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1 U.S. DEPARTMENT OF ENERGY 

2 

3 

4 

5 Public Meeting on Test Procedure Notice 

6 Of Proposed Rulemaking and Energy Conservation 

7 Standards Preliminary Analysis for Ceiling Fans 

8 

9 

10 

11 

12 

13 9:13 a.m. to 4:00 p.m. 

14 Wednesday, November 19, 2014 

15 

16 U.S. Department of Energy 

17 1000 Independence Avenue, SW 

18 Room 8E-089 

19 Washington, D.C. 

20 

21 

22 
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1 ATTENDEES: 

2 

3 Facilitator: 

4 DOUGLAS BROOKMAN, Public Solutions 

5 

6 Department of Energy: 

7 JOHN CYMBALSKY 

8 LUCY DEBUTTS 

9 JENNIFER TIEDEMAN 

10 STEVE GOERING 

11 LAURA BARHYDT 

12 JOANN MILLIKEN 

13 

14 Industry Representatives: 

15 CHRISTIAN TABER, Big Ass Fans 

16 JANIE WISE, Cassidy & Associates 

17 VAN SMITH, Van Ness Feldman LLP 

18 DAVE GATTO, Westinghouse Lighting 

19 MARIANNE DIMASCIO, ASAP 

20 CHUCK MATTHEWS, Matthews Fan Company 

21 TIM FLANNERY, The Minka Group 

22 NATHAN FRAMPTON, Fanimation 
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1 ATTENDEES (continued): 

2 

3 Industry Representatives (continued): 

4 DONALD BRUNDAGE, Southern Company 

5 ALLEN ROO, Emerson Electric Company 

6 BILL WALKER, Hunter Fan Company 

7 DAVID TURNER, Hunter Fan Company 

8 CLARK LINSTONE, Lamps Plus 

9 RICHARD UPTON, American Lighting Association 

10 ALEX BOESENBERG, National Electrical 

11 Manufacturers Association 

12 

13 Consultants: 

14 MOHAN GANESHALINGAM, Lawrence Berkeley 

15 National Laboratory 

16 COLEEN KANTNER, Lawrence Berkeley National 

17 Laboratory 

18 SAMUEL JASINSKI, Navigant 

19 ARIS MARANTAN, Navigant 

20 MYTHRI KUMAR, Navigant 

21 JULIE PIERCE, Navigant 

22 
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1 ATTENDEES (continued): 

2 

3 Also attending: 

4 KENT MATHIS, HKC 

5 TERRY MCGOWAN, American Lighting Association 

6 MICHAEL WEEMS, American Lighting Association 

7 SARAH MEDEPALLI, ICF International, on behalf 

8 Of Energy Star 

9 HAMPTON NEWSOME, Federal Trade Commission 

10 ELIZABETH NOLL, National Resources 

11 Defense Council 

12 LOUIS-BENOIT DESROCHES, Lawrence Berkeley 

13 National Laboratory 

14 

15 

16 

17 

18 

19 

20 

21 

22 
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1 C O N T E N T S 

2 PAGE 

3 MORNING SESSION 6 

4 AFTERNOON SESSION 168 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 
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1 P R O C E E D I N G S 

2 Morning Session 

3 MR. BROOKMAN: So, let's start. Please 

4 take your seats. 

5 Good morning, everyone. Welcome. This 

6 is the U.S. Department of Energy's Public Meeting 

7 on Test Procedure Notice of Proposed Rulemaking 

8 and Energy Conservation Standards Preliminary 

9 Analysis for Ceiling Fans. Today is Wednesday, 

10 November 19, 2014, here in the Forrestal Building 

11 in Washington, D.C. My name is Doug Brookman, 

12 Public Solutions. Glad to see you all this 

13 morning. We're going to start with welcoming 

14 remarks from John Cymbalsky. 

15 MR. CYMBALSKY: Thank you, Doug. Good 

16 morning, everyone. Welcome to the Public Meeting 

17 for Ceiling Fans. A lot of familiar faces from 

18 yesterday, for the light kits. For those of you 

19 who were here yesterday, some of this material 

20 will be a little repetitive, unfortunately, but 

21 we do have a lot of new faces in the room, so 

22 we'll have to actually cover the same ground with 
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1 ceiling fans that we did with light kits 

2 yesterday, but I have a feeling today will be a 

3 little more lively than yesterday -- not to say 

4 yesterday wasn't lively. I thought we had a 

5 great discussion and appreciate all the good 

6 comments we received. 

7 As always, we will record your oral 

8 comments here at the meeting, but, again, please 

9 follow up with written comments for the record. 

10 We appreciate a good, lively discussion today. I 

11 know there are at least two or three issues I can 

12 think of that should spark a good conversation 

13 today, so thanks for coming. 

14 MR. BROOKMAN: Okay. We always start 

15 with introductions. I'm going to start to my 

16 immediate left. You can get used to turning 

17 these microphones both on and off; the little 

18 green light illuminates. Name and organizational 

19 affiliation, and we'll go down the desk. 

20 MR. TABER: Christian Taber, Big Ass 

21 Solutions. 

22 MS. WISE: Janie Wise, Big Ass Solutions. 
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1 MR. SMITH: Van Smith, Van Ness Feldman 

2 LLP. 

3 MR. BOESENBERG: Alex Boesenberg, 

4 National Electrical Manufacturers Association. 

5 MR. GATTO: Dave Gatto, Westinghouse 

6 Lighting. 

7 MS. DIMASCIO: Marianna DiMascio, 

8 Appliance Standards Awareness Project. 

9 MR. MATTHEWS: Chuck Matthews, Matthews 

10 Fan Company. 

11 MR. FLANNERY: Tim Flannery, the Minka 

12 Group. 

13 MR. FRAMPTON: Nathan Frampton, 

14 Fanimation. 

15 MR. BRUNDAGE: Don Brundage, Southern 

16 Company. 

17 MR. ROO: Allen Roo, Emerson Electric. 

18 MR. WALKER: Bill Walker, Hunter Fan. 

19 MR. TURNER: David Turner. Hunter Fan. 

20 MR. LINSTONE: Clark Linstone, Lamps 

21 Plus. 

22 MR. UPTON: Dick Upton, President of the 
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1 American Lighting Association. 

2 MS. TIEDEMAN: Jennifer Tiedeman, DOE. 

3 MR. CYMBALSKY: John Cymbalsky, DOE. 

4 MR. JASINSKI: Sam Jasinski, Navigant. 

5 MR. GANESHALINGAM: Mohan Ganeshalingam, 

6 Lawrence Berkeley National Labs. 

7 MR. MARANTAN: Aris Marantan, Navigant 

8 Consulting. 

9 MS. KUMAR: Mythri Kumar, Navigant 

10 Consulting. 

11 MS. KANTNER: Colleen Kantner, Lawrence 

12 Berkeley National Laboratory. 

13 MR. MCGOWAN: Terry McGowan, American 

14 Lighting Association. 

15 MR. WEEMS: Michael Weems, American 

16 Lighting Association. 

17 MR. MATHIS: Kent Mathis, HKC. 

18 MS. MEDEPALLI: Sarah Medepalli, ICF 

19 International, on behalf of Energy Star. 

20 MR. GOERING: Steve Goering, DOE. 

21 MS. BARHYDT: Laura Barhydt, DOE. 

22 MR. NEWSOME: Hampton Newsome, Federal 
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1 Trade Commission. 

2 MS. NOLL: Elizabeth Noll, NRDC. 

3 MS. MILLIKEN: JoAnn Milliken, DOE. 

4 MR. DESROCHES: Louis Desroches, Lawrence 

5 Berkeley National Laboratory. 

6 MS. DEBUTTS: Lucy deButts, DOE. 

7 MR. BROOKMAN: Thanks to all of you. I 

8 appreciate you being here this morning. All of 

9 you received a packet of information, I hope, as 

10 you entered the building this morning. I'm going 

11 to a very brief agenda review. Immediately 

12 following this agenda review there is an 

13 opportunity for opening remarks, brief summary 

14 statements here at the outset, about issues that 

15 matter to you, available to all that wish to do 

16 so. 

17 Moving from there, an examination of test 

18 procedure, regulatory history, and then 

19 rulemaking overview. Moving on, covered 

20 products, existing test procedure, proposed 

21 metric. We'll take a break midmorning, right 

22 about 10:30, or whenever we need it and get 
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1 there. 

2 Following that, the proposed test 

3 procedures, and then following that, description 

4 of the test procedure, closing remarks on the 

5 test procedure and NOPR. 

6 That might take us all the way to lunch. 

7 If we finish that at 11 o'clock, we'll probably 

8 take a break, but then we'll proceed with the 

9 second segment of this meeting today, which is to 

10 work on the energy conservation standards portion 

11 of the meeting. 

12 So, immediately when we get there, 

13 opening statements on the energy conservation 

14 standards regulatory history, rulemaking 

15 overview. Moving on from there, scope and 

16 technology assessment, screening analysis, 

17 engineering analysis. We'll take a break mid18 afternoon, around about 2:15, 2:30, or so. 

19 Following that, markups, energy use, life 

20 cycle cost analysis, shipments analysis, national 

21 impact analysis, preliminary manufacturer impact 

22 analysis, and then NOPR analyses. And, at the 
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1 end of the day, whenever we get there, whenever 

2 all this material has been covered, another 

3 opportunity for public comment, another 

4 opportunity for you to say things that need to be 

5 said, things that you don't think have been 

6 covered sufficiently. 

7 I ask for your consideration. Please 

8 speak one at a time. Yesterday everybody was 

9 quite disciplined about saying their name each 

10 time they spoke. I appreciate that. It's very 

11 helpful for developing the record. It really is 

12 very, very helpful, and then I don't have to 

13 remind folks as much. 

14 There will be a complete transcript of 

15 this meeting available. If you could please be 

16 concise with your comments, share the air time. 

17 There is a lot to be said today, I'm certain. If 

18 you haven't turned your cell phone on silent mode 

19 yet, please do so. 

20 Limit your sidebar conversations, and 

21 webinar participants, we welcome you. The 

22 Department of Energy is trying hard to make these 
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1 meetings totally accessible via the Web. Please 

2 keep your telephones on mute, and raise your 

3 hands to be recognized to speak, via the software 

4 provided. If you do so, we should be able to 

5 hear you here in the room, and we'll try and make 

6 that work. 

7 As I said, the Department is wanting to 

8 make these meetings totally accessible via the 

9 Web, and I would encourage all stakeholders to 

10 submit written comments, as John Cymbalsky did 

11 via the Web or here in the room. That would be 

12 very, very helpful to the department. 

13 So, I think we'll proceed with the test 

14 procedure content, as listed here. 

15 Oh, wait. First of all, we're going to 

16 do opening remarks, here, around the room. 

17 Opening statements? Yesterday we had a few. 

18 MR. UPTON: Dick Upton, President of the 

19 American Lighting Association. Doug, I think the 

20 best thing I can say is we appreciate our 

21 people's participation and we had a lot of help 

22 yesterday from Dave Gatto at Westinghouse because 
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1 of the nature of what we were discussing, but I 

2 think you'll have a lot more participation from 

3 our 13 members who are here today, plus Big Ass, 

4 which is also a new member of ALA. And we'll get 

5 more participation from our people. 

6 Doug, do you have something to start 

7 with? 

8 MR. TURNER: Yes. David Turner with 

9 Hunter Fan. My opening comment is more specific 

10 to the sections that we're going to cover 

11 regarding operating hours and the allocation of 

12 the hours to the varying fan speeds. In the TSD, 

13 DOE included data form the LBNL survey, where 

14 high was the most-often used speed -- it was 

15 about 41 percent -- and low was the least often, 

16 and then to keep the testing from becoming really 

17 burdensome, it allocated Medium to the same 

18 ratio, so it ended up about a 66/34 split, high 

19 and low speed, as to how that would be tested. 

20 And we provided data in our response from 

21 AcuPOLL that stated differing data, and we 

22 understood what was said, in response, in the 
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1 TSD, was that our data asked the question a 

2 different way, so that they were going to go with 

3 the LBNL study. So, what we did is we went back 

4 and we conferred with DOE on the question we 

5 should ask, and then we went back and re-asked 

6 the question to a different group, through 

7 AcuPOLL, and received some -- we got the results 

8 back on Monday, so this is a survey that we can 

9 shoot over to you guys, but the survey results 

10 came back very similar to our initial estimates 

11 from AcuPOLL, that as far as ranging from Medium 

12 is the most used, then low, then high. 

13 So we would ask that the DOE relook at 

14 how they allocate the operating hours, because 

15 right now we feel like it's inflated, the energy 

16 usage would be inflated, considering that Medium 

17 is much closer to low speed, as far as the 

18 wattage and energy consumption. 

19 So that's just something that we'd like 

20 to -- and we can hit on it as we get into the 

21 details, but this was something that we kind of 

22 went on in between the release of the TSD and the 
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1 NOPR, and went back and got some more data. 

2 MR. CYMBALSKY: This is John from DOE. 

3 Just a clarifying question. So, your concern is 

4 how we break out the operating hours, not 

5 necessarily with the number of hours per year per 

6 se? 

7 MR. TURNER: Correct. It was the 

8 allocation of the fan speed. 

9 MR. CYMBALSKY: Perfect. Thank you. 

10 MR. BROOKMAN: Other remarks here at the 

11 outset? Okay. Excellent. Do you want to do -- 

12 yes. Lucy deButts. 

13 MS. DEBUTTS: Hi. This is Lucy again. 

14 So, today we, as John stated, we're going to 

15 discuss this procedure and the standards for 

16 ceiling fans. This morning will be the test 

17 procedure discussion. So when we start 

18 discussing the analysis, we will see, on the 

19 presentations, the issue boxes. These issue 

20 boxes correspond to the issues that were outlined 

21 in the notice, and we welcome all the remarks, as 

22 was stated, but we also would like to see those 
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1 remarks in writing, which will help us to write 

2 our rules. 

3 All the information associated with the 

4 test procedure can be found in the docket, and 

5 the number of the docket and a link to the docket 

6 is listed here on the slide. 

7 The deadline for submitting comments for 

8 the ceiling fan test procedure is December 31st 

9 of this year, so it would be a nice New Year's 

10 gift for us, hopefully. 

11 Okay. In order to submit written 

12 comments, you will need to provide us with a 

13 little more information, so we'll know what you 

14 are commenting on, and we ask you to please note 

15 the docket number, the RIN number of the test 

16 procedure, and, of course, submit it via the e17 mail address that's listed on this slide. You 

18 can also send it to us by Postal Service or 

19 courier, but electronic options are preferable, 

20 again. 

21 And just so nobody forgets, December 31st 

22 of 2014 is the deadline for submitting written 
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1 comments. 

2 We already did opening remarks, so 

3 skipping to the schedule. 

4 The ceiling fan test procedure rulemaking 

5 was initiated by publication of the notice in the 

6 Federal Register, which happened on October 17th 

7 of 2014. It started the 75-day comment period, 

8 which ends, as I stated already, on December 

9 31st, 2014. DOE is projecting to have a final 

10 rule for the ceiling fan test procedure to be 

11 published in the third quarter of 2015, with the 

12 effective day, which is going to be 30 days after 

13 the final rule publication, of third quarter 

14 2015, as well. Any questions? Nope? Okay. 

15 Let's go over regulatory history. It's 

16 very similar to what was done yesterday. The 

17 EPCA authorized DOE to start regulating certain 

18 products, and the EPAct 2005 actually established 

19 energy conservation standards for ceiling fans, 

20 which were based on the Energy Star testing. 

21 On December 8, 2006, DOE published a 

22 final rule which codified the test procedure for 
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1 ceiling fans, and the last bullet on here shows 

2 the U.S. Code number, which authorizes DOE to do 

3 the test procedures. 

4 EISA, in 2007, authorized DOE to do the 

5 7-year look-back review of all the test 

6 procedures, and that's what we're doing here 

7 today. Based on that authority, we are reviewing 

8 the ceiling fan test procedures. 

9 As far as the existing test procedure for 

10 ceiling fans, as stated in the last bullet, you 

11 can see it can be found in the Code of Register 

12 under Appendix U. 

13 And that concludes the history and the 

14 schedule. So, for covered products, I will 

15 welcome Colleen right now to help me with the 

16 presentation. 

17 MR. BROOKMAN: At any point during the 

18 presentation, if you want clarification, if you 

19 wish to ask questions, please feel free to do so. 

20 MS. KANTNER: Thanks, Lucy. First we'll 

21 cover scope and applicability. The test 

22 procedures apply to ceiling fans that meet the 
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1 statutory definition, where EPCA defines a 

2 ceiling fan as "a non-portable device that is 

3 suspended from a ceiling for circulating air via 

4 the rotation of fan blades." DOE is proposing to 

5 reinterpret the statutory definition of a ceiling 

6 fan to incorporate hugger ceiling fans. Hugger 

7 ceiling fans are generally indistinguishable from 

8 other types of ceiling fans in that they move air 

9 via the rotation of fan blades, are intended to 

10 improve comfort, and are rated on their ability 

11 to move air. This reinterpretation more 

12 accurately reflects the statutory definition and 

13 does not draw an artificial distinction between 

14 units which serve the same functional purpose. 

15 DOE proposes to clarify that multi-mount 

16 ceiling fans and high-volume ceiling fans meet 

17 the statutory definition of a ceiling fan, and 

18 also clarifies that the current and proposed test 

19 procedures do not apply to centrifugal ceiling 

20 fans, and do not apply to air circulators, which 

21 are fans that are typically mounted on a 

22 pedestal, but could include wall, ceiling, or I-
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1 beam mounting brackets. 

2 MR. FRAMPTON: Hi. This is Nathan with 

3 Fanimation. Could we get further definition on 

4 your definition of an air circulator? 

5 MS. KANTNER: This is intended to 

6 describe fans that, in theory, could be mounted 

7 on a ceiling but aren't sold for that purpose. I 

8 mean, they would normally be on a pedestal or 

9 attached to something else, but you could, in 

10 theory, put a bracket on them and mount them on 

11 the ceiling. We're trying not to broaden the 

12 scope to include anything that, in theory, could 

13 be mounted on a ceiling, but is not sold to be a 

14 ceiling fan. 

15 Does that clarify your question? 

16 MS. ARMSTRONG: I'm going to turn the 

17 question around on you. Where do you see the 

18 ambiguity? Can you give us an example, as to why 

19 certain types of air circulators would 

20 potentially fall into this definition of ceiling 

21 fan, or why not? What is the exact issue? 

22 MR. BROOKMAN: Ashley Armstrong. Now 
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1 back to Nathan. 

2 MR. FRAMPTON: I'm just trying to 

3 understand the definition. 

4 MS. ARMSTRONG: So we don't have one. I 

5 mean, I think that's as simple as that. Right 

6 now we didn't propose one, so we just clarified 

7 the fact that, generally speaking, air 

8 circulators, we don't believe the test 

9 procedures, as it exists today, or as proposed, 

10 applies to them. However, it sounds like you're 

11 suggesting that we need further clarification as 

12 to what would fall into that bucket, and I'm 

13 asking why. 

14 MR. BROOKMAN: Chuck, do you have a 

15 comment? 

16 MR. MATTHEWS: I do. Chuck Matthews, 

17 Matthews Fan Company. There are products on the 

18 market which could be considered air circulators 

19 which are mounted to the ceiling -- 

20 MS. ARMSTRONG: Okay. 

21 MR. MATTHEWS: -- in which case I'd also 

22 ask you to define what is a fan blade and what is 
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1 a fan head, and what is a ceiling mounting 

2 bracket. 

3 MS. ARMSTRONG: Okay. Go ahead. 

4 MR. TABER: Christian Taber, Big Ass 

5 Fans. I think AMCA 230, in their definition 

6 section, has some language that could be used to 

7 help with that. 

8 MS. ARMSTRONG: Great. Thank you. 

9 MR. BROOKMAN: Thank you. 

10 MS. KANTNER: I believe this language 

11 here is the language from AMCA 230. 

12 MR. BROOKMAN: Chuck? 

13 MR. MATTHEWS: Is that the language that 

14 we're supposed to refer to, then, in the AMCA 

15 230, which was mentioned by Big Ass? 

16 MS. ARMSTRONG: So, he's suggesting that 

17 DOE do some clarifications by looking at that as 

18 one source of data to answer your question, so 

19 we're going to have to get back to you, I think 

20 is the answer. 

21 MR. MATTHEWS: But I thought she said 

22 that that was the language. 
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1 MS. ARMSTRONG: So she believes that's 

2 the language. I think he's suggesting, in the 

3 Definition section, there may be further language 

4 to add to this. 

5 MR. MATTHEWS: Okay. Alright. 

6 MR. BROOKMAN: Christian, follow on. 

7 MR. TABER: That's in the Scope portion 

8 of AMCA 230, that's what it says, but there's 

9 also a Definition portion of AMCA 230 that 

10 further defines some of those terms. So I was 

11 saying that maybe we could use the Definition 

12 section to clarify a little bit of what's going 

13 on. 

14 MS. KANTNER: Thanks for that. 

15 MR. BROOKMAN: Additional questions, 

16 comments before we move on? 

17 MS. KANTNER: And now there are some 

18 items for comment. First, DOE is reinterpreting 

19 the statutory definition of a ceiling fan to 

20 include hugger ceiling fans and clarifying that 

21 the definition includes multi-mount ceiling fans. 

22 DOE invites comment on the reinterpretation and 
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1 clarification. 

2 MR. BROOKMAN: Yes, Dave. 

3 MR. GATTO: Dave Gatto, Westinghouse 

4 Lighting. I'm not sure if this is where you want 

5 to talk about the timeline, so I can do that now, 

6 actually, or if there's a better place for it. 

7 MS. ARMSTRONG: No. This is it. 

8 MR. GATTO: I have a tendency to start 

9 talking about something and it's the next slide, 

10 so I figured I'd ask. 

11 MS. ARMSTRONG: Just for those that 

12 weren't in the room yesterday, where we touched 

13 on this, and the reason Dave is bringing up 

14 timeline -- and I'll open it up to everyone -- 

15 but DOE has proposed this part of this test 

16 procedure NOPR to reinterpret the definition of 

17 ceiling fan as encompassing huggers. Obviously, 

18 that interpretation, that proposed interpretation 

19 is out for comment. 

20 One of the things that came up yesterday, 

21 as a repercussion of this, ceiling fan light kits 

22 sold with hugger fans would then be subject to 
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1 the ceiling fan light kit standard. Our proposal 

2 is effective 30 days after the final rule. 

3 Should we finalize it as proposed? And some of 

4 the discussion suggested that 30 days may not be 

5 a sufficient amount of time for products that may 

6 need to be redesigned. 

7 So we turned around the question and 

8 asked people yesterday, with respect to light 

9 kits, doing the same thing today with respect to 

10 ceiling fans, what would you suggest is a 

11 reasonable amount of time? So that's where I'm 

12 going to turn it back over, just to give some 

13 context. 

14 MR. GATTO: Thank you, Ashley. Dave 

15 Gatto, Westinghouse Lighting. We've had a little 

16 bit of dialog about this, but if I miss 

17 something, everybody feel free to weigh in. The 

18 test procedure, 30-day, just simply isn't 

19 physically possible, and there are some reasons 

20 for that, too. You mentioned huggers, but in 

21 addition to huggers, you changed the test 

22 procedure for existing models, which means that, 
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1 without clarification, that would suggest we 

2 would need to potentially retest current models 

3 of fans, even though there's no efficiency 

4 standard. 

5 So, you're looking at, for all of us, 

6 basically, the entire product line. From a 

7 timing standpoint, that requires product 

8 development of potentially hundreds of models, 

9 both in the fan and the light kit -- light kit 

10 specifically as it relates to huggers -- and 

11 while we don't do any industrial light kits at 

12 Westinghouse, if someone has an industrial fan 

13 with a light kit, they'd have the same 

14 consideration there. 

15 In addition to the product development 

16 cycle, which can take 90 to 180 days with these 

17 kinds of numbers of models to look at, we then 

18 have to identify what are the component changes, 

19 and then there are some sourcing needs. Now, 

20 things like sockets and glass, probably not a big 

21 deal, but we discussed limiters among us 

22 yesterday, and some of us reached out to the 
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1 supplier, and the limiter sudden spike in demand 

2 could add 90, 120, 140 days to the supply. So 

3 it's the availability of some of the components 

4 we would need for light kits. 

5 The next step in the process would be 

6 once we've established what those new base models 

7 are, we've done our development work, we've 

8 established full materials, we then have to 

9 produce a sample and then test it. Having 

10 hundreds of fans tested by all of us at the same 

11 time will make what's already a fairly long lead 

12 time from Intertek and UL, or whoever we're 

13 using, potentially even longer. 

14 Once that's done, we need to gather the 

15 data, we need to make sure everything is on 

16 point, and we need to prepare certification for 

17 DOE and submit it, and that includes FTC data, so 

18 there's a question that we have that relates to 

19 the template, because the test procedure now for 

20 multi-mount fans might require two separate 

21 pieces of information, and currently I think 

22 there's only a place for one in the FTC section. 
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1 Once that's done, we actually have to 

2 present those models to our customers, to the 

3 retail channel, and because there are going to be 

4 component changes, design changes, potentially -- 

5 not potentially in the light kits; there will 

6 definitely be a cost change -- there's a whole 

7 cycle there to get placement before we can cut a 

8 production order to a contract factory. 

9 From the date you cut a production order, 

10 average lead time we came up with was about 110 

11 days. That includes the 30 days Tim spoke to 

12 yesterday from the day it's produced, actually 

13 comes off the production line, to the day it 

14 arrives in the U.S., and that can fluctuate, that 

15 last 30 days. Right now it's probably closer to 

16 6 weeks because of some of the port issues we're 

17 all dealing with. 

18 But that all-in somewhere between 18 and 

19 20 months. So it's not a 30-day timeline. 

20 Believe me, it isn't that we don't agree with 

21 huggers. I think we were on board with that 

22 conversation in the last meeting, but the sheer 
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1 volume of work that will be associated with this 

2 is massive for the industry, and, as a general 

3 statement, which I haven't really cleared with 

4 everybody but this is how we look at it, because 

5 we're going to have a final rule that's going to 

6 go into effect -- and let's just say we're on a 

7 timeline with 2019 -- what I'd like to see happen 

8 is make the test procedures effective 1 year 

9 prior, because we're going to need to be doing it 

10 at that point anyway. 

11 Now, I recognize that for DOE that could 

12 create a challenge for the hugger 

13 reinterpretation as it reflects on light kits, 

14 but my preference would be to have everything go 

15 into effect at one time, so 20 months -- really, 

16 it's 24 months, at that point -- is really the 

17 preference of the industry. 

18 MR. BROOKMAN: So your last comment said 

19 it's the preference of the industry. You've 

20 spoken to your colleagues, the other members here 

21 present? They're generally in agreement, 

22 alignment with that statement? 
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1 MR. GATTO: It's a good point, Doug. 

2 I've talked to most of the people here but not 

3 everyone, and I'm also opening it up to both 

4 everyone here, and if there is anybody from a fan 

5 company that's on the line, to weigh in, if I 

6 have either missed something or misstated the 

7 timeline that everyone thinks is appropriate, 

8 absolutely weigh in. But we did discuss this 

9 over the last few days, actually, prior to 

10 yesterday's meeting. 

11 MR. BROOKMAN: These timelines are always 

12 very sensitive things. Yes. Yes, please, Allen. 

13 MR. ROO: Allen with Emerson. Emerson 

14 agrees with Westinghouse on this schedule. 

15 Eighteen months is appropriate. 

16 MR. BROOKMAN: Okay, thank you. Bill? 

17 MR. WALKER: Bill, Hunter Fan. Hunter 

18 agrees with the schedule. 

19 MR. BROOKMAN: Okay. Do we have other 

20 commenters that are in the manufacturing domain, 

21 just so we get that on the record, if it's 

22 appropriate? Okay, yes, Nathan? Tim? 
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1 MR. FLANNERY: Tim Flannery, the Minka 

2 Group. I'm in agreement with Dave from 

3 Westinghouse, but one thing that I didn't hear 

4 that Dave brought up, which is also a concern, is 

5 existing inventory. How is that going to be 

6 handled? Product that's in the warehouses, 

7 products that have shipped. So are you prepared 

8 to grandfather existing product that's come into 

9 the country? I know Ashley brought that up 

10 yesterday, but I don't know if it was clear or 

11 not. 

12 MR. BROOKMAN: Yeah, I'd like to just 

13 hold on that additional topic, just for the 

14 moment. We'll turn to it almost immediately. Go 

15 ahead, Nathan. 

16 MR. FRAMPTON: Nathan with Fanimation. 

17 We also agree with Westinghouse. 

18 MR. BROOKMAN: Don Brundage, you had a 

19 comment here? 

20 MR. BRUNDAGE: Yes, a general comment on 

21 this 30-day. I was in a hearing on large unitary 

22 equipment and the efficiency changes there would 
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1 require retesting and recertification, and they 

2 were complaining that 3 years was barely enough 

3 time to have to do all the recertification. I've 

4 never seen a time that you would require 

5 recertification with only 30 days. I'm just 

6 confused on where this very short time frame is 

7 coming from, because, typically, for measures 

8 that require retesting, it's, as they're 

9 suggesting, a couple of years. 

10 MS. ARMSTRONG: Okay. I'm going to try 

11 to clarify a couple of things. This is Ashley 

12 from DOE. Currently we have design standards for 

13 ceiling fans. We do not have airflow efficiency 

14 for ceiling fans, standards-wise. Now, I 

15 understand that manufacturers make 

16 representations of their airflow efficiency, 

17 whether that be when they're labeling, in public 

18 disclosures for the Energy Star program, or for 

19 other voluntary efforts that they may participate 

20 in. The certification to the Department right 

21 now has nothing to do with airflow efficiency. 

22 It's purely on design standards. 
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1 That certification wouldn't change with 

2 respect to inclusion of huggers and the light 

3 kits that go along with huggers, or other types 

4 of fans, and the larger scale fans. That doesn't 

5 change. We're not picking up a certification for 

6 airflow efficiency. At this time, at least, we 

7 haven't changed the certification requirements. 

8 So the cert would just be to the design 

9 standards. 

10 To the extent the reinterpretation goes 

11 final as it was proposed, yes, that certification 

12 would need to be picked up whenever we do the 

13 effective date, but that would be with respect to 

14 those design standards, not in airflow 

15 efficiency. So there is a significant difference 

16 there, between what you're bringing up with 

17 regards to commercial unitary and here. They 

18 have energy conservation standards but they're 

19 design standard energy. 

20 With respect to the retesting issue, I 

21 guess I'm going to turn it around on you guys. 

22 Maybe you can better explain what it is you 
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1 currently do today, in terms of the public 

2 disclosures you make. Yes, we have a test 

3 procedure that must be used for representation 

4 purposes, if you make representations of airflow 

5 efficiency. But because we don't have standards 

6 for airflow efficiency, it's not a certified 

7 value that you're doing right now. So is 

8 everyone testing every single fan right now, to 

9 the DOE test procedure for airflow efficiency? 

10 MR. BROOKMAN: Nathan. 

11 MR. FRAMPTON: I think the issue is right 

12 now we're all testing ceiling fans per the Energy 

13 Star airflow test, so if we're going to include 

14 huggers in the definition of ceiling fan, which 

15 we're all fine with, we're all going to have to 

16 test the hugger per the Energy Star standard, and 

17 if based on the light kit in the fan, we'll have 

18 to add a limiter. 

19 MR. BROOKMAN: Yes, please, Dave, coming 

20 back to you. 

21 MR. GATTO: Ashley, just one other thing, 

22 because I know you're thinking about this. While 
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1 we don't have an efficiency standard, we have an 

2 obligation under FTC to test and report airflow 

3 value. When you redefine the fan -- and, 

4 Hampton, I know you're here, so if you want to 

5 weigh in -- the way we're interpreting your 

6 definition is FTC's definition is tied to yours. 

7 So that would suggest to us that we do 

8 have to certify those values before we submit 

9 them and before we can -- we have to put them on 

10 our packaging. We have to submit them to FTC. 

11 Admittedly, we're submitting through DOE kind of 

12 as a support valve to FTC, but it's not a 

13 voluntary program, unless we want to put the 

14 Energy Star mark on the product. But I do kind 

15 of see where you're looking at them as different. 

16 MR. BROOKMAN: Ashley. 

17 MS. ARMSTRONG: With respect to huggers 

18 specifically, I mean, if we went final as 

19 proposed with the test procedure, and the 

20 reinterpretation of huggers, whatever the 

21 effective date is -- proposed effective date is 

22 30 days -- there was a representation clause, 
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1 which means representations get 180 days to 

2 change over. So it's not as simple as just the 

3 30-day mark, but you would begin to use the test 

4 procedure at the 30-day mark. You would get the 

5 180 days to fully change over representation. 

6 So what I'm hearing from you is 180 days 

7 isn't sufficient to move to the new test 

8 procedure. Is that an accurate of what you're 

9 saying? 

10 So, can you say it for the record instead 

11 of shaking your head? 

12 MR. GATTO: Sorry. Yeah, I guess I 

13 deserved that since yesterday I was pushing on 

14 you to go on the record. 

15 MS. ARMSTRONG: You did. You cornered me 

16 yesterday. 

17 MR. GATTO: So, yes, we don't believe 

18 it's sufficient, and it might be that some of our 

19 interpretation is creating burden where there is 

20 none, where we would appreciate some 

21 clarification. But in addition to hugger, I 

22 think multi-mount fans, which a lot of us carry, 
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1 the test procedure is different for those than 

2 what we've done to date. So, it could be that 

3 it's just more conversation, but, as you kind of 

4 heard yesterday, we're very concerned that, to be 

5 compliant, which is all of our goal, that it just 

6 wouldn’t be possible, the way we understand what 

7 the requirements would be. 

8 MR. BROOKMAN: So, restate what you think 

9 the appropriate time period would be. 

10 MR. GATTO: So, I think the preferred 

11 timeline would be 1 year prior to the effective 

12 date of the new rule. The preferred timeline, as 

13 a worst case, would be 18 to 20 months from the 

14 date of the final test procedure has been 

15 published. 

16 MR. BROOKMAN: Nathan, you wish to chime 

17 in here? 

18 MS. ARMSTRONG: He's just going to agree. 

19 MR. FRAMPTON: Nothing other than I 

20 agree. 

21 MR. BROOKMAN: Okay. Christian. 

22 MR. TABER: Christian Taber, Big Ass 
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1 Fans. Our concern is that if airflow efficiency 

2 is included, or any changes to the test procedure 

3 are done, we will have to recertify -- everyone 

4 will have to recertify all of their fans. There 

5 are only, as far as I know -- and you guys can 

6 correct me if I'm wrong -- two Energy Star test 

7 labs in the United States, and trying to funnel 

8 everyone's fans through those for recertification 

9 will be a very difficult process. 

10 MR. BROOKMAN: Do you agree with the 

11 general statement about the timeline? 

12 MR. TABER: I don't have enough 

13 background to know how fast the labs would be 

14 able to go through and recertify, but I know that 

15 that would be a lot of fans in a very short time. 

16 MS. ARMSTRONG: So perhaps you can also 

17 clarify one other thing for me. We're going to 

18 get into some details a little bit later in the 

19 presentation, so I'm going to kind of curtail 

20 this discussion, because we do have a specific 

21 slide on compliance dates, effective dates, 

22 transition times, and we can hit this again. 
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1 But, could somebody explain to me the percentage 

2 of the market that's Energy Star and the 

3 percentage that's not? I know we have some of 

4 our own distributions that we made, but just off 

5 the top of your head? DOE does allow you to test 

6 in your own labs, and I was under the impression 

7 that most of you, for non-Energy Star fans, are 

8 testing in your own labs. Maybe that's a false 

9 impression. 

10 MR. BROOKMAN: I see Allen. 

11 MS. ARMSTRONG: I know I've been told by 

12 certain companies that they do do their own 

13 testing. 

14 MR. BROOKMAN: Either Allen or Clark. 

15 MR. ROO: I just want to make it clear 

16 that third-party certification is not required 

17 for FTC DOE data, for CFM data. 

18 MS. ARMSTRONG: Absolutely. 

19 MR. ROO: So, therefore, you do not need 

20 to use certified labs. 

21 MS. ARMSTRONG: You can use in-house 

22 testing. We do not require a third party. We do 
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1 not require a certification body. We do not have 

2 DOE-approved labs. You need to test in 

3 accordance with the test procedure provisions, if 

4 you feel you have the confidence to do that. 

5 Now, Energy Star models, I understand. 

6 There's a certain percentage of the market that 

7 will have to go through those channels, so that's 

8 what I'm trying to get at. Is it 30 percent? Is 

9 it 40 percent? Is it 25 percent? What 

10 percentage of the market typically flows through 

11 those channels? 

12 MR. BROOKMAN: It looks like -- 

13 MR. LINSTONE: I think it's true that 

14 probably the largest fan manufacturers do in15 house testing. I mean, they can comment, but I 

16 would say there's a lot of fan manufacturers that 

17 do not, so they would use a third party, and 

18 California, in fact, requires third-party. 

19 So a concern that I have on this 

20 particular topic is just potential disruption, 

21 where just because of timelines, things might not 

22 be available for sale until such time as some of 
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1 these things can be done, whether it be through a 

2 third-party lab, or changeover, if there's the 

3 requirement to change something. And that would 

4 be my big concern, is we just kind of get out of 

5 sync, where it's just not feasible in a specific 

6 time frame to do some of these things, whether it 

7 be through a third party or just through our own 

8 product, you know, development change process. 

9 MR. BROOKMAN: Do we have any additional 

10 comments here about issues related to timelines 

11 and testing burden? Dave. 

12 MR. GATTO: Just briefly, it's CEC Title 

13 20 requires third-party labs. I know that's not 

14 a national standard, but, unfortunately, they're 

15 part of the 50 states that we sell to. So it is 

16 something that industry has to deal with, even 

17 though I know it isn't required by DOE. 

18 MS. ARMSTRONG: Okay. Thank you. 

19 Anybody else? 

20 MR. BROOKMAN: Christian. 

21 MR. TABER: I was just going to say, I 

22 don't know the other companies' percentages, for 
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1 us, 100 percent of our fans are Energy Star. 

2 MS. ARMSTRONG: Okay. Thanks. 

3 MR. BROOKMAN: Allen. 

4 MR. ROO: To your question about the 

5 quantity of Energy Star certified test labs, I 

6 believe there are only three -- Hunter; Intertek, 

7 Cortland, New York; and Taiwan UL, and possibly 

8 the CSA lab in Ohio. So there are four labs that 

9 are Energy Star certified test labs. 

10 MS. ARMSTRONG: Okay. 

11 MR. ROO: It's a small quantity. 

12 MR. BROOKMAN: Do you know about the 

13 percentage of the market? 

