AMCA-Advocate Meeting, Chicago

December 4-5, 2014

Building Technologies Office

Energy Efficiency & Renewable Energy

Department of Energy

Energy Conservation Standards 

for Commercial and Industrial 

Fans
2 

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
3 

Introduction and Rulemaking Background

• Title III of the Energy Policy and Conservation Act of 1975 (42 U.S.C.6291, et seq;

“EPCA”), Pub. L. 94-163, sets forth a variety of provisions designed to improve 

energy efficiency. Part C of title III, which for editorial reasons was re-designated 

as Part A-1 upon incorporation into the U.S. Code (42 U.S.C. 6311–6317, as 

codified), establishes the "Energy Conservation Program for Certain Industrial 

Equipment." These include commercial and industrial fans and blowers (42 U.S.C. 

6311(1)(H))

• On June 28, 2011, DOE published a Notice of Proposed Determination of 

Coverage (76 FR 37678)

• On February 1, 2013, DOE published a notice in the Federal Register that 

announced the availability of the “Commercial and Industrial Fans and Blowers 

Energy Conservation Standard Framework Document.” (78 FR 7304)

• On December 3, 2014, DOE issued a notice of data availability (NODA) for 

“Commercial and Industrial Fans and Blowers Energy Conservation Standard 

Framework Document” that announced the availability of five spreadsheets 

(http://energy.gov/sites/prod/files/2014/12/f19/fans_blowers_noda_0.pdf) 
4 

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
5 

Scope of the NODA 

• Scope of the analysis presented in the NODA

– Fan types included in analysis

• Axial Fans

• Centrifugal Fans 

• Inline and Mixed Flow Fans

• Radial Fans 

• Power Roof Ventilator Fans

– Fan types NOT included in analysis

• Safety Fans

• Cross Flow Fans

• Circulating Fans

• Induced Flow fans

• Air Curtains

– Scope limit 

• The fan has a maximum shaft input power of at least 1 horsepower (0.746 kW) but not 

greater than 200 horsepower (149 kW) at its maximum speed
6 

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
7 

Metric Used in the NODA

• Fan Energy Index (FEI) : Fan energy rating (FERSTD) of a fan that exactly meets the 

efficiency level analyzed divided by the FER of a given fan model (FER)

FFFFFF =

FFFFFFSSSSSS

FFFFFF

• Fan Energy Rating (FER), represents the electric input power to the fan over a 

specified load profile, at a given speed

FFFFFF = ∑ ωωiiPPii

iiii

ii 

 = ∑ ωωii( ii

PPoooooo,ii

ηηffffff,ii × ηηTT,ii

+ LLMM,ii) 

– Where

– Speed for FEI calculation is 850, 1150, 1750, or 3550 RPM depending on the fan’s 

operating speed range. 

• i = load points: 100%, 110% and 115% 

of flow at BEP

• ωi = weighting at each loading point 

(equal weighting)

• Pin

i = electric input power to the fan

• Pout,i = output airpower of the fan 

• ηfan,i = total fan efficiency 

• ηT,i = default transmission efficiency

• LM,i = default motor losses
8 

Metric Used in the NODA

• Fan Energy Rating for a fan that exactly meets the efficiency level being analyzed 

(FERSTD) is calculated based on the same equation, at the same specified speed 

FFFFFFSSSSSS = ∑ ωωiiPPii

iiii

ii 

 = ∑ ωωii( ii

PPoooooo,ii

ηηffffff, SSSSSS,ii × ηηTT,ii

+ LLMM,ii) 

– Where

• i = load points: 100%, 110% and 115% of flow at BEP

• ηηffff , SSSSSS,ii = total fan efficiency at load point i for a fan that exactly meets the 

efficiency level being analyzed

– Assumed

• ηηffff , SSSSSS,110% = 0.982 ηηffff , SSSSSS,100%

• ηηffff , SSSSSS,115% = 0.982 ηηffff , SSSSSS,100%

– Where

• ηηffff , SSSSSS,100% is calculated as a function of flow and total pressure based on a 

two-variable polynomial of second order
9 

Metric Used in the NODA

• The calculation of the ηηffff , SSSSSS,100% is based on the following equation for fan total efficiency at 

BEP and at 85 % maximum speed

ηηffff ff,SSSSSS,100% = CC + 10.2205 ∗ ln QQ + 2.8085 ∗ ln PP − 0.3932 ∗ ln QQ 2

+0.8530 ∗ ln QQ ∗ ln PP − 2.1379 ∗ ln PP 2 /100

• Where

– Q = flow at BEP at 85 percent maximum recommended speed in cubic feet per minute at 

60Hz

– P = total pressure at BEP at 85 percent maximum recommended speed in inches of water 

gauge at 60 Hz

– C = an intercept that is set for the surface, which is set based on the equipment type of the 

applicable fan model. The C-values are used to determine fan total efficiency corresponding 

to different market model cut-off levels

• In order to use a single 3D surface equation, fan laws are used to convert the flow and pressure 

information from the FEI calculation speed to 85% of the fan’s maximum speed 

• This “3-D surface” can be compared with AMCA’s PBER proposal and provides a relationship 

between efficiency as a function of flow and pressure
10

PBER Two-variable Polynomial “3D”

