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### U.S. DEPARTMENT OF ENERGY 1

2

3

4 

### Public Meeting on Test Procedure Notice 5 

### Of Proposed Rulemaking and Energy Conservation 6 

### Standards Preliminary Analysis for Ceiling Fans 7

8

9

10

11

12 

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

### Wednesday, November 19, 2014 14

15 

### U.S. Department of Energy 16 

### 1000 Independence Avenue, SW 17 

### Room 8E-089 18 

### Washington, D.C. 19

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### ATTENDEES: 1

2 

### Facilitator: 3 

### DOUGLAS BROOKMAN, Public Solutions 4

5 

### Department of Energy: 6


### JOHN CYMBALSKY 7


### LUCY DEBUTTS 8


### JENNIFER TIEDEMAN 9


### STEVE GOERING 10


### LAURA BARHYDT 11


### JOANN MILLIKEN 12

13 

### Industry Representatives: 14 

### CHRISTIAN TABER, Big Ass Fans 15 

### JANIE WISE, Cassidy & Associates 16 

### VAN SMITH, Van Ness Feldman LLP 17 

### DAVE GATTO, Westinghouse Lighting 18 

### MARIANNE DIMASCIO, ASAP 19 

### CHUCK MATTHEWS, Matthews Fan Company 20 

### TIM FLANNERY, The Minka Group 21 

### NATHAN FRAMPTON, Fanimation 223

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### ATTENDEES (continued): 1

2 

### Industry Representatives (continued): 3 

### DONALD BRUNDAGE, Southern Company 4 

### ALLEN ROO, Emerson Electric Company 5 

### BILL WALKER, Hunter Fan Company 6 

### DAVID TURNER, Hunter Fan Company 7 

### CLARK LINSTONE, Lamps Plus 8 

### RICHARD UPTON, American Lighting Association 9 

### ALEX BOESENBERG, National Electrical 10 

### Manufacturers Association 11

12 

### Consultants: 13 

### MOHAN GANESHALINGAM, Lawrence Berkeley 14 

### National Laboratory 15 

### COLEEN KANTNER, Lawrence Berkeley National 16 

### Laboratory 17 

### SAMUEL JASINSKI, Navigant 18 

### ARIS MARANTAN, Navigant 19 

### MYTHRI KUMAR, Navigant 20 

### JULIE PIERCE, Navigant 21

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### ATTENDEES (continued): 1

2 

### Also attending: 3 

### KENT MATHIS, HKC 4 

### TERRY MCGOWAN, American Lighting Association 5 

### MICHAEL WEEMS, American Lighting Association 6 

### SARAH MEDEPALLI, ICF International, on behalf 7 

### Of Energy Star 8 

### HAMPTON NEWSOME, Federal Trade Commission 9 

### ELIZABETH NOLL, National Resources 10 

### Defense Council 11 

### LOUIS-BENOIT DESROCHES, Lawrence Berkeley 12 

### National Laboratory 13

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### C O N T E N T S 1


### PAGE 2 

### MORNING SESSION 6 3 

### AFTERNOON SESSION 168 4

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

### Morning Session 2 

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

### take your seats. 4 

### Good morning, everyone. Welcome. This 5 

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

### on Test Procedure Notice of Proposed Rulemaking 7 

### and Energy Conservation Standards Preliminary 8 

### Analysis for Ceiling Fans. Today is Wednesday, 9 

### November 19, 2014, here in the Forrestal Building 10 

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

### Public Solutions. Glad to see you all this 12 

### morning. We're going to start with welcoming 13 

### remarks from John Cymbalsky. 14 

### MR. CYMBALSKY: Thank you, Doug. Good 15 

### morning, everyone. Welcome to the Public Meeting 16 

### for Ceiling Fans. A lot of familiar faces from 17 

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

### who were here yesterday, some of this material 19 

### will be a little repetitive, unfortunately, but 20 

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

### we'll have to actually cover the same ground with 227

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### ceiling fans that we did with light kits 1 

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

### little more lively than yesterday -- not to say 3 

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

### great discussion and appreciate all the good 5 

### comments we received. 6 

### As always, we will record your oral 7 

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

### follow up with written comments for the record. 9 

### We appreciate a good, lively discussion today. I 10 

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

### think of that should spark a good conversation 12 

### today, so thanks for coming. 13 

### MR. BROOKMAN: Okay. We always start 14 

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

### immediate left. You can get used to turning 16 

### these microphones both on and off; the little 17 

### green light illuminates. Name and organizational 18 

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

### MR. TABER: Christian Taber, Big Ass 20 

### Solutions. 21 

### MS. WISE: Janie Wise, Big Ass Solutions. 228

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### MR. SMITH: Van Smith, Van Ness Feldman 1


### LLP. 2 

### MR. BOESENBERG: Alex Boesenberg, 3 

### National Electrical Manufacturers Association. 4 

### MR. GATTO: Dave Gatto, Westinghouse 5 

### Lighting. 6 

### MS. DIMASCIO: Marianna DiMascio, 7 

### Appliance Standards Awareness Project. 8 

### MR. MATTHEWS: Chuck Matthews, Matthews 9 

### Fan Company. 10 

### MR. FLANNERY: Tim Flannery, the Minka 11 

### Group. 12 

### MR. FRAMPTON: Nathan Frampton, 13 

### Fanimation. 14 

### MR. BRUNDAGE: Don Brundage, Southern 15 

### Company. 16 

### MR. ROO: Allen Roo, Emerson Electric. 17 

### MR. WALKER: Bill Walker, Hunter Fan. 18 

### MR. TURNER: David Turner. Hunter Fan. 19 

### MR. LINSTONE: Clark Linstone, Lamps 20 

### Plus. 21 

### MR. UPTON: Dick Upton, President of the 229

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### American Lighting Association. 1 

### MS. TIEDEMAN: Jennifer Tiedeman, DOE. 2 

### MR. CYMBALSKY: John Cymbalsky, DOE. 3 

### MR. JASINSKI: Sam Jasinski, Navigant. 4 

### MR. GANESHALINGAM: Mohan Ganeshalingam, 5 

### Lawrence Berkeley National Labs. 6 

### MR. MARANTAN: Aris Marantan, Navigant 7 

### Consulting. 8 

### MS. KUMAR: Mythri Kumar, Navigant 9 

### Consulting. 10 

### MS. KANTNER: Colleen Kantner, Lawrence 11 

### Berkeley National Laboratory. 12 

### MR. MCGOWAN: Terry McGowan, American 13 

### Lighting Association. 14 

### MR. WEEMS: Michael Weems, American 15 

### Lighting Association. 16 

### MR. MATHIS: Kent Mathis, HKC. 17 

### MS. MEDEPALLI: Sarah Medepalli, ICF 18 

### International, on behalf of Energy Star. 19 

### MR. GOERING: Steve Goering, DOE. 20 

### MS. BARHYDT: Laura Barhydt, DOE. 21 

### MR. NEWSOME: Hampton Newsome, Federal 2210

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### Trade Commission. 1 

### MS. NOLL: Elizabeth Noll, NRDC. 2 

### MS. MILLIKEN: JoAnn Milliken, DOE. 3 

### MR. DESROCHES: Louis Desroches, Lawrence 4 

### Berkeley National Laboratory. 5 

### MS. DEBUTTS: Lucy deButts, DOE. 6 

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

### appreciate you being here this morning. All of 8 

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

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

### to a very brief agenda review. Immediately 11 

### following this agenda review there is an 12 

### opportunity for opening remarks, brief summary 13 

### statements here at the outset, about issues that 14 

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



### so. 16 

### Moving from there, an examination of test 17 

### procedure, regulatory history, and then 18 

### rulemaking overview. Moving on, covered 19 

### products, existing test procedure, proposed 20 

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

### about 10:30, or whenever we need it and get 2211

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### there. 1 

### Following that, the proposed test 2 

### procedures, and then following that, description 3 

### of the test procedure, closing remarks on the 4 

### test procedure and NOPR. 5 

### That might take us all the way to lunch. 6 

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

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

### second segment of this meeting today, which is to 9 

### work on the energy conservation standards portion 10 

### of the meeting. 11 

### So, immediately when we get there, 12 

### opening statements on the energy conservation 13 

### standards regulatory history, rulemaking 14 

### overview. Moving on from there, scope and 15 

### technology assessment, screening analysis, 16 

### engineering analysis. We'll take a break mid17 

### afternoon, around about 2:15, 2:30, or so. 18 

### Following that, markups, energy use, life 19 

### cycle cost analysis, shipments analysis, national 20 

### impact analysis, preliminary manufacturer impact 21 

### analysis, and then NOPR analyses. And, at the 2212

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### end of the day, whenever we get there, whenever 1 

### all this material has been covered, another 2 

### opportunity for public comment, another 3 

### opportunity for you to say things that need to be 4 

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

### covered sufficiently. 6 

### I ask for your consideration. Please 7 

### speak one at a time. Yesterday everybody was 8 

### quite disciplined about saying their name each 9 

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

### helpful for developing the record. It really is 11 

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

### remind folks as much. 13 

### There will be a complete transcript of 14 

### this meeting available. If you could please be 15 

### concise with your comments, share the air time. 16 

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

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

### yet, please do so. 19 

### Limit your sidebar conversations, and 20 

### webinar participants, we welcome you. The 21 

### Department of Energy is trying hard to make these 2213

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### meetings totally accessible via the Web. Please 1 

### keep your telephones on mute, and raise your 2 

### hands to be recognized to speak, via the software 3 

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

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

### that work. 6 

### As I said, the Department is wanting to 7 

### make these meetings totally accessible via the 8 

### Web, and I would encourage all stakeholders to 9 

### submit written comments, as John Cymbalsky did 10 

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

### very, very helpful to the department. 12 

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

### procedure content, as listed here. 14 

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

### do opening remarks, here, around the room. 16 

### Opening statements? Yesterday we had a few. 17 

### MR. UPTON: Dick Upton, President of the 18 

### American Lighting Association. Doug, I think the 19 

### best thing I can say is we appreciate our 20 

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

### yesterday from Dave Gatto at Westinghouse because 2214

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### of the nature of what we were discussing, but I 1 

### think you'll have a lot more participation from 2 

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

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

### more participation from our people. 5 

### Doug, do you have something to start 6 

### with? 7 

### MR. TURNER: Yes. David Turner with 8 

### Hunter Fan. My opening comment is more specific 9 

### to the sections that we're going to cover 10 

### regarding operating hours and the allocation of 11 

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

### DOE included data form the LBNL survey, where 13 

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

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

### and then to keep the testing from becoming really 16 

### burdensome, it allocated Medium to the same 17 

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

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

### And we provided data in our response from 20 

### AcuPOLL that stated differing data, and we 21 

### understood what was said, in response, in the 2215

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### TSD, was that our data asked the question a 1 

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

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

### and we conferred with DOE on the question we 4 

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

### the question to a different group, through 6 

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

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

### shoot over to you guys, but the survey results 9 

### came back very similar to our initial estimates 10 

### from AcuPOLL, that as far as ranging from Medium 11 

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

### So we would ask that the DOE relook at 13 

### how they allocate the operating hours, because 14 

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

### usage would be inflated, considering that Medium 16 

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

### wattage and energy consumption. 18 

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

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

### details, but this was something that we kind of 21 

### went on in between the release of the TSD and the 2216

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### NOPR, and went back and got some more data. 1 

### MR. CYMBALSKY: This is John from DOE. 2 

### Just a clarifying question. So, your concern is 3 

### how we break out the operating hours, not 4 

### necessarily with the number of hours per year per 5


### se? 6 

### MR. TURNER: Correct. It was the 7 

### allocation of the fan speed. 8 

### MR. CYMBALSKY: Perfect. Thank you. 9 

### MR. BROOKMAN: Other remarks here at the 10 

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

### yes. Lucy deButts. 12 

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

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

### discuss this procedure and the standards for 15 

### ceiling fans. This morning will be the test 16 

### procedure discussion. So when we start 17 

### discussing the analysis, we will see, on the 18 

### presentations, the issue boxes. These issue 19 

### boxes correspond to the issues that were outlined 20 

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

### was stated, but we also would like to see those 2217

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### remarks in writing, which will help us to write 1 

### our rules. 2 

### All the information associated with the 3 

### test procedure can be found in the docket, and 4 

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

### is listed here on the slide. 6 

### The deadline for submitting comments for 7 

### the ceiling fan test procedure is December 31st 8 

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

### gift for us, hopefully. 10 

### Okay. In order to submit written 11 

### comments, you will need to provide us with a 12 

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

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

### the docket number, the RIN number of the test 15 

### procedure, and, of course, submit it via the e16 

### mail address that's listed on this slide. You 17 

### can also send it to us by Postal Service or 18 

### courier, but electronic options are preferable, 19 

### again. 20 

### And just so nobody forgets, December 31st 21 

### of 2014 is the deadline for submitting written 2218

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### comments. 1 

### We already did opening remarks, so 2 

### skipping to the schedule. 3 

### The ceiling fan test procedure rulemaking 4 

### was initiated by publication of the notice in the 5 

### Federal Register, which happened on October 17th 6 

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

### which ends, as I stated already, on December 8 

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

### rule for the ceiling fan test procedure to be 10 

### published in the third quarter of 2015, with the 11 

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

### the final rule publication, of third quarter 13 

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

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

### very similar to what was done yesterday. The 16 

### EPCA authorized DOE to start regulating certain 17 

### products, and the EPAct 2005 actually established 18 

### energy conservation standards for ceiling fans, 19 

### which were based on the Energy Star testing. 20 

### On December 8, 2006, DOE published a 21 

### final rule which codified the test procedure for 2219

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### ceiling fans, and the last bullet on here shows 1 