14 MR. ROO: The rule is the top 25 percent 

15 of the market, and, quite frankly, with the new 

16 proposed test method coming online, we won't be 

17 certifying any new Energy Star test fans, or any 

18 Energy Star fans, per the procedure, due to the 

19 cost involved. And then, what's going to happen 

20 with the Energy Star test procedure itself and 

21 the program? Are they going to follow suit with 

22 your guidance? 
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1 MS. ARMSTRONG: Yes. DOE is responsible 

2 for test procedures for the regulatory program 

3 and for Energy Star, so it would all be a single 

4 test. It would all roll together. 

5 MR. ROO: So, once again, the Energy Star 

6 program would wipe clean the listings, and we'd 

7 all start anew? 

8 MS. ARMSTRONG: so, I'm sure someone from 

9 EPA is probably on the webinar. I'm not sure if 

10 that's Abby. So, they would initiate a process 

11 to revise the spec, once we get further down -- 

12 I'm going to speak for them and they can correct 

13 me if I'm wrong. 

14 MR. BROOKMAN: Please say your name, and 

15 make sure that's on. 

16 MS. MEDEPALLI: Okay. This is Sarah 

17 Medepalli from ICF, representing Energy Star. 

18 Yes, as Ashley mentioned, Energy Star typically 

19 adopts the DOE test method and their 

20 certification process. So whenever the test 

21 method is finalized, Energy Star will begin the 

22 revision process of the specification and adopt a 
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1 test method, and, typically, provides a 9-month 

2 transition time to, or allowing manufacturers to 

3 recertify to the new version, with the new test 

4 method. And I just wanted -- 

5 MS. ARMSTRONG: Just to clarify, the 9 

6 months would be a transition to the specs, the 

7 spec levels? Whatever transition is required for 

8 the test procedure would be dictated by what's 

9 determined in the rulemaking and what becomes 

10 federal law. That transition would have to occur 

11 across the board. So when she's talking about 

12 transition, given that's for the EPA Energy Star 

13 spec levels, and what they may become and what 

14 they look like post the test procedure change, 

15 but the actual effective compliance date 

16 representations turnover would be determined by 

17 the rule themselves, for all readings. Okay. 

18 MR. BROOKMAN: Okay. Thank you. 

19 MS. MEDEPALLI: Thank you. 

20 MR. BROOKMAN: Do you wish to try to 

21 address Tim's question about existing inventory 

22 here? 
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1 MS. ARMSTRONG: So, I think I'm going to 

2 table Tim's question, not to not answer Tim's 

3 question. We will get back to you, I promise. 

4 But when we get to the compliance date section, 

5 just so there are some nuances on that slide, 

6 remind me then to get back to your inventory 

7 question about exactly what happens, what happens 

8 with representations. If Hampton wants to chime 

9 in about the label, as he's running out the door. 

10 [Off mic comment.] 

11 MS. ARMSTRONG: Oh, there we go. 

12 MR. CYMBALSKY: This is John from DOE. 

13 So, with respect to inventory, what I think will 

14 help the conversation we've had with other groups 

15 is how much inventory you do keep on hand. My 

16 understanding, except for maybe one manufacturer, 

17 most of the stuff is coming from Asia, so it 

18 would be good to know all of that, those pieces 

19 of information, to try to figure out the flow of 

20 product and how long it takes. 

21 MR. BROOKMAN: In the written comments. 

22 MS. ARMSTRONG: And I think, from DOE -- 
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1 no, for this afternoon -- and I think that the 

2 difference for DOE is inventory here or is 

3 inventory overseas, and it does matter, for the 

4 answer. 

5 MR. BROOKMAN: Yes, Dave. 

6 MR. GATTO: That's okay. I'm just going 

7 to throw it out there. Depending on part of that 

8 conversation, I don't know that I'm going to be 

9 comfortable giving here, but I will commit to 

10 answers that I don't feel comfortable in the 

11 public media. I can file it through Navigant. 

12 We're under an NDA. 

13 MS. ARMSTRONG: Sure. 

14 MR. BROOKMAN: Great. Hampton, I see you 

15 at the microphone. 

16 MR. NEWSOME: I'm Hampton Newsome from 

17 the Federal Trade Commission, and, as you know, 

18 we're the agency that does the labeling component 

19 of the efficiency program. I probably will not 

20 be here all day, so I just, since there are some 

21 FTC issues that have kind of come up, I just 

22 wanted to clarify a couple of things. 
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1 One is just the general provision under 

2 the statute, under EPCA, is that if there is a 

3 DOE test procedure for a product then any energy 

4 representation you make needs to be based on 

5 that. So, obviously, if DOE updates the test 

6 procedure, then any FTC labeling requirements 

7 will need to reflect that, and then, also, any 

8 Energy Star representations will need to reflect 

9 that, so everything will be kind of in one bin 

10 there, at DOE. That also goes for any FTC 

11 requirements. So if DOE updates their test 

12 procedure, then any representation, including 

13 those made on a label, will need to reflect the 

14 new DOE test. 

15 Now, as Ashley said, under the statute, 

16 there is a representation provision that 

17 basically says that manufacturers have 180 days 

18 after DOE issues a test procedure to change all 

19 their representation. So when we're talking 

20 about the 180 days, we're talking about something 

21 that's in the statute, that none of the agencies 

22 really have much flexibility on. Now, DOE, in 
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1 terms of releasing the test procedure and that 

2 kind of thing, that's a decision for them, in 

3 terms of timing, and it looks like you guys are 

4 talking about that. 

5 Also, reporting. Currently FTC has 

6 reporting, but if DOE has a certification program 

7 for a product and reporting, it's FTC's practice 

8 to simply defer to that, so that we don't have 

9 duplicative reporting. So that's something that 

10 we'll have to keep an eye on as this issue goes 

11 through, and it's likely that FTC would just 

12 eliminate our separate reporting requirements and 

13 defer to DOE. 

14 The third thing is, as most of you know, 

15 we proposed some changes to the design of the 

16 EnergyGuide label, of the ceiling fan label. The 

17 current ceiling fan label has airflow efficiency 

18 and some other information. Most EnergyGuide 

19 labels we have for consumer products these days, 

20 the primary disclosure is an estimated yearly 

21 operating cost, and we propose that, to change 

22 the ceiling fan label to basically put the 
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1 EnergyGuide title on it, and to also have 

2 operating cost as the primary disclosure. And, 

3 in comments we've received, there are some open 

4 issues that look like they are directly tied to 

5 the DOE proceeding. 

6 The label is relatively simple, but when 

7 we have an operating cost figure on there, we 

8 need some assumptions behind that, and one of 

9 them is a use figure, and we had proposed 6 hours 

10 per day. And the other issue that's come up is 

11 the speed at which the fans are tested at. 

12 Currently, the label is at high speed, and 

13 there's concern about whether that overestimates 

14 the number, and that's something that, if DOE 

15 sets a speed or whatever DOE says in the test 

16 procedure, is what we would generally follow on 

17 the label. The intent, generally, with the 

18 labeling program, is not to reinvent things or do 

19 things differently than what DOE is requiring 

20 manufacturers to do. 

21 So, that's something. Those two issues 

22 are things that, from FTC's perspective, the 
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1 staff will be looking at during this proceeding, 

2 to see how that is resolved, so that we can have 

3 a consistent label, if the Commission decides to 

4 update the design. 

5 MR. BROOKMAN: Since we have Hampton 

6 here, and since he said he might not be here all 

7 day, do we have questions for Hampton? Dave. 

8 MR. GATTO: Dave Gatto, Westinghouse 

9 Lighting. Listen, I'm never going to get this 

10 right, so -- 

11 MR. BROOKMAN: Yes, you will. You're 

12 doing better all the time. Keep going. 

13 MR. GATTO: So, two questions. One is -- 

14 well, one, thank you. I do appreciate, and I 

15 think we've given these comments before, but I 

16 don't know if I've given them directly to you, 

17 Hampton, that it's been very good for industry 

18 that you guys have worked together to make it 

19 easier for us to both submit the data and also to 

20 have one result that we're reporting and putting 

21 on the label. 

22 My question is about the 180-day 
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1 provision, and it's more of a, just to make sure 

2 I understand it right. It's 180 days from when 

3 DOE says the effective date of the test 

4 procedure, or when DOE says the compliance date 

5 of the test procedure? I know that sounds like a 

6 weird thing, but I'm concerned that DOE agrees to 

7 20 months but FTC is only giving us 180, and 

8 we're going to end up -- 

9 MR. NEWSOME: It's not FTC. It's the 

10 statute. The statute, I believe -- 

11 MR. GATTO: I didn't mean to blame you 

12 for that. 

13 [Laughter.] 

14 MR. NEWSOME: And my lawyer over here -- 

15 the statute says, I believe -- 

16 MS. ARMSTRONG: He's all of our lawyers. 

17 MR. NEWSOME: But that's kind of DOE's 

18 interpretation of what that means, because 

19 they're the ones issuing it. And so this is 

20 something that obviously will be an important 

21 issue in this proceeding, and DOE will look into 

22 it and try to figure out the timing. Ideally, 
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1 for this type of change, since we're changing the 

2 label, it makes sense to try to time things so 

3 that everyone is, when they're making the test 

4 procedure changes, they're redoing the test 

5 procedure, they're also redoing the label. 

6 Whether that's going to work out exactly, I don't 

7 know. I can't predict that. But that's 

8 certainly consistent with the way we've handled 

9 things in the past, so that manufacturers aren't 

10 making lots of changes in series. 

11 MR. BROOKMAN: Thank you, Hampton. So, 

12 I'm -- yes, Christian, please. 

13 MR. TABER: Christian Taber, Big Ass 

14 Fans. I did have one question on the labeling. 

15 Would that also apply to high-volume, large16 diameter fans? 

17 MR. NEWSOME: Our coverage would 

18 generally match whatever DOE's test procedure 

19 covers. So, for instance, now, I believe our 

20 rule says specifically that we don't cover any 

21 fan models that cannot be tested under the 

22 current test procedure, even though, 
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1 theoretically, if you read the definition, there 

2 may be a fan that would fit in there. But if it 

3 can't be tested under the test procedure, then we 

4 don't want a label for it because you're not 

5 going to have consistent information. 

6 MS. ARMSTRONG: So the answer to you 

7 would be yes. 

8 MR. NEWSOME: Yes. Since this would be 

9 covered by it, then, yes, there would be a label 

10 for it. 

11 MS. ARMSTRONG: If we finalize as 

12 proposed. 

13 MR. BROOKMAN: Thank you, Ashley. Thank 

14 you, Christian. Any other questions, comments, 

15 before we move off this general topic, because 

16 we're about to move on? Okay, then. Back to 

17 Colleen. Did you think we dealt with Issue 1 

18 fully, Colleen? 

19 MS. KANTNER: I think so, Issue 1. I 

20 mean, we started to touch on Issue 2. 

21 MR. BROOKMAN: Do you think we got all of them? 

22 MS. ARMSTRONG: Yup. 
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1 MR. BROOKMAN: Okay. Then final comments 

2 on Issue 1, 2, and 3, before we move on. Let's 

3 take a peek and make sure that we've covered it 

4 here. 

5 Okay, Colleen. 

6 MS. KANTNER: DOE determined that it was 

7 necessary to delineate these two types of fans, 

8 high-volume and low-volume ceiling fans, where 

9 volume refers to airflow volume, because they 

10 deliver different distinct utilities to ceiling 

11 fan users and require different methods of 

12 testing. 

13 One distinct utility that low-volume 

14 ceiling fans offer, compared to high-volume 

15 ceiling fans, is that they can safely be used in 

16 residential locations. Because of this distinct 

17 utility, DOE tried to harmonize the delineation 

18 between these two types with existing UL 507 

19 safety requirements for fans installed such that 

20 the blades are within 10 feet of the floor, as 

21 seen in Table 1. 

22 Additionally, DOE defines all ceiling 
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1 fans greater than 7 feet in diameter as high2 volume fans, and all fans less than 7 feet in 

3 diameter that do not produce more than 5,000 CFM 

4 of airflow as low-volume ceiling fans. And the 

5 next slide illustrates the categorization of low6 versus high-volume ceiling fans, using a flow 

7 chart. 

8 Now, this flow chart is specifically for 

9 reversible ceiling fans, ceiling fans capable of 

10 operating both in the forward and reverse 

11 directions. Ceiling fans only capable of 

12 operating such that the airflow is downward would 

13 use a similar flow chart with different maximum 

14 tip speeds corresponding to the blade edge 

15 thickness. 

16 But for reversible ceiling fans, you 

17 would first determine whether a ceiling fan was 

18 larger than 7 feet, and if it is, then it's a 

19 high-volume fan. If not, then you would 

20 determine if the maximum airflow is less than or 

21 equal to 5,000 CFM, and if it is, then the fan is 

22 a low-volume fan. But if it's greater than 5,000 
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1 CFM, then whether or not it's a high- or low2 volume ceiling fan would depend on the maximum 

3 tip speed for a given blade thickness, and this 

4 is because thinner blades present a greater 

5 danger to consumers at high speeds. 

6 MR. BROOKMAN: Yes, Tim. 

7 MR. FLANNERY: Can you please help me 

8 with how we came to the determination of 5,000 

9 CFM? 

10 MR. BROOKMAN: I'd like to make a 

11 request. Can everybody pull these microphones 

12 close to their face, please? 

13 MR. FLANNERY: This is Tim Flannery from 

14 the Minka Group. When you came to the number of 

15 5,000 for low-volume, where did that number come 

16 from, or how did we determine that that was a low 

17 volume? 

18 MS. KANTNER: We thought it was 

19 appropriate that there was some cutoff on airflow 

20 volume below which you couldn't be considered a 

21 high-volume ceiling fan. I think 5,000 was 

22 determined by looking at typical airflows of 
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1 high-volume ceiling fans and making sure that 

2 there were none that were below that threshold. 

3 MR. BROOKMAN: Tim, do you wish to 

4 suggest another threshold? 

5 MR. FLANNERY: Tim Flannery with the 

6 Minka Group. I'm not sure if everyone is in 

7 agreement, but I would suggest low-volume go up 

8 to 10,000. 

9 MR. BROOKMAN: Oh, interesting. Yes, 

10 Christian. 

11 MR. TABER: I have a question on that 

12 5,000. Is that 5,000 based on published numbers, 

13 or is it based on the CFM that would be generated 

14 with the inclusion of the false ceiling? The 

15 false ceiling reduces airflow by 30 to 50 

16 percent, so 5,000 under the new test procedure is 

17 dramatically different than 5,000 under the old 

18 test procedure. 

19 MS. KANTNER: That's a good point. This 

20 number referred to the current test procedure, 

21 where there isn't a false ceiling. You're right 

22 that under the new test procedure -- 
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1 MR. TABER: It's more like 8,000 or 9,000 

2 CFM, which is closer to that number. 

3 MR. BROOKMAN: Tim, do you wish to follow 

4 on? 

5 MS. ARMSTRONG: We would likely -- we 

6 will, I will say, we will update it to be 

7 consistent with what would be generated from the 

8 new test procedure. 

9 MR. TABER: I have comments on the new 

10 test procedure in that respect, as well. 

11 MS. ARMSTRONG: We'll get there. Hold 

12 the -- but, so, what I'm hearing, and just to 

13 summarize is perhaps you think a higher number is 

14 a better number to differentiate the two types, 

15 as the measures exist today, as representations 

16 are made today. However, it's, that might be in 

17 the right ballpark for what the airflow would 

18 look like under the new test procedure, as 

19 proposed, with a false ceiling, if we finalize it 

20 that way. Is that fair, or no? 

21 MR. FLANNERY: I believe that it's fair. 

22 MS. ARMSTRONG: Okay. 
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1 MR. BROOKMAN: Thank you, Tim, and thank 

2 you, Ashley. Don Brundage. 

3 MR. BRUNDAGE: I've got sort of a 

4 regulatory philosophy question here. 

5 MR. BROOKMAN: Do we want to do that 

6 after the break? 

7 MS. ARMSTRONG: We want to do that after 

8 the break. 

9 MR. BROOKMAN: Just kidding. 

10 MR. BRUNDAGE: Generally, with covered 

11 products, you're looking at things, and the 

12 general theme is something that would be normally 

13 used in a residential home, and it's covered 

14 under 10 CFR 430, and something that would be 

15 used in a commercial or industrial setting would 

16 be regulated under 10 CFR 431, non-covered, i.e., 

17 ASHRAE product. I can't envision many homes that 

18 would have a ceiling fan with a fan diameter 

19 greater than 7 feet, but it's getting included as 

20 a covered product. 

21 I'm just -- is there some specific 

22 legislation that puts all ceiling fans, 
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1 regardless of size, under 430, or why is there 

2 not a break in treating it differently, from a 

3 regulatory viewpoint? Thank you. 

4 MS. ARMSTRONG: This is Ashley from DOE. 

5 I think the general answer is the statute sets up 

6 covered products more broadly, just the covered 

7 product is a ceiling fan and they defined it in a 

8 specific way, and we believe these types meet 

9 that definition. There are certain products 

10 where they put the entire, all the different 

11 categories under a given product, covered product 

12 heading in a specific section. So, for example, 

13 certain types of lighting products are all in 

14 Part 430, even though we know they get sold to a 

15 lot of different applications. It's just the 

16 way. 

17 So, ceiling fans, all the different 

18 categories of ceiling fans are all of a type, 

19 which is ceiling fan, and they happen to be 

20 placed in the consumer product section of 430, 

21 but we believe all these different categories of 

22 ceiling fan meet the statutory definition. 
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1 Obviously, some things we welcome comment on, but 

2 this is DOE's interpretation. 

3 MR. BRUNDAGE: In other words, the way I 

4 would interpret what you said, because when they 

5 added ceiling fans through legislation to Section 

6 430, they did not distinguish a size, so all 

7 ceiling fans are going under 430. Is that more 

8 or less correct? 

9 MS. ARMSTRONG: Any ceiling fan that 

10 meets that definition. The definition is not 

11 restricted by size. 

12 MR. BRUNDAGE: Okay. 

13 MR. BROOKMAN: Okay. Thank you. Yes, 

14 Christian. 

15 MR. TABER: Can we go back to the slide 

16 with the chart? 

17 MR. BROOKMAN: The flowchart? Yes. 

18 MR. TABER: I guess this is a general 

19 comment. Would it be possible to have my slide 

20 brought up? Would this be appropriate to do 

21 that, from my general comments? 

22 MS. DEBUTTS: Sure. We could. 
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1 MR. TABER: Generally speaking, we find 

2 this methodology to be a little confusing, and it 

3 creates some issues. It took three degreed 

4 engineers about 4 hours to figure out which 

5 category our fans fell into. I don't think the 

6 average user is going to spend 4 hours doing 

7 that. 

8 Right there. Back one. 

9 So, we tried to create a -- one more. 

10 Sorry. Forward. Right there. That one. 

11 We tried to create a chart that kind of 

12 showed all seven factors, and then color-coded 

13 them, to put them together, to make it a little 

14 more understandable, and we kind of got lost. 

15 And, so, we tried to just wipe the slate and go 

16 back and think, if we were to do this, how would 

17 we do this -- which is not necessarily the right 

18 answer. It's just a different answer. 

19 If you can go down a slide. 

20 There are a couple of issues with small21 diameter fans having different methods of test. 

22 Generally speaking, AMCA 230 produces about 15 
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1 percent less CFM for the same fan, on the test 

2 stand. So there are instances where a small3 diameter fan may move sufficient airflow to move 

4 it into the high-volume category, but when tested 

5 under the other test metric, it would not qualify 

6 for the high-volume category. So, if it moved 

7 5,500 CFM on Energy Star, on AMCA 230 it would be 

8 more like 4,500 CFM, so it would fall into the -- 

9 yes, which I don't think gray is a good thing 

10 when it comes to legislation. 

11 In addition, because it produces 15 

12 percent less airflow, small-diameter, high-volume 

13 fans would then be de-rated, from an efficiency 

14 standpoint, which may lead a consumer to pick a 

15 less-efficient product, simply because of a 

16 different method of test. 

17 So our proposal is that all fans less 

18 than 7 feet in diameter would be tested via 

19 Energy Star, which is about the limit of what 

20 that room can realistically test, and then 

21 anything larger than 7 feet in diameter would be 

22 tested via AMCA 230. So it's just a straight 
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1 diameter. Hugger fans would still fall under 

2 Energy Star test method, and they would be 

3 defined by 10-inches, and decorative fans would 

4 be based on tip speed instead of RPM, which is a 

5 different thing, and then 2,000 CFM. So it keeps 

6 an apples-to-apples comparison for test methods 

7 and it greatly simplifies that chart. 

8 MS. ARMSTRONG: Okay. Thank you. Does 

9 anybody have any feedback or comments to his 

10 proposal? Support? 

11 MR. BROOKMAN: Allen. 

12 MR. ROO: Yeah, I kind of agree with him. 

13 Allen with Emerson. I do agree with Big Ass in 

14 that the small-diameter fans shall be tested per 

15 the existing Energy Star, solid-state test 

16 methodology and/or the modified methodology that 

17 you're proposing. Our labs, our factories, 

18 they're all, they've been testing with that 

19 methodology for 10 years. We have good 

20 confidence with that test methodology, and it's 

21 changed to a methodology where I've spoken with 

22 previous engineers who worked with the load cell 
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1 and they say it's a very twitchy testing device. 

2 You have to run multiple tests. 

3 I'm afraid your estimate of $3,500 is 

4 low. Currently, the test cost for Energy Star is 

5 $1,800 in China, which is one test, and you're 

6 finished. So I'm suspecting that the test is 

7 much more expensive than what we're expecting. 

8 MR. BROOKMAN: Okay. Thank you. 

9 Additional comments on -- yes, Dave -- on this, 

10 what was just presented by Christian? 

11 MR. GATTO: Dave Gatto, Westinghouse 

12 Lighting. I might have gotten it right that 

13 time. So, I won't speak to the large-diameter -- 

14 we don't do a product over 7 feet -- but I do 

15 agree with Christian, and it's been a topic of 

16 conversation for us, that testing based on the 

17 fan diameter, using the same test method for what 

18 we would consider industrial as well as 

19 residential products, makes sense. It's going to 

20 provide consistent results and it's going to take 

21 some confusion out for our internal folks on what 

22 specific tests we need to do and when. 
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1 MR. BROOKMAN: Okay. Thank you. 

2 Christian. 

3 MR. TABER: One other comment. Christian 

4 Taber. The load cell needed for a small-diameter 

5 fan is very different than the load cell needed 

6 for a large-diameter fan, so it would require, as 

7 written, two separate load cells, one with enough 

8 resolution to be able to test the small diameters 

9 and then one with a different set for the large 

10 diameter. 

11 MR. BROOKMAN: Okay. Additional comments 

12 here? You had -- are these all the slides that 

13 you wish to present? I thought you had some 

14 slides. 

15 MR. TABER: This is Christian Taber. I 

16 have others. I think, though, as we go through 

17 the topic, it's more useful than just trying to 

18 do it all at once. 

19 MR. BROOKMAN: Yeah. That's what I 

20 wanted to figure out. Yes, Bill. 

21 MR. WALKER: Bill Walker, Hunter Fan. 

22 So, just a point of clarification, I think what I 
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1 understood you to say is the two methods don't 

2 correlate. They're off about 15 percent. Is 

3 that correct? 

4 MR. TABER: Correct. If you take the 

5 same fan and you -- Christian Taber, sorry. If 

6 you take the same fan and you test it via Energy 

7 Star and it gives you 1,000 CFM, you would get 15 

8 percent less if you tested it via AMCA 230, 

9 roughly. That number varies but that's about 

10 what we see. 

11 MR. WALKER: That was one of the 

12 questions I had later on, so you've answered that 

13 now, so I think Hunter agrees that it's a good 

14 proposal, what he's proposing. 

15 MR. BROOKMAN: Okay. Yes, Allen. 

16 Nathan. 

17 MR. FRAMPTON: This is Nathan with 

18 Fanimation. We also agree with Big Ass. 

19 MR. BROOKMAN: Thank you. And, Tim, yes. 

20 MR. FLANNERY: Tim Flannery, the Minka 

21 Group. We also agree. 

22 MR. BROOKMAN: Good. And, of course, 
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1 these comments you're providing will be very 

2 helpful to the Department. We're going to 

3 proceed. 

4 MS. KANTNER: In the framework document, 

5 DOE considered establishing a definition for 

6 hugger ceiling fans, based on the average 

7 vertical distance between the fan blades and the 

8 ceiling. In determining an appropriate boundary 

9 between hugger and standard ceiling fans, an 

10 analysis was conducted of all ceiling fans 

11 available from Hansen Wholesale, and online 

12 wholesaler that sells a wide variety of ceiling 

13 fan brands. Ninety percent of ceiling fans 

14 described as hugger fans had blades for which the 

15 average vertical position was 9 inches or less 

16 from the ceiling, suggesting that 9 inches might 

17 be an appropriate threshold. 

18 By contrast, half of all ceiling fans 

19 that were described as standard ceiling fans had 

20 blades for which the average vertical position 

21 was 12 inches, was within 12 inches of the 

22 ceiling, suggesting that a higher threshold might 
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1 result in the categorization of a significant 

2 number of standard ceiling fans as hugger ceiling 

3 fans. 

4 DOE has also determined that a definition 

5 based on the maximum distance between the blades 

6 and the ceiling is more appropriate than a 

7 definition based on the average distance between 

8 the blades and the ceiling, when considering 

9 whether or not a ceiling fan is safe to operate 

10 in a room with a low ceiling. 

11 Therefore, DOE is proposing to define a 

12 hugger ceiling fan in terms of the vertical 

13 distance between the ceiling and the lowest point 

14 on the fan blades. To account for the additional 

15 vertical distance between the average vertical 

16 position of the fan blades and the lowest point 

17 on the blades, DOE determined that adding 1 inch 

18 to the vertical distance specified in the 

19 definition would be appropriate, given the 

20 typical width and pitch of a fan blade. 

21 Therefore, DOE is proposing to define a 

22 hugger ceiling fan as "a ceiling fan where the 
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1 lowest point on the fan blade is no more than 10 

2 inches from the ceiling." DOE is also proposing 

3 a complementary definition for standard ceiling 

4 fans, of "a ceiling fan where the lowest point on 

5 the fan blades is more than 10 inches from the 

6 ceiling," and a definition for multi-mount 

7 ceiling fans, of "a ceiling fan that can be 

8 mounted in both the standard and hugger ceiling 

9 fan configurations." 

10 And just as a note, to meet DOE's 

11 definition of a multi-mount ceiling fan, a fan 

12 must be capable of being mounted in both 

13 configurations that meet DOE's definition of a 

14 hugger and standard ceiling fan. A ceiling fan 

15 that can be mounted at more than one height does 

16 not necessarily qualify as a multi-mount ceiling 

17 fan to DOE. 

18 MR. BROOKMAN: Dave. 

19 MR. GATTO: Just a question on that note. 

20 So if a ceiling fan can be mounted -- on our 

21 definition of multi-mounted, we talked and it's a 

22 little bit different, but I understand where DOE 
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1 is coming with it. My question is, if I have a 

2 fan that has a downrod that can also be mounted 

3 close to ceiling, and both distances from the 

4 ceiling are, let's say, 12 and 15 inches. One 

5 test, and in which configuration? I can pick the 

6 one, or --? 

7 MS. KANTNER: That will be actually 

8 clarified later in this presentation. 

9 MR. GATTO: Okay. Thanks. 

10 MR. BROOKMAN: Thank you, Colleen. 

11 MS. ARMSTRONG: But just to clarify here, 

12 that's a standard ceiling fan. That would be a 

13 standard ceiling fan. 

14 MR. GATTO: I'm sorry. So, I could've 

15 asked it that way. So what you're saying is it 

16 wouldn't be multi-mount, so it falls into 

17 standard? 

18 MS. ARMSTRONG: Correct, and then how to 

19 test a standard fan with multiple options for 

20 different sized downrods will be what we clarify 

21 later. But your distances that you said qualify 

22 it just as a standard, under our proposed 
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1 definition. 

2 MR. GATTO: Okay. I'm sorry. Dave 

3 Gatto, Westinghouse. Thank you, Ashley. 

4 MS. ARMSTRONG: So just to tee this up, do 

5 people agree with the 10-inch cutoff? Do people 

6 disagree? Would people do it differently? How 

7 do you do it today? I mean, I will say -- in all 

8 honesty, DOE struggled with this a little bit, 

9 because as we reviewed literature, we looked at 

10 your diagrams, we were trying to figure out 

11 distances. You guys don't exactly all do it the 

12 same, even though you may all know what a hugger 

13 fan is. So we were trying to draw a line. So I 

14 guess we'd really like your feedback on this 10-

15 inch, if you'd be willing. 

16 MR. BROOKMAN: Allen. 

17 MR. ROO: Allen with Emerson. A lot of 

18 our huggers are in the 11- and 12-inch range, and 

19 we do this to avoid turbulent airflow into the 

20 blades. When you get close to the ceiling at 10, 

21 9 inches, you get turbulent air. The fan starts 

22 to vibrate, wobble, make noise. Consumers don't 
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1 like that, so we tend to make our huggers in the 

2 11- and 12-inch range. 

3 MS. ARMSTRONG: So is 12 better, 12-inch 

4 a more representative number, for what you're 

5 calling huggers today? I mean, the intent of 

6 this is not to completely change what you're 

7 calling huggers today. The intent was to 

8 characterize, in a uniform manner, what you guys 

9 are all calling huggers today. Some we found 10, 

10 some we -- you know, we found different numbers. 

11 Let's put it that way. 

12 MR. BROOKMAN: Tim, first. 

13 MS. ARMSTRONG: Especially depending on 

14 where you measure it. 

15 MR. FLANNERY: Tim Flannery, the Minka 

16 Group. We classify a hugger fan as a fan that 

17 mounts directly to the ceiling without a downrod. 

18 MS. ARMSTRONG: Hence the difference 

19 then. 

20 MR. FLANNERY: Okay. And as far as 

21 ceiling, distance from ceiling to the blade, we 

22 go from the top of the blade versus the bottom of 
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1 the blade. Okay, so we have a variance ratio 

2 there. But, you know, I don't really understand 

3 why we're broadening this category to tri-mount 

4 fans, and maybe you can better clarify that for 

5 me. I mean, we look at a hugger fan as an 

6 application type fan. I don't see it as a 

7 disadvantage but I also don't see the advantage, 

8 and I'd just kind of like clarification. 

9 MS. ARMSTRONG: So, I'm not completely 

10 sure I understand your question, but the reason 

11 DOE believes it needs a definition of hugger fan 

12 is to clarify what a hugger fan actually is. 

13 Now, sure, we could use that definition, a more 

14 broad definition, that's more general in nature, 

15 that just says it's intended to be flush-mounted 

16 to the ceiling, or something along those lines, 

17 but we want to make sure that comparable 

18 products, as they are being sold into the market, 

19 are able to be compared and tested in a 

20 comparable way. 

21 So if we're testing huggers in a certain 

22 way, and that gives you a certain answer, we want 
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1 to make sure all fans, or all huggers are also 

2 tested in that way. And we find, from what we've 

3 learned in our other regulatory space, we find 

4 it's easiest based to do it on definitive 

5 characteristics, rate definitions based on 

6 definitive characteristics, than intended use, 

7 because people do -- slightly it's designed, 

8 intended to be used a little differently. 

9 MR. FLANNERY: Tim Flannery again. So 

10 when you're -- predominantly there are a fair 

11 amount of products that are in the marketplace 

12 today that are shipped with two downrods, a 3- 

13 and a 6-inch downrod, or variations of, and that 

14 would really categorize -- the general 

15 application would be for 6-inch, but putting that 

16 3-inch downrod in would qualify that as a hugger, 

17 and then, at that point, if we're required to put 

18 the CFM ratings based on the lowest performer, 

19 that's really going to, I think, damage the 

20 industry. I mean, from my perspective, I think 

21 CFM ratings is very important. When you get into 

22 your coastal and you get into your tropical 
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1 areas, the consumer is looking for CFM 

2 performance. 

3 So, you know, as a goal, from our 

4 perspective, we really want to increase our CFMs. 

5 I don't understand why we'd want to bring 

6 something in that would, in fact, lower it, 

7 because my understanding is that you're going to 

8 now, if you're supplying the two downrods to 

9 where you have an application to hang that lower, 

10 to a lower application, you're now going to 

11 require that that lower CFM be on the rating. Is 

12 that correct? 

13 MS. ARMSTRONG: So, I -- our proposal is 

14 that if you fall into both categories, hugger and 

15 standard, you would have to make representations 

16 of both. That's the nuance. So, on your 

17 representations, on your certifications -- 

18 MR. FLANNERY: On the box, or in the 

19 instruction manual? 

20 MS. ARMSTRONG: The box is going to go to 

21 Hansen, in case Hansen wants to speak, because 

22 DOE doesn't have any -- FTC has the authority 
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1 over disclosures and not type for ceiling fans. 

2 But for DOE's purposes, you would be certifying 

3 in both configurations. You would be testing and 

4 certifying in both configurations. 

5 MR. FLANNERY: So if the application 

6 would be that, your general application would be 

7 for it to be on a 6-inch downrod, but you're 

8 including a 3-inch downrod, okay, you can state 

9 that in the instruction manual, that the fan is 

10 offered in a hugger format at such -- is also 

11 available in a hugger format, which is at a 

12 specified CFM rating? Would that be acceptable? 

13 MR. NEWSOME: I'm not sure I understand 

14 the question. 

15 MR. BROOKMAN: Hampton, you've got to 

16 find a microphone. 

17 MS. ARMSTRONG: While Hampton moves to 

18 the microphone, I'm going to try to clarify what 

19 I think. So, Hampton, what we did in our 

20 proposal here is if something falls into two DOE 

21 definitions, as different categories of ceiling 

22 fans, that they have to test and come up with 
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1 ratings in both configurations. 

2 So I think the question is, would they 

3 then be allowed to disclose, on their literature 

4 or on their box, as they wish, both numbers, 

5 because they fall into two categories of fans, 

6 and would get different ratings? Is that fair? 

7 I think that's his question, more or less. 

8 MR. BROOKMAN: Tim, do you want to 

9 restate the question? 

10 MR. FLANNERY: My feeling is that, from 

11 an optimum standpoint, if we're designating the 

12 fan with a 6-inch application, however we're 

13 offering a 3-inch downrod, what I believe that, 

14 from Minka's perspective, we would like to do is 

15 we would like to show the CFM rating for the 6-

16 inch downrod on the box, and then, in the 

17 instruction manual, state that as an option you 

18 can put this fan into a hugger category, which 

19 will provide this CFM. So we're not hiding 

20 anything, but we're putting in on the package as 

21 we'd like to indicate, for general sale. 

22 MR. BROOKMAN: Hampton. 
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1 MR. NEWSOME: Well, there are two issues. 

2 One is what goes on the label, and, obviously, we 

3 don't want two numbers on the label. It's very 

4 confusing, so we would want to work out, well, 

5 what's the most representative and what is the 

6 number that allows consumers to make the best 

7 comparisons with competing products. 

8 The second question is, well, you know, 

9 and then it comes up in a lot of different 

10 contexts. Well, I get all of this information 

11 about the test procedure, and I want to present 

12 that to consumers, or regulatory bodies, or 

13 whatever. So, in that situation, there probably 

14 wouldn't be any prohibition on you providing that 

15 information, say, in a brochure, but in these 

16 types of situations, where you've got these kind 

17 of competing metrics, you want to be very, very 

18 clear about what you're presenting, so people 

19 understand, well, this number comes from this 

20 particular part of the test, or this represents 

21 whatever conditions. 

22 It depends on what you're talking about. 
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1 You don't want to be in a situation where, 

2 because you've got different information and 

3 you're just throwing it out there you don't want 

4 to do it in a deceptive way. You want to make 

5 sure people understand where it's coming from. 

6 But for the label, obviously, we'd want 

7 to have a single thing. Ashley, is that -- 

8 MS. ARMSTRONG: Yep. That's great. 

9 Thank you. 

10 MR. BROOKMAN: We have several people who 

11 wish to comment. 

12 MS. ARMSTRONG: There's an open seat 

13 right by the mic, in case you want to -- 

14 [Laughter.] 

15 MR. BROOKMAN: I guess Christian and then 

16 to Nathan and then to Marianne. 

17 MR. TABER: Christian Taber, Big Ass 

18 Solutions. I keep trying not to say fans. As 

19 the test procedure is currently written, we'd be 

20 supportive of the way that it currently is, with 

21 the hugger rating and then the standard rating. 

22 That seems to make sense. 
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1 MR. BROOKMAN: As defined? 

2 MR. TABER: As currently defined. We're 

3 supportive of the 10-inch height. From our 

4 research on the fans that we pulled on the 

5 Internet, 10 seemed to be -- it would grasp the 

6 majority of the market, although maybe not 

7 everyone's. But from what we saw, that was the 

8 majority of the fans fell into that 10-inch 

9 distance. 

10 If the proposed change to testing all 

11 fans, based on diameter, and all small fans are 

12 Energy Star, and the false ceiling issue is 

13 addressed, that we'll bring up in a little bit, 

14 then the penalty for a hugger is not as dramatic 

15 as it currently is. The numbers do drop 

16 slightly, but they're not as dramatic. So it 

17 would be possible to potentially just eliminate 

18 the hugger classification entirely. 

19 MR. BROOKMAN: Nathan. 

20 MR. FRAMPTON: That's kind of where I was 

21 going to go to, because I think anybody disagrees 

22 with testing all these categories the same way. 
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1 So then the question is, would there be a 

2 different efficiency standard for these 

3 categories, and if the answer to that question is 

4 no, then this is almost all irrelevant. 

5 MR. BROOKMAN: Marianne. 

6 MS. DIMASCIO: My question was along 

7 those lines. If the huggers are less efficient, 

8 and you have a product with a 6-inch rod, and the 

9 amount of energy it will use on the box, but then 

10 you end up using a 3-inch rod and it uses a lot 

11 more electricity. So, that's the question. 

12 MR. BROOKMAN: Yeah. I see Nathan, 

13 Christian. Neither one of you -- you're shaking 

14 your heads, both of you. 

15 MR. TABER: Christian Taber. It's the 

16 same watts, less CFM, so the fan ends up 

17 producing less airflow for the same amount of 

18 power when it's placed closer to the ceiling. So 

19 the efficiency goes down but the wattage stays 

20 the same, more or less. 

21 MS. DIMASCIO: Part of it is, is the 

22 consumer getting enough information to make a 
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1 good choice, with what's on the label and with 

2 the purchase. 

3 MR. BROOKMAN: Dave. 

4 MR. GATTO: Dave Gatto, Westinghouse. 

5 Before I go there, just real quick, Ashley, I 

6 think the industry is consistent in defining 

7 huggers by the mounting configuration. I don't 

8 disagree with the proposal, but I think that 

9 we've always done it that way, and I think that's 

10 part of what you ran into when you were looking 

11 for consistency. 

12 So, in answer to your question, I think 

13 this is where Tim and Hampton were talking. If 

14 the consumer -- we can test it in a certain 

15 configuration, but some consumers like to have 

16 the option of, we included downrods that can go a 

17 shorter distance, or even close to ceiling. 

