don't necessarily know, you know, know where it's going to 
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be used necessarily, but I'm not sure that that matters. I 

think we can just focus on defining it. 

 MR. CYMBALSKY: Well, getting back to the scope. 

 MR. SMITH: I'm sorry? 

 MR. CYMBALSKY: Back to the scope. This is not 

even part of it. Again, go back to the scope, what's inwhat's out? 

 MR. SMITH: Okay, so -- 

 MR. CYMBALSKY: That doesn't need to be defined. 

 MR. SMITH: Right. 

 MR. WHITWELL: So John, I mean I just jumped a 

little bit ahead on scope. So perhaps we could say the 

scope, as it relates to HVAC equipment, would be what DOE 

defines as commercial HVAC equipment, as opposed to

residential, right? Where we come off as single phase, less 

than 65,000 BTU per hour, something like that, right, could 

be part of the scope? 

 MR. JASINSKI: Yes, so I think, I'll propose 

another way to do this. I would say once, to the overall 

fan definition is important as a mechanism for sort of 

defining DOE's authority. So that, I mean that's not on the 

table. But once we start getting into these types of 

definitions, these definitions will be mechanisms for the 

test procedure, for defining the scope as the working group 

wants it, so I think it might almost be better to discuss 
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pretty straightforward about what each of you wants in and 

what each of you wants out. And then once you have that 

list, you can come back to these definitions and tweak them 

to make sure that they align with what the working group 

agrees to. 

 For instance, the discussion about grid connected

or, you know, do we want helicopter rotary blade, you know, 

rotors in this. If the working group says no, then you go 

to these definitions and make sure that they are such that 

those are not included. 

 So it's, I would say that doing the definitions 

first is sort of tempting because I think it skirts maybe 

the tougher conversations, but it might be better to just be 

straightforward about what each of you wants in and what 

each of you wants out, and then the definitions can be 

crafted to match that. 

 MR. WAGNER: This is Greg. I'd like to make 

comments. Hello? 

 MR. SMITH: Go ahead. 

 MR. WAGNER: The Department, in recent rulemaking

for residential furnace fans, defined what residential was. 

Why can't it not continue with that same sort of definition 

that those products outside of that residential scope is 

what is covered under commercial and industrial, because 

they do have a rulemaking for residential fans already. 
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 MR. JASINSKI: So what I was saying is that it 

can, but the way that would impact the rule is, you know, if 

this working group decided that it wanted certain fans that 

are used only in residential applications out, it could 

craft a definition for commercial and industrial or for 

residential and encompass those, and then vote to exclude 

them. 

 So Greg, it could absolutely come up with 

definitions for residential, commercial and industrial as a 

mechanism for defining and eliminating the scope for the 

working group. And then those could be used in the test 

procedure and in the standard. 

 MR. SMITH: So, just wait a minute. So Sam, 

you're saying come back to this later? 

 MR. JASINSKI: I'm saying make that list of what 

you want in and what you want out. 

 MR. SMITH: Okay, I've got it. 

 MR. JASINSKI: And these definitions are what you

use to make that so in the rulemaking. 

 MR. CYMBALSKY: I think we did exactly this for 

pumps, as I recall in the negotiations. With the pumps, 

it's very, very broad and includes some residential stuff. 

 MR. SMITH: Yep. Okay. Let's go to the next. 

Scroll down, if you would, a little bit. 

 Okay, so we haven't figured this out. This is 
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safety fans and certain oddball, difficult process 

applications, very, very difficult to tackle. There is a 

philosophical intent that says, you know, safety fans that 

exist and sit idle but only run on an emergency basis, don't 

consume much energy and, therefore, don't really matter. 

And of course are designed for safety and not for 

efficiency, and that seemed to be fine for everybody, but 

when you get down to the writing a definition that will be 

used to exclude those fans but not create a loophole for 

other fans it becomes very difficult. 

 And I’m not saying we've given up on it, but I’m 

just saying that on this subject we sort of ended up where 

Sam just described -- let's go figure out what we want to 

have exempt and then we will come back to this question. So 

we really haven't tackled this one very adequately.

 MR. BOTELER: It's a little bit -- Rob Boteler 

with Nidec, that's a little bit similar with what we do with 

fire pump motors. And the way we got around that is it's 

separate equipment class and it is labeled by the NF -- what 

is it? NFPA? 

 MR. SMITH: NFPA. 

 MR. BOTELER: Right, so it has a separate label. 

 MR. SMITH: Right. 

 MR. BOTELER: You might consider that. 

 MR. SMITH: Right. And so that kind of third 
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party approval for certain types of products, et cetera is 

on the table but we haven't figured it out yet. All right? 

So, if you all have feedback or ideas about definitions that 

will help us there, I think that will be most welcome. 

 Okay, so here's an example, a jet fan. And the 

fan committee responds that jet fans need to be evaluated 

based on thrust and power, which is, has nothing to do with 

the definition. And so we're, we're going to have to come 

back and revisit this one too. The AMCA members are 

generally fine with a jet fan being regulated under this 

regulation unless it is reversible. And if it is 

reversible, the entire design of the fan has to be 

compromised so that it can have performance that is

specified in reverse flow as well as forward flow. And that 

compromise includes a lot of efficiency compromise.

 So they asked of the fan committee, we asked the 

fan committee was to create a definition that distinguished 

these two types of jet fans, and they didn't have time to 

tackle it basically. So just to make clear for our list of 

in's and out's, we would be fine if jet fans were in but not 

fine if they are reversible. The only caveat is that jet 

fans have a rating standard which has nothing to do with 

flow and pressure. It has to do with thrust. And the 

reason that thrust is used is because it's a proxy for the 

useful output of a jet fan, which is a plume of air moving 
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quickly in a certain direction. 

 And in a perfect world, you'd actually measure 

that plume, figure out what the velocity is at some

particular distance from the fan. Such a rating standard 

doesn't yet exist, although it's being talked about, and so 

the proxy for -- oh, I love that word proxy -- the proxy for 

that is to measure the thrust of the fan, which is 

equivalent to its plume power. 

 MR. WHITWELL: Wait, wait, what are the jet fans,

what are these for? 

 MR. SMITH: To ventilate tunnels and car parts. 

 MR. WHITWELL: Okay, so it could be, and maybe 

it's a different probably class for the reversible one 

versus the ones that are non-reversible. 

 MR. SMITH: Right. We just have to define it. 

That was the mission here. 

 MR. FERNSTROM: Wait, wait, this is Gary, no 

proxies about it. 

 MR. SMITH: Thank you. 

 MR. SMILEY: This is Bill Smiley, without defining 

specifically the thrust values, a condenser fan could be a 

thruster or a jet fan because you want to get the air up and 

away. So just to be certain. 

 MR. SMITH: Thank you. 

 MR. SMILEY: So there should be, you know. 
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 MR. SMITH: Lots of things could be. It's what it 

is. 

 MR. SMILEY: Yes. 

 MR. SMITH: So what it is that jet fans are rated

on the basis of thrusters. 

 MR. WHITWELL: Yeah, but I mean a lot of the 

products are rated differently than what we're talking about 

here. 

 MR. BUBLITZ: So do you have a proposal? 

 MR. WHITWELL: It could be rated on efficiency. I 

mean I don't know enough about what these jet fans are, but 

I don't think it should be exempted just because it has a 

thruster. 

 MR. BUBLITZ: We're not -- 

 MR. SMITH: We didn't ask for a definite -- we 

didn't ask for an exemption. We asked for a, we asked for a 

definition. 

 MR. WHITWELL: Okay, well I thought the way you 

were leading up to that, perhaps, in some future point. 

 MR. SMITH: No, what I said -- 

 MR. WHITWELL: I apologize if I misunderstood. 

 MR. SMITH: Well, what I said just to be clear is

that AMCA group is fine with jet fans being regulated under 

this regulation using the metrics that we talked about, even 

though they are different than thrust, and is not fine with 
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a reversible jet fan because it has an efficiency 

compromise. 

 And so in the next breath somebody might argue 

that if we made one for an efficiency compromise -- yeah, I 

mean all of these things are possible. At the end of the 

day it becomes a question of how much energy, what's the 

connected load, what's the effort for the regulators and for 

the regulated to comply, and is the juice worth the squeeze. 

 And as the presentation from AHRI and others 

pointed out yesterday, this is a very, very complicated 

scope. There's lots of variety here. And in some places 

you have to start paring it back to become practical. And 

since the connected load of jet fans is really small, it's a 

candidate to come off the list, okay? 

 MR. DIKEMAN: We've still got to define it? 

 MR. SMITH: Yeah, but we haven't defined it yet. 

Okay, so let's move on. 

 MR. HAUER: Wait. 

 MR. SMITH: Yes? 

 MR. HAUER: It's Armin Hauer speaking. 

 MR. SMITH: Yes, sir. 

 MR. HAUER: I wish everyone could see the 

European-like relation on that one, talking about the jet 

fan and exclusive atmosphere and corrosive media. So maybe 

it would be easy to harmonize them. 
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 MR. BUBLITZ: Do you have that regulation number 

in your head? 

 MR. SMITH: Actually, Armin, I think when we first 

started talking about safety fan exemptions we started with 

that. And there are some difficulties with the European 

definitions under the American law. They are permissive in 

terms of their description of a product linked to its 

application, and we are trying to find definitions that are 

not dependent upon how the fan is applied but rather are 

very clear so that if you're standing, if you're on the 

beach and -- you know. 

 MS. ARMSTRONG: That's me. 

 MR. SMITH: Welcome, Ashley. 

 MS. ARMSTRONG: Good morning. Cross flow fans --

go ahead? 

 MR. ROY: I had a question. So you mentioned with 

jet fans there are a couple of applications, tunnels and 

parking garages. And so what was it determining, how did 

you make the determination that the lower the smog level 

because intuitively it seems like, you know, it would be 

used in a variety of applications across the board. That 

there are quite a few tunnels and parking garages. 

 MR. SMITH: Right. 

 MR. ROY: So how did you make that determination?

 MR. SMITH: We counted the number of jet tunnel 
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fans that our members ship, including their connected load, 

the horsepower of those fans, and added them up. You know, 

I might add that jet fans are much more common overseas than 

they are in the United States. Generally, we don't use jet 

fans in car parts. They are used commonly, commonly used in 

tunnels. 

 MR. ROY: So you have an approximate estimate or 

is that just proprietary? 

 MR. SMITH: No to both of those questions. Not 

proprietary and I don't have an estimate at my fingertips. 

 MR. ROY: Okay. 

 MR. SMITH: Okay. Okay, then we come to cross 

flow fans. What happened to our cross flow fan there? 

There we go. It's down, another one. There you go. 

 Is there anything about cross flow fans? Did I 

miss something? Oh, it was jet fan, okay. 

 Cross flow fans, another example of a product that 

has a very low connected load and a very specialty 

application. We find them in small, through the wall and 

many split products. Certainly less than one horsepower. 

In horsepowers that are one or greater, they sometimes 

appear in air curtains and they sometimes appear in

industrial applications where -- well, like in wind tunnels, 

for example, where they're trying to test and they need the 

certain air distribution that a cross flow fan gives them 
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and it turns out to be a good solution. But it's an odd 

ball product and a very small connected load. Each one of 

these products takes a lot of work to get to a regulation, 

and this is one - and air curtains - where we want to ask 

for an exemption. 

 I think where we are, and we'll let you read this

later, but I think where we are over here on the left was 

just fine with the fan committee. We sort of, in this 

column here of definitions, so a cross flow fan is a fan in 

which the airflow path through the impeller blades is in a 

direction that right angles to the axis of rotation, with 

airflow both entering and leaving the impeller at the 

periphery. 

 And then the definition for air curtains is 

something that Dave Johnson has been working on with his 

team. And I'll just let you talk this through, if you 

would, Dave. 

 MR. JOHNSON: Yes, Dave Johnson, Berner 

International. The air curtain fans is a fixed location or 

air moving device that produces a directionally controlled 

air stream moving across the entire height and width of a 

building opening, which reduces the infiltration or transfer 

of air from one side of the opening to the other, and/or 

inhibits flying insects, dust or debris from passing 

through. 
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 There was a request to as it's in a cabinet to 

somehow from the DOE to add some sort of identifier to it. 

And we were able to pretty much guarantee that the discharge 

of a unit always has a width across the building opening 

that's at least five times the diffuser's depth. So, in any 

cases where the nozzle is a couple of inches, you know, 

we're always at least, you know, 36 to 48, towards, you 

know, all the way up to 16 feet. So this is not your 

typical fan application, but defined based on resisting 

infiltration or exfiltration across an opening and, in many 

instances will, as Wade said in his other applications, make 

a fan less-efficient to make a product more efficient. We 

can more effectively resist resistance across an opening by 

sometimes changing, either making our own scrolls or 

mismatching housings and impellers to give us a plenum 

design that will give us a more effective profile of an 

airstream to cover an opening. 

 MR. SMITH: So on this particular product the AMCA 

members are asking for an exemption. And the argument, and 

it should go on our to-be-determined list, but the argument 

for an exemption is that the purpose of this product is to 

save energy, to prevent infiltration across an open doorway. 

And, you know, its net energy use is negative. Its net 

energy use is negative. And so, you know, anything that 

would encourage its use in the marketplace -- 
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 MR. SMILEY: What about an economizer? It's the 

same thing. Net energy -- 

 MR. SMITH: Okay, can we just talk about air 

curtains for a minute? 

 MR. SMILEY: Well, you can't -- 

 MR. SMITH: Yes, yes, we can actually. Okay, 

we're going to talk about air curtains. We can talk about 

economizers later. 

 So, the air curtain prevents infiltration and, you 

know, when you sit down to design an air curtain, as Dave 

said, you know, you care most about its effectiveness at 

doing that. And so the best metric, and by the way, the 

manufacturers of air curtains that are part of AMCA are not 

opposed to regulation of the efficiency of their product. 

They would, however, like that regulation to have in its 

numerator the effectiveness of the air curtain at preventing 

Infiltration. And in its denominator, the power that it 

consumes. 

 So this is one that if you use the traditional fan 

power as the numerator, you end up with unintended 

consequences in the design of the product that compromises 

its performance and could result in a net energy increase. 

 Laura? 

 MS. PETRILLO-GROH: I'm still curious to what kind 

of fans are used in these products. It doesn't seem that 
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the definition is specific to -- 

 MR. SMITH: There are three different types of 

fans that are used: cross flow fans, forward curved fans, 

backward inclined fans. 

 MS. PETRILLO-GROH: So, just -- 

 MR. SMITH: And occasionally, occasionally an 

axial. 

 MR. JOHNSON: Dave Johnson, Berner, and also axial 

fans. All different fan types. And in some instances 

they're matched and other times they're just embellished. 

Again, we will take centrifugal impellers but not 

centrifugal housing to create part of a cabinet to be the 

housing. 

 MS. PETRILLO-GROH: So this is quite fairly a 

similar issue that we're all facing with some -- 

 MR. SMITH: Yes, the difference is they have a 

really low connected load. In other words, the total, the 

total -- 

 MS. PETRILLO-GROH: Oh, that's the difference? 

 MR. SMITH: Yes, that's the difference. I mean, I 

mean it's a trivial segment of the market. 

 MS. PETRILLO-GROH: So how would one tell a fan 

coming off the line is going to air curtain versus one 

that's going somewhere else? 

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goes in an air curtain should be unregulated. We're 

suggesting that the air curtain should be unregulated. 

 MR. WHITWELL: So you're talking about a product 

class perhaps? 

 MR. SMITH: Definition. 

 MR. WHITWELL: Okay. 

 MS. ARMSTRONG: Wait a minute. Can you explain 

what you just said real quick? 

 MR. SMITH: Me? 

 MS. ARMSTRONG: Yes. 

 MR. SMITH: Yeah, if the fan, if Berner 

International purchases a fan, which is one horsepower or 

above that is regulated, he's buying a regulated fan. 

 MS. ARMSTRONG: For inclusion into air curtain 

products? 

 MR. SMITH: That's correct. 

 MS. ARMSTRONG: And if he doesn't purchase one and 

he makes it, let's say he makes it himself in an air curtain 

product, is that fan still regulated? 

 MR. SMITH: Well, that's up to the working group 

and the DOE. 

 MS. ARMSTRONG: So where is there -- 

 MR. SMITH: The working group to recommend to the

DOE -- 

 MS. ARMSTRONG: What is it supposed to be though? 
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The fan or the air curtain as a whole? 

 MR. JOHNSON: The air curtain as a whole. 

 MS. ARMSTRONG: Inclusive of the fan or not? 

 MR. JOHNSON: I would say it would be inclusive -- 

Dave Johnson, Berner, I would say it would be inclusive of 

the fan. 

 MR. SMITH: Yeah, the answer to your question -- 

 MR. JOHNSON: Whether it would be built into the 

cabinet and not built as fan to be shipped or sold 

separately. 

 MR. SMITH: The fan is regulated, the air curtain, 

we would propose, is not. 

 MS. ARMSTRONG: That's not what you just said. 

 MR. SMITH: Is that, do you agree with that? What 

I just said? 

 MR. JOHNSON: Well, the question asked if we, if 

the air curtain manufacturer was to build a fan, then we 

would have to regulate the fan to then stick in the air 

curtain product. 

 MR. SMITH: Oh, well, I think another scenario 

which would be more likely is that they buy an unregulated 

fan and put it in their product, buy it overseas. I know 

what your concern is. 

 MS. ARMSTRONG: That's not possible. You just 

said if they buy a fan, it would be a regulated fan. 
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 MR. SMITH: No, I didn't. I said if it's in the 

scope of the regulation, and it's a fan and it's made then 

it's regulated. That would be the proposal. 

 MR. DYGERT: I have a question with the 

definition, Ryan Dygert, Carrier. What happens if you have 

a cabinet that has a, does dual-duty? So it not only moves 

air through the cabinet but also serves to form an air 

curtain? I'm thinking of refrigerated display cabinets and 

such? 

 MR. SMITH: That's a good question. 

 MR. BUBLITZ: I should probably write that down. 

 MR. SMITH: Yeah, I don't know. 

 MR. WHITWELL: Mr. Smith? 

 MR. SMITH: Yes? 

 MR. WHITWELL: In the interest of time, 30 

definitions to go. 

 MR. SMITH: Okay. 

 MR. WHITWELL: Can we restrict the discussion on 

scope and keep the commentary on definitions? 

 MR. SMITH: Okay, so let's move on. 

 MS. ARMSTRONG: So one thing. We had a client 

from the webinar, and it's from Rod Coffey (phonetic sp.), 

and he contends that this is an application not a specific 

fan-state definition. And that's what my, I mean just 

following on to that, that's what my question was getting 
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at. 

 MR. SMITH: Yeah. 

 MS. ARMSTRONG: What exactly is your ask? 

 MR. SMITH: Right. Right. Well, the ask is to 

have the air curtain be unregulated. 

 MR. WHITWELL: Can we stick to the definitions, 

please? 

 MR. SMITH: Well, I was just answering the 

question. As a comment, Ashley, we have this issue with 

other products as well where like roof ventilator. You can 

look at a roof ventilator and say, well, that's a housing 

wrapped around an unshrouded impeller, but the membership of 

AMCA, and we would hope the working group supports the idea 

that a powered roof ventilator is a product, is a fan, and 

it is regulated under this scope. 

 That's our intent. That's our proposal. And even 

though what could be done is break it apart, that's not what 

we propose that the regulation allow for. 

 And so, in air curtains, what could be done is you 

could break it apart. But you run into this, Ashley, on 

product, after product, after product. And so at the end of 

the day, you have to make a decision of am I going to 

regulate it as a product or am I going to regulate it as a 

minimally testable component. 

 MS. ARMSTRONG: So we'll let you, just so we all 
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stay calm for 9:00, we'll let you proceed with the 

definitions. But why intent is important is because if you 

don't get it right in the definitions, your definitions is 

how we implement intent. 

 MR. BUBLITZ: Mr. Jasinski recommended we go 

through the definitions. 

 MS. ARMSTRONG: No, I understand. 

 MR. BUBLITZ: Minus scope and then come back and 

do the definitions again that more align with the intent of 

the scope. 

 MS. ARMSTRONG: Right. 

 MR. JASINSKI: Wait, maybe to clarify, my 

recommendation was to not go through the definition. 

 MR. BUBLITZ: That's what I thought. 

 MR. JASINSKI: My recommendation was to be upfront 

about what you want in, what you want out, and then once 

that list is agreed upon, the definitions can be written to 

make that so. That was my -- 

 MR. SMITH: Okay, well we'll cross cross-flow fans 

out. 

 MR. JASINSKI: And that's fine. And I think then

that's the discussion the group should have because what 

ends up happening is that when you talk about each line and 

the definition is that you get all these lines of 

questioning about well, what's the implication? Does that 
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mean it's in? Does that mean it's out? Are we regulating 

at this point or at that point? And so it's more, I think 

it's probably more efficient to just have the conversation 

about is it in, regulated here, not here, et cetera. 

 MS. ARMSTRONG: Right. 

 MR. JASINSKI: Just be upfront about what, what 

you're, what you're asking and what you want and let the 

group discuss it in that way. 

 MR. WOLF: So this is Mike Wolf, Greenheck. And 

so that's what I thought we were asking. And my question is 

how do we get there because we need some sort of a template 

to follow, and the template that comes into my mind is I 

think one of the slides that we had up at the last ASRAC 

where we got, and let's just start with the helicopter 

blade, in or out, probably out. Okay, let's talk a backward 

inclined blower, probably in. Air curtains, maybe. We need 

to define it more. But go down through those broad

categories first and get those on the list, and then what 

you're saying is come back around and put some definitions. 

 MR. JASINSKI: Right, I mean -- 

 MR. WOLF: Put them on those products that fall 

under those. 

 MR. JASINSKI: Right. 

 MR. WOLF: Or don't. 

 MR. JASINSKI: Right. And I can imagine there 
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being three lists. You might have the ones that everybody 

agrees on, and I don't think anybody knows what those are. 

It sounds like there are a few out there that everybody 

could agree on, but we don't know that yet. 

 MR. WOLF: Right. 

 MR. JASINSKI: Maybe that's -- 

 MR. WOLF: Maybe that's -- 

 MR. JASINSKI: That's one list. There's another 

list that everybody can agree on of what's in, and then 

there's all the stuff in between. 

 MR. SMITH: Well, why don't we -- I think it's a 

great suggestion. 

 MR. WOLF: How do we get to make this? 

 MR. JASINSKI: Make the three lists. 

 MR. SMITH: Can I make a suggestion? Yeah, we'll

go through the definitions and we'll see the definition and 

then we can say whether we want it in or out. And the 

reason I say that's handy is because all the fan, all the 

fan categories, to be a category we've got to have a 

definition. So this is useful. 

 MR. JASINSKI: Yeah, I would agree with Wade. I 

would say that instead of, you know, air curtain, here's how 

we, here's the, here's what we're talking about. This is 

the definition. We're not talking about rewriting this 

definition. We're saying that once you understand this -- 
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 MS. ARMSTRONG: In or out. 

 MR. JASINSKI: -- what it is and what we're 

talking about, in or out. Great, so each of these lines, 

the question, the end question should be in or out, not what 

should this definition say. 

 MR. WOLF: Mike Wolf, again, in the interest of 

I'm just sensing a little anxiety there, but in the

discussion -- so the discussion, the question right now on 

the table with air curtains, in, out or we don't know? 

 MR. WHITWELL: I think we don't know. 

 MR. WOLF: Okay. 

 MR. WHITWELL: From the discussion. 

 MR. WOLF: Let's go on. Next one. Move on. 

 MS. ARMSTRONG: I feel that -- 

 MR. WOLF: Do you agree with that, Mark? 

 MR. BUBLITZ: I think it's a larger discussion, 

right. 

 MR. WOLF: But for right now, in, out or we don't

know. 

 MR. STARR: I think part of this, too, this is 

Louis with NEEA, part of this is just so other people 

understand what the air curtain -- 

 MR. WOLF: And that's fair. 

 MR. STARR: Some of these people don't know what 

an air curtain is until they got to this meeting. So this 
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definition catches that but it would be a bad legal

definition. So -- 

 MR. SMITH: Okay, I just want to add that air 

curtains have a connected load that we estimate at about 

50,000 horsepower per year. 

 MR. WOLF: So just an idea. 

 MR. SMITH: Say it out loud for the record. 

 MR. JOHNSON: Dave Johnson, Berner International,

that 50,000 includes below one horsepower. 

 MR. SMITH: Okay, axial fan, so we ended up with 

this definition here. A fan in which airflow enters and 

exits the impeller parallel to the shaft access. The axial 

fan may or may not be equipped with a cylindrical housing, 

inlet or outlet guide vanes, outlet diffuser, orifice panel 

or orifice ring. 

 Any questions about that? 

 MR. WAGNER: This is Greg. 

 MR. SMITH: Go ahead Greg. 

 MR. WAGNER: Within, since these are legal 

definitions, does something like parallel mean it has to be 

exactly parallel? In previous line, in the cross flow it 

was essentially perpendicular and then it was changed to 

just perpendicular. So if it's off at 91 degrees, does that 

not qualify? 

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specific fan that you have in mind that is at 91 and would 

not meet this definition that you think it should? Or, 

because again, that question sounds like we're trying to 

tweak the definition and I think that it would be better to 

say if everybody in the room pretty much agrees on what an 

axial fan is, regardless of legal definition - a legal 

definition, like I said, can come later - but if everyone in 

the room is thinking of the same set of fan when we say 

axial fans, I don't think we need to necessarily have that 

discussion. We just need to say if this, are axial fans as 

we all understand them to be, in or out, or we don't know. 

And then the legal definition can come later. 

 But if there is a specific fan that you don't know 

how to classify as either axial or I guess the other one 

would be mixed flow because of the angle of the air, then 

maybe this would work well in the discussion. 

 MR. WAGNER: It does get tricky when you start 

getting into mixed flow versus axial, even some centrifugal 

versus mixed flow. But back to the cross flow, they don't 

really exit perpendicular. It is essentially perpendicular. 

They often, you know, they'll go in different directions. 

 But anyhow, my point is that if these are legal 

definitions, which somebody said a little bit earlier, we 

should be a little more precise in what we're trying to say. 

 MS. ARMSTRONG: And I think what you're hearing 
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from DOE is we will be more precise at some point in time, 

perhaps not today and, in all honesty, once our lawyer team 

gets a hold of these definitions you're going to see words 

replaced. So it would be a good exercise to give us some 

chance. Once we understand the overall intent and what you 

guys want, give us a chance to work with them a little bit 

in terms of what they'll look like in our framework and 

bring them back to you guys. 

 MR. WAGNER: Well, okay, this is where I agree 

with what Armin had said about the ISO definition, and they 

do have some angular measurements and requirements on what 

you have to meet, and that was a nice way to put clear-cut 

definition of what you mean by axial, centrifugal and mixed 

flow. 

 MS. ARMSTRONG: Sounds good. Thanks. 

 MR. SMITH: So I would say we assign the fan 

committee to go back and take a look at that. 

 MR. PERSFUL: Axial fan -- 

 MR. SMITH: Is that specific assignment? 

 MR. BUBLITZ: Yeah. 

 MR. SMITH: What is the specific assignment? 

 MR. BUBLITZ: To test the word -- 

 MR. SMITH: To test the word -- 

 MR. BUBLITZ: Oh, on axial, got it. 

 MR. SMITH: And the next one is vane axial, which
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is an axial fan with a cylindrical housing with guide vanes 

before or after the impeller, or both. 

 MR. SMILEY: So I think, do the, the axial fans 

are in, right? 

 MR. SMITH: Some axial fans are in, certainly, but 

possibly not all. 

 MR. SMILEY: So this is Bill Smiley with Trane. 

So vane axial, tube axial and panel fan are all three 

subclasses of an axial fan? 

 MR. SMITH: Fair enough. 

 MR. SMILEY: Because axial fan includes those. 

 MR. SMITH: That’s true, also jet fans. 

 MR. SMILEY: Yes, well, yeah. 

 MR. SMITH: The next one is tube axial, an axial 

fan with cylindrical housing and no guide vanes. Okay. 

 The next one, the panel fan, an axial fan without

a cylindrical housing, which is mounted in an orifice, ring 

or panel. 

 Any concerns or comments, or questions? 

 MR. PERSFUL: This is Trinity. Do we need to say

in or out, or are we just silence is consent? 

 MS. ARMSTRONG: In. 

 MR. SMITH: We can test this. These three, and 

the AMCA group would suggest that they are, they would be 

regulated. Is anybody, does anybody want to argue for an 
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exclusion? 

 MR. SMILEY: Bill Smiley, Trane, I think in 

general, yes, they would all be in, but there may be some 

limits that we define later in scope. 

 MR. SMITH: Sure. 

 Okay, the next one is circulating fan, a nonducted fan which has no provision for connection to ducting, 

or separation of impeller from its outlet -- excuse me, 

separation of the impeller inlet from its outlet, used for 

the general circulation of air within a confined space. 

 And the proposed revision, let's see, the fan 

committee suggested deleting the last sentence. Okay. So 

the proposed revision was a non-ducted fan, which has no 

provision for connection to ducting or separation of the 

propeller inlet from the outlet designed to be used for the 

general circulation of air. 

 And then the advocates added here that a 

circulating fan has no housing or other than the safety 

guard, and then fan committee challenged the additional 

sentence as adding no value. 

 So do you guys, and I must say that the advocates

have not seen these comments. So if you want to talk about 

it you can, and if you want to wait and talk about it later, 

that's fine too. 

 MR. MATHSON: Wade, this is Tim Mathson. I would
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say that the fan committee said that there are circulating 

fans that have small housings. So that's why they suggested 

that. 

 MR. SMITH: Really? How do you distinguish them 

between a circulating fan and a panel fan? 

 MR. SMILEY: This is Bill Smiley, Trane. Wouldn't 

it be the separation of the inlet and the outlet would be 

the defining difference between the circulating fan and the 

panel fan? Because you could have like a box fan instead. 

 MR. SMITH: Yeah, that's a perfect example. It 

has the small housing but it's a circulating fan. 

 MR. SMILEY: Yeah, but a circulating would be one

without separation, or no separation. 

 MR. SMITH: No separation. 

 MR. STEVENS: This is Mark. I don't agree with 

that because there are circulating fans that do have 

housings to direct the airflow. The difference between that 

is that this is generally like a rolled housing. It goes 

around. It you look at a panel fan, it's just normally 

square with some sort of orifice. 

 MR. SMITH: Right. 

 MR. STEVENS: So a panel fan actually has a panel

attached to it. 

 MR. SMITH: Right, so, but what you described in 

the first case was a tube axial fan, is it not? 
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 MR. STEVENS: A tube axial, it looks like a tube 

axial fan. Yeah. 

 MR. SMITH: So how do I distinguish it from a tube 

axial fan in definition? 

 MR. SMILEY: Bill Smiley, Trane, I would say 

generally the inlet and outlet. 

 MR. STEVENS: Generally, the shape of the blades. 

I would say they are normally flatter, wider with tube 

axial. 

 MR. MATHSON: You know, Tim Mathson from Greenheck 

again, many of these fan designs have just been applied in 

both cases, in both applications. You know, panel fans can 

be hanging up in a back room. 

 MR. SMITH: Right. 