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

### the test procedures. 3 

### EISA, in 2007, authorized DOE to do the 4 

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

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

### today. Based on that authority, we are reviewing 7 

### the ceiling fan test procedures. 8 

### As far as the existing test procedure for 9 

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

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

### under Appendix U. 12 

### And that concludes the history and the 13 

### schedule. So, for covered products, I will 14 

### welcome Colleen right now to help me with the 15 

### presentation. 16 

### MR. BROOKMAN: At any point during the 17 

### presentation, if you want clarification, if you 18 

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

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

### cover scope and applicability. The test 21 

### procedures apply to ceiling fans that meet the 2220

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### statutory definition, where EPCA defines a 1 

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

### suspended from a ceiling for circulating air via 3 

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

### reinterpret the statutory definition of a ceiling 5 

### fan to incorporate hugger ceiling fans. Hugger 6 

### ceiling fans are generally indistinguishable from 7 

### other types of ceiling fans in that they move air 8 

### via the rotation of fan blades, are intended to 9 

### improve comfort, and are rated on their ability 10 

### to move air. This reinterpretation more 11 

### accurately reflects the statutory definition and 12 

### does not draw an artificial distinction between 13 

### units which serve the same functional purpose. 14 

### DOE proposes to clarify that multi-mount 15 

### ceiling fans and high-volume ceiling fans meet 16 

### the statutory definition of a ceiling fan, and 17 

### also clarifies that the current and proposed test 18 

### procedures do not apply to centrifugal ceiling 19 

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

### are fans that are typically mounted on a 21 

### pedestal, but could include wall, ceiling, or I- 2221

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### beam mounting brackets. 1 

### MR. FRAMPTON: Hi. This is Nathan with 2 

### Fanimation. Could we get further definition on 3 

### your definition of an air circulator? 4 

### MS. KANTNER: This is intended to 5 

### describe fans that, in theory, could be mounted 6 

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

### mean, they would normally be on a pedestal or 8 

### attached to something else, but you could, in 9 

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

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

### scope to include anything that, in theory, could 12 

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

### ceiling fan. 14 

### Does that clarify your question? 15 

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

### question around on you. Where do you see the 17 

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

### certain types of air circulators would 19 

### potentially fall into this definition of ceiling 20 

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

### MR. BROOKMAN: Ashley Armstrong. Now 2222

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### back to Nathan. 1 

### MR. FRAMPTON: I'm just trying to 2 

### understand the definition. 3 

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

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

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

### the fact that, generally speaking, air 7 

### circulators, we don't believe the test 8 

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

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

### suggesting that we need further clarification as 11 

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

### asking why. 13 

### MR. BROOKMAN: Chuck, do you have a 14


### comment? 15 

### MR. MATTHEWS: I do. Chuck Matthews, 16 

### Matthews Fan Company. There are products on the 17 

### market which could be considered air circulators 18 

### which are mounted to the ceiling -- 19 

### MS. ARMSTRONG: Okay. 20 

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

### ask you to define what is a fan blade and what is 2223

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### a fan head, and what is a ceiling mounting 1 

### bracket. 2 

### MS. ARMSTRONG: Okay. Go ahead. 3 

### MR. TABER: Christian Taber, Big Ass 4 

### Fans. I think AMCA 230, in their definition 5 

### section, has some language that could be used to 6 

### help with that. 7 

### MS. ARMSTRONG: Great. Thank you. 8 

### MR. BROOKMAN: Thank you. 9 

### MS. KANTNER: I believe this language 10 

### here is the language from AMCA 230. 11 

### MR. BROOKMAN: Chuck? 12 

### MR. MATTHEWS: Is that the language that 13 

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

### 230, which was mentioned by Big Ass? 15 

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

### DOE do some clarifications by looking at that as 17 

### one source of data to answer your question, so 18 

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

### is the answer. 20 

### MR. MATTHEWS: But I thought she said 21 

### that that was the language. 2224

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### MS. ARMSTRONG: So she believes that's 1 

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

### Definition section, there may be further language 3 

### to add to this. 4 

### MR. MATTHEWS: Okay. Alright. 5 

### MR. BROOKMAN: Christian, follow on. 6 

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

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

### also a Definition portion of AMCA 230 that 9 

### further defines some of those terms. So I was 10 

### saying that maybe we could use the Definition 11 

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



### on. 13 

### MS. KANTNER: Thanks for that. 14 

### MR. BROOKMAN: Additional questions, 15 

### comments before we move on? 16 

### MS. KANTNER: And now there are some 17 

### items for comment. First, DOE is reinterpreting 18 

### the statutory definition of a ceiling fan to 19 

### include hugger ceiling fans and clarifying that 20 

### the definition includes multi-mount ceiling fans. 21 

### DOE invites comment on the reinterpretation and 2225

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### clarification. 1 

### MR. BROOKMAN: Yes, Dave. 2 

### MR. GATTO: Dave Gatto, Westinghouse 3 

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

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

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

### MS. ARMSTRONG: No. This is it. 7 

### MR. GATTO: I have a tendency to start 8 

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

### so I figured I'd ask. 10 

### MS. ARMSTRONG: Just for those that 11 

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

### on this, and the reason Dave is bringing up 13 

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

### but DOE has proposed this part of this test 15 

### procedure NOPR to reinterpret the definition of 16 

### ceiling fan as encompassing huggers. Obviously, 17 

### that interpretation, that proposed interpretation 18 

### is out for comment. 19 

### One of the things that came up yesterday, 20 

### as a repercussion of this, ceiling fan light kits 21 

### sold with hugger fans would then be subject to 2226

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### the ceiling fan light kit standard. Our proposal 1 

### is effective 30 days after the final rule. 2 

### Should we finalize it as proposed? And some of 3 

### the discussion suggested that 30 days may not be 4 

### a sufficient amount of time for products that may 5 

### need to be redesigned. 6 

### So we turned around the question and 7 

### asked people yesterday, with respect to light 8 

### kits, doing the same thing today with respect to 9 

### ceiling fans, what would you suggest is a 10 

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

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


### context. 13 

### MR. GATTO: Thank you, Ashley. Dave 14 

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

### bit of dialog about this, but if I miss 16 

### something, everybody feel free to weigh in. The 17 

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

### physically possible, and there are some reasons 19 

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

### addition to huggers, you changed the test 21 

### procedure for existing models, which means that, 2227

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### without clarification, that would suggest we 1 

### would need to potentially retest current models 2 

### of fans, even though there's no efficiency 3 

### standard. 4 

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

### basically, the entire product line. From a 6 

### timing standpoint, that requires product 7 

### development of potentially hundreds of models, 8 

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

### specifically as it relates to huggers -- and 10 

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

### Westinghouse, if someone has an industrial fan 12 

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

### consideration there. 14 

### In addition to the product development 15 

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

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

### have to identify what are the component changes, 18 

### and then there are some sourcing needs. Now, 19 

### things like sockets and glass, probably not a big 20 

### deal, but we discussed limiters among us 21 

### yesterday, and some of us reached out to the 2228

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### supplier, and the limiter sudden spike in demand 1 

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

### it's the availability of some of the components 3 

### we would need for light kits. 4 

### The next step in the process would be 5 

### once we've established what those new base models 6 

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

### established full materials, we then have to 8 

### produce a sample and then test it. Having 9 

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

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

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

### using, potentially even longer. 13 

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

### data, we need to make sure everything is on 15 

### point, and we need to prepare certification for 16 

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

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

### the template, because the test procedure now for 19 

### multi-mount fans might require two separate 20 

### pieces of information, and currently I think 21 

### there's only a place for one in the FTC section. 2229

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### Once that's done, we actually have to 1 

### present those models to our customers, to the 2 

### retail channel, and because there are going to be 3 

### component changes, design changes, potentially -- 4 

### not potentially in the light kits; there will 5 

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

### cycle there to get placement before we can cut a 7 

### production order to a contract factory. 8 

### From the date you cut a production order, 9 

### average lead time we came up with was about 110 10 

### days. That includes the 30 days Tim spoke to 11 

### yesterday from the day it's produced, actually 12 

### comes off the production line, to the day it 13 

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

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

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

### all dealing with. 17 

### But that all-in somewhere between 18 and 18 

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

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

### huggers. I think we were on board with that 21 

### conversation in the last meeting, but the sheer 2230

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### volume of work that will be associated with this 1 

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

### statement, which I haven't really cleared with 3 

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

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

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

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

### is make the test procedures effective 1 year 8 

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

### at that point anyway. 10 

### Now, I recognize that for DOE that could 11 

### create a challenge for the hugger 12 

### reinterpretation as it reflects on light kits, 13 

### but my preference would be to have everything go 14 

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

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

### preference of the industry. 17 

### MR. BROOKMAN: So your last comment said 18 

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

### spoken to your colleagues, the other members here 20 

### present? They're generally in agreement, 21 

### alignment with that statement? 2231

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### MR. GATTO: It's a good point, Doug. 1 

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

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

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

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

### have either missed something or misstated the 6 

### timeline that everyone thinks is appropriate, 7 

### absolutely weigh in. But we did discuss this 8 

### over the last few days, actually, prior to 9 

### yesterday's meeting. 10 

### MR. BROOKMAN: These timelines are always 11 

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

### MR. ROO: Allen with Emerson. Emerson 13 

### agrees with Westinghouse on this schedule. 14 

### Eighteen months is appropriate. 15 

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

### MR. WALKER: Bill, Hunter Fan. Hunter 17 

### agrees with the schedule. 18 

### MR. BROOKMAN: Okay. Do we have other 19 

### commenters that are in the manufacturing domain, 20 

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

### appropriate? Okay, yes, Nathan? Tim? 2232

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### MR. FLANNERY: Tim Flannery, the Minka 1 

### Group. I'm in agreement with Dave from 2 

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

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

### existing inventory. How is that going to be 5 

### handled? Product that's in the warehouses, 6 

### products that have shipped. So are you prepared 7 

### to grandfather existing product that's come into 8 

### the country? I know Ashley brought that up 9 

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


### not. 11 

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

### hold on that additional topic, just for the 13 

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

### ahead, Nathan. 15 

### MR. FRAMPTON: Nathan with Fanimation. 16 

### We also agree with Westinghouse. 17 

### MR. BROOKMAN: Don Brundage, you had a 18 

### comment here? 19 

### MR. BRUNDAGE: Yes, a general comment on 20 

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

### equipment and the efficiency changes there would 2233

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### require retesting and recertification, and they 1 

### were complaining that 3 years was barely enough 2 

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

### never seen a time that you would require 4 

### recertification with only 30 days. I'm just 5 

### confused on where this very short time frame is 6 

### coming from, because, typically, for measures 7 

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

### suggesting, a couple of years. 9 

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

### to clarify a couple of things. This is Ashley 11 

### from DOE. Currently we have design standards for 12 

### ceiling fans. We do not have airflow efficiency 13 

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

### understand that manufacturers make 15 

### representations of their airflow efficiency, 16 

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

### disclosures for the Energy Star program, or for 18 

### other voluntary efforts that they may participate 19 

### in. The certification to the Department right 20 

### now has nothing to do with airflow efficiency. 21 

### It's purely on design standards. 2234

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### That certification wouldn't change with 1 

### respect to inclusion of huggers and the light 2 

### kits that go along with huggers, or other types 3 

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

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

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

### haven't changed the certification requirements. 7 

### So the cert would just be to the design 8 

### standards. 9 

### To the extent the reinterpretation goes 10 

### final as it was proposed, yes, that certification 11 

### would need to be picked up whenever we do the 12 

### effective date, but that would be with respect to 13 

### those design standards, not in airflow 14 

### efficiency. So there is a significant difference 15 

### there, between what you're bringing up with 16 

### regards to commercial unitary and here. They 17 

### have energy conservation standards but they're 18 

### design standard energy. 19 

### With respect to the retesting issue, I 20 

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

### Maybe you can better explain what it is you 2235

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### currently do today, in terms of the public 1 

### disclosures you make. Yes, we have a test 2 

### procedure that must be used for representation 3 

### purposes, if you make representations of airflow 4 

### efficiency. But because we don't have standards 5 

### for airflow efficiency, it's not a certified 6 

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

### everyone testing every single fan right now, to 8 

### the DOE test procedure for airflow efficiency? 9 

### MR. BROOKMAN: Nathan. 10 

### MR. FRAMPTON: I think the issue is right 11 

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

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

### huggers in the definition of ceiling fan, which 14 

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

### test the hugger per the Energy Star standard, and 16 

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

### to add a limiter. 18 

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

### back to you. 20 

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

### because I know you're thinking about this. While 2236

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### we don't have an efficiency standard, we have an 1 