18 There's also the ability for a consumer to buy a 

19 downrod from somebody else and then install it 

20 with the fan. All of those height changes change 

21 the CFM. They don't change the amount of energy 

22 the fan uses, so there's no additional watts 
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1 used. But that's really application-driven. 

2 So I think that if -- again, FTC will 

3 definitely be weighing in on how that looks, and 

4 he's already asked for information from us on 

5 what the label would look like. The consumer is 

6 going to have as much information as they need to 

7 make a good choice, in the intended application. 

8 If they decide to use it differently, I think the 

9 challenge for industry will be we don't have way 

10 to tell them what the result would be, because we 

11 don't know the room size. They go and buy a 12-

12 foot downrod from somebody and hang it from a 

13 cathedral ceiling, it changes things. But the 

14 actual watts used don't change at all. 

15 MR. BROOKMAN: Okay. Additional comments 

16 related to these proposed definitions? I think 

17 we haven't gained clarity yet. Christian. 

18 MR. TABER: Just one quick one. 

19 Christian Taber, Big Ass Solutions. I think that 

20 including the information for both would be 

21 useful to the end user, so that they would know 

22 the ramifications of their decision to take a 
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1 multi-mount fan and mount it in a hugger 

2 configuration, essentially that they would be 

3 reducing the airflow and the utility of that 

4 product, in the name of safety or some other 

5 aesthetic reason for why they'd want the fan less 

6 than 10 inches from the ceiling. 

7 MR. BROOKMAN: Nathan. 

8 MR. FRAMPTON: Nathan with Fanimation. I 

9 agree with that. 

10 MR. BROOKMAN: Allen. 

11 MR. ROO: Allen with Emerson. The test 

12 procedure that you're proposing also doesn't 

13 account for blade warpage, which sometimes does 

14 occur in the package. We try to send our labs 

15 random samples. We never look at them. We send 

16 them up there, and they do come back sometimes 

17 with warped blades, and, therefore, they usually 

18 notify us. But if that doesn't happen, a fan 

19 that is on the margin of 10 or 12 inches may get 

20 categorized in the wrong category, due to blade 

21 warpage. I'd like to see something addressed 

22 that accounts for that. A certain percentage of 
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1 warpage? I don't know. 

2 MS. ARMSTRONG: I guess I don't 

3 understand why that's necessary. If it just 

4 happens, like there's an issue with blade warpage 

5 because of shipping or because of -- 

6 MR. ROO: Just the nature of the product. 

7 MS. ARMSTRONG: The nature of the 

8 product. 

9 MR. ROO: We're dealing with wood, and 

10 wood does what it wants to sometimes. 

11 MS. ARMSTRONG: Okay. So are you saying 

12 then that that happens to the majority of your 

13 products, so that it's more representative to -- 

14 MR. ROO: It happens, and random 

15 sampling, not really previewing the product as we 

16 send it to the lab, there could be issues with 

17 that. 

18 MR. BROOKMAN: And that's another reason 

19 why 10 inches isn't appropriate? 

20 MR. ROO: It may be a problem. It may 

21 miscategorize a product. 

22 MR. BROOKMAN: Say that again. What 
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1 would be -- 

2 MS. ARMSTRONG: You would be categorizing 

3 your product, right? So this is a definition for 

4 which a manufacturer would be responsible for 

5 declaring what type their product is. I assume 

6 that you would be able to do that, you know, 

7 either in your own lab, or if you had a product 

8 shipped out, you know what you've designed it to 

9 be. 

10 Now, that being said, yes, if DOE were to 

11 pick a unit and test it, and there were some 

12 questions, we would come have a conversation with 

13 you. We probably wouldn't just say, right out 

14 the gate, you're wrong. We would come have a 

15 conversation, and if you're like, "Oh, those 

16 blades are definitely warped. Let's look at 

17 another one." But I don't know if that 

18 necessitates having blade warpage included in the 

19 definition. 

20 MR. ROO: Okay. I agree. 

21 MS. ARMSTRONG: At least in my opinion. 

22 MR. BROOKMAN: Dave. 
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1 MR. GATTO: Dave Gatto, Westinghouse. 

2 I'm going to kind of go back to lamps for a 

3 minute. I think this is really the nominal 

4 versus manufacturing variation. I know you hate 

5 that. So, what I think Allen is saying, because 

6 I kind of agree with that, is that we have a fan 

7 and, as designed, it's 9-1/2 inches off the 

8 ceiling. Maybe in natural production sometimes 

9 it's 9-3/4, sometimes it's 9-3/8, but as you get 

10 close to that 10-inch -- and we have some stuff 

11 that's 10-1/4 and we have some stuff that's 9-3/4 

12 -- you could end up with a combination of events 

13 that, just in normal, high-volume manufacturing, 

14 puts the product that a single consumer receives 

15 into another product class. 

16 So what I heard you -- and I know that 

17 DOE has been good about this in the lamp 

18 category, so I'll acknowledge that -- if the 

19 nominal design is 10 inches or less, and you 

20 happen to pick a random sample, and you kind of 

21 said this, as long as what we submitted for 

22 testing in our design BOM and our drawings say 
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1 10, you would work with us. It wouldn't 

2 immediately become a compliance issue? 

3 MS. ARMSTRONG: I would say we would 

4 initiate a conversation with you, yes. You know, 

5 what I'm hearing around the table is there may 

6 need to be some wiggle room in the definition -- 

7 10 inches, plus or minus 1/2. I mean, something 

8 along that line, to acknowledge that there would 

9 be some variation, either from warpage, from the 

10 manufacturing line, whatever it is. But something 

11 that's small enough, so that the definition is at 

12 least meaningful, to provide a clear cutoff. At 

13 least that's the intent. 

14 MR. BROOKMAN: David. 

15 MS. ARMSTRONG: So, can I actually go 

16 back before -- 

17 MR. BROOKMAN: Yeah, please do. Let's 

18 close this. 

19 MS. ARMSTRONG: Do you want to comment on 

20 this warpage issue? Okay. So I'm going to go 

21 back to Nathan's comment, partially your comment, 

22 that has to do with, do we have a single test 
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1 procedure, kind of getting rid of -- a single 

2 methodology for all types of fans, but still 

3 allow for disclosure of information about what 

4 would happen if it's mounted closer to the 

5 ceiling, and the airflow is impacted but not the 

6 watts? 

7 Well, in effect, what you're asking is 

8 two different test procedures that give you two 

9 different numbers, to be able to make that 

10 disclosure. Now, that's not to say that you 

11 can't have a very similar methodology, but to 

12 show that differential impact of what would 

13 happen when the consumer installs them 

14 differently, because they are installed in 

15 different configurations and that does impact how 

16 they operate, by definition, we call that a 

17 different test method, in DOE's world. So maybe 

18 there's -- 

19 MR. TABER: Is it a different -- sorry. 

20 Christian Taber. Is it a different test 

21 procedure or is it just a different test? I 

22 mean, it's the same test procedure. It's just 
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1 one fan is tested at 3 inches and one is tested 

2 at 6 inches. I'm sorry. I just wanted to 

3 clarify. 

4 MS. ARMSTRONG: Sure. Yes. I think 

5 we're talking about the same thing. 

6 MR. TABER: They just have to run it 

7 twice. 

8 MS. ARMSTRONG: Correct. There could be 

9 a way to do this so that you don't have to run it 

10 twice and you could get two numbers out of the 

11 same test. Maybe that's the way we're going 

12 here. I don't know. No? 

13 MR. FRAMPTON: I actually think we're -- 

14 it's semantics, at this point. We're going to 

15 run the same -- we're going to use the same test 

16 procedure, but we're going to mount the fan the 

17 one, two, three different ways it could be 

18 mounted. So we'd have to run the test more than 

19 once, for the different configurations. 

20 MS. ARMSTRONG: But just setup would be 

21 different. Mounting would be different. 

22 MR. FRAMPTON: Right. The downtube would 
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1 be different. 

2 MR. BROOKMAN: Yes, David. 

3 MR. TURNER: Yes. David from Hunter. 

4 This is more just kind of a point of 

5 clarification, and maybe it's the names that 

6 we're using on this that's probably causing the 

7 confusion. So, if we have a fan that uses a 

8 downrod but the downrod that comes in the box is 

9 at 9-1/2 inches off the ceiling -- so it's a 

10 downrod-capable fan. It can be mounted on a 24-

11 inch downrod, but the downrod that comes in the 

12 box, with the fan, only brings the fan blades 

13 down to 9-1/2 inches off the ceiling. 

14 That would be classified as a hugger, 

15 correct? Okay. And I'm asking that because I 

16 think that's what's -- we call a hugger something 

17 that's directly bolted to the ceiling. This is 

18 classifying a hugger as completely something 

19 different. So I think that's probably a lot of 

20 the confusion, and maybe if just took the names 

21 off. 

22 MS. ARMSTRONG: Yep. Completely open to 
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1 suggestions of names. Completely open to A, B, 

2 Ashley, John, whatever we want to call them here. 

3 MR. TURNER: So just not names. Just 

4 definitions. 

5 MS. ARMSTRONG: Sure. The intent here, 

6 though, with this definition, was a definitive 

7 classification of what you guys called hugger. 

8 So perhaps we didn't get it quite right. Perhaps 

9 we did. I mean, we actually pulled all your spec 

10 sheets, that you say hugger, and we started doing 

11 measurements, so that's how we got to this 

12 definition. And, like we said, most of them fell 

13 in, in our opinion, most of them fell into this 

14 categorization. 

15 MR. TABER: Just to clarify, one of the 

16 issues that we would have with defining it as 

17 just directly mounted to the ceiling is that, 

18 with the exception of our multi-mount, all of our 

19 fans are directly mounted to the ceiling, so even 

20 our standard fan, which would not meet the 10-

21 inch definition, would be classified as a hugger, 

22 even though the blades would be roughly 16 inches 
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1 off the ceiling. So it's just a different 

2 design. It doesn't affect the utility but it 

3 would classify as a hugger if we used the direct4 mounted definition. 

5 MR. BROOKMAN: Okay. Have we covered it? 

6 Have we covered definitions now? Are there 

7 additional comments here. 

8 Okay. We're going to move on. Colleen. 

9 MS. KANTNER: Up next is the existing 

10 test procedure. Before proposing test 

11 procedures, DOE first examines existing test 

12 procedures. DOE's test procedures for ceiling 

13 fans are located at Appendix U to subpart B of 10 

14 CFR Part 430. The current DOE test procedure 

15 references Energy Star's guidance manual for 

16 testing ceiling fans, version 1.1, and that 

17 Energy Star test method is no long current. 

18 Now let's discuss the proposed metric. 

19 DOE proposes to apply a single metric based on 

20 airflow efficiency to all ceiling fans. For low21 volume ceiling fans, DOE is proposing to use a 

22 weighted average of airflow and power consumption 
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1 at high and low speeds. This is because testing 

2 at a single speed might limit representativeness 

3 and testing at two speeds avoids any ambiguity in 

4 testing ceiling fans with more than three speeds. 

5 Additionally, testing at three speeds would incur 

6 more cost burden than testing at two speeds. 

7 For high-volume ceiling fans, DOE is 

8 proposing to use the airflow and power 

9 consumption at high fan speed only. This is 

10 because high-volume ceiling fans often do not 

11 have discrete speeds, but rather have a speed 

12 controller that is continuously adjustable, so 

13 speeds other than high may not be well-defined. 

14 For all ceiling fans with standby 

15 functionality, and this includes ceiling fans 

16 with a light kit, DOE is proposing to incorporate 

17 standby power consumption into the overall 

18 airflow efficiency metric. 

19 DOE is not proposing to include off-mode 

20 power consumption in the metric, because DOE 

21 believes that ceiling fans do not consume power 

22 in off-mode. 
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1 And just to clarify what it is we mean by 

2 standby, EPCA defines standby mode as the 

3 condition in which an energy-using product is 

4 connected to a main power source, and offers one 

5 or more of the following user-oriented or 

6 protective functions: to facilitate the 

7 activation or deactivation of other functions by 

8 remote switch, internal sensors, or timer; and 

9 continuous functions, including information or 

10 status displays, or sensor-based functions. 

11 And off mode is the condition at which 

12 the ceiling fan is connected to a main power 

13 source and is not providing any standby or active 

14 mode function. 

15 In the metric for low-volume ceiling 

16 fans, DOE is proposing to weight the airflow and 

17 power consumption at high speed and low speed, 

18 according to the fraction of time spent at each 

19 speed. DOE considered hours of use data from 

20 both an AcuPOLL survey and a study conducted by 

21 LBNL. The AcuPOLL survey asked respondents for 

22 the single speed at which they typically operated 
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1 their fan, whereas the LBNL study asked 

2 respondents for the fraction of time they spent 

3 at each speed. Because the fraction of time 

4 spent at each speed is the relevant input in 

5 determining representative energy consumption for 

6 a ceiling fan, DOE used the disaggregated data 

7 set from LBNL. It sounds like there is more 

8 information, so it would be great to see the 

9 results of the new study. 

10 MR. TURNER: David from Hunter. I guess 

11 that should just be part of our written comment, 

12 and then it would be considered -- okay. 

13 MS. KANTNER: Definitely. 

14 MR. TURNER: So we'll make sure to -- 

15 MS. KANTNER: For high-volume ceiling 

16 fans, limited data were available, so DOE used 

17 feedback from manufacturers, indicating that 

18 while the hours of operation may vary 

19 significantly across industry and application, 12 

20 hours per day spent in active mode may be a 

21 representative value, and DOE welcomes any 

22 available data on operating hours for high-volume 
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1 ceiling fans. 

2 This table summarizes the hours of use 

3 weights DOE is proposing to use in the ceiling 

4 fan metric. Note that for ceiling fans with 

5 standby functionality, DOE assumes that the 

6 ceiling fan is always activated remotely, and 

7 thus is never in off-mode. 

8 And here is the equation, the efficiency 

9 equation for the metric. The top equation shows 

10 the efficiency metric for low-volume ceiling 

11 fans, where the numerator is the product of 

12 airflow and operating hours, summed over high and 

13 low speed, and the denominator is the product of 

14 standby power consumption and standby operating 

15 hours, added to the product of power consumption 

16 and operating hours, again, summed over high and 

17 low speeds. 

18 The bottom equation shows the efficiency 

19 metric for high-volume ceiling fans, and is the 

20 same as the metric for low-volume ceiling fans, 

21 except that only airflow and power consumption at 

22 high speed are included. 
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1 And now we have some issues for comment. 

2 DOE seeks comment on its proposed approach to 

3 incorporate standby power consumption into the 

4 efficiency metric for ceiling fans. 

5 MR. BROOKMAN: Dave. 

6 MR. GATTO: I need you fan guys to help 

7 me out here. Do we agree? Dave Gatto, 

8 Westinghouse Lighting. We agree. 

9 MR. BROOKMAN: Okay. Thank you. David? 

10 MR. TURNER: Dave Turner. I guess we 

11 need to get better at this, from Hunter, we 

12 agree. 

13 MR. BROOKMAN: Okay. Thank you. 

14 Affirmation is very useful. Thank you. Allen? 

15 Christian? Allen. 

16 MR. ROO: Allen with Emerson. We agree. 

17 MR. BROOKMAN: Thank you. Christian. 

18 MR. TABER: Christian Taber, Big Ass 

19 Fans, or Big Ass Solutions. Sorry. We sort of 

20 agree. Would it be possible to have a couple of 

21 slides go up? It's actually the last one. 

22 Generally speaking, we agree that standby energy 
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1 should be included -- it's the absolute last 

2 slide -- however, we do have a comment. It's not 

3 necessarily a negative or something else. It's 

4 just to beware of the ramifications. 

5 The inclusion of standby losses, in the 

6 way that they're currently done, if you took a 

7 minimally efficient fan, an 84 CFM per watt at 

8 high speed current fan, and you used the proposed 

9 metric, including high speed, low speed, and 

10 standby, that fan jumps up to about 89 CFM per 

11 watt. 

12 If you take a high efficiency fan, where 

13 the overall power consumption of the fan is 

14 dramatically less, which makes standby 

15 proportionally larger piece of the pie, that fan 

16 can drop by as much as 30 percent on its CFM per 

17 watt -- 13 for this one, by as much as 30, 

18 depending on the model. So what used to be a 

19 fairly wide spread for the apples-to-apples 

20 comparison, just dramatically decreases, and high 

21 efficiency products actually become a lower CFM 

22 per watt. So it's not necessarily bad. It's 
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1 just to be aware that it's compressing the 

2 difference between the perceived efficiency of a 

3 minimum and a perceived efficiency of a high. So 

4 it's not necessarily wrong or anything. It's 

5 just different. 

6 MS. KANTNER: Is there a suggestion about 

7 another way to handle this? 

8 MR. TABER: We will submit one. I don't 

9 have one, at this point. It just was -- we noted 

10 this right as we were getting ready to go, that 

11 when we started running the numbers on some of 

12 the premium efficiency products we had, their CFM 

13 per watts were dropping dramatically, and it was 

14 penalizing them, while the minimum efficiency 

15 products were actually seeing bumps up. 

16 MR. BROOKMAN: Interesting. Additional 

17 comments on standby power consumption? 

18 Thank you. Back to Colleen. 

19 MS. KANTNER: So the next item for 

20 comment is DOE seeks comment on its proposed 

21 approach to assign all standby power consumption 

22 for a remote receive that controls both a ceiling 
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1 fan and a light kit to the ceiling fan. 

2 MR. BROOKMAN: Christian. 

3 MR. TABER: Christian Taber, Big Ass 

4 Fans. We agree with that. 

5 MR. BROOKMAN: Okay. Other members that 

6 agree with that? Dave. 

7 MR. GATTO: Westinghouse Lighting. We 

8 agree with that. 

9 MR. BROOKMAN: Great. Okay. Keep going, 

10 Colleen. 

11 MR. CYMBALSKY: No, we'll take these 

12 comments. 

13 MR. BROOKMAN: Okay. We'll take these 

14 comments, as well. Bill. 

15 MR. WALKER: Bill with Hunter. We agree. 

16 MR. BROOKMAN: Thank you. 

17 MS. KANTNER: I think we discussed the 

18 next one a little bit, but does anyone else have 

19 a comment on the proposed operating hours for 

20 calculating ceiling fan efficiency for low-volume 

21 ceiling fans? 

22 MR. BROOKMAN: Marianne. 
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1 MS. DIMASCIO: I just have a comment. I 

2 wondered if Dave of Hunter could share on the 

3 daily operating hours for low-volume ceiling 

4 fans, just the basic numbers that you would put 

5 in there, so we would have that information. 

6 MR. BROOKMAN: And, Dave, will you get 

7 that close to your face, please? 

8 MR. TURNER: David Turner at Hunter. The 

9 question was asked, very similar to the LBNL 

10 study, if they had varying degree, or how many 

11 fans they had in their home, and from most used 

12 down to third-most, so there are varying 

13 percentages. We'll provide this in the 

14 commentary, but high was a range of 23 to 27, 

15 medium was 37 to 41, and low was 32 to 39. And 

16 we can throw out a summary in our written 

17 comments, but that's the raw data. 

18 MR. BROOKMAN: Do we have additional 

19 comments on operating hours? Christian? 

20 MR. TABER: I actually have a slide for 

21 this. I'm sorry. 

22 MS. ARMSTRONG: I also have a public 
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1 meeting on Friday, in case you want to come and 

2 present for me. 

3 [Laughter.] 

4 MS. ARMSTRONG: You're doing a great job. 

5 MR. TABER: Yeah. This is not my comfort 

6 zone. So, go to the next one. Sorry. 

7 When we looked at the LBNL study in more 

8 detail, we noticed that essentially medium and 

9 high were within 4 percent of each other. LBNL 

10 did not publish confidence intervals for those 

11 numbers, so we could not tell if they were 

12 statistically significant in their difference, 

13 but at a 4-percent difference, we did not feel it 

14 justified the use of high, especially given that 

15 all of the other studies provided by all of the 

16 manufacturers showed that medium was more 

17 typical, which has been our experience, as well. 

18 Do we want to go into the -- 

19 MS. KANTNER: Can you clarify what you 

20 mean by using high? 

21 MR. TABER: Using high as the basis of 

22 the metric. 
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1 MS. KANTNER: I mean, the reason for the 

2 high-volume fans was just a definitional issue, 

3 not -- 

4 MR. TABER: No. For high-volume, we're 

5 fine with using high speed. It's very difficult 

6 to define a speed for a high-volume fan, other 

7 than high, due to the variable frequency drives, 

8 or variable speed nature of the product. 

9 So, I guess, to kind of go to the next 

10 point, the other issue that we had was the use of 

11 -- sorry, back up a slide -- for using high speed 

12 as the rating -- down one; sorry. There we go. 

13 The issue we have with using high speed as the 

14 basis of rating is that it does not create an 

15 equal comparison. It would be the equivalent of 

16 rating a Porsche and a Prius at their top speeds, 

17 so it's as fast as it can possibly go. 

18 To get a true efficiency comparison, we 

19 propose specifying a CFM, say, 3,000 under the 

20 new metric, or 5,000 under the old, whatever it 

21 would be, and then making the manufacturer use 

22 their closest operating speed that exceeds that 
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1 number, somewhat similar to the way that Energy 

2 Star works right now for high speed. That would 

3 give a fair comparison for efficiency to perform 

4 a specific task, so to move X CFM requires this 

5 many watts, which would be a fair efficiency 

6 comparison, versus forcing a fan that may produce 

7 10,000 CFM to move 10,000 CFM, and a fan that 

8 moves 4,000 CFM to move 4,000 CFM. 

9 So, given a specific CFM, it gives a fair 

10 comparison for true efficiency of, to perform the 

11 given task. Next slide. 

12 We just noted the potential way that you 

13 could gain the current metric would be to take 

14 the fan on the right, 160 CFM per watt at high 

15 speed, to remove the top operating speed on that 

16 four-speed fan and make it a three-speed fan. 

17 You would decrease the CFM rating but you would 

18 take a closer to minimally compliant product and 

19 make it appear top of Energy Star, or near, 

20 simply by reducing the product's functionality. 

21 MS. KANTNER: Is there a recommended CFM 

22 at which you would test? 
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1 MR. TABER: It depends on which one we're 

2 talking about. Under the existing Energy Star 

3 test method, 5,000 CFM is the minimum required 

4 for high speed. We would propose using that 

5 number. Under the new metric, that would 

6 obviously have to be changed to whatever impacts 

7 that would have. 

8 MR. CYMBALSKY: This is John from DOE. I 

9 have a question with what you proposed. So, 

10 let's use your example. You do the 3,000 CFM. 

11 What if Brand X has low speed at 3,000 and Brand 

12 Y has medium speed at 3,000? Now, if I'm the 

13 consumer and if what you're saying is true, they 

14 all like medium. When it goes out into the home, 

15 the guy who designs the 3,000 at the low speed, 

16 the consumer actually is going to use it at 

17 medium speed. The label, in my opinion, the 

18 representation on the label, then, gets murky. 

19 I understand your comparison in the test, 

20 but -- 

21 MR. TABER: Ceiling fans are essentially 

22 operated to keep people comfortable, and so if 
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1 you have two fans that have two different 

2 performance levels, a 10,000 and a 3,000, if 

3 you're warm, you're going turn the fan up to 

4 provide a specific airflow. So, in a warm 

5 scenario in a house, 3,000 CFM out of both fans, 

6 theoretically, would provide equal comfort. So 

7 they would likely be running them, one at the 

8 speed that gives 3,000 and the other one at the 

9 speed that gives 3,000. 

10 This is where it gets wonky, and it's 

11 hard to really say it well, but I think 

12 efficiency defined as the same amount of work 

13 being done using a specific amount of power is 

14 just a much clearer way of doing things, versus -

15 - again, high speed for a Porsche, it is more 

16 fuel efficient than high speed for a Prius. In 

17 reality, when the person drives that car, the 

18 Prius is going to consume much less gas. 

19 MR. CYMBALSKY: I guess from the 

20 consumer's perspective, if the consumer knows 

21 what is the maximum wattage this thing is going 

22 to draw, and you do it that way -- 
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1 MR. TABER: But I don't think most 

2 consumers run their ceiling fan based on power 

3 usage. They run it off of what makes them 

4 comfortable. 

5 MR. CYMBALSKY: Right. But theoretically 

6 they could, and this goes back to the downrod 

7 example. You said exactly what I was going to 

8 say in response to the downrod example, that you 

9 do the 3 and the 6, the person is just going to 

10 adjust the speed to get the same level of airflow 

11 from the 3 that he can get from the 6. So that's 

12 why I think it's important to do both, in that 

13 case, as well. 

14 MR. BROOKMAN: Nathan. 

15 MR. FRAMPTON: This is Nathan with 

16 Fanimation. I really like where he's going and I 

17 agree with most of what he's saying. I think it 

18 makes a lot of sense. I think the Prius-Porsche 

19 example is on base. 

20 MR. BROOKMAN: Okay. Thank you. Yes. 

21 MR. GATTO: Dave Gatto with Westinghouse. 

22 Christian, I may ultimately agree with you but I 
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1 haven't had time to really think that through. 

2 But I think I disagree, at least from what I've 

3 seen so far, partly because I know FTC would 

4 probably weigh in. The primary value to the 

5 consumer that we tend to get asked is "What's my 

6 worst case?" and that's come up in some of our 

7 prior dialog with DOE. 

8 So the fact that they probably won't -- 

9 and I think, John, I asked you this question 

10 directly, way back when, and I got an answer 

11 different from the one I was hoping for -- some 

12 people just put their fan on high and they 

13 complain that they're cold. 

14 [Laughter.] 

15 MR. GATTO: So whenever you get into 

16 consumer experience, I get really nervous when 

17 we're trying to -- I think, hours, you kind of 

18 have to do if the analysis doesn't work. But my 

19 bigger fear would be, what would the test 

20 procedure look like with a fan that has three 

21 fixed speeds, versus variable speed. So now you 

22 might find that a fan that is at 4,990, at 
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1 medium, and 6,900 at high, but uses 30 percent 

2 more power at high, is going to be at a 

3 disadvantage, medium to medium, from somebody who 

4 is at 5,001 at medium. 

5 So I get nervous, and I don't know what 

6 the test procedure would look like, because that 

7 -- you almost have to test to see where you're 

8 hitting the CFM. So, that seems overly 

9 cumbersome. It could be that I'm just not 

10 understanding where you're at. 

11 MR. TABER: And that's exactly how Energy 

12 Star works, currently, is you have a minimum CFM, 

13 and then you test at your first speed that's over 

14 that. 

15 MR. GATTO: Specifically to qualify for 

16 Energy Star? 

17 MR. TABER: Right. 

18 MR. GATTO: But for the Energy Star test 

19 procedure that we use, we test at high, medium, 

20 and low, and provide CFM at those three values, 

21 along with CFM per watt. So, if this was purely 

22 a changing the Energy Star test procedure to 
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1 qualify for Energy Star, I'd probably be more in 

2 agreement, because (a) it's voluntary, and (b) 

3 there's a reason that I'm going down that path to 

4 qualify. But this is, for Westinghouse, anyway, 

5 this is more about what am I going to have to do 

6 for every fan that we manufacture, and what 

7 information do consumers need to know about it, 

8 that's also not going to run into a disclosure 

9 issue with FTC, where I think if we landed on 

10 we're only going to disclose medium, there would 

11 be pushback there. 

12 Because the actual potential consumer 

13 experience might be higher than what we publish, 

14 which is something that came up in the earlier 

15 discussion, when the EnergyGuide labels were 

16 first established, that there was a very -- and 

17 we agree with it, wherever you are, Hampton -- 

18 there's a very legitimate concern on FTC's part, 

19 that because a consumer could use it at high, 

20 they need to make the proper choice, that 

21 Marianne was talking about. They need to know 

22 what their cost would be at high. 
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1 MR. TABER: Right, but the blended rate 

2 that's being proposed wouldn't provide that. 

3 MR. GATTO: I agree with you, but we had 

4 earlier discussions where there was a point where 

5 we leaning towards publishing all three on the 

6 label. 

7 MR. TABER: Which I think we would 

8 support. 

9 MR. GATTO: Yeah, and I think FTC's 

10 position was -- and I don't want to speak for 

11 you, but you even said it earlier -- but I think 

12 part of what we heard back was that multiple 

13 points of information are too confusing. 

14 But I'm with you. We were in a place 

15 where, if we could disclose all three -- which, 

16 for a while we were doing, for California -- at 

17 least the consumer has that ability to choose, 

18 and compare the Prius to the Porsche. I think 

19 the challenge we have is that knowing the path 

20 that we've already gone down with the EnergyGuide 

21 label, this would be either a concern for FTC or 

22 more confusing to the consumer than we would want 
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1 it to be, if that makes sense. 

2 MR. TABER: My concern would be that if I 

3 can take a fan and just de-rate it to the point 

4 that it becomes premium efficiency, I decrease 

5 the usefulness of the product to the end 

6 consumer. They're going to rely more heavily on 

7 air conditioning than on ceiling fans, because 

8 the ceiling fan no longer functions. 

9 MR. GATTO: I don't know what to say to 

10 that -- Dave Gatto, Westinghouse -- other than 

11 that hasn't happened yet, and this is a pretty 

12 mature category. So not that there isn't an 

13 efficiency standard, but in the absence of an 

14 efficiency standard, that hasn't happened. I 

15 can't really see. 

16 I'm not saying that -- I know DOE's 

17 experience has been that products tend to, over 

18 time, drift towards the minimum efficiency level, 

19 but if the minimum efficiency level is above the 

20 bar that it is today, I don't have a concern 

21 about that. And consumers, they choose with 

22 their pocketbook. If they find a brand or a 
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1 product that is not delivering what they want, 

2 especially with Internet comments, then that fan 

3 won't be around very long. 

4 MR. BROOKMAN: Nathan, do you have a 

5 comment here? Allen? 

6 MR. ROO: Allen with Emerson. Currently, 

7 with the current FTC label, consumers look at the 

8 CFM value more than they do the efficiency value. 

9 With the proposed combined efficiency value, I 

10 know they're totally going to be confused. They 

11 won't understand it, other than to look at one 

12 fan and another and say, "Well, this is cheaper 

13 to operate." They want to know CFM. 

14 Will the new label include both CFM and 

15 the combined efficiency? 

16 MR. BROOKMAN: Hampton. 

17 MR. NEWSOME: Hampton Newsome, FTC. Our 

18 current proposal doesn't, because we don't have 

19 that information yet. DOE hasn't made decisions 

20 about it. We didn't propose anything like that. 

21 Under the new label, the primary disclosure is 

22 operating cost, and then CFM will be there, and 
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1 then the efficiency rating, which is probably 

2 less useful to the typical consumer, will be 

3 there, but it won't be that prominent. In terms 

4 of getting into the nuances of different 

5 efficiency ratings, that's not something that 

6 we've gone into. 

7 Obviously, the label -- just to back up a 

8 little bit, one of the general principles we work 

9 under -- and, obviously, everything I'm saying 

10 here, I'm speaking as an FTC staffer. I'm not 

11 speaking for the Commission. Generally, when 

12 we're designing labels, we want to make them 

13 simple, we want to make sure that the information 

14 allows consumers to compare competing product, 

15 and if there are key assumptions that are behind 

16 the label, of electricity rate, hours of use, 

17 what have you, we want to put that on the label, 

18 but we don't want to freight the label down with 

19 so much information that consumers might just 

20 tune it out. So it's kind of a balancing act 

21 that we're working on. 

22 MR. BROOKMAN: Okay. Thank you. Yes, 
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1 Dick. 

2 MR. UPTON: Hampton, thank you. Will the 

3 consumer -- do you have a problem in putting all 

4 three speeds on the box? 

5 MR. NEWSOME: That was proposed in 

6 comments, so that we haven't resolved that issue. 

7 In the original rulemaking, as was mentioned 

8 before -- this was, what, 8 or 9 years ago -- I 

9 believe that was discussed, and for the reasons 

10 that were mentioned earlier, we went with just 

11 that high speed. 

12 I believe another issue was the question 

13 of, if you were trying to put multiple speeds, 

14 whether all models had multiple speeds, and how 

15 that would be reflected in the label. That was 

16 another issue. 

17 But the answer to your question is that 

18 that issue is kind of on the table. 

19 MR. UPTON: Thank you. One of the things 

20 we pointed out to Hampton was our labeling 

21 ability on a ceiling fan box is not the same as 

22 the labeling ability on a refrigerator. That's 
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1 something we have to wrestle around with, too, 

2 because it makes a significant different to 

3 manufacturers, in being able to do that label and 

4 hopefully have it for one time. Because if 

5 you're talking about redoing and redoing, that 

6 becomes doggone expensive for us, as well. 

7 MR. BROOKMAN: Okay. Let's deal with 

8 operating hours for high volume ceiling fans. 

9 Additional comments on comment, Issue Number 8? 

10 Christian. 

11 MR. TABER: As the only high-volume fan 

12 manufacturer present, at least large diameter -- 

13 so the rating would be for 12 hours of operation 

14 at high speed, would be the FTC label number? 

15 That would be the annual power and energy? Is 

16 that right? Or would it be the -- because the 

17 math in the TSD was very different. It had a 

18 certain number of hours at certain speeds. It 

19 was very -- it was different than 12 hours at 

20 high speed, 365 days a year. 

21 MR. BROOKMAN: Do you remember? 

22 MS. ARMSTRONG: It would be whatever is 
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1 coming out of the test procedure, not 

2 necessarily. 

3 MR. TABER: So that would be 12 hours a 

4 day? So, I would say that represents a very 

5 worst case scenario. For 6 month of the year, 

6 average climate, most of the fans are running at 

7 about 30 to 25 percent of maximum RPM, which, 

8 with fan laws, puts it around 10 percent of 

9 maximum power. So we would be provided a very, 

10 let's say, conservative estimate of their annual 

11 power consumption. 

12 MR. BROOKMAN: That added data would be 

13 very useful -- 

14 MS. ARMSTRONG: Agreed. 

15 MR. BROOKMAN: -- for the Department. 

16 MR. TABER: We've submitted that already. 

17 MR. BROOKMAN: Okay. Thank you. 

18 Additional thoughts on operating hours for high19 volume? No? 

20 I think we're due for a break. Yes. 

21 It's now 11 o'clock. Let's not tarry here. 

22 Let's get back here at 11:15. So we'll start 
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1 crisply at 11:15. 

2 We've had a really good start on the day. 

3 We've covered a lot of ground, a very useful 

4 discussion. We'll continue that when we resume 

5 at 11:15. 

6 [Recess taken from 11:02 to 11:21 a.m.] 

7 MR. BROOKMAN: Let's resume. Okay, 

8 Ashley Armstrong to lead off. 

9 MS. ARMSTRONG: So, a couple of things. 

10 One is, we did get some feedback that a lot of 

11 you decided that you love spending so much time 

12 with the Department that you have flights, that 

13 you need to get out of here by about three-ish. 

14 So we're going to start, kind of, breezing 

15 through some of this stuff. Now, that's not to 

16 mention -- please feel free to stop us. Please 

17 feel free to chime in. 

18 Some of these slides I may just skip 

19 because, it's not that they're not important, but 

20 they're in your packet. Take them home. If you 

21 have questions, we can engage in a conversation 

22 after this or we welcome your comments, but there 
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1 are certain things that we would definitely like 

2 to tee up for discussion points, that, in my 

3 opinion, are more important than probably others, 

4 at least for us to have a discussion around. 

5 That's not to say that everything is not 

6 important for feedback on, as part of your 

7 written comments, or an afternoon dialog. Okay? 

8 MR. BROOKMAN: And, of course, if it's 

9 important to you, we want to hear it. Right? 

10 Okay. So we're going to proceed. 

11 MS. KANTNER: We're just going to move 

12 quickly through the proposed modifications to the 

13 current test procedure. DOE proposes to modify 

14 the current test procedure for ceiling fans to 

15 address the following issues... We'll just go 

16 through these on the slides anyway. 

17 First, DOE proposes to require testing at 

18 high and low fan speeds, for low-volume ceiling 

19 fans. I think we already discussed this. 

20 DOE proposes to eliminate the requirement 

21 to test with a test cylinder. 

22 MR. BROOKMAN: That's perhaps a little 
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1 too fast. Bill. But that was fast. 

2 MR. WALKER: That was real fast. 

3 [Laughter.] 

4 MR. WALKER: So the new testing method 

5 you're proposing, it would do away with the 

6 current Energy Star test method. Correct? 

7 MS. ARMSTRONG: Correct. 

8 MR. WALKER: Okay. So then there will be -- 

9 you're testing at two speeds. 

10 MS. ARMSTRONG: The proposal is two 

11 speeds. 

12 MR. WALKER: Yeah, high and low, at two 

13 speeds. What's the spec for what is Energy Star 

14 and what's not Energy Star, at this point? 

15 MS. ARMSTRONG: I think this is what we 

16 addressed earlier. At the conclusion of this 

17 process, in terms of once we make the final 

18 decisions about the test procedure, what speeds, 

19 how we test, once we get that squared away, in 

20 terms of what the actual ratings will look like, 

21 Energy Star will then initiate a process to 

22 revise their spec. I'm sure they will engage 
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1 with all of you about what those new levels 

2 should look like, and what will and will not be 

3 Energy Star. 

4 So this will go first, followed quickly 

5 by that. Amazingly enough, DOE and EPA do talk 

6 pretty regularly. 

7 MS. KANTNER: Any comments on the 

8 elimination of the requirement to test with a 

9 test cylinder? 

10 MS. ARMSTRONG: So -- go ahead. I do 

11 want feedback on this one. 

12 MR. BROOKMAN: Christian has a comment, 

13 and then we'll pick up others. 

14 MR. TABER: Christian Taber, Big Ass 

15 Solutions. We ran tests with and without in our 

16 lab and we did not see a significant difference, 

17 so we're completely supportive of the elimination 

18 of the cylinder. 

19 MR. WALKER: Bill with Hunter. We 

20 supplied data, from the last meeting, that I 

21 think I ran 30 tests or something. 

22 MR. BROOKMAN: And, as a consequence, do 
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1 you support this, or not? 

2 MR. WALKER: Do we support it? 

3 MS. KANTNER: I think you suggested it. 

4 MR. WALKER: Oh, absolutely. 

5 MR. BROOKMAN: Thank you. Nathan. 

6 MR. FRAMPTON: Nathan with Fanimation. 

7 We also support this. 

8 MR. BROOKMAN: Okay. Thank you. Okay. 

9 Then we're moving on. 

10 MS. KANTNER: DOE proposes to test all 

11 low-volume ceiling fans with the addition of a 

12 false ceiling directly above the ceiling fan. 

13 MR. BROOKMAN: Yes, Christian. 

14 MR. TABER: I'm sorry. This is the last 

15 PowerPoint slide. Christian Taber. Big Ass 

16 Solutions. We did a lot of testing regarding the 

17 addition of false ceiling for all ceiling fans. 