 MR. SMILEY: Then it's a circulating fan. 

 MR. MATHSON: It's a circulating fan. 

 MR. SMILEY: Because there's no -- Bill Smiley, 

Trane, because there's no separation, adequate separation. 

 MR. SMITH: So I think the intent though, is it 

not, that -- this is Wade, that if the fan is intended, it's 

manufactured so that there can be a separation, that's 

what's anticipated, the fact that it's applied as a

circulating fan, it doesn't matter, it's a panel fan and it 

may be applied as a circulating fan but it's a panel fan? 

 MR. SMILEY: Bill Smiley, Trane, then it ends up 
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like your air curtain discussion. It's the application. 

 MR. SMITH: No, it doesn't end up like the air 

current discussion. 

 MR. STEVENS: Well, let's get back to your 

question on tube axial versus circulating. 

 MR. SMITH: Right. 

 MR. STEVENS: The tube axial generally will come 

with some sort of appliance, as you said, to hold up the 

ductwork. In a circulating fan, the housing will not. 

 MR. DIKEMAN: Right. 

 MR. SMITH: So if we go back to the tube axial 

fan, cylindrical housing with guide vanes before and after 

the impeller guides, so no cylindrical housing and guide 

vanes. So you're saying that the existence of a cylindrical 

housing is not sufficient to call it a tube axial fan? It 

also has to have duct connections? 

 MR. STEVENS: On at least one side. 

 MR. MATHSON: Yeah, this is Tim Mathson. I was 

going to suggest that same thing. One of the unique 

features of a panel fan and a circulating fan is no

provision for connection to a duct. That's one obvious 

feature that we hadn't talked about. 

 MR. SMILEY: So, Bill Smiley with Trane, so you 

can only connect it to a duct if it has a fan? I mean, you 

know, now we're starting to, you don't need a fan to hold a 
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duct up. It's typical that that's convenient. I mean this 

is just going to be like the discussion with the air 

curtain. The fan and air curtain -- 

 MR. JOHNSON: This is Dave Johnson, Berner 

International, with the air curtain discussion, what I 

failed to mention is that, you know, the rating methods are 

different. Air curtain, in what we're discussing here is 

how to efficiently move air. And with an air curtain, the 

intent is not to officially say connect the load and move 

air. 

 MR. SMILEY: I say air curtains are out. 

 MR. JOHNSON: You know, what we're, what they 

would be measured upon is how well they effectively save or 

prevent infiltration from across an opening. And that's 

why, whether they build the fan or whether we purchase a 

fan, it really should be rated on the product effectiveness 

and not necessarily it -- because it will fail if you take 

how much energy we move air. But we don't really care about 

how much air we move, we care about how well we cover that 

opening. 

 MR. FERNSTROM: So this is Gary. I take exception 

to that premise. You know, I agree that the air curtain's 

primary purpose may be to improve the efficiency of heating 

and cooling systems by reducing heat loss through doors, but 

there is no reason why an air curtain can't move the same 
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amount of air in the same manner to accomplish that purpose 

and use a more efficient loader, and use electricity in the 

process of achieving that outcome. 

 So to say we don't need to worry about them 

because they're saving heating and cooling in energy isn't 

really addressing the energy efficiency opportunity. 

 MR. JOHNSON: This is Dave Johnson, Berner, what 

I’m saying is we don't have to, we can't rate them. I'm 

staying, or I'm saying that we should not rate them based on 

energy consumption and air output. You would rate them on 

effectiveness and energy input. If I have, if I have two 

products that have the same rating that are capable of 

preventing infiltration, the product that consumes the less 

energy would be the more efficient product. You would not 

rate that based on -- the product that does a better job may 

move less air, you know, but based on a fan rating that 

would be less efficient because you're putting in the same 

amount of energy but getting less air out of it. I can put 

the same amount of energy into a product but get a more 

efficient air curtain. 

 MR. FERNSTROM: How then would we get at the 

opportunity associated with driving the fan with a more 

efficient motor? 

 MR. JOHNSON: Effectiveness, which would be a 

different type of rating that doesn't exist right now. 
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 MR. DIKEMAN: You guys are on parallel train 

tracks right now. 

 MR. SMITH: Right. You both are in the same 

direction. This is Wade. The air curtain folks are not 

regulated. They are against a regulatory metric that has 

the unintended consequence of increasing energy use. 

 MR. FERNSTROM: Okay, this is Gary. So I 

understand and concede. 

 MR. TEAKELL: Let the record show. 

 MR. SMITH: Just say thank you and move on. And 

move on we shall. 

 Okay, here is centrifugal fan. 

 MR. WAGNER: This is Greg. This is Greg. I have

a question on that wonderful housing. There's going to need 

to be a definition on housing if there's some question about 

how you distinguish between a panel fan and a tube axial. 

 MR. SMITH: Yeah, I think we should take that into 

the notes and revisit the question because I agree with you. 

This cylindrical housing thing is a bit of a can of worms. 

So we need to tackle it again. 

 MR. MATHSON: Tim Mathson again, and you know, 

hopefully, what we have proposed is an efficiency metric 

that doesn't depend on these definitions. It depends on how 

the fan is tested. So hopefully this is all minor details 

that don't even matter that encourages substitution between 
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a panel fan and a circulating fan. 

 MR. SMITH: Well, it does matter because the 

definitions also need to distinguish between the circulating 

fan and a tube axial fan, right? 

 MR. MATHSON: I don't, I don't, I don't 

necessarily think that. 

 MR. SMITH: Well. 

 MR. MATHSON: I think it distinguishes, what may 

distinguish those is whether the fan was tested with an 

outlet duct or not. 

 MR. SMITH: Well, so we're also asking for an 

exception for circulating fans because the connected load 

above one horsepower is nearly zero. And that's why the 

definition matters, okay? 

 MR. MATHSON: Yes. 

 MR. SMITH: So in one case you test it and in the

other case you don't bother. 

 So that should be on the -- maybe circulating fans 

should be on the I don't know list. Okay? In other words 

it's been proposed that circulating fans will be exempt. 

 Okay, centrifugal fans, a fan in which airflow 

enters the impeller parallel to the shaft axis but changes 

direction within the impeller and exits the impeller 

perpendicular to the shaft in a radial direction. The 

impeller may have one or two inlets and may or may not have 
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a housing component. 

 Could you just scroll down and see what the fan 

committee said about this? 

 The fan committee said prefer to stick with our 

definition in column D. And at the end of the sentence, 

after the word rotation, the first time, add a new sentence, 

the tangent to the blade of the tip must be at least 25 

degrees from it. 

 Let me explain why it turned out that way. So --

 MR. WHITWELL: But wait a minute. You skipped 

down. You went down one. Right, we were on centrifugal. 

 MR. SMITH: Oh, no action required. Thank you 

very much. Thank you very much. Any questions about the 

centrifugal fan? 

 MR. BOTELER: You're too close to it. 

 MR. SMITH: The mind says, come on Wade, hurry up. 

Okay, go to the next one. 

 So here we have -- 

 MR. WAGNER: Well, before you get off that. 

 MR. SMITH: Yep. 

 MR. WAGNER: Greg again. Before you get off of 

that, I'm not sure what exactly is meant by those, by those 

words of outward direction and opposite. I think a little 

more clarity in what you're saying, and I wrote you a note 

on this a few days back, last Friday, specific, and that is 
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maybe it's better to define it as 25 degrees tangent to the 

blade tip and define where you're saying that. In the 

European Union it's mid-blade, but it could be the most 

outermost portion of the blade because there are blades that 

have skew to them. There are blades that are not straight. 

There are a lot of different things there that could have a 

variety of implications on that backward curve. 

 MR. SMITH: Well, we didn't talk about backward 

curve yet. We talked about centrifugal fan. 

 MR. WAGNER: Oh, I'm sorry. My screen scrolled 

down. 

 MR. SMITH: Well, yeah, our screen scrolled down 

too. Are you okay with the definition of centrifugal fan or 

does your comment apply there? 

 MR. WAGNER: I think I am. Again, back to that 

angular exit or perpendicular shaft. Is that exactly 

perpendicular? The European Union puts a range on it. I 

think that might be more appropriate. 

 MR. SMITH: Okay. So then we go to the next one,

which is backward bladed, house centrifugal backward bladed. 

Where we ended up here, let's see, we started on the left 

column. This is the one where the fan committee is

recommending column D, and there was proposed revisions from 

the advocates. 

 So let me just read what the fan committee is 
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proposing. A type of centrifugal fan with a housing and 

with impeller blades that are sloping backwards relative to 

the direction of rotation by more than 25 degrees from the 

perpendicular to the axis of, from a line that is 

perpendicular to the axis of rotation. This 25 degree 

number becomes important to distinguish between a backward 

incline, a radial and a forward curve fan. 

 And the advocates said opposite the direction of 

rotation. And I think the fan committee said they didn't 

know what that was. So they suggested, instead, that we 

just use the tangent of the blade at the tip must be at 

least 25 degrees from radial. 

 MS. ARMSTRONG: So can I just ask a higher level 

question? 

 MR. SMITH: Uh-huh. 

 MS. ARMSTRONG: Why do you think you need those 

definitions? 

 MR. SMITH: Um. 

 MS. ARMSTRONG: Like backward, forward, I mean at

the end of the day they all fall down to the highest level, 

you know, house centrifugal. That's it. 

 MR. SMITH: True enough, but Ashley, there are 

classes of fans that are subordinate to the general category 

of ducted fans, which appear in the NODA, and which invite 

discussion about performance standards that are different by 
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different categories. And so we feel that it's important to 

define the different categories. If we choose then to lump 

them together in the regulation, that's a decision that can 

be made later, but we've gone to the hard work here of 

defining these because they appeared in the framework, and 

the notes, both of them, and so that's what we're doing. 

 MR. WAGNER: And there's functional utility to 

them. 

 MR. SMITH: Right. 

 MR. WAGNER: There's radial fans that definitely 

need to be in place, but how do you define the radial from 

any other centrifugal. 

 MR. SMITH: And I think to Sam's point, if we come 

back later and we say this definition isn't important, then 

we can dispense with it. 

 MR. SMILEY: Bill Smiley, Trane, those do provide

a very distinguishable, recognizable, accurate review about 

a fan as to what type it is. 

 MS. ARMSTRONG: Well, you -- 

 MR. SMILEY: You said yesterday you want to be 

without argument. 

 MS. ARMSTRONG: Well, I do, and for the purposes,

you know, if we are, so it depends on how we end up here. I 

mean if we ultimately treat them as different equipment 

classes because they meet the equipment class criteria, then 
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yes, you would need to be able to distinguish different 

equipment. If we ultimately decide on a high level this 

category of fans should not be subject to the potential 

regulations of this committee, then that's also important to 

have a clear distinction. 

 However, if we're defining five different 

categories of fans that get lumped into one equipment class 

for the purposes of regulation because individually those 

five utilities don't have, or five different categories 

don't have the attributes necessary to meet our equipment 

class criteria under the statute, those definitions don't 

matter. 

 MR. SMITH: They do have sufficient difference to

meet the criteria of a separate class. 

 MS. MAUER: This is Joanna. But we had talked 

about two classes originally, right? 

 MR. SMITH: Well, we talked about, actually, 

originally, originally we had many. But we boiled them down 

to two, yes. 

 MS. MAUER: So then they still -- 

 MR. SMITH: I understand. It's a definition of a

backward inclined fan. You asked us to define it. We did. 

 MR. STARR: I think it helps frame the discussion, 

too, is the other part so that everybody is talking about 

the same thing. 
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 MS. ARMSTRONG: I think what I'm telling you here

is that it's great for the discussion purpose -- 

 MR. STARR: Right. 

 MS. ARMSTRONG: -- it's great to have a discussion 

about what's in and what's out, that's what matters, but 

what you may see in a regulation, or what we may come up 

with down the road may not look like this because things get 

collapsed for different purposes, statutory requirements are 

slightly different. So I think it's okay, it's fine for the 

purposes of discussion, but I want you to understand that 

ultimately collapsing into two equipment classes or a couple 

of equipment classes, a handful, whatever they end up being, 

then subcategories of definitions become unnecessary. 

 MR. WAGNER: This is Greg again. We could take 

that up another level and say why do we have a different 

definition of centrifugal, or mechanical or some kind of 

energy to turn that shaft to convert it to energy. There is 

utility in differences between backward centrifugal, radial 

centrifugal and forward centrifugal, and to ignore that 

would be not in the interest of this group I don't think. 

 MR. SMITH: Okay, if we could go down to the next

one. We're at forward curved. And so the suggestion was to 

use this definition here. A type of centrifugal fan with a 

housing and impeller blades that are curved forward, 

relative to the direction of rotation, such that the 
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direction of the blades at the impeller periphery are more 

than 25 degrees from perpendicular to the axis of rotation. 

 And the suggestion is to use, to delete the word 

bladed from column A, with house centrifugal forward bladed 

doesn't -- I realize it's a forward curved blade, but all 

fans have blades. So bladed doesn't add a lot of value. 

And to use the wording in column D, which is what I just 

read, the advocates suggested something called position 

forward relative to the direction of rotation. And it isn't 

the positioning of the blade, it's actually the angle of the 

blade at the discharge. 

 MR. WAGNER: This is Greg again. I think that, I

think that position forward relative to the direction of 

rotation is kind of unclear in my mind what you mean by 

that. You probably should use the same kind of definition 

you have up in the backward curve, just from the standpoint 

of defining what you mean by 25 degrees. 

 MR. SMITH: Greg, would you be willing to draft a

proposed change? 

 MR. WAGNER: Yeah, I sent you one and I'll resend

it. I'll clean it up a little bit. 

 MR. SMITH: Yeah, why not send it, send it, send 

it to the group so it's in the public record, okay?

 MR. WAGNER: All right. I got you. 

 MR. SMITH: Okay, the next one is radial bladed. 
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And here we ended up with a type of centrifugal fan with a 

housing, with impeller blades positioned such that the 

outward direction of the blade at the impeller periphery is 

within 25 degrees of the access rotation. 

 The next one is unshrouded radial blades. Some of 

the AMCA members have suggested that an unshrouded radial 

bladed fan is both an efficiency compromise and has some 

useful purpose, reason, related to its material handling 

duties. And they, therefore, propose that an unshrouded 

radial bladed fan be exempt from regulation. And we have to 

do the homework to define what the connected load is there. 

I believe it will be relatively low. And of course we need 

a definition. The fan committee didn't understand why we 

were asking for the definition, and that's the answer. 

 So I think we still need to do some work in this 

area. 

 Laura? 

 MS. PETRILLO-GROH: Laura Petrillo-Groh, what's 

the difference between unshrouded and then unhoused? 

 MR. SMITH: Well, a shroud is a piece of the 

impeller that has no, it's not part of the housing. It 

doesn't have anything to do with the housing. It has to do 

with the impeller. So a shroud, if you think about it, if 

you think about a centrifugal compressor. It has a, you 

know, a back blade and gas comes in and, you know, and it 
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exits like that and the blade sort of exits like that, 

right? 

 MS. PETRILLO-GROH: Yes. 

 MR. SMITH: Well, so if there's a piece of metal 

on the inlet side that shrouds the gas and captures it 

between the back blade and the front blade, that front blade 

is called a shroud. 

 MR. WHITWELL: It's rotating with the fan. 

 MR. SMITH: It's rotating with the wheel, right? 

 MS. PETRILLO-GROH: Okay. 

 MR. SMITH: And it's also a common application, 

especially in compressors is to have the blades but no 

shroud, so the blades are sort of passing the housing, if 

you will; the housing is becoming part of what's channeling 

the gas from the inlet to the outlet. 

 MS. PETRILLO-GROH: Thank you. 

 MR. SMITH: So in fans, there's always a shroud 

except when the application is concerned about material 

clogging as it goes through the fan. And these fans are 

being used specifically for material handling. The best 

example, your vacuum cleaner, its purpose is not to move 

air. Its purpose is to move dirt. And so it's a dirt 

handling fan, okay? 

 MS. PETRILLO-GROH: Thank you. 

 MR. PERSFUL: This is Trinity with Twin City Fans. 
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 MR. WAGNER: Another one. 

 MR. PERSFUL: This is Trinity with Twin City Fans. 

While Wade had mentioned there are some members that want an 

exemption for this class, there are other members like 

ourselves that don't want an exception for this class. So I 

just want to put that. 

 MR. SMITH: Right. So it's a question mark. 

 MR. DYGERT: Ryan Dygert, Carrier, I just wonder 

why we would break out a radial fan that's unshrouded and 

not a backward curve as unshrouded. 

 MR. SMITH: We know of no examples of backward 

inclined fans that don't have a shroud. 

 MR. DYGERT: Well, there are. You can always put

the shroud in the stationary component in the clearance gap 

at the tip of the blade. 

 MR. SMITH: We don't know of any such fan. 

 MR. DYGERT: Okay. 

 MR. WAGNER: Well, there are, and you mentioned 

the vacuum cleaner, and having designed a few when I was 

much younger. 

 MR. DYGERT: Right, it is done. I can assure you. 

 MR. SMITH: At one horsepower and above? 

 MR. DYGERT: At one horsepower and above I can't.

 MR. WAGNER: Yes, vacuum cleaners are above one 

horsepower. All of them are 1,200 or 1,400 watts. 
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 MR. SMITH: Okay. That's a good comment. 

 Okay, the next one is unshrouded centrifugal, a 

centrifugal fan without a housing that may be arranged in an 

array of discharging, in an array and discharging into a 

plenum. 

 Let's say, we prefer the definition in column C, a 

centrifugal fan without a housing. And the advocates have 

suggested which may be arranged in an array discharging into 

a common plenum. 

 So there's some options there that we really 

haven't settled, but the simple one is the one that AMCA 

members preferred, a centrifugal fan without a housing. 

 You don't agree? 

 MR. DIKEMAN: This is Steve Dikeman. There are 

examples of housed centrifugal fans that are not connected 

to a duct. So if you look at the far right column, that was 

one of the things that we went through at last fan 

committee. 

 MR. SMITH: Right. Right, but the conclusion that 

you came up with is to use the definition in column C. 

 MR. DIKEMAN: Without a connecting duct. 

 MR. SMITH: Oh, I'm sorry, so what you're 

suggesting is a centrifugal fan without a housing -- 

 MR. DIKEMAN: With or without a housing that is 

not connected to, does not have an outlet duct. There needs 
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to be a breakoff there. 

 MR. SMITH: So you're suggesting that an unhoused

centrifugal could have a house? 

 MR. DIKEMAN: A housed centrifugal might not have

an outlet duct. 

 MR. HAUER: Housed centrifugal. 

 MR. SMITH: Okay, this is the definition for an 

unhoused centrifugal fan, yes? 

 MR. DIKEMAN: Yes, but the definition of a housed

centrifugal is that it has a duct. There can be a housed 

centrifugal without a duct. 

 MR. SMITH: This is the definition for unhoused 

centrifugal. Are you suggesting a change? 

 MR. DIKEMAN: Well, once we get between housed and 

unhoused there's a third mutant, housed centrifugal without 

an outlet duct. 

 MR. WAGNER: So is that a configuration question?

 MR. DIKEMAN: Yes. 

 MR. WAGNER: You know, as they do in the EU? 

 MR. SMITH: Well, Steve, you can apply a utility 

fan, for example, and common, it's common to apply a utility 

fan with no duct. 

 MR. DIKEMAN: Um-hmm. 

 MR. SMITH: But it's tested and rated as a ducted

fan. 
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 MR. SMITH: Um-hmm. 

 MS. ARMSTRONG: So I would argue that ducting 

should have nothing to do with the definition, because what 

we're doing here is going to be specifying the ducting as 

part of the duct realizing that when applied actually 

implies the majority go into this and there may be some 

exceptions. 

 MR. DIKEMAN: It's actually from the testing 

configuration that this problem occurs. A housed fan that 

would not have an outlet duct. 

 MR. SMITH: Which the manufacturer rates based on

a test with no duct. 

 MR. DIKEMAN: I mean that's where the fan array 

comes into this conversation for that very reason, and 

that's where we've settled out that without the connecting 

duct. So, anyway, between unhoused centrifugal and housed 

centrifugal, we've got a third member up there to just 

capture at some point. 

 MS. ARMSTRONG: Thank you. 

 MR. SMITH: Just a point of clarification, as Wade 

said, would that essentially, Steve, become a new fan 

category which would be in the unducted group? 

 MR. DIKEMAN: Well, I think that's where we have 

our categories, you know, unducted and ducted, sort of 

transcends some of these definitions. So one way or another 
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we just have to capture it. 

 MR. MATHSON: Yeah, this Tim Mathson, regardless 

of where we put that fan array product, it would be tested 

without a duct. 

 MR. SMITH: Um-hmm. 

 MS. ARMSTRONG: Right. 

 MR. MATHSON: So it does have a housing around it

but it would always be tested without a duct. 

 MR. DYGERT: Ryan Dygert, Carrier, I would make 

the same argument for a housed axial fan because there's 

nowhere it says a housed axial fan can't duct into a plenum. 

 MR. SMITH: That's a question of how the 

manufacturer normally rates the product. Rating tables have 

to be based on something. 

 MR. DYGERT: I agree but I think this goes back to 

the, you know, we start talking about using static and total 

efficiency and we need to pay attention to the outlet into 

the plenum. You can't just automatically assume that a 

housed axial fan and a housed centrifugal fan are always 

ducted. 

 MR. SMITH: Well, what you can do, however, is 

observe how the product is offered for sale in the 

marketplace. 

 MR. DYGERT: Right. 

 MR. SMITH: If the product is offered for sale in
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the marketplace using ratings that are tested in a 

configuration with a ducted outlet, then it's a 

ducted-rated -- 

 MR. DYGERT: No, no, no. 

 MR. SMITH: -- and has efficiency that's based on

that rating. If it's tested and rated and cataloged based 

on no duct, then it's a completely different circumstance. 

 MR. DYGERT: So if I have an invented fan and I'm

rating it on total efficiency and I put it to a product 

where it comes into a plenum where the only thing that 

matters is its static efficiency, then I disagree with that 

point. Even if the product is ducted, the fact that the fan 

is invented and is not communicating directly with the duct 

it's recovering the velocity pressure -- 

 MR. SMITH: The question, the question is what is

the basis of your rating? 

 MR. WHITWELL: Yeah, but we're talking about fans, 

it's separate from the rating of the equipment itself, 

right? 

 MR. SMITH: The question is when you represent it

to your customer, what are you representing it as? How, 

what's the test configuration that you identified to your 

customer? What's the assumption about how the product will 

be applied that's built into your ratings? 

 MR. ERNST: This is Skip Ernst. They can apply 
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today without regulation. It's the fan in the whole box. 

That's what's represented to the customer. 

 MR. SMITH: And do you base it on the duct leaving 

the box or -- 

 MR. ERNST: Yes. 

 MR. SMITH: -- or a plenum discharge leaving the 

box? 

 MR. ERNST: Normally with the duct. 

 MR. DYGERT: Normally. If I take all the kinetic

energy out of this fan and dump it into a plenum and squeeze 

it back down in the duct, the fact that the product was 

ducted at the inlet and outlet has no never mind how -- 

 MR. SMITH: Well, how do you rate the product? 

 MR. DYGERT: But what we're talking here is taking 

the fan as a component out of the system and identifying its 

efficiency levels. 

 MR. WHITWELL: Yes, it's two different things. 

 MR. DYGERT: Yeah. 

 MS. MAUER: This is Joanna. I think we probably 

need some more discussions. I think what we had talked 

about previously was based on what category a fan falls into 

could be tested either ducted or unducted. And there may be 

a different way to do it. 

 MR. WHITWELL: Yes, that was last week's, or last

meeting's discussion was a lot of the time was spent on 
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that, testing. 

 MR. SMITH: So if you end up for embedded fans, if 

the answer at the end of the day is we're going to take that 

fan out of the unit and we're going to rate it 

independently, this becomes a very important question. 

 MR. WHITWELL: Well, that was the discussion last

week. That was the tested combination was the fan, and the 

housing -- 

 MR. SMITH: If you -- 

 MR. WHITWELL: -- and the motor. 

 MR. SMITH: Yeah. 

 MR. WHITWELL: And the structure. 

 MR. SMITH: If you decide that's what you want. 

Yesterday there was a presentation up here that advocated a 

completely different approach. My point is that there is 

more than one approach and it depends on what approach you 

choose as to whether or not this matters. 

 MR. WHITWELL: Sure. I agree. 

 MR. SMITH: Okay. 

 MR. WHITWELL: Yeah, but still we should keep in 

mind that there are ducted housed and unducted housed, 

right? 

 MR. SMITH: Makes sense. Mixed flow, okay, we 

ended up with I think in column D, a fan in which air flow 

enters the impeller parallel to the shaft access but changes 
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direction with the blade passage to impart partial radial 

directions of the flow. Airflow in a mixed flow fan must 

exist in the impeller at greater, at a greater mean diameter 

than the inlet and must exist the impeller at an angle 

between full and axial and 25 degrees of radial. The mixed 

flow fan housing may be similar to either an axial or a 

centrifugal fan, while the air flows through the impeller is 

between -- 

 MR. WHITWELL: Centrifugal and axial. 

 MR. SMITH: -- centrifugal and axial. 

 And the advocate comment is there a need to define 

a fan which airflow enters the impeller in a direction 

between parallel and perpendicular to the axis of rotation. 

And the response was no, because none of us know of any such 

fan that exists or probably ever will exist. 

 Armin? 

 MR. HAUER: Armin Hauer with ebm-papst. My 

company makes mixed flow fans without housings. It's 

basically a plenum fan and then the discharge is at an 

angle. And it's unducted. 

 MR. SMITH: So the difference, would this 

definition apply to that fan? 

 MR. HAUER: Well, you're speaking about a housing

here and the diameter of the inlet and the outlet. 

 MR. SMILEY: This is Bill Smiley at Trane. You 
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would need to add applied without a housing or with a 

housing similar to the axial. 

 MR. SMITH: Well, I don't see any reference to 

housing in this definition. I guess I'm missing it. 

 MR. SMILEY: Look at column D. 

 MR. SMITH: Housing may be similar. 

 MR. SMILEY: Yeah. 

 MR. SMITH: So maybe, maybe that needs to be 

accommodated. 

 MS. MAUER: And this is Joanna. I would defer to

make, but I think the question was more kind of thinking 

could someone develop some different fan. 

 MR. SMITH: Right. 

 MS. MAUER: And not necessarily does this stay. 

 MR. SMITH: Right. And I understand the question

and the only thing I'll tell you is that the fan guys said, 

phew, no. 

 MR. WAGNER: This is Greg. On that comment 

question where it says the fan, I would say it should either 

be average or essentially parallel or perpendicular because 

air does enter not perpendicular or parallel to the shaft. 

There should be some qualifier there. 

 MR. SMILEY: It depends on what plane of the entry 

you're at you define the entering air direction. If you 

define it at the throat of the inlet column -- 
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 MR. SMITH: Right. 

 MR. SMILEY: -- it's pretty much parallel to the 

axial direction. If you define it a half an inch either 

way, it's going to be angled. It comes in, the bell-mouth 

inlet comb pulls air in from all around and directs it in. 

 MR. SMITH: So you would suggest clarifying the 

location of the inlet? 

 MR. SMILEY: I'm okay with it. 

 MR. WAGNER: Half our entire -- 

 COURT REPOTER: Could you repeat? 

 MR. WAGNER: The air coming through the inlet of 

an impeller, whether it's, you know, an unhoused centrifugal 

or an axial fan, or those that don't have a duct directing 

air directly into the inlet comes in at angles other than 

straight along the axis of rotation. So, therefore, it 

should be essentially, or on average, or something like that 

in terms of entering in the direction of rotation. 

 MR. STARR: I think the word he said was half of a 

sphere, if that was what you were missing. 

 MR. SMITH: Okay, so Greg, could you include that

in your write-up, if you would, when you send it up? 

 Mr. WAGNER: Sure. 

 MR. SMITH: Thank you. Okay, next one. 

 Induced flow fans. You may have to scroll up just 

a bit. Oh, inline centrifugal, a house fan with a 
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centrifugal impeller designed with the necessary housing and 

fittings to be mounted between duct sections with air 

flowing in an axial direction at the inlet and the outlet. 

 There was a suggestion from the advocates, which 

the fan committee agreed with, which says design, we 

recommend deleting the word design. Okay, so a housed fan 

with a centrifugal impeller with the necessary housing and 

fittings to be mounted between the duct sections with air 

flowing in an axial direction at the inlet and the outlet. 

 And they're suggesting replace the word fittings 

with structure. The necessary housing and structure to be 

mounted between duct sections. 

 So, again, if you've got -- 

 MR. SMILEY: Bill Smiley, Trane, so the intent is

that this has to have an inlet and outlet? Or just fitting 

so you could connect it? 

 MR. SMITH: Tim? 

 MR. MATHSON: Tim Mathson, I would say just, it 

just has fitting for connection. None of these say whether 

they have to have a fitting for the duct. 

 MR. SMILEY: Well, then it's not that clear. 

Okay, I see what you're saying but we need to change a word 

or so. 

 MR. DIKEMAN: Steve Dikeman, remember that part of 

that conference call, fittings seem like it could be 
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perceived as a loophole and structure, it was, we felt it 

was more universal than fittings. 

 MR. SMITH: So Bill, if you have a suggestion to 

change, why don't you write it up and submit it, okay? 

 MR. SMILEY: Okay. 

 MR. SMITH: Okay, now we've got induced flow fans. 

A housed fan with a nozzle and a wind band whose outlet 

airflow is greater than its inlet airflow due to an induced 

airflow. All the flow entering the inlet will exit through 

the nozzle. The flow entering the wind band will include 

the nozzle flow plus induced airflow -- exiting the wind 

band, excuse me, will include the nozzle flow plus the 

induced airflow. 

 We're asking for an exemption for induced flow 

fans, I believe. Okay. These are safety fans, laboratory 

fans and have a relatively low connected load, the size of 

which is in our database that we submitted to DOE. I don't 

remember what it is but it's a pretty small number.

 Okay. Centrifugal power roof and wall 

ventilators, a fan consisting of a centrifugal impeller with 

an integral drive with a housing designed to prevent 

precipitation from entering the building and with a base 

designed to fit, usually by means of a curve over a roofed 

or walled opening. 

 And the advocates suggested weather resistant 
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housing rather than housing designed to prevent 

precipitation. Oh, AMCA changed it to weather resistant 

housing and advocates were okay with that. So this is where 

we ended up, right here. 

 Any questions or comments on that? 

 Okay, next one? Axial, it's the same line just 

substitutes the word axial for centrifugal. So it's a fan 

consisting of an axial impeller with an integral drive, with 

a housing designed to prevent precipitation from entering 

the building and a base designed to fit, usually by means of 

a curve over a roof or walled opening. 

 Okay. Okay, then in the most recent NODA, there 

were questions about definitions of embedded fans, ducted 

fans, non-ducted fans, et cetera, and you can collapse, if 

you would, columns B through E because there aren't any, and 

then we can better see this, I think. 

 IT SPECIALIST: You mean hide them? 

 MR. SMITH: Yeah, hide, yeah, I'm sorry, hide 

columns B through E. 

 MR. JOHNSON: Right-click on it. 