### obligation under FTC to test and report airflow 2 

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

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

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

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

### So that would suggest to us that we do 7 

### have to certify those values before we submit 8 

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

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

### Admittedly, we're submitting through DOE kind of 11 

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

### voluntary program, unless we want to put the 13 

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

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

### MR. BROOKMAN: Ashley. 16 

### MS. ARMSTRONG: With respect to huggers 17 

### specifically, I mean, if we went final as 18 

### proposed with the test procedure, and the 19 

### reinterpretation of huggers, whatever the 20 

### effective date is -- proposed effective date is 21 

### 30 days -- there was a representation clause, 2237

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### which means representations get 180 days to 1 

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

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

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

### 180 days to fully change over representation. 5 

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

### isn't sufficient to move to the new test 7 

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

### saying? 9 

### So, can you say it for the record instead 10 

### of shaking your head? 11 

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

### deserved that since yesterday I was pushing on 13 

### you to go on the record. 14 

### MS. ARMSTRONG: You did. You cornered me 15 

### yesterday. 16 

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

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

### interpretation is creating burden where there is 19 

### none, where we would appreciate some 20 

### clarification. But in addition to hugger, I 21 

### think multi-mount fans, which a lot of us carry, 2238

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### the test procedure is different for those than 1 

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

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

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

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

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

### the requirements would be. 7 

### MR. BROOKMAN: So, restate what you think 8 

### the appropriate time period would be. 9 

### MR. GATTO: So, I think the preferred 10 

### timeline would be 1 year prior to the effective 11 

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

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

### date of the final test procedure has been 14 

### published. 15 

### MR. BROOKMAN: Nathan, you wish to chime 16 

### in here? 17 

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

### MR. FRAMPTON: Nothing other than I 19


### agree. 20 

### MR. BROOKMAN: Okay. Christian. 21 

### MR. TABER: Christian Taber, Big Ass 2239

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### Fans. Our concern is that if airflow efficiency 1 

### is included, or any changes to the test procedure 2 

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

### will have to recertify all of their fans. There 4 

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

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

### labs in the United States, and trying to funnel 7 

### everyone's fans through those for recertification 8 

### will be a very difficult process. 9 

### MR. BROOKMAN: Do you agree with the 10 

### general statement about the timeline? 11 

### MR. TABER: I don't have enough 12 

### background to know how fast the labs would be 13 

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

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

### MS. ARMSTRONG: So perhaps you can also 16 

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

### get into some details a little bit later in the 18 

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

### this discussion, because we do have a specific 20 

### slide on compliance dates, effective dates, 21 

### transition times, and we can hit this again. 2240

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### But, could somebody explain to me the percentage 1 

### of the market that's Energy Star and the 2 

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

### our own distributions that we made, but just off 4 

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

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

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

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

### impression. 9 

### MR. BROOKMAN: I see Allen. 10 

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

### certain companies that they do do their own 12 

### testing. 13 

### MR. BROOKMAN: Either Allen or Clark. 14 

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

### that third-party certification is not required 16 

### for FTC DOE data, for CFM data. 17 

### MS. ARMSTRONG: Absolutely. 18 

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

### to use certified labs. 20 

### MS. ARMSTRONG: You can use in-house 21 

### testing. We do not require a third party. We do 2241

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### not require a certification body. We do not have 1 

### DOE-approved labs. You need to test in 2 

### accordance with the test procedure provisions, if 3 

### you feel you have the confidence to do that. 4 

### Now, Energy Star models, I understand. 5 

### There's a certain percentage of the market that 6 

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

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

### it 40 percent? Is it 25 percent? What 9 

### percentage of the market typically flows through 10 

### those channels? 11 

### MR. BROOKMAN: It looks like -- 12 

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

### probably the largest fan manufacturers do in14 

### house testing. I mean, they can comment, but I 15 

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

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

### California, in fact, requires third-party. 18 

### So a concern that I have on this 19 

### particular topic is just potential disruption, 20 

### where just because of timelines, things might not 21 

### be available for sale until such time as some of 2242

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### these things can be done, whether it be through a 1 

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

### requirement to change something. And that would 3 

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

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

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

### be through a third party or just through our own 7 

### product, you know, development change process. 8 

### MR. BROOKMAN: Do we have any additional 9 

### comments here about issues related to timelines 10 

### and testing burden? Dave. 11 

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

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

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

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

### something that industry has to deal with, even 16 

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

### MS. ARMSTRONG: Okay. Thank you. 18 

### Anybody else? 19 

### MR. BROOKMAN: Christian. 20 

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

### don't know the other companies' percentages, for 2243

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### us, 100 percent of our fans are Energy Star. 1 

### MS. ARMSTRONG: Okay. Thanks. 2 

### MR. BROOKMAN: Allen. 3 

### MR. ROO: To your question about the 4 

### quantity of Energy Star certified test labs, I 5 

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

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

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

### are Energy Star certified test labs. 9 

### MS. ARMSTRONG: Okay. 10 

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

### MR. BROOKMAN: Do you know about the 12 

### percentage of the market? 13 

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

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

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

### certifying any new Energy Star test fans, or any 17 

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

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

### with the Energy Star test procedure itself and 20 

### the program? Are they going to follow suit with 21 

### your guidance? 2244

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### MS. ARMSTRONG: Yes. DOE is responsible 1 

### for test procedures for the regulatory program 2 

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

### test. It would all roll together. 4 

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

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

### all start anew? 7 

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

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

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

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

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

### me if I'm wrong. 13 

### MR. BROOKMAN: Please say your name, and 14 

### make sure that's on. 15 

### MS. MEDEPALLI: Okay. This is Sarah 16 

### Medepalli from ICF, representing Energy Star. 17 

### Yes, as Ashley mentioned, Energy Star typically 18 

### adopts the DOE test method and their 19 

### certification process. So whenever the test 20 

### method is finalized, Energy Star will begin the 21 

### revision process of the specification and adopt a 2245

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### test method, and, typically, provides a 9-month 1 

### transition time to, or allowing manufacturers to 2 

### recertify to the new version, with the new test 3 

### method. And I just wanted -- 4 

### MS. ARMSTRONG: Just to clarify, the 9 5 

### months would be a transition to the specs, the 6 

### spec levels? Whatever transition is required for 7 

### the test procedure would be dictated by what's 8 

### determined in the rulemaking and what becomes 9 

### federal law. That transition would have to occur 10 

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

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

### spec levels, and what they may become and what 13 

### they look like post the test procedure change, 14 

### but the actual effective compliance date 15 

### representations turnover would be determined by 16 

### the rule themselves, for all readings. Okay. 17 

### MR. BROOKMAN: Okay. Thank you. 18 

### MS. MEDEPALLI: Thank you. 19 

### MR. BROOKMAN: Do you wish to try to 20 

### address Tim's question about existing inventory 21 

### here? 2246

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### MS. ARMSTRONG: So, I think I'm going to 1 

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

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

### But when we get to the compliance date section, 4 

### just so there are some nuances on that slide, 5 

### remind me then to get back to your inventory 6 

### question about exactly what happens, what happens 7 

### with representations. If Hampton wants to chime 8 

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

### [Off mic comment.] 10 

### MS. ARMSTRONG: Oh, there we go. 11 

### MR. CYMBALSKY: This is John from DOE. 12 

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

### help the conversation we've had with other groups 14 

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

### understanding, except for maybe one manufacturer, 16 

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

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

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

### product and how long it takes. 20 

### MR. BROOKMAN: In the written comments. 21 

### MS. ARMSTRONG: And I think, from DOE -- 2247

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### no, for this afternoon -- and I think that the 1 

### difference for DOE is inventory here or is 2 

### inventory overseas, and it does matter, for the 3



### answer. 4 

### MR. BROOKMAN: Yes, Dave. 5 

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

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

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

### comfortable giving here, but I will commit to 9 

### answers that I don't feel comfortable in the 10 

### public media. I can file it through Navigant. 11 

### We're under an NDA. 12


### MS. ARMSTRONG: Sure. 13 

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

### at the microphone. 15 

### MR. NEWSOME: I'm Hampton Newsome from 16 

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

### we're the agency that does the labeling component 18 

### of the efficiency program. I probably will not 19 

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

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

### wanted to clarify a couple of things. 2248

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### One is just the general provision under 1 

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

### DOE test procedure for a product then any energy 3 

### representation you make needs to be based on 4 

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

### procedure, then any FTC labeling requirements 6 

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

### Energy Star representations will need to reflect 8 

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

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

### requirements. So if DOE updates their test 11 

### procedure, then any representation, including 12 

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


### new DOE test. 14 

### Now, as Ashley said, under the statute, 15 

### there is a representation provision that 16 

### basically says that manufacturers have 180 days 17 

### after DOE issues a test procedure to change all 18 

### their representation. So when we're talking 19 

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

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

### really have much flexibility on. Now, DOE, in 2249

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### terms of releasing the test procedure and that 1 

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

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

### talking about that. 4 

### Also, reporting. Currently FTC has 5 

### reporting, but if DOE has a certification program 6 

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

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

### duplicative reporting. So that's something that 9 

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

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

### eliminate our separate reporting requirements and 12 

### defer to DOE. 13 

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

### we proposed some changes to the design of the 15 

### EnergyGuide label, of the ceiling fan label. The 16 

### current ceiling fan label has airflow efficiency 17 

### and some other information. Most EnergyGuide 18 

### labels we have for consumer products these days, 19 

### the primary disclosure is an estimated yearly 20 

### operating cost, and we propose that, to change 21 

### the ceiling fan label to basically put the 2250

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### EnergyGuide title on it, and to also have 1 

### operating cost as the primary disclosure. And, 2 

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

### issues that look like they are directly tied to 4 

### the DOE proceeding. 5 

### The label is relatively simple, but when 6 

### we have an operating cost figure on there, we 7 

### need some assumptions behind that, and one of 8 

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

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

### the speed at which the fans are tested at. 11 

### Currently, the label is at high speed, and 12 

### there's concern about whether that overestimates 13 

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

### sets a speed or whatever DOE says in the test 15 

### procedure, is what we would generally follow on 16 

### the label. The intent, generally, with the 17 

### labeling program, is not to reinvent things or do 18 

### things differently than what DOE is requiring 19 

### manufacturers to do. 20 

### So, that's something. Those two issues 21 

### are things that, from FTC's perspective, the 2251

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### staff will be looking at during this proceeding, 1 

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

### a consistent label, if the Commission decides to 3 

### update the design. 4 

### MR. BROOKMAN: Since we have Hampton 5 

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

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

### MR. GATTO: Dave Gatto, Westinghouse 8 

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

### right, so -- 10 

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

### doing better all the time. Keep going. 12 

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

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

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

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

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

### that you guys have worked together to make it 18 

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

### have one result that we're reporting and putting 20 

### on the label. 21 

### My question is about the 180-day 2252

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### provision, and it's more of a, just to make sure 1 

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

### DOE says the effective date of the test 3 

### procedure, or when DOE says the compliance date 4 

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

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

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

### we're going to end up -- 8 

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

### statute. The statute, I believe -- 10 

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

### for that. 12 

### [Laughter.] 13 

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

### the statute says, I believe -- 15 

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

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

### interpretation of what that means, because 18 

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

### something that obviously will be an important 20 

### issue in this proceeding, and DOE will look into 21 

### it and try to figure out the timing. Ideally, 2253

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### for this type of change, since we're changing the 1 

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

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

### procedure changes, they're redoing the test 4 

### procedure, they're also redoing the label. 5 

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

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

### certainly consistent with the way we've handled 8 

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

### making lots of changes in series. 10 

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

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

### MR. TABER: Christian Taber, Big Ass 13 

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

### Would that also apply to high-volume, large15 

### diameter fans? 16 

### MR. NEWSOME: Our coverage would 17 

### generally match whatever DOE's test procedure 18 

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

### rule says specifically that we don't cover any 20 

### fan models that cannot be tested under the 21 

### current test procedure, even though, 2254

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### theoretically, if you read the definition, there 1 

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

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

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

### going to have consistent information. 5 

### MS. ARMSTRONG: So the answer to you 6 

### would be yes. 7 

### MR. NEWSOME: Yes. Since this would be 8 

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

### for it. 10 

### MS. ARMSTRONG: If we finalize as 11 

### proposed. 12 

### MR. BROOKMAN: Thank you, Ashley. Thank 13 

### you, Christian. Any other questions, comments, 14 

### before we move off this general topic, because 15 

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

### Colleen. Did you think we dealt with Issue 1 17 

### fully, Colleen? 18 

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

### mean, we started to touch on Issue 2. 20 

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

### MS. ARMSTRONG: Yup. 2255

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### MR. BROOKMAN: Okay. Then final comments 1 

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

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

### here. 4 

### Okay, Colleen. 5 

### MS. KANTNER: DOE determined that it was 6 

### necessary to delineate these two types of fans, 7 

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

### volume refers to airflow volume, because they 9 

### deliver different distinct utilities to ceiling 10 

### fan users and require different methods of 11 

### testing. 12 

### One distinct utility that low-volume 13 

### ceiling fans offer, compared to high-volume 14 

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

### residential locations. Because of this distinct 16 

### utility, DOE tried to harmonize the delineation 17 

### between these two types with existing UL 507 18 

### safety requirements for fans installed such that 19 

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

### seen in Table 1. 21 

### Additionally, DOE defines all ceiling 2256

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### fans greater than 7 feet in diameter as high1 