18 So, in our testing, we found that there was a 

19 decrease in performance that was achieved, due to 

20 the false ceiling, as well as the fan blades 

21 becoming closer to the ceiling, so we are 

22 supportive of the test procedure being more 
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1 representative of a home installation. I'm 

2 unaware of any home installations where there's a 

3 false ceiling that's 8 inches larger than the fan 

4 diameter, so we propose that rather than mounting 

5 to a false ceiling that is slightly larger than 

6 the fan, that the fan be mounted to the ceiling. 

7 The false ceiling basically blocks 

8 incoming airflow of the recirculation of the air, 

9 and about one-third of the reduction in the 30-

10 to-50 percent performance drop that would be 

11 witnessed with the new test, as DOE noted, about 

12 one-third of that is due to the fact that the 

13 blades are closer to the false ceiling or the 

14 actual ceiling. Two-thirds of it is due to the 

15 fact that the airflow is not allowed to reenter 

16 the top of the fan. It's blocked by the false 

17 ceiling, and essentially the fan has to start 

18 anew each time it starts to move air. So that 

19 decrease in performance is not representative of 

20 the real world, and it's unnecessary. 

21 MS. KANTNER: I think I can explain why 

22 it was that we did it this way. We wanted to 
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1 maintain a consistent distance between the fan 

2 blades and the air velocity sensors, and you 

3 can't change the height of the air velocity 

4 sensors easily, so the only option was the fan. 

5 MR. TABER: Go to the next slide. So 

6 when we changed the height of the air velocity 

7 sensors, on the right-hand side we saw data that 

8 was consistent. The red line is a standard 

9 ceiling fan mounted according to the current 

10 Energy Star. That gave the highest CFM and the 

11 highest CFM per watt. 

12 When we then moved that fan up to its 

13 actual standard mounting configuration and then 

14 used the same actuator device to just raise the 

15 sensor height, we got a decrease in performance 

16 that was very logical, and then, when we moved 

17 that into a hugger-type configuration, we saw 

18 another proportional and logical decrease in 

19 performance. That's the right-hand side. 

20 On the left-hand side, when we performed 

21 the same tests, we did not see nearly the same 

22 proportional decreases. There was a lot more 
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1 noisiness in the numbers and the data became 

2 skewed, so that it was much harder to tell what 

3 was going on. So, by raising the sensor heights 

4 and keeping that distance consistent, instead of 

5 varying the ceiling height, which was awkward, as 

6 well, and time-consuming, from a testing 

7 standpoint, we got much better and more 

8 consistent data. 

9 So we would propose mounting the fan to 

10 the ceiling, as it would be installed in the real 

11 world, and then adjusting the sensor height, 

12 rather than the false ceiling height, to account 

13 for that. 

14 MR. WALKER: Bill with Hunter. So you're 

15 saying keep the sensor-to-blade height the same, 

16 but adjust the test figure. 

17 MR. TABER: Exactly as DOE proposes. You 

18 just adjust the sensors up and down, based on 

19 where the fan is, and that way you're testing the 

20 fan mounted to a ceiling, like it really would be 

21 installed. 

22 MS. ARMSTRONG: So I agree, disagree. We 
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1 did get some feedback, originally, that there 

2 were some concerns mounting to the ceiling, so I 

3 would be interesting in hearing. 

4 MR. FRAMPTON: This is Nathan with 

5 Fanimation. I 100 percent agree. 

6 MR. BROOKMAN: Thank you. 

7 MS. ARMSTRONG: Okay. 

8 MR. BROOKMAN: Okay. Any other comments 

9 -- and, of course, a few written comments, also. 

10 Yes, Tim. 

11 MR. FLANNERY: I have a question, and I 

12 agree with the ceiling, as well, but is there any 

13 other requirements, as far as the room, i.e., 

14 size, openness, doors, closed doors? 

15 MR. BROOKMAN: Christian. 

16 MR. TABER: Christian Taber, Big Ass 

17 Solutions. We kept the exact same Energy Star 

18 setup that we had -- closed doors, air 

19 conditioning off, 20x20x11, roughly. The only 

20 thing we changed was the elimination of the false 

21 ceiling. 

22 MR. FLANNERY: So will there be a 
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1 requirement for actually rooms, so everybody is 

2 on a level playing field? Will there be a 

3 requirement as far as room size and application, 

4 whether it's 20x20 -- obviously, ceiling height 

5 is determined -- but do we all have to have 

6 testing in the same environment, because there 

7 are a number of factories here that are large 

8 enough, that are doing their own independent 

9 testing. So will there need to be a requirement 

10 for that? 

11 MR. TABER: I believe there's already a 

12 requirement, well, at least in the Energy Star 

13 test procedure, for room size. It's 20x20x11, 

14 with maybe a 6-inch variance either way. I don't 

15 remember the specifics. 

16 MR. FLANNERY: Okay. I was not aware of 

17 that. Okay. 

18 MS. KANTNER: I was wondering if the Hunter Fan 

19 folks could comment on how hard or how expensive 

20 it would be to change the air velocity sensor 

21 height versus the ceiling fan height. 

22 MR. WALKER: Bill with Hunter. Are you 
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1 asking how hard it will be? It will take some 

2 design work. We do our sensors a little 

3 different. If you look on the Energy Star 

4 website, that's our lab in those pictures, so 

5 instead of using one array and rotating it, we 

6 use four, so it will be a little bit more 

7 cumbersome to do that. 

8 MR. BROOKMAN: Christian. 

9 MR. TABER: Christian Taber, Big Ass 

10 Fans. That's actually the exact setup we have, 

11 as well as the four axes. We don't do the 

12 rotation. We found that the drop ceiling, 

13 specifically moving it up and down and keeping it 

14 level, especially when trying to test odd-shaped 

15 fans, it was very cumbersome to try to keep that 

16 in the same position, and level and flat, and it 

17 was much easier to just change the sensors. 

18 MS. KANTNER: Next, DOE proposes to 

19 define the vertical position of a ceiling fan 

20 with respect to the distance between the lowest 

21 point on the ceiling fan blades and the heads at 

22 air velocity sensors. Any comments on that? 
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1 MR. BROOKMAN: Comments here on these? 

2 Christian. 

3 MR. TABER: Christian Taber, Big Ass 

4 Fans. We're supportive of this. 

5 MR. BROOKMAN: Okay. Thank you. 

6 Additional comments? Additional comments before 

7 we move on. 

8 MS. KANTNER: Next, and I think this 

9 addresses an issue that came up earlier. DOE 

10 proposes to clarify that if there is more than 

11 one mounting option specified by the manufacturer 

12 that would meet the definition of a standard, 

13 low-volume ceiling fan, that ceiling fan should 

14 be tested in the configuration that minimizes the 

15 distance between the ceiling and the lowest part 

16 of the fan blades, and a similar clarification is 

17 proposed for hugger fans. 

18 MR. BROOKMAN: Yes, Dave. 

19 MR. GATTO: Dave Gatto, Westinghouse 

20 Lighting. We're in agreement with this. I think 

21 the only question would be, or maybe a piece of 

22 information for DOE, is that -- and I understand 
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1 that the reason for this is so that the least2 efficient configuration is the one that's tested 

3 and certified, which makes perfect sense to me. 

4 However, from a marketing standpoint, if we don't 

5 have the ability to show both ways, then it 

6 potentially would mean we would remove utility, 

7 because we remove the option. 

8 It sounds a little silly, I know, but I 

9 just want you guys to be aware that it 

10 potentially would mean that we wouldn't, at least 

11 for Westinghouse, we wouldn't necessarily include 

12 the option to change height from ceiling, which 

13 is a consumer utility that you're not really 

14 directly affecting, but this could cause us to 

15 choose not to include it. 

16 MS. ARMSTRONG: So is your ask that you 

17 be allowed to test in other ways, like, this is, 

18 at the very least, what you have to do, but you 

19 want the ability to test that at other heights, 

20 and potentially certify them as different basic 

21 models? Or what is the ask? 

22 MR. GATTO: So, it's interesting. Dave 
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1 Gatto, Westinghouse Lighting. I don't know if 

2 the ask is for you. It might end up being an FTC 

3 conversation, about what we can publish. Partly 

4 why I don't have an objection to this is because 

5 it will be an even playing field for everyone. 

6 We're all going to have the same results for the 

7 same performing fans. 

8 But when we start certifying data and 

9 there's an efficiency standard, there are rules 

10 around what we can claim outside of the 

11 certification database. So I'm just not sure if 

12 there's clarification you can give now, or if 

13 that's something that you've considered that, in 

14 the absence of clarification, we might publish 

15 information that then would be slightly 

16 different, because of the application, than 

17 what's in the database. 

18 MS. ARMSTRONG: So, I think that's a 

19 question specifically for Hampton, but I think, 

20 when you submit comments, think about it, because 

21 if DOE's test procedure requires testing in a 

22 specific configuration that's prohibiting testing 
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1 in other configurations, to the extent you do 

2 wish to be allowed to test in other 

3 configurations, we would need to know that, as 

4 part of the test procedure, not just 

5 representations. 

6 MR. GATTO: Okay. Thank you. 

7 MR. BROOKMAN: Okay. We're moving on. 

8 Oh, David. 

9 MR. TURNER: David with Hunter. So if a 

10 fan qualifies as multi-mount, meaning standard 

11 and hugger, it would need to meet the efficiency 

12 metric, as defined for hugger and standard. Is 

13 that correct? 

14 MS. ARMSTRONG: Yes. 

15 MR. TURNER: Okay. I wanted to clarify. 

16 MS. KANTNER: DOE proposes to clarify 

17 that during testing, any heater package with the 

18 ceiling fans should be installed in case it might 

19 affect airflow, but the heater should be switched 

20 off. 

21 MR. BROOKMAN: Comments on this? 

22 MR. TURNER: Hunter agrees. 
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1 MR. BROOKMAN: Hunter agrees. Okay. 

2 Thank you. That was David. Additional thoughts, 

3 comments? Okay. Moving on. 

4 MS. KANTNER: DOE proposes to change the 

5 sensor tolerance from the current test procedure 

6 value of 1 percent to 5 percent. 

7 MR. WALKER: Bill with Hunter. The 

8 current Energy Star test method has 5 percent in 

9 there, version 1.2, I think it is. 

10 MR. BROOKMAN: Okay. So you're 

11 supportive of this? Yes. 

12 MR. WALKER: And I think this will 

13 probably come later. There has to be some sort 

14 of round-robin testing, though, between the labs, 

15 to make sure all the labs correlate. It's out of 

16 hand right now. 

17 MR. BROOKMAN: Okay. Thanks for that. 

18 MS. ARMSTRONG: I will mention, just with 

19 that introduction, DOE has been engaging a 

20 variety of different industries to do round-robin 

21 testing. We would be interested in setting 

22 something up with all of you, if you would be 
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1 willing. 

2 MR. TABER: We would be supportive of 

3 that. Christian Taber, Big Ass Fans. 

4 MR. BROOKMAN: Okay. Thank you. Thanks 

5 to both of you. Okay. 

6 MS. KANTNER: And now let's move on to 

7 the proposed additional test methods, and we'll 

8 go through these one by one anyway. 

9 DOE proposes to test low-volume, multi10 mount ceiling fans in two configurations, in the 

11 standard configuration and in the hugger 

12 configuration, and in both cases it's the 

13 configuration that minimizes the distance between 

14 the ceiling and lowest part of the fan blades 

15 that meets the definition for that configuration. 

16 Any comments? 

17 MR. BROOKMAN: Thoughts on this? 

18 Comments? Bill. No. Okay. I guess there's no 

19 comments. 

20 MS. KANTNER: DOE proposes to measure 

21 airflow of multi-headed fans by testing a single 

22 fan head, with that fan head in the same position 
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1 as the fan head is in when it's just a single fan 

2 head being tested, such that it is directly over 

3 the central sensor. 

4 MR. FRAMPTON: This is Nathan with 

5 Fanimation. We agree. 

6 MR. BROOKMAN: Okay. Thank you. 

7 MS. KANTNER: DOE proposes to measure 

8 power consumption of multi-headed ceiling fans at 

9 a given speed with all ceiling fan heads turned 

10 on. 

11 MR. BROOKMAN: Nathan. 

12 MR. FRAMPTON: Nathan with Fanimation. We 

13 agree. 

14 MR. BROOKMAN: Thank you. 

15 MR. CYMBALSKY: This is John from DOE. 

16 Who makes this fan? That's pretty cool. 

17 [Laughter.] 

18 MR. MATTHEWS: Chuck Matthews, Matthews 

19 Fan Company. I also agree. 

20 [Laughter.] 

21 MR. FLANNERY: Tim Flannery, Minka. We 

22 agree, as well. 
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1 MS. KANTNER: DOE proposes to clarify 

2 that for ceiling fans with non-vertical airflow, 

3 the ceiling fan head should be adjusted such that 

4 the airflow is as vertical as possible prior to 

5 testing. If a ceiling fan cannot achieve 

6 vertical airflow, DOE proposes to orient the 

7 ceiling fan such that any remaining tilt is 

8 aligned along one of the four sensor axes, and 

9 then air velocity should only be measured along 

10 that axis, and the axis oriented 180 degrees with 

11 respect to that axis, and then airflow would be 

12 measured along the -- would be calculated based 

13 on the continuous set of sensors with the largest 

14 air velocity measurements. This little 

15 illustration here is supposed to indicate how 

16 that might shift for a fan with a tilt. 

17 MR. BROOKMAN: Yes, Bill. 

18 MR. WALKER: Bill with Hunter. We don't 

19 really have a dog in this hunt, but it doesn't 

20 mean we might not at some point in time. It 

21 seems kind of ambiguous to me that the airflow 

22 should be calculated based on the continuous set 
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1 of sensors with the largest air velocity 

2 measurement. Where do you cut it off at? What 

3 do you say -- okay, I'm going to use this sensor 

4 but I'm not going to use this one, because, I 

5 mean, it's a curve there. 

6 MS. KANTNER: The number of sensors is 

7 defined by the size of the fan. It would be same 

8 as -- 

9 MR. WALKER: So you're still going to use 

10 fan that -- okay. 

11 MS. KANTNER: Exactly. You're just 

12 allowing that to shift, in case that -- you've 

13 got a different set that are maximizing the 

14 airflow. 

15 MR. WALKER: Eight inches larger than the 

16 -- 

17 MS. KANTNER: Exactly. 

18 MR. WALKER: Okay. 

19 MR. BROOKMAN: Okay. Nathan. 

20 MR. FRAMPTON: Nathan with Fanimation. 

21 We agree. 

22 MR. BROOKMAN: Thank you. Okay. 
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1 MS. KANTNER: DOE proposes to calculate 

2 high-volume ceiling fan efficiency based on 

3 airflow and power consumption at high speed. For 

4 ceiling fans up to 24 feet in diameter, DOE 

5 proposes to test high-volume ceiling fans using a 

6 test procedure based on AMCA 230. 

7 MR. GATTO: Dave Gatto, Westinghouse 

8 Lighting. I was just going to second Christian's 

9 earlier comment that for fans less than 7 feet, 

10 that they're tested in the same test method 

11 procedure as what you're calling low-volume 

12 ceiling fans. 

13 MR. BROOKMAN: Yes. Christian. 

14 MR. TABER: Christian Taber, Big Ass 

15 Solutions. Obviously, I'm going to agree with my 

16 own previous comments on this. In addition, AMCA 

17 230 is currently in a revision process. The 

18 committee is, I would say, dramatically changing 

19 the standard to make it much more usable and 

20 consistent. There are words like "mental 

21 averaging" and things in the current version of 

22 the standard that are a little less than maybe 
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1 ideal for a DOE test standard to be used. 

2 I would highly recommend that either the 

3 new version of the standard, if it's published in 

4 time, or at least the language from the new 

5 version of the standard be used. I don't know on 

6 the timing of the actual publication of 230-14 or 

7 -15, whenever it makes it out of the ANSI 

8 process, but there are a lot of useful changes 

9 that the committee has put together on it, that 

10 would make it much more consistent and usable 

11 test. 

12 And the other comment is, there is a 

13 proposed change to this that says AMCA 230, but 

14 with different room sizes. The room sizes 

15 proposed by DOE are different than the room size 

16 change proposed by the 230 committee. I would 

17 ask that those two numbers be aligned. 

18 MS. KANTNER: Are the numbers proposed by 

19 the 230 committee publicly available? 

20 MR. TABER: Yes. No, actually, no. 

21 They're not publicly available, but they are 

22 available from AMCA themselves. AMCA did not 
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1 send a representative, but they would like to be 

2 a part of it. 

3 MR. BROOKMAN: Okay. Additional 

4 thoughts, comments here? 

5 MS. KANTNER: I think your previous 

6 comment sort of gets at this slide. These are 

7 DOE's proposals to modify the specified room 

8 dimensions for high-volume ceiling fans in the 

9 following ways. I think we've already talked 

10 about that. 

11 MR. BROOKMAN: So, Christian, you're 

12 supportive? 

13 MR. TABER: I am not supportive of the -- 

14 Christian Taber, Big Ass Solutions. I am not 

15 supportive of the proposed dimensions, for 

16 example, the 44-inch minimum height clearance 

17 above blade would result in at least two of our 

18 models being starved and producing insufficient 

19 airflow. The clearance above the blades is 

20 generally larger for larger ceiling fans. There 

21 are several manufacturers that would not have 

22 optimal performance with the 44-inch clearance. 
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1 So, again, I would point to the AMCA 230 

2 revisions for suggested room heights. 

3 MR. BROOKMAN: Okay. Thank you. 

4 Additional thoughts here? Yes. 

5 MR. GATTO: Dave Gatto, Westinghouse. I 

6 won't dispute that with Christian. I'm not 

7 really sure, but it could potentially affect 

8 that. But I do agree with the greater than 10 

9 foot for ceiling fans with blade fans of 6 feet 

10 or greater. We don't currently play in that 

11 particular one, but there are products that are 

12 under consideration, that I think that's an 

13 appropriate height. 

14 MR. TABER: And I would -- if the 

15 proposed change were accepted, to just all fans 7 

16 feet in diameter or less, via the Energy Star 

17 method, then I would obviously suggest that that 

18 number change to greater than 7 feet. 

19 MR. BROOKMAN: Okay. 

20 MS. KANTNER: DOE proposes to test 

21 standby power consumption in ceiling fans with 

22 standby functionality for both low-volume and 
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1 high-volume ceiling fans. 

2 MR. BROOKMAN: Christian. 

3 MR. TABER: Christian Taber, Big Ass 

4 Solutions. One of the reasons for standby mode 

5 is controls. Ceiling fans without complex 

6 controls options or remotes really have no 

7 standby power. Looking at our product line, we 

8 have a fan with an occupancy sensor, and one of 

9 the reasons it has standby power consumption is 

10 because of that occupancy sensor. 

11 Looking at the LBNL study, or survey that 

12 was used for the high and low speed, there is a 

13 section on it, on the operation of ceiling fans 

14 when no one is present in the room, and it showed 

15 that more than half of ceiling fans are run 

16 during hours when no one is in the space. If a 

17 penalty is to be imposed for standby power 

18 consumption for controls, we would also propose a 

19 credit be given for controls that reduce the 

20 unnecessary operating hours of a fan. 

21 Yesterday, in the lighting discussion, 

22 was there any talk on occupancy sensors and a 
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1 credit for that? 

2 MR. BROOKMAN: I don't think so. 

3 MS. ARMSTRONG: So, the answer is no 

4 because what we've proposed for light kits is a 

5 lamp efficiency other than luminaire, for most 

6 parts, so the test procedure isn't reflective of 

7 the controls, at this stage, although there was 

8 some discussion about whether it should be. 

9 MR. TABER: Okay. And if it's just a 

10 lumens per watt, then that would maybe not make 

11 sense. But for ceiling fans, since we're eating 

12 all of the standby power of the unit, I would 

13 propose that there be some sort of credit given 

14 if there was a way to reduce annual operating 

15 hours, via something like an occupancy sensor. 

16 MS. ARMSTRONG: Okay. So we had the same 

17 question. What is the delta for adding occupancy 

18 sensor, in terms of wattage, for standby mode? 

19 MR. TABER: I'm a mechanical engineer -- 

20 MS. ARMSTRONG: Me, too. 

21 MR. TABER: -- and so I would have to ask 

22 some -- 
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1 MR. CYMBALSKY: You can use a watt meter. 

2 MR. TABER: If an electrical is holding 

3 it, yes, I can use a watt mater. I don't 

4 actually know that. We can definitely provide 

5 that information. 

6 MS. ARMSTRONG: That would be great. 

7 MR. BROOKMAN: Okay. Thank you. 

8 Additional comments before we move on? Okay. 

9 MS. KANTNER: Now we're moving on to the 

10 effective date and compliance date. The 

11 proposals for amending Appendix U would not 

12 affect a manufacturer's ability to comply with 

13 current energy conservation standards because DOE 

14 does not currently have performance-based 

15 standards for ceiling fans, as measured by 

16 airflow efficiency. 

17 DOE expects that any final rule will be 

18 in effect 30 days after publication of the test 

19 procedure final rule in the Federal Register. 

20 Revised Appendix U must be used to determine any 

21 representations of efficiency 180 days after the 

22 publication of any final amended test procedures. 
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1 MR. BROOKMAN: Dave. 

2 MR. GATTO: Dave Gatto, Westinghouse. We 

3 don't need to go through the whole thing again. 

4 That revised Appendix U, though, I understand 

5 it's in the statute. We would really appreciate, 

6 as industry, some clarification on how that would 

7 be applied, because I think that does create a 

8 scenario where even if DOE is in agreement with 

9 the extended timeline needed to meet the 

10 compliance date, if we can't represent the 

11 product performance, which is required under FTC, 

12 we're kind of back in the soup again. 

13 MS. ARMSTRONG: I think Hampton clarified 

14 the fact that the 180-day time frame is in the 

15 statute, for changing over representations. I 

16 think what we need to hear from industry -- and I 

17 think you somewhat addressed this this morning -- 

18 your ask is a year before compliance with amended 

19 standards, should DOE end up promulgating amended 

20 standards as part of this latter half of this 

21 rulemaking effort. But to the extent anyone has 

22 comments on that, please submit them in writing. 
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1 And then to answer the inventory 

2 question, you know, it is my understanding -- and 

3 Hampton is not here anymore -- just like DOE's 

4 regs, it's with date of manufacture. So the date 

5 of manufacture is synonymous with date of 

6 importation, which is important in this space. 

7 MR. BROOKMAN: Can you hang on a second. 

8 Tim, she's answering the inventory question. 

9 MS. ARMSTRONG: It's okay. So, I think 

10 that, it's my understanding, and we can get 

11 Hampton to confirm this, but that the dates are 

12 synonymous with date of manufacture, so if 

13 representations have to be changed over within 

14 180 days, that would be starting for manufactured 

15 beginning 180 days after that point and going 

16 forward, and that's also including date of 

17 importation. 

18 So you would be okay as long as things 

19 are inventory here and cleared, but newly 

20 manufactured, newly importing starting that date, 

21 whatever that date may be, would be subject to 

22 the new requirements. Okay? 
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1 MR. BROOKMAN: Okay? Nathan. 

2 MR. FRAMPTON: Did we sufficiently make 

3 our case that we need a lot more time? 

4 [Laughter.] 

5 MS. ARMSTRONG: So, I would say your 

6 concerns have been well heard. Now, what the 

7 statute allows, we need to go back and look at 

8 the statute, and look at the language, and see, 

9 given your concerns and given what you've said 

10 today, what DOE has the flexibility of doing. 

11 MR. BROOKMAN: Terry. 

12 MR. MCGOWAN: You don't have to answer 

13 this right now, but I would like to go back to 

14 the previous slide, if that's appropriate, and 

15 I'm sorry to do this, but I didn't want the 

16 moment to go by without recalling the discussion 

17 we had yesterday, in a little more detail, 

18 regarding controls, and I would like to see a 

19 placeholder here for incorporating the effective 

20 controls in both lighting and in fans, so that we 

21 understand that future energy savings, as 

22 efficiencies and efficacies peak out, are going 
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1 to have to come from controls, and we should 

2 consider carefully about including controls and 

3 their effects, in some way, in this rulemaking. 

4 And we can comment on that and propose 

5 some ways, but I want to be sure it's there. 

6 MR. BROOKMAN: Okay. Thank you. 

7 Christian. 

8 MR. BRUNDAGE: Don Brundage, Southern 

9 Company. Just a suggestion. I'm trying to look 

10 for ways to fit within the statute. Since you're 

11 going to have several classes of products, if you 

12 potentially said Class A of a product needs to 

13 use the new test procedure on this date, and 

14 issue a test procedure ruling later for a 

15 different class of product within ceiling fans, 

16 that might get you within the letter of the law 

17 and reduce the burden on the manufacturers. 

18 MS. ARMSTRONG: Okay. 

19 MR. BROOKMAN: Christian: 

20 MR. TABER: Christian Taber. I actually 

21 had a question for Don. Do you remember, in 

22 90.1, ASHRAE Standard 90.1, building energy code, 
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1 what the credit is for occupancy sensors on 

2 lights when not required? Is it 10 percent? 

3 MR. BRUNDAGE: It's something like that. 

4 I don't recall. 

5 MR. TABER: Okay. So just looking for 

6 something that we could maybe reference for that 

7 Standard 90.1 is energy code for nonresidential 

8 buildings more than three stories, so that might 

9 be a useful place to look. 

10 MR. BROOKMAN: Okay. Thank you. I think 

11 we're on effective date. Yes, David. 

12 MR. TURNER: David from Hunter. 

13 Actually, you say date of import is the correct 

14 kind of cutoff? So -- and I just want to get my 

15 head right here. So, import from China to 

16 hitting the coast here is 30 to 45 days. So, 

17 that would actually mean we need to be shipping 

18 prior to the actual implementation or the final 

19 rule being -- okay. 

20 MS. ARMSTRONG: You wouldn't necessarily 

21 need to be shipping, right? I mean, effective 

22 date of 30 days, but you would have 180 days to 
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1 change over representations. So after that 180-

2 day mark, which would give you plenty of days to 

3 ship, 180 days from the publication of the test 

4 procedure final rule, is what Hampton clarified 

5 earlier, when the statute requires 

6 representations turnover. 

7 Now, this is all pending what we end up 

8 doing in the final rule, but it's the 180-day 

9 window you need to be concerned with. The 30-day 

10 window means you can start using the test 

11 procedure, for lack of a non-lawyerfied way of 

12 saying it. 

13 MR. BROOKMAN: Dave. 

14 MR. GATTO: Just real quick, because I 

15 think you know where we're at. Dave Gatto, 

16 Westinghouse Lighting. The challenge that 

17 creates is that we really can't start using it 

18 because we don't know, officially, that it's 

19 official until it's done. If we all submitted 

20 all of our products that needed testing so that 

21 we can provide proper representation values in 

22 that first 30 days, we would have to have results 
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1 on all of those models within the next 60 days, 

2 high side, to be able to meet the importation 

3 date that the 180-day provision requires. 

4 So, I know that -- I just really want to 

5 make it as clear as possible that anything that 

6 FTC and DOE and Laura, who is still here 

7 somewhere, can do -- and we'll include it in the 

8 comments, but the challenge it creates is it 

9 could create a shortage of supply of the product, 

10 so the consumer impact is going to be that they 

11 wouldn't be able to get any ceiling fans for some 

12 period of time, potentially an extended one. 

13 MS. ARMSTRONG: So, your concerns have 

14 been heard. I think, just by one ask, and this 

15 is in response to Nathan's question if, "Ashley, 

16 do you have all the information you need to 

17 know?" if, in your comments, you can talk about -

18 - you know, obviously, this is pending on how we 

19 end up finalizing the test procedure, but to the 

20 extent your numbers would look different -- I'm 

21 going to make up something -- but a ceiling fan 

22 would be rated at 10 now, and will become rated 
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1 at 8, that would be helpful. 

2 What is the magnitude of the changes 

3 we're talking about? Is everything going to look 

4 different, or is it just a different methodology 

5 but the numbers are going to look the same. 

6 That's something that I think we -- that's a 

7 piece of information, a piece of the puzzle that 

8 also would be helpful in this space. 

9 MR. GATTO: Dave Gatto, Westinghouse. I 

10 just want to make sure that I understand. So for 

11 new models, obviously, there is no 

12 representation. It's first test data. But for 

13 existing models -- 

14 MS. ARMSTRONG: So this would be for 

15 standard ceiling fans. 

16 MR. GATTO: Anything that we're already 

17 representing -- 

18 MS. ARMSTRONG: It's not relevant for 

19 hugger fans, because it's our interpretation that 

20 you guys don't test, currently, hugger fans. We 

21 had previously said they do not meet the 

22 definition. They're not tested. You're not 
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1 making representations. The test procedure is 

2 not applicable to them. 

3 MR. GATTO: So -- Dave Gatto, 

4 Westinghouse. I'm not sure if what you're saying 

5 is we wouldn't need to provide information on 

6 hugger fans until the final rule? 

7 MS. ARMSTRONG: So, I'm saying the change 

8 -- it is my opinion here that the changes in 

9 representation, the changes in the numbers is 

10 irrelevant for hugger fans. 

11 MR. GATTO: Right. There would be no 

12 change from representation. 

13 MS. ARMSTRONG: There would be a -- your 

14 concerns with that one would be I have to now 

15 test them -- 

16 MR. GATTO: Okay. 

17 MS. ARMSTRONG: -- and then I have to 

18 comply with the design standards. What does that 

19 do? However, it's not about -- for standard fans 

20 it would be, I now have to retest them, and what 

21 do the new ratings look like. 

22 MR. GATTO: Okay. Yeah, that helps me. 
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1 Thanks. I wanted to make sure I was really clear 

2 on that. 

3 MR. BROOKMAN: Christian. 

4 MR. TABER: Christian Taber, Big Ass 

5 Solutions. So just to clarify, you want someone 

6 to run a standard ceiling fan under the current 

7 test now, and then under the new, proposed tests 

8 and see what the delta is, CFM per watt? 

9 MS. ARMSTRONG: Roughly. Yeah. I mean, 

10 are we talking 5-percent change or are we talking 

11 10-percent change, or are we talking some are the 

12 same, some are different? It gets to the 

13 magnitude of the percentage of models that would 

14 necessarily have to -- 

15 MR. TABER: The slide that I had up 

16 earlier -- 

17 MS. ARMSTRONG: Yes. 

18 MR. TABER: -- we saw a 30 to 50 percent 

19 reduction in CFM per watt by the new test method, 

20 so roughly half. 

21 MR. BROOKMAN: Okay. Did we do this 

22 sufficiently? 
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1 MS. ARMSTRONG: Yes. 

2 MR. BROOKMAN: I remember it now. Okay. 

3 MS. ARMSTRONG: Actually, let me speak to 

4 the next two slides, because I'm going to go 

5 through these pretty quickly. This is something 

6 I touched on yesterday, for those that were here. 

7 One of the parts of DOE regulations that often 

8 gets overlooked is the fact that we do have 

9 sampling procedures that govern how you make 

10 represented value. 

11 What that means is two things. It says 

12 how many units you must test of each basic model, 

13 and then what is the associated tolerance that 

14 you must apply to your raw test results for 

15 individual units to come up with the readings 

16 that then you would certify, put on disclosures, 

17 use for Energy Star. 

18 So I just want to introduce this. I'm 

19 not going to go into it, but what's important is 

20 the confidence limit, and what the confidence 

21 limit is meant to say is to account for the 

22 variability experience, not only in the test 
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1 procedure but things coming off of the 

2 manufacturing production line, if you do see 

3 variability, like wood warping, or whatever. 

4 So that's something we would be 

5 interested in your feedback on. We've at least 

6 proposed that you have to test no less than two 

7 units. You may test more, at your discretion, 

8 but you at least have to test two for each basic 

9 model. So this wouldn't be a single-unit test to 

10 get a number, and that's the number you use. 

11 That's now how this works for DOE regulatory 

12 purposes. 

13 MR. BROOKMAN: Any questions on the 

14 sampling slide? 

15 MS. ARMSTRONG: This is a difference. 

16 Two fans, two speeds is the proposal, per what we 

17 call basic models. It's not every model but it's 

18 for basic model. You can do some groupings in 

19 there, if you'd like. 

20 MR. BROOKMAN: Bill. 

21 MS. ARMSTRONG: My favorite topic. I had 

22 to go there. I did have a slide on it. So, in 
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1 DOE's rating regulations, DOE allows 

2 manufacturers to group individual models into 

3 this thing we call basic model, and what it 

4 allows you to do is reduce your testing burden, 

5 because you only have to test two units per basic 

6 model, or at least two. You can test more if 

7 you'd like, but at least two. 

8 But, typically, the easiest way to do 

9 this is different finishes. Non-efficiency 

10 attributes, and even small changes in efficiency 

11 attributes that you don't want to claim, it 

12 allows you to group them for the purposes of 

13 reducing your testing burden. 

14 Now, the only caveat I will say, just so 

15 that you're all aware, is if you do do groupings, 

16 if DOE were to test one and find one non17 compliant, which, hopefully, would never occur in 

18 this space, it would affect all the models in 

19 that group. Basically, you're representing, this 

20 is the group's efficiency. 

21 And, so, some people in other industries 

22 have found this of particular interest to them, 
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1 as a way of significantly reducing your testing 

2 burden. We leave that at your discretion. 

3 MR. BROOKMAN: Okay. 

4 MS. ARMSTRONG: We can have a whole other 

5 day on that topic later, if you'd like. 

6 [Laughter.] 

7 MR. BROOKMAN: Okay. 

8 MS. ARMSTRONG: So you can just move on 

9 to Slide 51. 

10 MS. KANTNER: Did you want to talk about 

11 this, or should I continue? 

12 MS. ARMSTRONG: It doesn't matter. You 

13 can do it. 

14 MS. KANTNER: Okay. DOE prepared an 

15 initial regulatory flexibility analysis for this 

16 rulemaking which describes the potential impact 

17 on small businesses associated with ceiling fan 

18 testing requirements. DOE estimated that there 

19 were between 25 and 35 small business 

20 manufacturers of low-volume ceiling fans and 

21 between 15 and 25 small business manufacturers of 

22 high-volume ceiling fans. 
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1 The current DOE test procedure doesn't 

2 specify the number of speeds to be tested, so we 

3 compared the proposed DOE test procedure to the 

4 current Energy Star test procedure, and the 

5 differences between those two test procedures are 

6 listed here, along with estimates of what the 

7 differential impact will be. 

8 In total, DOE estimates that the test 

9 cost per basic model of standard or hugger 

10 ceiling fan would be between $1,200 and $3,600 

11 for a basic model of a standard or hugger ceiling 

12 fan. Double that for a basic model of a multi13 mount ceiling fan, and between $2,600 and $4,000 

14 for a multi-head ceiling fan. 

15 DOE also estimated the expected costs 

16 under the proposed rule for high-volume ceiling 

17 fans -- and I should probably clarify that for 

18 both low-volume and high-volume ceiling fans, 

19 these numbers were based on quotes and estimates 

20 given from testing facilities. 

21 For high-volume ceiling fans, these were 

22 the associated costs for the one-time cost, and 
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1 then the cost to conduct a particular test. 

2 MR. BROOKMAN: David, please. 

3 Microphone. 

4 MR. TURNER: David from Hunter, on this 

5 slide. So I realize there's not a current test 

6 procedure, so you used Energy Star. That's what 

7 we're kind of discussing, so given that 5 to 10 

8 percent of the current industry is Energy Star, 

9 there's a 90-percent factor of fans that probably 

10 aren't getting tested to that full effect there. 

11 I don't know if that means the difference 

12 is off. I mean, I don't know how you quantify 

13 that. I just kind of wanted to get on the record 

14 to say that there are a lot of fans out there, 

15 upwards of three-quarters of the market that 

16 probably aren't getting tested to that full 

17 effect on the far left, so that difference is 

18 probably greater, in the end. 

19 MS. KANTNER: We were just trying to use 

20 this as a point of reference, as far as what the 

21 changes were. 

22 MR. TURNER: Yeah, so I just wanted to 
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1 get on the record for that. 

2 MR. BROOKMAN: Okay. Thank you. Are we 

3 ready to move on? 

4 MS. KANTNER: Any comments on this slide? 

5 Okay. 

6 In summary, DOE estimated the number of 

7 basic models per manufacturer and found between 1 

8 and 80 for low-volume ceiling fans, and 1 and 30 

9 for high-volume ceiling fans, and then based on 

10 estimates of the median revenue came up with an 

11 estimate at the bottom of this table for the test 

12 cost as a fraction of median revenue, which was 

13 between 0.01 percent and 1 percent for low-volume 

14 ceiling fan small business manufacturers, and 

15 between 0.05 percent and 1.5 percent for high16 volume small business manufacturers. 

17 MS. ARMSTRONG: I don't think we need to 

18 put up the next slide. Just ask for comment on 

19 the small business impacts, whether it be an 

20 estimate of the actual number of small businesses 

21 or the impacts. If you have any specific 

22 comments or changes, in addition to the ones that 
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1 Hunter already made, we would welcome those and 

2 your written comments in follow-on. 

3 This does conclude the portion of the 

4 test procedure rulemaking, so does anybody want 

5 to make any other final comments about the test 

6 procedure before we move on to lunch, and then 

7 standards? 

8 MR. BROOKMAN: Bill. Get that close. 

9 MR. WALKER: Bill with Hunter. Are you 

10 talking about, even Issue Number 19? 

11 MS. ARMSTRONG: Sure. 

12 MR. WALKER: I mean, it's up there now. 

13 MR. BROOKMAN: Yes, please. 

14 MR. WALKER: So, a comment on how 

15 calibration between testing facilities could be 

16 facilitated, I think that's going to be somewhat 

17 tough. Allen mentioned there were maybe three or 

18 four labs, but there's a lot of certification or 

19 verification bodies out there. They have to go 

20 through that, too. I mean, that has to be a part 

21 of it. 

22 I can tell you that I tested a fan in my 
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1 lab, and I had two other certification bodies 

2 test it, same fan, same blades, exactly the same. 

3 We got three different results. 

4 MR. BROOKMAN: Significantly different? 

5 MR. WALKER: I'm sorry? 

6 MR. BROOKMAN: Significantly different? 

7 MR. WALKER: Substantially different. 

8 Energy Star versus non-Energy Star. So, you 

9 know, the comment is, I don't know how it needs 

10 to be accomplished, but it's got to be 

11 accomplished somehow, and Hunter will work with 

12 you to do that. 

13 MS. ARMSTRONG: Yeah. So, I think 

14 there's a couple of things. One of the things we 

15 do, we'd be happy to engage in a round-robin, get 

16 that set up, starting as soon as possible. Two 

17 would be, that's one of the reasons we have our 

18 reading requirements the way we set up. If you 

19 work through the math, the certification 

20 requirements do push manufacturers to rate 

21 conservatively. 