 MR. SMITH: That's okay. That's enough. We got 

it. 

 You know, you might go to the top and click on F,

and then under the Home, wrap text. There you go. Okay. 

 So now we've got, we didn't tackle embedded fan 
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and I don't know that we need to, but anyway, we didn't. 

Okay? 

 MR. SMILEY: Well, Bill Smiley, Trane, isn't that

just as important as tackling the definition for powered 

roof and ventilated? 

 MR. SMITH: Yeah, we just didn't do it. 

 MR. SMILEY: Right, so what's to say it's not 

important. It may not be important to the panel --

 MR. SMITH: I didn't say it wasn't important. 

 MR. SMILEY: Yeah, you did. 

 MR. MATHSON: Well, this is Tim Mathson. 

Thankfully no matter what we say, this group is going to 

argue about it. 

 MR. SMILEY: Oh, yeah. 

 MR. MATHSON: We just avoided it. We didn't say 

what was important. 

 MR. SMITH: If I said it wasn't important, I 

misspoke. I'm sorry. 

 MR. SMILEY: Or I misheard. My ears are old. 

 MR. MATHSON: It's probably the most important 

thing here but we didn't want -- 

 MR. SMITH: We didn't tackle it. 

 MS. ARMSTRONG: And I don't think we need to worry 

about the definition right now until we actually figure out 

our intent with scope. So I would just keep on going. 
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 MR. WHITWELL: Yeah, I mean I assume -- 

 MS. ARMSTRONG: There's no reason to deal with it. 

 MR. WHITWELL: Assuming that most fans, if not 

all, are embedded somewhere in something. 

 MS. ARMSTRONG: Yeah, and I'm not sure that DOE 

would agree that a definition of an embedded fan is the 

right way to execute anything. We might agree to not 

setting standards for it at this point in time. 

 MR. SMITH: So this is the first time, you know, 

we've seen these, but we asked the fan committee to come up 

with the definition for ducted and unducted fans. And this 

has to do with how it's tested. So a ducted fan is a housed 

fan tested with an outlet, according to AMCA Standard 210, 

installation type D or B. And an unducted one is a housed 

or unhoused fan with an outlet ducted according to AMCA 

Standard 210, installation type A or C. 

 MS. ARMSTRONG: Could we make this a little 

bigger? 

 MR. SMITH: Sure. 

 MS. ARMSTRONG: So without needing to discuss the

ducted, the definitions and specifics, I think at a high 

level from my perspective it's not clear where a ducted fan 

definition or an unducted fan definition would be utilized. 

If the test procedure conditions are going to apply to a 

specific type of fan and they're going to tell you for these 
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types of fans you use this as set up and that setup will 

include the presence or the absence of a duct -- 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: -- so I’m not sure, you know, if 

we need to spend a whole lot of time. I could be wrong, so 

this is helpful kind of -- 

 MR. MATHSON: Yeah, Tim Mathson, I would disagree

with that approach because, I mean a classic example would 

be an air handler manufacturer and a double-width fan. 

Normally, a housed centrifugal, if you classify that as a 

housed centrifugal, you would say it's tested and let's go. 

But why would the DOE prevent us from testing a double-width 

centrifugal, or an air handling application. I don't know 

why you would do that. 

 MS. ARMSTRONG: So I mean this gets back to our 

discussion last week, and I thought I heard, and perhaps you 

guys can correct me if I'm wrong, but you know, even 

manufacturers that make a fan that may be used with and 

without prefer to test it and rate it only as one way. Do 

you actually want to have to test and rate and comply with 

both configurations? 

 MR. MATHSON: No, this is Tim. We don't want, we

don't want to do that. I'm saying that 99 percent of the 

time that double-width would be tested, as well as the duct. 

 MS. ARMSTRONG: Well, it's a yes or no, right? 
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You can't have it both ways. It's not going to be at your 

discretion? 

 MR. MATHSON: Why not? Why not? If the customer

wants it? 

 MS. ARMSTRONG: Well, so that's different. I mean 

you can ask DOE to -- 

 MR. MATHSON: If the application is going to -- 

 MR. WOLF: Let me try because I was going to bring 

this up before. I think one of the things that I hear and 

I'm struggling with is what are we going to use for a rating 

metric, and then what are we going, how is, is that a 

mechanism that is going to be used to convey the components 

to the end customer? 

 MS. ARMSTRONG: Yes. 

 MR. WOLF: The answer to that is yes? 

 MS. ARMSTRONG: Yes. 

 MR. WOLF: So then in that case then we come back

to Tim's situation. 

 MS. ARMSTRONG: Yes, that's where I was going with 

my thing. So I hear Tim asking, we want a standardized 

rating method but we also want a way to be able to make 

representations the other way. 

 MR. WOLF: Well, do it. 

 MS. ARMSTRONG: I don't know, I don't know the 

answer but the answer is you can't make representations of 
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an efficiency metric that's not -- 

 MR. DIKEMAN: Well, this is Steve Dikeman. 

Ashley, here are 90 examples of a house centrifugal fan that 

is never tested, rated or used with a duct. 

 MS. ARMSTRONG: Okay. 

 MR. DIKEMAN: I picked these up off of a testable

configuration work we did last time. 

 MS. ARMSTRONG: Um-hmm. 

 MR. DIKEMAN: The product falls into a 

definition -- 

 MS. ARMSTRONG: Yep. 

 MR. DIKEMAN: -- of a housed fan, but it's never 

used that way. So if it doesn't have a duct connection to 

go test it that way to meet that description, then it just 

went down. 

 MR. BUBLITZ: So what's your recommendation? 

 MR. DIKEMAN: What we have to sort out is this 

ducted/unducted. What Tim Mathson said was that the 

manufacturer may choose, but I think there's also some 

product that says it's housed but it will never be ducted. 

 MS. ARMSTRONG: The DOE is not going to say you 

can choose because we want manufacturer A to choose the same 

way that manufacturer B is going to choose. 

 MR. DIKEMAN: There needs to be a requirement 

housed -- 
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 MS. ARMSTRONG: There needs to be a way -- right. 

So there needs to be a requirement in our regs that kind of 

dictates how you choose. 

 MR. DIKEMAN: To be housed? 

 MS. ARMSTRONG: The choice is I want to make 

representations of both configurations. You need to let us 

know if it's that there is a sliver of the market that we 

can define separately that need to make both, fine, then you 

need a definition, fan committee, or you know, maybe it's 

that you don't want any of that and you want to standardize. 

I don't know. 

 I mean another thing to think about is there, you

convey the information to the customer in different ways. 

Is it just in the energy efficiency metric that you would do 

it, or is there other ways about the performance that you're 

talking about? Because I think that matters too. 

 So I don't think we can answer that today, but you 

guys need to think about what you want and how this applies, 

because the way it works is then DOE reg says we return a 

method that governs how you make representation to DOE, but 

that's a lot broader. Marketing, literature, customers, and 

they would need to be made in accordance with the DOE test 

procedure. 

 So if we go down the pathway, which is what I 

thought I heard last week so I'm glad we're having this, is 
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to standardize the method, it would preclude you. 

 MR. SMITH: So since the beginning of time, right, 

the industry has developed giving the manufacturer the 

option of how they want to rate their product, A, B, C or D, 

with the requirement that they identify to the customer how 

the rating occurred in their rating tables? 

 MS. ARMSTRONG: Yes. 

 MR. SMITH: In spite of the fact that they have a

choice, a very high percentage of the time manufacturers 

choose one approach. But as, and that I think has governed 

our thinking that we were developing in these ideas. But as 

Steve points out, in that sort of momentum of thought, we 

overlooked the fact that, no, there's a lot of members who 

represent their products to the marketplace based on a 

different rating method and identify that, which is, which 

is allowed under 210, and encouraged, truthfully, because we 

want the actual performance of the fan differs if it has a 

duct on it than if it doesn't. 

 And so I would just inject here that it's better 

if it has a duct on it. But if the fan is not intended to 

have a duct and its performance in an unducted application 

is the way the manufacturer wants to represent it to their 

customer because that's how their customer applies the 

product, then that's the appropriate thing to do. So 

somehow we have to make an accommodation, because if we 
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don't we'll lose the utility of being able to provide honest 

ratings, not misrepresented ratings, but honest ratings to 

the customer. 

 MS. ARMSTRONG: And what we're, how that 

translates into a world where you have discretionary kind of 

things to deal with, you have the discretion to make ratings 

the way you want to the regulatory world, in which DOE is 

going to standardize things so that everyone is doing, using 

a similar method, and similar rating points, and making 

representations that can be comparable for the purposes of 

utility programs, et cetera, et cetera. You know, what that 

means is that if you want that, we need to figure out a way 

to accommodate that, but we would also, you know, if you 

decide this sliver should be rated both ways -- 

 MR. SMITH: No, one or the other. 

 MR. DIKEMAN: Not both. Not both. 

 MR. SMITH: One or the other. 

 MR. DIKEMAN: It would be housed but not ducted. 

 MS. ARMSTRONG: Think about it a little bit more 

in terms of what you want. I mean however you want it, I 

don't care, and I think Tim was saying there are, there may 

be cases. You guys think about what you may want. But if 

the answer is I want both, then you would be subject to 

regulation of both. 

 MR. SMITH: Both. 
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 MS. ARMSTRONG: Or potentially. 

 MR. SMITH: Right. Right. 

 MS. ARMSTRONG: That's a discussion we would need

to have. But I mean you guys should speak up, in terms of 

ratings and what you want to see on ratings, and I think one 

of the things you're at the table is because you want 

standardized ratings. Those ratings that are sent into the 

department and people are seeking out that information more 

and more, and so not just what they would make in 

discretionary language. 

 MR. STARR: Yeah, this is Louis again. I think 

the other aspects of the whole loophole business is that 

people, I mean I think fan guys want the same thing. 

Wouldn't you be concerned if someone tested one way and 

rates it another? It's your -- 

 MR. SMITH: Yeah. 

 MR. STARR: You think you're comparing apples-toapples, but actually you're comparing something else. 

 MR. SMITH: Right. 

 MR. STARR: So that one guy gets the sale. So, I

think it's equally, while it may seem like DOE is being a 

regulatory nitpicky, perhaps, but it's not and in reality 

you want, you want the same thing they want ultimately. So 

it's just something we work on. 

 MR. SMITH: Right, so this thing, I've got a 
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centrifugal fan, it's sitting in front of me. The paradigm 

is that it's a housed centrifugal fan. The paradigm is that 

it's ducted. So how do we accommodate the manufacturer who 

employs that fan in a non-ducted application exclusively for 

their product, and therefore chooses to rate it in a nonducted way. How do we make that accommodation, recognizing 

that there's -- well, I won't say this. I was going to say 

recognizing that there's no way to physically distinguish 

the product, but I think what I hear you saying is that we 

have to find a way to physically distinguish the product. 

And so in the definitions we need to find that way so we can 

put it in the right category. 

 MS. ARMSTRONG: So can I make a suggestion at this 

juncture? I know you guys have some feedback on the 

definitions. I'm going to actually suggest that before you 

ask your fan committee to take another deep dive with some 

of these definitions that you actually let DOE give it a 

shot based on what we heard today. 

 And the reason for that is two-fold. One is we've 

heard some what we think are pretty good intentions of what 

you meant. We are not by any means fan experts, but we 

understand how our regs kind of would be implemented. 

 And then two-fold, I can try to get some of my 

lawyers to at least look through and get first feedback, a 

little feedback on that, because you will see some 
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significant changes that may make sense. And I think before 

you start, and I know you guys have put a lot of work into 

it, so why don't you let us give it a shot, if that's okay 

with you? 

 MR. SMITH: Sure. 

 MS. ARMSTRONG: Thanks. And then I do want to 

move to the NODA before it's too long. I mean anyone who 

has specific definitions in response to what we've talked 

about today, we welcome that. We can include them in all of 

our feedback and recommendations, so just send them our way. 

And then we'll obviously we'll distribute something for the 

group to further consider from there. 

 MR. SMITH: I think before you were here we talked 

about driver and this became a scope question. 

 MS. ARMSTRONG: Um-hmm. 

 MR. SMITH: And so for whenever it is that you 

want to talk about scope, we can revisit this driver 

question. 

 MS. ARMSTRONG: Okay. 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: Sounds good. Thank you. 

 MR. SMITH: So there's also, there were DOE's 

proposals in the ASRAC, and you see the comments here. Fan 

committee was okay, okay, okay, change where the fan 

impeller is connected directly to the drivers. This is 
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direct-driven fan. So there's some suggestions there. 

 MS. ARMSTRONG: Great. 

 MR. SMITH: And that so ends the discussion of 

definitions. 

 MS. ARMSTRONG: Okay. Thank you. So at this 

juncture I'm going to propose that we take a break, come 

back and we're going to load up and get ready to talk about 

the NODA analyses and walk through that. 

 So maybe 15 minutes or so, just so everyone has a

chance if they do want to grab something to drink or 

something downstairs. 

 (Whereupon, a brief recess was taken.) 

 MS. ARMSTRONG: So it's 10:42. We're going to do

a good, solid hour-plus on these slides and see how far we 

get with these. This is your opportunity to ask questions 

about the NODA that has been put online as well as like how 

we do things, if you need to find something in the 

spreadsheet but can't figure out how do you find things, 

this would be your opportunity to those individuals that 

created those spreadsheets. So use this as such a thing. 

We're going to go through this. We'll break for lunch. 

We're going to continue and finish it and my hope is that we 

can get through all of this, we're going to plow through it, 

as well as revisit the ratings discussions yesterday because 

I had a lot of questions about it. So, just continue that 
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round table before we finish up at three. So, with that I'd 

asked Sam today to just keep going unless there are specific 

questions. Okay? 

 MR. JASINSKI: Thanks, Ashley. Sam Jasinski, 

Navigant Consulting. I'll be talking today about the NODA 

analysis. These are pretty barebones, similar to what was 

published. It's really just to get the tools and the data 

and information out for your review. But if you remember, 

so these will be from the May 1st NODA results, the most 

recent, but I believe we also have these updated to reflect 

the static versus total efficiency for ducted and unducted 

fans as was discussed in previous working group meetings. 

So the scope of the, if you remember, just to provide some 

context, if you remember in one of the earlier working group 

meetings we showed that DOE by statute has to account for 

certain factors, I think there are seven of them. Typically 

DOE has one or two analyses to consider each of those 

factors. So you'll see this presentation organized around 

those analyses and we'll go through each of them. So that's 

the organization of the presentation. Okay, to kick things 

off, the scope of the May 1st NODA included the fans you see 

here which we've talked about it a lot. Fans that were 

included, axial, centrifugal, inline and mixed flow, radial, 

power roof ventilators. Fan types not included in the 

analysis, safety, cross flow, circulating, induced flow, air 
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curtains. And the scope was limited. The fans in this 

analysis had a maximum shaft input power of at least one 

horsepower but not greater than 200 horsepower at max speed. 

Did you have a question? 

 MR. BUBLITZ: Mark Bublitz, New York Blower. So 

we can conclude that that is the list of fan categories 

under which you conducted your analysis and every fan that 

would qualify would fall in one of those buckets? 

 MR. JASINSKI: Yeah. 

 MR. BUBLITZ: Thank you. 

 MR. JASINSKI: Well, the caveat is, all fans for 

which we have information to conduct the analysis fell into 

those buckets, yes. If that makes sense. 

 MR. BUBLITZ: Makes sense but it's not clearer. 

 MR. JASINSKI: Okay. Let's, we're going to talk a 

lot about our data sources and I think you at least will be 

very familiar with most of the data that we used. So, it 

should be clear to you and maybe you can help me articulate 

it to the rest of the group who might be having, who might 

be similarly confused. I'll let Sanaee actually speak to 

this slide. 

 MS. IYAMA: So, here is just to kind of give an 

overview of the, of the main dataset that we used to run the 

analysis on. So this data, this data set that we later 

called the LCC sample was developed based on aggregated, 
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sorry, based on 2012 AMCA sales data and we filtered the 

data to adjust it to the scope that Sam just presented. So, 

you know, looking at fans over one horsepower and below 200 

horsepower within the categories that were listed as in the 

scope of the analysis. Doing that, we ended up with about 

70,000 fan selections, representing about 100,000 units sold 

and this is what you see on that graph here and the size of 

the bubble kind of represent the volume on the market. 

 MR. JASINSKI: They're kind of hard to see but the 

axes here are total pressure on the Y-axis and flow the Xaxis. Yes? 

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

Does this include the entire fan or just the impeller? 

 MS. IYAMA: So these are fans meaning impeller 

housing, structure when they were -- 

 MR. JASINSKI: As they were sold. These are fan 

sales, correct? 

 MS. IYAMA: Yeah. 

 MR. JASINSKI: So, as they were sold. 

 MS. PETRILLO-GROH: This data would not represent

any fans in packaged units where they were built, where the 

impeller was purchased and embedded in the unit by 

(indiscernible)? 

 MS. IYAMA: So, some could actually go later on or 

be sold to manufactures. I think that's what Wade had 
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mentioned; that some of these fans in the database that AMCA 

provided could also be embedded fans, right? 

 MR. JASINSKI: But are any of them just the 

impeller itself? 

 MS. IYAMA: No. 

 MR. ROY: I guess -- Aniruddh Roy. I guess a 

follow-up to Laura's question is, in this data set, do you 

ever take let's say a rooftop and maybe extract the fan from 

there and then conduct a test? 

 MR. SMITH: Can I answer that? 

 MR. JASINSKI: Wade. 

 MR. SMITH: The database from AMCA members and the 

fans that are included include a lot of fans sold in 2012 to 

manufacturers of air handling units and large unit carrier 

equipment. I feel that the backward inclined fan data is in 

the database, the data that's in the database is 

representative of the full market including embedded fans. 

But I believe that while some of the FC fans may be embedded 

two things can be said. Number one, the number of FC fans 

that are in the database is a very small number and number 

two, I believe it is not representative of the embedded FC 

fans. All right? So, mentally, the way I have thought 

about this data is that the forward curved fan data is a 

small sample, it's much smaller than I would like, it's not 

representative of the market, it's certainly not 
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representative of fans embedded inside equipment, forward 

curved. With backward included and airfoil fans I feel that 

it does represent and the market expansion that we did since 

the database isn't the full market, it's just the market 

that was reported to us. We then expanded that to represent 

the full market and in that expansion I’m quite comfortable 

that we captured the imbedded fan market for backward 

inclined fans. Okay? 

 MR. ROY: Thank you. 

 MR. SMILEY: Bill Smiley of Trane, I have a 

question, actually have two questions. First one should be 

easy. But I noticed the total pressure you have here goes 

up to 140 inches of water and with our definition that we've 

tossed around and I think finally agreed on since day one, 

the max pressurized would be like 40 inches. So, I wondered 

if you -- 

 MR. SMITH: No, it's 120. 

 MR. SMILEY: 120? 1.1 pressure ratio is 120 

inches? 

 MR. SMITH: It's over 100, let's put it that way.

 MR. BUBLITZ: It's the 25 -- 

 MR. STEVENS: It's 1.3. 

 MR. SMILEY: That's 1.3, not 1.1. 

 MR. SMITH: Well, 25 kilojoules is -- 

 MS. IYAMA: So, I think, you know -- 
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 MR. SMITH: -- over 100. 

 MS. IYAMA: -- these were analyses that were done

before all -- 

 MR. SMILEY: Oh, okay. 

 MS. IYAMA: these discussions happened so -- 

 MR. SMILEY: So you haven't done -- 

 MS. IYAMA: -- so we would, if we were to redo 

this with whatever the working group agrees that should be 

in or should be out we would address that dataset again. 

 MR. SMILEY: Okay. 

 MR. WHITWELL: Bob Whitwell of Carrier, oh sorry,

Bill, go ahead. 

 MR. SMILEY: Go ahead. 

 MR. WHITWELL: No, you finish. I thought you were 

done. 

 MR. SMILEY: Well, okay. So, we might need to 

discuss it a little bit further. I mean, I really don't 

care about the pressure, pressure issue at least. It seems 

1.3 is a little high for a fan. You're getting into 

compressor stuff. 

 MR. SMITH: It's just that, Bill, it's the 

accepted definition in the AMCA literature, in European 

literature. 

 MR. SMILEY: No, what I saw was 1.1 but that's 

okay. We don't need to -- the other question is, for every 
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dot that's on there you have information on the fan that 

included cfm and total pressure apparently, fan power and 

RPM and that kind of stuff, correct, in the database? 

 MS. IYAMA: So we have, the information that we 

have in the detailed list of all the variables that we had 

is in the LCC spreadsheet. We can go through that but it 

was mainly, flow, pressure, static and total -- 

 MR. SMILEY: Yeah. 

 MS. IYAMA: -- you know, design point -- 

 MR. SMILEY: So you're able to plot flow and 

pressure for every fan that's in the database that you 

analyzed -- 

 MS. IYAMA: The fan selection. 

 MR. SMILEY: And what you just told me, you told 

us that every fan that's in this database, a lot of them 

were sold to manufacturers that embed them in other

products. And I'm wondering how the fan manufacturer knows 

the flow and pressure points specifically for all those fans 

that are going to be imbedded in other products. So -- 

 MR. SMITH: Because -- 

 MR. SMILEY: -- is it a guess, a best guess or 

what? 

 MR. SMITH: No. 

 MR. SMILEY: I mean, when we -- 

 MR. SMITH: Can I answer the question? 
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 MR. SMILEY: Sure, please answer the question. 

 MR. SMITH: Okay. So, there is some data in the 

database which does not have the flow and pressure 

information and that is where there's a query on the 

database that requires that information. Those lines are 

ignored. 

 MR. SMILEY: Right. 

 MR. SMITH: Most of the embedded fans that are 

sold and included in the database are purchased from the fan 

manufacturer with a flow and pressure and that data then is 

available and if it's available it's in the database. 

 MR. SMILEY: Well, okay. It just surprises me 

that we would order a fan from a fan supplier and tell them, 

we want this fan and, oh, it's for this flow and this 

pressure. 

 MR. SMITH: You don't and none of your data's in 

here. But other companies do and they do exactly that. 

 MR. SMILEY: Well, that's good to know then. 

Thank you. 

 MR. WHITWELL: Yeah, so Bob Whitwell, so just to 

follow-up on that, Wade. So, you said forward curved you 

think is under represented here so I assume that those are 

forward curved fan components that are sold to people that 

then put them into their units with, and put their own 

housing? 
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 MR. SMITH: Well, they're not in here so I don't 

know -- 

 MR. WHITWELL: Yeah, they're not in here, right. 

So they're not in here so there's a lot of those that are 

not in here. 

 MR. SMITH: Right. 

 MR. WHITWELL: And how about panel fans where the

manufacturer sells just the blade and that gets put into the 

product? I assume there's a lot of those that are not in 

here as well? 

 MR. SMITH: Well, those, in our world those are 

not fans and they're not in here. 

 MR. WHITWELL: Right. Okay. So, based on the 

definition of fans that we're talking about they're not in 

here? 

 MR. SMITH: However, right, in each category we 

took the data that we did have, right, and we said, all 

right, what percentage of the market is the data this 

represents. So we looked at the total market and then when 

determining savings or non-compliance rates as an example we 

grossed up what was in the database to represent to the 

total market. And in the case of panel fans in particular 

that grossing up was quite large. In other words, there's a 

lot of unreported panel fans, not reported to AMCA for a 

statistics program, certainly not reported to the database. 
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So, we took the, a market estimate, an expanded market which 

by definition is an estimate because we have reported 

markets, right, and then we have the unreported. And so the 

expanded which includes the unreported data by category was 

sitting off here to the side, all the data was sitting off 

here. So, if we're asking a question like non-compliance 

rate, well, I don't know the non-compliance rate of the 

market that wasn't reported to me but I do in the market 

that was. And so the question then, is well, okay, what's 

the answer, take an order of 15 percent non-compliance rate, 

right, okay. So I have 15 percent non-compliance rate in 

the database, is the database large enough to be a 

statistically significant representative of the total market 

and that's a judgment call that's made one product category 

at a time. But in every fan category except for forward 

curved fans we feel like the database is representative of 

the market. 

 MR. WHITWELL: Okay. You went way beyond my 

question. I was just trying to understand the 10,000 versus 

what my thought is about the number of fans they use. 

 MR. SMITH: There's a lot of panel fans that are 

not in the database but the database is a statistically 

significant representative of the total market. 

 MR. FLY: Mark Fly with AAON. I think there's 

also probably a lot of BI and BC fans, I don't think you've 
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really got the majority of them. I, our company uses those 

almost exclusively, we never buy a complete fan, I don't 

think that's unusual for major manufacturers. The people in 

the custom business do tend to buy complete fans. And so 

when you're selling to a fan manufacturer you're probably 

leaning heavily on that side of the business as opposed to 

the more standardized commercial products. 

 MR. SMITH: Right. So I'll just tell you what we

did. 

 MS. ARMSTRONG: Well, can I turn it over? So, I 

think this is a whole, what we're here to do today though is 

explain to you the NODA and I think that we would welcome 

data. I mean, if you believe your fans with the data that 

we have used so far, I mean, are not incorporated in some 

manner or form or not represented we would welcome that, 

we'll include them, no problem. This is just draft analyses 

as you know. The reason for presenting it to you today is 

to get feedback on its refinement, so this discussion I 

think is helpful but I do want to make sure we get through 

some of the technical aspects of exactly what type of data 

sources. But like I said, if you bring data to the table 

I’m happy to incorporate into one of those analyses for your 

use and the working group. That's the whole point of this. 

 MR. FLY: Okay. 

 MS. ARMSTRONG: Thank you. 
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 MR. JASINSKI: Okay. I'll move on. I'm going to

skip this for just a second but I'll come right back to it. 

So, the first analysis I wanted to talk about is the 

engineering analysis. The purpose of the engineering 

analysis is to characterize the relationship between 

manufacture and production cost and more efficient fan 

designs. We're essentially trying to figure out the 

incremental cost to the manufacturer, the per unit 

production cost for a more efficient design. The first, 

this is just a quick overview of that analysis. The first 

major step is to select efficiency levels which is the 

previous slide which I'll go back to. DOE identifies the 

baseline, in this particular, that represents the least 

efficient fans. In this case that means that we used an 

efficiency level that was achievable by most fans in the 

AMCA database. DOE also identifies a max tech. This 

represents the most efficient models. For this particular 

analysis this means that we picked an efficiency level that 

retains some fans in each type of, of each type in the AMCA 

database. So, see we just tried to bound the data that was 

given to us in terms of the least and most efficient fan 

models. And then DOE also selects intermediate efficiency 

levels. In this particular NODA we selected levels between 

the baseline and the max tech and you can see them here. 

EL0 would be the baseline, EL6 would be the max tech. You 
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can see the efficiency targets associated with those. And 

the, a target of 62 percent was used to present results for 

ducted fans in AMCA's DOE fan efficiency proposal presented 

at the 59th AMCA annual meeting. So there's a public, they 

use that publicly. So you can see we used efficiency levels 

above and below that but we wanted to make sure that that 

one was represented. You can see that it's an EL2. Do you 

have a question in the back? 

 MR. SMILEY: Real quick question. Was this -- 

Bill Smiley, Trane. Was this base on peak efficiency of the 

data that you had -- 

 MR. JASINSKI: Go ahead, Sanaee. 

 MR. SMILEY: -- or efficiency of the actual points 

that you're analyzing? 

 MR. JASINSKI: Efficiency -- 

 MS. IYAMA: So -- 

 MR. JASINSKI: Go ahead. 

 MS. IYAMA: Good point. 

 MR. SMILEY: Thank you. 

 MR. JASINSKI: So, these are the efficiency levels 

that were selected and you'll see them through the rest of 

the analysis. Yes? 

 MR. FLY: Mark Fly with AAON. Is this, for these

efficiency levels, is this expressed in efficiency for all 

fan types or is it split up by -- 
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 MR. JASINSKI: No, it will be -- 

 MR. FLY: -- per types of fan? 

 MR. JASINSKI: -- you'll see fan types or 

equipment classes analyzed. 

 MR. FLY: Okay. 

 MR. JASINSKI: So each of these -- 

 MR. FLY: Each one is analyzed individually? 

 MR. JASINSKI: Yes. 

 MR. FLY: Okay. 

 MR. JASINSKI: And Sanaee, I believe there's a 

different set of these for static? 

 MS. IYAMA: Yeah. So this is just, again, the May 

1st NODA where we did everything with total pressure and 

metric using total efficiency. 

 MR. JASINSKI: Okay. So you'll see another set of 

these later on in the revision that includes static. 

 MS. IYAMA: Right. And these are the targets, 

right, and then depending on the operating point you'll have 

that equation with the de-rating factors, right. That's 

just the target used in the efficiency equation. 

 MR. JASINSKI: In the metric that was discussed at 

the last meeting. 

 MR. MCCABE: Michael McCabe, could you explain 

again the EL6, the max tech and how that compares in the 

specific class to the best available? 
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 MR. JASINSKI: EL6, the way the max tech was 

selected here was we looked at the AMCA database of fans and 

we pushed it as high as it would go without eliminating an 

entire fan type essentially which means that every fan type 

included in the analysis there is a selection of a fan type 

in the analysis for each fan type that can meet this level. 

Wade? 

 MR. SMITH: I sent an e-mail that everybody got 

but I just want to reiterate that the non-compliance rates 

that are shown up there are quite different than the noncompliance rates we've calculated. So, we're working off 

the same database nominally so we need to try and reconcile 

it -- 

 MR. JASINSKI: Right. 

 MR. SMITH: -- we're going to do. 

 MR. JASINSKI: Yeah. And I think it's, we can 

come back to these. I think it's, I think the rest of this 

presentation will provide some context to those numbers. 

So, we're getting a little ahead of ourselves. The other 

thing to remember again is that this is just what was done 

here. If the working group decides that max tech should be 

higher or lower then we will consider that as well as any of 

these other efficiency levels. This is just what was 

selected for this particular analysis. 

 MR. WAGNER: Before you go off that, this is Greg, 
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you have that EL6 at 86 percent. Does that, let's look at 

axial fans, are you saying any type of axial fan or are you 

saying panel fans can reach 86 percent? 

 MR. JASINSKI: I believe that it only means that 

there is an axial fan that, there was an axial fan in the 

database that could meet that efficiency level. 

 MR. WAGNER: So that's a vane axial fan is what 

you're saying? 

 MR. JASINSKI: We can look. I don't believe that

we tried to preserve every subgroup. I think it was simply 

in the equipment classes that were used in the NODA, if 

there was a fan sold that could meet this efficiency level 

in that equipment class then -- 

 MR. WAGNER: Well, it might be useful to know what 

that non-compliance stands for, composed of for each of 

those EL levels because that might be important. 

 MR. JASINSKI: Okay. Sanaee? 

 MS. IYAMA: So, Greg, if you look at the LCC 

spreadsheet, if you guys want to know what these numbers 

would look like, whether it's by category code or fan 

category, category being the subcategories, all the data is 

in there. We just didn't put it all on the slides. So I 

think maybe we could just move on and then maybe later dig 

into the details. 

 MR. JASINSKI: Sounds good to me. Any other 
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questions before I move on? 