Calculated at BEP. The fan’s maximum speed is then 

set such as the fan meets the PBER and not as a 

function of the fan’s structural rigidity

Calculated at 100%, 110%, 115% of BEP flow and at 

the maximum speed corresponding to a motor pole 

configuration and included in the fan’s operating 

speed range (850, 1150, 1750, or 3550 RPM)

Calculated at design conditions. The fan’s operating 

region is set such as the fan meets the PBER

Comparison with PBER 

PBER “3D”

ηηffff = αα ×

QQ

QQ + ββ ×

PP

PP + γγ ηηffff ff,SSSSSS,100% = CC + aa ∗ ln QQ + bb ∗ ln PP + cc ∗ ln QQ 2

+dd ∗ ln QQ ∗ ln PP + ee ∗ ln PP 2 /100
11

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis 

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
12

Engineering Analysis Overview

Designate 

energy use 

levels for 

analysis

• Baseline

• Set not to cut off any models 

from the market

• Max Tech

• Fans are a mature technology 

with all available efficiency 

improvements already existing 

in the marketplace

• Intermediate energy use levels

Evaluate MPCs 

and 

manufacturer 

markups 

• Identify subgroups in each 

equipment group

• Calculated individually for each 

subgroup

•Weighted based on 

distribution of models in 

current market at each energy 

use level

Estimate 

aerodynamic 

redesign costs

• Evaluated for each subgroup, 

then aggregated by equipment 

group and energy use level

• Resulting conversion cost 

recovery markup included in 

standards-case MSP in 

downstream analysis

• Evaluate costs associated with increased efficiency
13

Energy Use Levels in PTE

• C-value (vertical offset) of PTE 

surface equation varies 

– Determined separately for each 

potential energy level and equipment 

group

– Based on cutting off fixed percentage of 

models using resulting FER

• Database of 2800 fans

• Cut-off percentages: 5, 10, 15, 20, 50 70

– FEI 5 = 5% of that group’s models cut off 

using that C-value 

– Example this slide: Axial Housed group

FEI (Cutoff %): Baseline* 5 10 15 20 50 70

Axial Housed C-Value - -18.6675 -15.3981 -13.562 -11.7859 -2.3139 3.6529

*Baseline is the C-value that removes 0 percent of the market. As such, there are no C-values associated with the baseline level. 

Axial Housed Peak Total Efficiency

Peak Total Efficiency
14

Manufacturer Production Cost Assessment Methodology

• Subgroups

– Equipment groups divided into subgroups based 

on impeller type or presence of guide vanes

• Teardowns 

– Physical Teardowns conducted on 5 units from 

4/26 subgroups

– Virtual Teardowns conducted on remaining 

subgroups 

• MPC as a function of impeller diameter 

– Estimated for one subgroup

– MPC multipliers calculated to adjust MPC 

function for other subgroups

Fan Group Subgroup

Centrifugal Housed Airfoil

Backward Curved

Backward Inclined

Forward Curved

Centrifugal Unhoused Airfoil

Backward Curved

Backward Inclined

Inline and Mixed Flow Mixed Flow - Airfoil

Mixed Flow - Single Thickness

Centrifugal Inline - Airfoil

Centrifugal Inline - Backward Curved

Centrifugal Inline - Backward Inclined

Centrifugal Inline - Forward Curved

Radial Open Radial

Radial Tip

Shrouded Radial

Backplate Radial

Power Roof Ventilator Centrifugal PRV - Airfoil

Centrifugal PRV - Backward Curved

Centrifugal PRV - Backward Inclined

Centrifugal PRV - Forward Curved

Axial PRV - Panel/Proppeller

Axial PRV - Tubeaxial

Axial Housed Vane Axial

Tube Axial

Axial Unhoused Panel/Propeller

Physical & 

Virtual 

Teardowns

Bills of 

Materials 

(BOMs)

Cost Model

CostEfficiency 

Relationship
15

Manufacturer Production Cost Assessment Methodology

Teardown results example

Raw Material Costs $222.34 Direct cost of raw materials

Purchased Parts Material Costs $139.87 Direct cost of purchased parts

Assembly Labor Cost $109.54 Component and unit assembly on manufacturing line

Fabrication Labor Cost $299.14 Conversion of raw material into parts ready for assembly

Supervision Cost $21.25 Fraction of indirect labor that is paid a higher wage

Indirect Labor Cost $141.88 Fraction of overall labor not associated directly with product manufacturing (e.g. 

forklift drivers, quality control)

Equipment Depreciation Cost $38.55 Straight line depreciation over expected equipment life

Tooling Depreciation Cost $3.56 Cost is allocated on a per-use basis or obsolescence, whichever is shorter

Building Depreciation Cost $25.40 Straight line depreciation over expected building life