22 There's a reason for that. It does two 
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1 things. One is the consumer gets that or better, 

2 so it protects the consumer, and the savings that 

3 we all want to deliver to the consumer. But, 

4 two, it also somewhat protects you in your 

5 ratings, if DOE were to pull a product from 

6 market and test it at a third-party lab. 

7 And then we do have tolerances, different 

8 set of tolerances on the other side, for 

9 enforcement-type purposes, which are above and 

10 beyond the tolerances given, or provided for you 

11 guys for certification testing, but it does make 

12 it a lot harder for DOE to actually determine 

13 that a product is not compliant, due to what we 

14 all know will happen, which is lab-to-lab 

15 variation. Okay? 

16 MR. BROOKMAN: Okay. Additional closing 

17 remarks at this time, before we go to lunch? 

18 Great. Good progress this morning. 

19 Let's go to lunch. It's now twelve, 

20 approximately, so we will resume at one o'clock. 

21 We're mindful that many persons present will be 

22 departing at 3:00 or 3:15 or so, so we're going 
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1 to go as rapidly as possible and still cover all 

2 the content in what's listed in the slides when 

3 we return and resume at one. 

4 Please make sure to wear your badge. For 

5 those of you that aren't familiar with the 

6 facilities, a lot of folks will be going down to 

7 the bottom floor and trooping about 100 yards 

8 that way, to the big cafeteria. 

9 This room will be supervised. You can 

10 leave your stuff. You probably need an ID to get 

11 back through the security portal, if you go to 

12 the big cafeteria. 

13 At one o'clock we'll resume. 

14 [Recess taken from 12:05 to 1:01 p.m.] 

15 Afternoon Session 

16 MR. BROOKMAN: As we noted first thing 

17 this morning, we are now going to move to the 

18 energy conservation standards portion of the 

19 meeting. We had a very productive discussion 

20 this morning. I really appreciate everybody 

21 being so forthcoming with their ideas and their 

22 comments, and the Department will hope to see 
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1 those comments amplified in writing. 

2 So, now to Lucy deButts. 

3 MS. DEBUTTS: Okay. This is Lucy here, 

4 again. We're going to go quickly through some 

5 slides, because we've covered a lot of territory 

6 this morning, so the written comments can be 

7 submitted. This is the information provided on 

8 the slide. I just wanted to point out the 

9 written comments on the energy conservation 

10 standards is due on November 28th of 2014, and 

11 it's coming up. 

12 Opening remarks on this one? 

13 MR. BROOKMAN: Yeah, any brief summary of 

14 remarks here at the outset? David, I see you're 

15 ready. 

16 MR. TURNER: David at Hunter. Just a, if 

17 there would be any consideration for an extension 

18 on the written comment period, given for what 

19 next week is, and where we all right now. John 

20 and Ashley, there was a finger pointed at you by 

21 someone. 

22 [Laughter.] 
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1 MR. CYMBALSKY: So, I think this was 

2 brought up yesterday. So are you asking for a 

3 comment extension for both? For one? 

4 MR. TURNER: The only one due next week 

5 is the TSD comment, right? 

6 MS. DEBUTTS: For standards. 

7 [Discussion off mic regarding dates.] 

8 MR. TURNER: Honestly, it's just the 

9 holiday next week, plus not being able to get 

10 together as much as we'd like, to make sure that 

11 our unified response is as well thought out as we 

12 want to. I don't know if we need much more than 

13 a week or two, but the week of Thanksgiving, I 

14 mean, half the week is dead already. 

15 MR. CYMBALSKY: Okay. So if we say the 

16 end of, the Friday of the first week of December? 

17 MR. TURNER: That's the following week, 

18 correct? 

19 MR. CYMBALSKY: December 6th or something 

20 like that? 

21 MR. TURNER: I think that would be a huge 

22 help. 
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1 MR. CYMBALSKY: Okay. Why don't you just 

2 send me an e-mail with that request. 

3 MR. TURNER: Thank you. 

4 MS. DEBUTTS: Anything else? 

5 MR. BROOKMAN: No opening comments? 

6 We're going to launch straight into it, then. 

7 Okay. 

8 MS. DEBUTTS: Okay. So this slide was on 

9 the screen for a while. This is the rulemaking 

10 schedule. As you can see, we're projecting to 

11 come up with third quarter of 2015 for the NOPR, 

12 second quarter of 2016 for the final rule, and 

13 compliance date will be in 2019. 

14 We have discussed regulatory history. 

15 Also, you can read about it. If you would like to 

16 comment on it later, that's fine. 

17 The preliminary analyses that were done 

18 were composed of this analysis, described on the 

19 slide, and we are going to go into detail later. 

20 EPA also requests DOE to consider seven factors 

21 that are listed on the current slide, and when we 

22 did our printouts this week, considered all of 
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1 them while proposing our levels. 

2 And now we're going to go into scope 

3 coverage. 

4 MR. BROOKMAN: We're going to do this as 

5 expeditiously as possible, but that should not 

6 diminish anyone's capacity to comment. If you 

7 want us to slow down, if you've got something to 

8 raise, raise it. Here we go. 

9 MS. ARMSTRONG: We're going to jump to 

10 the next one because we already went through this 

11 this morning. 

12 MS. KANTNER: I want to talk about the 

13 highly decorative. 

14 MS. ARMSTRONG: Oh yeah, highly 

15 decorative. We do need to talk about that, 

16 actually. But we already went over scope of 

17 coverage this morning. It's the same thing for 

18 standards. It's comparable other than this, that 

19 one issue. 

20 MR. BROOKMAN: Thank you, Ashley. 

21 MS. KANTNER: In this rulemaking, DOE is 

22 considering a definition for highly decorative 
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1 ceiling fans. Specifically, DOE is considering 

2 defining a highly decorative ceiling fan as "a 

3 ceiling fan that operates at a maximum rotational 

4 speed of 90 rpm and produces less than 2,000 CFM 

5 of airflow on high speed." DOE considered 

6 definitions based on CFM and RPM alone, and 

7 believes that the combined definition is 

8 preferable. Some large, high-volume ceiling fans 

9 operate with a low RPM but produce very 

10 significant airflow, and clearly have air 

11 movement as a primary feature. 

12 DOE also found examples of some smaller 

13 fans, and by smaller I mean 26 inches in 

14 diameter, or less, which did not produce 2,000 

15 CFM but seemed, by all indications, to have air 

16 movement as their primary purpose. 

17 Any comments on that? 

18 MR. BROOKMAN: Yes. Christian. 

19 MR. TABER: Christian Taber, Big Ass 

20 Solutions. Sorry. I have two issues, I guess. 

21 The combination of RPM and CFM is better than 

22 just RPM, because, obviously, our products move 
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1 slow, and they move at a large CFM, but I think 

2 it creates an issue, not our product, but looking 

3 at some non-traditional ceiling fans. There's 

4 one called Exhale, which is a centrifugal -- it's 

5 not centrifugal -- it spins and blows air 

6 outwards, so it's not going to be easily able to 

7 measure using the Energy Star test rig. So 

8 trying to prove that it moves less than 2,000 CFM 

9 would be difficult. 

10 Fanimation actually makes the FP-600. 

11 It's the one with the blades that kind of go 

12 like, around in this way. I don't know how you 

13 would hook that up to a test stand, to try to get 

14 at CFM. And so trying to prove that your fan 

15 moves less than 2,000 CFM, when it's not really 

16 intended as a ceiling fan that's highly 

17 decorative, can be burdensome, so trying to get 

18 out of this. 

19 If we just did a tip speed, which is 

20 fairly consistent across the industry -- not 

21 everybody has the same tip speed, but a 

22 decorative fan with something like, I think I 
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1 have 680 feet per minute as its tip speed, would 

2 be incapable of producing 2,000 CFM. So it would 

3 kind of fall under both and it would just be one 

4 very easy-to-prove metric. It moves this fast, 

5 it's diameter, therefore it's this tip speed. So 

6 it would be easy to show that you don't, you're 

7 decorative and not designed to create airflow. 

8 MR. BROOKMAN: Okay. Thank you. 

9 Additional comments on highly decorative? Yes. 

10 MR. MATTHEWS: Chuck Matthews, Matthews 

11 Fan Company. Is the RPM really necessary for 

12 this category? 

13 MS. KANTNER: You mean including it in 

14 the definition? I think, as -- 

15 MR. MATTHEWS: Given the small percentage 

16 of this product that's sold in the United States, 

17 I'm just wondering if it's really necessary. 

18 MR. CYMBALSKY: This is John from DOE. 

19 Do you have a reaction to the Big Ass Solutions 

20 tip speed, as opposed to what we are proposing 

21 here? We're asking for your -- what would you 

22 propose? Instead of asking us why this, how 
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1 about, what's your idea? 

2 MR. MATTHEWS: No RPM or tip speed. 

3 MR. CYMBALSKY: So just CFM? 

4 MR. MATTHEWS: Just CFM. I mean, given 

5 that the primary purpose is maybe decorative, and 

6 the fact that this product is not what is mostly 

7 sold today in the U.S. -- it's a small percentage 

8 of product, but it's still a product that is 

9 somewhat popular with designers and architects. 

10 MS. KANTNER: So would that CFM 

11 requirement be as a function of blade span? 

12 MR. MATTHEWS: I guess it would -- the 

13 CFM, then, would decide whether it's highly 

14 decorative or functional. 

15 MS. KANTNER: I guess what I'm trying to 

16 say is if you've got a small ceiling fan, it 

17 seems like then you might produce 2,000 CFM, even 

18 though that fan isn't -- 

19 MR. MATTHEWS: Or less. Yeah. We've got 

20 some small product. Some blades are like 12 

21 inches in diameter, approximately 12 inches in 

22 diameter, and so, therefore, approximately 2,000 
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1 CFM in them is what we're producing, maybe a 

2 little less. But these fans use high-velocity 

3 motors, which are spinning at 90 RPMs. So it's a 

4 decorative, functional product. It's utilitarian 

5 in that it can direct airflow in a particular 

6 direction. It's not designed, necessarily, to 

7 cool down a room, but that product, then, might 

8 not be for sale in the U.S., given this present 

9 definition. So the removal of the RPM minimum -- 

10 MR. BROOKMAN: If it was slightly higher, 

11 would that do it? If it was 100 or 120, or 

12 something? 

13 MR. MATTHEWS: 1,100, perhaps. I mean, 

14 these are high-speed blower motors that we're 

15 using. But, again, they're not designed to cool 

16 a room, either. They're designed to provide 

17 directional airflow into a space directly 

18 underneath or across a room. 

19 MR. BROOKMAN: Okay. 

20 MS. KANTNER: I guess I'm slightly 

21 confused. They would still be allowed to be 

22 sold. This is just a categorization. 
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1 MS. ARMSTRONG: Yeah. It's a different 

2 issue. 

3 MR. MATTHEWS: Isn't this an exemption? 

4 MS. ARMSTRONG: This is an exemption, but 

5 to the extent that you wouldn't fall under the 

6 exemption. You would just have to meet the 

7 standards. 

8 MR. CYMBALSKY: Meet the standard. 

9 MR. MATTHEWS: And that's what I mean. 

10 There's the potential that these products might 

11 not meet the standards, and that's why I'm asking 

12 for an exemption. 

13 MR. TABER: Christian Taber, Big Ass 

14 Solutions. Would it be possible that they 

15 wouldn't qualify under the definition of a 

16 ceiling fan? Because if it's mounted this way, 

17 blowing that way, then I think it would be more 

18 under the fan head pedestal type, the first slide 

19 that there was the issue, which may have been the 

20 reason for the question. 

21 MR. MATTHEWS: That's another 

22 possibility, yes. 
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1 MR. TABER: I think it may be exempt for 

2 that reason, not necessarily for this reason. 

3 MR. MATTHEWS: I'm covering a couple of 

4 bases, so -- 

5 MR. BROOKMAN: Okay. Thanks for the 

6 comment. Yes. Marianne. 

7 MS. DIMASCIO: Marianne DiMascio, ASAP. 

8 I think the concern is if there are many ways for 

9 these to be exempt that people may use that to 

10 get around standards, and it will have a higher 

11 market share. It would be a loophole, so that 

12 would be our concern. 

13 MR. BROOKMAN: Okay. Yes, Christian. 

14 MR. TABER: One other point. Christian 

15 Taber, Big Ass Solutions. If we're going to 

16 specify a CFM, then that CFM should be probably 

17 based on the test method, since both give 

18 different numbers. 

19 MS. ARMSTRONG: Yep. 

20 MR. BROOKMAN: Okay. 

21 MR. TABER: Or if specified for both test 

22 methods. 
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1 MR. BROOKMAN: Dave. 

2 MR. GATTO: Dave Gatto, Westinghouse. 

3 Thanks, Christian. That's kind of where I was 

4 going, is we set this bar based on the current 

5 test procedure. If the new test procedure is 

6 going to change the results, we could 

7 inadvertently push products that are currently in 

8 scope out of scope, which would be, I think, a 

9 concern for Marianne. But also, for us, you 

10 could end up with a product that's not going to 

11 meet the efficiency standard because we based it 

12 on a platform that isn't exactly what we're going 

13 to get, in terms of the new test procedure 

14 results. 

15 MR. BROOKMAN: Okay. We're moving on, 

16 then. 

17 MS. KANTNER: So, next is the market and 

18 technology assessment. I described the purpose 

19 of the market and technology assessment 

20 yesterday, so I think we'll just move on. In the 

21 market assessment, DOE first categorized ceiling 

22 fans into two types, high-volume and low-volume, 
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1 and DOE estimated that the market share was about 

2 10 percent for high-volume and around 90 percent 

3 for low-volume. There's a fair amount of 

4 uncertainty in the high-volume numbers. 

5 Within the low-volume category, DOE 

6 categorized four types of low-volume ceiling 

7 fans: standard, hugger, multi-mount, and highly 

8 decorative, and found that each of those 

9 categories was the percentage of market indicated 

10 here, and this was based on models found in store 

11 surveys. 

12 And this table summarizes DOE's market 

13 estimate with respect to major manufacturers and 

14 the market, historical shipments, the number of 

15 ceiling fans in homes - the fraction of homes 

16 with ceiling fans and the number of ceiling fans 

17 in homes - and lifetime, for both low-volume and 

18 high-volume ceiling fans. About 80 percent of 

19 low-volume ceiling fans are sold through three 

20 mass-market retailers, and DOE believes that low21 volume ceiling fans are manufactured overseas. 

22 In contrast, as DOE understands it, most 
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1 of the high-volume, large-diameter ceiling fans 

2 are manufactured in the U.S., and DOE assumes 

3 that most small-diameter, high-volume ceiling 

4 fans are also manufactured overseas. 

5 Shipments numbers we talked about 

6 yesterday, so I'll just skip that. 

7 DOE estimates that 73 percent of U.S. 

8 households have ceiling fans, with an average of 

9 3.1 ceiling fans per household, and, again, there 

10 was limited data available on high-volume ceiling 

11 fans. 

12 As far as lifetime, Appliance Magazine 

13 estimated that the lifetime of a low-volume 

14 ceiling fan was between 7 and 18 years, and DOE 

15 assumed that the lifetime was the same for high16 volume ceiling fans, due to limited data to 

17 indicate otherwise. 

18 Then we have a couple of items for 

19 comment, first on the manufacturing locations of 

20 high-volume ceiling fans. 

21 MR. BROOKMAN: Yes, Dave. 

22 MR. GATTO: Dave Gatto, Westinghouse. 
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1 We'll include this in the comments. For high2 volume, small-diameter fans, we agree with DOE's 

3 analysis that the majority, if not all 

4 manufacturing is in Asia. 

5 MR. BROOKMAN: Thank you. 

6 MR. GATTO: I'm sorry. I'm looking at 

7 the other question, in case that's one I'm 

8 supposed to do there, as well. No, I don't have 

9 anything further to add. 

10 MR. BROOKMAN: Christian. 

11 MR. TABER: Christian Taber, Big Ass 

12 Solutions. To comment on the high-volume, large13 diameter fans, for fans that are for sale in the 

14 United States, I believe there is only one 

15 manufacturer who is not located in the United 

16 States, and they are in Canada. 

17 MR. BROOKMAN: Moving on to high-volume. 

18 MS. KANTNER: DOE also seeks comment and 

19 data on the distribution of sizes and motor power 

20 for both high-volume, large-diameter ceiling fans 

21 and high-volume, small-diameter ceiling fans. In 

22 particular, for high-volume, large-diameter 
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1 ceiling fans, DOE assumed a 1-horsepower ceiling 

2 fan is representative of the entire market and 

3 requests comments on the accuracy of this 

4 assumption. DOE also seeks comment and data on 

5 the distribution of end users by industry and 

6 application and the geographic distribution of 

7 high-volume ceiling fans. 

8 MR. BROOKMAN: Dave. 

9 MR. GATTO: Dave Gatto, Westinghouse. On 

10 the high-volume, small-diameter fans, the 

11 applications are primarily industrial and 

12 commercial, unconditioned warehouse space, multi13 story warehouse. There are some light commercial 

14 applications, as well, but it's almost zero 

15 residential. 

16 And there may be a slide for this, and I 

17 think your previous slide told me why you 

18 couldn't find them in the home center channel, 

19 which is why I think the baseline that you 

20 selected was incorrect, and we can provide 

21 information to help you with that, as well. 

22 MR. BROOKMAN: Christian. 
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1 MR. TABER: For large-diameter -- sorry. 

2 Christian Taber, Big Ass Solutions. For high3 volume, large-diameter fans, let's see, it is 1-

4 1/2 times more likely that a 20-foot model would 

5 have a 2-horsepower motor than a 1-horsepower 

6 motor. A 20-foot diameter was assumed to be the 

7 vast majority of the market. I think 67 percent 

8 of the fans sold were estimated to be 20-foot 

9 diameter fans. So a 1-horsepower would not be 

10 representative of a 20-foot diameter fan. 

11 And, in actuality, when we look at the 

12 calculations included in here, the wattage of the 

13 fan was 1,154 watts, which would be indicative of 

14 a 1-1/2 horsepower or a 2-horsepower motor. So 

15 the numbers used in the analysis were not 

16 indicating a 1-horsepower motor, which would be 

17 closer to 750 watts. 

18 For the smaller diameters, for a 12-foot 

19 diameter fan and an 8-foot diameter fan, 1 would 

20 be more typical for a 12, and then a fractional, 

21 maybe 3/4-horsepower would be more typical for 

22 the smaller diameter. We do have comments that 
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1 kind of break out for the industry how many of 

2 each, in each category, what size, that kind of 

3 details that out. 

4 But our suggestion would be, for the 20-

5 foot fan, either a 1-1/2 or a 2, and then for the 

6 smaller diameters, either a 1 or possible 3/4 or 

7 1/2. 

8 MR. BROOKMAN: Thank you. Additional 

9 comments before we move on? 

10 MS. KANTNER: DOE estimated a current 

11 household saturation rate for ceiling fans of 73 

12 percent. DOE assumed that the residential market 

13 for low-volume ceiling fans would continue to 

14 penetrate until a saturation of 75 percent is 

15 reached. Additionally, DOE estimated, on 

16 average, that 3.1 ceiling fans are installed in 

17 new installations, and DOE welcomes comment on 

18 these assumptions. 

19 MR. BROOKMAN: Yes, Dave. 

20 MR. GATTO: Dave Gatto, Westinghouse. We 

21 kind of covered this yesterday. We agree with 

22 those assumptions as being the most reasonable to 
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1 use. I'm not sure that we're going to agree with 

2 how the shipment analysis played off of this, 

3 when we get there. 

4 MR. BROOKMAN: Okay. 

5 MS. KANTNER: There is currently only one 

6 product class for ceiling fans. Pursuant to 

7 EPCA, DOE establishes product classes based on 

8 three criteria: energy used, capacity, and other 

9 performance-related features, including utility. 

10 DOE is considering five separate ceiling fan 

11 product classes, based on capacity and utility, 

12 where utility might include the ability to be 

13 installed safely in rooms with low ceilings, or 

14 in general residential applications. 

15 Specifically, DOE is considering three 

16 product classes for low-volume ceiling fans -- 

17 hugger, standard, and highly decorative, with the 

18 definitions discussed earlier -- and DOE is 

19 considering two product classes for high-volume 

20 ceiling fans, based on fan diameter. 

21 MR. FRAMPTON: This is Nathan with 

22 Fanimation. One question, and it affects this 
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1 slide and a couple of others. Were there any 

2 tests done on high-velocity fans that have DC 

3 motors, because I'm not aware of any products 

4 that have high-velocity DC motors. 

5 MR. BROOKMAN: Yes. Aris. 

6 MR. MARANTAN: Aris Marantan, Navigant 

7 Consulting. I'm not aware of any, and we did not 

8 test any that had DC motors for high-volume, 

9 small-diameter. 

10 MR. BROOKMAN: thank you. Don Brundage. 

11 MR. BRUNDAGE: For the larger ceiling 

12 fans that would just be used in a commercial and 

13 industrial setting, I have some concern over -- 

14 you're doing this under 10 CFR 430 with the 

15 exemptions, with the preemption of other 

16 efficiency standards. It would probably be more 

17 appropriate to do this, the large ones, as an 

18 ASHRAE product and not have preemption on how you 

19 would do that in the context of one rulemaking. 

20 But it's going to limit the ability to use them 

21 in building codes, because, essentially, with a 

22 covered product, you typically are not showing 
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1 any sort of efficiency standards within the 

2 building codes, to avoid the preemption issues. 

3 Thank you. 

4 MR. BROOKMAN: Please. 

5 MS. NOLL: This is Elizabeth Noll, NDRC. 

6 I was wondering if DOE looked at the high-volume 

7 ceiling fan with respect to airflow as opposed to 

8 diameter, and if they have any reaction on the 

9 two approaches, if they could explain that? 

10 MS. KANTNER: I'm sorry. Can you restate 

11 that? 

12 MS. NOLL: So, with the product classes, 

13 the efficiency standards will be based on, with 

14 respect to diameter, and if they looked at 

15 efficiency with respect to airflow as an 

16 alternative approach. 

17 MS. KANTNER: I believe we looked at both 

18 and we found that there was a very high 

19 correlation between the split between these 

20 diameters and where the various capacity ranges 

21 were, of airflow, so we felt like this was maybe 

22 a simpler one. 
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1 MS. NOLL: Okay. Thank you. 

2 MR. TABER: Christian Taber, Big Ass 

3 Solutions. Obviously, I would just point back to 

4 our previous comments on the simplification of 

5 classes. 

6 MR. BROOKMAN: Okay. Additional comments 

7 on product classes? Yes. Marianne. 

8 MS. DIMASCIO: This may go into the next 

9 section, but I'm wondering if you've looked at 

10 specific consumer utility for non-conventional 

11 blades. 

12 MR. CYMBALSKY: So -- 

13 MS. DIMASCIO: Is there any consumer 

14 utility for them? 

15 MR. CYMBALSKY: This is John from DOE. 

16 So, part of the rule, we look at the utility 

17 side. If what you're saying is do consumers 

18 derive utility from a conventional fan blade 

19 shape that we're all used to seeing versus like 

20 airfoil blade -- is that -- I believe there are 

21 utility concerns there, sure. 

22 MS. DIMASCIO: Okay, because the question 
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1 I have is, it seems that those blades constrain 

2 the standard, so if there's a utility, would it 

3 make sense to have a separate product class for 

4 those? 

5 MR. CYMBALSKY: I think you'll see that 

6 our analysis looked at the shapes of the blades. 

7 I think we'll see that later. 

8 MS. DIMASCIO: Okay. 

9 MR. BROOKMAN: Okay. 

10 MS. KANTNER: So, moving on. DOE is also 

11 clarifying the status of multi-mount ceiling 

12 fans. As we discussed earlier, the test 

13 procedure is proposing to test them both in the 

14 standard and hugger configurations, and DOE is 

15 considering requiring multi-mount ceiling fans 

16 meet the potential energy conservation standards 

17 for both standard and hugger product classes. 

18 And DOE seeks comment on the product 

19 classes under consideration for ceiling fans, and 

20 DOE also seeks comment on its approach to highly 

21 decorative ceiling fans. I think we talked about 

22 that last one a little bit already. 
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1 MR. BROOKMAN: Comments here. Okay. 

2 Nothing at this time. 

3 MS. KANTNER: All right. DOE 

4 investigated the following technology options to 

5 improve ceiling fan efficiency, in three main 

6 categories. Among the more efficient motor 

7 technology options considered were more efficient 

8 direct-drive, single-phase induction motors; 

9 geared, single-phase induction motors; brushless 

10 direct current motors; and three-phase induction 

11 motors. 

12 Among the more efficient blade options 

13 DOE considered were fewer fan blades, twisted 

14 blades, curved or airfoil blades, blade 

15 attachments, beveled blades, and blade materials. 

16 DOE also considered ceiling fan controls, 

17 specifically occupancy sensors. 

18 DOE is also tentatively not including 

19 wind or temperature sensors as a technology 

20 option at this time. DOE is not aware of any 

21 ceiling fans that include wind sensors, and only 

22 one ceiling fan model that includes temperature 
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1 sensors. DOE is also not aware of any data that 

2 would indicate how such products would translate 

3 into energy savings, as used in the field. 

4 And then we have a couple of items for 

5 comment on this. DOE requests information on the 

6 availability of ceiling fans including wind and 

7 temperature sensors, and any data on the 

8 potential energy savings associated with such 

9 products. 

10 MR. TURNER: David from Hunter. We would 

11 agree with the approach not including them, and 

12 we don't know of any products out there. 

13 MR. BROOKMAN: That's what I wanted to 

14 know, the volume is -- okay. 

15 MR. TABER: Christian Taber, Big Ass 

16 Solutions. As the manufacturer of the fan with 

17 the temperature sensor in it, I think we're fine 

18 with not including the temperature sensor. The 

19 occupancy sensor, I think would be the one of 

20 more interest to us. But the temperature sensor 

21 does bring up the point that the fan, paired with 

22 air conditioning, does provide an overall 
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1 positive, and that's really the purpose that that 

2 sensor serves, is to work in conjunction with a 

3 thermostat, to reduce overall energy consumption. 

4 MR. BROOKMAN: Okay. 

5 MS. KANTNER: And DOE requests comments 

6 on these technology options being considered and 

7 any additional options that should be included. 

8 MR. BROOKMAN: You should go back to the 

9 list, so they can see it. Any additional 

10 options, comments on these. Yes, Christian. 

11 MR. TABER: Christian Taber, Big Ass 

12 Solutions. The more efficient blades -- and 

13 we've commented on this a couple of times, and 

14 I'm trying to think of the right way to say it, 

15 so bear with me if I'm babbling. But all those 

16 things kind of go together. Fewer fan blades, by 

17 themselves, doesn't necessarily equal a more or 

18 less efficient fan. 

19 Angle of attack -- all factors kind of go 

20 together into one, and simply stating that fewer 

21 fan blades makes a fan more efficient, there are 

22 one-bladed fans on the market and they are not 
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1 any more efficient, necessarily, than a five2 bladed fan. There's a specific interest in our 

3 industry in that some manufacturers tout the 

4 number of blades as the reason why their fan is 

5 more efficient, which is not necessarily true. 

6 So, we would prefer a more holistic 

7 approach of fan blade design, which includes all 

8 of those things as one, not necessarily each 

9 individually taken up. 

10 MR. BROOKMAN: Okay. Dave. 

11 MR. GATTO: Dave Gatto, Westinghouse. 

12 Just to circle back briefly, I do agree with 

13 Hunter that there aren't any, other than 

14 Comprishing [ph] and that fell into the, I think, 

15 high-volume, large-diameter. As it relates to 

16 occupancy sensors, for low-volume, and even, to 

17 an extent, to the high-volume, small-diameter -- 

18 the occupancy sensor with fans, we've provided 

19 these comments. That can be a very tough thing 

20 to manage, particularly in a residential space. 

21 What I would suggest to DOE is to 

22 consider the fact that that energy-saving option 
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1 is not only available, it's part of multiple 

2 national and local building codes, but typically 

3 it's the room occupancy sensor that's controlling 

4 multiple devices. So even in the event that we 

5 would want to consider -- and I think you 

6 selected this out in the next couple of slides, 

7 which we'd agree with -- I would just kind of 

8 caution you that if we decide to bring it back 

9 in, you're going to end up with multiple 

10 occupancy sensors, potentially, because the fan 

11 to come with one, the room might have one to meet 

12 local code, and now you're actually driving up 

13 standby power with no additional benefit. 

14 MR. BROOKMAN: Yes. Aris. 

15 MR. MARANTAN: Aris Marantan, Navigant 

16 Consulting. I want to thank you, Christian, for 

17 your comment on the holistic approach to the fan 

18 design option. I do want to try and maybe get 

19 some more information from you on how we might be 

20 able to account for that in the analysis. As 

21 you'll see later, in the engineering analysis, we 

22 try to cost different design options, try to find 
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1 out the incremental increasing cost for an 

2 approach, as well as the incremental increase in 

3 efficiency, so we would welcome any input you 

4 have on that for the holistic design approach. 

5 MR. BROOKMAN: Thank you. Moving on. 

6 Oh, sorry, David. 

7 MR. TURNER: David from Hunter. As we 

8 indicated in our initial comments that, in the 

9 retail space, fans have a high aesthetic appeal 

10 and that has to be considered whenever we start 

11 talking about changing something that's seen by 

12 the consumer and is part of their choice of what 

13 fan to buy. If we start changing the aesthetics, 

14 then customer utility is affected, as far as 

15 consumer choice. So I just wanted to reinforce 

16 that. 

17 MR. BROOKMAN: Okay. 

18 MS. KANTNER: And now Sam Jasinski of 

19 Navigant will present the screening analysis. 

20 MR. JASINSKI: Thanks, Colleen. Good 

21 afternoon. My name is Sam Jasinski from Navigant 

22 Consulting. Today I'll be discussing the 
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1 screening analysis. The purpose of the screening 

2 analysis is to evaluate the technology options 

3 that we were just discussing, using four criteria 

4 prescribed by EPCA, that are listed here. In 

5 doing so, DOE will only consider, in its 

6 downstream analyses, particularly the engineering 

7 analysis, technologies from that list that are 

8 technologically feasible, practicable to 

9 manufacture, install, and service, do not have 

10 adverse impacts on product utility or product 

11 availability, or adverse impacts on health or 

12 safety. 

13 So I'll cycle through the product classes 

14 and discuss specifically which of the technology 

15 options got screened in or out for each. Here's 

16 the low-volume ceiling fan product class, and as 

17 you see on the slide, we categorized the 

18 technology options in three broad categories -- 

19 more efficient motors, more efficient blades, and 

20 ceiling fan controls. 

21 For the low-volume ceiling fan product 

22 class, more efficient direct-drive single-phase 
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1 induction motors and brushless DC motors will be 

2 considered. Geared induction motors, three-phase 

3 induction motors will not, mostly because DOE is 

4 not currently aware of commercially available 

5 products that use these. For the three-phase 

6 induction motors, there is also a utility 

7 concern, or practicability to install concern 

8 because low-volume ceiling fans are mostly used 

9 in residential or commercial applications where 

10 three-phase electricity is not used. 

11 For the blade designs, these are also 

12 mostly screened out. Due to the sensitivity 

13 that's been raised by Hunter Fans and others, DOE 

14 is aware that there is a sensitivity in this 

15 market to the physical appearance of fans, and a 

16 lot of these have impacts on those. DOE is 

17 preliminarily screening them out because of those 

18 impacts on utility, but is welcoming comments to 

19 get a better understanding of how these specific 

20 design options might impact utility to be 

21 considered further in the next iteration of the 

22 analysis. 
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1 Some that are screened out for other 

2 reasons, fans with fewer fan blades. DOE does 

3 not currently have sufficient information to show 

4 that this will actually improve efficiency. 

5 There are also concerns that they will increase 

6 noise, which is a reduction in utility to 

7 consumers. For blade attachments, very 

8 similarly, DOE does not have sufficient data to 

9 show that these will improve efficiency, and DOE 

10 is also not currently aware of any commercially 

11 available products that use them. 

12 In the last category, ceiling fan 

13 controls, DOE is aware of one particular product 

14 that uses occupancy controls, the SenseME from 

15 Big Ass Solutions. However -- actually, let me 

16 rephrase that. It's not yet commercially 

17 available but they are taking preorders. Is it 

18 commercially available now? At the time of the 

19 analysis it was not commercially available. It 

20 was available for preorders. 

21 Something else that DOE considers is 

22 intellectual property. We understand that there 
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1 might be some intellectual property surrounding 

2 this, so preliminarily it's screened out for now 

3 until DOE can get more details and information 

4 about the commercially available product and 

5 whether or not there are intellectual property 

6 concerns that DOE needs to be aware of. 

7 Any comments on the screening analysis 

8 for low-volume ceiling fans? 

9 MR. BROOKMAN: Dave. 

10 MR. GATTO: Westinghouse Lighting. 

11 Westinghouse agrees with DOE's screen in/screen 

12 out. We'll have further comments on brushless DC 

13 motors and the efficiency versus cost when we get 

14 to that slide. 

15 MR. BROOKMAN: Okay. Thank you. David, 

16 do you want to comment here? Okay. 

17 MR. TURNER: To make sure I understand 

18 this screen properly, you analyzed a list of 

19 potential options. These are the ones that you 

20 decided to move forward looking at or not looking 

21 at. But when we get to the individual options at 

22 the EL levels -- I always get that wrong when 
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1 we're in fans -- then, at that point, we can 

2 provide comments on whether we think those ELs 

3 are appropriate or not. So, yeah. 

4 MR. CYMBALSKY: That'll be at 3:30. 

5 [Laughter.] 

6 MR. GATTO: Dave Gatto, Westinghouse. I 

7 made sure that some of the fan guys were staying 

8 with me to the end of the day. 

9 MR. BROOKMAN: Christian, do you have 

10 another comment? 

11 MR. TABER: Yeah, just a comment on the 

12 occupancy sensors, or a question, actually, more 

13 than anything else. As far as when something is 

14 screened out, what does that officially mean? 

15 MR. JASINSKI: Officially it means that, 

16 for this iteration of the analysis, it will not 

17 be considered in the engineering analysis, which 

18 means DOE does not go through the process of 

19 determining whether or not it's economically 

20 justified, which means there won't be any 

21 implications in where the level is set, depending 

22 on any efficiency or cost impacts for using that 
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1 technology option. 

2 MR. TABER: So would that mean that there 

3 could be no credit given in the test metric for 

4 that item, if it was not included in the 

5 engineering analysis? 

6 MS. ARMSTRONG: No. They're separate 

7 decisions. 

8 MR. TABER: Okay. That's fine. What we 

9 would say is, essentially, on the occupancy 

10 sensors, the fan has been available since 

11 September of 2014. If you all would like to -- I 

12 can't remember the exact wording that you used, 

13 but further investigate that sensor, we would be 

14 more than glad to allow you to play with one. 

15 MR. JASINSKI: Thanks. Next I'll move on 

16 to the high-volume ceiling fans. This slide is 

17 specifically regarding the high-volume, small18 diameter ceiling fans. Again, in the high19 efficiency motors category, brushless DC motors 

20 are screened in. More efficient direct-drive, 

21 single-phase induction motors were screened out, 

22 mostly because we believe that most of the 
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1 commercially available products are already using 

2 the most efficient single-phase induction motors 

3 currently. Therefore, there won't be any 

4 improvement in efficiency by adopting them. They 

5 already have a high market penetration. 

6 Geared induction motors were screened out 

7 because DOE is not currently aware of any 

8 commercially available products that use those. 

9 Three-phase induction motors were screened out 

10 for similar reasons to the low-volume ceiling 

11 fans, mostly because DOE is not currently aware 

12 of any commercially available products that use 

13 it, and there are concerns about practicability 

14 to install, because of the lack of three-phase 

15 electricity in most of the applications where 

16 these are used. 

17 For the more efficient fan blades, 

18 airfoil blades and curved blades are in. DOE is 

19 aware of commercially available products that use 

20 those. For the others, those are screened out 

21 for similar reasons to the other fan blade 

22 technologies, for low-volume ceiling fans. Fans 
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1 with fewer blades was screened out because, 

2 again, DOE does not have sufficient data at this 

3 time to show that fewer fan blades would improve 

4 efficiency. 

5 Twisted fan blades, DOE is aware of only 

6 a very few number of products that have these 

7 technologies, and, again, there are some patent 

8 and intellectual property concerns for those. 

9 Blade attachments, DOE currently doesn't have 

10 enough information to show that these will 

11 positively impact efficiency. For alternative 

12 blade materials, a similar case. DOE is aware of 

13 very few products that use alternative materials, 

14 but there are very few, and, again, there are 

15 concerns whether there is intellectual property 

16 surrounding those that might make them 

17 impractical to manufacture on a large commercial 

18 scale. 

19 Same story with the occupancy sensors 

20 here. I think we've covered that sufficiently, 

21 unless there are more comments. 

22 MR. BROOKMAN: Dave. 
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1 MR. GATTO: Sorry. Dave Gatto, 

2 Westinghouse. On occupancy sensor, Pekka 

3 couldn't be here from Lutron, but he texted me, 

4 so he's clearly listening in. So while I'm not 

5 speaking for him, if I say this wrong, it's his 

6 fault. 

7 Occupancy sensors for fans are also -- 

8 and we're glad you screened it out -- a concern 

9 for bedroom applications, because, typically, 

10 even though there may be an occupancy sensor the 

11 lighting in that room, and other products, the 

12 ceiling fan, the consumer expectation is that it 

13 will continue to run and keep them cool at night. 

14 So, again, it's just one more reason we agree 

15 with the thinking behind screening that out. 

16 MR. BROOKMAN: Yes, Christian. 

17 MR. TABER: So there are -- sorry. 

18 Christian Taber, Big Ass Solutions. There are 

19 ways to deal with that. You can, for example, 

20 include a schedule in the setup with the 

21 occupancy sensor. So, our product, for example, 

22 the occupancy sensor can be set in the bedroom to 
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1 run from 8 a.m. until 10 p.m., and then from 10 

2 p.m. until 8 a.m. the occupancy sensor would be 

3 disabled. 

4 MR. BROOKMAN: Okay. 

5 MR. TABER: So there are technological 

6 ways to get around those issues. 

7 MR. BROOKMAN: So, additional comments on 

8 small-diameter ceiling fans, and what's been 

9 screened in and screened out. I guess we're 

10 about to move on to large-diameter. 

11 MR. JASINSKI: For large-diameter fans, 

12 geared motors, three-phase induction motors, and 

13 brushless DC motors were screened in. More 

14 efficient direct-drive, single-phase induction 

15 motors were screened out, mostly because most of 

16 these are fans installed in industrial 

17 applications where three-phase electricity is 

18 used, and in the cases where these motors might 

19 be used, they're already representative of the 

20 baseline, so there's no room for improvement 

21 there. 

22 For more efficient fan blades, airfoil 
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1 blades, fans with fewer blades, and curved blades 

2 were screened in. DOE is aware of commercially 

3 available products that use these. Twisted 

4 blades, this is one where, for this particular 

5 product class, DOE is aware of very few fans that 

6 use these commercially, and where they do, again, 

7 there are patent concerns and intellectual 

8 property concerns. 