 MR. MATHSON: Well, this is Tim Mathson, I think 

we're just a little confused and this confused me too when I 

first saw it. But this 86 percent that Greg asked about, 

you know, you think well how can, there's a 47 percent noncompliant, well how can the 53 percent actually comply with 

that. But this is that number before it's de-rated. 

 MS. IYAMA: Yes. That's just the target. 

 MR. MATHSON: And this is just an extremely highpressure, high flow type of a fan. There probably wasn't a 

fan in the database that met 86 but the requirement was 

somewhat lower than that. 

 MR. JASINSKI: Right. What Tim's pointing out is

that the efficiency target here is represented as a single 

value but in the metric that we use it's actually a

continuous curve de-rated by pressure and flow. So, for a 

particular, for some of the fans in the database, depending 

on the operating point, the target efficiency would not be 

86 percent. 

 MR. DIKEMAN: I understand. 

 MR. STARR: This is Louis with NEEA, one thing I 

should ask, just, I forgot what you call it now, it's not 

PBER (phonetic sp.) but the metric, whatever that -- 

 MR. SMITH: FER/FEI? 

 MR. STARR: Yeah. Is there a lower limit on it to 
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where the results don't actually, like on FEG it was five 

inch impeller? Is there something on that on the FEI/FER 

metric, is there a lower number? Does it go all the way 

down? I mean, there must be a lower limit somewhere. 

 MR. MATHSON: There's no diameter in it. 

 MR. SMITH: It's just -- 

 MR. STARR: Are the answers so realistic? I mean, 

they're pulling the numbers from the database, they can have 

some, I don't know, probably worth someone taking a look at 

it I would say. 

 MR. SMITH: I would just say that we focused our 

energy, our energy -- 

 MR. STARR: One horsepower. 

 MR. SMITH: -- one horsepower and up and we 

selected data on fans below one horsepower and used that 

data to say how big is that market, how many fans, what 

types, blah blah blah blah blah. But we used that data to 

sort of guide our advocacy to one horsepower and up and then 

thereafter we did a lot of analysis on the one horsepower 

up, so. 

 MR. STARR: All right. 

 MR. BURDICK: This is Larry, I've got a question 

still. On the EL6 then, so that, the efficiency is

obtainable using the 250 adder on the flow and the .4 adder 

on the static? 
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 MS. IYAMA: So, I think there is maybe a confusion 

in the way that this, these ELs are presented. So maybe 

I'll try to clarify. We presented in the last meetings that 

efficiency equation which would be the minimal efficiency 

that you would have to meet at a given flow and pressure. 

In that equation you had an efficiency target which was a 

constant which kind of reflects the, how high that 3D 

surface would be relative to the pressure axis, efficiency 

axis. And then there was also a pressure de-rating function 

which was, you know, the pressure over pressure plus the 

pressure constant, 0.4, and then you would also multiply 

that with the flow de-rating function which was flow divided 

by flow plus a constant. 

 MR. BURDICK: Which is 250. 

 MS. IYAMA: Which was 250. 

 MS. ARMSTRONG: So you're seeing a single point, 

but what it's really, what we really do is get the point on 

the entire span which aren't going to be the same as that 

number once you go across the entire span of pressure and 

flow. So that number is just the -- 

 MS. IYAMA: That number is the constant in that 

efficiency equation before it's de-rated. 

 MR. BURDICK: Right. But in the end aren't we 

going to end up with, or is the intention to end up with a 

value that's FEP type factor or are there going to be these 
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EL levels. So what's going to be the -- 

 MR. JASINSKI: The purpose of this is just to show 

that we analyzed a range of efficiency levels. In order to 

show what we're trying to say this table would have to have 

pressures and flows across a ridiculous range and there 

would be a different efficiency target numbers in every one 

of those cells. So this is, you can just, you know, I would 

ignore the efficiency target column. 

 MS. ARMSTRONG: Get on the flight. So at the end

of the day the standard will be a function of pressure and 

flow. So you're not going to see a single number in a hard 

line. 

 MR. SMITH: It's the format. 

 MS. ARMSTRONG: It's what we've discussed, the 

format of the metric and format the standard will take will 

be a function. 

 MR. JASINSKI: The point is that the analysis 

calculated results for everything from the least efficient 

fan, a level for least efficient fans up to the most 

efficient fans and a lot of increments in between. 

 MS. ARMSTRONG: Right. 

 MR. WOLF: So, the metric itself is going to be 

the FER or FEI -- 

 THE COURT REPORTER: Can you speak up? 

 MR. WOLF: The metric is ultimately going to be 
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this FEI or FER and what I envision in my head is a 3D 

surface or in a 2D -- 

 MS. ARMSTRONG: The bubble. 

 MR. WOLF: Yeah, I see the bubble. 

 MR. JASINSKI: Yeah. 

 MR. WOLF: And what might be easier for me to 

understand anyway is at the different levels what was the, 

you know, starting level, I'm assuming level one is 1.0, I'm 

making that assumption, I could be wrong. 

 MR. JASINSKI: 1.0 -- 

 MR. WOLF: Is what the initial target -- 

 MR. PERSFUL: Index. 

 MR. WOLF: -- index is going to be. 

 MR. JASINSKI: No, I don't think it, it would be 

better to not think of it in terms of the index. It would 

be better to think of it in terms of the FER equation as 

presented by AMCA. 

 MR. WOLF: Okay. Well the FER equation drives to

a number of right now 1.0, right? 

 MR. SMITH: Just get to your point because I 

think, what's the question though, related to the -- 

 MR. WOLF: Well, I'm wondering, you know, what 

we're thinking as we move forward, the level zero is going 

to be sea level as we talked about and as you move up it's 

going to be 1.1 or 1.2 or I'm just trying to get a feel for 
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it. 

 MS. MAUER: So I think, Mike, the standard, if we

did an index the standard that we'd end up setting would be 

one. 

 MR. WOLF: Okay. 

 MS. MAUER: So but here we're figuring out -- 

 MR. WOLF: Okay, where that means. 

 MR. JASINSKI: Fundamentally it's increasing in 

efficiency. So once the efficiency levels are selected for 

the engineering analysis DOE then models the manufacturing 

and production costs. First, DOE selects representative 

models, expand the range of equipment class, fan type, size, 

efficiency, manufacturers, et cetera. Then DOE generates 

bills of materials. These are based on physical and virtual 

teardowns, essentially deconstructing a subset of the models 

to evaluate what it costs to the manufacturer to produce a 

piece of equipment. 

 MR. WOLF: Sam, can I ask? 

 MR. JASINSKI: Sure. 

 MR. WOLF: Do you do that by the product classes 

(indiscernible) or -- 

 MR. JASINSKI: Yes, yes. And finally the 

manufacturer production cost is estimated using a cost model 

that uses those building materials as an input. The cost 

model includes assumptions for things like production 
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volume, labor rates, real estate values, et cetera, et 

cetera, et cetera. And finally I put the last one in blue 

because it's a little bit of a deviation from what's 

typically done in rule makings but as we found out in this 

industry the incremental manufacturer production costs may 

not necessarily, it might be zero when going from let's say 

a forward curved fan to a backwards inclined fan. Now this 

is the manufacturer production per unit cost. Once all the 

redesign has been done, once all the investment in R&D and 

any new production equipment is done, after that the cost to 

the manufacturer per unit to produce maybe a higher, a 

generally more efficient fan using a backward inclined 

blade, it won't show up in the MPC compared to a forward 

curved blade or it won't be, it won't be significant. And 

so similar to what was done on pumps, because we understand 

that the majority of the cost to make more efficient fans is 

in aerodynamic redesigns which include product conversion 

costs related to testing, R&D or capital conversion costs 

which are related to investments you'd have to make into 

your production facility in order to produce more efficient 

fans, for this engineering analysis those redesign costs 

were included in the cost efficiency relationships. And 

I'll get into more details about that. But first we 

estimate the number of redesigns required at each efficiency 

level. We also estimated the per model redesign cost and 
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with those we calculated the total redesign cost at each 

efficiency level. And as I said before we include those in 

the cost efficiency relationship and I'll explain how in 

just a minute? Bob? 

 MR. WHITWELL: Yeah. Bob Whitwell from Carrier. 

So, Sam, I want to take this down a rabbit hole but in our 

comments in response to the NODA we made some comments that 

the manufacturer and production cost and the redesign cost 

didn't take into effect, into consideration the impact on 

fan users to redesign and also the extra costs associated 

with putting more efficient fans in their equipment. And 

now after the meetings of this and now that I understand 

that I am a fan manufacturer as well I'm even more concerned 

about it, especially if it means that in order to meet a 

higher efficiency level we have to use a bigger fan. That 

means our equipment gets bigger, that means it's harder to 

replace and we'll get into conversion curves like the 

discussion that we've had in the other working group and we 

get into not only having to redesign the fan but then we 

also have to requalify that in our equipment -- 

 MR. JASINSKI: Sure. 

 MR. WHITWELL: -- which can be a very expensive, 

time consuming effort. 

 MR. JASINSKI: Sure. 

 MR. WHITWELL: So I think going forward that needs 
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to be some of the consideration based on the direction that 

this working group is headed. 

 MR. JASINSKI: What I would recommend is that, I'm 

assuming there are other people in this room who have 

similar concerns or maybe different concerns. When we go 

through this, look at this as how do I articulate those 

concerns to DOE, this provides that answer. So, while I 

might show you a cost, a cost assumption for testing time, 

if that, don't look at that as DOE hasn't accounted for me. 

Look at that as, if I want DOE to account for my concerns in 

that area that's the number I need to give them that 

reflects my situation. 

 MS. PETRILLO-GROH: Sam? 

 MR. JASINSKI: Yes? 

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

DOE has these numbers for all the regulated products, I 

mean, there's been an engineering analysis on unitary 

equipment, the list goes on and on. And in every single one 

of those engineering analysis that has been conducted they 

looked at the impact, the financial impact and the 

engineering impact of incorporating a larger fan into the 

product. I would suggest that while we work on our data, 

DOE go down and just look at all those rule makings and 

incorporates that financial burden and engineering burden 

into this. 
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 MR. JASINSKI: I can assure you that if that is 

the case we will absolutely be doing that. 

 MR. BOSWELL: So, one correction, the analysis 

that's done is not specifically looking at a larger fan. 

 MS. PETRILLO-GROH: Correct. 

 MR. WHITWELL: It's looking at higher efficiency 

levels or whatever the metric is. 

 MR. JASINSKI: Right. The other -- 

 MR. WHITWELL: So the larger fan is a completely 

different thing. 

 MS. ARMSTRONG: And to date we didn't, so this is

where your feedback and actually looking at the spreadsheets 

is key because to date we didn't find any situations for 

which increasing the efficiency of a fan, at least in our 

dataset, would require a change out in terms of the size. 

 MR. WHITWELL: Right. 

 MS. ARMSTRONG: So we kept the sizes the same. So 

it wouldn't have those downstream impacts. Now, we may get 

to a situation where that's not the case and we do need to 

then, and then we can look at other things. But I don't 

think it's necessarily one to one between the other

engineering analyses. We may have that data or could 

generate that data from data we have other rules but it's 

not necessarily one to one on the impacts because they are 

looking at slightly different things. 
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 MR. WHITWELL: It may not be one to one but it 

ought to be kind of directionally correct. 

 MS. ARMSTRONG: Right, that's what I mean. 

 MR. WHITWELL: For example -- 

 MS. ARMSTRONG: We can do that -- 

 MR. WHITWELL: Yeah. 

 MS. ARMSTRONG: -- but, I mean, fundamentally this 

analysis as you see it in a NODA did not change size. Those 

impacts would not occur, period. 

 MS. PETRILLO-GROH: Sure. 

 MR. WHITWELL: Okay. 

 MS. PETRILLO-GROH: But actually there's -- 

 MS. ARMSTRONG: So, I mean, that's where your data 

comes into play. If there's data that you have on your, you 

know, to include in that fundamental data set that would 

show otherwise then that's when we would need to --

 MR. WHITWELL: Right, understood. 

 MS. ARMSTRONG: -- account for and we haven't had

a need yet. 

 MS. PETRILLO-GROH: Ashley, I’m a little confused

how the data that we're going to collect would actually be 

able to answer that question of increasing efficiency of the 

fan -- 

 MR. JASINSKI: Well, you'll see later on. We'll 

get into some questions about how we built the logic model 
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to determine when a fan was redesigned, when it was

reselected, your input on how to construct that logic model 

for your particular equipment or products is where we would 

account for that. So that's what I was saying in terms of, 

you know, instead of, it's important to understand what was 

done and what was in and what was out and all of that. But 

the other thing is that this is probably going to go through 

a lot of changes and we are going to, DOE is going to rely 

on your feedback to execute those. So if you want this 

analysis to tell your story accurately look for the levers 

that need to be pulled in order to do that. There will be 

mechanisms in here that will allow for us to account for 

those things even if they weren't necessarily executed or 

implemented in this particular analysis the way you would 

like them to. Recognize that they could and that there's 

data that we need or information that we need in order to do 

that. 

 MR. DADDIS: I'm Duane Daddis, Carrier. You 

mentioned that the size wasn't changed. Did we look at 

different fan types? Still a lot of testing to change a fan 

type I guess -- 

 MS. ARMSTRONG: Yeah, so I mean I get that but so

there are different costs and considerations. So you should 

make sure you're comfortable with some of the things and how 

we implemented but I did want a caveat that the dataset that 
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we have we were otherwise able to find a more efficient 

selection to go in without changing the size. 

 MR. WHITWELL: And that's all the way up to EL6? 

 MR. JASINSKI: Yup. 

 MR. WHITWELL: Okay. 

 MS. ARMSTRONG: Yep. 

 MR. STARR: So this is Louis with NEEA. So, two 

things, first one, it sounds like when the manufacturers go 

back with a new equation and stick it in they'll see whether 

the return fans and supply fans change size and they can 

stick in the EL levels that you've put in the for the 

various levels and stick that in and see between fan size 

and once they do that they'll know if it's going to affect 

their casing if they just did it on commercial AC or have an 

idea -- 

 MR. JASINSKI: So with the tools we provided the 

manufacturer won't be able to tell whether to change size. 

The way it works now is it will just say that it is, it 

passes EL0, 1, 2, 3, 4, and if the -- 

 MR. STARR: So it's not, they don't have the 

equations or the equations not available? It's not the 250, 

or it's the -- 

 MR. JASINSKI: Does the tool indicate whether it 

would be redesigned or reselected? 

 MR. WAGNER: This is Greg. One of the things to 
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keep in mind is that the data that these manufacturers, and 

that was a big part of the message yesterday, is not the 

same data as what's being analyzed here. So their fan 

energy consumption efficiency numbers and all those kinds of 

things are based on a totally different operating point, 

different efficiency metric than what you would have shown 

in this analysis. 

 MR. STARR: I don't understand that. 

 MS. ARMSTRONG: I don't understand what you're 

saying either? 

 MR. STARR: Yeah. 

 MR. WAGNER: This data for fans and AHRI 

appliances, it's inside the box with all the other 

pertinences. So you have the system loss as well as the 

pressure drops through each of the each other different 

types of coils, filters and other items within that box. 

 MS. ARMSTRONG: I think we understood that and we

kind of dealt with that yesterday by saying what do you 

want. And so that's where it's on you guys to come, I mean, 

yes you gave a presentation that at the beginning ended 

with, we think we should be tested in a box and then 

subsequent to that is, well wait a minute we think we might 

not want to be accounted for. And then subsequent to that 

is, well maybe don't want to be, we want to be outside. 

Anyway, long story short, it's more of a question about -- 
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 MR. WAGNER: Well let me -- 

 MS. ARMSTRONG: -- what do you want at this point. 

So -- 

 MR. WAGNER: Let me be more precise in what I’m 

saying. What I’m saying is those efficiency numbers shown a 

couple slides ago or a slide ago are based upon a fan only. 

 MS. ARMSTRONG: Yeah. 

 MR. WAGNER: Numbers, efficiencies or whatever 

performance metrics that they have to compare air flow to 

energy are not going to be in the same category. So saying, 

go back to your, and analyze this based upon your level of 

efficiency, we're talking apples and oranges. They're not 

the same, they're not the same starting point of how you 

measure efficiency -- 

 MS. ARMSTRONG: Yeah. 

 MR. WAGNER: -- or how you can begin to say -- 

 MS. ARMSTRONG: So -- 

 MR. WAGNER: -- we have to -- 

 MR. JASINSKI: Point taken. 

 MS. ARMSTRONG: You guys come back and said one 

that talks about a box -- 

 MR. JASINSKI: So I'm going to keep moving 

forward. So, within the engineering analysis you'll see the 

fan groups to the left and these align with the equipment 

classes that were discussed -- 
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 THE COURT REPORTER: I'm having trouble hearing. 

 MR. STARR: I actually had another question. It's 

the last one on this one. It had to deal with, so you 

looked at changes between fans, types, did you look, so if I 

had -- 

 MR. JASINSKI: We're going to get to the logic 

model -- 

 MR. STARR: Oh, okay. 

 MR. JASINSKI: -- it will explain -- 

 MR. STARR: All right, I'll wait. 

 MR. JASINSKI: -- when a fan was deemed noncompliant with the level. We have a logic model that says, 

okay, within the same fan type and within a certain

tolerance of the performance point and at the same size, is 

there another fan that was sold where it could just be 

reselected. 

 MR. STARR: Okay. So in other words if you had, 

let's say you had a given EL level, you had a fans that had 

a number of design points that you have a new or higher EL 

level, now you only have, you know, five of your fan 

selection will fit so essentially you have to redesign your 

fan line. 

 MR. JASINSKI: Well, that -- 

 MR. STARR: Did you get into that or not really? 

 MR. JASINSKI: That is where we need feedback -- 
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 MR. STARR: Okay, got it. 

 MR. JASINSKI: -- from the group to say, as a fan

manufacturer if X percent of your operating points -- 

 MR. STARR: Disappear. 

 MR. JASINSKI: -- are non-compliant would that 

trigger a redesign. 

 MR. STARR: Right. 

 MR. JASINSKI: And I believe the answer would 

probably be different for every different model for every 

different fan manufacturer. But, that is something that we 

would -- 

 MR. STARR: Okay. 

 MR. JASINSKI: -- can and would like to include 

into the logic model to the extent possible -- 

 MR. STARR: Yeah. 

 MR. JASINSKI: -- and to the extent agreeable to 

the working group. So, I'm having a hard time seeing these. 

Are they dark enough? Can people read these? So, you'll 

see on the left the fan groups. These align with the 

equipment classes as we've been discussing them. Within 

each equipment class DOE identified subgroups. Typically 

these were whether there was presence of guide vanes or not, 

different blade designs, and while it's, essentially these 

are subgroups to identify design changes that impact 

efficiency. And in general but it's understood not always, 
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an airfoil is generally more efficient than a forward 

curved, et cetera, et cetera. And these are designs that we 

want to capture whether or not the manufacturer production 

cost of those designs should be accounted for in terms of 

making a fan more efficient. And so those were the

subgroups that were identified and then you'll see the 

column to the right that we were, we had to tie these back 

to the database that we were given. And sometimes 

information to differentiate these subgroups was not 

available in the database and so the groups all the way to 

the right, the database categories are what were actually 

analyzed. So, for instance you'll see that in a database 

backward curved centrifugal housed and backward inclined 

centrifugal housed were not differentiated. So we analyzed 

them as backward bladed. In the centrifugal unhoused 

category there was no differentiation for the subgroups so 

all the fans within that subgroup were lumped together. And 

so you'll see results throughout this engineering analysis 

by the database category. In some cases we came up with 

intermediate results for the subgroups and then we had to 

combine those mathematically in order to represent a 

category where the subgroups were not differentiated in the 

database. 

 MS. PETRILLO-GROH: So, quick question. Laura 

Petrillo-Groh, AHRI. So when you said in the efficiency 
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level was analyzed or the slide that the subgroups weren't 

preserved does that mean that there was a centrifugal housed 

fan that was -- 

 MR. JASINSKI: The efficiency -- 

 MS. PETRILLO-GROH: -- in each level or -- 

 MR. JASINSKI: The efficiency levels were analyzed 

for each of the database categories. 

 MS. PETRILLO-GROH: Database categories. 

 MR. JASINSKI: Database categories. I'm sorry, 

no. The fan groups, each efficiency level was analyzed for 

the fan groups. The subgroups here are just a construct in 

the engineering analysis to identify designs that may have 

impacts on the manufacturer and production costs. 

 MS. PETRILLO-GROH: So, then it's, so sorry if 

this was already covered, does that mean for example, 

centrifugal housed fans max tech you might have lost all the 

forward curved fans? 

 MS. ARMSTRONG: It's in the -- 

 MR. JASINSKI: Yeah, it's in the databases but 

I'm, I can't say with 100 percent certainty but I don't 

believe any whole subgroups were eliminated. Sanaee is 

shaking her head and she's pretty familiar with the

database. 

 MS. IYAMA: Yeah, all of them. 

 MR. JASINSKI: Were not eliminated. 
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 MS. IYAMA: We never reached a point where 

something disappeared -- 

 MS. PETRILLO-GROH: Okay, thank you. 

 MS. IYAMA: -- off the market. 

 MR. SMITH: But to go back to that, apparently you 

did have circumstances where you replaced a forward curved 

with a backward inclined. 

 MS. IYAMA: Right. I mean, yeah. 

 MR. JASINSKI: In the LCC? 

 MS. IYAMA: When a fan was reselected, yeah. 

 MR. SMITH: At the same diameter? 

 MS. IYAMA: Yeah. 

 MR. JASINSKI: But not if there was another fan of 

the same fan type available. 

 MS. IYAMA: Yeah. So, I think we'll get to that. 

I mean, I don't know for sure that it happened but if they 

were, if the database had such fan then it could have. 

 MR. JASINSKI: Right. So there are some 

limitations here. We are, when we get to the reselection 

and redesign logic model I think we can go into those but I 

can tell that the group is already identifying some of the 

limitations of that database and that we would like to get 

feedback from the working group that may address some of 

those limitations. Yes? 

 MR. SMILEY: When you say fan diameter I think 
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that they found that referred to a fan impeller diameter -- 

 MR. JASINSKI: Yes. 

 MR. SMILEY: -- is that correct? Well, an FC fan

impeller diameter and airfoil BI impeller diameter might be 

the same but the housing they go in might be totally 

different in size. So when you say we did the same diameter 

for the same diameter, changed fan types, so did you take 

into account any physical geometry size change -- 

 MR. JASINSKI: Okay. 

 MR. SMILEY: -- might be something that needs to 

be considered. 

 MR. JASINSKI: Okay. If there are, you know, I'm

sure there's a lot of variation but if there are general 

rules of thumb about how, you know, the fan housing, the 

ratio of the diameter of the fan housing to the impeller is 

different for, et cetera, that would be good to know and we 

can try to incorporate that to make sure that the overall 

size of the fan assembly or testable configuration does not 

increase this. That's useful. Thank you. Wade? 

 MR. SMITH: So, from the very beginning we have 

argued that the forward curved fan has a completely

different utility that is unique and peculiar to forward 

curved fans and unique and different, a lot different, from 

backward inclined and airfoil. So, in our proposal to the 

advocates and to DOE and in all our comments we understand 
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and agree that backward inclined, backward curved, airfoil 

fans are different efficiency shapes of the same color but 

they don't behave at all like forward curved fans. They're 

different acoustically, they're different structurally, 

they're different RPMs, they're different vibration

questions, they're completely different and Bill just 

pointed out that the physical size of the scroll that 

surrounds the wheel is also completely different. 

Substituting one for the other is a big change. You know, I 

want to say that the fan manufacturers very, very strongly 

argue that there's a difference in utility and that forward 

curved fans need to be a category unto themselves because 

their utility in the marketplace is peculiar and unique and 

not interchangeable with backward inclined fans. Having 

said that, there are applications where the exchange of one 

for the other is not material and to the extent that one 

might be more efficient than the other, we want to encourage 

people to move to the more efficient fan. But it's a gross 

mistake to suggest that all forward curved fans could 

suddenly become, or any forward, every forward curved fan 

could, if cost justified, move to a backward inclined. 

That's just not true. 

 MR. JASINSKI: Okay. 

 MR. SMITH: Okay. 

 MR. JASINSKI: So, I'll explain the implications 
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of this type of grouping in that if they are grouped 

together then that would mean that when standards are set 

the same standard would be applicable to all of the fans in 

the subgroup associated. My understanding is that AMCA and 

the advocates wanted to go the ducted and unducted route and 

set the same standard for those groups. And so I'm just 

explaining -- 

 MR. SMITH: It doesn't matter. It shouldn't but 

it does and here's why, here's when it matters. When you 

say a forward curved fan embedded in a product has become 

non-compliant and so to eliminate any impact that the 

increase in efficiency that's about to happen, to eliminate 

any impact on the casing we're going to preserve the 

diameter but then you change it to backward bladed, I’m 

sorry, you haven't preserved. You see what I'm saying? 

 MR. JASINSKI: Yeah. 

 MR. SMITH: You haven't done what you intended to

do. Backward bladed fan -- 

 MR. JASINSKI: Let me just -- 

 MR. SMITH: -- of the same diameter is a different 

casing, different fan, different structure and different lot 

of things. 

 MR. JASINSKI: I understand. Let me just, I want

to finish by saying that I was bringing that up to show that 

there are different ways to account for what you are talking 
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about in the rule-making analysis. And I want to make sure 

that you're focusing on the right mechanism to do that. I 

was just explaining the implications of groupings so the 

equipment classes may not be the best mechanism for

preserving what you're talking about. The logic model later 

on that determines when the impacts of a redesign or a 

reselection are estimated might be a better place for that. 

So it might be, could be -- 

 MR. SMITH: That point is well taken. 

 MR. JASINSKI: Okay. 

 MS. ARMSTRONG: That's where feedback would be 

good, though. 

 MR. WOLF: So this could help me understand. What 

are you proposing relative to this slide? 

 MR. SMITH: Nothing. I just wanted to point out 

that -- 

 MR. WOLF: All right. That's all I -- 

 MR. SMITH: I wanted to put on the record an 

objection to (indiscernible). 

 MR. WOLF: So then the next question I've got for

Sam is you're only doing the ducted and non-ducted, would 

that potentially be another column on here that helps us -- 

 MR. JASINSKI: No. Where that would come in would 

be the test procedure. 

 MR. WOLF: All right. 
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 MR. JASINSKI: So there would be, of those fan 

groups, some would be designated as ducted, some would be 

designated as unducted and that would have impacts on how 

they were tested. 

 MR. WOLF: This is -- 

 MS. ARMSTRONG: So that first group would have 

ratings -- 

 MR. JASINSKI: And the metric. 

 MS. ARMSTRONG: -- that are, would have ratings 

and efficiency levels that are analyzed based on their 

ducting configuration. 

 MR. WOLF: Okay. 

 MS. ARMSTRONG: Period. So this is where the 

earlier discussion matters. 

 MR. JASINSKI: Right. And the metric would be --

 MS. ARMSTRONG: Right. 

 MR. JASINSKI: -- total versus static. 

 MR. FLY: Mark Fly with AAON. I'm still trying to 

get my head around some of this. When you looked at a fan 

and say that you decided that it was a non-compliant fan at 

some point of operation, some selection, and you looked for 

a fan to replace it with that was compliant are you looking 

at the same point of operation -- 

 MR. JASINSKI: We -- 

 MR. FLY: -- same cfm and -- 
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 MR. JASINSKI: There was a tolerance of what, 20 

percent -- 

 MS. IYAMA: There's a slide on this later on. 

 MR. JASINSKI: Yeah. 

 MR. FLY: Okay. 

 MR. JASINSKI: We're going to get there. 

 MR. FLY: I'll wait. 

 MS. IYAMA: Right now we're just talking about, 

you know, in the event where that fan had to be redesigned 

how did we estimate the cost of that redesign and that's it. 

 MR. FLY: Okay. 

 MR. JASINSKI: So, I think we're going to get to a 

lot of these questions and if we don't we can circle back. 

 MR. FLY: Right. 

 MR. JASINSKI: So, a little bit more information 

on how we calculate the manufacturer production costs. Like 

I said, we only conducted teardowns to generate bills 

materials. We did physical teardowns on roughly five units 

which represented four out of the 26 subgroups and then we 

did what we call virtual teardowns on the remaining

subgroups. A virtual teardown is we would refer to

specification sheets, drawings, any other information we can 

get our hands on in terms of identifying the types of, the 

components, designs, materials, processes that might be used 

and compare those to our physical teardowns. So, for 
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instance, you can imagine if you did a physical teardown on 

a tube axial you could look at a schematic or a product 

literature for a vane axial and try to get into about those 

vanes that would allow you to incorporate the cost and make 

sure that the designs are similar everywhere else, that you 

could come up with an estimated manufacturer production cost 

for something that you didn't physically tear down just as 

an example. So we did a lot of those too to, because it's 

impractical to tear down every model of every fan type and 

every variation. 

 MR. SMITH: That's what we say about testing. 

 MR. WAGNER: Hey, Sam, this is Greg. 

 MR. JASINSKI: Yup. 

 MR. WAGNER: Question on the, how do you 

differentiate between high volume, low volume products and 

things like that because we make the same product, same size 

in two different methods and a low volume product line is 

significantly higher cost than a high volume product. 

 MR. JASINSKI: So, within the cost model that I 

discussed and is referenced in the second bullet there are 

assumptions made for production volume. At this time I 

believe the production volume is kept constant for all of 

the fan groups but that doesn't have to be the case. If we 

get feedback that certain fan groups are at a certain 

production volume than others we can certainly make
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modifications to that. For instance, if you look at the 

furnace fan rule I remember that some of those product 

classes were deemed high volume product classes and some 

were deemed low volume product classes and certain 

differences, for instance, in the assumed production volume 

were incorporated in the analysis to reflect the impact on 

manufacturer production costs as well as some other things. 

So that would be something that would be up to the working 

group if you wanted to provide feedback on the production 

volumes by fan group or subgroup or whatever else that would 

be very helpful for this cost analysis. So to the right you 

can see a diagram that tries to illustrate the process. As 

I said, we did physical and virtual teardowns. The raw 

materials, we evaluate the fabrication processes used to 

create finished materials. Anything that was purchased we 

also incorporate into the assemblies and then ultimately 

after we weighed, measured, identified the materials, 

processes used, we put those bills of materials into the 

cost model and it uses those inputs to estimate a 

manufacturer production cost. Here you will see an example 

of the outputs from that cost model to give you an idea of 

exactly what's included. The numbers here are just

illustrative. On the left you can see the cost category. 

In the middle you can see the cost estimate. I believe this 

is for a centrifugal housed, either 22, I think 22,
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somewhere between 20 and 30 inches impeller diameter. And 

then to the right you can see a brief description of what's 

included in that cost category. So I know there's a lot on 

here. I can give people a minute to read through it. But 

this is also included in the NODA materials that are 

published on the DOE website if you want to take a look at 

those later. You can also get with me after the meeting or 

separately if you want more information about these. 

 MR. WHITWELL: So is this a fan without, with the

housing but no motor? 

 MR. JASINSKI: This would be without the motor. 

 MR. WHITWELL: Housing, shaft, structure -- 

 MR. JASINSKI: Yes. 

 MR. WHITWELL: -- fan. 

 MR. JASINSKI: Yup. 