Indirect Process Costs $35.24 Consumables including welding rods, lubrication on dies, etc., as well as paint and 

related processes

Maintenance Costs $21.48 Based on installed equipment and tooling investment

Utility Costs $8.35 A fixed fraction of all material costs meant to cover electricity and other utility 

costs

Property Tax $9.60 A fixed fraction based on total unit costs

Insurance $8.61 A fixed fraction based on total unit costs

Total $1,084.80
16

Manufacturer Production Cost Calculations

• Established relationship: 

MPC = Multiplier * (A * Diameter + Diameter ^ B)

– A = 18.92

– B = 2.10

• Multiplier calculation:

Adjusts MPC curve for each subgroup

– Calculation example, 

Centrifugal Unhoused – Backward Inclined:

• Diameter of Virtual Teardown: 20.5”

• Virtual teardown MPC: $581.60

• MPC from equation, at teardown diameter: 

$964.09

• Resulting multiplier: $581.60/$964.09 = 

0.603

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

0 10 20 30 40 50

MPC [$]

Diameter [in]

MPC Scaling as a Function of Diameter

MPC Fit, Centrifugal Housed Airfoil

MPC Fit Adjusted for Centrifugal Unhoused Backward Inclined

Teardown MPC, Centrifugal Housed Airfoil

Teardown MPC, Centrifugal Unhoused Backward Inclined

MPC = 1.00 * (18.92*D + D ^ 2.10)

MPC = 0.60 * (18.92*D + D ^ 2.10)
17

Manufacturer Production Cost Results

FEI 0 5 10 15 20 50 70

Centrifugal Housed

MWEIGHTED 0.77 0.80 0.83 0.86 0.88 0.97 0.98

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 244 714 1,429 254 742 1,485 263 769 1,538 271 793 1,587 279 815 1,631 305 893 1,787 309 905 1,810

Centrifugal Unhoused

MWEIGHTED 0.60 0.62 0.63 0.64 0.64 0.63 0.63

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 191 560 1,120 196 573 1,146 199 582 1,165 201 588 1,177 202 590 1,181 200 584 1,168 200 584 1,168

Inline and Mixed Flow

MWEIGHTED 0.90 0.90 0.90 0.90 0.90 0.95 0.96

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 283 829 1,658 284 829 1,659 284 831 1,663 284 832 1,664 286 837 1,674 299 875 1,751 305 892 1,786

Radial

MWEIGHTED 0.88 0.88 0.88 0.88 0.88 0.90 0.91

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 280 819 1,639 280 819 1,639 280 819 1,639 280 819 1,639 280 819 1,639 285 833 1,666 289 846 1,693

Power Roof Ventilator

MWEIGHTED 0.54 0.54 0.54 0.54 0.54 0.54 0.54

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 171 501 1,002 171 501 1,002 171 501 1,002 171 501 1,002 171 501 1,002 171 501 1,002 171 501 1,002

Axial Housed

MWEIGHTED 1.02 1.02 1.03 1.03 1.03 1.06 1.08

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 323 946 1,893 324 948 1,897 325 950 1,902 326 954 1,908 327 957 1,915 336 984 1,969 343 1,0032,007

Axial Unhoused

MWEIGHTED 0.2 0.2 0.2 0.2 0.2 0.2 0.2

Diameter [in] 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30 10 20 30

Example MPC [$] 62 181 361 62 181 361 62 181 361 62 181 361 62 181 361 62 181 361 62 181 361
18

Manufacturer Selling Price

• MSP = Manufacturer Markup * Conversion Cost Recovery Markup * MPC

– Conversion Cost Recovery Markup

• Product conversion costs 

– Modeled as being the same for all models regardless of size, performance, equipment 

group, or efficiency

– Calculated with the following assumptions

» 6 month total redesign time

» 4 month testing time

» Additional costs for non-DOE certifications and marketing

» Labor rates based on information from the Bureau of Labor and Statistics

• Capital conversion costs

– Modeled as different for each subgroup, but not varying with size, performance, or 

efficiency

– Assumptions made regarding manufacturing investments in tooling and fabrication 

equipment
19

Industry Conversion Costs

• Total industry conversion costs by equipment class

– Determined at each efficiency level by the number of individual models (from the database of 

2800 fans) that would be cut off in that equipment group at that level, with the following 

assumptions:

• All fans that did not meet the level would be redesigned to the efficiency level being analyzed

• The conversion costs varied only by the subgroup of the resulting model

• The redesigned models would be distributed in the subgroups within each class in the proportions of 

the subgroups between that efficiency level and the next in the base case (the database of 2800 

fans)

– Example: If 100 models were cut off at housed axial FEI 5, all of them were assumed to be redesigned to meet 

FEI 5. If, in the base case, 30% of the housed axial fans between FEI 5 and FEI 10 were vane axial and 70% were 

tube axial, then the assumption is that 30 fans would be aerodynamically redesigned to be vane axial and 70 to 

be tube axial regardless of the subgroups of the fans that were cut off
20

Conversion Cost Results

• The resulting total industry conversion costs are presented in the table below

– Assumption: the database of 2800 fans represents all models on the market in the scope of the rulemaking