### volume fans, and all fans less than 7 feet in 2 

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

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

### next slide illustrates the categorization of low5 

### versus high-volume ceiling fans, using a flow 6 

### chart. 7 

### Now, this flow chart is specifically for 8 

### reversible ceiling fans, ceiling fans capable of 9 

### operating both in the forward and reverse 10 

### directions. Ceiling fans only capable of 11 

### operating such that the airflow is downward would 12 

### use a similar flow chart with different maximum 13 

### tip speeds corresponding to the blade edge 14 

### thickness. 15 

### But for reversible ceiling fans, you 16 

### would first determine whether a ceiling fan was 17 

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

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

### determine if the maximum airflow is less than or 20 

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

### a low-volume fan. But if it's greater than 5,000 2257

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### CFM, then whether or not it's a high- or low1 

### volume ceiling fan would depend on the maximum 2 

### tip speed for a given blade thickness, and this 3 

### is because thinner blades present a greater 4 

### danger to consumers at high speeds. 5 

### MR. BROOKMAN: Yes, Tim. 6 

### MR. FLANNERY: Can you please help me 7 

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


### CFM? 9 

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

### request. Can everybody pull these microphones 11 

### close to their face, please? 12 

### MR. FLANNERY: This is Tim Flannery from 13 

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

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

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

### volume? 17 

### MS. KANTNER: We thought it was 18 

### appropriate that there was some cutoff on airflow 19 

### volume below which you couldn't be considered a 20 

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

### determined by looking at typical airflows of 2258

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### high-volume ceiling fans and making sure that 1 

### there were none that were below that threshold. 2 

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

### suggest another threshold? 4 

### MR. FLANNERY: Tim Flannery with the 5 

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

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

### to 10,000. 8 

### MR. BROOKMAN: Oh, interesting. Yes, 9 

### Christian. 10 

### MR. TABER: I have a question on that 11 

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

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

### with the inclusion of the false ceiling? The 14 

### false ceiling reduces airflow by 30 to 50 15 

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

### dramatically different than 5,000 under the old 17 

### test procedure. 18 

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

### number referred to the current test procedure, 20 

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

### that under the new test procedure -- 2259

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### MR. TABER: It's more like 8,000 or 9,000 1 

### CFM, which is closer to that number. 2 

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


### on? 4 

### MS. ARMSTRONG: We would likely -- we 5 

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

### consistent with what would be generated from the 7 

### new test procedure. 8 

### MR. TABER: I have comments on the new 9 

### test procedure in that respect, as well. 10 

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

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

### summarize is perhaps you think a higher number is 13 

### a better number to differentiate the two types, 14 

### as the measures exist today, as representations 15 

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

### the right ballpark for what the airflow would 17 

### look like under the new test procedure, as 18 

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

### that way. Is that fair, or no? 20 

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

### MS. ARMSTRONG: Okay. 2260

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### MR. BROOKMAN: Thank you, Tim, and thank 1 

### you, Ashley. Don Brundage. 2 

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

### regulatory philosophy question here. 4 

### MR. BROOKMAN: Do we want to do that 5 

### after the break? 6 

### MS. ARMSTRONG: We want to do that after 7 

### the break. 8 

### MR. BROOKMAN: Just kidding. 9 

### MR. BRUNDAGE: Generally, with covered 10 

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

### general theme is something that would be normally 12 

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

### under 10 CFR 430, and something that would be 14 

### used in a commercial or industrial setting would 15 

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

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

### would have a ceiling fan with a fan diameter 18 

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

### a covered product. 20 

### I'm just -- is there some specific 21 

### legislation that puts all ceiling fans, 2261

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### regardless of size, under 430, or why is there 1 

### not a break in treating it differently, from a 2 

### regulatory viewpoint? Thank you. 3 

### MS. ARMSTRONG: This is Ashley from DOE. 4 

### I think the general answer is the statute sets up 5 

### covered products more broadly, just the covered 6 

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

### specific way, and we believe these types meet 8 

### that definition. There are certain products 9 

### where they put the entire, all the different 10 

### categories under a given product, covered product 11 

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

### certain types of lighting products are all in 13 

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

### lot of different applications. It's just the 15


### way. 16 

### So, ceiling fans, all the different 17 

### categories of ceiling fans are all of a type, 18 

### which is ceiling fan, and they happen to be 19 

### placed in the consumer product section of 430, 20 

### but we believe all these different categories of 21 

### ceiling fan meet the statutory definition. 2262

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### Obviously, some things we welcome comment on, but 1 

### this is DOE's interpretation. 2 

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

### would interpret what you said, because when they 4 

### added ceiling fans through legislation to Section 5 

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

### ceiling fans are going under 430. Is that more 7 

### or less correct? 8 

### MS. ARMSTRONG: Any ceiling fan that 9 

### meets that definition. The definition is not 10 

### restricted by size. 11 

### MR. BRUNDAGE: Okay. 12 

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

### Christian. 14 

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

### with the chart? 16 

### MR. BROOKMAN: The flowchart? Yes. 17 

### MR. TABER: I guess this is a general 18 

### comment. Would it be possible to have my slide 19 

### brought up? Would this be appropriate to do 20 

### that, from my general comments? 21 

### MS. DEBUTTS: Sure. We could. 2263

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### MR. TABER: Generally speaking, we find 1 

### this methodology to be a little confusing, and it 2 

### creates some issues. It took three degreed 3 

### engineers about 4 hours to figure out which 4 

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

### average user is going to spend 4 hours doing 6 

### that. 7 

### Right there. Back one. 8 

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

### Sorry. Forward. Right there. That one. 10 

### We tried to create a chart that kind of 11 

### showed all seven factors, and then color-coded 12 

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

### more understandable, and we kind of got lost. 14 

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

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

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

### answer. It's just a different answer. 18 

### If you can go down a slide. 19 

### There are a couple of issues with small20 

### diameter fans having different methods of test. 21 

### Generally speaking, AMCA 230 produces about 15 2264

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### percent less CFM for the same fan, on the test 1 

### stand. So there are instances where a small2 

### diameter fan may move sufficient airflow to move 3 

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

### under the other test metric, it would not qualify 5 

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

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

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

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

### when it comes to legislation. 10 

### In addition, because it produces 15 11 

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

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

### standpoint, which may lead a consumer to pick a 14 

### less-efficient product, simply because of a 15 

### different method of test. 16 

### So our proposal is that all fans less 17 

### than 7 feet in diameter would be tested via 18 

### Energy Star, which is about the limit of what 19 

### that room can realistically test, and then 20 

### anything larger than 7 feet in diameter would be 21 

### tested via AMCA 230. So it's just a straight 2265

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### diameter. Hugger fans would still fall under 1 

### Energy Star test method, and they would be 2 

### defined by 10-inches, and decorative fans would 3 

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

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

### an apples-to-apples comparison for test methods 6 

### and it greatly simplifies that chart. 7 

### MS. ARMSTRONG: Okay. Thank you. Does 8 

### anybody have any feedback or comments to his 9 

### proposal? Support? 10 

### MR. BROOKMAN: Allen. 11 

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

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

### that the small-diameter fans shall be tested per 14 

### the existing Energy Star, solid-state test 15 

### methodology and/or the modified methodology that 16 

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

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

### methodology for 10 years. We have good 19 

### confidence with that test methodology, and it's 20 

### changed to a methodology where I've spoken with 21 

### previous engineers who worked with the load cell 2266

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### and they say it's a very twitchy testing device. 1 

### You have to run multiple tests. 2 

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

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

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

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

### much more expensive than what we're expecting. 7 

### MR. BROOKMAN: Okay. Thank you. 8 

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

### what was just presented by Christian? 10 

### MR. GATTO: Dave Gatto, Westinghouse 11 

### Lighting. I might have gotten it right that 12 

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

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

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

### conversation for us, that testing based on the 16 

### fan diameter, using the same test method for what 17 

### we would consider industrial as well as 18 

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

### provide consistent results and it's going to take 20 

### some confusion out for our internal folks on what 21 

### specific tests we need to do and when. 2267

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### MR. BROOKMAN: Okay. Thank you. 1 

### Christian. 2 

### MR. TABER: One other comment. Christian 3 

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

### fan is very different than the load cell needed 5 

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

### written, two separate load cells, one with enough 7 

### resolution to be able to test the small diameters 8 

### and then one with a different set for the large 9 

### diameter. 10 

### MR. BROOKMAN: Okay. Additional comments 11 

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

### you wish to present? I thought you had some 13 

### slides. 14 

### MR. TABER: This is Christian Taber. I 15 

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

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

### do it all at once. 18 

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

### wanted to figure out. Yes, Bill. 20 

### MR. WALKER: Bill Walker, Hunter Fan. 21 

### So, just a point of clarification, I think what I 2268

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### understood you to say is the two methods don't 1 

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

### that correct? 3 

### MR. TABER: Correct. If you take the 4 

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

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

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

### percent less if you tested it via AMCA 230, 8 

### roughly. That number varies but that's about 9 

### what we see. 10 

### MR. WALKER: That was one of the 11 

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

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

### proposal, what he's proposing. 14 

### MR. BROOKMAN: Okay. Yes, Allen. 15 

### Nathan. 16 

### MR. FRAMPTON: This is Nathan with 17 

### Fanimation. We also agree with Big Ass. 18 

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

### MR. FLANNERY: Tim Flannery, the Minka 20 

### Group. We also agree. 21 

### MR. BROOKMAN: Good. And, of course, 2269

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### these comments you're providing will be very 1 

### helpful to the Department. We're going to 2 

### proceed. 3 

### MS. KANTNER: In the framework document, 4 

### DOE considered establishing a definition for 5 

### hugger ceiling fans, based on the average 6 

### vertical distance between the fan blades and the 7 

### ceiling. In determining an appropriate boundary 8 

### between hugger and standard ceiling fans, an 9 

### analysis was conducted of all ceiling fans 10 

### available from Hansen Wholesale, and online 11 

### wholesaler that sells a wide variety of ceiling 12 

### fan brands. Ninety percent of ceiling fans 13 

### described as hugger fans had blades for which the 14 

### average vertical position was 9 inches or less 15 

### from the ceiling, suggesting that 9 inches might 16 

### be an appropriate threshold. 17 

### By contrast, half of all ceiling fans 18 

### that were described as standard ceiling fans had 19 

### blades for which the average vertical position 20 

### was 12 inches, was within 12 inches of the 21 

### ceiling, suggesting that a higher threshold might 2270

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### result in the categorization of a significant 1 

### number of standard ceiling fans as hugger ceiling 2 

### fans. 3 

### DOE has also determined that a definition 4 

### based on the maximum distance between the blades 5 

### and the ceiling is more appropriate than a 6 

### definition based on the average distance between 7 

### the blades and the ceiling, when considering 8 

### whether or not a ceiling fan is safe to operate 9 

### in a room with a low ceiling. 10 

### Therefore, DOE is proposing to define a 11 

### hugger ceiling fan in terms of the vertical 12 

### distance between the ceiling and the lowest point 13 

### on the fan blades. To account for the additional 14 

### vertical distance between the average vertical 15 

### position of the fan blades and the lowest point 16 

### on the blades, DOE determined that adding 1 inch 17 

### to the vertical distance specified in the 18 

### definition would be appropriate, given the 19 

### typical width and pitch of a fan blade. 20 

### Therefore, DOE is proposing to define a 21 

### hugger ceiling fan as "a ceiling fan where the 2271

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### lowest point on the fan blade is no more than 10 1 

### inches from the ceiling." DOE is also proposing 2 

### a complementary definition for standard ceiling 3 

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

### the fan blades is more than 10 inches from the 5 

### ceiling," and a definition for multi-mount 6 

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

### mounted in both the standard and hugger ceiling 8 

### fan configurations." 9 

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

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

### must be capable of being mounted in both 12 

### configurations that meet DOE's definition of a 13 

### hugger and standard ceiling fan. A ceiling fan 14 

### that can be mounted at more than one height does 15 

### not necessarily qualify as a multi-mount ceiling 16 

### fan to DOE. 17


### MR. BROOKMAN: Dave. 18 

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

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

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

### little bit different, but I understand where DOE 2272

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### is coming with it. My question is, if I have a 1 

### fan that has a downrod that can also be mounted 2 

### close to ceiling, and both distances from the 3 

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

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

### one, or --? 6 

### MS. KANTNER: That will be actually 7 

### clarified later in this presentation. 8 

### MR. GATTO: Okay. Thanks. 9 

### MR. BROOKMAN: Thank you, Colleen. 10 

### MS. ARMSTRONG: But just to clarify here, 11 

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

### standard ceiling fan. 13 

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

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

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

### standard? 17 

### MS. ARMSTRONG: Correct, and then how to 18 

### test a standard fan with multiple options for 19 

### different sized downrods will be what we clarify 20 

### later. But your distances that you said qualify 21 

### it just as a standard, under our proposed 2273

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### definition. 1 

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

### Gatto, Westinghouse. Thank you, Ashley. 3 

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

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

### disagree? Would people do it differently? How 6 

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

### honesty, DOE struggled with this a little bit, 8 

### because as we reviewed literature, we looked at 9 

### your diagrams, we were trying to figure out 10 

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

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

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

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

### inch, if you'd be willing. 15 

### MR. BROOKMAN: Allen. 16 

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

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

### we do this to avoid turbulent airflow into the 19 

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

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

### to vibrate, wobble, make noise. Consumers don't 2274

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### like that, so we tend to make our huggers in the 1 