 MR. WOLF: And what level of detail do you take 

this in -- I know that I probably should know that, but -- 

 MR. JASINSKI: This is exactly what's on -- 

 MR. WOLF: But I mean you take it into the product 

category or -- 

 MR. JASINSKI: Yup. I don't know if it's included 

in here but there's a slide that we'll show that number 

that's at the bottom, the total, for every fan group, every 

efficiency level and I think we also included some 

representative diameters to show you what it would be at a 
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given diameter. And I'll show you how we get to those 

different costs from the small subset that we actually did 

teardowns on. So that's what we're going to get into here. 

So this slide, just explaining how we developed the

relationship between manufacturer production costs and 

diameter. So we used teardown results to characterize this 

relationship. We also did a series of manufacturer

interviews to get feedback on this relationship and this is 

what we got. So you can see the form of the equation. MPC 

is a function of a constant A times the diameter plus the 

diameter raised to the power of another constant, B. 

 MS. PETRILLO-GROH: Sam? 

 MR. JASINSKI: Yup. 

 MS. PETRILLO-GROH: Would you be able to publish 

the, you know, any redacted version of the manufacturer 

impact analysis interviews or just distribute that to the 

group since -- 

 MS. ARMSTRONG: We'll think about that. 

 MR. JASINSKI: Okay. I think that would be up to

DOE. Any questions about this slide? 

 MR. WAGNER: Hey, Sam? 

 MR. JASINSKI: Yup? 

 MR. WAGNER: Sam, this is Greg, how many points 

were used to make that curve? 

 MR. JASINSKI: I'm sorry, can you repeat that? 
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 MR. WAGNER: How many points were used to make 

that curve? I see two points on the screen but -- 

 MR. JASINSKI: This curve was based on two data 

points but the curve form was based on feedback that we got 

from multiple manufacturers. 

 MR. DYGERT: Excuse me, I have a question. 

 MR. JASINSKI: Yes? 

 MR. DYGERT: Ryan Dygert, Carrier. So do you have 

a different curve for different types of fans I'm assuming? 

 MR. JASINSKI: Yes, that's on the next slide. 

 MR. DYGERT: Okay. 

 MR. JASINSKI: So this was for one fan type. On 

this slide I explain how we translated that relationship to 

the other fan types. So we established a multiplier, M, to 

adjust this curve to each subgroup. So it goes even in more 

detail than just by fan group. You can see the form of the 

equation there and we essentially took the same form of the 

equation and used it for multipliers to overlay that 

equation on the other virtual and physical teardown points 

that we had for the other fan groups to get the, or fan 

subgroups, to get the MPC equation as a function of diameter 

for each subgroup. And at the bottom right I've included an 

example. So this is centrifugal unhoused backward inclined. 

So we have the diameter of the CUBI fan as 20 and a half 

inches. The estimated MPC of this CUBI based on that green 
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equation is, or I’m sorry, the estimated MPC based on the 

teardowns of the CUBI is in the second row there, $581 and 

change. The calculated MPC based on the equation I showed 

in the last slide which is the same as equation one here is 

$964.09. So the multiplier is just the ratio of those two 

to get the adjustment factor to get the general form of the 

equation to align with our teardown value of $581 and 

change. And this was done for each subgroup. Louis? 

 MR. STARR: Louis of NEEA. I noticed your fan 

wheel goes down to about 10 inches which is not exactly sure 

but somewhere between one and two horsepower. So, for 

anything less than that do you have any -- 

 MR. JASINSKI: These are, to a certain extent I 

wouldn't look too far outside of the points that are shown 

on the graph. I think this was just for illustrative 

purposes. 

 MR. STARR: Okay. 

 MR. JASINSKI: Any other questions before I move 

on? 

 MR. SMILEY: One question. Are you, are we 

looking for some indication from manufacturers as to whether 

we think that curve's too high or too low and by maybe some 

sort of an amount? 

 MR. JASINSKI: Yeah. I mean, we're looking for 

feedback on everything. We're looking for feedback on -- 
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 MS. ARMSTRONG: I mean, obviously we welcome that. 

That's usually typically not something that we'll see at a 

public meeting, other than just -- 

 MR. SMILEY: Right, it wouldn't be -- 

 MS. ARMSTRONG: But to the extent people -- 

 MR. SMILEY: It would be given to you guys. 

 MS. ARMSTRONG: -- wanted to do it in a private 

manner, especially a confidential manner, I would 

(indiscernible). 

 MR. JASINSKI: Basically anywhere you've seen a 

number, if you want to give us a different number we'll take 

it. If it's for all these categories, some of these 

categories, just that last number, these constants. If you 

want to give us data for any of this we will incorporate it. 

 MS. ARMSTRONG: The point here today is to show 

you what we have done to date which is this draft. 

 MR. MATHSON: Tim Mathson. I just, I know, Sam, 

you said I wouldn't use it too much beyond these points. I 

would, if you're going to go to the left I would say that 

point levels off. 

 MR. JASINSKI: Okay. Obviously. 

 MR. MATHSON: A size 12 and a size 13 cost the 

same amount to build. 

 MR. JASINSKI: Right. 

 MR. MATHSON: So, and I'd hate to go too far to 
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the right. 

 MR. JASINSKI: I thought I saw one more hand. 

 MR. BUBLITZ: Mark Bublitz, New York Blower, I'm 

looking in the lifecycle cost spreadsheet and I’m seeing the 

result -- 

 MR. JASINSKI: Okay. 

 MR. BUBLITZ: -- the consolidated number but I 

don't see the -- 

 MR. JASINSKI: So there's a -- 

 MR. BUBLITZ: -- factors by -- 

 MR. JASINSKI: There's an engineering spreadsheet. 

 MR. BUBLITZ: Okay, an engineering. 

 MR. JASINSKI: So, it's in a separate spreadsheet. 

 MR. BUBLITZ: Thank you. 

 MR. JASINSKI: Yup. So, using those relationships 

we calculated the MPC individually for each of the 

subgroups. As I mentioned earlier, not all subgroups were 

differentiated in the AMCA database. So in those cases, we 

averaged the subgroup MPCs to be consistent with the fan 

categories in the AMCA database. For example, the AMCA 

database didn't differentiate between airfoil, BI and BC 

unhoused centrifugal fans so DOE averaged its MPC results 

for those subgroups to get a representative MPC for unhoused 

centrifugal fans. And then the last bullet point here, at 

each efficiency level we weighted the fan group MPCs based 
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-- or I'm sorry, for each fan group we weighted the fan 

group MPCs based on the distribution of subgroup shipments 

in the AMCA database. So, within a fan group, let me go 

back here to give you an example. So for instance, to get a 

representative MPC for centrifugal housed we weighted the 

MPC by shipments of airfoil, backward bladed and forward 

curved. If we had, if those were differentiated in the AMCA 

database. And this was the table I was showing you. This 

is the engineering analysis results. You can see all the 

fan groups to the left. Across the top you can see the 

efficiency level. M, this is that multiplication, the 

adjustment factor to get the curve. Then you can see some 

representative diameters and then you can see example MPCs 

for each of those diameters. And the reason that M

increases with efficiency is that the distribution of the 

subgroups within those, within the groups gets more

efficient essentially so that curve moves up. 

 MR. ERNST: So forward curved, this is Skip Ernst, 

forward curved and airfoil must be averaged or blended to 

get centrifugal housed? 

 MR. JASINSKI: Yes. So, the way I would read this 

table, because of how they were blended and averaged is 

essentially saying that DOE is estimating that in order to 

get a 20 inch diameter fan, let's say centrifugal housed, in 

order to get a 20 inch centrifugal housed diameter fan to 
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meet a target efficiency of 87 de-rated by pressure and 

flow, to meet efficiency level two would cost a manufacturer 

$803 to manufacture that fan. That's what this table is 

saying. At that same efficiency level for the same group it 

would cost a manufacturer $1600 to manufacture a 30 inch 

fan. 

 MS. PETRILLO-GROH: Sam? 

 MR. JASINSKI: Yes? 

 MS. PETRILLO-GROH: Sorry, does this include the 

motor or not? 

 MR. JASINSKI: No motor. 

 MS. JAKOBS: This is Diane Jakobs. So why doesn't 

radial change for any of the EL levels? 

 MR. JASINSKI: So the reason radial does not 

change is because there were no, no subgroups identified in 

the AMCA database. So, it was, this is, this is exactly why 

we incorporated the redesign costs in the MPC is because 

we've heard from the industry that the cost of, the

manufacturer production cost of generally more efficient fan 

subgroups may not be more expensive to manufacture. So, 

that may or may not be the case for radial. But the reason 

it shows up that way in our analysis is because the AMCA 

database did not provide any differentiation between the 

subgroups that were identified that might impact efficiency 

and therefore basically the manufacturer production costs 
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at every efficiency level for a radial is just assumed to be 

the same. 

 MR. SMILEY: Bill Smiley, Trane. Sam, but what 

you are showing is if that's not the case you can adjust 

that -- 

 MR. JASINSKI: Absolutely. 

 MR. SMILEY: -- because you've got the capability

in your -- 

 MR. JASINSKI: Absolutely. 

 MR. SMILEY: -- analysis to accommodate that. 

 MR. JASINSKI: Yes. 

 MR. SMILEY: But you just call that the data. 

 MS. ARMSTRONG: Right. 

 MR. JASINSKI: Right. 

 MR. WOLF: I believe you said that the redesign 

costs were factored into to the MCP. 

 MR. JASINSKI: No, no, no. The redesign cost is 

separate. 

 MR. WOLF: Okay. 

 MR. JASINSKI: It's factored into the 

manufacturer's selling price which comes up later in the LCC 

analysis. So this is only the cost to the manufacturer to 

produce the unit. 

 MR. SMITH: So in the database you've got radial 

fans to focus in on that one at many different peak
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efficiency levels and many different applied efficiency 

levels. And for each fan that was sold you have both. You 

also have the selling price. But obviously you don't have 

the cost. So you believe based on your interviews is that 

the cost to make an efficient radial fan and an inefficient 

radial fan is the same? 

 MR. JASINSKI: I would state it a little different 

in that we can't always show what we believe if we can't 

substantiate it in terms of -- 

 MR. SMITH: But the feedback you got led you to 

this being what you believe is truthful. 

 MR. JASINSKI: This is our interpretation of the 

industry based on the information that we could gather or 

have been given. 

 MR. SMITH: Well, are you looking for feedback to

suggest that this is wrong and there ought to be something 

different? 

 MR. JASINSKI: Absolutely. That was the point of

this analysis. The point is also to show, it's also to show 

you when giving that feedback we, anecdotal we try to 

incorporate anecdotal evidence as much as possible but if 

you're telling us that radial fans at higher efficiencies 

will cost a manufacturer more to produce we need to know how 

much more, we need to know why. 

 MR. SMITH: So the -- 
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 MR. JASINSKI: We need to know -- 

 MR. SMITH: -- form of the input that you're 

looking for is from a manufacturer who says, this is my 

manufactured cost on model Z and model B which are both 

radial fans in this category, model Z is much more efficient 

than model B, cost me more to make, here's my detailed cost 

sheets, you can compare, and that would suggest that your 

cost model at the different efficiency levels ought to look 

like this and not what it does? 

 MR. JASINSKI: Yes. 

 MR. SMITH: And it's anecdotal because they have,

we make 10,000 of these fans and we make 2,000 of these fans 

and so it's not anecdotal, there's a lot of volume attached 

to these numbers but I've got two points because I make two 

radial fans. Actually, most of the companies that make 

radial fans make a lot more than two different ones. 

 MR. JASINSKI: Well -- 

 MR. SMITH: But the point is that one company 

which makes multiple fan models that are different 

efficiency levels is in a position to answer you at a 

credible way to change these numbers, am I correct?

 MR. JASINSKI: Yes. And the last thing I want to

do is trivialize the feedback that you guys have given us. 

So when I mean anecdotal I just mean -- 

 MR. SMITH: No, I -- 
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 MR. JASINSKI: -- qualitative is probably -- 

 MR. SMITH: No, I -- 

 MR. JASINSKI: -- a better way to describe it. 

 MR. SMITH: No offense taken. 

 MR. WOLF: So, go to the next slide, the next one. 

 MR. JASINSKI: The table? 

 MR. WOLF: So, help me understand rule-making 

process. Where does this data fit into that process? I 

guess to raise public question, is let's say for example the 

number you gave for those level two, for that centrifugal 

how it goes from a 20 inch fan $747 -- 

 MR. JASINSKI: Right. 

 MR. WOLF: -- to $800. 

 MR. JASINSKI: Right. So -- 

 MR. WOLF: What if that number goes to $8,000? 

 MR. JASINSKI: These results are inputs for 

downstream analyses -- 

 MR. WOLF: Okay. 

 MR. JASINSKI: -- such as the lifecycle cost 

analysis. 

 MR. SMITH: Where else are they used? 

 MS. ARMSTRONG: Everywhere. I mean, the bottom 

line is this is deep down basic. This is the foundation of 

all the downstream economic analyses period. This is what's 

going to drive LCC, this is what's going to drive the MIA, 
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at least in terms of the cost side of it this is what's 

going to drive the MIA. I mean, what matters is not the 

total cost, it's the delta. And then deltas get added to 

that later for other things. So maintenance cost, repair 

costs, selling price is going to account for your capital 

type changes that you need to make. But this is what's 

happening to your product. As we increase efficiency what 

happens to the cost of your product. That is a driver, the 

delta is a driver throughout. And so we're going to accrue 

costs at each, you know, at each of the analyses for 

different things. We're going to accrue savings. 

 MR. SMITH: Right. So, at the end of the day 

yesterday -- 

 MS. ARMSTRONG: You asked about the -- 

 MR. SMITH: -- I asked about the sensitivity and 

the reason is because when we sit down and say, well I don't 

believe those cost numbers, these cost numbers are more 

accurate. And if that's a material change to the outcome of 

the analysis then it becomes really important. But if it 

doesn't make a material change to the outcome of the 

analysis it's a lot of effort with no perceived benefit. 

I'm trying to, I'm trying to understand whether or not 

there's benefit zeroing in on this data or whether we should 

just leave it alone. 

 MS. ARMSTRONG: I don't have an answer for you 
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yet. 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: If there's, I would say if 

something looks fundamentally off you should raise it. 

 MR. SMITH: Right. 

 MS. ARMSTRONG: You'd be surprised how much 

incremental little things add up. But at the same time, 

nitpicking every cent is probably also -- 

 MR. SMITH: Yeah. 

 MS. ARMSTRONG: -- not where you want to go. 

 MR. SMITH: Right. 

 MS. ARMSTRONG: If we're in the general ballpark,

you know, I think we can agree to disagree but these numbers 

are typical but maybe not representative -- 

 MR. SMITH: Right. 

 MS. ARMSTRONG: -- of any particular person. 

 MR. WAGNER: This is Greg. Taking a look at the 

axial fans, particularly the panel fans, why are any of them 

made at EL0 would be my first question because if EL6 costs 

exactly the same there shouldn't be anybody making the ones 

at EL0, is there? 

 MR. SMITH: You bet. 

 MR. WHITWELL: So, similarly -- 

 MR. WAGNER: So, my point is, kind of what Wade 

said, I think there is a significance here that should be 
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looked at because I can't imagine that axial fans are the 

same cost at all efficiency levels. 

 MR. JASINSKI: So this is cost to the 

manufacturer, not to the consumer. So, there might be other 

factors that, you know, factors in the market that require 

other types of, you know, model differentiation that don't 

impact efficiency and those would not be captured here. 

 MR. WAGNER: Well, could you describe that for me

for an axial housed panel fan because I don't know what that 

would be. 

 MR. JASINSKI: Well -- 

 MR. WAGNER: People aren't buying these 

necessarily on the street either but -- 

 MR. JASINSKI: Well, maybe another fan 

manufacturer can help me out here. 

 MR. HARTLEIN: Yeah, this Dan, can you hear me? 

 MR. JASINSKI: Yes. 

 MR. HARTLEIN: Good morning. You know, there's a

massive difference in the construction of a high efficient 

axial fan and what we might consider a commodity product. 

So, to Greg's point he's right. That's not representative. 

As the efficiency of an axial fan goes up the cost goes up 

quite fantastic. Trinity has a couple of pictures, or a 

couple of 90 percent axial fans that are like 90 percent 

efficient and you can see that the cost of those products 
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are not relative to this equation. So it's a very, very 

different product. So Greg's point is correct. 

 MR. WHITWELL: Bob Whitwell from Carrier. I mean

I think the same thing can be said about the centrifugal and 

how, I don't know if that's, if there's a typo there but how 

can it not be a cost difference? 

 MR. JASINSKI: So the reason you're not seeing 

cost differences, and I'll go back, is driven by the fact 

that the subgroups here are a list of design changes that we 

identified as generally impacting the efficiency of the fan. 

If those sub, if those design types were not differentiated 

in the database of sales that we had, there was no way with 

this methodology to account for those, those cost 

differences. 

 MR. SMITH: Well, they are. 

 MR. JASINSKI: Because we couldn't identify them.

 MR. SMITH: Yeah, well, you've got three 

categories in the database here from the backward inclined 

and forward curved blades. 

 MS. IYAMA: I don't -- 

 MR. JASINSKI: Well, he was talking about the 

centrifugal un-housed. 

 MR. SMITH: Oh, okay. 

 MR. WHITWELL: But I'm assuming that as you go 

from low efficiency to high efficiency, I mean that could go 
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from a -- 

 MR. SMITH: Flat blade to a -- 

 MR. WHITWELL: -- flat blade to airfoil, right? 

That's the -- 

 MR. JASINSKI: Well -- 

 MR. WHITWELL: There's a big -- 

 MR. JASINSKI: Sure. So we, so we identified that 

as a, right? We tried to identify that and if we had, if 

the database had those subgroups differentiated we could 

have captured that. 

 MR. SMITH: But the database doesn't have cost 

information anyway. 

 MR. JASINSKI: No, but it has, it, we can generate 

the cost from the tear downs. We can, we can look at -- 

 MR. SMITH: Did you -- 

 MR. JASINSKI: The differences. But we don't 

know -- 

 MR. SMITH: Did -- 

 MR. JASINSKI: We don't know how many of those 

exist at each efficiency level is what I'm explaining. 

 MR. SMITH: Oh, I got it. 

 MR. JASINSKI: Because they're weighted at each 

efficiency level -- 

 MR. SMITH: I got it. 

 MR. JASINSKI: -- by the number of model, number 
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of sale at that efficiency level. So if we can't determine 

how many were sold -- 

 MR. SMITH: What I don't understand, though Sam. 

 MR. JASINSKI: Yeah? 

 MR. SMITH: As you go from EL-0 to EL-whatever, an 

EL-7, all right? What data do you have that suggest to you 

that the costs don't change as you move from one to the 

other? I don't get that. 

 MS. ARMSTRONG: So -- 

 MS. IYAMA: I think it's more that we don't have 

data that could help us. 

 MR. WHITWELL: So -- 

 MR. SMITH: Well, I -- 

 MR. WHITWELL: So -- 

 MR. SMITH: Wait, whoa, whoa, whoa, whoa, whoa. 

You went out and you tore down, you tore down fans of these 

three types. You interviewed manufacturers who make these 

three types. 

 MS. ARMSTRONG: Uh-huh. 

 MR. SMITH: You can't -- 

 MS. ARMSTRONG: But, so -- 

 MR. SMITH: So we must appreciate that there's a 

different cost. 

 MR. JASINSKI: So what was done is -- 

 MS. ARMSTRONG: I -- 
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 MR. JASINSKI: in the first, in the first NODA, we 

made assumptions about number of models and sales. But then 

we were given a database that had exact sales. So if you 

were -- 

 MR. SMITH: I'm not talking about savings, I'm 

talking about cost. 

 MR. JASINSKI: I know. But we were asked to do 

our analysis to model that database. 

 MR. WHITWELL: Right, yeah. 

 MR. JASINSKI: This is what comes out when we 

model that database. 

 MR. SMITH: So you didn't integrate information 

that you had from other activities? You just, this is just 

from the database? And since the database doesn't have this 

information, you ignored other information you had from 

other activities? They didn't integrate -- 

 MR. JASINSKI: I -- 

 MR. SMITH: -- your interviews with the databases? 

 MS. ARMSTRONG: Yes, we did. I mean, what Sam is

trying to say is, I think there's two things going on. One 

is the database doesn't show that these products are being 

sold. That's one thing, right? You gave us a database of 

sales and there are individual points in there and we 

modeled each of the individual points in terms of costs. We 

did integrate feedback we've gotten, but what you're seeing 
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here is when you analyze your database and the attributes of 

your database, this is kind of what we get. So if we think 

there are gaps in terms of information of products that 

exist on the market that aren't being reflected here, that's 

because that they're not in the database, as far as we could 

distinguish. Happy to have that conversation, a non-issue. 

I think one of the questions that was thrown out, I mean, 

Bob and otherwise, I get what Dan said, he clearly said the 

MPC would be different for a certain type of fan because it 

has a completely different design. I mean, just because 

something has a completely different design doesn't

necessarily necessitate that it costs more from a materials 

-- 

 MR. WHITWELL: Okay, but -- 

 MS. ARMSTRONG: -- purely standpoint. We haven't

gotten to MSP, and I get that we might have to change 

capital, I get that you might have to change other things. 

That's going to be a reflected later, but you could also 

come up with, come to a situation where to make a more 

efficient fan, purely materials based, if, if a delta is 

close to the top. 

 MR. WHITWELL: So I would disagree -- 

 MR. SMITH: It could be. 

 MR. WHITWELL: -- because, I mean, the panel fan,

let's use that because it's a simple -- it could a, the EL-0 
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could be a two bladed model, right? As you move across to 

higher efficiencies, you're going to add more blades. 

You're going to add material because you're going to have a 

denser fan -- 

 MS. ARMSTRONG: Yes. 

 MR. WHITWELL: -- as you look at it. And then on

the far right, you might have something that's made out of a 

composite material that's got, you know, it's a lot more 

expensive than what you're looking at, at the -- 

 MS. ARMSTRONG: So I think -- 

 MR. WHITWELL: -- at the left. 

 MS. ARMSTRONG: -- this is exactly the example 

what we're looking for, right? If you would each -- 

 MR. WHITWELL: Okay, so -- 

 MS. ARMSTRONG: -- march down that line, you would 

do X, Y, and Z changes that are -- I think what we're trying 

to tell you is that's not discernible from the database. 

 MR. WHITWELL: Okay, so what would be helpful -- 

 MS. ARMSTRONG: The -- 

 MR. WHITWELL: -- for us, for me and I think 

others that don't have access or haven't seen the database 

is, which of these do you have examples for and which one 

are not flat? 

 MS. ARMSTRONG: Okay. 

 MR. SMITH: Or else -- 
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 MR. WHITWELL: Or else -- 

 MR. SMITH: -- are they -- 

 MR. WHITWELL: -- not even, just assume it's flat, 

right? That would be helpful. 

 MS. ARMSTRONG: We don't have to walk through it,

I don’t think that -- okay, so go -- 

 MR. WOLF: The next question. 

 MS. ARMSTRONG: You may. 

 MR. WOLF: So some other questions, have you said

motors are not (indiscernible)? 

 MR. JASINSKI: No. 

 MR. WOLF: But we do agree that this much are 

going to be, the ruling, the rulemaking is going to be wire 

to air, correct? 

 MR. JASINSKI: Yes. 

 MS. ARMSTRONG: It will, it will be. 

 MR. WOLF: So a key part of the efficiency of the

fan is going to be the motor and maybe the drive? And one 

way to improve the efficiency of the fan is to maybe go to a 

more expensive motor. But that's not a conflict. 

 MR. JASINSKI: Or is -- 

 MR. WOLF: The analysis either done and should it

be, I guess, or? 

 MR. JASINSKI: No, it's not accounted for in the 

analysis taken. 
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 MR. WOLF: But it probably should be, right? If 

that what the rulemaking's -- 

 MS. ARMSTRONG: It's all accounted for. 

 MR. WAGNER: Or -- 

 MR. WOLF: I'm sorry? 

 MR. WAGNER: And Mike, you raise a good point. 

Variable speed is also an important consideration. 

 MR. WOLF: Right. 

 MR. WAGNER: Part load operation versus full load. 

 MR. WOLF: Yeah. 

 MS. ARMSTRONG: So we can do that, right? I mean, 

we can definitely, I mean, sort of analysis the cumulative 

effect of optimizing the fan, the motor, and the drive 

system on the wire to air efficiency. But that would mean 

that those levels that you might be able to obtain by 

optimizing that a given fan manufacturer would then

potentially have to, does that make sense? 

 MR. HAUER: It's Armin Hauer speaking. 

 MS. ARMSTRONG: You should want to. 

 MR. HAUER: Yeah, we, that is, we do electric fans 

and motors and our experience is that if you make a better 

fan, you can save on the motor. So that's the, we try to 

optimize our materials. 

 MR. WOLF: So you're saying -- 

 MS. ARMSTRONG: So you're saying find a level of 
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(indiscernible). 

 MR. HAUER: It's ending cheaper, actually. 

 MR. PERSFUL: Trinity from Twin City Fan. So what 

you're looking for is for us to take that, those functions, 

compile our own data, and if it's different or whatever we 

consider to be specific, give you that feedback and then we 

can move on? So our task is, if we so choose it, is it 

takes that formula, apply our stuff to it. If we get 

something vastly different, let you know? 

 MR. JASINSKI: Yeah. 

 MR. PERSFUL: I mean, it is, would end -- 

 MR. JASINSKI: Yeah. It's twofold. It's data to

feed into the methodology that we're explaining, and it's 

feedback that if there's a methodology that we're using that 

you don't agree with, let us know what you disagree with and 

an alternative. 

 MR. STARR: So this is Louis with NEEA, I was kind 

of wondering would it be -- the information you need is, at 

best, done by a manufacturer, by manufacturer basis? Or -- 

 MR. JASINSKI: That's it. 

 MR. STARR: -- is there enough information that it 

could be probably developed into a survey tool and conduct 

information by filling in the requests for information 

through a trade circulation. 

 MS. ARMSTRONG: I mean, that's totally on a 
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manufacturer by manufacturer basis. 

 MR. STARR: Okay. 

 MS. ARMSTRONG: On our experience previously. 

 MR. STARR: Okay. 

 MR. JASINSKI: Paul? 

 MR. LIN: Paul Lin from Regal Beloit, so one of 

the things that was mentioned was the variable speed. Based 

on the current formulas that you have today, it doesn't take 

into account any variable speed component, so we would have 

to add that into the formula in order to bring that variable 

speed component into it. 

 MR. JASINSKI: Okay. 

 MR. LIN: Yeah. 

 MR. JASINSKI: Thanks Paul. 

 (Off the record discussion.) 

 MR. JASINSKI: So next we determine a manufacturer 

markup. This supplies the manufacturer production cost to 

arrive at a manufacturer selling price in the base case. 

The manufacturer markup up that we used for the NODA was 

1.45. And then that, that's indicative of a typical, we're 

making a typical engineering analysis. But as I mentioned 

earlier, we also wanted to incorporate conversion costs. 

The way we did that was we calculated the total conversion 

costs and each efficiency level for the industry. And we 

derived markups as that efficiency levels that would allow 
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for the manufacturer to recover those conversion costs. And 

I'll explain those shortly. 

 So the outputs of the engineering, as I touched 

on, that were passed on to, to the downstream analysis where 

the manufacturer production costs by equipment group and 

efficiency level. The manufacturer markup that I just 

identified. And then total, the total industry conversion 

costs by equipment group and efficiency level. The

conversion cost recover markup that I mentioned that was 

calculated based on those total industry conversion costs, 

was calculated as part of the LCC and had a very similar 

approach that was used in pumps. For those that aren't 

familiar with that, we will describe it here. 

 So redesign costs. DOE, as I mentioned earlier, 

DOE recognizes that fan efficiency is improved primarily or 

predominantly through aerodynamic redesign, aerodynamic 

redesign costs do not necessarily impact manufacturer 

production costs, but require investment in R&D, testing, 

and other conversion costs. We develop the cost recovery, 

the conversion cost recovery markup methodology to account 

for aerodynamic redesigns in the cost efficiency 

relationships, using the analysis. And the cost recovery 

markup is based on the total cost of aerodynamic redesigns 

to the industry required for me to give a level applied to 

the NPC to calculate manufacturer selling price that would 
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enable the manufacturers to recover those redesign costs. 

 MR. ERNST: So what value, what value did you use? 

 MR. JASINSKI: We'll get into that. But there is

also a spreadsheet, I believe it's incorporated in the 

engineering spreadsheet in the new, most recent package that 

shows the total conversion costs for the industry by 

efficiency level on the website. 

 MR. WHITWELL: So just a comment on this, so Bob 

Whitwell from Carrier. So redesign costs for us are going 

to tend, they could vary significantly depending on what the 

use is. A supply air fan that's used in a, for cooling and 

heating is going to have a very high redesign cost, because 

we've got to completely re-qualify the air conditioning and 

the heating side. Prop fan, a conductor fan, could have a 

different redesign cost but still be significant, because we 

have to re-qualify the air conditioning side. An exhaust 

fan, significant but less than those. So somehow I guess 

we'd have to, I don't know -- 

 MR. JASINSKI: The -- 

 MR. WHITWELL: -- how you'd account for that. 

 MR. JASINSKI: The best way to do it is describe 

the scenario that you're talking about, you know? Pick the 

different cases for your particular company or industry, and 

describe that scenario in the terms that we're using here. 

So, you now, and then we will try to figure out the best way 
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to account for it in the analysis, so. Talk about, well, 

here's the list of things that the, that I would, the 

factors that I would say are most important when trying to 

describe or characterize the scenarios that you are alluding 

to. So for those of you that are a little more 

mathematically minded, the slide that I just presented, I 

put at the top an equation form, the manufactured selling 

price for this analysis is that manufacturer markup times 

the cost, the conversion cost recovery markup, times the 

manufacturer production costs. So DOE estimated product and 

capital conversion cost to determine a markup that would 

enable manufacturers to recover these costs. On the left, 

you'll see a list of the product conversion costs. They're 

modeled the same, modeled -- or, I'm sorry. Some of the 

assumptions and the actual factors are included. Their 

model is the same for each subgroup. We have 12 months 

total redesign time. Six months testing time. Adding costs 

for non-DOE certifications and marketing, and we calculate 

the labor rates to derive costs for that testing time and 

redesign time from the Bureau of Labor and Statistics. And 

I believe a lot of that is also included in that conversion 

costs tab in the published spreadsheet. 

 On the right, we have a list of the capital 

conversion costs. These are modeled as different for each 

subgroup, because each subgroup is assumed to have different 
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impacts on the production line, depending on whether you're 

trying to produce more airfoil blades or more forward curved 

blades, those capital conversion costs would be different. 

And as I mentioned, it assumes investments in fabrication 

and tooling. We have a footnote here that product and 

capital conversion costs were modeled as the same, 

regardless of the size of the fan. So -- 

 MR. SMILEY: Bill Smiley, Trane. Just a quick 

question. These costs are associated with, apparently you 

already knowing what you want in a design change you want to 

make, are there any costs associated with the R&D required 

five years earlier than this? 