9 Blade attachment -- DOE, at this time, 

10 does not have sufficient information to determine 

11 whether or not they actually improve efficiency, 

12 so they were screened out preliminarily. If DOE 

13 receives more information to the contrary, that 

14 can be considered for the next iteration of the 

15 analysis. 

16 Alternative blade materials, similar to 

17 the small-diameter. DOE is only aware of very 

18 few models that use this technology, with the 

19 concerns about intellectual property. DOE also 

20 does not have enough information at this time to 

21 be sure that they positively impact efficiency. 

22 And then, in this category, the discussion 
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1 surrounding occupancy sensors is very similar. 

2 MR. BROOKMAN: Comments here? Yes, 

3 Christian. 

4 MR. TABER: Christian Taber, Big Ass 

5 Solutions. Blade attachments. The DOE 

6 statements here were that only one manufacturer 

7 uses blade attachments, that there is 

8 insufficient evidence that blade attachments 

9 improve efficiency. Comments from manufacturers 

10 indicated that blade attachments do not aid in 

11 efficiency. Basically, blade attachments are 

12 used on more than 50 percent of the available 

13 high-volume, large-diameter fans. We'll be 

14 submitting data that shows the difference between 

15 the exact same fan with and without blade 

16 attachments that can be used. 

17 I'm trying to think if there's anything 

18 else. Obviously, the use of blade attachments is 

19 common in the aerospace industry. There are a 

20 number of articles on that. And there are really 

21 only three manufacturers that do not use blade 

22 attachments, and of the major players in the 
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1 industry, there is only one. So they are much 

2 more common in the industry to have than to not 

3 have. 

4 MR. JASINSKI: Thanks. Yeah, we 

5 appreciate that and we appreciate any data that 

6 you can provide. If you were paying close 

7 attention, you could see how repetitive I get in 

8 saying that DOE is not currently aware of, and 

9 things to that nature. So DOE is not making the 

10 statement that these -- they're not concluding 

11 that these technologies are not commercially 

12 available or that they don't improve efficiency. 

13 It's mostly we're dependent on what information 

14 we can gather that's either through public means 

15 or, as we'll talk about later, there's other 

16 mechanisms through manufacturer interviews that 

17 are protected under NDA, things to that nature. 

18 So if you are aware of commercially 

19 available products that use the technologies that 

20 were screened out, or have information about how 

21 they impact efficiency, cost, all of those 

22 things, the Department would really appreciate 
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1 that, and those things can be considered in the 

2 next iteration of the analysis. 

3 MR. TABER: I have a couple more. Sorry. 

4 This is my world. 

5 MR. BROOKMAN: Please. 

6 MR. TABER: Fans with fewer blades is 

7 screened in, in this case. In previous slides it 

8 was screened out, for all of the other 

9 technologies, primarily due to a lack of 

10 available data, as there is no standard method of 

11 test in the circulator fan industry, and every 

12 company kind of does their own thing. Also, as 

13 the only manufacturer that makes fans with 

14 different blade counts, it's surprising that the 

15 DOE was able to find reliable information that 

16 shows that fewer blades actually increase 

17 efficiency. 

18 Again, it goes back to the more holistic 

19 approach of the number of blades does not 

20 determine the efficiency. Cord width, angle of 

21 attack, blade attachments, all paired with the 

22 number of blades determine, I may go with a 
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1 smaller number of blades but a wider cord for a 

2 specific fan. For another fan, I may go with a 

3 larger number of blades and a narrower cord, with 

4 a more steep angle of attack. It all depends on 

5 the fan to determine what the optimum efficiency 

6 is, and I think including it here while excluding 

7 it for the others is a little concerning. 

8 MR. JASINSKI: I believe, in this 

9 particular case, DOE was able to find two models 

10 that were identical, aside from blade count. Did 

11 we test those, or did we get the performance 

12 information from spec sheets, Aris? 

13 MR. MARANTAN: Aris Marantan, Navigant. 

14 We got that from spec sheets. We did identify 

15 specific set of fans from the same manufacturer 

16 with different blade counts. 

17 MR. TABER: As the only manufacturer that 

18 does different blade counts, that would be 

19 typical of one product model out of an entire 

20 industry. 

21 MR. JASINSKI: So you're saying it's not 

22 typical? 
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1 MR. TABER: I would say it would be a 

2 gross generalization of something that may or may 

3 not always be true. 

4 MR. JASINSKI: Okay. Thanks. 

5 MR. TABER: Sorry. I'm trying to think -

6 - 

7 MR. BROOKMAN: Okay. Moving on. 

8 MR. JASINSKI: Thanks. I'll hand it over 

9 to Aris to talk about the engineering numbers. 

10 MR. BROOKMAN: Dick has a comment before 

11 we move on. 

12 MR. UPTON: I'm not an engineer, number 

13 one. You're speaking significantly of your 

14 commercial product, are you not? 

15 MR. TABER: Christian Taber, Big Ass 

16 Solutions. Well, I guess one of the other things 

17 that's in here is the statement that HVLD fans 

18 are only used in industrial settings. Generally 

19 speaking, the DC motored fans -- for example, our 

20 Isis or Element or Essence lines are not 

21 necessarily industrial fans. The smaller22 diameter, high-volume, large-diameter can be used 
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1 in commercial more than industrial. The high2 volume, large-diameter 16-, 18-, 20-, 24-foot, 

3 those are primarily industrial environments, so 

4 it kind of depends. 

5 Noise is also a concern for us. It is 

6 not necessarily a concern in our industrial 

7 product lines, but one of the primary reasons 

8 that we don't use geared motors with VFDs in some 

9 of our products is that they are going into 

10 acoustically sensitive spaces, so if there are 

11 noise concerns with small-diameter fans going to 

12 fewer blades, there would also be concern on our 

13 part for large-diameter fans going to fewer 

14 blades for noise, for the commercial side of our 

15 product lines. 

16 MR. UPTON: You answered my comment. 

17 Significantly commercial? 

18 MR. TABER: It depends, but yeah. 

19 MR. UPTON: Application. 

20 MR. TABER: For the smaller fans, it 

21 would be generally be more of the commercial 

22 line, and for the larger fans, it would be more 
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1 the industrial line. 

2 MR. BROOKMAN: Okay. Thank you. 

3 MR. MARANTAN: Thank you, Sam. Okay. 

4 Now that we've discussed the screening criteria 

5 and what remains, we conduct the engineering 

6 analysis from those remaining technologies. So 

7 we call those the design options that are part of 

8 the next analysis, which is engineering. 

9 Okay. The purpose of the engineering 

10 analysis is to determine the relationship between 

11 manufacturer's selling price and efficiency. The 

12 methodology consists of five steps, which are 

13 outlined on this slide. The first step is to 

14 choose product classes and representative sizes. 

15 These are the ones that are to be analyzed. The 

16 second step is to select baseline efficiency 

17 levels. These are based on common features and 

18 bottom-of-the-market efficiency. 

19 The third step is to identify higher 

20 efficiency units. So for each representative 

21 product class and size, we identify the 

22 efficiency and cost of more efficient units, 
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1 based on design option modeling, product testing 

2 and teardowns. 

3 The fourth step is to develop efficiency 

4 levels for the analysis, that range from the 

5 baseline all the way up to max-tech, and the 

6 fifth step is to determine the cost-efficiency 

7 relationship. So the results of engineering 

8 analysis is a set of cost-efficiency curves, in 

9 terms of MSP versus efficiency, for each product 

10 class and representative size analyzed. These 

11 cost-efficiency curves are then used as inputs to 

12 the subsequent economic analysis, such as the 

13 LCC. 

14 I'll begin by describing the analysis 

15 conducted for low-volume first, and then we'll 

16 get into the analysis for high-volume after that. 

17 Okay. The first step consists of 

18 choosing product classes and representative 

19 sizes. For low-volume ceiling fans, two products 

20 classes and five representative size were 

21 identified. These are standard fans in 44 

22 inches, 52 inches, 60 inches, and hugger fans in 
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1 44- and 52-inch sizes. These representative 

2 sizes were chosen because they broadly represent 

3 the range of sizes available in each product 

4 class. Also, manufacturers stated that these 

5 sizes represent a large percentage of the sales 

6 and shipments for low-volume ceiling fans. 

7 So I'll pause here if there are any 

8 comments on this table of representative sizes 

9 and classes. 

10 MR. TURNER: David from Hunter. We would 

11 agree with that assessment, that those are the 

12 most widely used blade diameters. Yes, shipped, 

13 sold, imported. 

14 MR. MARANTAN: Okay. The second step 

15 consists of selecting baseline efficiency levels. 

16 Because there is currently no performance 

17 standards for ceiling fans, just design 

18 requirements, currently, baseline efficiency 

19 levels were selected based on common features and 

20 bottom-of-market efficiencies. However, in 

21 conducting the analysis, we found that the most 

22 common types of ceiling fans on the market was 
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1 not the least efficient. 

2 Most low-volume ceiling fans on the 

3 market, and most ceiling fan sales, consist of 

4 fans with four or five flat blades that are made 

5 of wood or wood composites like plywood or MDF, 

6 and also have single-phase induction motors. 

7 However, the least efficient fans on the market 

8 consist of unconventional blades, which, for 

9 example, are ones shaped like palm leaves. Fans 

10 with unconventional blades are generally less 

11 efficient than similarly sized fans with flat 

12 blades. 

13 So, because unconventional-blade fans 

14 tend to have lower performance characteristics 

15 but serve a specific market niche, the cost and 

16 efficiency of both types were analyzed 

17 separately. The results of both types were then 

18 combined to create an aggregate curve. We chose 

19 to use an aggregate curve for flat and 

20 unconventional-blade fans, as opposed to defining 

21 two separate product classes, because fans with 

22 flat blades and fans with unconventional blades 
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1 are functionally indistinguishable. Both fan 

2 types move air via the rotation of blades, 

3 improve comfort by this air movement, and can be 

4 used in similar spaces. Further, since flat 

5 blade and unconventional-blade fans on the market 

6 appear to operate within the same CFM range, they 

7 both have the same product capacity. 

8 So, again, I'll pause here for any 

9 comments. 

10 MR. BROOKMAN: Marianne. 

11 MS. DIMASCIO: If we could insert my 

12 earlier comment in here, this is what I was 

13 talking about, the palm blades. When you said 

14 airfoil, I misspoke. So I was talking about 

15 this. 

16 MR. CYMBALSKY: I went the other way on 

17 it. 

18 MS. DIMASCIO: Yeah. 

19 MR. BROOKMAN: Okay. Thank you. 

20 MR. MARANTAN: Okay. Continuing. This 

21 slide gives a little more detail on how we went 

22 about selecting the baseline efficiency levels. 
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1 The following tables show the efficiencies of the 

2 market-minimum flat blade and unconventional3 blade fans identified in the market. I'd like to 

4 note that the efficiencies for the hugger product 

5 class are based on the use of an artificial 

6 ceiling, as proposed in the test procedure NOPR. 

7 The efficiencies provided in this table are 

8 calculated based on an aggregate efficiency 

9 formula that was also described in that test 

10 procedure NOPR. 

11 As described previously, the baseline 

12 efficiency is the efficiency of the least 

13 efficient fan identified on the market, for each 

14 product class and representative size. 

15 Therefore, the baseline efficiency selected for 

16 low-volume ceiling fans was identified as the 

17 efficiency of the market-minimum, unconventional18 blade fans. The baseline efficiencies for the 

19 aggregate curve are circled in the table here. 

20 So, again, I'll pause here for comments. 

21 MR. BROOKMAN: Christian. 

22 MR. TABER: Christian Taber, Big Ass 
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1 Solutions. So, I just want to make sure I've got 

2 this straight in my head. The hugger fans were 

3 tested with a false ceiling, so that's the new 

4 proposed test method? That's their CFM per watt? 

5 MR. MARANTAN: Correct. That's the values 

6 with the asterisks. 

7 MR. TABER: And then the standard ceiling 

8 fans were tested via the current Energy Star 

9 method, or via the new method minus the drop 

10 ceiling? 

11 MR. MARANTAN: The values on this table 

12 are using the current Energy Star method. In our 

13 TSD, Chapter 5, engineering analysis, we provide 

14 both. 

15 MR. TABER: Okay. 

16 MR. MARANTAN: Okay. Continuing. The 

17 third step consists of identifying higher 

18 efficiency units above the baseline. DOE 

19 identified a selection of fans for analysis that 

20 spanned a range of the manufacturers and 

21 efficiencies of commercially available products, 

22 and incorporate the design options being 
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1 considered in this rule. The units selected were 

2 tested and then disassembled for costing 

3 purposes. 

4 Next, estimates of the factory cost were 

5 developed for each unit torn down, and a bill of 

6 materials was developed. This information was 

7 used to calculate the cost of each individual 

8 component, for example, blades, motor, motor 

9 housing, packaging controls, and final assembly. 

10 Then, component costs and other inputs to the 

11 cost model were validated against manufacturer 

12 input. 

13 Finally, a cost model was developed to 

14 estimate the factory cost of the fans that were 

15 not specifically torn down. The models were 

16 developed such that when design specifications 

17 for a certain fan are entered, it estimates the 

18 factor cost, based on the average component costs 

19 that were developed in the tear-downs. 

20 I'll pause here. All right. 

21 The next step in the analysis is to 

22 develop efficiency levels for the curves. DOE 
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1 examined each design option being considered, to 

2 see how much each would increase the efficiency 

3 and cost of a baseline ceiling fan. From here, 

4 cost and efficiency deltas were developed for 

5 each design option. To calculate these deltas, 

6 we identified fan technology pairs for each of 

7 the design options, based on a variety of 

8 sources, including test data, manufacturer 

9 specifications, retail prices, manufacturer 

10 interviews, and the tear-down analysis. 

11 A fan technology pair is a pair of 

12 ceiling fans in the same product class with the 

13 same blade diameter, where one fan possesses a 

14 particular design option being considered, while 

15 the other fan does not, and all other features 

16 remain the same in both fans. We tested at least 

17 one fan technology pair for each design option, 

18 and used the results to calculate the change in 

19 efficiency, or efficiency delta, and the change 

20 in cost, or cost delta, for that particular 

21 design option. The efficiency and cost deltas 

22 were then compared to and combined with catalog 
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1 data and input from manufacturers to arrive at a 

2 final estimate of the efficiency improvement 

3 attributable to that design option. 

4 So, you can see here, at the bottom of 

5 this slide, the design options, in terms of 

6 increasing efficiency deltas, were determined to 

7 be (1) fan optimization, (2) larger direct-drive 

8 motor, and (3) a DC motor. 

9 MR. BROOKMAN: Bill. 

10 MR. WALKER: Bill with Hunter Fan. So, 

11 for the larger direct-drive motors, can you 

12 expand a little bit on what size motor you went 

13 from to what size motor you went to? 

14 MR. MARANTAN: I don't remember exactly 

15 the sizes that were used. We could look that up 

16 for you. I can get -- 

17 MR. BROOKMAN: Do you have -- does this 

18 not make sense to you, or is it -- 

19 MR. WALKER: Well, one consideration I 

20 would have, just going to a larger motor, (1) 

21 you're going to increase your tip speed. Do you 

22 know that you stayed within the tip speed 
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1 requirements of UL when you went to the larger 

2 motor? 

3 MS. KUMAR: This is Mythri Kumar from 

4 Navigant Consulting. Yes, we kept within the tip 

5 speed of the UL. 

6 MR. WALKER: Okay, and then the first 

7 question, what size motor did you go from and to? 

8 Do you know? 

9 MS. KUMAR: We went from 153-15 to a 172-

10 14. 

11 MR. WALKER: 153-15 to a what? 

12 MS. KUMAR: 172-14. 

13 MR. WALKER: 172-14. 

14 MS. KUMAR: But we also used efficiency 

15 delta information from manufacturer interviews 

16 and combined both our test results, and those 

17 results we got from manufacturer interviews to 

18 come up with the efficiency delta. 

19 MR. BROOKMAN: Okay. Yes. Dave. 

20 MR. GATTO: Dave Gatto, Westinghouse. 

21 Just while you've got that information available, 

22 did you record the wattage at each motor size? 
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1 MS. KUMAR: This is Mythri Kumar from 

2 Navigant Consulting. Yeah. Yes, we did. We 

3 recorded both the CFM and wattage. 

4 MR. GATTO: Do you have that in front of 

5 you? It's okay if you don't. Just -- 

6 MS. KUMAR: How about I look it up and 

7 get back to you? 

8 MR. GATTO: Yeah. I don't have a problem 

9 letting her get back. 

10 MR. BROOKMAN: That's okay. Okay. 

11 David? 

12 MR. TURNER: David with Hunter. Aris, 

13 can you take us through exactly what's included 

14 in fan optimization, the different items? 

15 MR. MARANTAN: Sure. For the fan 

16 optimization, we considered that manufacturers 

17 would make small adjustments to existing fans 

18 that they already produce, and these would 

19 include things such as changing the blade pitch 

20 and adjusting the RPM of the fan rotation, so 

21 very nominal changes. 

22 MR. WALKER: You said adjusting the RPM, 
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1 just redesigning the motor? Or adjusting RPM 

2 how? 

3 MR. MARANTAN: Well, I think we're not 

4 exactly sure what the manufacturers would choose 

5 to do, in terms of that, but what we've heard was 

6 small adjustments such as that would be 

7 considered. 

8 MR. BROOKMAN: Yes, please. Chuck. 

9 MR. MATTHEWS: Chuck Matthews, Matthews 

10 Fan Company. I know, with our product, we've 

11 always tried to produce as much CFM as possible, 

12 but once you increase the angle of the blade iron 

13 to the -- once you increase the angle of the 

14 blade iron, you would also increase heat rise on 

15 the motor, and then you run afoul of UL rules and 

16 guidelines, and CSA also. So it's not a question 

17 of just increasing blade iron pitch. If that 

18 were the case, we would've already done that. 

19 But sometimes we're already operating at the 

20 highest level, the highest pitch we can, so that 

21 our motors operate safely. 

22 MR. BROOKMAN: Okay. Thank you. Yes. 
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1 Additional comments here? Bill. 

2 MR. WALKER: Hunter just agrees with 

3 that. It is a tradeoff there. 

4 MR. BROOKMAN: Okay. 

5 MR. MARANTAN: Okay. The last step 

6 consists of determining the cost-efficiency 

7 relationship. DOE created two separate cost8 efficiency curves by applying the efficiency and 

9 cost deltas for each design option to the cost 

10 and efficiency values of the market-minimum fans. 

11 The first point in the curve represents the 

12 market-minimum fans, and each subsequent point 

13 represents design options applied to the baseline 

14 design. 

15 As mentioned earlier, two cost-efficiency 

16 curves were developed, based on the two market17 minimum low-volume ceiling fans, one for 

18 unconventional blades and one for flat blades. 

19 This was done for each product class and 

20 representative size. Unconventional blade fans 

21 make up about 2 percent of the market while flat22 blade fans make up about 98 percent of the 
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1 market. These relative market shares were then 

2 used to aggregate the two cost efficiency curves 

3 into a single curve for each product class and 

4 representative size. 

5 The resulting efficiency levels for the 

6 aggregate curves are shown in the table here, and 

7 I also have a graphic on the next slide. This 

8 slide shows, graphically, how the two individual 

9 curves were aggregated. The green curve 

10 represents the unconventional-blade fans, which 

11 are 2 percent of the market; the red curve 

12 represents the flat-blade fans, which represent 

13 98 percent of the market; and the black curve 

14 represents the aggregated curve, which is based 

15 on the relative weightings of the green and the 

16 red curve. 

17 You'll see here that the baseline 

18 efficiency level of the aggregate curve is the 

19 least efficient fan on the market, and the max20 tech efficiency level of the aggregate curve is 

21 the maximum efficiency of the unconventional22 blade fans. 
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1 MR. GATTO: Dave Gatto, Westinghouse 

2 Lighting, and I want to preface this with I don't 

3 have an objection to the curve itself, but I 

4 would ask DOE, did you consider that the 

5 potential, when you aggregate this way, the 

6 unconventional-blade options may not be able to 

7 meet the standard, which would remove a 

8 decorative utility? 

9 So, again, I don't really have a -- from 

10 a Westinghouse Lighting standpoint, it's more of 

11 a, how did DOE bake that in, the fact that 

12 there's a utility there that you recognize 

13 consumers want, that potentially could be weeded 

14 out because of the way you did the aggregate 

15 curve. And I actually agree with the math. I'm 

16 saying how did you account for that, or did you? 

17 MR. CYMBALSKY: We did. Actually, I can 

18 answer this question. I was actually there and 

19 was drawing the plot. So, yes, we did exactly do 

20 that with this graph. So, as Aris pointed out, 

21 you could see that the max-tech actually 

22 represents the unconventional-blade, for that 
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1 reason. That's how we preserved the utility. 

2 MR. BROOKMAN: Additional thoughts, 

3 comments? We're going to keep moving then. 

4 MR. MARANTAN: Okay. Since research 

5 indicated that low-volume ceiling fans are 

6 manufactured overseas, a factory markup of 1.2 

7 was used to calculate the manufacturer production 

8 cost, or MPC. This was determined based on DOE 

9 experience with other rules that involve units 

10 produced overseas and sold into the United 

11 States. 

12 Next, a manufacturer markup of 1.37 was 

13 determined, based on an examination of data 

14 obtained from publicly traded ceiling fan 

15 manufacturers, and an aggregation of data from 

16 manufacturer interviews. This markup was applied 

17 to the MPC to calculate the manufacturer selling 

18 price, or MSP. Using this analysis, DOE was able 

19 to determine a set of cost-efficiency 

20 relationships for each design option in the form 

21 of MSP versus efficiency and CFM per watt, for 

22 each product class and representative size. 
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1 MR. GATTO: Dave Gatto, Westinghouse 

2 Lighting. Sorry. Just a question. I know I 

3 provided a lot of information, and I'm sure the 

4 others did, to Mythri, or whoever you work with 

5 on the manufacturing interview. So, 1.2, does 

6 that include the, was it 4.7 tariff, or are you 

7 leaving that out, because, currently, ceiling 

8 fans are subject to a duty that applies on top of 

9 the factory cost. 

10 MR. MARANTAN: We did not leave it out 

11 but that's not part of the 1.2. It's part of the 

12 distribution channel. 

13 MR. GATTO: So, I'm not sure what that 

14 means. The MPC is -- 

15 MS. ARMSTRONG: It's in the markup 

16 analysis. 

17 MR. MARANTAN: It's the next section of 

18 the analysis. 

19 MR. GATTO: Okay. Thanks. 

20 MR. MARANTAN: Okay. This slide shows 

21 example results of the engineering analysis. DOE 

22 plotted the efficiency and aggregated CFM for all 
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1 representative sizes at each efficiency level and 

2 connected the points with straight lines. The 

3 resulting graph shows the baseline efficiency 

4 level, with the various candidate standard levels 

5 above the baseline as a function of fan diameter. 

6 And I will note that we have a series of tables, 

7 also, in Chapter 5, Section 10 of the TSD, that 

8 describes all the results for every product class 

9 and representative size. 

10 MR. CYMBALSKY: This is John at DOE. So, 

11 we're going to push the fast-forward button here. 

12 We're going to flip a little bit, but, from what 

13 I heard, there are some stakeholders who want to 

14 make comments on the prices. Can you skip to 

15 Slide 129, please? 

16 Okay. So we just did the engineering 

17 analysis for this product, as we're going to go 

18 back, but I think it's appropriate now to bring 

19 up what we think about the installed costs for 

20 the options that you just saw. So, here they 

21 are. You can look at the numbers, and this is, I 

22 think, where some folks wanted to comment, if I 
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1 understood correctly. 

2 So, I wanted to give you that 

3 opportunity. We're after two o'clock now, so 

4 we'll just open it up here. 

5 MR. TURNER: Can you explain -- so, I 

6 think yesterday when we were going over -- this 

7 is David from Hunter -- when we were going over 

8 the light kits, the cost delta between the 

9 different efficiency levels was just, on light 

10 kits, it was just the bulbs and the associated 

11 hardware that would make it LED, which was the 

12 CSL category. So, the difference between EL3 and 

13 4, I guess, what changes with the fans, so that 

14 we know that -- how do you get to the 120 to 149? 

15 MR. MARANTAN: EL4 is the efficiency 

16 level for a DC motor, and so it's just the 

17 incremental difference between a DC motor and the 

18 AC motor. 

19 MR. TURNER: So that's the only 

20 difference between the two efficiency levels? 

21 MR. MARANTAN: Yeah, and then that's 

22 marked up throughout the distribution chain, as 
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1 well, so there's markups along the distribution 

2 channel, and that's how we arrive at the 

3 installed costs. 

4 MR. TURNER: So that's a retail 

5 difference of $29? 

6 MR. MARANTAN: The numbers you see here. 

7 MR. BROOKMAN: Yes. Nathan. 

8 MR. FRAMPTON: Nathan with Fanimation. 

9 The difference isn't just AC versus DC, though, 

10 right? It's EL2 plus DC? 

11 MR. BROOKMAN: Correct. It's additive. 

12 MS. KANTNER: Can I provide a quick 

13 clarification? EL4 doesn't represent DC motors 

14 for all fans. It only represents for those that 

15 have unconventional blades. Most fans at EL4 

16 have AC motors, right? 

17 MR. MARANTAN: Yes. It represents the 

18 aggregation that we did in that last step, as 

19 well. 

20 MR. WALKER: I'm confused, all of a 

21 sudden. 

22 MR. TURNER: I'm very confused. 
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1 MR. BROOKMAN: If you go back to 90 -- 

2 MR. TURNER: I'm on 90. 

3 MR. BROOKMAN: And then you see EL3 is 

4 EL2 plus larger direct-drive motors, and EL4 is 

5 EL2 plus DC. 

6 MR. TURNER: Just to clarify, is EL2 

7 something that's an existing product, or did you 

8 take an EL1 product and make modifications? 

9 MS. ARMSTRONG: I think what you're 

10 asking is, we start up -- they're cumulative, 

11 right? This is what this shows. So, if you're 

12 asking, we take a baseline product. We would 

13 then modify it each step of the way, and the cost 

14 deltas you see are the deltas with respect to 

15 those designs. 

16 MR. TURNER: Right. I understand that. 

17 So, on EL2, is that a modification that the DOE 

18 tested, or is that a product that exists on the 

19 market? 

20 MR. MARANTAN: The EL2 is based on EL1 

21 plus the fan optimization deltas that were 

22 calculated in the previous step, so those deltas 
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1 were based on an examination of products with and 

2 without that particular design option. 

3 MS. ARMSTRONG: So products on the market 

4 today. 

5 MR. BROOKMAN: Yes, please. Marianne. 

6 MS. DIMASCIO: Marianne DiMascio, ASAP. 

7 So, based on Colleen's comment about EL4, saying 

8 that that is really for the unconventional 

9 blades, I guess I'd ask my question again, of why 

10 wouldn't you have separate categories for 

11 unconventional blades and regular blades, or 

12 classes? 

13 MR. CYMBALSKY: So that goes back to the 

14 utility issue, where we combined the curves. 

15 MS. DIMASCIO: Right. Is there an answer? 

16 MR. BROOKMAN: He thought he answered it. 

17 MR. CYMBALSKY: It's one curve. 

18 MS. DIMASCIO: Right. Is there a reason 

19 you would not have two separate classes there, 

20 one for the unconventional blades and then one 

21 for the others? 

22 MS. ARMSTRONG: I think we felt that this 
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1 was the right way to do this, so obviously that's 

2 out for thought. 

3 MR. CYMBALSKY: Yeah. You can comment on 

4 that, but I think this way, actually preserves 

5 the utility from the unconventional blades. 

6 MR. BROOKMAN: Clark. 

7 MR. LINSTONE: I'm sorry. I'm still not 

8 -- Clark Linstone, Lamps Plus. I'm still not 

9 clear on just, for DC motor with conventional 

10 blades, that is under EL -- what? 

11 MR. CYMBALSKY: If you go back to the 

12 graph where you -- yeah, that. So we're looking 

13 at the black line here. So you could see the end 

14 of the black line is what EL4 represents. 

15 MR. FRAMPTON: They use green to get to 

16 black, but there's no red. 

17 MS. ARMSTRONG: I mean, black is so 

18 closed to red, but -- 

19 MR. BROOKMAN: Okay. Thank you. 

20 MR. CYMBALSKY: Now let's return to Slide 

21 129, and get your thoughts, comments on these 

22 cost figures. 
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1 MR. GATTO: I'm going to encourage other 

2 fan guys to chime in, but I'm just going to say 

3 that because I was confused when I reviewed this 

4 in the original document, when I first reviewed 

5 it, because I kind of had that same perception of 

6 how the ELs were calculated, so, the one comment 

7 I would make is that I think the installed cost 

8 for EL0 is probably 30 to 40 percent high. I 

9 think what's missing there, because I don't 

10 believe Navigant received any direct information 

11 from the two largest retailers, is there's a 

12 large segment of volume that's associated with 

13 fans that are direct factory to the two largest 

14 retailers. 

15 You may have captured the efficacy of 

16 those fans by looking at market data, but I don't 

17 know that you captured the installed cost, 

18 because the sheer volume that those two, or even 

19 if you count three, the way you guys had it laid 

20 out in the TSD, that would shift that needle 

21 down. I think $107 might be appropriate if 

22 looked at the fan manufacturers represented here, 
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1 but I don't think it represents the market, if 

2 that makes sense. 

3 MR. CYMBALSKY: John with DOE. So if I 

4 go to Home Depot and I bought the baseline unit, 

5 and have somebody install it for me, you think 

6 it's not $107? 

7 MR. GATTO: So, I was under the 

8 impression that you were not including 

9 installation cost, in terms of contractor cost, 

10 that it was -- 

11 MR. CYMBALSKY: This is just the off-the12 shelf cost. Okay. 

13 MR. GATTO: Yeah, so I could be wrong, 

14 John, so could Navigant confirm that it's off15 the-shelf cost versus installed with contractor 

16 cost, because that might change my answer. 

17 MS. KANTNER: Colleen Kantner, Lawrence 

18 Berkeley National Lab. I can confirm that that 

19 did not include installation costs. 

20 MR. GATTO: I think this came up in the 

21 earlier one, where the exposure to DYI product, 

22 and we agreed, as an industry, that you would 
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1 leave it out of the installed cost. 

2 MR. CYMBALSKY: So this is the retail 

3 price. 

4 MR. GATTO: That being the retail, I 

5 don't know what the right number is, but I think 

6 if you went to Home Depot, you wouldn't 

7 necessarily, for that low-efficiency fan, pay -- 

8 I hate to say anywhere close, but it would 

9 probably be $30, or possibly more, less. 

10 MR. CYMBALSKY: We'll go to the one in 

11 Manhattan and we'll see how much it costs. 

12 MR. GATTO: I don't have a response that 

13 I can give on the record. 

14 MR. BROOKMAN: Additional thoughts on 

15 these cost figures. Yes, please. Clark. 

16 MR. LINSTONE: Clark Linstone, Lamps 

17 Plus. I think Dave Gatto's point is very 

18 important, because the sheer volume of the lower19 cost fans is very significant in this market. 

20 We're retail and kind of the mid and higher price 

21 points, but everything we've seen, in terms of 

22 just the sheer volume at the lower price points, 
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1 it's very significant to this discussion. 

2 MR. BROOKMAN: Okay. 

3 MR. CYMBALSKY: This is John from DOE. 

4 So, do you think the whole curve shifts down, or 

5 are you just focused on the lower ELs here, such 

6 that the spread would be bigger, or are we 

7 talking about shift in the curve? 

8 MR. GATTO: Dave Gatto, Westinghouse 

9 Lighting, and that's why I kind of spoke it the 

10 way I did, John. I don't know that I have the 

11 answer to that. I think the lower end, 

12 particularly EL0, because that's the baseline, I 

13 think that would definitely shift it. It might 

14 not shift much at 1, but it might a little bit if 

15 you factored them in, because they do have quite 

16 a bit of $99 fans that are probably at that EL1 

17 level. I think, at the top end -- and I'm going 

18 to loudly encourage my competitors, my 

19 compatriots -- I'm just going to use a different 

20 word here -- 

21 [Laughter.] 

22 MR. GATTO: -- to chime in. I think at 
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1 EL4, now that I understand that EL3 and 4 are 

2 direct-drive with optimization and DC, I think 

3 those numbers are probably low. I think what you 

4 really have is a bell curve, and the bottom end 

5 is a little high and the top end is a little low. 

6 But it may be a lot high or a lot low on the top 

7 end, and you guys really have to weigh in here. 

8 MR. BROOKMAN: David. Oh, go ahead. 

9 Nathan, go ahead. 

10 MR. FRAMPTON: This is Nathan with 

11 Fanimation. I agree. I think EL0 is too high, 

12 and I think EL4 is too low. 

13 MR. BROOKMAN: If you can -- is it 

14 possible to say what you think it is? 

15 MR. FRAMPTON: I mean, right here I'd 

16 just be, not guessing, but I'd rather do that in 

17 a formal comment. 

18 MR. BROOKMAN: Doug. 

19 MR. TURNER: This is Dave from Hunter. 

20 I'm with Nathan. I'd rather do that in a written 

21 comment, but I can say that EL4, the lowest 

22 retail DC motor fan on the market, the lowest, is 
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1 $149, and if that's being used as -- I mean, 

2 everything else is, well, it ramps up from there, 

3 I guess, so I don't think that should be used as 

4 the, kind of the baseline for EL4, because it's 

5 the lowest available right now. 

6 MR. CYMBALSKY: Clarification there. So, 

7 you're saying there -- but there is one that is 

8 $149? 

9 MR. TURNER: I believe so. 

10 MR. CYMBALSKY: Okay. Thank you. 

11 MR. BROOKMAN: Nathan. 

12 MR. FRAMPTON: Nathan with Fanimation. 

13 The model he's speaking of is a loss leader 

14 across all factory manufacturer distributor. 

15 MR. BROOKMAN: Okay. Colleen. 

16 MS. KANTNER: Hi. I just wanted to 

17 clarify again that only 2 percent of the fans 

18 that were included in that price had DC motors, 

19 at EL4. 

20 MR. BROOKMAN: Okay. Nathan. 

21 MR. FRAMPTON: I thought EL4 was DC 

22 motors, so wouldn't all in that category be DC 
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1 motor? 

2 MS. KANTNER: Colleen Kantner, Lawrence Berkeley 

3 National Lab. That was only for the 

4 unconventional blades. 

5 MR. MARANTAN: I can clarify here. If we 

6 go back to Slide 90, 91, you'll see here, on the 

7 black curve, the top end is EL4. That particular 

8 point represents the top end of the green, which 

9 is the 2 percent that Colleen was speaking of, 

10 that had the DC motors, and 98 percent of the red 

11 at that point, which do not. 

12 MR. GATTO: Dave Gatto, Westinghouse 

13 Lighting. I think that if EL4 requires a DC 

14 motor with a palm blade -- as, an example, 

15 unconventional blade -- and I'm going from 

16 looking at what the metrics were and plugging it 

17 into some calculators, I think the concern I 

18 would have is that setting the standard that a DC 

19 motor fan with an unconventional blade can meet, 

20 I agree with DOE that preserving the utility is 

21 important, even though it's only a small 

22 percentage of the marketplace. 
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1 I think that averaging the price of that, 

2 unless your EL4 is a CFM per watt that a non-DC 

3 motor fan could hit with a flat blade, then that 

4 would be a challenge. That wouldn't make sense 

5 to me. 

6 So, again, it's more about the analysis. 

7 So, if a DC motor fan with a flat blade is 

8 required to hit EL4, then you really need to use 

9 the weighted average of pricing based on DC motor 

10 fan, which is what would be needed to meet that 

11 efficiency level. 

12 Am I saying that right? I know, John, 

13 this is one of those things where I may not be 

14 saying it right, but I think you know where I'm 

15 at. 

16 MR. CYMBALSKY: Yeah. So, it depends on 

17 where on that red line the motor swap-out is. 

18 MR. GATTO: Yes. I agree, I think, but 

19 if we don't know where that is, then I don't know 

20 how to say whether that $149 price is 

21 appropriate, or it's way too low, and I want to 

22 be able to give valid feedback to DOE, or I think 
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1 we all do. 

2 MS. ARMSTRONG: Okay. So I think there's 

3 a more disaggregated example in the appendix of 

4 the TSD that I'm going to point you to, where you 

5 can see the red line and the green line in 

6 tabular format. So I think that will help get to 

7 the answer, because it seems like we're blurring 

8 lines with the weighted average of getting to the 

9 black line. So this will help you get your -- I 

10 think get us more, better feedback on what 

11 designs are implemented where, for discretely, 

12 for the red line and the green line. 

13 MR. GATTO: That would be great. 

14 MS. ARMSTRONG: It's in the appendix. 

15 So, I don't know exactly, but I'll point you to 

16 the right direction. 

17 MR. BROOKMAN: What is it? 

18 MS. KUMAR: It's Appendix 5A. 

19 MR. BROOKMAN: 5A. Appendix 5A. Nathan, 

20 do you want to comment here? 

21 MR. FRAMPTON: I'm not sure I totally 

22 understand, but if EL4 is a DC motor with 
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1 unconventional blades, then the $149 is grossly 

2 too low. 

3 MR. CYMBALSKY: No. So, again, it's 2 

4 percent of that value represents that. Ninety5 eight percent represents the point on the red 

6 line. Okay. So the point way up on that red 

7 line is the DC motor, the endpoint, so we're 

8 marching back from that. 

9 MS. ARMSTRONG: Take a look at the table, 

10 and if it's still unclear, let us know. I think 

11 the aggregation of the cost, the weighting of the 

12 cost, is what's causing confusion. If you were 

13 to see that the green line was actually, you 

14 know, double it -- I have no idea what it is, but 

15 I'm just making something up -- then maybe it 

16 makes a little more sense to you. 

17 MR. FRAMPTON: I understand the black 

18 line. I just don't understand the -- 

19 MS. ARMSTRONG: Yeah. So, we do it step20 by-step to get the green line, and then we do it 

21 step-by-step to get the red line, and the numbers 

22 are very different, and then the weighted average 
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1 is the aggregate of the number that you're 

2 referencing. So, let's take it back to the 

3 original table first. 

4 MR. CYMBALSKY: But we all agree that the 

5 black line preserves the market for these 

6 unconventional blades, right? That's the whole 

7 point here. 

8 MR. GATTO: Dave Gatto, Westinghouse. I 

9 think so. I haven't looked at it in that much 

10 detail, but if it's built the way you've 

11 described it, I think, yes. I think that was 

12 what we were hoping for. I have to look at the 

13 detail, but I appreciate that you went in that 

14 direction. 

15 MR. BROOKMAN: Let me note that it's 

16 2:25, and if some of you are heading out of here 

17 at 3:00, then let's keep zeroing in on comments 

18 that you wish to make, maybe about costs, maybe 

19 about other things. 