### 11- and 12-inch range. 2 

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

### a more representative number, for what you're 4 

### calling huggers today? I mean, the intent of 5 

### this is not to completely change what you're 6 

### calling huggers today. The intent was to 7 

### characterize, in a uniform manner, what you guys 8 

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

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

### Let's put it that way. 11 

### MR. BROOKMAN: Tim, first. 12 

### MS. ARMSTRONG: Especially depending on 13 

### where you measure it. 14 

### MR. FLANNERY: Tim Flannery, the Minka 15 

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

### mounts directly to the ceiling without a downrod. 17 

### MS. ARMSTRONG: Hence the difference 18 

### then. 19 

### MR. FLANNERY: Okay. And as far as 20 

### ceiling, distance from ceiling to the blade, we 21 

### go from the top of the blade versus the bottom of 2275

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### the blade. Okay, so we have a variance ratio 1 

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

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

### fans, and maybe you can better clarify that for 4 

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

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

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

### and I'd just kind of like clarification. 8 

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

### sure I understand your question, but the reason 10 

### DOE believes it needs a definition of hugger fan 11 

### is to clarify what a hugger fan actually is. 12 

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

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

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

### to the ceiling, or something along those lines, 16 

### but we want to make sure that comparable 17 

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

### are able to be compared and tested in a 19 

### comparable way. 20 

### So if we're testing huggers in a certain 21 

### way, and that gives you a certain answer, we want 2276

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### to make sure all fans, or all huggers are also 1 

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

### learned in our other regulatory space, we find 3 

### it's easiest based to do it on definitive 4 

### characteristics, rate definitions based on 5 

### definitive characteristics, than intended use, 6 

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

### intended to be used a little differently. 8 

### MR. FLANNERY: Tim Flannery again. So 9 

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

### amount of products that are in the marketplace 11 

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

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

### would really categorize -- the general 14 

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

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

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

### the CFM ratings based on the lowest performer, 18 

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

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

### CFM ratings is very important. When you get into 21 

### your coastal and you get into your tropical 2277

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### areas, the consumer is looking for CFM 1 

### performance. 2 

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

### perspective, we really want to increase our CFMs. 4 

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

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

### because my understanding is that you're going to 7 

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

### where you have an application to hang that lower, 9 

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

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

### that correct? 12 

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

### that if you fall into both categories, hugger and 14 

### standard, you would have to make representations 15 

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

### representations, on your certifications -- 17 

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

### instruction manual? 19 

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

### Hansen, in case Hansen wants to speak, because 21 

### DOE doesn't have any -- FTC has the authority 2278

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### over disclosures and not type for ceiling fans. 1 

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

### in both configurations. You would be testing and 3 

### certifying in both configurations. 4 

### MR. FLANNERY: So if the application 5 

### would be that, your general application would be 6 

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

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

### that in the instruction manual, that the fan is 9 

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

### available in a hugger format, which is at a 11 

### specified CFM rating? Would that be acceptable? 12 

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

### the question. 14 

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

### find a microphone. 16 

### MS. ARMSTRONG: While Hampton moves to 17 

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

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

### proposal here is if something falls into two DOE 20 

### definitions, as different categories of ceiling 21 

### fans, that they have to test and come up with 2279

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### ratings in both configurations. 1 

### So I think the question is, would they 2 

### then be allowed to disclose, on their literature 3 

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

### because they fall into two categories of fans, 5 

### and would get different ratings? Is that fair? 6 

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

### MR. BROOKMAN: Tim, do you want to 8 

### restate the question? 9 

### MR. FLANNERY: My feeling is that, from 10 

### an optimum standpoint, if we're designating the 11 

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

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

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

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

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

### instruction manual, state that as an option you 17 

### can put this fan into a hugger category, which 18 

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

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

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

### MR. BROOKMAN: Hampton. 2280

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### MR. NEWSOME: Well, there are two issues. 1 

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

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

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

### what's the most representative and what is the 5 

### number that allows consumers to make the best 6 

### comparisons with competing products. 7 

### The second question is, well, you know, 8 

### and then it comes up in a lot of different 9 

### contexts. Well, I get all of this information 10 

### about the test procedure, and I want to present 11 

### that to consumers, or regulatory bodies, or 12 

### whatever. So, in that situation, there probably 13 

### wouldn't be any prohibition on you providing that 14 

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

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

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

### clear about what you're presenting, so people 18 

### understand, well, this number comes from this 19 

### particular part of the test, or this represents 20 

### whatever conditions. 21 

### It depends on what you're talking about. 2281

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### You don't want to be in a situation where, 1 

### because you've got different information and 2 

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

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

### sure people understand where it's coming from. 5 

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

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

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

### Thank you. 9 

### MR. BROOKMAN: We have several people who 10 

### wish to comment. 11 

### MS. ARMSTRONG: There's an open seat 12 

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

### [Laughter.] 14 

### MR. BROOKMAN: I guess Christian and then 15 

### to Nathan and then to Marianne. 16 

### MR. TABER: Christian Taber, Big Ass 17 

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

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

### supportive of the way that it currently is, with 20 

### the hugger rating and then the standard rating. 21 

### That seems to make sense. 2282

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### MR. BROOKMAN: As defined? 1 

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

### supportive of the 10-inch height. From our 3 

### research on the fans that we pulled on the 4 

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

### majority of the market, although maybe not 6 

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

### majority of the fans fell into that 10-inch 8 

### distance. 9 

### If the proposed change to testing all 10 

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

### Energy Star, and the false ceiling issue is 12 

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

### then the penalty for a hugger is not as dramatic 14 

### as it currently is. The numbers do drop 15 

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

### would be possible to potentially just eliminate 17 

### the hugger classification entirely. 18 

### MR. BROOKMAN: Nathan. 19 

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

### going to go to, because I think anybody disagrees 21 

### with testing all these categories the same way. 2283

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### So then the question is, would there be a 1 

### different efficiency standard for these 2 

### categories, and if the answer to that question is 3 

### no, then this is almost all irrelevant. 4 

### MR. BROOKMAN: Marianne. 5 

### MS. DIMASCIO: My question was along 6 

### those lines. If the huggers are less efficient, 7 

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

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

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

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

### MR. BROOKMAN: Yeah. I see Nathan, 12 

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

### your heads, both of you. 14 

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

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

### producing less airflow for the same amount of 17 

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

### the efficiency goes down but the wattage stays 19 

### the same, more or less. 20 

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

### consumer getting enough information to make a 2284

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### good choice, with what's on the label and with 1 

### the purchase. 2


### MR. BROOKMAN: Dave. 3 

### MR. GATTO: Dave Gatto, Westinghouse. 4 

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

### think the industry is consistent in defining 6 

### huggers by the mounting configuration. I don't 7 

### disagree with the proposal, but I think that 8 

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

### part of what you ran into when you were looking 10 

### for consistency. 11 

### So, in answer to your question, I think 12 

### this is where Tim and Hampton were talking. If 13 

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

### configuration, but some consumers like to have 15 

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

### shorter distance, or even close to ceiling. 17 

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

### downrod from somebody else and then install it 19 

### with the fan. All of those height changes change 20 

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

### the fan uses, so there's no additional watts 2285

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### used. But that's really application-driven. 1 

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

### definitely be weighing in on how that looks, and 3 

### he's already asked for information from us on 4 

### what the label would look like. The consumer is 5 

### going to have as much information as they need to 6 

### make a good choice, in the intended application. 7 

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

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

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

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

### foot downrod from somebody and hang it from a 12 

### cathedral ceiling, it changes things. But the 13 

### actual watts used don't change at all. 14 

### MR. BROOKMAN: Okay. Additional comments 15 

### related to these proposed definitions? I think 16 

### we haven't gained clarity yet. Christian. 17 

### MR. TABER: Just one quick one. 18 

### Christian Taber, Big Ass Solutions. I think that 19 

### including the information for both would be 20 

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

### the ramifications of their decision to take a 2286

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### multi-mount fan and mount it in a hugger 1 

### configuration, essentially that they would be 2 

### reducing the airflow and the utility of that 3 

### product, in the name of safety or some other 4 

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

### than 10 inches from the ceiling. 6 

### MR. BROOKMAN: Nathan. 7 

### MR. FRAMPTON: Nathan with Fanimation. I 8 

### agree with that. 9 

### MR. BROOKMAN: Allen. 10 

### MR. ROO: Allen with Emerson. The test 11 

### procedure that you're proposing also doesn't 12 

### account for blade warpage, which sometimes does 13 

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

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

### them up there, and they do come back sometimes 16 

### with warped blades, and, therefore, they usually 17 

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

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

### categorized in the wrong category, due to blade 20 

### warpage. I'd like to see something addressed 21 

### that accounts for that. A certain percentage of 2287

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### warpage? I don't know. 1 

### MS. ARMSTRONG: I guess I don't 2 

### understand why that's necessary. If it just 3 

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

### because of shipping or because of -- 5 

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

### MS. ARMSTRONG: The nature of the 7 

### product. 8 

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

### wood does what it wants to sometimes. 10 

### MS. ARMSTRONG: Okay. So are you saying 11 

### then that that happens to the majority of your 12 

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

### MR. ROO: It happens, and random 14 

### sampling, not really previewing the product as we 15 

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

### that. 17 

### MR. BROOKMAN: And that's another reason 18 

### why 10 inches isn't appropriate? 19 

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

### miscategorize a product. 21 

### MR. BROOKMAN: Say that again. What 2288

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### would be -- 1 

### MS. ARMSTRONG: You would be categorizing 2 

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

### which a manufacturer would be responsible for 4 

### declaring what type their product is. I assume 5 

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

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

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

### be. 9 

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

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

### questions, we would come have a conversation with 12 

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

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

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

### blades are definitely warped. Let's look at 16 

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

### necessitates having blade warpage included in the 18 

### definition. 19 

### MR. ROO: Okay. I agree. 20 

### MS. ARMSTRONG: At least in my opinion. 21


### MR. BROOKMAN: Dave. 2289

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### MR. GATTO: Dave Gatto, Westinghouse. 1 

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

### minute. I think this is really the nominal 3 

### versus manufacturing variation. I know you hate 4 

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

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

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

### ceiling. Maybe in natural production sometimes 8 

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

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

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

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

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

### puts the product that a single consumer receives 14 

### into another product class. 15 

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

### DOE has been good about this in the lamp 17 

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

### nominal design is 10 inches or less, and you 19 

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

### said this, as long as what we submitted for 21 

### testing in our design BOM and our drawings say 2290

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### 10, you would work with us. It wouldn't 1 

### immediately become a compliance issue? 2 

### MS. ARMSTRONG: I would say we would 3 

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

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

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

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

### along that line, to acknowledge that there would 8 

### be some variation, either from warpage, from the 9 

### manufacturing line, whatever it is. But something 10 

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

### least meaningful, to provide a clear cutoff. At 12 

### least that's the intent. 13 

### MR. BROOKMAN: David. 14 

### MS. ARMSTRONG: So, can I actually go 15 

### back before -- 16 

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

### close this. 18 

### MS. ARMSTRONG: Do you want to comment on 19 

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

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

### that has to do with, do we have a single test 2291

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### procedure, kind of getting rid of -- a single 1 

### methodology for all types of fans, but still 2 

### allow for disclosure of information about what 3 

### would happen if it's mounted closer to the 4 

### ceiling, and the airflow is impacted but not the 5


### watts? 6 

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

### two different test procedures that give you two 8 

### different numbers, to be able to make that 9 

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

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

### show that differential impact of what would 12 

### happen when the consumer installs them 13 

### differently, because they are installed in 14 

### different configurations and that does impact how 15 

### they operate, by definition, we call that a 16 

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

### there's -- 18 

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

### Christian Taber. Is it a different test 20 

### procedure or is it just a different test? I 21 

### mean, it's the same test procedure. It's just 2292

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### one fan is tested at 3 inches and one is tested 1 

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

### clarify. 3 

### MS. ARMSTRONG: Sure. Yes. I think 4 

### we're talking about the same thing. 5 

### MR. TABER: They just have to run it 6 

### twice. 7 

### MS. ARMSTRONG: Correct. There could be 8 

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

### twice and you could get two numbers out of the 10 

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

### here. I don't know. No? 12 

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

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

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

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

### one, two, three different ways it could be 17 

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

### once, for the different configurations. 19 

### MS. ARMSTRONG: But just setup would be 20 

### different. Mounting would be different. 21 

### MR. FRAMPTON: Right. The downtube would 2293

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### be different. 1 

### MR. BROOKMAN: Yes, David. 2 

### MR. TURNER: Yes. David from Hunter. 3 

### This is more just kind of a point of 4 

### clarification, and maybe it's the names that 5 

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

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

### downrod but the downrod that comes in the box is 8 

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

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

### inch downrod, but the downrod that comes in the 11 

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

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

### That would be classified as a hugger, 14 

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

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

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

### classifying a hugger as completely something 18 

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

### the confusion, and maybe if just took the names 20 

### off. 21 

### MS. ARMSTRONG: Yep. Completely open to 2294

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### suggestions of names. Completely open to A, B, 1 

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

### MR. TURNER: So just not names. Just 3 

### definitions. 4 

### MS. ARMSTRONG: Sure. The intent here, 5 

### though, with this definition, was a definitive 6 

### classification of what you guys called hugger. 7 

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

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

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

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

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

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

### categorization. 14 

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

### issues that we would have with defining it as 16 

### just directly mounted to the ceiling is that, 17 

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

### fans are directly mounted to the ceiling, so even 19 

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

### inch definition, would be classified as a hugger, 21 

### even though the blades would be roughly 16 inches 2295

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### off the ceiling. So it's just a different 1 