 MR. JASINSKI: Yes. If you see on the left, in 

the product conversion costs, there's 12 months total 

redesign time, that includes -- 

 MR. SMILEY: That's -- 

 MR. JASINSKI: -- R&D. 

 MR. SMILEY: -- a redesign of the product, making

drawings, building samples, just these. I'm talking about 

the time required to come up with what that design change 

ought to be. 

 MS. ARMSTRONG: In the MIA. 

 MR. JASINSKI: I -- 

 MR. SMILEY: Is that -- 

 MR. JASINSKI: Well, this typically, this is 
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typically in the MIA, but we're including it in the

engineering analysis. What I would say is, that redesign 

time is supposed to include things like the R&D. So if you 

think it should be longer than 12 months -- 

 MR. SMILEY: Okay. 

 MR. JASINSKI: We're talking about 12 months 

multiplied times the labor rate. We're not talking about, 

we're not talking about, we're talking about 12 months of 

working time. It might happen over the course of five 

years. 

 MR. SMILEY: So in other words, the R&D work we 

associate with trying to out how to design a more efficient 

fan should be included in the -- in the modeling that you're 

doing. 

 MS. ARMSTRONG: To the extent that manufactures 

believe they're going to full pass that on. 

 MR. SMILEY: Well, if you want to stay in 

business, you have to pass it on somehow, yes. 

 MS. ARMSTRONG: I'm just saying, I mean, you know. 

We've gotten feedback depending on the industry, but yes. 

 MR. SMILEY: Okay. 

 MS. ARMSTRONG: Yeah. 

 MR. SMILEY: Just a question, thanks. 

 MR. FLY: What, it's Mark Fly with AAON. What 

kind of timeframe are you trying to distribute this
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recovery? 

 MR. JASINSKI: So in the analysis, it's recovered

over the analysis period, which was 30 years. 

 MS. ARMSTRONG: And you can change that. We ran 

different scenarios and pumps for a variety of reasons. 

 MR. FLY: Wow, I wish I could have people to 

invest in equipment just like that. 

 MR. JASINSKI: I think I saw a hand over here? 

 MR. DYGERT: Thanks, Ryan Dygert, Carrier. Just a 

clarification question on establishing conversion costs, 

problems with (indiscernible) aside, does that mean if I 

need to go out and buy a 10 inch mold for an injection 

molded fan, you would put it in the same cost as to a mold 

for a 16 inch diameter fan? 

 MR. JASINSKI: That is -- 

 MS. ARMSTRONG: Not necessarily. 

 MR. JASINSKI: Not, no, not necessarily. 

 MR. DYGERT: Okay. 

 MR. JASINSKI: No. 

 MR. DYGERT: It's not clear the way it was written 

on the opinion. 

 MS. ARMSTRONG: Yeah. 

 MR. JASINSKI: Yeah, understood. 

 MR. ROY: Question on the -- Aniruddh Roy, 

Goodman. Question on the manufacturers (indiscernible). 
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 MR. JASINSKI: That's mostly from things like SEC

filings, you know, revenue versus possible goods sold for 

the industry. Things like that. 

 MR. WHITWELL: Component suppliers? 

 MR. JASINSKI: What's that? 

 MR. WHITWELL: For fan component suppliers. 

 MR. JASINSKI: I'm not sure I understand your 

question. 

 MR. WHITWELL: Well, I mean, we have a different 

number being used for HVAC, and it's not, you know, I guess 

we're in the wrong business, that's all I can say. 

 MR. SMILEY: It's make your own fans? 

 MR. WHITWELL: Yeah. Well, we do. 

 MR. SMILEY: I know. Because we know it's not 

working out for us. 

 MR. JASINSKI: See and I -- 

 MR. WAGNER: Greg, Greg. The important point 

here, I think, might be that downstream, if you change a fan 

in a HVAC equipment manufacturers, they're going to have to 

re-qualify for safety and efficiency and performance, so 

there is subsequent downstream testing that's not included 

in this particular slide. 

 MR. JASINSKI: Well, it's a -- we have costs for 

non-DOE certification and marketing, so we have, we have 

that factored in. Whether or not the assumed value -- we 
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would love to get feedback on what that assumed, what that 

value should be. How much does it cost? 

 MR. WHITWELL: Yeah, so Sam, I'm sure it's a lot 

more -- 

 MR. WAGNER: Well, this is Greg. Just let me, I'm 

going to say that redesign time that actually and testing 

time, I don't know whether it's quite right or not, but 

certainly that would be something that close to what it 

would be for fans. But there's subsequent design and 

testing and validation work that needs to take place, right? 

Design over and above what you don't see on that time table. 

Certainly, given the other things that are going on in the 

industry with efficiency changes for furnaces, air 

conditioners, refrigerant changes, et cetera, there's a lot 

of things going on. So that empty time could be quite 

expensive beyond just the fan development and testing. 

 MR. JASINSKI: I'm going to get a little, into a 

little bit more detail on -- 

 MS. ARMSTRONG: You know, I think I'm going to cut 

you off. 

 MR. JASINSKI: Okay. But -- 

 MS. ARMSTRONG: And sorry, it's 12:15. We only 

have a couple of hours. I do want to break for lunch. What 

we're going to try to do is we're get -- I'm going to stop 

you here and I do want to come back and get to the LCC 
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parts. The reason for that is because the next couple of 

slides Sam's going to show are twofold. A couple of things 

is in house numbers in terms of what we estimated conversion 

costs and how that works. Obviously we want your feedback 

on it. But it's typically something you're going to 

volunteer anyway. The other is, you know, how this all 

wrapped up into getting SP values. Also, something we want 

your feedback on, but like I said, I think it's something 

you're going to have to take with you and look at and 

understand. And I want, today, to be able to at least 

introduce the LCC and so how we get to some of the modeling 

type issues, the choice model in terms of how we're making 

these designs. So at least when you take away this package 

and you look at the potential spreadsheets in the interim in 

between, you will have some context for that. 

 MR. WHITWELL: Okay, Bob Whitwell. And just one 

more comment on this, and then I'll shut up on it. But so 

the comment made about the fan design and then the equipment 

design, so those are sequential, right? And then the other 

thing, question I have and you don’t need to answer this, 

but I mean, you're showing 12 months total design time and 

six months total testing time. Depending on, I don't know 

how many engineers you assume that are doing the fan 

redesign or how much testing is, you know, how much, how 

many samples are being tested and stuff like that. That 
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could play a significant role in (indiscernible). 

 MR. JASINSKI: Maybe -- 

 MR. WHITWELL: Is that laid out in -- 

 MR. JASINSKI: Maybe man hours is a better -- 

 MR. WHITWELL: So these are man hours? One man 

year for the design? Six man months for the adjustment? 

 MR. JASINSKI: Yes. 

 MR. WHITWELL: Okay. Thank you. 

 MR. JASINSKI: Lunchtime? 

 MS. ARMSTRONG: All right, it's lunchtime. How 

quickly could we get back here? 

 MR. SMILEY: 1:15. 

 (Whereupon, a brief recess was taken.) 

 MS. ARMSTRONG: All right, so we're going to start 

back. So we're going to pick up on the LCC and walk through 

that now. 

 MS. IYAMA: Okay, so the LCC, the Lifecycle Cost 

Calculation is basically calculating, or adding the

insulation costs, or the first cost, and the operating costs 

into what is called a Lifecycle Cost. And so it uses, an 

input, some of the data that Sam presented. And one of the 

key items to understand is the approach that we took when 

analysis the AMCA database, in terms of how do we determine 

if a particular fan will be redesigned when a standard is, 

comes into place. Or is it going to be replaced by an 
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existing compliant fan. And so what we did, and we've 

already discussed, you know, alternatives to this approach, 

but here I'm just going to describe what is actually in the 

NODA, is that we, so we have this database of 70,000 fan 

selection. We pick one and we evaluate whether it meets a 

particular efficiency level. If it does, then nothing 

happens. There's no impact to the customer, it just keeps 

the same fan as the original fan that was selected. And so 

that's what is going on in the left part of that graph. 

 But if a particular fan selection doesn't meet a 

considered efficiency standard, then we consider two cases. 

In the first situation, we looked at the other fans that 

were in the database that have the same fan equipment class, 

or fan category, that have a design point within 20 percent 

flow and pressure, and that have the same diameter. And so 

these were, sort of, our filters to select an appropriate 

substitute, and of course it had to meet the standard. 

 And so with this process we were able to sort of 

identify a list of existing compliant fan substitutes that 

could eventually replace a particular fan selection that 

didn't meet a considered standard. And so that's the 

reselection scenario. And I have a list of, sort of, all 

the input parameters that can change that scenario. For 

example, we could tighten or broaden the window around flow 

and pressure. We could say we know, we don't want it to be 
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in the same fan equipment class. We want to try staying 

within the same subcategory and limit the reselection to a 

fan that is of the same fan subcategory. So that's the 

reselection scenario. And then we also considered the case 

where, you know, we couldn't find any existing compliant fan 

substitute that meet these, that met these criteria. And in 

this case we assumed that the non-compliant fan would be 

replaced by a redesigned fan. That fan would have a price 

that is calculated using the inputs that Sam presented from 

the engineering analysis. 

 MR. ERNST: Question? How, unless you were up at

EL-06, how could you not find those replacement fans? 

 MS. IYAMA: Because we were limited in the data 

that was available and in the assumptions that we could 

make. So the, each fan has a pretty broad operating region. 

We didn't have that information, we just had for each model 

a single selection point. So that's where, you know, that 

window of 20 percent could be broadened and say hey, you 

know, that fan? You assume that it can only operate at this 

particular selection point, and then you kind of -- and we 

use this 20 percent window to say, well if it can operate 

here, it can probably also operate within that region. 

 MR. JASINSKI: Sanaee, I just want to add that 

it's not that we only had one operating point per model. We 

only had one operating point per sale. So if a model was, 
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if a model had a lot of sales, we have very operating point 

at which that model was sold. So we might have a partial -- 

 MS. IYAMA: Right. 

 MR. JASINSKI: -- map of that fan's performance. 

 MS. IYAMA: But not the complete -- 

 MR. JASINSKI: But it, but not, not necessarily 

complete and I'm sure there probably are examples of fan 

models where there was, it was only sold that one operating 

point. It's possible, I don't know -- 

 UNIDENTIFIED MALE: Many. 

 MR. JASINSKI: -- how probable that is. 

 UNIDENTIFIED MALE: Many. Often. 

 MS. IYAMA: So the next line, I'm going to go 

through them pretty quickly, in the interest of time. But 

this line is just to say, well this is how we would

calculate the MSP of a fan in the database. So we just 

take, like, someone went over this already, we'd just take 

the manufacturing production cost, multiple it by the markup 

of 1.45, and in the case where a fan is replaced by an 

existing fan, we use the same equation. There is no 

redesign cost, because that fan is already on the market. 

In the case where we have a fan that's replaced by a fan 

that's being redesigned, we need to incorporate those 

increasing costs. So the MSP of that fan, that new

redesigned fan, is going to be calculated using the equation 
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that the, the MPC equation that Sam presented with the 

multiplier of value that corresponds to the efficiency level 

that's being analyzed. 

 So let's say, you know, I pick a fan selection, this 

fan's selection is at EL-01, so I was using the equation 

with the multiplier at EL-01 to calculate the MPC of that 

fan. That fan is now redesigned to meet, let's say, EL-03. 

I'm going to calculate the MPC of that fan using the 

multiplier at EL-03. So it's pretty straightforward. The 

only thing that's a little different from the traditional 

way of calculating costs is that we're adding those

conversion costs, in the form of a conversion cost markup. 

 Where is that? Yeah, it didn't go through. Yeah. 

So for the, yeah. So you'll have it in the slide, the 

equation that doesn't come up on here. 

 MR. WAGNER: If we could go back -- sorry, Greg. 

Going back to slide five, it'd be 30 years to amortize that 

cost markup of the conversion costs? 

 MS. IYAMA: Yeah. 

 MR. WAGNER: Does that mean that DOE won't have 

any regular for the next 30 years to change this or any 

other standard? 

 MS. IYAMA: So I think -- 

 MS. ARMSTRONG: Mike, you need to answer that one. 

 MR. WOLF: Nice try. 
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 MS. ARMSTRONG: I think -- Mike could guess to 

answer that one. 

 MR. SMITH: Well so that conversion cost should 

really be recovered during the cycle, until the next, until 

the next redesign then? Until the next -- 

 MS. ARMSTRONG: So I mean, you guys are welcome 

to -- 

 MR. WAGNER: I don't, I don't mean -- 

 MS. ARMSTRONG: -- say what a reasonable time 

period -- 

 MS. IYAMA: So I think -- 

 MS. ARMSTRONG: -- of recovery would be. 

 MS. IYAMA: I'm trying to get through the slides. 

I have a summary slide at the end of all these individual 

inputs that kind of summarize our assumptions. 

 MR. SMITH: Okay, may I ask a, just a point of a 

point of clarification. If the fan, a non-compliant 

selection is replaced by a compliant selection that's in the 

database. 

 MS. IYAMA: Uh-huh. 

 MR. SMITH: In that scenario, do you assume that 

there's no redesign. Is the compliant and selection that 

you picked from the database from the same manufacturer? 

 MS. IYAMA: No, but it could also be -- 

 MR. SMITH: Okay, so that's also a false 
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assumption because the manufacturer who lost that sale will 

redesign because he doesn't want to lose the sale to his 

competitor perpetually. So the fact that there is another 

fan on the market which would satisfy the need is no reason 

to say that there isn't going to conversion costs. There 

will be conversion costs. 

 MR. JASINSKI: So, I, as I mentioned earlier, we 

have a list of what we call limitations. Basically

limitations that we've identified, and that's one of them on 

the list. We understand that with this methodology there's 

certain limitations to that impact. Ideally, this is going 

to drive a count of the number of redesigns and reselections 

for the analysis, and the redesign count is obviously used 

to calculate the total industry conversion costs. 

 MR. SMITH: But it's -- 

 MR. JASINSKI: So we have a list of limitations 

and basically say we understand that for exactly what you've 

said. Just because, just because there is another fan that 

is compliant at the operating point and it's a reselection 

does not necessarily mean that there are no redesign costs. 

Because a manufacturer, as you've described, loses that 

sale, they might decide to redesign in order to have that 

sale, so. 

 MR. SMITH: Not might, is my point. 

 MR. JASINSKI: Okay, so, well, what I'm saying is, 
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we have a list of those limitations, and those are things 

that we would like to get feedback on. 

 MS. ARMSTRONG: You got it. 

 MR. JASINSKI: So you're saying that -- 

 MR. SMITH: You can -- 

 MS. ARMSTRONG: You got it. We can implement 

that. 

 MR. SMITH: -- you can change it? 

 MS. ARMSTRONG: Yeah. 

 MR. SMITH: With this assumption? 

 MR. JASINSKI: Yeah. 

 MS. IYAMA: Yeah. 

 MR. SMITH: Good. 

 MS. IYAMA: So an easy way to implement it would 

just be to add an additional filter when, you know, looking 

for a substitute, it would have to be from the same

manufacturer. 

 MR. FLY: And, Mark Fly with AAON, for us packaged 

unit manufacturers, any kind of supply fan that's really a 

-- there will be a conversion cost. If we cannot change the 

fan, at all, any kind of airflow change that's coming off 

that fan will change the, we have to re-go through heater 

qualifications, which is a six month test. Run time. 

 MR. WHITWELL: Per unit? 

 MR. FLY: Per unit. 
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 MS. ARMSTRONG: (Indiscernible). 

 MS. IYAMA: So I'm going to jump onto the energy 

use and to the calculation of the operating costs. And 

here's it's just the equation for calculating what we call 

the unit energy consumption in kilowatts per year of a given 

fan in the database. So here one of the assumptions that we 

made and that could be changed is that we assumed the fan 

would operate at its design point. And I think yesterday I 

heard some, like V, like VAV fans operate at 60 or 80 

percent of that design point. So this kind of feedback, you 

know, saying well you assumed it's operating at the design 

point. In reality, it's most likely going to be operating 

at X or Y. That would be useful. Although, in the

database, we don't, we only have the performance data for 

that particular design point. So there's limitation in what 

we can actually analyze. 

 MR. Smiley: So, real quick question. This is 

Bill Smiley. Where's the time on this equation that says 

overall average per year? 

 MS. IYAMA: I -- 

 MR. SMILEY: Because you need some type of 

hours -- 

 MS. IYAMA: Yeah, hours are missing. 

 MR. SMILEY: -- of operation per year. 

 MS. IYAMA: You're right. It, it's multiplied by
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hours. 

 MR. SMILEY: Well, I assume that's in the 

spreadsheet? 

 MS. IYAMA: Yes, it is. 

 MR. SMILEY: But left off this equation? 

 MS. IYAMA: Correct. 

 MR. SMILEY: Which makes this equation incorrect?

 MS. IYAMA: Yeah. 

 MR. STARR: So, this is Louis with NEEA. So if 

you were on, if you use something, I assume it would be less 

than the design point is what you're getting at. Because 

it, it, so you look in your database and you get a flow on 

the head, and then the assumption is, is that -- 

 MS. IYAMA: This is -- 

 MR. STARR: Chances are, it's going to be less 

than even? Forget about the VAV aspect of it. If you're 

putting it into a system, the chances that that meets right 

at the design point probably aren't good. And the chances 

are, the real design point, most likely, is less than that 

or you wouldn't be able to meet your design requirements. 

So I kind of wonder, I mean, it essentially predicts less 

energy. We'll do it that way, as opposed to using jus the 

design point that you have. I mean, is that kind of the 

summation of? 

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the operating point in the field, in the lifecycle cost 

calculation, was assumed to be equal to the design point. 

 MR. STARR: Okay. 

 MS. IYAMA: Specified by the purchaser. And so, 

for the fan performance data, that came directly from the 

AMCA database, so each fan selection was associated to flow 

pressure and efficiency value for the fan. And then we 

added additional assumptions to characterize the motor and 

whether or not, if the fan was sold in a belt driven 

configuration, then we accounted for the belt losses and 

these are exactly the same assumption and presented when 

talking about the metrics. I'm going to go pretty quickly 

over these. 

 UNIDENTIFIED MALE: Same thing. 

 MR. SMILEY: I have a question or maybe a 

suggestion. Bill Smiley, Trane. We have a multiplier of 

1.2 that you multiply it by the fan's brake horsepower, the 

size of the motor. So the motor name plate needs to be that 

or larger. In a lot of our equipment, we don't use 1.2, we 

may have a specific design motor, or we may select another 

motor close to what the fan brake horsepower is and not 

oversight. And you can get away with that a lot of the fact 

that they're over-tight motors because they're pretty -- 

 MS. IYAMA: So input could be replaced by a 

distribution. 
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 MR. SMILEY: Yeah, it's just -- 

 MS. IYAMA: If you want it to be more -- 

 MR. SMILEY: -- point out that we might need to -- 

 MS. IYAMA: -- representative. 

 MR. SMILEY: -- evaluate that more. 

 MS. IYAMA: And then, another input that you can 

see was missing from the equation are operating hours per 

year. We derived different operating hours depending on the 

sector and the application. They're presented in more 

detail, details in the LCC spreadsheet. And here I just 

have sort of an example of our assumptions in terms of how 

fans are distributed across sectors. 

 MS. PETRILLO-GROH: May I? 

 MS. IYAMA: Yes? 

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

Could you just give a range of the operating hours that are 

used? 

 MS. IYAMA: I think there's a couple sides that 

are in the -- 

 UNIDENTIFIED MALE: Slides coming up. 

 MS. PETRILLO-GROH: Thank you. 

 MS. IYAMA: And for example, in order to 

characterize whether a fan would be used more likely in the 

commercial, industrial sector, that depends on whether it's 

a small fan or a larger fan. So if you're a small fan you 
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have a higher likelihood to be used in the commercial 

sector. And the higher you go in size, the example, if 

you're, you know, a 100 horsepower, there is 61 percent 

change that you'd be used in the industrial sector. 

 MR. STARR: Yeah, so it's Louis, just on the last

one, did you include the efficiency of the motor in there 

somewhere in sizing up the stuff? So the 1.2 was for? 

 MS. IYAMA: Size of the motor. 

 MR. STARR: Well, it's not 100 percent efficient,

right? So once you know what your brake horsepower power 

and size are, the balance, then you need an efficiency for 

the motor too, because it -- 

 MS. IYAMA: Yeah. So the part load calculation, 

part load, calculation of the part load losses of the motor 

was done in the same way that you would do it for the 

metrics, that it didn't really go through that in the 

details, but. 

 MR. STARR: So you figured out the flow and head 

and came up with what the horsepower requirement was? 

 MS. IYAMA: Yes. 

 MR. STARR: You divided by 1.2 and divided by the

motor to choose what motor size that you would need? There 

actually is one other step you would need. You need to see 

if that motor's actually available. You could come up with 

3.4, but they don't make a 3.4 and have it be -- 
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 MS. IYAMA: Well, then we go to the -- 

 MR. STARR: Motor cadence? 

 MS. IYAMA: To the -- 

 MR. STARR: Okay. 

 MS. IYAMA: -- closest motor available. 

 MR. STARR: All right. 

 MS. IYAMA: That's above that number. 

 MR. BOTELER: This is Rob. The other issue that 

you have is you're looking at the data that we gave you for 

pumps, which was a closed motor, there's open motors. 

There's no air over motor data. 

 UNIDENTIFIED MALE: No. 

 MR. BOTELER: We told you the other day, air overs 

are significantly lower efficiency than what you would have 

in a pump data based on using the full closed ones. 

 MR. STARR: That describe about energy use a 

little more, right? 

 MR. BOTELER: Right. 

 MR. STARR: Yeah. 

 MR. BOTELER: Yeah. 

 MS. IYAMA: So this is just, this is some of the,

so all of the tables, in detail, are in, detailed in the LCC 

spreadsheet. This is just an example of sort of how we 

express the reliability and operating hours for the

commercial sector. So we identified two main applications 
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in the commercial sector. Each equipment class has a 

different distribution and across those two application, at 

the bottom of the table you have the average and the 

operating hours for each of these application. But it's an 

average value. And what is actually using the calculation 

is the distribution that you have on the graph below. 

Where, you know, the operating hours could be samples 

anywhere between basically zero and 8760 per year. 

 MR. BOTELER: Well that min/mix is hours? 

 MS. IYAMA: Yes. 

 MR. BOTELER: Wow. 

 MR. ERNST: Now you have, I mean, like for 

instance, in the, then, in number eight -- 

 MS. IYAMA: Yeah. 

 MR. ERNST: -- you have a huge usage about 7500 

hours. What type of industry is that? 

 MS. IYAMA: So these operating hours were -- 

wondering if I have the source cited. So we used Energy 

Plus data for the, for these operating hours. 

 MR. ERNST: But which air conditioning has to be a 

big chunk somewhere. I mean, it's nowhere near that right 

now. 

 MR. SMILEY: Hell, that's 22 hours a day, 7 days a 

week. 

 MR. ERNST: I mean, air quality is 5000, well 4000 
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hours. Maybe 5000 is better. 

 MR. PERSFUL: This is Trinity. That's most 

industrial applications. 

 MR. SMILEY: Right. 

 MR. ERNST: So again, I guess if this is all 

industrial, you're not going to -- 

 MS. IYAMA: These are the commercial center -- 

 MR. ERNST: It doesn't seem right. 

 MS. IYAMA: And then -- 

 MR. SMILEY: Bill Smiley with Trane. I think what 

this points out is for different types of equipment, there 

may be different operating hours that should be used in any 

analysis like this. And it's probably, I would assume, up 

to us to come forward with what we believe the operating 

hours per year for the type of equipment that we're talking 

about. 

 MS. IYAMA: So here, the way that it's 

constructed, each sector and application associated to a 

number of operating hours or statistical distribution of 

operating hours. And then each equipment class is 

associated to a distribution of application. 

 MR. SMILEY: Right. 

 MS. IYAMA: So if you're a centrifugal house, 

you're going to be, you know, in the commercial sector and 

you're only going to be using clean air ventilation. If you 
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think there is other, there are other applications that 

should be considered for that sector, and that equipment 

class. 

 MR. SMILEY: Well, I'm suggesting that there may 

be other groups. There are other ways of grouping this -- 

 MS. IYAMA: Right. 

 MR. SMILEY: -- other than fan design specific 

type. 

 MS. IYAMA: Okay. So I'm going to -- 

 MR. ERNST: One more. 

 MR. SMILEY: Hold, hold, hold. 

 MR. ERNST: When you said on that slide, it looks

like you had centrifugal house with a zero exhaust fans? 

 MS. IYAMA: Correct. 

 MR. ERNST: I mean, there's a pretty good 

percentage where those types of fans are exhaust fans. 

 COURT REPORTER: Please don't tap the table. 

 MS. IYAMA: So I think I, you know, these are all

good feedback for us. I'm trying to go through all the 

slides and then if you want to either come back with data on 

this or your best estimates or, you know, a suggestion on 

what those numbers should be, that would be really helpful. 

Here's it's just the result of the calculation, using all 

those assumptions, how the kilowatt per year would look like 

for each of the equipment classes at each of the considered 
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efficiency levels. And then we get into the other inputs 

for the Lifecycle Cost Calculation, one of them is lifetime. 

So we heard from the comments that we received that these 

may be, you know, a little too high. We haven't found data 

that could support changing of those numbers. If you have 

information that could help us it'd be very useful. The 

approach here was to calculate a mechanical length time, so 

the number of operating hours that the fan is able to 

provide before, you know, before its, before it reach its 

end of life. And then we would divide that by the annual 

operating hours to get the lifetime of the fans. 

 MR. SMITH: Sanaee, I just have one quick 

question. If you could go back a couple of slides, and then 

I promise not to dwell on it? 

 MS. IYAMA: Which one? 

 MR. SMITH: Next one back. There. Well that's 

okay, that's good. 

 MS. IYAMA: This one? 

 MR. SMITH: The chart at the bottom? 

 MS. IYAMA: Yeah? 

 MR. SMITH: Okay, so for example you've got a very 

large bar for commercial and seven and eight, nominally 7000 

hours of operation a year. And that is very high, just, you 

know, conceptually. But then does that tie to the next 

slide? Is that chart there consistent with what the figures 
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on the next slide? 

 MS. IYAMA: The next slide is for the industrial 

sector. 

 MR. SMITH: Okay. Do the industrial numbers tie 

to this slide? 

 MS. IYAMA: No, we have different distribution of

hours for the industrial sector. And these are in the LCC 

spreadsheet. I just didn't put all the tables on the 

slides. 

 MR. SMITH: Right, but the chart, go back. You 

have green bars for industrial. 

 MS. IYAMA: No, it's -- 

 MR. SMITH: Oh. 

 MS. IYAMA: It's commercial and ventilation -- 

 MR. SMITH: I stand corrected. 

 MS. IYAMA: -- and commercial exhaust. 

 MR. SMITH: Okay, now I understand. 

 MS. IYAMA: Yeah. 

 MR. SMITH: My mistake. 

 MS. IYAMA: And again, it's a lot of data, so, you 

know, it's all in the LCC spreadsheet. I think there's a 

sheet called application and sectors or something like that, 

with all the tables in there. 

 MR. STARR: This is Louis, I would suggest in your 

operation hours you can go and use the 90.1s and get the 
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schedules off there and that would give you a snapshot of 

the operating hours. 

 MS. IYAMA: So right now we use, we use Energy 

Plus building simulation data. 

 MR. STARR: Oh, that's -- 

 MS. IYAMA: Yeah, that's where it from. 

 MR. STARR: From the 90.1 form? 

 MS. IYAMA: I'm trying to remember what -- 

 MR. STARR: Okay. 

 MS. IYAMA: -- but it's, it's described in the LCC 

spreadsheet, and so. 

 MR. STARR: Okay. 

 MS. IYAMA: The exact source. 

 MR. SMITH: Now do we need to prepare sort of like 

a formal comment for this? Because what you did was not 

right. So the question is, how do we get it to be right? 

 MS. ARMSTRONG: What do you want to change? 

 MS. IYAMA: Well, in terms of the approach or 

the -- 

 MR. SMITH: Huh? 

 MS. IYAMA: -- implementation? 

 MS. ARMSTRONG: Tell us what you want to change. 

 MR. SMITH: Well, I think Louis had the right 

idea. 90.1 does a really good distribution of commercial 

operating hours, and none of them -- 
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 MS. ARMSTRONG: Take it under consideration. 

 MR. SMITH: -- are close to 7000. 

 MS. ARMSTRONG: No problem. 

 MR. SMITH: Okay. 

 MS. IYAMA: So here it's just a summary of all the 

input that impact the results of the LCC. So reselection 

criteria, we talked about it. We could add, it has to be 

from the same manufacturer. So this is just to help you 

kind of go through and, you know, if you have a different 

idea of how this should be done or what we should use, this 

is what you'd look at and want to tell us how to change it. 

and we could change it. 

 MR. WAGNER: This is Greg. I'd like to understand 

better where that 1.2 came from, under the default motor and 

transmission. 

 MS. IYAMA: It's mainly based on literature review 

of motor sizing practices and -- 

 UNIDENTIFIED MALE: Well, I -- 

 MS. IYAMA: -- it may not be representative of 

each way that people do it. 

 MR. STARR: So -- 

 MS. IYAMA: Yes. 

 MR. STARR: -- this is Louis Starr. That, I mean

you think about it, you'd want to change that factor right, 

for oversizing. In case it's wrong. And then you'd want a 
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10 percent service factor on your motor, so 20 percent, 

that's -- 

 MR. BURDICK: Yeah, it's Larry with SPX, and so 

typically in our industry the way motors are sized to use a 

service factor motor of 1.5, service factor motor. And that 

you would, you know, basically from the design point, you 

know, right up to the name plate. You would go into the 

service factor during cold periods or possibly go into the 

service factor in other periods, but when you're operating 

on a VFD fans slow down and so you don't infringe on the 

motor maintenance or that type of thing. We would like to 

see consideration of that, possibly say either actual 

expelled motor, actual implied motor horsepower, or 1.2 

factor. 

 MS. IYAMA: All right. 

 MR. ERNST: Another, where does the variable speed 

come into these estimates? 

 MS. IYAMA: So in this version, we only looked at

one operating point, based on the design point. 

 MR. ERNST: Okay, because that would, on air 

condition, that would drop your numbers to a third of what 

you have. 

 MR. SMITH: Yes. 

 MR. SMILEY: Do you have a provision built in that 

would accommodate the VAV for an (indiscernible)? That 
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would do that? 

 MS. IYAMA: Not right now. 

 MR. LIN: So, I mean, doesn't that go back to the, 

what I said earlier, which is that the equations doesn't 

take into account the part load? So the equation doesn't 

take into account part load, then she's not going to 

calculate the usage of a part load. 

 MR. SMITH: But yeah, she must. Because even 

though the fan has an efficiency gain at the design point, 

the fact that it's not operated at the design point means 

that the savings are diminished. And you can't just walk 

away and say, well, they're not diminished. Yeah, they're 

not diminished, because the fan is now operating at some 

reduced value relative to the -- 

 MR. LIN: So the rating should account for that 

somehow, but it doesn't. 

 MR. SMITH: No, it's -- 

 MR. LIN: She can't take account of that without 

having the rate -- 

 MR. SMITH: The ratings are at the design point, 

and they do not account for -- but when calculating savings 

you can't ignore that the fan is being operated at part 

load. 