Equipment Class Total Conversion Cost for Each Equipment Class at Each Efficiency Level 

FEI 0 FEI 5 FEI 10 FEI 15 FEI 20 FEI 50 FEI 70

Axial Housed $0 $2,608,515 $5,243,409 $7,898,257 $10,567,382 $26,638,238 $37,330,712

Axial Unhoused $0 $246,023 $492,045 $861,079 $1,107,102 $2,829,261 $3,936,363

Centrifugal Housed $0 $5,180,826 $10,305,247 $15,404,738 $20,504,842 $51,226,800 $72,511,767

Centrifugal Unhoused $0 $896,348 $1,808,992 $2,726,521 $3,639,041 $9,648,905 $13,421,612

Inline and Mixed Flow $0 $2,057,357 $4,123,137 $6,179,841 $8,457,972 $20,913,841 $29,002,399

Radial $0 $2,041,988 $4,083,976 $6,125,964 $8,167,953 $20,419,881 $28,448,452

Power Roof/Wall Ventilators $0 $1,291,619 $2,583,238 $3,874,857 $5,166,476 $12,916,190 $18,082,666
21

Engineering Analysis Outputs

• The following three results were passed on to the downstream analyses:

– Database of 2800 fans each with an FER, diameter (and thus base-case MSP), and equipment group

– Base case MSP (MSP = MPC * MM) by equipment group and efficiency level

– Total industry conversion costs by equipment group and efficiency level

• The conversion cost recovery markup was calculated as part of the LCC

– Same approach as used in pumps
22

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
23

Manufacturer Impact Analysis: Overview

• An MIA was performed on all manufacturers of covered CIFBs.

• Two markup scenarios were modeled to capture the range of potential outcomes 

manufacturers may experience following the implementation of energy conservation 

standards on CIFBs.

• Conversion Cost Pass Through Markup Scenario (Upper Bound)

- In this scenario, manufacturers are able to increase their prices of remodeled CIFBs 

to fully recover the conversion costs associated with remodeling, testing, and 

certifying those CIFBs.

- This markup scenario represents the upper bound of profitability for manufacturers 

since they are able to fully recover all of their conversion costs.

• Flat Markup Scenario (Lower Bound)

- In this scenario, manufacturers are not able to increase their prices at all following 

energy conservation standards on CIFBs.

- This markup scenario represents the lower bound of profitability for manufacturers 

since they are not able to recover any of their conversion costs.
24

Manufacturer Impact Analysis: Results (Table)

• INPV Results for the Conversion Cost Pass Through Markup Scenario (Upper Bound)

* Numbers in parentheses represent negative values.

• INPV Results for the Flat Markup Scenario (Lower Bound)

FEI 0 FEI 5 FEI 10 FEI 15 FEI 20 FEI 50 FEI 70 

INPV (2013$ MM) 499.2 480.8 465.4 447.3 429.9 340.3 278.0 

Change in INPV

(2013$ MM) - (18.4) (33.7) (51.9) (69.2) (158.9) (221.2) 

Change in INPV (%) - (3.7) (6.8) (10.4) (13.9) (31.8) (44.3) 

FEI 0 FEI 5 FEI 10 FEI 15 FEI 20 FEI 50 FEI 70 

INPV (2013$ MM) 499.2 460.5 421.1 381.2 340.3 94.5 (79.5) 

Change in INPV

(2013$ MM) - (38.7) (78.0) (118.0) (158.8) (404.7) (578.6) 

Change in INPV (%) - (7.8) (15.6) (23.6) (31.8) (81.1) (115.9) 
25

Manufacturer Impact Analysis: Results (Graph)

• Potential INPV impacts of standards on CIFB manufacturers

-7.8%

-15.6%

-23.6%

-31.8%

-81.1%

-115.9%

-3.7% -6.8% -10.4%

-13.9%

-31.8%

-44.3%

-140%

-120%

-100%

-80%

-60%

-40%

-20%

0%

20%

Base Case FEI 5 FEI 10 FEI 15 FEI 20 FEI 50 FEI 70

% Change in INPV

Flat Markup Conversion Cost Pass Through Markup
26

Manufacturer Impact Analysis: Small Business

• There are approximately 93 small businesses that could be affected by potential CIFB 

energy conservation standards. 35 of these small businesses are AMCA members.

• Based on preliminary market research, DOE has determined that the average small 

manufacturer typically offers fewer CIFB models, ships fewer units, and generates less 

revenue per model than an average large CIFB manufacturer. This could put small 

businesses at a disadvantage because any conversion costs they may incur would have 

to be spread over fewer units and smaller annual revenues.

• Small manufacturers may also be at a disadvantage regarding potential CIFB energy 

conservation standards due to a lack of engineering resources and a lack of experience 

in designing higher efficiency equipment. 