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

### would classify as a hugger if we used the direct3 

### mounted definition. 4 

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

### Have we covered definitions now? Are there 6 

### additional comments here. 7 

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

### MS. KANTNER: Up next is the existing 9 

### test procedure. Before proposing test 10 

### procedures, DOE first examines existing test 11 

### procedures. DOE's test procedures for ceiling 12 

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

### CFR Part 430. The current DOE test procedure 14 

### references Energy Star's guidance manual for 15 

### testing ceiling fans, version 1.1, and that 16 

### Energy Star test method is no long current. 17 

### Now let's discuss the proposed metric. 18 

### DOE proposes to apply a single metric based on 19 

### airflow efficiency to all ceiling fans. For low20 

### volume ceiling fans, DOE is proposing to use a 21 

### weighted average of airflow and power consumption 2296

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### at high and low speeds. This is because testing 1 

### at a single speed might limit representativeness 2 

### and testing at two speeds avoids any ambiguity in 3 

### testing ceiling fans with more than three speeds. 4 

### Additionally, testing at three speeds would incur 5 

### more cost burden than testing at two speeds. 6 

### For high-volume ceiling fans, DOE is 7 

### proposing to use the airflow and power 8 

### consumption at high fan speed only. This is 9 

### because high-volume ceiling fans often do not 10 

### have discrete speeds, but rather have a speed 11 

### controller that is continuously adjustable, so 12 

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

### For all ceiling fans with standby 14 

### functionality, and this includes ceiling fans 15 

### with a light kit, DOE is proposing to incorporate 16 

### standby power consumption into the overall 17 

### airflow efficiency metric. 18 

### DOE is not proposing to include off-mode 19 

### power consumption in the metric, because DOE 20 

### believes that ceiling fans do not consume power 21 

### in off-mode. 2297

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### And just to clarify what it is we mean by 1 

### standby, EPCA defines standby mode as the 2 

### condition in which an energy-using product is 3 

### connected to a main power source, and offers one 4 

### or more of the following user-oriented or 5 

### protective functions: to facilitate the 6 

### activation or deactivation of other functions by 7 

### remote switch, internal sensors, or timer; and 8 

### continuous functions, including information or 9 

### status displays, or sensor-based functions. 10 

### And off mode is the condition at which 11 

### the ceiling fan is connected to a main power 12 

### source and is not providing any standby or active 13 

### mode function. 14 

### In the metric for low-volume ceiling 15 

### fans, DOE is proposing to weight the airflow and 16 

### power consumption at high speed and low speed, 17 

### according to the fraction of time spent at each 18 

### speed. DOE considered hours of use data from 19 

### both an AcuPOLL survey and a study conducted by 20 

### LBNL. The AcuPOLL survey asked respondents for 21 

### the single speed at which they typically operated 2298

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### their fan, whereas the LBNL study asked 1 

### respondents for the fraction of time they spent 2 

### at each speed. Because the fraction of time 3 

### spent at each speed is the relevant input in 4 

### determining representative energy consumption for 5 

### a ceiling fan, DOE used the disaggregated data 6 

### set from LBNL. It sounds like there is more 7 

### information, so it would be great to see the 8 

### results of the new study. 9 

### MR. TURNER: David from Hunter. I guess 10 

### that should just be part of our written comment, 11 

### and then it would be considered -- okay. 12 

### MS. KANTNER: Definitely. 13 

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

### MS. KANTNER: For high-volume ceiling 15 

### fans, limited data were available, so DOE used 16 

### feedback from manufacturers, indicating that 17 

### while the hours of operation may vary 18 

### significantly across industry and application, 12 19 

### hours per day spent in active mode may be a 20 

### representative value, and DOE welcomes any 21 

### available data on operating hours for high-volume 2299

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### ceiling fans. 1 

### This table summarizes the hours of use 2 

### weights DOE is proposing to use in the ceiling 3 

### fan metric. Note that for ceiling fans with 4 

### standby functionality, DOE assumes that the 5 

### ceiling fan is always activated remotely, and 6 

### thus is never in off-mode. 7 

### And here is the equation, the efficiency 8 

### equation for the metric. The top equation shows 9 

### the efficiency metric for low-volume ceiling 10 

### fans, where the numerator is the product of 11 

### airflow and operating hours, summed over high and 12 

### low speed, and the denominator is the product of 13 

### standby power consumption and standby operating 14 

### hours, added to the product of power consumption 15 

### and operating hours, again, summed over high and 16 

### low speeds. 17 

### The bottom equation shows the efficiency 18 

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

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

### except that only airflow and power consumption at 21 

### high speed are included. 22100

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### And now we have some issues for comment. 1 

### DOE seeks comment on its proposed approach to 2 

### incorporate standby power consumption into the 3 

### efficiency metric for ceiling fans. 4


### MR. BROOKMAN: Dave. 5 

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

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

### Westinghouse Lighting. We agree. 8 

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

### MR. TURNER: Dave Turner. I guess we 10 

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


### agree. 12 

### MR. BROOKMAN: Okay. Thank you. 13 

### Affirmation is very useful. Thank you. Allen? 14 

### Christian? Allen. 15 

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

### MR. BROOKMAN: Thank you. Christian. 17 

### MR. TABER: Christian Taber, Big Ass 18 

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

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

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

### Generally speaking, we agree that standby energy 22101

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### should be included -- it's the absolute last 1 

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

### necessarily a negative or something else. It's 3 

### just to beware of the ramifications. 4 

### The inclusion of standby losses, in the 5 

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

### minimally efficient fan, an 84 CFM per watt at 7 

### high speed current fan, and you used the proposed 8 

### metric, including high speed, low speed, and 9 

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


### watt. 11 

### If you take a high efficiency fan, where 12 

### the overall power consumption of the fan is 13 

### dramatically less, which makes standby 14 

### proportionally larger piece of the pie, that fan 15 

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

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

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

### fairly wide spread for the apples-to-apples 19 

### comparison, just dramatically decreases, and high 20 

### efficiency products actually become a lower CFM 21 

### per watt. So it's not necessarily bad. It's 22102

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### just to be aware that it's compressing the 1 

### difference between the perceived efficiency of a 2 

### minimum and a perceived efficiency of a high. So 3 

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

### just different. 5 

### MS. KANTNER: Is there a suggestion about 6 

### another way to handle this? 7 

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

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

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

### when we started running the numbers on some of 11 

### the premium efficiency products we had, their CFM 12 

### per watts were dropping dramatically, and it was 13 

### penalizing them, while the minimum efficiency 14 

### products were actually seeing bumps up. 15 

### MR. BROOKMAN: Interesting. Additional 16 

### comments on standby power consumption? 17 

### Thank you. Back to Colleen. 18 

### MS. KANTNER: So the next item for 19 

### comment is DOE seeks comment on its proposed 20 

### approach to assign all standby power consumption 21 

### for a remote receive that controls both a ceiling 22103

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### fan and a light kit to the ceiling fan. 1 

### MR. BROOKMAN: Christian. 2 

### MR. TABER: Christian Taber, Big Ass 3 

### Fans. We agree with that. 4 

### MR. BROOKMAN: Okay. Other members that 5 

### agree with that? Dave. 6 

### MR. GATTO: Westinghouse Lighting. We 7 

### agree with that. 8 

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

### Colleen. 10 

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


### comments. 12 

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

### comments, as well. Bill. 14 

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

### MR. BROOKMAN: Thank you. 16 

### MS. KANTNER: I think we discussed the 17 

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

### a comment on the proposed operating hours for 19 

### calculating ceiling fan efficiency for low-volume 20 

### ceiling fans? 21 

### MR. BROOKMAN: Marianne. 22104

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### MS. DIMASCIO: I just have a comment. I 1 

### wondered if Dave of Hunter could share on the 2 

### daily operating hours for low-volume ceiling 3 

### fans, just the basic numbers that you would put 4 

### in there, so we would have that information. 5 

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

### that close to your face, please? 7 

### MR. TURNER: David Turner at Hunter. The 8 

### question was asked, very similar to the LBNL 9 

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

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

### down to third-most, so there are varying 12 

### percentages. We'll provide this in the 13 

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

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

### we can throw out a summary in our written 16 

### comments, but that's the raw data. 17 

### MR. BROOKMAN: Do we have additional 18 

### comments on operating hours? Christian? 19 

### MR. TABER: I actually have a slide for 20 

### this. I'm sorry. 21 

### MS. ARMSTRONG: I also have a public 22105

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### meeting on Friday, in case you want to come and 1 

### present for me. 2 

### [Laughter.] 3 

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

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

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

### When we looked at the LBNL study in more 7 

### detail, we noticed that essentially medium and 8 

### high were within 4 percent of each other. LBNL 9 

### did not publish confidence intervals for those 10 

### numbers, so we could not tell if they were 11 

### statistically significant in their difference, 12 

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

### justified the use of high, especially given that 14 

### all of the other studies provided by all of the 15 

### manufacturers showed that medium was more 16 

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

### Do we want to go into the -- 18 

### MS. KANTNER: Can you clarify what you 19 

### mean by using high? 20 

### MR. TABER: Using high as the basis of 21 

### the metric. 22106

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### MS. KANTNER: I mean, the reason for the 1 

### high-volume fans was just a definitional issue, 2


### not -- 3 

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

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

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

### than high, due to the variable frequency drives, 7 

### or variable speed nature of the product. 8 

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

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

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

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

### The issue we have with using high speed as the 13 

### basis of rating is that it does not create an 14 

### equal comparison. It would be the equivalent of 15 

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

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

### To get a true efficiency comparison, we 18 

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

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

### would be, and then making the manufacturer use 21 

### their closest operating speed that exceeds that 22107

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### number, somewhat similar to the way that Energy 1 

### Star works right now for high speed. That would 2 

### give a fair comparison for efficiency to perform 3 

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

### many watts, which would be a fair efficiency 5 

### comparison, versus forcing a fan that may produce 6 

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

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

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

### comparison for true efficiency of, to perform the 10 

### given task. Next slide. 11 

### We just noted the potential way that you 12 

### could gain the current metric would be to take 13 

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

### speed, to remove the top operating speed on that 15 

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

### You would decrease the CFM rating but you would 17 

### take a closer to minimally compliant product and 18 

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

### simply by reducing the product's functionality. 20 

### MS. KANTNER: Is there a recommended CFM 21 

### at which you would test? 22108

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### MR. TABER: It depends on which one we're 1 

### talking about. Under the existing Energy Star 2 

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

### for high speed. We would propose using that 4 

### number. Under the new metric, that would 5 

### obviously have to be changed to whatever impacts 6 

### that would have. 7 

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

### have a question with what you proposed. So, 9 

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

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

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

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

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

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

### the consumer actually is going to use it at 16 

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

### representation on the label, then, gets murky. 18 

### I understand your comparison in the test, 19 

### but -- 20 

### MR. TABER: Ceiling fans are essentially 21 

### operated to keep people comfortable, and so if 22109

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### you have two fans that have two different 1 

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

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

### provide a specific airflow. So, in a warm 4 

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

### theoretically, would provide equal comfort. So 6 

### they would likely be running them, one at the 7 

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

### speed that gives 3,000. 9 

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

### hard to really say it well, but I think 11 

### efficiency defined as the same amount of work 12 

### being done using a specific amount of power is 13 

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

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

### fuel efficient than high speed for a Prius. In 16 

### reality, when the person drives that car, the 17 

### Prius is going to consume much less gas. 18 

### MR. CYMBALSKY: I guess from the 19 

### consumer's perspective, if the consumer knows 20 

### what is the maximum wattage this thing is going 21 

### to draw, and you do it that way -- 22110

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### MR. TABER: But I don't think most 1 

### consumers run their ceiling fan based on power 2 

### usage. They run it off of what makes them 3 

### comfortable. 4 

### MR. CYMBALSKY: Right. But theoretically 5 

### they could, and this goes back to the downrod 6 

### example. You said exactly what I was going to 7 

### say in response to the downrod example, that you 8 

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

### adjust the speed to get the same level of airflow 10 

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

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

### case, as well. 13 

### MR. BROOKMAN: Nathan. 14 

### MR. FRAMPTON: This is Nathan with 15 

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

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

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

### example is on base. 19 

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

### MR. GATTO: Dave Gatto with Westinghouse. 21 

### Christian, I may ultimately agree with you but I 22111

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### haven't had time to really think that through. 1 

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

### seen so far, partly because I know FTC would 3 

### probably weigh in. The primary value to the 4 

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

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

### prior dialog with DOE. 7 

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

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

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

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

### people just put their fan on high and they 12 

### complain that they're cold. 13 

### [Laughter.] 14 

### MR. GATTO: So whenever you get into 15 

### consumer experience, I get really nervous when 16 

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

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

### bigger fear would be, what would the test 19 

### procedure look like with a fan that has three 20 

### fixed speeds, versus variable speed. So now you 21 

### might find that a fan that is at 4,990, at 22112

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### medium, and 6,900 at high, but uses 30 percent 1 