 MS. ARMSTRONG: But there's no, to his point, I 

mean, there's no push or incentive to operate at, or to max 
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the load more if you don't reflect it in the rating, which 

is the issue we talked about yesterday with regards to 

what's going on in HVAC. 

 MR. SMITH: Well, I just don't -- 

 MS. ARMSTRONG: You can't have it both ways. 

 MR. SMITH: Look, the calculation of savings needs 

to be an honest assessment of how much energy will be saved. 

And if a fan is operating on a variable volume system, the 

amount of savings associated with changing the efficiency at 

the design point are diminished. Because the fan doesn't 

operate at the design point. So you can't just say, well, I 

can't, I'm going to ignore that. No, well then you get the 

wrong answer. 

 MR. LIN: So, would you have -- 

 MR. SMITH: There's a percent -- 

 MR. LIN: -- your fan then take into account and 

have your fan take into account that it can operate at a 

lower, lower point and is more efficient than one that would 

operate only at a single fixed point? Unless -- 

 MR. SMITH: It's not air condition. 

 MR. BUBLITZ: It's not -- 

 MR. SMITH: It's using less energy. 

 MR. LIN: Use less energy? 

 MR. SMITH: Yeah. It's an interesting question 

and it's one around which there's been a lot of debate. The 
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consensus of the fan manufacturers is that the fans

efficiency at its design point should become the regulatory 

gate, but that said, it doesn't mean that the savings are, 

should be built on an assumption that the fan runs at the 

design point all the time. 

 MS. IYAMA: So, I think what you're saying is, 

this assumption -- 

 MR. SMITH: Like, the number of hours. 

 MS. IYAMA: -- here, about you know, the operating 

point. Instead of using a single point that's the design 

point, you'd want to see something like a profile? 

 MR. SMITH: Yes. 

 MS. IYAMA: Right? 

 MR. SMILEY: Yeah. Hours and -- 

 MR. SMITH: That's -- 

 MS. IYAMA: So, I think -- 

 MR. LIN: That's -- 

 MS. IYAMA: -- what would be useful then is -- 

 MR. SMITH: Two scenarios. 

 MS. IYAMA: Uh-huh. 

 MR. SMITH: There's a constant time scenario. 

 MS. IYAMA: Right. 

 MR. SMITH: Which you've mimicked correctly. And

there's a variable volume scenario. 

 MS. IYAMA: Right. 
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 MR. SMITH: Which -- 

 MS. IYAMA: So would it be something like, you 

know, like half of the time at half of the flow. Third of 

the time at -- 

 MR. SMITH: We can -- 

 MS. IYAMA: So some -- 

 MR. SMITH: We can give you guidance. 

 MS. IYAMA: But, and then we could run those. 

 MR. STARR: I was going to say, in the pumps they

had the same debate. They just used 25, 50, 75 equal bends, 

and they even did a sensitivity analysis on it and 

surprised, it didn't matter how we changed those bends. SO 

you're thinking, it's supposed to be 75 percent or 50, it 

didn't matter because you're using less energy at it. 

 MS. IYAMA: Right. 

 MR. STARR: So you could just do an equal way and

if that was, you get close enough. The other thing is, you 

don't -- 

 MR. SMITH: I don't, I think, I remembered with 

ASRAC a little different ratings. 

 MR. SMILEY: Yeah. 

 MR. LIN: But actually, you -- 

 MR. STARR: You could wing it. It won't make any

difference. But I mean, you may have to see that with the 

sensitivity. But anyway, with that, it would get, the other 
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thing you need to know is how many VFBs are on these fans. 

So I guess they, you must have some sense of that, too. How 

much these fan selections actually have VFD, multiply it for 

that portion of the population. 

 MR. ERNST: Well, going forward, it's a tremendous 

number. 

 MR. SMITH: I want to say that the data in the 

database shows a VFD that was sold by the fan manufacturer, 

but in most instances, there would just be fans are applied 

with VFD's purchased by the contractor, not from a fan 

manufacturer. So the database is not a good indication of 

how many VFDs are applied to fans. But I think by building, 

right? Right? They have all these, they have all these 

building types in the industrial, or different application 

types. And you've got a weighting for those different 

application types. It would be appropriate to do the same 

thing for commercial, and use the operating hours that come 

out of ASHRAE, 90.1, and some of those building types are 

going to be a high percentage variable volume. So you can 

assign a percentage that are variable volume and an average 

weighted or, you know, use this profile that we're going to 

give to you. Okay? 

 MS. IYAMA: All right. 

 MR. DIKEMAN: So then -- this is Steve Dikeman. 

Another thing, there's some custom reports that you can do 
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in Energy Plus to report those run times. Energy Plus has 

some custom outputs. You can go in and get the actual run 

hours and you can get the loading. 

 MS. IYAMA: Okay. 

 MR. DIKEMAN: So that would be yet another way, 

and then just apply it. You know, I think Trinity's 

right -- 

 MS. IYAMA: Yeah. 

 MR. DIKEMAN: -- that he's got a major part of the 

industrial's going to be 24/7. And then the commercial 

side. Some distribution of the commercial side would be 

VAV. 

 MS. IYAMA: So the commercial sector operating 

hours that we use are actually from Energy Plus, and we 

also -- 

 MR. DIKEMAN: But not fully loaded. 

 MS. IYAMA: -- extracted, we extracted the load 

profiles as well so we could use those. But my 

understanding is that there's some disagreement on whether 

or not we should use these data, so. 

 MR. DIKEMAN: But even Energy Plus can show you 

what on the VAV system that you're not doing designed power 

every operating minute. Here's a scan from the fan on 

Kramer House (phonetic sp.). 

 MS. IYAMA: Right. 
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 MR. DIKEMAN: You know, going into 80 percent of 

feed, I cut my VFD (phonetic sp.) in half. 

 MS. IYAMA: Right. 

 MR. STARR: So the 90.1 models gave you those 

numbers that, you know, that seems, well, okay, no. It 

should be about four to 5000 hours in a commercial office 

space, I would think. That's 10 hours a day, five days a 

week. How many ever weeks. 

 MS. IYAMA: So the next couple slides are just 

purely results tables, so I think I'm just going to skip 

directly through the shipments and national impact analysis. 

Which, so for shipments, these are units sold by equipment 

class for the specific scope that was analyzed in the NODA 

which are fans above one horsepower and below 200 

horsepower. 

 This is from aggregated data for 2012, expanded to 

the total U.S. market. And it doesn't include all those 

fans that we didn't consider, like, being useful fans. For 

example, so that's what we used for our reference here. And 

then we applied projections to estimate shipments over the 

entire analysis period of 30 years. Those sort of 

projections, those projections were used, were based on 

different indicators depending on the sector. For example, 

for commercial sector, we separated between shipments going 

to new building or existing buildings. For the one going to 
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new buildings, it's driven by commercial floor space growth 

as projected in the annual energy outlook publication. 

 In the industrial sector we used a different 

indicator the drive the sales, which was investment in -- 

investment in equipment and structures, that would include 

fans. This is just detailed so I'm going to go through this 

and this is just sort of the resulting projections for the 

30 years. And combining the shipments projections to all 

the influx from the LCC, we calculated the national impact. 

And as this results, so first in terms of national energy 

savings expressed in full fuel cycle, which is not the 

electricity but all the upstream electricity use. And also 

expressed in terms of energy being -- so again, I'm just 

going to go through these, because there are just result 

tables. These are just combined and expressed in terms of 

ducted or unducted. And the next slides that I have here, 

it's the revised analysis, so similar input date, similar 

methodology, the only thing that we change is that we used a 

metric based on the static efficiency, as a function of flow 

and pressure for unducted fans. 

 So I don't know if you want to take a quick break

and go back to the LCC input data? 

 MS. PETRILLO-GROH: I have one question. On the 

shipments and national impact analysis, the ratio of new 

buildings to existing buildings doesn't seem to make sense. 
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Can we speak a little bit more about that? 

 MS. IYAMA: Um -- 

 MR. STARR: It's the colored graph. 

 MR. SMILEY: Yeah, the colored one. That assumes

most of the market is going to be new building construction. 

 MS. IYAMA: Yeah. 

 MR. STARR: Fans last a long time, right? 

 MR. SMILEY: Yes, they do. 

 MS. IYAMA: So I think we were at a ratio of 80 

and 20 percent. But -- 

 MR. STARR: It's right here, (indiscernible). 

 MS. PETRILLO-GROH: I don't think I have it. 

 MS. IYAMA: I'm going to go back and check where 

that exactly came from. But -- 

 MR. STARR: Air handlers. 

 MS. IYAMA: So -- 

 MR. STARR: Air handlers you'd -- 

 MR. FERNSTROM: So this is, this is Gary. I think 

a question here is how do we treat building renovation? So 

if someone is remodeling an existing building, is that 

considered a new building or an existing building? If 

renovation is considered existing building, then I could see 

how you might have a higher number than if it were just 

replacement of equipment that they don't -- 

 MR. STARR: So, this is close. I think part of 
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what maybe drives the fan life this, I mean, for what they 

have right now, it's 30 years, so if that's not right, then 

that's going to maybe change the balance of those two. So I 

think if you change the fan life, it would switch those. 

But I don't, I actually don't know how long a fan lasts. 

 MR. FLY: This is Mark Fly with AAON, just from 

the motor people's standpoint, what do you think, what do 

you estimate is the life of a motor? 

 MR. BOTELER: We go with the DOE, that's 18 years. 

 MR. FLY: Eighteen years? 

 MR. BOTELER: Uh-huh. 

 MR. FLY: Okay. 

 MR. BOTELER: But let me tell you, some last much

longer. 

 MR. FLY: All right. 

 MR. BOTELER: I've been in water plants with 

motors older than me. 

 MR. FLY: Yeah. 

 MR. BOTELER: Really. 

 MR. FLY: Yes, Gary? And I've seen fans that 

lasted a week. 

 MR. FERNSTROM: Right, fair enough. That's -- 

 MR. FLY: Would this apply? 

 MR. BOTELER: They get repaired many times, and 

bearings and things. 
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 MR. SMILEY: This is Bill Smiley, Trane. What is

the typical design life for a motor? 

 MR. BOTELER: I'm sorry? 

 MR. SMILEY: Do they make -- what is the typical 

design life for a motor? Do you make a motor to last 18 

years at, at some -- 

 MR. STARR: I think you got industrial -- 

 MR. SMILEY: -- acceptable failure? 

 MR. STARR: -- you got industrial motors, sure. 

 MR. SMILEY: Is it 10 or 20? What about -- 

 MR. STARR: I'd say five. 

 MR. BOTELER: Commercial would be less. It 

wouldn't be 30. 

 MR. STARR: Yeah, but -- 

 MR. SMILEY: Okay. 

 MR. STARR: -- keep in mind, you just replace the

motor. You wouldn't go out and replace the fan, right? 

Right? 

 MR. SMILEY: Yeah, the equip -- our equipment 

design life isn't 30 years. 

 MR. STARR: Well not, so we're not talking about 

air handlers anymore. It's like exhaust fans and -- 

 MR. SMILEY: Well -- 

 MR. STARR: Yeah, I don't -- 

 MR. SMILEY: Well, that could be. I'm just 
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stating that for a sizable share of the market, which 

there's no data provided yet by us, there, the design life 

of the equipment is not 30 years. 

 MR. STARR: Your fan wheels don't last that long 

though, right? 

 MR. SMILEY: But if the equipment breaks down -- 

 MR. STARR: You'll replace -- 

 (Simultaneous conversation.) 

 MS. PETRILLO-GROH: Just retain the fan. 

 MS. IYAMA: So I just want to continue really 

quickly on the revised results that some of the members of 

the, well, I think everybody in the working group wanted to 

see, a revised analysis with a static metric for unducted 

fans. One of the starting point for the conducting this 

analysis was establishing efficiency levels in terms of 

static efficiency. And so here we have just a presentation 

of these targets. So before we were using 0.54 to 

characterize the EL-0, in terms of total efficiency target 

and in terms of static, we use 0.5, et cetera, all the way 

down. The way we kind of developed this target was to reach 

similar levels of noncompliant fan selections, whether it 

was for ducted or unducted fans. 

 MR. DYGERT: Excuse me, I have a question here 

real quick. It's Ryan Dygert at Carrier. Just note that 

the discrepancy in static efficiency and total efficiency is 
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very small across that fan. There are only four points, and 

then it's constant (indiscernible). 

 MS. IYAMA: So I think you're, you're right. I 

think the typical difference between a total and static 

efficiency would be more something like, at least above 10 

percentage points. So that's one way that we could kind of 

adjust these targets. The way that we did it here was to 

say, well, what's the target expressed in terms of static 

efficiency that leads to similar impact on the market? 

 MR. WOLF: There's other constants in those two 

calculations besides the efficiency, right? 

 MS. IYAMA: Right, so we use -- 

 MR. WOLF: I think that's important for us to 

know. It's not just the efficiency constant, there's -- 

 MS. IYAMA: Right. 

 MR. WOLF: -- other constants that help shape that 

3D -- 

 MS. IYAMA: Right. So we used 250 and 0.4. 

 MR. WOLF: Right. 

 MS. IYAMA: For both cases. 

 MR. WOLF: Okay. 

 MS. IYAMA: For all cases. It's, and these are 

just the revised results for all the analysis. Same thing. 

I don't think we have much time to go through them. And 

just to answer your question, Mark, Mike, these were 
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sensitivity analysis that were done based on different 

values for the constants. And you can see doesn't really 

have a strong impact on the number of compliant or 

noncompliant selections. We just changed, you know, Q-0 and 

P-0 (phonetic sp.) and looked at how one fan would fail or 

pass. Here it's a sensitivity analysis based on different 

reselection criteria for size. So in the analysis, we were 

pretty strict, we didn't allow for changing diameter. Here 

what would, the analysis would look like if we allowed, you 

know, up to two nominal sizes and here another sensitivity 

scenario, so. 

 MR. WOLF: Yeah, the challenge to you guys here, 

you only had what was in the database. 

 MS. IYAMA: Yes. 

 MR. WOLF: Prepared for you, so it would be good 

for us to go back and look at this probably a little -- 

 MS. IYAMA: So, you know, we can do more of these, 

sort of, sensitivity scenario as requested. 

 MR. WOLF: The other thing, just to clarify, this

was, this is what we, we had a little bit of a different 

result, right? 

 MR. SMITH: Right. 

 MS. IYAMA: Right. 

 MR. WOLF: Between that and the fans, we got to -- 

 MR. SMITH: I'm just trying to think of a task 
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list so now -- 

 MS. IYAMA: So, I, so do you want me to address 

your question that you sent -- 

 MR. SMITH: You can, sure. 

 MS. IYAMA: Yeah. 

 MR. SMITH: If you want. 

 MS. IYAMA: So I, so -- 

 MR. WAGNER: This is Greg, and one of the things 

that struck me, too, in that fan substitution equation is 

that within 20 percent of flow or within 20 percent of 

pressure. That's a pretty broad range and I certainly would 

love if my customers allowed me to get away with that. 

 MR. SMITH: Greg, I think that they were doing 

was, this is Wade Smith, they were looking for another fan 

that was that close to the design point and the assumption 

is that if a fan was sold that close to the design point in 

question, that it could be sold at the design point in 

question. 

 MR. WOLF: Yeah. 

 MS. IYAMA: We use the fan laws to adjust the -- 

 MR. SMITH: They use the fan laws to adjust. So I 

don't think that's necessarily all that wrong. It's not 

that the replacement selection operated at a different 

operating point. It's just that if it was available for 

sale, had been sold at an operating point within 20 percent 
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of the design, then they assume that it could be sold at the 

design. 

 MR. SMILEY: And speed it up or slow it down, or.

 MR. SMITH: Yeah, exactly. 

 MS. ARMSTRONG: Yeah, you could tweak it. 

 MR. WAGNER: Yeah, but that changes, that changes

the efficiency numbers, so. 

 MS. ARMSTRONG: Right. 

 MR. SMITH: Well, which they've done also. 

 MR. WAGNER: I don't know if it's the 

(indiscernible) controls. 

 MR. SMITH: Yeah, which they did also. 

 MS. ARMSTRONG: Ours did, too. 

 MR. SMITH: Right. 

 MS. ARMSTRONG: Then also the -- 

 MR. SMITH: They used the fan laws to guide it 

down to the design point, then calculated the efficiency at 

that level. Right? Right. 

 MR. WAGNER: Okay, so they adjusted the efficiency 

for the change of glow and pressure? 

 MR. SMITH: Yes, sir. 

 MR. WAGNER: As well as, as well as changing the 

speed adjusts the flow and pressure? 

 MS. ARMSTRONG: So -- 

 MR. SMITH: Right. 
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 MR. WAGNER: So instead, it was within the 

parameters, you know, after you adjusted for all that? 

 MR. SMITH: Right. 

 MS. ARMSTRONG: Yes. 

 MR. WAGNER: Okay. 

 MS. ARMSTRONG: All right. 

 MR. ERNST: On slide 65 and 66, you have INPV 

after. What does that? 

 MS. IYAMA: Say, Mr. -- I'll let Sam answer to 

that. 

 MR. JASINSKI: I'm sorry, what was the question? 

 MS. IYAMA: INPV. 

 MS. ARMSTRONG: Industry Net Present Value. 

 MR. JASINSKI: Yes, but what's the question? 

 MR. ERNST: What it stands for? 

 MR. SMITH: What it stand, what INPV stood for? 

 MR. JASINSKI: Oh, what it stood for. Yes, 

Industry Net Present Value, sorry. 

 MR. SMITH: It was a test. So they, I feel like 

we should have a, you know, the majority of members should 

go home with a homework assignment on this analysis and we 

ought to try and figure out what are the most important 

things to try and get done. 

 MS. ARMSTRONG: Why don't we, let us, may I 

suggest that given your feedback that you've said today, can 
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we come up with a potential list to send around? 

 MR. SMITH: If you would like. I would hope that

it would be, include operating hours -- 

 MS. ARMSTRONG: Okay, part of it. 

 MR. SMITH: -- and part load consideration. 

 MS. ARMSTRONG: Uh-huh. 

 MR. SMITH: And cost relationship to efficiency 

different than what is assumed. What else guys? 

 MR. SMITH: Equipment life. 

 UNIDENTIFIED MALE: End of life. 

 MR. SMITH: Equipment life. How about this one, 

recovery period for conversion costs? Well, what other 

manufacturers here think about a reasonable period to 

recover conversion costs? 

 MR. FLY: This is Mark Fly with AAON, it needs to

be designed product wise, not equipment wise. Not how long 

it lasts (indiscernible) long it can operate for sale. 

 MR. SMITH: And so what do you think? 

 MR. SMILEY: That's the maximum. 

 MR. SMITH: Yeah. 

 MR. WIGGINS: And that's the maximum. So, you 

know. It depends a lot of how often we're going to revisit 

these efficiency levels. 

 MR. SMITH: Well, the statute says every six 

years. 
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 MR. FLY: So that would be the outside. 

 MR. SMITH: So six years or less. 

 MR. SMILEY: It's the financial decision that 

management usually makes, it's what they'll accept for the 

length of payback for any commercial or, I mean, capital 

investment. It's just financial, you know? What is it? 

It's not going to be 30 years. 

 MR. FERNSTROM: This is Gary, you know that's 

exactly the same thing -- 

 MR. SMILEY: I think, for you guys? 

 MR. FERNSTROM: That's exactly the same thing with 

pumps guys. 

 MS. ARMSTRONG: Yup. 

 MR. SMILEY: What was the conclusion? 

 MR. FERNSTROM: Probably not 30 years. 

 MS. ARMSTRONG: No we ran, we ran different 

scenarios. 

 MR. SMILEY: Okay. 

 MS. ARMSTRONG: We want what they wanted. 

 MR. SMILEY: See the sensitivity? 

 MS. ARMSTRONG: Yeah, exactly. 

 MR. BOTELER: Motor guys won't comment. 

 MR. SMITH: And is there anything else that the 

members of the working group think that we ought to be 

working on? 
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 (Off the record discussion.) 

 MR. ERNST: I think the AHRI members have to 

estimate the air handler redesign costs. 

 MR. FLY: Right. 

 MR. ERNST: And the safety testing, too. 

 UNIDENTIFIED MALE: It's going to be a busy room. 

 MR. SMITH: So it's important for you to hear 

what's coming what -- 

 MS. ARMSTRONG: What did they say? 

 MR. SMITH: Do you want to repeat that? 

 MR. ERNST: The AHRI members have to estimate the

air handler redesign costs and the safety testing for 

furnaces and electric heat. 

 MS. ARMSTRONG: Okay. 

 MR. ERNST: It's -- 

 MS. MAUER: I would say, in the cases where you 

actually would have to change the fan. 

 MR. ERNST: Right. 

 MS. MAUER: I would agree. Because we don't have

to change the fan, then. 

 MR. ERNST: Yeah. 

 MS. MAUER: There's no redesign. 

 MR. ERNST: And at the -- 

 MR. FLY: Conversion cost doesn't apply if you 

don't have to change. 
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 MS. MAUER: Right, and I'm just saying, it may be

the case that in many cases you don’t actually have to 

change the fans. 

 MR. SMILEY: Well, we won't know that until the 

metrics' defined. 

 MS. MAUER: Right. 

 MR. SMITH: And I would suggest that you include 

conversion costs when the fan substitution is not from the 

same manufacturer. 

 MS. ARMSTRONG: Yeah, so we should talk about 

that. Because I'm not sure if I agree with that. 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: Just generally speaking. 

 MR. SMITH: Go ahead. 

 MS. ARMSTRONG: You know, I, I, you're telling me

that as a customer, I will always buy from the same supplier 

no matter what. That, that's what I'm -- because by doing 

that, but you're saying that I'm not going to shop around, 

essentially. 

 MR. SMITH: No, I'm not. 

 MS. ARMSTRONG: You are, because that's what you 

would do if you implement a situation where the redesign is 

always limited by the ability for that same manufacturer to 

produce more efficient equipment, and that wouldn't be a 

competitive market. 
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 MR. SMITH: The question is, what's the burden on

industry. And the answer is if you're -- 

 MS. ARMSTRONG: But that's not reality. 

 MR. SMILEY: Whoa, whoa. 

 MR. SMITH: Let me finish. 

 MR. SMILEY: Whoa. 

 MR. SMITH: Let me finish, please. 

 MS. ARMSTRONG: You see, a manufacturer -- 

 MR. SMITH: Right. If you're a manufacturer and 

you're selling a fan that becomes noncompliant. 

 MS. ARMSTRONG: Yup. 

 MR. SMITH: What you said is exactly what would 

happen. Either that manufacturer is going to redesign a 

product to become compliant -- 

 MS. ARMSTRONG: Right. 

 MR. SMITH: -- before the deadline. In which 

case, conversion costs are appropriate. Or, they don't. 

Those are the two choices. If they don't, the customer buys 

from somebody else. 

 MS. ARMSTRONG: Yeah. 

 MR. SMITH: The sales of the manufacturer who lost 

the business went down. Generally speaking, manufacturers 

are not happy -- 

 MS. ARMSTRONG: Yeah. 

 MR. SMITH: -- when their sales go down. So they
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meet in a meeting with not so many people as you have here, 

and say, you know what, we got to solve this problem and 

their going to invest to recover their market share. Which 

is my point. That if the product that is substituted for a 

noncompliant product is not from the same manufacturer, the 

manufacturer who made the noncompliant product will invest 

to change their product line. And they're going to change 

their product line with an incurred conversion costs, and 

it's a burden on the industry that you haven't included. 

 MS. ARMSTRONG: Yes. 

 MR. SMITH: So what I'm -- 

 MS. ARMSTRONG: But that's going to depend on what 

you're asking. 

 MR. STARR: One thing I would say about that way 

that has, let's say I, you have Carnes that makes a

particular kind of fan. And the regulations go in and their 

fan doesn't meet it at a particular design point in the 

flow. There may be another design point that they have a 

real good product offering in the market, so maybe Greenheck 

will pick up that sale that Carnes couldn't make. But at 

the same time, Greenheck may lose in a sweet spot that 

Carnes has, and so they have market segments maybe where 

they're, in other words -- 

 MS. ARMSTRONG: There's some pushing. 

 MR. STARR: -- they won't need to go into that 
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meeting because they'll have the -- 

 MR. SMITH: The pushing -- 

 MR. STARR: -- same amount of sales, right? 

 MR. SMITH: Some shifting and consolidation, 

that's what you're saying, right? 

 MR. ERNST: And that's an area, you move for a 

monopolist? 

 MR. SMILEY: Exactly. 

 MR. ERNST: Right? Your pricing doesn't take that 

into consideration. 

 MR. SMITH: I think the more likely scenario, 

actually, is that Carnes wakes up one afternoon and says, 

you know what? We don't have enough money to do that. So 

they abandon that segment of the market, or they shut down 

their factory in Verona, Wisconsin and move it to Juarez, 

Mexico. 

 (Simultaneous conversation.) 

 MS. ARMSTRONG: It's not that we can't model a 

variety of different scenarios, and obviously, I think the 

answer is probably somewhere in the middle, right? That it 

won't be necessarily, there will be some shifting going on, 

and hopefully shifting not at a level that -- what we do 

want to understand is, we don't want to disserve the market. 

I mean, today there are competitive effects that, cost 

shifting, for whatever reason. You guys do it today and I 
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think we can model that. But I don't think a straight 

manufacturer to manufacturer, the same one, A to A 

substitution is also the right way to that. It may be some 

balance around that scenario. 

 MR. SMITH: Right, so I've been a manufacturer 

most of my life and trust me, if I have a product that's 

about to become noncompliant, it's highly likely that we 

will invest to protect that product line. Highly likely. 

If we have a product to substitute from our own product 

line, maybe not. 

 MS. ARMSTRONG: Right. 

 MR. SMITH: Maybe we just say we're just going to

shift over. But if we don't, highly likely that we're going 

to make that investment. 

 MS. PETRILLO-GROH: So, actually, is it possible 

to model the first look at the same, within the same 

manufacturer and -- 

 MS. ARMSTRONG: Yeah, we can. 

 MS. PETRILLO-GROH: -- then task that? 

 MS. ARMSTRONG: We can model, so keep in mind, 

we're modeling the industry. It's not a given, specific 

manufacturer and how they are situated. Yeah, we can model 

for that scenario. We'll take a look. 

 MR. BUBLITZ: Are we winding down? Mark Bublitz. 

I'd like to, can we propose a transition to a new topic? 
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I'd like to understand more about ratings and manufacturer 

representation and for those of you that have been regulated 

already, this is probably old hat. But it's confusing when 

thinking about the data have and how that data will have to 

change, or may have to change, or may not have to change, 

post regulation. 

 MS. ARMSTRONG: Right. You want me to talk about

that a little bit? 

 MR. BUBLITZ: I would really appreciate that. I 

think you're the source. 

 MS. ARMSTRONG: Can we do one thing real quick? 

Can we take a five minute break so I can get -- 

 MR. SMITH: Absolutely. I'd like to have a while

break. 

 MS. ARMSTRONG: -- some slides or whatever else 

you may want? So, I'm going to talk on a high level and 

with some examples of kind of how we talk about ratings and 

the development of such ratings or representations with a 

respect to what we currently do every other, most every 

other piece of equipment, and then what this would look like 

if we did the same thing for fans. And this is not meant to 

say this is what we should do. This is not meant to say 

this is what we have to do. But this is so you understand 

that if we took the regulatory approach, as it exists today, 

for most other products we cover, this is kind of what it 
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would look like for you. I, I'm going to do these slides 

with the caveat that we put them together in the last hour 

and a half on the slide over there, so we may go back and, 

you know, put some additional meat on them as, before they 

are handed out, but. 

 So, basically you guys asked how we rate a basic 

model. And the way this works is, generally speaking, at 

least two units are selected at random from a given basic 

model to be tested. You would do the selecting for

certification. So I think some units for some products we 

have more than two required. There's never, I don't think 

there's any instances off the top of my head where just one 

is allowed. The idea behind a multiunit sample is that it 

takes into account the variation coming off the production 

line. So each sample, each unit is tested in accordance 

with the DOE test procedure. To account for these 

variations, the manufacturer processes at the times when the 

manufacturer is testing, so the subject we have control 

over, we apply what we call certification statistics. They 

govern how you can rate your equipment. We do that by using 

competence limits. A competence limit's change depending on 

the product, and obviously that would be something that we 

would be specific to here. And then it governs how you can 

make representations. DOE's regs generally speaking allow 

you to rate conservatively all the way down to the standard. 
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Even if you have test data that shows that you can rate 

higher, that part of it's going to be at the discretion of 

the manufacturer. So I'm going to walk through what this 

means for fans. 

 MR. PERSFUL: So, so if, this is Trinity, Twin 

City Fan, so if we wanted to, we could always rate at the 

bare minimum and say that this product is compliant and, 

essentially, has a zero risk of fines or whatever it may be 

called. Yet we give up, I mean, we give up other stuff I 

would assume. Like utility rebates type stuff. But if that 

was, would that be a true statement that we would be able to 

do that if we wanted to? 

 MS. ARMSTRONG: So I'm going to take that zero 

risk of fines and stuff off the table. But to the extent 

you have, I mean, I'm not here talking as the enforcement 

person. But just generally speaking about the regs. To the 

extent you have test data that shows that your product can 

be rated somewhere at the standard or above, more, the fan 

has less consumption or above, then you would, you could 

rate everything right at the standard. If you showed, you 

know. 

 MR. PERSFUL: Fair enough. 

 MS. ARMSTRONG: We do have people for certain 

products that do. So, given what we've set up over the past 

handful of weeks, what this would look like, what would this 
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mean for fans? So for each fan model, the regulatory perks 

that we've been talking about is that you are going to selfselect and then self-certify the FER or whatever, just work 

with me here, FER at every operating point for which you 

decide to self-declare that you're going to sell that fan 

model. So in other words, you're going to define more 

operating points. You would then certify to this. In order 

to do that, you would have two methods for calculating FER 

at each of these self-declared operating points. So the 

first method is you'd have your tested BHP, you apply the 

nominal approach. That would be the default motor loses, 

the default transmission, and the default controls. So it 

would be your tested fans with the nominal things. You'd 

test two samples at each of the given operating points you 

want to claim for the BHP. You'd apply all the nominal to 

get your FER for -- 

 MR. PERSFUL: Ma'am? 

 MS. ARMSTRONG: -- each unit -- 

 MR. PERSFUL: Ma'am? 

 MS. ARMSTRONG: -- in the sample. So at the end 

of the day, you'd have two FERs for what's supposed to be a 

given fan at a given operating point. 

 MR. PERSFUL: I'm sorry, this is Trinity, I'm 

sorry, but the way my mind works, I try to find all the ways 

to do this. So when you say nominal, just make sure I've 
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got my vernacular right. So if I take the nominal motor 

loss of, the motor nameplate says nominal -- 

 MS. ARMSTRONG: No. 

 MR. PERSFUL: Okay. 

 MS. ARMSTRONG: You're going to take, I'm, maybe 

that's a bad word, because when we're talking about -- 

 MR. PERSFUL: Yeah, don't -- 

 MS. ARMSTRONG: Default, how about default? 