20 Do you want to comment on the hugger 

21 results, or do you want to move on to a different 

22 section? David. 
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1 MR. TURNER: Is there another section 

2 where we would make comments on the LCC? 

3 MR. BROOKMAN: Yes. 

4 MR. CYMBALSKY: The question I have now, 

5 we could repeat what we just did for the two 

6 other types, so going through the engineering 

7 analysis for the high-volume stuff, or we can 

8 table that and you can all comment on that in 

9 your written comments, and it's up to everyone 

10 here, for the sake of time. What makes more 

11 sense to you guys -- because it's just going to 

12 be repetitive for the different classes? 

13 MR. GATTO: Dave Gatto, Westinghouse. 

14 We'll provide this in written comments. The 

15 baseline selected for high-volume, small-diameter 

16 is the only place, I think, we have any comments 

17 there, was, admittedly, thank you to Navigant, 

18 most likely because you couldn't find them, but 

19 we believe the least efficacious product out 

20 there is 95 CFM per watt, not 231, and we'll 

21 provide a number of -- it's the 56-inch fan, I'm 

22 sorry, the 56-inch baseline fan. The majority of 
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1 sales in that 56-inch fan are just a spinner. 

2 They're in the $95 to $115 range in the 

3 marketplace. And there may be higher out there, 

4 but I'm just saying that, at the least 

5 efficacious, which was the baseline selection, I 

6 just think you picked the one that you found at a 

7 major home center, but that's not really the 

8 market for these products. 

9 MR. BROOKMAN: Okay. David. 

10 MR. TURNER: Sorry. I just know if this 

11 is the correct spot, and we've addressed it in 

12 other written comments, but about our concerns 

13 with DC motor as a mandate. Do we lay those out 

14 here, or do we just put them in written comments? 

15 MR. CYMBALSKY: So, there's no proposal 

16 here. I understand your concerns with the DC 

17 motor. We've heard them. I want to make it 

18 clear that we are not proposing any level here. 

19 All we're showing is what's available on the 

20 market and what the engineering cost curves look 

21 like, based on what we've done. Certainly you're 

22 free to comment and think that that shouldn't be 
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1 a proposal, but I think, at the proposal stage, 

2 is where you really come out. If DOE were to 

3 propose that, then, obviously, you'll have strong 

4 comment. We're not doing that here. All we're 

5 showing is, this is the range of possibilities, 

6 and we're taking comment on the numbers that are 

7 backing up those range of possibilities. But 

8 you're free to make that comment, as well. 

9 MR. TURNER: It might be best in the 

10 written comment, because I know we're time11 pressed. But we will be commenting. I 

12 understood what you said, though. 

13 MR. CYMBALSKY: These numbers are just 

14 numbers, and there's no -- we didn't check a box 

15 next to the EL or CSL here. 

16 MR. BROOKMAN: Dick. 

17 MR. UPTON: Thank you for just keeping an 

18 open mind, which is what I'm hearing you say, and 

19 we appreciate that. 

20 MR. CYMBALSKY: Absolutely. There have 

21 been no decisions made whatsoever on what the 

22 standards will be. We are not anywhere close to 
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1 doing that. 

2 MR. BROOKMAN: What is the most 

3 productive thing for us to pursue in the next 

4 half an hour? 

5 MR. CYMBALSKY: There are definitely a 

6 few topics that I think most people -- 

7 MR. UPTON: What do you want to cover, 

8 John, while you've got us? 

9 MR. CYMBALSKY: So, I would say there's 

10 the whole issue of cooling versus fan use, and 

11 shipments, are ones that I've heard were 

12 important to you all. So we can cover that next. 

13 MR. BROOKMAN: Okay. What slide is that 

14 about. 

15 MR. CYMBALSKY: 114. That's right, and 

16 Aris is standing up there. You don't have to 

17 stand up there anymore. I think I'll take the 

18 arrows for this one. 

19 MS. ARMSTRONG: You don't have to stand 

20 up there, either. 

21 MR. CYMBALSKY: Yeah. Okay. So Slide 

22 114. We've heard a lot of public comment about 
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1 the use of ceiling fans and the use of either 

2 room air conditioning or central air 

3 conditioning, so we did actually do an RFI on 

4 this topic in October. We looked at lots of 

5 different studies out there. I think we worked 

6 with the industry to try to come up with more 

7 data on this issue. 

8 And what we showed yesterday -- we didn't 

9 really go into shipments yet today, but we showed 

10 yesterday, I think, and most of you were here, 

11 that based on the numbers that you saw in the 

12 previous table, with the costs, DOE does not 

13 believe there is a significant impact on the 

14 shipments, based on the numbers that we've seen. 

15 And so it is DOE's position that if 

16 shipments are not impacted by the ELs proposed 

17 here -- and, again, we didn't pick one -- we 

18 don't see this interaction as being an issue. So 

19 I'm just going to make that statement and then 

20 let you guys react to it. 

21 MR. TURNER: David with Hunter. And this 

22 might be my inexperience with how these processes 
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1 go. It's kind of my first one. The EL0 has a 

2 $42 jump to EL4. Am I reading that right -- 

3 that's a $42 retail increase over what that 

4 product is now? I just want to make sure I'm -- 

5 MR. CYMBALSKY: So, but weighted, based 

6 on the fact that 98 percent of EL4 in that 

7 number, I believe will not be a DC motor, because 

8 we're not at the top of that red line. For 2 

9 percent it would be, the unconventional blades, 

10 on that max-tech would have a DC motor, so 2 

11 percent, and then 98 percent of the product of 

12 that price, of that weighting, would not, would 

13 have a more efficient AC, I'm guessing, by where 

14 it is on the curve. 

15 MR. TURNER: But the $149 is 

16 representative of -- it's got the weighting in 

17 there? 

18 MR. CYMBALSKY: Yes. 

19 MR. TURNER: So $149 is where the retail 

20 would end up? 

21 MR. CYMBALSKY: Right. So of that, 2 

22 percent of that number would be higher, because 
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1 it had the DC motor in it, and 98 percent would 

2 be -- 

3 MR. TURNER: So $148 is the 98 percent? 

4 MR. CYMBALSKY: Yeah. Something like 

5 that. 

6 MR. TURNER: I guess that would be where 

7 -- when the statement was made that shipments 

8 won't be impacted with a large shift in retail 

9 like that, from a baseline product, or even the 

10 EL1 of the aggregated market minimum, that's 

11 where I think the industry disagrees that with 

12 that big of a retail jump, there is going to be 

13 an impact in shipments, and based upon the 

14 studies, one being the LBNL study that certain 

15 people do offset their AC usage with ceiling 

16 fans, that there will be a shipment impact, and, 

17 therefore, an energy offset. 

18 MR. CYMBALSKY: What I'm understanding 

19 from your comment is that you see -- we're going 

20 to just talk room AC here. Does that simplify 

21 it, window units, or -- 

22 MR. TURNER: Uh -- 
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1 MR. CYMBALSKY: Because you're talking 

2 about shipments, right? So people are going to 

3 either purchase a ceiling fan -- 

4 MR. TURNER: My offset was, instead of 

5 purchasing a ceiling fan, they would use their 

6 HVAC -- 

7 MR. CYMBALSKY: Whatever is already 

8 installed in their house. 

9 MR. TURNER: Mm-hmm. And, Colleen, I 

10 don't know if you can comment. That's what this 

11 would be, correct? This is from the LBNL study, 

12 the impact on air conditioning usage? Yeah. 

13 MR. CYMBALSKY: So it really comes down to 

14 -- so if we, so, we -- okay, so back to Slide 

15 129. So you're saying that at EL4, and I'm just 

16 going to look at the top table, the difference of 

17 $42, you'd say, would do what to shipments? We 

18 think it's negligible, so you think what would 

19 happen? If it's a million units -- what would 

20 happen? 

21 MR. TURNER: Rather than throwing a 

22 number at you right now, we'd like to probably 
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1 present something in written comments, and then 

2 we also kind of talked about potentially trying 

3 to get you sell-through data to show what that 

4 true $107 or baseline product is, because the 

5 home centers haven't been represented, or their 

6 sell-through hasn't been necessarily represented, 

7 because there are a lot of direct-from-factory. 

8 So, when that $107 may not be a true number, so 

9 then, if it drops $20 to $30, then that jump to 

10 $148 or $149 would be even large. 

11 I don't want to just throw a number out, 

12 as far as a percentage drop in shipments, but we 

13 would certainly like to get more information, 

14 hopefully, to you in our written comment. But I 

15 think that's our -- at least that's, you know, I 

16 don't want to speak for everybody, but that's my 

17 disagreement, that shipments wouldn't be impacted 

18 at all, and based upon the -- I'm looking at the 

19 LBNL study now -- but based on a few other 

20 studies, there would be an offset of people using 

21 their HVAC more. 

22 MR. CYMBALSKY: Only if they don't buy 
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1 the ceiling fans, -- 

2 MR. TURNER: Correct. 

3 MR. CYMBALSKY: -- so let's put aside 

4 that second impact first. I want to focus on the 

5 shipment. So, let's just say EL3. Forget about 

6 EL4 for now. Let's step back. So that's a $13 

7 difference in cost to the consumer. Do you think 

8 a $13 delta retail cost is going to impact, 

9 significantly impact the shipments of ceiling 

10 fans? 

11 MR. TURNER: Maybe. 

12 MR. SMITH: Hey, John, Van Smith. Maybe 

13 you could just help us understand the analysis 

14 here. I'm looking at the TSD and it says, for 

15 example, a relative price increase of 10 percent, 

16 which would be maybe $13, results a 3.4-percent 

17 decrease in shipments. So, that's on 9-16 of the 

18 TSD. Can you walk us through how -- 

19 MR. CYMBALSKY: So, that's right. That's 

20 the number that we think it is, and I'm saying -- 

21 so that's a 3 percent. I'm asking for your input 

22 on that. I'm hearing Dave say it's a big impact 
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1 to the shipments, and you read the number we 

2 have, so we're asking for comment on that, I 

3 think, right here. 

4 MR. SMITH: Okay. So I read that 

5 correctly and I see that that results in 3 

6 million reduced units later on in the same 

7 chapter of the TSD, so we would think that's 

8 significant, that those units, the absence of 

9 those units would have a potential impact on air 

10 conditioning usage for homes that would otherwise 

11 have those units. 

12 MR. CYMBALSKY: And, so, of those 3 

13 million, all those 3 million homes already have 

14 air conditioning? 

15 MR. SMITH: I'd have to go back and look. 

16 According to the RECS data, I think a large 

17 portion of them do. 

18 MR. CYMBALSKY: I thought the other -- 

19 John from DOE again. So the other comment was 

20 about the low-income, so I just want to make sure 

21 we cover all the topics that you raised. I'm 

22 assuming that this impact's probably focused on 
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1 the lower side of the market. Correct? 

2 MR. GATTO: Dave Gatto, Westinghouse, 

3 and, yeah, I think that's where I was, John, that 

4 if that $107 is overstated, and the low-income 

5 market's actually purchasing at, say, $69, then 

6 the delta is much larger than we, than is 

7 represented here. So, I don't know that I would 

8 necessarily disagree, and even if I did, I 

9 couldn't provide data to back it up with a 

10 fractional that Mohan covered yesterday, the 

11 fractional impact. 

12 I think what happens is that if we're 

13 analyzing a 10-percent reduction but it's really 

14 a 10-percent price premium and it's really a 40-

15 percent pricing premium, that would change that 

16 3-point to whatever. I would probably, honestly, 

17 since I know it's coming from a lot of aggregated 

18 data over a lot of decades, I would probably 

19 agree with what the percentage that was used. I 

20 think the challenge is if that EL0 number is not 

21 accurate, then that fractional increase is much 

22 bigger than what we're calculating. Does that 
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1 make sense? 

2 MR. CYMBALSKY: Yep. I understand that. 

3 So to make an analogy, so room air conditioners, 

4 I see in a similar situation here where they're 

5 used by a similar set of -- the impact you're 

6 worried about, I think, is the same. So -- and 

7 we've gone through several rounds of standards 

8 with room air conditioners, and we didn't see 

9 this phenomenon, so I guess I'll just throw it 

10 out there to the people at the table, why ceiling 

11 fans would be different than room air 

12 conditioners. I think they're serving a similar 

13 market. 

14 MR. BROOKMAN: Don Brundage. 

15 MR. BRUNDAGE: Well -- Don Brundage, 

16 Southern Company -- I'm not a manufacturer, but, 

17 intuitively, I think, as we've discussed, your 

18 low end, if you raise it by $15 or so, your low 

19 end product goes from, perhaps, $60 to $75, and I 

20 think, to me, ceiling fans do a different 

21 substitutionary effect than room air 

22 conditioners, because room air conditioners are 
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1 not really to supplement the, to use instead of 

2 the central air conditioning. 

3 They're to solve a specific need for a 

4 specific location that's not served by central 

5 air, added-on room, or that sort of thing, where 

6 you really don't have air conditioning. You're 

7 not choosing to put on a central air or put on a 

8 room air conditioner. You've got a place that 

9 doesn't have a central air or has a room that's 

10 not connected to central air. So a ceiling fan 

11 is not going to have the same substitutionary 

12 effect there that a room air conditioner would. 

13 You're really looking at ceiling fans 

14 being used as a substitute on some days for 

15 central air, or to run central air at higher 

16 temperatures. So I think it's a little 

17 different, and the market will drop. 

18 The other important thing is that you are 

19 using less energy with a ceiling fan than you 

20 would with a room air conditioner. You're 

21 probably using more energy for the same amount of 

22 BTUs of cooling with a room air conditioner than 
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1 you would with a central system. So the 

2 substitutionary effects hurts overall energy 

3 consumption. If you get rid of the ceiling fans, 

4 you're going to end up using more energy, so 

5 saving a few percent on the efficiency of a 

6 ceiling fan is going to hurt overall energy 

7 consumption if the central air runs more. Thank 

8 you. 

9 MR. BROOKMAN: Christian. 

10 MR. CYMBALSKY: Can I respond to that? 

11 MR. BROOKMAN: Please do. John, please. 

12 MR. CYMBALSKY: Okay. So if -- in your 

13 estimation, what would be the delta monthly cost 

14 on the electricity bill for someone who did what 

15 you just described? 

16 MR. BROOKMAN: Christian? 

17 MR. TABER: I can answer that one, kind 

18 of, sort of. So, the Cal Berkeley study that I 

19 usually reference for this would be roughly a 5-

20 percent decrease in air conditioning costs per 

21 degree of Fahrenheit rise. So a typical 

22 residential ceiling fan in a space can provide 
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1 anywhere from 3 to 5 degrees of cooling via 

2 elevated air speed, so you'd be looking at 15 to 

3 25 percent less energy consumption if you reset 

4 your thermostat appropriately. I don't know what 

5 the dollar amount is that works out to. That can 

6 be done with RECS data. Off the top of my head, 

7 my guess would be, I don't know, $60, $100 a 

8 year, something like that, depending. 

9 Also, to answer an earlier question, 87 

10 percent of homes in the United States have air 

11 conditioning, according to RECS. 

12 MR. CYMBALSKY: So, $60, so that's -- 

13 MR. TABER: If you asked me to hold to 

14 that number, I definitely wouldn't, but that's a 

15 guess. 

16 MR. CYMBALSKY: I'm just trying to do the 

17 math in my head, how much a 15 -- in a summer 

18 month, let's say, and let's say what you're 

19 saying is true, this low-income person, in the 

20 first month and a half, maybe, depending on how 

21 hot it is, would spend more on their electricity 

22 than they would on the incremental cost of this 
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1 EL3. So that's the economic decision. 

2 MR. BROOKMAN: Colleen. 

3 MS. KANTNER: Colleen Kantner, Lawrence 

4 Berkeley National Lab. I just wanted to provide 

5 a little context to that 13 million drop in 

6 shipments. That's out of cumulative shipments, 

7 over 30 years, at a total of about 486 million, 

8 so it's a 3-percent drop. 

9 MR. BROOKMAN: Okay. Thank you. 

10 Additional thoughts on this topic of low income? 

11 That's one you raised earlier as being something 

12 that you thought was important to cover. Dick? 

13 MR. UPTON: You ought to go back to the 

14 issue for the low-end purchaser, and I don't know 

15 the answer, so it's a question. What's the 

16 increased factor cost for that entry-level, as 

17 opposed to low-term savings on energy? Do they 

18 see a payback, or do they just see the opening 

19 additional cost, that's the impact, and so they 

20 walk away, as opposed to realizing, hey, for the 

21 more efficient product I'm going to save that 

22 amount of money over X amount of time? 
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1 MR. CYMBALSKY: Right. So what I'm 

2 seeing, again, back to Slide 129, is -- and I'm 

3 not saying, we're not proposing anything. This 

4 is just -- there's a phrase for this and I'm not 

5 going to say it on the record, but this is just 

6 for fun. 

7 [Laughter.] 

8 MR. CYMBALSKY: So, EL3 -- I'm just 

9 saying EL3 -- it's a 1.8-year simple payback. 

10 So, if they pay the extra $13, you know, this 

11 pays back in 1.8 years, and the life of the fan 

12 is 13.8. So, I'm just relating this to other 

13 rules that we do. That's a pretty low payback 

14 for the lifetime. Sometimes we have rules where 

15 you have 10-year payback and 15-year life, so, I 

16 mean, this one, for that EL level -- and, again, 

17 this is just for an example. 

18 MR. UPTON: My question really goes to 

19 Southern's comment of what's the barrier for -- 

20 damn, the price has gone up, and they don't even 

21 see X years out, at all. It's just the immediate 

22 price increase for them. 
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1 MR. CYMBALSKY: No. I think that the 

2 subgroup analysis, when we do it -- we haven't 

3 done that yet; we described that yesterday -- 

4 certainly DOE understands that the low-end 

5 people, that there is a cash constraint and that 

6 is an issue. I guess the point I was making, 

7 based on what we heard, was that if there is a 

8 big switch in -- let's say their ceiling fan 

9 happened to fail on a month right when this 

10 standard kicked in, and let's just assume it was 

11 a $13 difference, and assume it was a foregone 

12 purchase of a new ceiling fan. My question was, 

13 how much more are they paying in cooling if they 

14 do what I just heard they would do? 

15 I know these numbers don't match my math, 

16 but I was just doing it in my head. It would 

17 seem to me, in a couple of hot summer months, if 

18 people react the way you said they would react, 

19 they would have already made their money back by 

20 purchase a ceiling fan. 

21 I guess I said that in a convoluted way 

22 the first time, so I wanted to clarify the logic 
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1 in my head, based on what you were saying. 

2 MR. BROOKMAN: David. 

3 MR. TURNER: Dave from Hunter. My 

4 comment, that, which, I agreed that when you look 

5 at it from a holistic standpoint like that, but 

6 then a lot of the studies have found that it's 

7 not necessarily people setting their AC from 70 

8 to 72, 73. It's that they're not setting it from 

9 70 to 68, because they're kind of subconsciously 

10 being more comfortable but not setting their AC 

11 down. So, they may not know that, oh, man, I 

12 could have recouped the cost of that if I'd have 

13 made that purchase. Does that make sense? I'm 

14 probably saying in a convoluted way. 

15 MR. CYMBALSKY: No. This is a very 

16 sticky issue, obviously. That's why we're 

17 talking about it. I guess what I'm saying is 

18 that -- look. We understand the low-income 

19 impact and we want to obviously get it right. 

20 From what I heard, in terms of what the reaction 

21 would be if they didn't have a ceiling fan, I 

22 guess my reaction back is that that same low-
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1 income person, in 6 weeks' time, when they get 

2 their next electricity bill, will say, "Holy you3 know-what, I should've spent that 15 bucks." 

4 Maybe. This is just the logic in my head, based 

5 on what I'm hearing here. 

6 So, I don't want to talk about the 

7 interaction, the interplay. I want to really 

8 stick to the shipments, because without that 

9 issue, the other issue goes away, right? So I 

10 want to really focus on, let's get that right. 

11 What is that shipment rebound, if you will, based 

12 on the $13 or $29, or whatever the price 

13 difference is. 

14 Here we have the first ELs, no price 

15 difference at all, so I think we could all agree 

16 if the consumer doesn't see a price increase 

17 there will be no shipment change. So it's just 

18 looking at EL3 and EL4 in this example. These 

19 are the comments. We want to get this right, so 

20 this is why it's a healthy conversation to have 

21 here. 

22 MR. BROOKMAN: Don Brundage. 
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1 MR. BRUNDAGE: Well, I agree with what 

2 you say. The other aspect of it is low-end 

3 consumers are not going to have access to the 

4 data we have here, or probably have the analytic 

5 talent that's in this room to analyze it. It may 

6 be more like, I don't have the extra money. But 

7 I'm not saying that we wouldn't, that it's not 

8 reasonable, if these numbers work out to be 

9 valid, to do a 1.8 payback. I mean, that's below 

10 the 3-year payback prescriptive test that you've 

11 got to find some really good reason not to accept 

12 it. 

13 But with the substitutionary effects on 

14 other air conditioning, I would not support 

15 pushing up to the sort of things you do on other 

16 rulemakings lately, up into the high single-digit 

17 paybacks. I think it is reasonable to hold it 

18 down, to try to keep the price increase from 

19 going up too much, but it's hard not to justify a 

20 1.8-year payback to go ahead and do it. Thank 

21 you. 

22 MR. CYMBALSKY: And then just one last 
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1 comment I have on the low-income, and I'm not 

2 going to disagree with anything that's been said, 

3 but I think the low-income people actually are 

4 the same people who might not be able to afford 

5 high electricity bills, month to month, and that 

6 they tend to be conscious of that. So, to the 

7 extent that they don't have the ceiling fan, what 

8 we need to ask ourselves is, on their behavior, 

9 they still know they can't afford the electricity 

10 bill either, so, you know, we've got to think 

11 this through holistically. And I think, for the 

12 high-end consumers, you know, $13 or whatever it 

13 is -- 

14 MR. BROOKMAN: Dave. 

15 MR. GATTO: Dave Gatto, Westinghouse. 

16 Yeah, John, I agree with you, and, again, I've 

17 said it before. I come to applaud DOE for 

18 looking at it. A 1.8 payback period is well 

19 reasonable, and I think that even at the median 

20 and upper-level income levels it's a nominal 

21 difference, and they understand the math, in a 

22 lot of cases. So we appreciate where you're at. 
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1 I think where I would leave it is, you've 

2 given us clear acceptance that if we can provide 

3 the information needed to adjust the calculation, 

4 which is really what's going to drive the 

5 shipment difference, I don't know, as an 

6 industry, that we can provide that without some 

7 help from other stakeholders that so far have not 

8 provided the information. I don't know that we 

9 can give you legitimate data that would tell you 

10 what that price sensitivity is, but I do think 

11 that there's enough data on hand that if you came 

12 back with a proposal that included, as you did 

13 here, that as long as we're in agreement with the 

14 underlying installed cost base, we're probably 

15 going to agree with what the rebound effect is, 

16 in terms of price sensitivity. 

17 So I didn't want to suggest that we 

18 didn't agree with your number. It's more of a, 

19 your starting point, I think, it's throwing the 

20 number off. 

21 MR. CYMBALSKY: That's a great comment, 

22 and we'll obviously take it in at the next phase. 
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1 Anything else on this topic? I know it 

2 was one we wanted to cover. Okay, thanks. 

3 MR. BROOKMAN: Any other topics that we 

4 wish to raise before people start heading out the 

5 door? Dave. 

6 MR. TURNER: Dave from Hunter. Just with 

7 the new AcuPOLL data, which we'll submit in 

8 written comment. That might affect the payback 

9 period if the costs come down, and that's what 

10 we're going to exhibit. But, yeah, we'll submit 

11 it for your full viewing. It's difficult to go 

12 over if you guys haven't seen it yet. 

13 MR. BROOKMAN: Colleen. 

14 MS. KANTNER: Colleen Kantner, Lawrence 

15 Berkeley National Lab. When you submit the 

16 average fraction of time at each speed, it would 

17 be very helpful if you provided some of the raw 

18 data, because we like to use that data to build 

19 the energy use distributions that are used in the 

20 LCC analysis, and it would be helpful for those 

21 things to be consistent. 

22 MR. TURNER: Sure. I'm sure we own that 
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1 data, since we paid for the survey, so I should 

2 be able to get it to you. 

3 MS. KANTNER: Great. 

4 MR. BROOKMAN: Christian? 

5 MR. TABER: Christian Taber, Big Ass 

6 Solutions. At some point, I would like to 

7 discuss energy use characterization of high8 volume, large-diameter fans, but since I'm the 

9 only one in the room that's interested in that, 

10 it doesn't have to be now. 

11 MR. CYMBALSKY: Right, and I definitely 

12 had a feeling you were going to say that. So I 

13 think -- I just wanted to get a lot of the bigger 

14 cross-cutting topics out of the way. 

15 MR. BROOKMAN: Let me take an actual 

16 poll. How many of you need to leave at 3:00 or 

17 3:15, or so. One, two. How many of you need to 

18 leave at 3:30? How many of you need to leave at 

19 4:00? 

20 So what I'm going to suggest -- let me 

21 see. It's now almost -- 

22 MR. CYMBALSKY: Can I raise my hand? 
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1 [Laughter.] 

2 MR. BROOKMAN: Yeah. It seems like most 

3 of the folks that have participated in the 

4 conversation all day long are going to still be 

5 here at four o'clock. It's now 10 minutes until 

6 3. We got back from lunch at one. Maybe we 

7 should take a short break, and then maybe we 

8 should try and pick up where we left off with the 

9 slides, at page 90, and go rapidly, just kind of 

10 page through them, and then we'll stop for 

11 anybody that wishes to make a comment along the 

12 way. Okay? 

13 So let's take a short break. Let's take 

14 a 10-minute break, and we'll resume at three 

15 o'clock, and for those of you that need to leave 

16 us, we're so glad you could join us, and the 

17 Department looks forward to receiving all your 

18 detailed comments. And we'll resume at three 

19 o'clock, here in the room. At 3:05. 

20 [Recess taken from 2:53 to 3:07 p.m.] 

21 MR. BROOKMAN: If we go back to 90, is 

22 that you? Aris? 
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1 MR. MARANTAN: Yes. 

2 MR. CYMBALSKY: So, we were going to 

3 resume where we kind of broke off, in the 

4 engineering, but I'm going to propose, unless 

5 someone really wants to talk about the details, 

6 that are essentially repeating what we just did, 

7 for the two other types, if it's more 

8 constructive for everybody's time, I would 

9 suggest we just skip over. I know there were 

10 some questions about the energy use portion of 

11 the deck, and unless anyone has any objections, I 

12 would propose to kind of just go to that, Section 

13 6, so that would be after the markups. So 

14 starting on Slide 109. Any objections? 

15 Seeing none, why don't we do that, and 

16 I'd ask Colleen and whoever else is presenting, 

17 just try to hit the high points and get through 

18 this in quick order. I've got gloves. I'm 

19 renting it. They work with your cell phone, too. 

20 They have the little things on it. 

21 [Laughter.] 

22 MS. KANTNER: Colleen Kantner, Lawrence 
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1 Berkeley National Lab. The purpose of the energy 

2 use characterization is to develop distributions 

3 of annual energy consumption representative of 

4 purchasers in the U.S., where annual energy use 

5 is the site energy use associated with operating 

6 the product, and these distributions are used in 

7 the LCC and payback period analyses. 

8 So we develop purchaser samples, we 

9 develop distributions of operating hours at each 

10 speed, and then determining energy use is fairly 

11 straightforward from that. To account for 

12 variability in energy consumption, DOE develops a 

13 Monte Carlo sample of 10,000 purchasers. Low14 volume ceiling fans are assumed to be in the 

15 residential sector. DOE believes that some low16 volume ceiling fans are installed in commercial 

17 settings, but that the hours of use for these 

18 fans would be similar to the hours of use for 

19 ceiling fans in residential settings. Purchasers 

20 were drawn randomly from the set of households in 

21 RECS that use ceiling fans. 

22 High-volume ceiling fans were assumed to 
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1 be used in the commercial and industrial sectors 

2 only. 

3 The operating hours used were from a 

4 survey of ceiling fan owners performed by 

5 Lawrence Berkeley National Lab, with an average 

6 of 6.45 hours per day. I think we've talked 

7 about the fraction of time at each speed a fair 

8 amount already, so I'll skip over that. And then 

9 DOE sampled from census-division-specific hours 

10 of use distributions for each ceiling fan in the 

11 Monte Carlo sample. 

12 For high-volume ceiling fans, there were 

13 not a lot of publicly available data, so we used 

14 feedback from manufacturer interviews. We 

15 assumed an average of 12 hours per day, and the 

16 way that was broken out was we assumed that 80 

17 percent of the time is spent at medium speed, 10 

18 percent of the time was spent at high speed, and 

19 10 percent of the time was spent at low speed. 

20 And since we didn't have any data to suggest 

21 otherwise, we assumed that there was no 

22 difference in operating hours, either by 
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1 geographic location or season. 

2 The power during operation for low-volume 

3 ceiling fans came from engineering analysis, and 

4 I just wanted to clarify that, in theory, the 

5 energy consumption of multi-mount ceiling fans 

6 depends on both the potential standard for the 

7 hugger and standard product classes, but for this 

8 preliminary analysis, DOE assumed that when 

9 analyzing a given efficiency level for the 

10 standard product class, an equivalent standard 

11 was in place for the hugger product class, and 

12 vice versa. 

13 MR. BROOKMAN: Yes. Okay. Keep going. 

14 MS. KANTNER: For high-volume ceiling 

15 fans, the power at high speed was provided by the 

16 engineering analysis, and DOE used ratios between 

17 speeds from the low-volume engineering analysis 

18 to determine power at low and medium speed. This 

19 meant that medium was assumed to represent 53 

20 percent of high-speed power, and low speed 23 

21 percent of high-speed power. If anyone has 

22 comments on those numbers, we're happy to hear 
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1 them. 

2 MR. BROOKMAN: Christian. 

3 MR. TABER: Christian Taber, Big Ass 

4 Solutions. My comments are going to kind of mix 

5 the last two slides together. So, to look at 

6 this, what I did was take 53 percent of high7 speed power and I translated that into percent of 

8 maximum RPM. Fifty-three percent of maximum 

9 power roughly translates to 80 percent of maximum 

10 speed, and 23 percent of high-speed power 

11 translates to roughly 60 percent of maximum 

12 speed. So if you can go back up a slide. 

13 So, the way that that would work out is 

14 that 10 percent of the time the fan is running at 

15 maximum RPM, 80 percent of the time it is running 

16 at 80 percent of maximum RPM, and 10 percent of 

17 the time it is running at 60 percent of maximum 

18 RPM. For a 20-foot, large-diameter fan, 80 

19 percent of maximum speed is going to generate 

20 anywhere from 200 to 300 feet per minute of air 

21 speed, which is going to be roughly a 10-degree 

22 cooling effect. 
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1 To assume that in the winter a 10-degree 

2 cooling effect is desirable is obviously not 

3 true, so that led me to believe that the fan was 

4 reversed. There is one manufacturer of high5 volume, large-diameter ceiling fans that 

6 recommends that their fan be reversed. Eighty 

7 percent operating speed would be typical of their 

8 recommendation for that operation, but it is not 

9 typical of the industry. The industry, as a 

10 whole, with that one exception, recommends 

11 operating in the forward direction at low speed. 

12 That would be roughly 25 percent of maximum RPM 

13 and roughly 5 percent of maximum power. 

14 So my recommendation would be, if we 

15 don't want to do any geographical location or 

16 seasonal difference, that, essentially, 6 months 

17 of the year we should be running at around 5 

18 percent of power, so there should be a very low 

19 speed included in this. I ran through the 

20 numbers and will provide that in detail comments, 

21 I believe we actually already have. 

22 I took Purchaser Index 346 out of the 
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1 Monte Carlo analysis, and compared this method to 

2 how we would typically see a fan run. The total 

3 energy consumption for this scenario was 2,595 

4 kilowatt hours, which pretty much exactly matched 

5 DOE's numbers, so I was able to back into that. 

6 Run the way that we would recommend it, that fan 

7 would use about 1,139 kilowatt hours, so it's 

8 less than half of the DOE-calculated numbers. 

9 So, for one manufacturer, this would 

10 definitely be true, but for the industry as a 

11 whole, this would be a gross overestimation of 

12 our annual energy consumptions. 

13 MS. KANTNER: And we very much welcome 

14 any information. 

15 MR. TABER: You've got all of the 

16 spreadsheets and all the math, and all that. 

17 MR. BROOKMAN: That's great. Thank you 

18 very much. Thank you. 

19 Additional thoughts along these lines, 

20 operating hours and power drain operation? 

21 Nothing additional here? Okay. 

22 MS. KANTNER: As far as -- we already 
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1 talked about that one. With regards to standby 

2 power consumption for low-volume ceiling fans, 

3 DOE assumed that there was standby for all DC 

4 fans, which, again, is 2 percent of ceiling fans 

5 at EL4. DOE also assumed that there was standby 

6 for all AC ceiling fans that were used with a 

7 remote control, which DOE estimated to be 7.4 

8 percent of fans, based on an LBNL study. The 

9 power consumption during standby was assumed to 

10 be 1.4 watts, based on manufacturer feedback. 

11 For high-volume ceiling fans, standby 

12 power consumption was assumed for all DC-motor, 

13 small-diameter fans. Standby was assumed for all 

14 large-diameter ceiling fans, based on the 

15 variable frequency drive. Power consumption 

16 during standby was assumed to be 1.4 watts. It 

17 was assumed to be the same as the power 

18 consumption in standby for low-volume ceiling 

19 fans, based on not having better data. 

20 Ceiling fans with standby functionality 

21 were assumed to be in standby mode during all 

22 hours not in active mode, and we welcome comments 
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1 on all of these. 

2 MR. BROOKMAN: Christian. 

3 MR. TABER: Christian Taber, Big Ass 

4 Solutions. I don't actually have an issue with 

5 the numbers. I just have an issue with the 

6 because of variable frequency drive. There are 

7 high-volume, large-diameter fans that use direct8 drive motors. There are standby losses or 

9 standby energy consumption for those fans, but 

10 they don't have the variable frequency drive. So 

11 I think just the striking of "because of variable 

12 frequency drive" would make it fine. It's just a 

13 nuance, but there are a lot of fans that don't 

14 have VFDs. 

15 MS. KANTNER: So they would all have 

16 standby, but only some of them have the variable 

17 frequency drive? 

18 MR. TABER: Right. 

19 MS. KANTNER: Okay. 

20 MR. BROOKMAN: Yes, Dave. 

21 MR. GATTO: Just one quick question. On 

22 the small-diameter, what was the percentage 
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1 breakdown of DC versus non-DC? That part I don't 

2 remember. It might be in there, and if it is, 

3 you don't have to chase it down for me. But for 

4 small-diameter fans -- 

5 MS. KANTNER: For high-volume, small6 diameter fans? 

7 MR. GATTO: High-volume, small-diameter, 

8 where you would be calculating standby power. 

9 MS. KANTNER: We assumed that all the 

10 ceiling fans that were at EL4 were DC and would 

11 have standby power. Are you asking about the 

12 market distribution? 

13 MR. GATTO: Yeah. Maybe that's what it 

14 is. What's the percentage you allocated to that? 

15 MS. KANTNER: Mo, maybe you can help me 

16 out here. 

17 MR. GATTO: And if you don't have it 

18 readily available, I don't mind if we keep moving 

19 and just circle the data back to me. Sort of 

20 scrambling over here. Sorry, guys. 

21 MR. GANESHALINGAM: Hello. This is Mohan 

22 Ganeshalingam from Lawrence Berkeley National 
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1 Labs, and I believe, in 2012, when we were 

2 looking at the data, there were 0 percent. 

3 MR. GATTO: Thank you. 

4 MS. KANTNER: I think we talked about 

5 this topic already. So, here we see energy use 

6 and energy savings results for a 52-inch, low7 volume standard ceiling fan at each EL. Note 

8 that the numbers in this table represent an 

9 average of a distribution. The distribution for 

10 EL3 is presented here, just for illustrative 

11 purposes, where the red line indicates the mean 

12 of the distribution. And, as you can see, some 

13 ceiling fan owners use more or less energy than 

14 that. 

15 And here are the energy use results for 

16 low-volume ceiling fans, with the results for 44-

17 inch, 52-inch, and 60-inch standard ceiling fans 

18 in the top table, and 44-inch and 52-inch hugger 

19 fans in the bottom table. I just want to note 

20 that the results for each EL are based on using 

21 the same purchaser sample and the same hours of 

22 use, and this is true at all ELs and for both 
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1 product classes. 

2 And here are the energy use results for 

3 high-volume ceiling fans, with the results for 

4 the high-volume, small-diameter fans with 36 

5 inches and 56-inch diameters on top, and 8-foot, 

6 12-foot, and 20-foot diameters on the bottom. 

7 I think we've talked about both of these 

8 things already, so let's move on. 

9 MR. BROOKMAN: Additions before we move 

10 on? Okay. 

11 MS. KANTNER: Next up is the life-cycle 

12 cost analysis. The purpose of the life-cycle 

13 cost analysis is to provide an economic 

14 evaluation from the end-user's perspective. The 

15 life-cycle cost is the total purchaser cost over 

16 the life of a product, and the payback period is 

17 the time required to recover the increased 

18 purchase price of a more efficient product 

19 through reduced operating costs. 

20 The LCC uses the same purchaser samples 

21 developed in the energy use analysis. The LCC 

22 determines total installed cost for each EL, 
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1 operating costs for the first year and the 

2 lifetime of the product, and then calculates the 

3 payback period by dividing an increase in 

4 installed cost by the average decrease in first5 year operating costs. 

6 The LCC is just the sum of the installed 

7 cost and lifetime operating costs. And I just 

8 want to note that LCC savings are calculated with 

9 respect to the efficiency of a product a 

10 purchaser would purchase in the absence of a new 

11 standard. 

12 I think we talked about purchaser samples 

13 already in the energy use analysis. They're the 

14 same here. 

15 We used a distribution of fan diameters 

16 in the market for low-volume ceiling fans, and 

17 feedback from fan manufacturers for high-volume 

18 ceiling fans, to come up with these distributions 

19 of fans by blade span. Does anyone have any 

20 comments on this? I'll note that on the high21 volume side, there was not a lot of information. 

22 MR. BROOKMAN: Yes, Dave. 
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1 MR. GATTO: Dave Gatto, Westinghouse. I 

2 think on the low-volume it would be in line with 

3 where I think it would be, but I haven't done the 

4 analysis. On the high-volume, small-diameter, 

5 it's really tough. It's probably more like 85/15 

6 to the 56-inch. Christian, maybe you want to 

7 weigh in there, but I know it's a much higher 

8 percentage of the volume that we see in the 

9 marketplace. That's a guess. 