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

### disadvantage, medium to medium, from somebody who 3 

### is at 5,001 at medium. 4 

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

### the test procedure would look like, because that 6 

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

### hitting the CFM. So, that seems overly 8 

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

### understanding where you're at. 10 

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

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

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

### that. 14 

### MR. GATTO: Specifically to qualify for 15 

### Energy Star? 16 

### MR. TABER: Right. 17 

### MR. GATTO: But for the Energy Star test 18 

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

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

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

### a changing the Energy Star test procedure to 22113

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### qualify for Energy Star, I'd probably be more in 1 

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

### there's a reason that I'm going down that path to 3 

### qualify. But this is, for Westinghouse, anyway, 4 

### this is more about what am I going to have to do 5 

### for every fan that we manufacture, and what 6 

### information do consumers need to know about it, 7 

### that's also not going to run into a disclosure 8 

### issue with FTC, where I think if we landed on 9 

### we're only going to disclose medium, there would 10 

### be pushback there. 11 

### Because the actual potential consumer 12 

### experience might be higher than what we publish, 13 

### which is something that came up in the earlier 14 

### discussion, when the EnergyGuide labels were 15 

### first established, that there was a very -- and 16 

### we agree with it, wherever you are, Hampton -- 17 

### there's a very legitimate concern on FTC's part, 18 

### that because a consumer could use it at high, 19 

### they need to make the proper choice, that 20 

### Marianne was talking about. They need to know 21 

### what their cost would be at high. 22114

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### MR. TABER: Right, but the blended rate 1 

### that's being proposed wouldn't provide that. 2 

### MR. GATTO: I agree with you, but we had 3 

### earlier discussions where there was a point where 4 

### we leaning towards publishing all three on the 5 

### label. 6 

### MR. TABER: Which I think we would 7 

### support. 8 

### MR. GATTO: Yeah, and I think FTC's 9 

### position was -- and I don't want to speak for 10 

### you, but you even said it earlier -- but I think 11 

### part of what we heard back was that multiple 12 

### points of information are too confusing. 13 

### But I'm with you. We were in a place 14 

### where, if we could disclose all three -- which, 15 

### for a while we were doing, for California -- at 16 

### least the consumer has that ability to choose, 17 

### and compare the Prius to the Porsche. I think 18 

### the challenge we have is that knowing the path 19 

### that we've already gone down with the EnergyGuide 20 

### label, this would be either a concern for FTC or 21 

### more confusing to the consumer than we would want 22115

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### it to be, if that makes sense. 1 

### MR. TABER: My concern would be that if I 2 

### can take a fan and just de-rate it to the point 3 

### that it becomes premium efficiency, I decrease 4 

### the usefulness of the product to the end 5 

### consumer. They're going to rely more heavily on 6 

### air conditioning than on ceiling fans, because 7 

### the ceiling fan no longer functions. 8 

### MR. GATTO: I don't know what to say to 9 

### that -- Dave Gatto, Westinghouse -- other than 10 

### that hasn't happened yet, and this is a pretty 11 

### mature category. So not that there isn't an 12 

### efficiency standard, but in the absence of an 13 

### efficiency standard, that hasn't happened. I 14 

### can't really see. 15 

### I'm not saying that -- I know DOE's 16 

### experience has been that products tend to, over 17 

### time, drift towards the minimum efficiency level, 18 

### but if the minimum efficiency level is above the 19 

### bar that it is today, I don't have a concern 20 

### about that. And consumers, they choose with 21 

### their pocketbook. If they find a brand or a 22116

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### product that is not delivering what they want, 1 

### especially with Internet comments, then that fan 2 

### won't be around very long. 3 

### MR. BROOKMAN: Nathan, do you have a 4 

### comment here? Allen? 5 

### MR. ROO: Allen with Emerson. Currently, 6 

### with the current FTC label, consumers look at the 7 

### CFM value more than they do the efficiency value. 8 

### With the proposed combined efficiency value, I 9 

### know they're totally going to be confused. They 10 

### won't understand it, other than to look at one 11 

### fan and another and say, "Well, this is cheaper 12 

### to operate." They want to know CFM. 13 

### Will the new label include both CFM and 14 

### the combined efficiency? 15 

### MR. BROOKMAN: Hampton. 16 

### MR. NEWSOME: Hampton Newsome, FTC. Our 17 

### current proposal doesn't, because we don't have 18 

### that information yet. DOE hasn't made decisions 19 

### about it. We didn't propose anything like that. 20 

### Under the new label, the primary disclosure is 21 

### operating cost, and then CFM will be there, and 22117

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### then the efficiency rating, which is probably 1 

### less useful to the typical consumer, will be 2 

### there, but it won't be that prominent. In terms 3 

### of getting into the nuances of different 4 

### efficiency ratings, that's not something that 5 

### we've gone into. 6 

### Obviously, the label -- just to back up a 7 

### little bit, one of the general principles we work 8 

### under -- and, obviously, everything I'm saying 9 

### here, I'm speaking as an FTC staffer. I'm not 10 

### speaking for the Commission. Generally, when 11 

### we're designing labels, we want to make them 12 

### simple, we want to make sure that the information 13 

### allows consumers to compare competing product, 14 

### and if there are key assumptions that are behind 15 

### the label, of electricity rate, hours of use, 16 

### what have you, we want to put that on the label, 17 

### but we don't want to freight the label down with 18 

### so much information that consumers might just 19 

### tune it out. So it's kind of a balancing act 20 

### that we're working on. 21 

### MR. BROOKMAN: Okay. Thank you. Yes, 22118

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### Dick. 1 

### MR. UPTON: Hampton, thank you. Will the 2 

### consumer -- do you have a problem in putting all 3 

### three speeds on the box? 4 

### MR. NEWSOME: That was proposed in 5 

### comments, so that we haven't resolved that issue. 6 

### In the original rulemaking, as was mentioned 7 

### before -- this was, what, 8 or 9 years ago -- I 8 

### believe that was discussed, and for the reasons 9 

### that were mentioned earlier, we went with just 10 

### that high speed. 11 

### I believe another issue was the question 12 

### of, if you were trying to put multiple speeds, 13 

### whether all models had multiple speeds, and how 14 

### that would be reflected in the label. That was 15 

### another issue. 16 

### But the answer to your question is that 17 

### that issue is kind of on the table. 18 

### MR. UPTON: Thank you. One of the things 19 

### we pointed out to Hampton was our labeling 20 

### ability on a ceiling fan box is not the same as 21 

### the labeling ability on a refrigerator. That's 22119

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### something we have to wrestle around with, too, 1 

### because it makes a significant different to 2 

### manufacturers, in being able to do that label and 3 

### hopefully have it for one time. Because if 4 

### you're talking about redoing and redoing, that 5 

### becomes doggone expensive for us, as well. 6 

### MR. BROOKMAN: Okay. Let's deal with 7 

### operating hours for high volume ceiling fans. 8 

### Additional comments on comment, Issue Number 8? 9 

### Christian. 10 

### MR. TABER: As the only high-volume fan 11 

### manufacturer present, at least large diameter -- 12 

### so the rating would be for 12 hours of operation 13 

### at high speed, would be the FTC label number? 14 

### That would be the annual power and energy? Is 15 

### that right? Or would it be the -- because the 16 

### math in the TSD was very different. It had a 17 

### certain number of hours at certain speeds. It 18 

### was very -- it was different than 12 hours at 19 

### high speed, 365 days a year. 20 

### MR. BROOKMAN: Do you remember? 21 

### MS. ARMSTRONG: It would be whatever is 22120

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### coming out of the test procedure, not 1 

### necessarily. 2 

### MR. TABER: So that would be 12 hours a 3 

### day? So, I would say that represents a very 4 

### worst case scenario. For 6 month of the year, 5 

### average climate, most of the fans are running at 6 

### about 30 to 25 percent of maximum RPM, which, 7 

### with fan laws, puts it around 10 percent of 8 

### maximum power. So we would be provided a very, 9 

### let's say, conservative estimate of their annual 10 

### power consumption. 11 

### MR. BROOKMAN: That added data would be 12 

### very useful -- 13 

### MS. ARMSTRONG: Agreed. 14 

### MR. BROOKMAN: -- for the Department. 15 

### MR. TABER: We've submitted that already. 16 

### MR. BROOKMAN: Okay. Thank you. 17 

### Additional thoughts on operating hours for high18 

### volume? No? 19 

### I think we're due for a break. Yes. 20 

### It's now 11 o'clock. Let's not tarry here. 21 

### Let's get back here at 11:15. So we'll start 22121

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### crisply at 11:15. 1 

### We've had a really good start on the day. 2 

### We've covered a lot of ground, a very useful 3 

### discussion. We'll continue that when we resume 4 

### at 11:15. 5 

### [Recess taken from 11:02 to 11:21 a.m.] 6 

### MR. BROOKMAN: Let's resume. Okay, 7 

### Ashley Armstrong to lead off. 8 

### MS. ARMSTRONG: So, a couple of things. 9 

### One is, we did get some feedback that a lot of 10 

### you decided that you love spending so much time 11 

### with the Department that you have flights, that 12 

### you need to get out of here by about three-ish. 13 

### So we're going to start, kind of, breezing 14 

### through some of this stuff. Now, that's not to 15 

### mention -- please feel free to stop us. Please 16 

### feel free to chime in. 17 

### Some of these slides I may just skip 18 

### because, it's not that they're not important, but 19 

### they're in your packet. Take them home. If you 20 

### have questions, we can engage in a conversation 21 

### after this or we welcome your comments, but there 22122

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### are certain things that we would definitely like 1 

### to tee up for discussion points, that, in my 2 

### opinion, are more important than probably others, 3 

### at least for us to have a discussion around. 4 

### That's not to say that everything is not 5 

### important for feedback on, as part of your 6 

### written comments, or an afternoon dialog. Okay? 7 

### MR. BROOKMAN: And, of course, if it's 8 

### important to you, we want to hear it. Right? 9 

### Okay. So we're going to proceed. 10 

### MS. KANTNER: We're just going to move 11 

### quickly through the proposed modifications to the 12 

### current test procedure. DOE proposes to modify 13 

### the current test procedure for ceiling fans to 14 

### address the following issues... We'll just go 15 

### through these on the slides anyway. 16 

### First, DOE proposes to require testing at 17 

### high and low fan speeds, for low-volume ceiling 18 

### fans. I think we already discussed this. 19 

### DOE proposes to eliminate the requirement 20 

### to test with a test cylinder. 21 

### MR. BROOKMAN: That's perhaps a little 22123

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### too fast. Bill. But that was fast. 1 

### MR. WALKER: That was real fast. 2 

### [Laughter.] 3 

### MR. WALKER: So the new testing method 4 

### you're proposing, it would do away with the 5 

### current Energy Star test method. Correct? 6


### MS. ARMSTRONG: Correct. 7 

### MR. WALKER: Okay. So then there will be -- 8 

### you're testing at two speeds. 9 

### MS. ARMSTRONG: The proposal is two 10 

### speeds. 11 

### MR. WALKER: Yeah, high and low, at two 12 

### speeds. What's the spec for what is Energy Star 13 

### and what's not Energy Star, at this point? 14 

### MS. ARMSTRONG: I think this is what we 15 

### addressed earlier. At the conclusion of this 16 

### process, in terms of once we make the final 17 

### decisions about the test procedure, what speeds, 18 

### how we test, once we get that squared away, in 19 

### terms of what the actual ratings will look like, 20 

### Energy Star will then initiate a process to 21 

### revise their spec. I'm sure they will engage 22124

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### with all of you about what those new levels 1 

### should look like, and what will and will not be 2 

### Energy Star. 3 

### So this will go first, followed quickly 4 

### by that. Amazingly enough, DOE and EPA do talk 5 

### pretty regularly. 6 

### MS. KANTNER: Any comments on the 7 

### elimination of the requirement to test with a 8 

### test cylinder? 9 

### MS. ARMSTRONG: So -- go ahead. I do 10 

### want feedback on this one. 11 

### MR. BROOKMAN: Christian has a comment, 12 

### and then we'll pick up others. 13 

### MR. TABER: Christian Taber, Big Ass 14 

### Solutions. We ran tests with and without in our 15 

### lab and we did not see a significant difference, 16 

### so we're completely supportive of the elimination 17 

### of the cylinder. 18 

### MR. WALKER: Bill with Hunter. We 19 

### supplied data, from the last meeting, that I 20 

### think I ran 30 tests or something. 21 

### MR. BROOKMAN: And, as a consequence, do 22125

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### you support this, or not? 1 

### MR. WALKER: Do we support it? 2 

### MS. KANTNER: I think you suggested it. 3 

### MR. WALKER: Oh, absolutely. 4 

### MR. BROOKMAN: Thank you. Nathan. 5 

### MR. FRAMPTON: Nathan with Fanimation. 6 

### We also support this. 7 

### MR. BROOKMAN: Okay. Thank you. Okay. 8 

### Then we're moving on. 9 

### MS. KANTNER: DOE proposes to test all 10 

### low-volume ceiling fans with the addition of a 11 

### false ceiling directly above the ceiling fan. 12 

### MR. BROOKMAN: Yes, Christian. 13 

### MR. TABER: I'm sorry. This is the last 14 

### PowerPoint slide. Christian Taber. Big Ass 15 

### Solutions. We did a lot of testing regarding the 16 

### addition of false ceiling for all ceiling fans. 17 

### So, in our testing, we found that there was a 18 

### decrease in performance that was achieved, due to 19 

### the false ceiling, as well as the fan blades 20 

### becoming closer to the ceiling, so we are 21 

### supportive of the test procedure being more 22126

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### representative of a home installation. I'm 1 