• DOE found in an analysis of its CIFB product database that on average, a smaller 

percentage of small manufacturers’ product offerings meet each efficiency level 

compared to larger manufacturers. 
27

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
28

Life-Cycle Cost Calculation Overview

Baseline 

Manufacturer Cost

Engineering 

Analysis Std-Level 

Manufacturer Cost

Manufacturer 

Markup

Markups 

Analysis

Distributor & 

Contractor 

Markups

Sales Tax

Energy Use 

Analysis

Energy 

Consumption

Energy

Prices

Consumer

Price

Installation

Cost

Total

Installed Cost

Annual

Energy Cost

Repair

Cost

Maintenance

Cost

Annual

Operating Costs

Lifetime

Discount

Rate

Energy Price Trend

Lifetime Operating

Costs

Payback

Period

Life-Cycle

Cost
29

Operating Cost Calculation - Energy Use

• Energy Use Calculation and Inputs

– The annual unit energy consumption (kWh/yr) is calculated based on the 

following equation

UEC = ∆PPPP

ηfan ×η + LM × OOOOOOOOOOOOOO

– Operating hours

• Industrial sector: Data from 123 plant assessments 

• Commercial sector: Based on Energy Plus building simulation results

– Load and Load profile

•Load is defined as the operating flow divided by the flow at BEP at a given 

operating speed

•Used a single average annual load point 

– Speed: used four representative speeds (850, 1150, 1750, and 3550 RPM) to 

model the operating speeds in the field
30

Operating Cost Calculation - Energy Use

• Set of representative units at 850 RPM for a given fan group (example) Pressure @ BEP

Flow @ BEP

Fan Group #1 @ 850 RPM Representative 

Unit Represents the 

“average” of all 

catalog models ( ) 

in each Power x 

Flow bin in terms 

of diameter, flow 

and pressure at 

BEP, fan curve and 

efficiency curve.

Weighted by 

shipments based on 

the AMCA sales data
31

Operating Cost Calculation - Energy Use

• Average annual energy use by fan group for each considered standards case 

(kWh) 

Fan Group EL 0 EL 1 EL 2 EL 3 EL 4 EL 5 EL 6

Axial Housed 45,008 44,923 44,814 44,704 44,501 42,828 41,031 

Axial Unhoused 15,598 15,597 15,597 15,594 15,592 15,438 15,050 

Centrifugal Housed 68,839 68,802 68,713 68,554 68,406 66,945 65,754 

Centrifugal 

Unhoused 33,256 33,219 33,156 33,126 33,064 32,305 31,864 

Inline and Mixed 

Flow 23,312 23,300 23,259 23,227 23,197 22,807 22,402 

Radial 49,346 49,182 48,892 48,555 48,232 46,369 43,936 

Power Roof 

Ventilator 10,860 10,852 10,833 10,796 10,755 10,477 10,007 
32

Additional inputs to the Operating Cost Calculation

• Lifetimes

• Discount Rates

• Electricity Price and Electricity Price trend

– Derived from AEO 2014 (commercial and industrial prices)

Fan Group Lifetime Mechanical Lifetime Hours of Operation

Axial Housed 28.8 163,281 6,428 

Axial Unhoused 28.3 171,073 6,513 

Centrifugal Housed 27.3 176,243 6,721 

Centrifugal Unhoused 27.3 175,895 6,722 

Inline and Mixed Flow 27.3 176,160 6,720 

Radial 30.4 159,782 6,016 

PRV 29.7 162,231 6,221 

Sector Mean Standard Deviation

Commercial 5.1 % 1.3 %

Industrial 5.2 % 1.2 %
33

Total Installed Costs Calculation

• The equipment prices are calculated both for baseline and higher efficiency equipment by 

applying markups to manufacturer selling price.

• Three main distribution channels (percentage units sold) :

• Distribution Channel markups:

– Overall baseline markup: MMMMOOOOOOOOOOOOOO_BB = 1.73 

– Overall incremental markup: MMMMOOOOOOOOOOOOOO_IIIIII = 1.51

Equipment Classes Manufacturer -> OEM -> 

Distributor -> User 

Manufacturer -> Distributor -

> Contractor -> User 

Manufacturer -> Distributor -

> User 

Axial Housed 47% 27% 26% 

Axial Unhoused 34% 57% 9% 

Centrifugal Housed 32% 23% 45% 

Centrifugal Unhoused 40% 6% 54% 

Inline and Mixed Flow 8% 85% 7% 

Radial 5% 3% 92% 

Power Roof Ventilator 5% 89% 6% 

 Total 28% 43% 29% 
34

Total Installed Costs Calculation

• Base-case equipment price calculation

BB = MMMM BB × MMMMOOOOOOOOOOOOOO_BB

• Standards-case equipment price calculation without inclusion of conversion costs

SSSSSS, nn = MMMM BB × MMMMOOOOOOOOOOOOOO_BB + ∆MMMM BB × MMMMOOOOOOOOOOOOOO_IIIIII

• Adding the conversion costs: 

– All consumers with a fan that would not meet the efficiency level considered would purchase 

a redesigned fan at a higher cost. 

