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MEMORANDUM

TO: DOE Office of General Counsel

FROM: Doug Smith

DATE: August 2 9 , 2013

RE: Record of Communication Concerning Ceiling Fan and Ceiling Fan Light Kit

Framework Document

— Docket No. EERE

- 2012

- BT

- STD

- 0045

This memo pr ovides an overview of communications made to DOE staff on the subject of

possible changes to standards and test procedures for ceiling fans and ceiling fan light kits. The

communications occurred at a meeting held at 10:30 a

. m

. on August 20, 2013, followi ng the

close of the comment period on the initial framework document for ceiling fans and light kits.

The meeting attendees included:

John Cymbalsky (DOE/EERE)

Lucy deButts (DOE/EERE)

Eric Stas (DOE/OGC)

Francine Pinto (DOE/OGC)

Aris Marantan (Navigant )

Tom Early (Burgess Lighting and Distributing)

Dave Turner (Casablanca Fan Company/Hunter Fan Co.)

Jeremy Tarr (Casablanca Fan Company/Hunter Fan Co.)

Bill Walker (Casablanca Fan Company/Hunter Fan Co.)

Rob Godlewski (Emerson Ceiling Fans)

Nathan Frampton (Fanimation)

Doreen Edelman (Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, for Hunter)

Tony Davidson (Kichler Lighting)

Tim Flannery (Minka Group)

Clark Linstone (Pacific Coast Lighting, Inc.)

Ed Kolb (Quorum)

David Gatto (Westinghouse Lighting Corp oration)

Richard Upton (American Lighting Association)

Terry McGowan (American Lighting Association)

Doug Smith (Van Ness Feldman, LLP, for ALA)- 2

- A group of 2 5 ceiling fan and light kit manufacturers, distributors and retailers (list attached),

organized b y the American Lighting Association (ALA ), filed timely written comments on issues

raised in the Framework Document. The companies in this group represent more than 90% of

the annual U.S. sales of ceiling fans and ceiling fan light kits. Th is meeting was used to

elaborate on issues raised in th e group’s written comments. The agenda for the meeting is

attached. Key points made at the meeting included:

- Many of the ceiling fan technology options identified in the Framework Document

present significant tec hnical, consumer utility, and/or cost problems. DC motors and

associated electronic controls, for instance, present reliability issues and have high first

costs that are very unlikely to be paid back in energy savings for typical consumers. A

number of t he technology options would create consumer utility problems, such as

occupancy sensors incorrectly turning off a fan in bedrooms whe n occupants are asleep.

- Ceiling fans are often used in conjunction with air conditioning in homes . DOE needs to

take this effect i nto account in evaluating energy savings from any new fan standard,

especially if increased first costs for fans drive down fan sales and thereby result in

increased AC usage. More research is needed on this AC offset effect

.

- The primary driver of light fixture efficiency is the lamp, not the light kit. Lamp

efficiency is comprehensively regulated by DOE . Further light kit standards are not

appropriate.

- For light kits with 3 or fewer candelabra sockets, or 4 or fewer intermediate base sockets,

there is no need for the power limiter requirement given lamp efficiency standards. The

limiter itself is a source of product failure and an added cost to consumers , so the existing

requirement for a limiter should be eliminated for light kits with these configurations.

- Test procedures that cover fan operation at low, medium, and high speed, such as the

existing test procedure, are appropriate. If a single r ating value is to be determined based

on efficiency at three speeds, DOE will need to specify consumer usage fact ors. The

AccuPoll data submitted by ALA provides a basis for consumer usage factors of: 29% on

low; 51% on medium; and 21% on high.

Attachment s15 August 2013 Prepared By:

The American Lighting Association 

### ROSTER

ALA

‐ Industry Coalition

Of

Ceiling Fan Manufacturers

And Retailers

Responding To

The DOE’s Evaluation of Potential New Energy Efficiency Requirements

For

Ceiling Fans and Ceiling Fan Light Kits

Air Cool International, Ltd. Luminance

American Lighting Association Matthews Fan Company & WPT Design

Canarm Ltd. Maxim Lighting International

Casablanca Fan Company /Hunter Fan Co. Minka Group

Emerson Ceiling Fans Pacific Coast Lighting, Inc.

Fanimation Progress Lighting, a Division of Hubbell

Feiss

‐ Monte Carlo Quorum International

Kendal Lighting Inc. Regency Ceiling Fans

Kichler Lighting Savoy House Lighting

King of Fans The Home Depot

Lamps Plus The Modern Fan Co.

Litex Industries Limited/Ellington

Fans/Craftmade Vaxcel International

Lowe's Companies, Inc. Westinghouse Lighting Corporation

### DOE

- ALA

- Ceiling Fan Industry

Meeting Agenda

Tuesday, 20 August 2013

Time: 10:30 AM

- 1:00 PM

Location: 950 L’Enfant Plaza, #6162

Washington, D.C.

10:30 AM I. Meeting Called to Order

A. Introduction of DOE Attendees and Opening

Comments

B. Response and Introduction of ALA/Ceiling Fan

Industry Attendees John Cymbalsky

, Supervisor, Appliance

Standards, DOE

Dick Upton , ALA

10:37 AM

1 0:40 AM

10:45 AM

10:50 AM

1 1 : 0 5 AM

11:15 AM

11:25 AM

11: 40 AM

11:45 AM

11:50 AM

11:55 AM II. ALA Ceiling Fan Industry Comments and Presentation

A. Goals of the Meeting

B. K ey P oints

- CEILING FANS

1. Ceiling fan definition

2. Product classes

3. Technology option assessment

a. Motors

b. Blade design

c. Occupancy sensors

4. Residential energy consumption

– offsetting

changes in AC usage

C. Key P oints

- LIGHT KITS

1. Primary efficiency driver is the lamp (not the

light kit)

2. LEDs

3. Power limiters

4. Utilization/consumer wants and needs Clark Linstone , Chair

ALA Gov. Affairs

D ave Turner

, Casablanca/Hunter

Terry McGowan

,

ALA

T. McGowan/

D. Turner

Dave Gatto

, Westinghouse

12:05 PM

12: 10

12: 1 5 D. Test Procedures

E. Legal Issues

F. Flexibility to Defer the R ulemaking Bill Walker

, Casablanca/Hunter

Doug Smith

, Van Ness Feldman

Jeremy Tarr

, Casablanca/Hunter

12:30 PM III. Responding to DOE Questions Not Already Discussed D. Upton

12:40 PM IV. DOE’s View of Areas Where More Study/Data is Needed

A. The Framework Document

B. Points made by the Industry today C. LinstoneDOE, ALA, Ceiling Fan Industry Meeting

20 August 2013

2

12:47 PM

12:50 PM V. Close

A. For DOE

B. For the Industry J. Cymbalsky

D. Upton

12:55/1:00 P M VI. Anticipated Adjournment