10 MR. BROOKMAN: Christian. 

11 MR. TABER: Christian Taber, Big Ass 

12 Fans, or Big Ass Solutions. Sorry. I keep 

13 struggling with that. I would generally say 

14 that, yeah, if I see a high-volume, small15 diameter fan on a project, it tends to be of a 

16 larger diameter, a lot more than 2-to-1. But 

17 that's ancillary. That's just what I see pass 

18 through my desk. And then for our distribution, 

19 we definitely trend highly to the 20- and 24-foot 

20 diameter fans. Larger products are, by far, the 

21 bulk, so that would be representative. 

22 MR. BROOKMAN: Thank you. 
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1 MS. KANTNER: Great. Thank you. Again, 

2 to estimate the average LCC savings of an 

3 efficiency level, DOE first considers the 

4 expected market distribution by efficiency level 

5 in the base case. For low-volume ceiling fans, 

6 this was largely based on models available in7 store. DOE also assumed that the same 

8 distribution for standard and hugger fans existed 

9 in 2013, but they differed slightly by 2019, 

10 based on the consumer choice model that will be 

11 discussed later in the shipments analysis. 

12 For high-volume ceiling fans, the 

13 efficiency distribution is based on models 

14 available on manufacturer websites. 

15 MR. BROOKMAN: Dave. 

16 MR. GATTO: Dave Gatto, Westinghouse 

17 Lighting. The only thing I would say about the 

18 low-volume percentage of each EL is that, not 

19 from our own product line but I think if you 

20 looked at the actual home center units moved, if 

21 we had that data or if you had that data, I think 

22 it might shift more to the hugger. That's a 
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1 guess, but just from the price points that are 

2 out there, and there's two different product 

3 types, I would guess that the volume might be 

4 higher. 

5 MS. KANTNER: You're talking about 

6 huggers relative to standard fans, or are you 

7 talking about ELs within the hugger product 

8 class? 

9 MR. GATTO: Really, I'm talking about the 

10 current EL0, that the current distribution might 

11 skew towards hugger, due to the unit volume 

12 associated with the lower-priced products, but it 

13 is a little bit of a wild guess. But it's just 

14 based on what we see in the marketplace and where 

15 we know the consumer choice point is for that 

16 particular product. 

17 MS. KANTNER: Okay. 

18 MR. TURNER: We agree that the lower 

19 price points are generally huggers, so those sub20 $30, $40. 

21 MR. CYMBALSKY: This is when the standard 

22 would come into play. 
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1 MR. TURNER: Yeah. 

2 MR. CYMBALSKY: So I guess my question to 

3 the folks around the table is, let's forget about 

4 2019 for the moment, but just today, because I 

5 think we know what we're doing today, do we think 

6 that these -- 

7 MS. KANTNER: Hopefully. 

8 MR. CYMBALSKY: Well, I think. I heard, 

9 out in the hallway we might be able to get some 

10 numbers here. Do we think these percentages are 

11 -- I think what I'm hearing is maybe EL0 and 1 

12 would have much higher percentages. Did I 

13 interpret those comments correctly? 

14 MR. GATTO: Dave Gatto, Westinghouse. 

15 Yes. I think that's what I'm saying, is that 

16 because there's some missing data, that I think 

17 that the results here are skewed towards what we 

18 know, or what DOE and Navigant knows, but it's 

19 one of those things where we know we have a 

20 pretty big gap in our knowledge base for this 

21 particular topic. 

22 MR. CYMBALSKY: Right, and my sense in 
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1 this product -- and correct me if I'm wrong -- is 

2 that absent a government intervention here, with 

3 the standard, we think the market wouldn't move 

4 up without any little extra nudging. 

5 MR. GATTO: It's tough. At the lower 

6 end, my personal -- Dave Gatto, Westinghouse 

7 Lighting -- my personal opinion is it's lower and 

8 probably not at the median end. We all compete 

9 with each other, so their efficiency is actually 

10 one -- this is a similar lamp. This is a place 

11 where efficiency and high CFM and CFM per watt 

12 actually plays a role in our ability to compete. 

13 So we're constantly looking for those 

14 extra tweaks anyway. So I think in the absence 

15 of a rule, maybe EL1, but definitely EL2, and I 

16 think that that's not accurate. But for EL0 and 

17 1, it's going to stay right where it is, along as 

18 there's no change in the standard, because that's 

19 what drives the price point. 

20 MR. CYMBALSKY: Right. Got it. 

21 MR. GATTO: Is that where you were at? 

22 MR. CYMBALSKY: That's exactly what I was 
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1 saying. So you'll play in the higher ELs and 

2 those will shift. But, yeah, I think we're on 

3 the same page. 

4 MR. GATTO: Okay. 

5 MS. KANTNER: Next is the total installed 

6 cost, and this is just the purchase price 

7 provided by the markups analysis, and price 

8 learning is incorporated to account for decreases 

9 in manufacturing costs, due to production 

10 experience, by the compliance data, and, again, 

11 more detail on this is going to be provided in 

12 the shipments sections. 

13 Recall that the remote control cost was 

14 added to 7.4 percent of low-volume AC ceiling 

15 fans. The remote control was already included in 

16 the price of DC fans, from an engineering 

17 analysis. 

18 Sales tax is also applied, and is 

19 determined based on the geographic location of 

20 the purchaser. Installation cost was not 

21 included because it does not appear to vary with 

22 efficiency level. 
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1 Next up is annual energy cost. Annual 

2 energy consumption was provided by the energy use 

3 analysis, and electricity prices were estimated 

4 using data from EIA, and note that estimated 

5 price varies based on geographic location and 

6 economic sector. 

7 MR. BRUNDAGE: Don Brundage, Southern 

8 Company. I think one of the issues, when we're 

9 talking about very inexpensive ceiling fans, is 

10 that low-income consumers are probably more 

11 likely to do it do-it-yourself and have a zero 

12 installation cost. I think that's one of the 

13 factors that's different from your analysis, 

14 compared to effective low income of making a 

15 small change in the purchase price. 

16 So if there was some assumption of a 

17 larger percentage of being do-it-yourselfer, and 

18 have a zero installation cost in some of the 

19 considerations for the low-end market or for 

20 effect on low-income consumers, that's probably 

21 reasonable. Thank you. 

22 MR. BROOKMAN: Thank you. 
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1 MS. KANTNER: Next we have repair and 

2 maintenance costs. Maintenance costs were not 

3 included in the LCC calculation because DOE did 

4 not find evidence that it varies with efficiency 

5 level. As far as repair cost, we should first 

6 clarify that the repair cost we're talking about 

7 here is the cost to a consumer to repair a 

8 ceiling fan, because it may cost something to the 

9 consumer even if it's still under warranty. They 

10 may still pay to have the fan taken down and put 

11 it back up after it's fixed. Any costs that 

12 might be borne by the manufacturer are not 

13 included here. 

14 DOE included a repair cost for 6.5 

15 percent of DC fans, and note that this isn't the 

16 total number of DC fans that might require 

17 repair, but the estimated percentage of DC fans 

18 in excess of AC fans that DOE expected would need 

19 repair. And this was based on an estimate from a 

20 ceiling fan industry consultant. 

21 For low-volume ceiling fans, based on 

22 feedback from manufacturer interviews, DOE 
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1 estimated a repair cost of $150, and this was 

2 assumed to be the same for standard and hugger 

3 ceiling fans. Since DOE didn't have any data to 

4 suggest otherwise, DOE assumed that this would be 

5 the same for high-volume, small-diameter ceiling 

6 fans. For high-volume, large-diameter ceiling 

7 fans, DOE estimated a repair cost of $1,000, and 

8 this was based on estimates of the installation 

9 costs for these types of ceiling fans. 

10 MR. BROOKMAN: Dave. 

11 MR. GATTO: Dave Gatto, Westinghouse 

12 Lighting. I'm not sure how to ask this. So, 

13 you're estimating the repair cost for more than 

14 the installed cost of the fan. Is that accurate? 

15 That's how I'm reading this. Maybe I'm reading 

16 this wrong. But if the EL0, 1, and 2 are $107 

17 installed cost, you're estimated the repair cost 

18 for those models was $150? 

19 MS. KANTNER: Yeah. I'll note that we 

20 didn't include installation costs in the cost for 

21 the ceiling fans. 

22 MR. GATTO: You're including it here. 
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1 MS. KANTNER: This is mostly based on an 

2 installation cost. This is the cost to take it 

3 down, have somebody fix it, and put it back up. 

4 MR. GATTO: To have somebody fix it. 

5 MS. KANTNER: Well, if it's under 

6 warranty. 

7 MR. CYMBALSKY: Like swap the motor out, 

8 essentially? 

9 MR. GATTO: Okay. That's helpful. I 

10 think that I'm just going to repeat a little bit 

11 of where Don was a few minutes ago, that I think 

12 at the low end, you'd just buy a new one. If 

13 it's under warranty, we take care of it. If it’s 

14 not under warranty, there would be no repair 

15 cost. If you wanted to include replacement cost 

16 in there, that might make sense. 

17 MS. KANTNER: And, to note, we didn't 

18 assume any repair costs in this analysis for AC 

19 fans. It was only for DC fans where repair costs 

20 were relevant, so there may be a different 

21 tradeoff. 

22 MR. GATTO: Well, then, I don't know that 
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1 the low-income really applies here. So, thank 

2 you. 

3 MR. CYMBALSKY: My question to the 

4 manufacturers is the middle bullet. So they 

5 assume the second middle bullet. This is 

6 actually appropriate for ceiling fans. The 

7 assumed failure would occur in the middle of the 

8 fan's lifetime. I think people would have strong 

9 opinions on this, maybe? For a DC fan. So we're 

10 saying it's, what, a 13.8-year lifetime? 

11 MS. KANTNER: Yes. It was 7 years in. 

12 MR. CYMBALSKY: So 7 years in. 

13 ALLEN ROO: Allen Roo with Emerson. The 

14 first DC fan we produced was approximately 7 

15 years ago, and as of yet we've not seen a spike 

16 in anything, but, at this point, the motor itself 

17 is not repairable. You basically throw the fan 

18 away. Under our warranty program, we'll let you 

19 repurchase a new fan at a negotiated price. If 

20 it's the controller that's at fault, it is 

21 repairable. And, basically, you don't have to 

22 take the fan down. You just repair it on the 
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1 ceiling. It's a plug-and-play type operation. 

2 MR. BROOKMAN: Thank you. 

3 MS. KANTNER: All right. Let's move on 

4 to lifetime. DOE estimated the lifetime 

5 distribution from a combination of shipments data 

6 and the age distribution of ceiling fans found in 

7 an LBNL study. DOE assumed that the lifetime 

8 distribution would take the form of a Weibull 

9 function, and found a mean of 13.8 years. 

10 Any comments on the lifetime? 

11 MR. BROOKMAN: We mentioned this before, 

12 I think, but did we get confirmation on it? The 

13 lifetime. 

14 MR. TURNER: David Turner from Hunter 

15 Fan. We agree with the 13.8 assumption. 

16 MR. BROOKMAN: Okay. 

17 MS. KANTNER: How about the assumption 

18 that the lifetime distribution would be the same 

19 for high-volume ceiling fans? 

20 MR. GATTO: Dave Gatto, Westinghouse 

21 Lighting. For high-volume, small-diameter, the 

22 warranty return is extremely low. I don't know 
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1 how to answer that. I think that it's not 

2 fashion-oriented, but because it's in commercial 

3 space, the space might change. I think my answer 

4 last time was I don't have a better number to 

5 give you. It might be longer than 13.8, but I 

6 don't have any way to give you a backup for what 

7 it would be. 

8 Christian, you may have an opinion, so 

9 you may have to just go with that. 

10 MR. TABER: Christian Taber, Big Ass 

11 Solutions. I'm going to echo, kind of, the I 

12 don't have a better number to give you. High13 volume, large-diameter fans were invented about 

14 13.8 years ago -- 

15 [Laughter.] 

16 MR. TABER: -- so I don't know. 

17 MR. BROOKMAN: Okay. They're at the mean 

18 of their life right now. 

19 [Laughter.] 

20 MS. KANTNER: Next is discount rates. 

21 Maybe we can just skip this slide. We talked 

22 about discount rates yesterday and they're pretty 
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1 much the same here. 

2 And here are the LCC results for low3 volume ceiling fans, with standard ceiling fans 

4 shown in the top table and hugger ceiling fans in 

5 the bottom table. Again, the results include 

6 installed costs, which we talked about already, 

7 first year's operating cost, lifetime operating 

8 cost, lifecycle cost, and simple payback period, 

9 which may be compared to the average lifetime. 

10 And, again, all of these results for each EL 

11 represent the average outcome if all 10,000 

12 purchasers in that Monte Carlo sample purchased 

13 at that EL, and the same sample is used at each 

14 EL. 

15 The hugger results are pretty similar to 

16 the standard results. Any comments? 

17 MR. CYMBALSKY: I think we beat this one 

18 a little bit. 

19 MS. KANTNER: And here are the results 

20 for high-volume ceiling fans, with small-diameter 

21 ceiling fans show in the top table and large22 diameter ceiling fans shown in the bottom table. 
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1 Any comments? 

2 MR. GATTO: Dave Gatto, Westinghouse 

3 Lighting. I think I'm in agreement with this, in 

4 general, for the high-volume, small-diameter. 

5 Installed cost, I'm assuming left install cost 

6 out. You're assuming it's the same at each EL? 

7 MS. KANTNER: Yes. 

8 MR. GATTO: So then, yeah, I'm think I'm 

9 okay here. 

10 MR. BROOKMAN: Okay. Additional 

11 comments? 

12 MS. KANTNER: Okay. We have a few items 

13 for comment. DOE requests information and 

14 comment on the market shares by efficiency level 

15 for each product class. I think maybe we already 

16 discussed that one. 

17 MR. BROOKMAN: I think we've done all of 

18 them. 

19 MS. KANTNER: We discussed all of these? 

20 Okay. 

21 MR. BROOKMAN: And we've done them as 

22 we've been going along, as well. So on to 
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1 shipments. 

2 MS. KANTNER: All right. Up next is 

3 Mohan Ganeshalingam, who is going to present the 

4 shipments analysis and the national impact 

5 analysis. 

6 MR. CYMBALSKY: This is John with DOE. I 

7 propose that Sections 9, 10, and 11, there's 

8 really -- we'll do closing remarks, but I think 

9 I'll just say preliminary NIA and NOPR analyses. 

10 Just stuff for the future. We covered it 

11 yesterday. There's no reason to go through it 

12 again. We don't have any information per se to 

13 present. It's just process stuff. So we'll 

14 finish up here. I think the shipments, obviously 

15 we've talked about a lot, but if we need to 

16 discuss more, let's do it here, and then we'll 

17 close up for the day. 

18 MR. BROOKMAN: Okay. Additional thoughts? 

19 Comments on shipments? 

20 MR. GANESHALINGAM: All right. Thank 

21 you. Good afternoon, everyone. I am Mohan 

22 Ganeshalingam from Lawrence Berkeley National 
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1 Labs. So, yeah, I'll be covering shipments and 

2 national impact analysis, or NIA, for short. 

3 We went over a lot of this yesterday, so 

4 I'll try to breeze through some of this. The 

5 purpose of the shipments analysis is to project 

6 future shipments of ceiling fans over the 

7 analysis period, from 2019 to 2048. DOE projects 

8 shipments in the base case and under the impacts 

9 of a potential amended energy efficiency 

10 standard. Shipments are then just aggregated 

11 into product classes and efficiency levels, over 

12 time. 

13 DOE's method for estimating shipments 

14 uses a stock-accounting method calibrated to 

15 historical shipments data. DOE identifies the 

16 market segments that drive shipments over time 

17 and projects their contribution to total 

18 shipments. In this analysis, DOE accounts for 

19 shipments due to product replacements, 

20 installations into new constructions, and 

21 installations into existing buildings that did 

22 not previously have a ceiling fan. 
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1 Shipments are then disaggregated by 

2 product class and efficiency level, using a 

3 consumer-choice model to project purchasing 

4 decisions for each year in the analysis period. 

5 For low-volume ceiling fans, the consumer-choice 

6 model assumes consumers are only sensitive to 

7 first cost, and for high-volume ceiling fans, the 

8 model assumes consumers are sensitive to first 

9 cost and operating cost. 

10 So, just diving a little bit deeper into 

11 the assumptions that we make in our analysis, 

12 this table is for low-volume ceiling fan inputs, 

13 and the data source for those inputs. For 

14 replacements, DOE used historical shipments from 

15 Appliance Magazine, NPD, and Energy Star, and 

16 then applied a retirement function to those 

17 historical shipments, to derive the number of 

18 replacements that we shipped in each year. 

19 New construction, DOE estimated the 

20 number of shipments to new construction using 

21 estimates of new housing starts from the Annual 

22 Energy Outlook 2014, and assumed that 73 percent 
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1 of new houses were installed with ceiling fans, 

2 with an average installation of 3.1 fans per 

3 home. 

4 For existing buildings, DOE performed 

5 analysis, looking at the increase of ceiling fans 

6 found in households between RECS 1993 to RECS 

7 2009, indicating that the number of ceiling fans, 

8 or the fraction of households with ceiling fans 

9 was increasing with time, but the rate of 

10 increase was slowing. So, in 2009, that 

11 saturation was at 73 percent, and DOE put a cap 

12 at 75 percent for its analysis. 

13 And for market shares, those are based 

14 off of model counts from in-store visits and 

15 online retailers, to derive the current 

16 efficiency distribution and product class market 

17 shares. 

18 For sector usage, estimates from 

19 manufacturers indicated that about 5 percent of 

20 low-volume ceiling fan shipments were to the 

21 commercial sector, or used in the commercial 

22 sector. However, in our analysis we assumed that 
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1 there would be similar usage between ceiling fans 

2 in residential and commercial sectors, so they 

3 ended up all being analyzed as low-volume ceiling 

4 fans in the residential sector. 

5 For market shares by product class, we 

6 estimated that, from in-store visits and online 

7 retailer data, we found that about 53 percent 

8 were multi-mount, 26 percent were standard, 21 

9 percent were hugger. And then based off of 

10 results from the AcuPOLL survey, which asked 

11 about installation configuration of ceiling fans, 

12 we assumed that 73 percent of the multi-mount 

13 fans would be installed as standard fans, and 27 

14 percent would be installed as hugger, and we sort 

15 of ran with those numbers through our analysis, 

16 so they were treated as standard or hugger, 

17 according to those proportions. 

18 Now, a couple of items for comment. DOE 

19 estimated that 21 percent of fans are hugger, 26 

20 percent of fans are standard, and 53 percent are 

21 multi-mount, and we open this up to comment, and 

22 if anyone would like to provide us data, that 
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1 would be very useful. 

2 MR. BROOKMAN: Dave. 

3 MR. GATTO: I think the only comment I'd 

4 make - we've covered a lot of this -- is that the 

5 hugger market share is probably skewed in the 

6 same manner that we talked about elsewhere, 

7 because the unit volume -- if you looked at 

8 there's 100 fans at a particular retailer and 21 

9 percent of them were huggers, what you might be 

10 missing is the unit volume associated with the 

11 five least expensive fans, which are probably all 

12 hugger. 

13 So if we can get that, that would be 

14 great. If not, I don't think we really have 

15 anything other than anecdotal to give you, to 

16 change what you did. 

17 MR. GANESHALINGAM: Okay. Thank you. 

18 And then, also, for ceiling fan installation 

19 configurations, DOE requests information 

20 regarding the similarity of installation 

21 distributions between all ceiling fans and the 

22 subset of multi-mount ceiling fans. DOE also 
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1 requests information or comment on the assumption 

2 that close-mount ceiling fans should be 

3 categorized as standard ceiling fans and not 

4 hugger ceiling fans. 

5 MR. BROOKMAN: David. 

6 MR. TURNER: David from Hunter Fan. I 

7 would agree with the percentage breakdowns you 

8 have. I assume a lot of it is from the AcuPOLL 

9 data, which we all pretty much -- 

10 MR. GANESHALINGAM: So, I think from that 

11 AcuPOLL data is where we get this 73/27, and I 

12 think that was assuming that close-mount was 

13 categorized as standard. 

14 MR. BROOKMAN: Thank you. 

15 MR. GANESHALINGAM: So, on to high-volume 

16 ceiling fan inputs and assumptions. As we 

17 already discussed, we used the same retirement 

18 function for high-volume, small-diameter ceiling 

19 fans as we did for low-volume ceiling fans. To 

20 get the total number of shipments, we scaled the 

21 shipments of low-volume ceiling fans by 12 

22 percent, which assumes a similar penetration of 
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1 high-volume, small-diameter fans into commercial 

2 industrial faces, as low-volume ceiling fans into 

3 commercial spaces. 

4 I'll stop here for comment, if anyone has 

5 any on that. 

6 MR. BROOKMAN: Dave. 

7 MR. GATTO: I'm just going to say that, 

8 in general, I think I agree with that for the 

9 same reason we said earlier, that I don't have 

10 any reason to disagree with it. 

11 MR. GANESHALINGAM: Okay. Thank you. 

12 And then for the large-diameter fans, we assumed 

13 linear shipments trend associated with new 

14 installations, starting in 2000, when these 

15 products started to come onto the market, and we 

16 kept that linear trend out to 2013, to match 2013 

17 estimate for stock, which I believe was at about 

18 50,000. So, we continued to use that linear 

19 trend as what we expect new installations to be 

20 over the course of our analysis period, and then 

21 we factor in the replacements of those fans. 

22 And we invite comment on that assumption. 
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1 All right. So, and this is just a 

2 schematic, showing, essentially, what I've 

3 already talked about, that we take into account 

4 the different market segments that feed into 

5 total shipments, replacements, new construction, 

6 and new installations. That gives us a total 

7 shipment, which we then disaggregate using a 

8 consumer choice model into shipments by product 

9 class and efficiency level. 

10 So, the retail price associated with each 

11 efficiency level will impact projected market 

12 share over the course of the shipments analysis 

13 period. DOE accounts for price learning in its 

14 estimate of ceiling fan prices over the analysis 

15 period. Price learning is the systematic 

16 decrease in manufacturing cost due to production 

17 experience. The idea here being that as the 

18 cumulative number of units produced increases, 

19 manufacturers are able to reduce manufacturing 

20 cost via optimized manufacturing methods and 

21 economies of scale. 

22 For ceiling fans, DOE only applied price 
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1 learning to those ceiling fans which had DC 

2 motors, and, specifically, only to the electronic 

3 components associated with the controls in the DC 

4 motor. The cost for controls were estimated to 

5 be the incremental cost between a DC fan and an 

6 AC motor fan. So, for instance, it would be 

7 between EL3 and EL4, from the engineering 

8 analysis. That incremental cost is what we would 

9 apply price learning to, and, in this case, we 

10 used a price learning rate of 6 percent, which 

11 was based off of a producer price index for 

12 semiconductor components and these components 

13 used in the controls should track the larger 

14 industry of semiconductor components. 

15 MR. BROOKMAN: Dave. 

16 MR. GATTO: Dave Gatto, Westinghouse 

17 Lighting. Just one quick question. So, price 

18 learning through -- what was the time frame, 

19 because that bottoms out. 

20 MR. GANESHALINGAM: Well, I guess -- so, 

21 you're right. It does flatten out over time. We 

22 didn't fix it, I guess. 
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1 MR. GATTO: Okay. I don't know that it 

2 would represent a really big deal in the 

3 analysis, but I would just suggest that there's a 

4 diminishing return there, where it's going to end 

5 up at a mature price where it doesn't move a 

6 whole lot. 

7 MR. GANESHALINGAM: And since we're only 

8 applying it to that incremental price -- 

9 MR. GATTO: Oh, I'm sorry. So that's the 

10 2 percent of the -- 

11 MR. GANESHALINGAM: So, I guess -- 

12 MR. GATTO: All right. 

13 MR. CYMBALSKY: So it's 6 percent of -- 

14 MR. GANESHALINGAM: Yeah. It's 6 percent 

15 of that incremental -- 

16 MR. CYMBALSKY: Over 30 years. 

17 MR. GANESHALINGAM: -- of that 2 percent. 

18 MR. GATTO: All right. Thanks. So it's 

19 probably nominal, if I took calculator out. So, 

20 thank you. 

21 MR. CYMBALSKY: You don't need a 

22 calculator. 
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1 MR. GANESHALINGAM: Okay. So, DOE 

2 adopted a learning rate of 6 percent applied to 

3 the cost premium associated with a brushless DC 

4 motor, based on information from a technical 

5 expert for low-volume ceiling fans. DOE requests 

6 stakeholder input on the validity of this 

7 learning rate, as applied to low-volume and high8 volume ceiling fans. 

9 MR. BROOKMAN: I'm thinking we've covered 

10 this. 

11 MR. GANESHALINGAM: One item I would like 

12 to touch on is the magnet used in DC motors. DOE 

13 requests information on the type of magnet used 

14 in DC motors and the associated cost of that 

15 magnet. 

16 MR. BROOKMAN: Yes. Christian. 

17 MR. TABER: Christian Taber, Big Ass 

18 Solutions. I'm not a magnet guy, but we have 

19 one, and he is going to supply comments and 

20 details on the magnets we use, the other types of 

21 magnets, and their relative costs, in his 

22 opinion. 
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1 MR. BROOKMAN: Thanks very much. Yes, 

2 Bill. 

3 MR. WALKER: Bill with Hunter Fan. I'm 

4 not a magnet guy, either, but in some analysis 

5 that we've done lately, recently, we've seen a 

6 lot of ferrite. Cost-wise, I can't tell you. I 

7 don't know. But ferrite has been the main one. 

8 MR. BROOKMAN: Okay. 

9 MR. GANESHALINGAM: Great. Thank you. 

10 So, onto the consumer-choice model. The 

11 consumer-choice model is an econometric model, 

12 used to estimate market shares for each EL, based 

13 on consumer sensitivity to first cost and 

14 operating cost. The model calculates a 

15 probability a consumer will chose each efficiency 

16 level by looking at parameters that influence 

17 consumer decisions. 

18 In our implementation, the consumer19 choice models considers consumer sensitivity to 

20 first cost for low-volume ceiling fans, and, in 

21 the case of high-volume ceiling fans, first cost 

22 and operating cost. And this basically allows 
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1 for voluntary purchases of more efficient 

2 technologies. 

3 For high-volume ceiling fans, the relative 

4 weighting of sensitivity to first cost and 

5 operating cost was estimated using the current 

6 market share distribution for high-volume ceiling 

7 fans, and for low-volume ceiling fans, the 

8 sensitivity to first cost was estimated using 

9 market data from NPD, which gave the distribution 

10 of sales as a function of retail price. 

11 So that diagram that you see on the right 

12 here is the distribution from NPD and the fit, 

13 which is an exponential fit, is in red, and that 

14 essentially gives us our sensitivity to first 

15 cost, which is used in our consumer-choice model. 

16 If anyone has any comments on that. 

17 MR. TURNER: On the Issue 33? 

18 MR. GANESHALINGAM: That and also, I 

19 guess, just general methodology here. 

20 MR. TURNER: Well, on the Issue 33, I 

21 would say, when we say product classes, we're 

22 talking about hugger, low-volume. Because there's 
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1 an aesthetic and a style design piece to ceiling 

2 fans, I think there's definitely some crossover 

3 with them. Somebody may go in looking for a 

4 hugger close to the ceiling, but if they find a 

5 fan that they think fits their home better, 

6 they'll make it work. I don't know what 

7 percentage would go to that, but there is some 

8 crossover between products. 

9 MR. GANESHALINGAM: Okay. Is that 

10 something you would imagine changing with time? 

11 So we have sort of the fraction of market share 

12 appropriate to hugger versus standard. 

13 MR. TURNER: Oh, as far as huggers 

14 becoming more popular or less popular? 

15 MR. GANESHALINGAM: Yeah, exactly. 

16 MR. TURNER: No? I mean, the crossover 

17 effect is still going to be there, going forward 

18 -- 

19 MR. GANESHALINGAM: Yeah, right. 

20 MR. TURNER: -- but as far as the overall 

21 market share of huggers or standard fans, without 

22 a crystal ball I wouldn't say it's going to 
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1 change too much. 

2 MR. GATTO: Dave Gatto, Westinghouse 

3 Lighting. Yeah, I agree with Dave Turner. I 

4 think that because when you pick -- like if we 

5 use the current definition that you're proposing 

6 at 10 inches, there's a lot of products that are 

7 really in a narrow band around that. So there's 

8 some utility reasons people would not switch 

9 classes. Outside of that, it tends to be more 

10 decorative, or some other particular function. 

11 I think rather than product class 

12 switching -- and you've got it kind of captured 

13 here -- because of the first cost is really where 

14 the sensitivity is, I think the consumer choice 

15 point would not be between classes. It would be 

16 between buying a fan or not buying a fan. 

17 MR. TURNER: David from Hunter. 

18 Actually, I was thinking of, in my brain, of what 

19 a hugger was. There would probably be a shift to 

20 huggers at some point, because standard fans 

21 could potentially roll into the hugger category 

22 now, versus what we call them today. In my head, 
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1 that makes sense, because it's a distance-based 

2 thing. 

3 MR. GATTO: Dave Gatto, Westinghouse. 

4 And just to be careful, I made an assumption that 

5 what you're calling standard and hugger in the 

6 analysis is based on the proposed definition. 

7 MR. GANESHALINGAM: That's correct. 

8 MR. GATTO: Okay. So I think they did 

9 that, but I didn't actually ask the question, so 

10 I'm glad you said it that way or I might have 

11 assumed that, and you were actually using our 

12 definition in the analysis. So, thanks. 

13 MR. CYMBALSKY: And, of course, Dave set 

14 up the last slide of the day with his previous 

15 comment. 

16 MR. GANESHALINGAM: So the impact of 

17 standards, DOE expects that an increase in price, 

18 due to the implementation of an amended 

19 efficiency standard could lead to a decrease in 

20 shipments. DOE estimates this impact using a 

21 relative price elasticity. I think we've talked 

22 a little bit about this. Another thing we 
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1 considered is since ceiling fans are often 

2 packaged with CFLKs, a ceiling fan light kit, a 

3 CFLK standard will also impact ceiling fan 

4 shipments, even in the absence of a ceiling fan 

5 standard. 

6 So, DOE also includes this impact in its 

7 analysis, and the range of CFLK standard 

8 scenarios are considered and the results 

9 presented in the TSD chapter. 

10 MR. GATTO: Dave Gatto, Westinghouse 

11 Lighting. I think we talked about the price 

12 elasticity within fans, not to death, but 

13 definitely enough where I think you guys know 

14 where we're at, and I'm wondering if Ashley 

15 intentionally let this be the last slide so she 

16 wouldn't have to be here for them, when she 

17 pushed me off to today. 

18 What I would say is that I don't -- and 

19 it could, in part, John, be because the analysis, 

20 when you combine them, throws the math off, but I 

21 think that if you have a four-time increase in 

22 CFLK pricing and even a moderate increase in fan 
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1 pricing -- so when you were talking about 10 

2 percent -- I think that when you look at the 

3 percentage of the market, 88 percent that are 

4 packaged with, then what that really would result 

5 in, to me, is either we would follow that and 

6 consumers wouldn't buy fans, or, more likely, 

7 that you'd see fan light kits come off of fan. 

8 There are two challenges with that. One 

9 is that that will make consumers unhappy, because 

10 this thing goes in the middle of a room and 

11 typically there is a light fixture there. And I 

12 don't know that this can be analyzed, but the 

13 corresponding -- I don't know if rebound effect 

14 is what you would want to call it, but the 

15 potential energy usage effect of that would be 

16 that if the fan doesn't have a light, and you 

17 need to have a light in the room, they're going 

18 to shift to an alternate light source -- floor 

19 lamp, table lamp, multiple wall sconces -- 

20 because the fan is going to take the place of the 

21 centrally located light source, and because of 

22 the way the definition is written, you can't make 
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1 a luminaire that's not a covered product and 

2 stick it on a fan, because as soon as you do, 

3 it's CFLK. 

4 MR. BROOKMAN: Don Brundage. 

5 MR. BRUNDAGE: I wasn't here yesterday 

6 for the ceiling fan light kits, but it just seems 

7 like you're delivering light more efficiently 

8 from the center, on the ceiling of the room, and 

9 it's going to take more light if you substitute 

10 it from floor lamps or luminaires, or whatever. 

11 I think there's some substitutionary 

12 effects. I don't really understand the logic of 

13 even regulating ceiling fan light kits. It's 

14 just another place to stick a light bulb into. 

15 You don't regulate the efficiency of a lamp 

16 somebody sticks on the floor. You regulate the 

17 efficiency of the light bulbs you could 

18 potentially put into it. 

19 MR. CYMBALSKY: It's essentially a lamp 

20 standard. I know you weren't here. It's a lamp 

21 standard. They can explain it to you, but it is 

22 a lamp standard. 
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1 MR. BRUNDAGE: Okay. 

2 MR. GATTO: And, Don, we can talk 

3 offline, but, yeah, I agree with John. 

4 Basically, DOE did hear us, and they went with a 

5 lamp standard. I think the challenge that I'm 

6 proposing back to DOE is that it's a lamp 

7 standard that's above the current federal lamp 

8 standard for light bulbs by themselves, so that 

9 that substitution effect would be that you would 

10 put a fixture that does not have a regulation on 

11 what efficacy label you can use, and you'd use 

12 what's available in the market, which potentially 

13 could be less efficient -- not suggesting it 

14 would be. I know the LEDs, we all agree, are 

15 moving towards adoption. 

16 MR. CYMBALSKY: Right. I mean, it's the 

17 bulbs you would use. If you can envision a light 

18 kit with three lamps in it, are you saying now 

19 you'd need four fixtures around the room instead 

20 of three overhead? I think that's what you're 

21 getting at. 

22 MR. BRUNDAGE: Yeah. That's what I'm 
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1 getting at. It's going to require more light to 

2 inefficiently deliver into probably the corners 

3 of the room instead of central from the middle, 

4 directly down onto what you want to illuminate. 

5 MR. GATTO: Dave Gatto, Westinghouse, and 

6 I agree with that. I don't know what the effect 

7 is. I know we don't really have a sense of it. 

8 I think the thing that I'm trying to impress upon 

9 DOE is that you're talking about the amount of 

10 light that you need. What I'm saying is that the 

11 amount of light that you need is going to be 

12 produced by a less-efficient light bulb because 

13 there's no standard on the corresponding product 

14 that the consumer would select. 

15 I know you know that. I just want to be 

16 on the record with it, so we're clear. 

17 MR. CYMBALSKY: Okay. Anything else on 

18 shipments, because this is where we're going to 

19 end for the day. 

20 MR. BROOKMAN: We covered national impact 

21 analysis in considerable depth yesterday. So, 

22 now, anybody that wishes to make closing remarks, 
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1 final statements about things that we haven't 

2 covered sufficiently. Chuck. 

3 MR. MATTHEWS: I'd like to make an 

4 addendum to Slide 66, a little slow where the 

5 process goes. Something was said by the woman 

6 who was sitting here. She thought there might be 

7 a loophole created for manufacturers to create 

8 more products if the wing tip speed or the RPMs 

9 were removed from the highly decorative 

10 definition. I don't believe so, and I don't 

11 believe my fellow manufacturing folks here would 

12 suggest that either, because it's still a very 

13 small niche market. It's a highly decorative, 

14 small niche market. The vast majority of 

15 customers do want high CFMs to come from a 

16 ceiling fan, and so these particular products are 

17 few in number, and wouldn't represent any sort of 

18 advantage loophole if that definition were 

19 amended to remove the RPMs. 

20 MR. BROOKMAN: Okay. Thank you. Final 

21 concluding remarks? Bill. 

22 MR. WALKER: Bill with Hunter. Just a 
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1 question, clarification for my benefit. So, 

2 we've established that the Energy Star test 

3 procedure is going away as it currently exists, 

4 and you're proposing the new test procedure, and 

5 that EPA will come up with the requirements for 

6 that Energy Star program at some point in time. 

7 So, fans outside of the Energy Star 

8 program, or outside of Energy Star requirements -

9 - you've got the EL0 through 5, or whatever -- 

10 and you maybe not can answer this question right 

11 now, but do you see that there will be efficiency 

12 levels associated with each fan, and that will be 

13 on the carton, or do you see that, no, you're 

14 going to go to a, all fans will be EL2 and that 

15 efficiency level will be some certain standard 

16 CFM per watt -- or can you answer that? 

17 MR. CYMBALSKY: The way we have it set up 

18 here is each of those product classes would be 

19 evaluated individually. 

20 MR. WALKER: Okay. And you would just 

21 rate it? I mean, if you came in at a certain 

22 level, you would have an EL1 fan, or whatever. 
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1 Is that what you're saying? 

2 MR. CYMBALSKY: Sure. 

3 MR. WALKER: Okay. And just one more, 

4 important information from Navigant. David 

5 requested that wattage and CFM per watt. You 

6 don't have to do it right now, but if I can get 

7 it after the meeting. 

8 MS. KUMAR: Yeah, sure. 

9 MR. WALKER: We can talk after this. I 

10 think that's important information. 

11 MR. BROOKMAN: David. 

12 MR. GATTO: Dave Gatto, Westinghouse 

13 Lighting. Dick had to leave, but on behalf of 

14 ALA and the fan manufacturers that were 

15 participating here, we appreciate DOE's time. We 

16 definitely appreciate the amount of engagement 

17 you've allowed, both in the public meeting 

18 setting and offline conversations. It's very 

19 encouraging to get the kind of dynamic and dialog 

20 that you've provided, rather than simply, here's 

21 what we're doing and figure it out for 

22 yourselves. So we just want to say thank you. 
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1 MR. CYMBALSKY: This is John from DOE. 

2 And I appreciate that, and I think it's a two-way 

3 street. We engaged in all our rulemakings, and 

4 the fact here is that you guys engage too. So, 

5 without that, I don't think we get the level of 

6 cooperation from each other, so DOE definitely 

7 appreciates the level of effort that all of you 

8 went through to read this document. We've seen 

9 the comments and we really appreciate the level 

10 of effort and the amount of data that's been 

11 provided thus far, and I know you'll provide 

12 more. 

13 We talked about the comment extension, 

14 and I think we're looking at December 9th. It's a 

15 Monday. For those of us that work over the 

16 weekend, that gives you a couple of extra days. 

17 MR. GATTO: Michael Weems is going to 

18 email you tomorrow. 

19 MR. CYMBALSKY: So, again, if there's 

20 nothing else, thanks, everyone, for coming. We 

21 really appreciate it. I think it was very 

22 productive couple of days.
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1 [Whereupon, at 4:00 p.m., the Public 

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1 CERTIFICATE OF COURT REPORTER 

2 I , Brian Knieser , the officer before whom 

3 the foregoing proceedings were taken , do hereby 

4 certify that the foregoing pages are a correct 

5 and accurate transcription of the proceedings 

6 that were recorded by me and thereafter reduced 

7 to typewriting under my direction ; that I am 

8 neither counsel for , related to , nor employed by 

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any of the parties associated with these 

proceedings . 

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