– Manufacturers recover the total conversion costs at each efficiency level

• Calculation of the conversion markup (across all bins within an fan group)

MMMM , = 

TT TT EEEE+ TT TT RRRRRR RRRR FF FF,EEEE

TT TT RRRRRR RRRR FF FF,EEEE

 

• Calculation of the standards-case equipment price (within one bin)

SSSSSS = 

BBBBBB RR × MMMM , − BBBBBB RR PP ,

BBBBBB UU FF ,
35

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Axial Housed Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 4,766 3,258 46,954 51,721 -- 28.8

- 1 4,813 3,252 46,865 51,678 7.6 28.8

- 2 4,858 3,244 46,752 51,610 6.6 28.8

- 3 4,900 3,236 46,637 51,537 6.1 28.8

- 4 4,946 3,221 46,427 51,374 4.9 28.8

- 5 5,283 3,100 44,699 49,982 3.3 28.8

- 6 5,539 2,970 42,846 48,385 2.7 28.8

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 1.9 43

- 2 5.8 111

- 3 6.3 184

- 4 6.0 347

- 5 14.0 1,738

- 6 16.3 3,336

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Axial Housed Fans
36

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Axial Unhoused Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 1,207 1,676 23,770 24,976 -- 28.3

- 1 1,207 1,676 23,769 24,976 4.9 28.3

- 2 1,207 1,676 23,768 24,975 5.7 28.3

- 3 1,208 1,676 23,764 24,972 3.0 28.3

- 4 1,208 1,676 23,760 24,968 2.0 28.3

- 5 1,210 1,659 23,528 24,738 0.2 28.3

- 6 1,211 1,617 22,938 24,150 0.1 28.3

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 0.0 0.6

- 2 0.9 0.9

- 3 0.2 4 

- 4 0.3 8 

- 5 0.0 239

- 6 0.0 826

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Axial Unhoused Fans
37

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Centrifugal Housed Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 2,131 6,697 94,878 97,009 -- 27.3

- 1 2,172 6,693 94,820 96,992 10.1 27.3

- 2 2,226 6,685 94,694 96,920 7.4 27.3

- 3 2,273 6,669 94,467 96,740 4.9 27.3

- 4 2,324 6,654 94,257 96,581 4.4 27.3

- 5 2,654 6,512 92,228 94,882 2.8 27.3

- 6 2,870 6,396 90,596 93,467 2.5 27.3

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 3.6 17

- 2 3.1 89

- 3 5.0 269

- 4 7.2 428

- 5 17.4 2,127

- 6 19.9 3,543

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Centrifugal Housed Fans
38

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Centrifugal Unhoused Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 1,678 3,495 49,652 51,330 -- 27.3

- 1 1,684 3,491 49,596 51,281 1.6 27.3

- 2 1,693 3,484 49,500 51,193 1.4 27.3

- 3 1,703 3,481 49,453 51,156 1.8 27.3

- 4 1,710 3,474 49,358 51,068 1.6 27.3

- 5 1,740 3,395 48,229 49,969 0.6 27.3

- 6 1,765 3,349 47,574 49,338 0.6 27.3

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 0.1 49

- 2 0.7 137

- 3 0.7 174

- 4 0.4 262

- 5 0.4 1,361

- 6 5.7 1,992

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Centrifugal Unhoused Fans
39

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Inline and Mixed Flow Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 2,206 2,436 34,710 36,915 -- 27.3

- 1 2,231 2,435 34,693 36,924 21.6 27.3

- 2 2,261 2,430 34,632 36,894 9.9 27.3

- 3 2,288 2,427 34,585 36,872 9.0 27.3

- 4 2,321 2,424 34,541 36,861 9.4 27.3

- 5 2,542 2,383 33,965 36,507 6.4 27.3

- 6 2,709 2,341 33,362 36,071 5.3 27.3

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 3.9 (8.7)

- 2 5.2 22 

- 3 6.4 43 

- 4 8.5 54 

- 5 25.3 409 

- 6 29.8 845 

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Inline and Mixed Flow Fans
40

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Radial Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 1,550 3,581 52,081 53,631 -- 30.4

- 1 1,581 3,569 51,899 53,480 2.6 30.4

- 2 1,610 3,548 51,574 53,184 1.8 30.4

- 3 1,640 3,523 51,213 52,853 1.6 30.4

- 4 1,670 3,500 50,873 52,544 1.5 30.4

- 5 1,856 3,365 48,921 50,777 1.4 30.4

- 6 1,999 3,189 46,368 48,367 1.2 30.4

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 0.6 151

- 2 2.4 447

- 3 5.3 778

- 4 3.1 1,087

- 5 7.5 2,854

- 6 10.8 5,264

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Radial Fans
41

Life Cycle Cost and Payback Period Analysis

• Average LCC and PBP Results for each Standards Case for Power Roof Ventilator Fans

TSL Efficiency 

Level

Average Costs 

(2013$) Simple Payback

years

 