 MR. PERSFUL: Default, because that's, that's -- 

 MR. DELANEY: It's not in my dictionary. 

 MR. PERSFUL: That's exactly, that's the exact 

point I was trying to get at. 

 MS. ARMSTRONG: How about default? 

 MR. PERSFUL: Okay. 

 MS. ARMSTRONG: We're going to give you the 

default values -- 

 MR. PERSFUL: Okay. 

 MS. ARMSTRONG: -- that you're allowed to apply -- 

 MR. PERSFUL: Okay. 

 MS. ARMSTRONG: -- pursuant to the past procedure. 

 MR. PERSFUL: Okay, that's -- 

 MS. ARMSTRONG: No defaults are going to be look 

up tables that we've talked about, well, whatever. You're 

going to use the -- well, and basically it's like saying 

you're not running the wire to air test. You are applying 
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to your fan test some default values to get out your FER, 

okay? 

 MR. PERSFUL: When you said nominal -- 

 MR. FLY: So actually, this is Mark Fly with AAON, 

you anticipate having an AEDM or a fan law so that we don't 

have to test every model? 

 MS. ARMSTRONG: Right, we haven't got there yet, 

but I -- 

 MR. FLY: Okay, I'm jumping the gun. 

 MS. ARMSTRONG: I would say that for a commercial, 

(indiscernible), so yeah, no issue. Okay, so we've gotten 

through this scenario. The key here is, the thing I think 

we need to talk about is whether, and this is not for, 

potentially feedback today, but it's whether you want to 

consider testing one sample for your fan efficiency, 

multiple samples for your fan curves. I mean, basically how 

many units of a given fan model do you test to get that 

representative, what you think is a fan curve. And I don't 

know need an answer today. It's something you probably want 

to think about. But it gets to the heart of what's your, 

your own test times in your lab if you have one, and then 

what's your manufacturer variation coming off your 

production line for a given fan line? 

 MR. MAGILL: Question. 

 UNIDENTIFIED MALE: It's 0.2 -- 
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 MR. MAGILL: John Magill with Howden. How do you

plan to handle custom designs? One off? 

 MS. ARMSTRONG: So we do have ways to handle 

custom designs, we do have them in our regs for other 

equipment where there's one offs. There's a couple of 

different ways we can talk about doing it. I think

depending on how we do it for the overall population that 

would feed into it, but a lot of people just typically use 

simulation methods, which is what he was getting at. With, 

we call those AEDMs in our regs. And they simulate the 

efficiency of the product, rather than testing at all. So 

that option is on the table, especially for custom built. 

There is some, there are some things you have to do make 

sure that your simulation is what I would call validated. 

For the purposes of comparing tested results and model 

results. But once we consider it validated, it can be used, 

you know, to write other untested model combinations. So 

that's typically what a lot of people do for custom built 

equipment. There's also other provisions with the reg to 

certification where we have different accommodations for 

custom built equipment. 

 MR. FLY: This is Mark Fly with AAON. And in our

other product that we went through a lot of this, the 

engineered, what we called the engineered to order -- 

 MS. ARMSTRONG: Yeah. 
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 MR. FLY: -- side. You did have to, even though 

you didn't have to list it prior to operating it for sale, 

you had to list it prior to shipment. So before you 

shipped, you had to go on the DOE website and say this is my 

custom product, here it is. It went in, I think, a special 

section and stayed there some period of time 

(indiscernible). 

 MS. ARMSTRONG: Yeah. 

 MR. MAGILL: Is that available to the public? 

 MS. ARMSTRONG: Yeah, that's in our regs. 

 MR. MAGILL: But I have customers that wouldn't 

want that information divulged. 

 MS. ARMSTRONG: In other words you have customers

that wouldn't want their operating characteristic divulged? 

 MR. MAGILL: Correct. 

 MS. ARMSTRONG: Okay, so you need to talk about, 

we probably should talk about at some point given the 

requests for a self-declared operating range as your 

regulatory approach. Okay? We don't, they would have an 

issue with, just to be clear, model numbers and operating 

characteristics? 

 MR. MAGILL: We don't have a model number. It's a 

unique one off design. 

 MS. ARMSTRONG: I get that part, but you say, for

the purposes of certification, we made you say this Actually 
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123 and you would know what Actually 123 is. 

 MR. MAGILL: Uh-huh. 

 MS. ARMSTRONG: If we didn't put your 

manufacturer's name out there, but we did put model number 

information, Actually 123, which is meaningless to the world 

other than you, and DOE, would that still cause an issue? 

 MR. MAGILL: Perhaps. 

 MS. ARMSTRONG: Okay. 

 MR. MAGILL: Not sure. 

 MS. ARMSTRONG: Well, think about it. 

 MR. MAGILL: One of the customers is the U.S. 

Navy. 

 MS. ARMSTRONG: Okay. 

 MR. BUBLITZ: So at this, Mark Bublitz, New York 

Blower Company. 

 MS. ARMSTRONG: Yes? 

 MR. BUBLITZ: So at this point -- 

 MR. MAGILL: I can't tell you -- 

 MS. ARMSTRONG: Oh no, I -- 

 MR. BUBLITZ: -- the manufacturers have one of, so 

we got on this path, one method is for a manufacturer to 

acquire, to manufacture two randomly selected products, test 

them, put it in a crank and out comes the metric. 

 MS. ARMSTRONG: Out comes the FER. 

 MR. BUBLITZ: Okay. 
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 MS. ARMSTRONG: And you'll have two FERs. Well, 

if we go down this, two units -- 

 MR. BUBLITZ: I, I -- 

 MS. ARMSTRONG: You'll have two FERs, right? 

We're continuing. Okay, now we're going to go to FERs, all 

right? Wire to air. So I conduct a wire to air test for 

two units within a given, so one, two units at a given 

operating point, obviously you'll probably run in the 

standard operating points, but whatever. At the same time, 

that being said, you'll then use the DOE statistics to 

calculate the sample mean and the upper contents on it from 

the FER values, and then that will determine your allowable 

range for selecting a representative value. So you're 

probably looking at, what does that really mean? 

 MR. MAGILL: Right. 

 MS. ARMSTRONG: So purely illustrative, I made up

numbers not based on anyone's particular product. But this 

is essentially what it would, will come out to be. You 

would have your BHP and BHP are the numbers you would get 

for a given test, two different units at the same operating 

points. You would get those values. Just say that those 

are the, that's the variation you see for whatever reason. 

You would then apply the defaults values as we give them to 

you in the test procedure, and you would get your FER 

values. These are the two values. If you apply how we 
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typically govern ratings and representations, if you apply 

the statistics that govern that, you get a value for which 

you have tested FERs of 7.34 to 7.22. It is going to shift 

you down the bell curve, pushing you to rate conservatively 

if we used, I think this example we used a 95 percent 

confidence. No, this used a 97.5 percent confidence limit. 

You would be able to rate no less than a 7.66. 

 MR. SMITH: No less than? 

 MS. ARMSTRONG: No less than, the way this works. 

 MR. SMITH: So, and what -- 

 MS. ARMSTRONG: And honestly, there's a lot of -- 

 MR. SMITH: Oh, excuse me. This is brake 

horsepower? 

 MR. STARR: Yeah. 

 MR. SMITH: Or -- 

 MS. ARMSTRONG: No, no -- 

 MR. SMITH: -- or whatever? 

 MR. STARR: Yeah. 

 MR. SMITH: Import-wise. 

 MS. ARMSTRONG: Yeah. Right? There's a lot that

goes into this, and like I said, I just picked random 

illustrative examples. We could pick the confidence limits, 

we could pick the number of samples, but this is generally 

speaking how this works and why this matters is because when 

you come out with a representative ER, FER, I should have 
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put a number here. So let's just say the standard level of 

eight here, you could rate anywhere between 7.6 and eight, 

right? You could rate anywhere higher. You could opt, as 

Trinity said, as a business decision to go all the way 

conservatively to eight. You could rate everything. You 

could go somewhere in that range, because you want to make 

sure if DOE pulls a unit, or somebody else pulls a unit for 

testing, you're always going to get that or better. But you 

cannot go above this number, period. 

 MR. SMITH: Above or below? 

 MS. ARMSTRONG: Lower, sorry. 

 MR. STARR: I was like, what? 

 MR. SMITH: How did it, the factors that fend you

from 7.28 to 7.66, what are those? 

 MS. ARMSTRONG: So it's going to be based on your

competence and -- so what's driving that decision is the 

variation that you would experience in the manufacturing 

processes. 

 MR. SMITH: And this is at the discretion of the 

manufacturer? 

 MS. ARMSTRONG: Nope. We will set the competence

limit. So some products it's 99, sometimes it's 97.5, 

sometimes it's 95, it just depends. But obviously we would 

like your input on, but setting those numbers does matter. 

Now, that being said, even if you set a 97.5 competence 
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limit, if you do, if you have a really narrow bell 

distribution, you're going to be able to rate closer to your 

values of 7.3 -- closer to your tested values. So there is 

some discretion and control within the manufacturer, even 

though we're building in a competence limits. I mean, how 

wide that curve goes -- 

 MR. BUBLITZ: You -- 

 MS. ARMSTRONG: You get to see the variation 

coming off your line. 

 MR. BUBLITZ: So Mark Bublitz, Blower. And the 

way that you prove that that distribution is narrow is you 

either increase the number of samples -- 

 MS. ARMSTRONG: Yes. 

 MR. BUBLITZ: But that doesn't kind of defeat -- 

 MS. ARMSTRONG: Take, we take two or more. 

 MR. BUBLITZ: Or you find a way through 

manufacturing technology to make sure those numbers come out 

the same? 

 MS. ARMSTRONG: You got it. That's how this 

works. But why this matters is because at the end of the 

day, whatever that FER value that we tell is how you 

calculate it and how you have to certify that the same line 

you have is in your literature and your public 

representations and your marketing, voluntary programs and 

everything else. They can't have different numbers. 
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 MR. HARTLEIN: This is Dan, quick question? 

 MS. ARMSTRONG: Yeah. 

 MR. HARTLEIN: I'm not sure how to raise my hand,

sorry about that. 

 MS. ARMSTRONG: It's okay. 

 MR. HARTLEIN: But how does this work for custom 

equipment? 

 MR. FERNSTROM: So Dan, it's Gary here, sitting 

right next to me, and I saw you raise your hand. 

 MR. HARTLEIN: Oh, thank you, Gary. I appreciate

that. 

 MS. ARMSTRONG: Yeah, so we kind of touched on 

that at the beginning. There are some nuances with custom 

equipment, one offs, built to order, we engineer to order. 

We can make accommodations for those. I would say focus the 

effort on this, what should this look like? And then we can 

talk about how that translates to custom equipment. 

Generally speaking, and you know, some of our other, in some 

of our other industries, there's a significant concern, 

understandably so, about testing every single custom built 

equipment. If a similar concern exists here, even for 

running fan curves, one solution to that is AEDMs, what we 

call simulating results rather than testing. 

 MR. HARTLEIN: But there is, outside of custom, 

there is a tremendous amount of equipment in our industry 
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that is, I would call, semi-custom. It's quasi-custom. You 

know? Somebody has changed the, the width of a wheel, a 

diameter of a wheel ever so slightly to hit a particular 

duty point. That might happen once a year on a particular 

product. Does that become custom relative to this analysis? 

 MS. ARMSTRONG: So as a second term in our regs 

that we use, which is called basic model. And the basic 

model concept is really kind of like this made up concept 

for DOE regulations, but what it allows a manufacturer to do 

is group essentially identical units coming off a production 

line, essentially identical models coming, individual models 

coming off a production line, for the purposes of developing 

a rating and reducing the housework. 

 MR. SMITH: So, so -- 

 MS. ARMSTRONG: Um -- 

 MR. SMITH: Does that imply that in the example he 

chose, in the sample you used, he would declare this 

slightly different unit to have a 7.66 or would be able to 

use a AEDM to alter that number? 

 MS. ARMSTRONG: So the answer's going to be it 

depends. If we allow the use of an AEDM, once you have a 

validated AEDM pursuant to our regs, you can use it. 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: You know, that would be an option. 

That being said, you know, we -- 
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 MR. SMITH: Likely that he's giving the 7.66? 

 MS. ARMSTRONG: Right. 

 MR. FLY: It's Mark Fly. The other thing that's 

going to happen with a basic model, when you group those, 

whatever you represent that basic model as, no model that 

falls in that basic model, that grouping of basic units in 

that basic model can be represented any higher in efficiency 

than that, and on tested it better meet -- 

 MR. SMITH: Right. 

 MR. FLY: -- that requirement? So you can make 

your model groups depending on how we define it? 

 MR. SMITH: Right. 

 MS. ARMSTRONG: yeah. 

 MR. FLY: Rather broad, but you're going to be 

paying a lot of -- a lot of range of models, likely. 

 MS. ARMSTRONG: Right. And we, we try to allow 

you guys some flexibility. I mean, you can get it down to 

rating every single model that you make or you can do it as 

roughly as grouping hundreds of models (indiscernible). 

 MR. SMITH: Right so, what, what -- 

 MR. BUBLITZ: I think I was first. 

 MR. SMITH: Go ahead. 

 MR. BUBLITZ: Mark Bublitz, New York Blower. So I 

have a, currently we have catalogs with lots of CFM, static 

pressure, brake horsepower, our data. 
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 MS. ARMSTRONG: Yeah. 

 MR. BUBLITZ: And then I would have to, let's 

just, let's go down the model road for a second. Let's just 

assume that I have a model and I have a catalog. And 

attached to that model would be a test which creates a 

distribution which creates a rating. I won't, if I took my 

calculator out and I took the catalog data and I turned the 

crank, I wouldn't get the rated value. I would get, in 

theory, a number less than the rated value. 

 MR. SMITH: 7.28. 

 MR. BUBLITZ: Is that -- 

 MS. ARMSTRONG: So what is it from your catalogs 

that's going to give you that -- 

 MR. BUBLITZ: Well, the FER number. I'm going to

take the brake horsepower and I'm not, I'm going to get -- 

 MS. ARMSTRONG: Oh, right, you're going to get 

something lower then. I understand. It's not, it's meant 

to represent the population, right? But, technically, I 

mean, the way we would work, because that brings up a 

question about whether we should have a rating conversions 

for other things other than just FER. We weren’t going down 

that pathway, but we can talk about that, whether there's a 

disconnect between what would be in your catalogs versus --

we understand. 

 MR. ROY: So the UCL over here incorporates 97.5.
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 MS. ARMSTRONG: Right. 

 MR. ROY: So if we think there's better products,

like let's say air conditioners, I think we see -- 

 COURT REPORTER: Please keep your volume up. 

 MR. ROY: I think the UCL for that is 95 percent,

in terms of rating. So is this up for consideration in 

terms of the competency is concerned? 

 MS. ARMSTRONG: Yeah, that's what I said. 

 MR. ROY: Because it likely that, you know, it'd 

depend, it would be different for covered equipment if we go 

that route. 

 MS. ARMSTRONG: I think it depends on how you test 

it, right? If you end up testing it and vet it there should 

be, a different version would be when you end up testing it 

free flow or stand alone and you're testing the 

configuration, meaning the variation is not that different 

from the rest of the fans we're talking about here. 

 MR. PERSFUL: Trinity, Twin City Fan. So for the

last 20 years we have tested data, we have got our own lab 

and everything else. Can we retroactively use that test 

data to get these numbers? So we don't have to redo 

everything, or -- 

 MS. ARMSTRONG: As long as it's in accordance with 

the DOE tests at the end of the day. 

 MR. PERSFUL: Okay. 
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 MR. BUBLITZ: Slide one says a randomly selected 

sample. And -- 

 MS. ARMSTRONG: That's on you to figure out. I 

mean, if you're testing what you have, if you believe is 

representative of your population. I mean, typically some 

manufacturers do this, in which case they have two units 

that you have to certify for distribution and commerce. And 

so you would certify the department, and then if they have a 

given model for which they don't see the life of that model 

is supposed to say 10 years, you know, they may spot check 

and add to that testing to over time. And to the extent you 

have data that no longer shows that your rating's valid, you 

are required to recertify. But if the rating remains to be 

valid, if you make slight improvements but don't want to 

claim such an improvement, that's okay. But if you wanted 

to claim such improvements, you better have the testing done 

that underlies your rating. 

 MR. MCNEIL: Donald McNeil, Buffalo Air Handling. 

We're a custom air handling unit manufacturer. We're buying 

our fans. 

 MS. ARMSTRONG: Okay. 

 MR. MCNEIL: I can see this excluded from 

reporting requirements, because we're buying a tested fan 

that's already rated. Do you see it the same way? 

 MS. ARMSTRONG: Well I was trying not to have to 
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answer that question next. 

 MR. MCNEIL: Oh. 

 MS. ARMSTRONG: So I think it depends. I will 

say, because we don't have fan regulations, I'm not going to 

say what it would mean to fan people. Right now, 

certification is based on manufacturing and imports. So if 

you were an importer, you would still be required to certify 

for most other products. But that being said, you know, I 

don't know if we would be willing to entertain other things 

here, in terms of that, but that is a nuance. It would be 

the fan manufacturer, but it would also include the importer 

if someone, if a different entity was importing a box of 

fans (indiscernible). 

 MR. MCNEIL: Okay, and I have a second question. 

What if we used the fan and that was later discovered not to 

meet the requirements? 

 MS. ARMSTRONG: Um -- 

 MR. MCNEIL: How do you find this? Or find where

the equipment is or whatever? 

 MS. ARMSTRONG: So I don’t think that's 

something -- 

 MR. MCNEIL: I don't want to put 

 MS. ARMSTRONG: -- that I can actually answer. I

don't think that, I mean, that really gets to our team of 

lawyers and how they deal with specific enforcement
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investigations. But I would caution that you'd be 

surprised. 

 MR. MCNEIL: Okay. 

 MR. BUBLITZ: And this specific to how we will be

allowed to present information in markets. This is not 

portion testing, sampling -- 

 MS. ARMSTRONG: No, it's a specific to just how 

you're, how you come up with your representive, what I'm 

calling your representative value. That's going to be the 

value that you get certified to the department, but that's 

also going to be the value you show in your literature and 

everything else. 

 MR. HOWE: Okay, so hopefully you can just -- 

 MS. ARMSTRONG: Right. 

 MR. HOWE: -- up for me. Nick, Carnes. Right 

now, my catalogue's got 5.92 and 5.87. 

 MS. ARMSTRONG: Yup. 

 MR. HOWE: So let's just say this is a belt drive

fan. So we had the motor losses drive us low. We get to 

7.34. 

 MS. ARMSTRONG: Yup. 

 MR. HOWE: But the guy buying it saw 5.92. He 

said all right, I'm going to buy your fan, I'm going to 

stick a 7.5 horsepower motor on it, because it's the next 

one. Now, you add the rest of the stuff, I add my 
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confidence and I'm at 7.66. So he goes, well, I'm over my 

7.5, now it's got a 10. Did that just hurt the whole 

purpose for sitting in this room? 

 MS. ARMSTRONG: It didn't hurt the whole purpose 

for sitting in this room. But I mean you're fundamentally 

asking me to -- no. I mean, we're all here with great 

purpose, right? And great intentions. And, but if

downstream of you someone -- I don't have an answer to this, 

by the way, but you're asking what happens basically outside 

of the fan manufacturer's purview and other product, and 

other components less efficient than the nominal components 

are added to my product and thus, you know, erasing the 7.66 

gains that I thought I was going to be getting. Is that 

what you're asking, more or less? 

 MR. HOWE: (No audible reply.) 

 MS. ARMSTRONG: I don't think I can answer that, 

per se. At least at this point in time. 

 MR. SMITH: Well, on the surface, I would 

speculate that the manufacturers would be very comfortable 

with a requirement that relates to their representation of 

the FER from, in this, and would be delighted if that was 

the end of the restriction on what they chose to move in the 

marketplace. 

 MS. ARMSTRONG: What does that mean? 

 MR. SMITH: What that means is that they would 
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like to publish the airflow and the pressure and the RPM of 

their fan that ties to their confidence and their 

traditional practice in the marketplace. The power input is 

restricted by a DOE regulation, and they would deal with 

that. So that, I mean, I'll be certain, not happy to, but 

I'll be certain to survey our members to make sure that 

that's -- I'm pretty certain that's the case. The second 

thing I wanted to -- 

 MS. ARMSTRONG: And I mean, just to be clear, when 

you're talking about, just to make sure I understand you, 

though, before we move on. When you're talking about those 

other operating ranges, I mean, those are discrete points 

that they're going to certifying with different FER values? 

I mean, that's what's going to -- 

 MR. SMITH: No, they aren't going to have 

different FER values because you just told us we couldn't. 

 MS. ARMSTRONG: Well, every operating point. 

 MR. SMITH: Every point? Every operating point? 

Well -- 

 MS. ARMSTRONG: Every operating point will. 

 MR. SMITH: Every operating point will have a 

different FEI or FER, yes. 

 MS. ARMSTRONG: And we've set this up so that 

you're going to self-declare what those points are, thus -- 

 MR. SMITH: Right. 
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 MS. ARMSTRONG: -- defining -- 

 MR. SMITH: This is the range -- 

 MS. ARMSTRONG: -- your rate. 

 MR. SMITH: -- over which we are selling this fan. 

 MS. ARMSTRONG: And so you're asking, can they 

make representation of other attributes, other 

characteristics of their fans outside of the FER, but as 

long as they're within that same range, correct? 

 MR. SMITH: Yeah. 

 MS. ARMSTRONG: We allow that for other things, so 

I'm not sure why that would be off the table here. 

 MR. SMITH: And then the other comment I'll make,

I think you know this, but I just want to be clear. It is, 

you know, a tradition in our industry to test several fans 

to rate an entire product line. Not each fan's size in that 

product line is tested in order to determine the ratings. 

But rather, a well proven AEDM that's related to the fan 

laws, basically, allows one to do that. So the idea of 

having to test two fans in a product line is no burden at 

all. It is also true, however, that as you, the ratings 

standard that is used extrapolates up from a test to larger 

sizes, but not down. And that is because that as you move 

up the ratings become more conservative. Which is a 

manufacturer doesn't rate an entire product line from one 

fan. They pick various sizes, recognizing that they're 
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driving themselves to be conservative as they extrapolate 

up. So with that understanding, then we'll do whatever is 

required to win your support of the AEDMs that are used. 

 MS. ARMSTRONG: I -- 

 MR. SMITH: There's no problem. 

 MS. ARMSTRONG: I wouldn't necessarily call it an

AEDM, but I think -- 

 MR. SMITH: Well, it is. 

 MS. ARMSTRONG: Well, that's just a calculation of 

that, right? 

 MR. SMITH: Yeah. 

 MS. ARMSTRONG: I mean, we can -- that's no issue. 

 MR. SMITH: Yeah, okay. 

 MS. ARMSTRONG: That being said, though, I just 

want to follow up on some things. You test, just explain to 

me what you do. You test two, two or more currently for an 

entire line, which may expand sizes? 

 MR. SMITH: Yeah, let's -- 

 MS. ARMSTRONG: Or do you test -- 

 MR. SMITH: The example you might have is a 

product line, they go from 24 to 72 inches. And in the 24 

to 72 inches, there's 10 different diameters. Yeah, 

probably, they would test two fans in that range, two 

different sizes, and rate the entire range. 

 MS. ARMSTRONG: And just to be clear, there's 
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never a case where you test two 24 inch fans? 

 MR. SMITH: Not unless we make -- 

 MS. ARMSTRONG: I would go as far as to say that's 

what this would -- 

 MR. SMITH: You have it exactly right. We'll have 

to double up on everything, yes. 

 MS. ARMSTRONG: -- require you to, so if that's 

not what we want to talk about, if that's not what we want 

to do, if you believe the variation -- 

 MR. SMITH: Yeah. 

 MS. ARMSTRONG: -- is captured if you test just 

two in that diameter or range and use the fans for others, 

that's something that we need to have a discussion about. 

Because I write the regs the way they are for the other 

products, I don't believe that you could continue to do it 

that way. 

 MR. SMITH: That, okay. So that is what we 

believe. And the statistical support for that belief, in 

our certification program is, that every three years we test 

a model in this product range that has never been tested 

before, at our lab, at the AMCA lab, and we pull it in and 

the manufacturer's at risk if that unit rated with 

mathematics, if that unit is not, does not perform 

correctly. And the confidence level that our members have 

in that rating method is very, very, very high. 
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 MS. ARMSTRONG: I'm not questioning, necessarily,

the validity. I'm questioning what it is that you wanted us 

to consider. So perhaps you could take that back and let us 

know. 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: As a group of you, a wholesale, 

exactly what it is. And I just wanted to make, there is a 

nuance from DOE between, you know, given fan model, the 

specific diameter and specific attributes versus the entire 

product line which may span, you know, different sizes, 

different lengths. 

 MR. SMITH: So that's certainly our ask. 

 MS. ARMSTRONG: And so Armin, I have a question 

for you, now. 

 MR. HAUER: Yes? 

 MS. ARMSTRONG: So for wire to air, do you guys 

test every combination of fan/motor/drive system that you 

might want to offer to come up with a rating, exclusively? 

Do you test more than one unit of each of those, or do you 

test some and then also extrapolate some? 

 MR. HAUER: We test all basic models. 

 MS. ARMSTRONG: All basic -- and one unit of each

or multiple? Multi-sampled, is what I would say. 

 MR. HAUER: Well, because of our precious control

we will need multiple fans as well. 
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 MS. ARMSTRONG: Okay. 

 MR. SMITH: Right. 

 MR. HAUER: So we have preliminary data, you know? 

And then we make 10 samples and then -- 

 MS. ARMSTRONG: Okay. 

 MR. HAUER: Yes. 

 MS. ARMSTRONG: So you (indiscernible)? Okay. 

 MR. PERSFUL: Trinity from Twin City Fans. What's 

the, if we sell to a distributor or OEM or somebody that's 

not usually the customer, what's their responsibility to 

pass on the rating or the performance, you know, the FER? 

What's -- 

 MS. ARMSTRONG: It depends, they, I mean, it 

depends on what you guys decide you want to do with legally. 

Disclosures, those types of things. It depends on what we 

define, what DOE ultimately defines is a fan manufacturer 

and who that entity is. It depends on what we went up 

seeing is the testable configuration in terms of who that 

entity is responsible. So the answer is, I don't know yet. 

But if you have specific proposals for which you want the 

group to consider about legal disclosures, those types of 

things, and the information that needs to be passed along, 

we welcome that. I have no idea what time it is. 

Everyone's standing. I take it it's time to go? 

 MR. SMITH: It's 3 o'clock. 
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 MR. STARR: It's 3 o'clock. 

 MR. SMILEY: 3 o'clock. 

 MS. ARMSTRONG: Go. I'm here to answer questions

if you want them. 

 MR. ERNST: If, I don't, I haven't -- 

 MS. ARMSTRONG: Safe travels. 

 MR. ERNST: -- been to many of these meetings, but 

have you yet thought about what type of information was 

submitted to DOE from the fan manufacturers? Since it's an 

envelope that would be a computer program or something 

pretty complex, I guess, right? 

 MS. ARMSTRONG: No, I don't think we thought it 

was going to be a computer program. I mean, they're going 

to come off the, they may have a computer program that comes 

up with discrete readings, but I think it'll look more like 

a table. 

 Yeah? 

 COURT REPORTER: I can't hear you over the talking 

room. 

 MS. ARMSTRONG: Okay. So we can stay here and 

continue talking, we can wrap up and pick it up next time. 

Whatever you guys want to do. 

 MR. SMITH: I just have one more question that I 

think everybody would be interested in. Okay. Imagine this 

scenario, we have a fan that's rated just as you describe 
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based on an airshaft test, and FER rating is applicable to 

any time I sell that fan with an airshaft and people couple 

it with other things. Imagine that I also want to offer 

this same mechanical fan with a particular motor and drive 

that I carefully select and I select that motor and drive 

based on its efficiency. Now it's motors and drive, because 

it's a range, so it's going to involve more than one motor. 

And the motors and the drives are collectively more

efficient than the default values. 

 MS. ARMSTRONG: Yeah. 

 MR. SMITH: So we understand that we can test the

wire to air and demonstrate using the test method that the 

efficiency is higher and we can offer that package, that 

extended product, at that higher efficiency. 

 MS. ARMSTRONG: It is a different, certified, 

basic model? 

 MR. SMITH: Right. However, can we use AEDMs to 

determine the efficiency of this infinite number of

operating points for the extended product? 

 MS. ARMSTRONG: Well, I think that's up to us to 

talk about, right? 

 MR. SMITH: Okay. 

 MS. ARMSTRONG: We don't have, you know, at this 

point, we don't have lines that govern AEDMs to the fans. 

 MR. SMITH: Okay. 
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 MS. ARMSTRONG: We have some AEDMs that can be 

widely used. We have other AEDMs that have bounds around 

them. If you believe that, you know, for a specific motor 

and drive and then package and sold all together, a working 

group feels that they should be tested, then we put those 

regs in place. So we consider putting those regs in place. 

We, right now, it's a white sheet of paper. 

 MR. MCNEIL: Donald McNeil. If they do the test,

do I have to buy the motor and drive from them? The fan 

manufacturer, or can I buy an identical motor and drive 

through other channels? 

 MS. ARMSTRONG: Well, in theory, if they're offer

-- if the fan manufacturer is offering for sale a fan, 

independent of a motor and drive, for which they rated with 

nominal values, you're buying that base model. Because 

you're doing your own motor and drive thing. And then 

they're also offering for sale this other system package 

that has that same fan, but a specific motor and drive, and 

so it's essentially, in DOE's mind, two separate models. 

You're taking this one and doing your own thing and they're 

taking this one and claiming higher efficiencies because 

they've taken into account system effects that they wanted 

to optimize. 

 MR. MCNEIL: Even though I bought the exact same 

motor, the exact same drive that they tested? 
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 MS. ARMSTRONG: Are you asking to recertify it? 

 MR. MCNEIL: No. That's the answer. 

 MR. SMILEY: You don’t get to put the number on 

it. 

 MR. SMITH: So you want a motor AEDM, or a 

drive -- 

 MS. ARMSTRONG: They have them. They have a motor 

one. 

 MR. SMILEY: So, for example, we can have -- 

 MS. ARMSTRONG: Anyhow, so we can have, we can 

talk about this. These are all topics to talk about, but 

hopefully this was somewhat helpful for your parting gifts 

on the way home. Like I said, I'm going to make some tweaks 

to these slides, just because we didn't have a whole lot of 

time to put, at least, an explanations behind it. So when 

they're sent out that at least somewhat makes sense. But 

thank you for coming, we'll see you in a couple weeks. 

 UNIDENTIFIED MALE: Yes, ma'am. 

 MS. ARMSTRONG: Lucky for you, you were able to 

get the room up the street, so bigger and it has a cooler. 

So we'll send out a reminder that we're going to be up the 

street then. I think it's the 22nd, 23rd? 

 UNIDENTIFIED MALE: So the schedule shows one day

over there and one day back here? 

 MS. ARMSTRONG: So both days we're going to go to
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there. 

 (Whereupon, the meeting was concluded.) 
246 

% Digitally signed by Nicholas Allen 

 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: 

 

 

 Nicholas Allen, Transcriber