Average 

Lifetime

years

Installed Cost

First Year’s 

Operating Cost

Lifetime 

Operating Cost

LCC

Base Case 1,523 1,166 16,382 17,904 -- 29.7

- 1 1,529 1,165 16,370 17,900 8.4 29.7

- 2 1,537 1,163 16,340 17,877 4.8 29.7

- 3 1,543 1,159 16,285 17,828 3.0 29.7

- 4 1,551 1,155 16,223 17,773 2.5 29.7

- 5 1,593 1,125 15,805 17,398 1.7 29.7

- 6 1,621 1,074 15,098 16,719 1.1 29.7

Note: The results for each TSL are calculated considering all customers. The PBP is measured relative to the base case

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Customers that 

Experience

Net Cost

Average Savings*

(2013$)

- 1 0.6 4.7

- 2 2.3 28

- 3 1.8 77

- 4 2.1 131

- 5 6.3 506

- 6 2.7 1,185

* The calculation includes customers with zero LCC savings (no impact)

• LCC Savings Relative to the Base Case Efficiency Distribution for Power Roof Ventilator Fans
42

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis

8. Requests for Comments
43

Shipments and National Impact Analysis

• Shipments

– Projections based on the following indicators, depending on the market segment:

• Industrial sector: Fixed investments in equipment and structures including 

fans (0.32 percent compound annual growth rate)* 

• Commercial sector, new buildings: AEO new commercial floor space index 

(1.81 percent compound annual growth rate)*

• Commercial sector, existing buildings: Fixed investments in existing structures 

including fans (2.14 percent compound annual growth rate)*

– This resulted in an aggregate compound annual growth rate of 1.64 percent * 

*Compound annual growth rate over 2013-2048
44

National Full Fuel-Cycle Energy Savings (quads)

Fan Group EL 1 EL 2 EL 3 EL 4 EL 5 EL 6*

Axial Housed 0.02 0.1 0.1 0.1 0.6 1.1 

Axial Unhoused 0.00 0.00 0.00 0.01 0.2 0.8 

Centrifugal 

Housed 0.03 0.1 0.2 0.3 1.5 2.5 

Centrifugal 

Unhoused 0.02 0.1 0.1 0.1 0.5 0.8 

Inline and Mixed 

Flow 0.00 0.01 0.02 0.03 0.1 0.2 

Radial 0.1 0.2 0.3 0.5 1.3 2.4 

Power Roof 

Ventilator 0.01 0.0 0.1 0.1 0.3 0.7 

Total 0.2 0.4 0.8 1.2 4.6 8.4

Shipments and National Impact Analysis

• National Full Fuel-Cycle Energy Savings (quads)

** EL 1, 2, 3, 4, 5, and 6 correspond to cutting off 5, 10, 15, 20, 50, and 70 % of 

models, respectively 
45

Shipments and National Impact Analysis

Fan Group Discount 

Rate (%) EL 1 EL 2 EL 3 EL 4 EL 5 EL 6**

Axial Housed

3 0.07 0.17 0.28 0.49 2.27 4.24 

7 0.02 0.05 0.08 0.15 0.72 1.36 

Axial Unhoused

3 0.003 0.004 0.02 0.04 0.97 3.33 

7 0.001 0.001 0.01 0.01 0.33 1.14 

Centrifugal 

Housed

3 0.06 0.27 0.75 1.18 5.77 9.60 

7 0.01 0.06 0.22 0.35 1.83 3.10 

Centrifugal 

Unhoused 

3 0.09 0.23 0.29 0.44 2.29 3.36 

7 0.03 0.08 0.10 0.15 0.79 1.15 

Inline and Mixed 

Flow

3 (0.003) 0.03 0.05 0.06 0.38 0.74 

7 (0.004) 0.00 0.01 0.01 0.10 0.20 

Radial

3 0.28 0.79 1.39 1.96 5.23 9.61 

7 0.09 0.25 0.45 0.64 1.71 3.16 

Power Roof 

Ventilator

3 0.01 0.07 0.18 0.30 1.16 2.68 

7 0.003 0.02 0.05 0.09 0.37 0.88 

Total

3 0.5 1.6 3.0 4.5 18.1 33.6 

7 0.1 0.5 0.9 1.4 5.8 11.0 

* Note: Parentheses indicate negative values

• NPV of Consumer Benefits by Equipment Class (billion 2013$)* 

** EL 1, 2, 3, 4, 5, and 6 correspond to cutting off 5, 10, 15, 20, 50, and 70 % of 

models, respectively 
46

Topics

1. Introduction and Rulemaking Background

2. Scope of the NODA 

3. Metric Used in the NODA

4. Engineering Analysis

5. Manufacturer Impact Analysis

6. Life Cycle Cost and Payback Period Analysis 

7. National Impact Analysis 

8. Requests for Comments
47

Requests for Comment - 1 

1. DOE generated formulae for manufacturer production cost (MPC) as a function of subgroup and diameter 

(which DOE believes can be used as a general proxy for airflow). DOE requests comments on whether there are 

any other parameters, such as pressure, construction class, rating RPM, etc., which DOE should use as inputs in 

calculating the MPC, in addition to or instead of diameter. If so, DOE encourages stakeholders to submit data 

illustrating the relationship of MPC with these parameters.

2. DOE assumed that the cost to redesign multiple fan models was equal to the number of models times an 

estimated cost to redesign one fan model. DOE recognizes that manufacturers may be able to share resources 

between redesigns in the same company, or in the same product line (i.e. different diameters). If this is current 

practice or possible, DOE requests comments on the scenarios in which resource sharing can occur and to 

what extent.

3. DOE estimated the cost to redesign a fan as a function of the subgroup of fan resulting from the redesign. 

There may be other parameters, such as the fan’s diameter, RPM properties, FEI or efficiency, or construction 

class, or the properties of the fan before it was redesigned, that DOE should take into consideration. If so, DOE 

requests information on which parameters should be taken into consideration and how each affects the cost to 

redesign a fan.

4. DOE used a redesign time of 6 months per fan model in its calculation of redesign costs. DOE requests 

comment on this assumption and whether this time period is sufficient for prototyping and the revision of 

marketing materials. 
48

Requests for Comment - 2 

5. DOE did not explicitly consider fan noise performance in its analyses. DOE requests comment on whether 

noise considerations provide barriers to increased fan efficiencyas testedor as analyzed.

6. DOE requests information on the number of models and number of shipments of forward curved fans..

7. DOE requests comment on its use of a database of over 2500 fan models as approximately representing all fan 

models in the scope of this rulemaking currently available in the United States today.

8. DOE used current subgroup distributions of fan models within each fan group at each efficiency level analyzed 

to weight the total conversion cost per model regardless of the efficiency level or the subclass of the fan model 

before redesign. In other words, DOE assumed that fan model impeller distributions at a given efficiency level 

would not change as a result of standards. DOE requests comment on this assumption.

9. DOE requests comment on the inclusion of tubeaxial and vaneaxial fans into a single fan group separate from 

centrifugal inline and mixed flow fans. DOE requests information regarding whether these two groups of fans 

provide distinct utility that justifies the separation and resulting different FEIs for the same rated flow and 

pressure.

10. DOE requests comment on the cost drivers included in the engineering analysis (i.e. aerodynamic redesign, 

impeller type, and presence of guidevanes).
49

Requests for Comment - 3 

11. DOE requests information on the design and manufacturing differences between commercial and industrial 

fans.

12. DOE requests information on how forward curved impeller manufacturing differs from the manufacturing of 

other impeller types. DOE also requests comment on how other fan components differ between forward 

curved models and non-forward curved models, such as component materials and material gauges.

13. DOE requests comment on its MPC as a function of diameter equation and multipliers.

14. DOE did not consider variable pitch blades in its analysis. DOE requests information on the effect variable-pitch 

blades have on efficiency in the field, the mechanism of that effect, and how testing can be conducted to 

capture any benefit from variable-pitch blades.

15. DOE requests comment on any of the industry financials (working capital rate; net property, plant, and 

equipment rate; selling, general, and administrative expense rate; research and development rate; 

depreciation rate; capital expenditure rate, and tax rate) used in the GRIM (located in the “Financials” tab of 

the GRIM spreadsheet).
50

Requests for Comment - 4 

16. DOE requests comment on the use of 11.4 percent as the real industry manufacturer discount rate (also 

referred to as the weighted average cost of capital) for commercial and industrial fan manufacturers (located in 

the “Financials” tab of the GRIM spreadsheet).

17. DOE requests comment on the use of 1.45 as a manufacturer markup (this corresponds to a 31 percent gross 

margin) for all fan groups and efficiency levels in the base-case (located in the “Markups” tab of the GRIM 

spreadsheet). DOE requests information regarding manufacturer markups and whether they vary by fan 

efficiency, fan group, fan subgroup, or any other attribute.

18. DOE requests comment on both its methodology of calculating total industry capital and product conversion 

costs and the specific industry average per model capital and product conversion cost estimates for each fan 

subgroup (located in the Conversion Cost spreadsheet).

19. DOE assumed that every fan model that did not meet a candidate standard level being analyzed would be 

redesigned to meet that level. DOE requests comment on this assumption and on what portion of fan models 

that do not meet a standard level would be redesigned to meet the level versus dropped from the American 

market. 

20. DOE seeks inputs on its characterization of market channels for the considered fan groups, particularly related 

to whether the channels include all intermediate steps, and estimated market shares of each channel. 
51

Requests for Comment - 5 

21. DOE seeks inputs and comments on the estimates of flow operating points used in the energy use analysis 

(expressed as a function of the flow at best efficiency point).

22. DOE seeks inputs and comments on the estimates of annual operating hours by sector and application and on 

the estimated distributions of fans across sectors and applications.

23. DOE seeks comments on its proposal to use a constant price trend for projecting future commercial and 

industrial fan prices.

24. DOE requests comment on whether any of the efficiency levels considered in this analysis might lead to an 

increase in installation, repair, and maintenance costs, and if so, data regarding the magnitude of the increased 

cost for each relevant efficiency level.

25. DOE seeks comments on the proposal to use a compliance year of three years after the publication of the final 

rule.

26. DOE seeks comments on the use of constant efficiency trends in the base-case and in the standards-cases.