### unaware of any home installations where there's a 2 

### false ceiling that's 8 inches larger than the fan 3 

### diameter, so we propose that rather than mounting 4 

### to a false ceiling that is slightly larger than 5 

### the fan, that the fan be mounted to the ceiling. 6 

### The false ceiling basically blocks 7 

### incoming airflow of the recirculation of the air, 8 

### and about one-third of the reduction in the 30- 9 

### to-50 percent performance drop that would be 10 

### witnessed with the new test, as DOE noted, about 11 

### one-third of that is due to the fact that the 12 

### blades are closer to the false ceiling or the 13 

### actual ceiling. Two-thirds of it is due to the 14 

### fact that the airflow is not allowed to reenter 15 

### the top of the fan. It's blocked by the false 16 

### ceiling, and essentially the fan has to start 17 

### anew each time it starts to move air. So that 18 

### decrease in performance is not representative of 19 

### the real world, and it's unnecessary. 20 

### MS. KANTNER: I think I can explain why 21 

### it was that we did it this way. We wanted to 22127

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### maintain a consistent distance between the fan 1 

### blades and the air velocity sensors, and you 2 

### can't change the height of the air velocity 3 

### sensors easily, so the only option was the fan. 4 

### MR. TABER: Go to the next slide. So 5 

### when we changed the height of the air velocity 6 

### sensors, on the right-hand side we saw data that 7 

### was consistent. The red line is a standard 8 

### ceiling fan mounted according to the current 9 

### Energy Star. That gave the highest CFM and the 10 

### highest CFM per watt. 11 

### When we then moved that fan up to its 12 

### actual standard mounting configuration and then 13 

### used the same actuator device to just raise the 14 

### sensor height, we got a decrease in performance 15 

### that was very logical, and then, when we moved 16 

### that into a hugger-type configuration, we saw 17 

### another proportional and logical decrease in 18 

### performance. That's the right-hand side. 19 

### On the left-hand side, when we performed 20 

### the same tests, we did not see nearly the same 21 

### proportional decreases. There was a lot more 22128

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### noisiness in the numbers and the data became 1 

### skewed, so that it was much harder to tell what 2 

### was going on. So, by raising the sensor heights 3 

### and keeping that distance consistent, instead of 4 

### varying the ceiling height, which was awkward, as 5 

### well, and time-consuming, from a testing 6 

### standpoint, we got much better and more 7 

### consistent data. 8 

### So we would propose mounting the fan to 9 

### the ceiling, as it would be installed in the real 10 

### world, and then adjusting the sensor height, 11 

### rather than the false ceiling height, to account 12 

### for that. 13 

### MR. WALKER: Bill with Hunter. So you're 14 

### saying keep the sensor-to-blade height the same, 15 

### but adjust the test figure. 16 

### MR. TABER: Exactly as DOE proposes. You 17 

### just adjust the sensors up and down, based on 18 

### where the fan is, and that way you're testing the 19 

### fan mounted to a ceiling, like it really would be 20 

### installed. 21 

### MS. ARMSTRONG: So I agree, disagree. We 22129

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### did get some feedback, originally, that there 1 

### were some concerns mounting to the ceiling, so I 2 

### would be interesting in hearing. 3 

### MR. FRAMPTON: This is Nathan with 4 

### Fanimation. I 100 percent agree. 5 

### MR. BROOKMAN: Thank you. 6 

### MS. ARMSTRONG: Okay. 7 

### MR. BROOKMAN: Okay. Any other comments 8 

### -- and, of course, a few written comments, also. 9 

### Yes, Tim. 10 

### MR. FLANNERY: I have a question, and I 11 

### agree with the ceiling, as well, but is there any 12 

### other requirements, as far as the room, i.e., 13 

### size, openness, doors, closed doors? 14 

### MR. BROOKMAN: Christian. 15 

### MR. TABER: Christian Taber, Big Ass 16 

### Solutions. We kept the exact same Energy Star 17 

### setup that we had -- closed doors, air 18 

### conditioning off, 20x20x11, roughly. The only 19 

### thing we changed was the elimination of the false 20 

### ceiling. 21 

### MR. FLANNERY: So will there be a 22130

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### requirement for actually rooms, so everybody is 1 

### on a level playing field? Will there be a 2 

### requirement as far as room size and application, 3 

### whether it's 20x20 -- obviously, ceiling height 4 

### is determined -- but do we all have to have 5 

### testing in the same environment, because there 6 

### are a number of factories here that are large 7 

### enough, that are doing their own independent 8 

### testing. So will there need to be a requirement 9 

### for that? 10 

### MR. TABER: I believe there's already a 11 

### requirement, well, at least in the Energy Star 12 

### test procedure, for room size. It's 20x20x11, 13 

### with maybe a 6-inch variance either way. I don't 14 

### remember the specifics. 15 

### MR. FLANNERY: Okay. I was not aware of 16 

### that. Okay. 17 

### MS. KANTNER: I was wondering if the Hunter Fan 18 

### folks could comment on how hard or how expensive 19 

### it would be to change the air velocity sensor 20 

### height versus the ceiling fan height. 21 

### MR. WALKER: Bill with Hunter. Are you 22131

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### asking how hard it will be? It will take some 1 

### design work. We do our sensors a little 2 

### different. If you look on the Energy Star 3 

### website, that's our lab in those pictures, so 4 

### instead of using one array and rotating it, we 5 

### use four, so it will be a little bit more 6 

### cumbersome to do that. 7 

### MR. BROOKMAN: Christian. 8 

### MR. TABER: Christian Taber, Big Ass 9 

### Fans. That's actually the exact setup we have, 10 

### as well as the four axes. We don't do the 11 

### rotation. We found that the drop ceiling, 12 

### specifically moving it up and down and keeping it 13 

### level, especially when trying to test odd-shaped 14 

### fans, it was very cumbersome to try to keep that 15 

### in the same position, and level and flat, and it 16 

### was much easier to just change the sensors. 17 

### MS. KANTNER: Next, DOE proposes to 18 

### define the vertical position of a ceiling fan 19 

### with respect to the distance between the lowest 20 

### point on the ceiling fan blades and the heads at 21 

### air velocity sensors. Any comments on that? 22132

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### MR. BROOKMAN: Comments here on these? 1 

### Christian. 2 

### MR. TABER: Christian Taber, Big Ass 3 

### Fans. We're supportive of this. 4 

### MR. BROOKMAN: Okay. Thank you. 5 

### Additional comments? Additional comments before 6



### we move on. 7 

### MS. KANTNER: Next, and I think this 8 

### addresses an issue that came up earlier. DOE 9 

### proposes to clarify that if there is more than 10 

### one mounting option specified by the manufacturer 11 

### that would meet the definition of a standard, 12 

### low-volume ceiling fan, that ceiling fan should 13 

### be tested in the configuration that minimizes the 14 

### distance between the ceiling and the lowest part 15 

### of the fan blades, and a similar clarification is 16 

### proposed for hugger fans. 17 

### MR. BROOKMAN: Yes, Dave. 18 

### MR. GATTO: Dave Gatto, Westinghouse 19 

### Lighting. We're in agreement with this. I think 20 

### the only question would be, or maybe a piece of 21 

### information for DOE, is that -- and I understand 22133

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### that the reason for this is so that the least1 

### efficient configuration is the one that's tested 2 

### and certified, which makes perfect sense to me. 3 

### However, from a marketing standpoint, if we don't 4 

### have the ability to show both ways, then it 5 

### potentially would mean we would remove utility, 6 

### because we remove the option. 7 

### It sounds a little silly, I know, but I 8 

### just want you guys to be aware that it 9 

### potentially would mean that we wouldn't, at least 10 

### for Westinghouse, we wouldn't necessarily include 11 

### the option to change height from ceiling, which 12 

### is a consumer utility that you're not really 13 

### directly affecting, but this could cause us to 14 

### choose not to include it. 15 

### MS. ARMSTRONG: So is your ask that you 16 

### be allowed to test in other ways, like, this is, 17 

### at the very least, what you have to do, but you 18 

### want the ability to test that at other heights, 19 

### and potentially certify them as different basic 20 

### models? Or what is the ask? 21 

### MR. GATTO: So, it's interesting. Dave 22134

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### Gatto, Westinghouse Lighting. I don't know if 1 

### the ask is for you. It might end up being an FTC 2 

### conversation, about what we can publish. Partly 3 

### why I don't have an objection to this is because 4 

### it will be an even playing field for everyone. 5 

### We're all going to have the same results for the 6 

### same performing fans. 7 

### But when we start certifying data and 8 

### there's an efficiency standard, there are rules 9 

### around what we can claim outside of the 10 

### certification database. So I'm just not sure if 11 

### there's clarification you can give now, or if 12 

### that's something that you've considered that, in 13 

### the absence of clarification, we might publish 14 

### information that then would be slightly 15 

### different, because of the application, than 16 

### what's in the database. 17 

### MS. ARMSTRONG: So, I think that's a 18 

### question specifically for Hampton, but I think, 19 

### when you submit comments, think about it, because 20 

### if DOE's test procedure requires testing in a 21 

### specific configuration that's prohibiting testing 22135

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### in other configurations, to the extent you do 1 

### wish to be allowed to test in other 2 

### configurations, we would need to know that, as 3 

### part of the test procedure, not just 4 

### representations. 5 

### MR. GATTO: Okay. Thank you. 6 

### MR. BROOKMAN: Okay. We're moving on. 7 

### Oh, David. 8 

### MR. TURNER: David with Hunter. So if a 9 

### fan qualifies as multi-mount, meaning standard 10 

### and hugger, it would need to meet the efficiency 11 

### metric, as defined for hugger and standard. Is 12 

### that correct? 13


### MS. ARMSTRONG: Yes. 14 

### MR. TURNER: Okay. I wanted to clarify. 15 

### MS. KANTNER: DOE proposes to clarify 16 

### that during testing, any heater package with the 17 

### ceiling fans should be installed in case it might 18 

### affect airflow, but the heater should be switched 19 

### off. 20 

### MR. BROOKMAN: Comments on this? 21 

### MR. TURNER: Hunter agrees. 22136

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### MR. BROOKMAN: Hunter agrees. Okay. 1 

### Thank you. That was David. Additional thoughts, 2 

### comments? Okay. Moving on. 3 

### MS. KANTNER: DOE proposes to change the 4 

### sensor tolerance from the current test procedure 5 

### value of 1 percent to 5 percent. 6 

### MR. WALKER: Bill with Hunter. The 7 

### current Energy Star test method has 5 percent in 8 

### there, version 1.2, I think it is. 9 

### MR. BROOKMAN: Okay. So you're 10 

### supportive of this? Yes. 11 

### MR. WALKER: And I think this will 12 

### probably come later. There has to be some sort 13 

### of round-robin testing, though, between the labs, 14 

### to make sure all the labs correlate. It's out of 15 

### hand right now. 16 

### MR. BROOKMAN: Okay. Thanks for that. 17 

### MS. ARMSTRONG: I will mention, just with 18 

### that introduction, DOE has been engaging a 19 

### variety of different industries to do round-robin 20 

### testing. We would be interested in setting 21 

### something up with all of you, if you would be 22137

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### willing. 1 

### MR. TABER: We would be supportive of 2 

### that. Christian Taber, Big Ass Fans. 3 

### MR. BROOKMAN: Okay. Thank you. Thanks 4 

### to both of you. Okay. 5 

### MS. KANTNER: And now let's move on to 6 

### the proposed additional test methods, and we'll 7 

### go through these one by one anyway. 8 

### DOE proposes to test low-volume, multi9 

### mount ceiling fans in two configurations, in the 10 

### standard configuration and in the hugger 11 

### configuration, and in both cases it's the 12 

### configuration that minimizes the distance between 13 

### the ceiling and lowest part of the fan blades 14 

### that meets the definition for that configuration. 15 

### Any comments? 16 

### MR. BROOKMAN: Thoughts on this? 17 

### Comments? Bill. No. Okay. I guess there's no 18


### comments. 19 

### MS. KANTNER: DOE proposes to measure 20 

### airflow of multi-headed fans by testing a single 21 

### fan head, with that fan head in the same position 22138

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### as the fan head is in when it's just a single fan 1 

### head being tested, such that it is directly over 2 

### the central sensor. 3 

### MR. FRAMPTON: This is Nathan with 4 

### Fanimation. We agree. 5 

### MR. BROOKMAN: Okay. Thank you. 6 

### MS. KANTNER: DOE proposes to measure 7 

### power consumption of multi-headed ceiling fans at 8 

### a given speed with all ceiling fan heads turned 9



### on. 10 

### MR. BROOKMAN: Nathan. 11 

### MR. FRAMPTON: Nathan with Fanimation. We 12


### agree. 13 

### MR. BROOKMAN: Thank you. 14 

### MR. CYMBALSKY: This is John from DOE. 15 

### Who makes this fan? That's pretty cool. 16 

### [Laughter.] 17 

### MR. MATTHEWS: Chuck Matthews, Matthews 18 

### Fan Company. I also agree. 19 

### [Laughter.] 20 

### MR. FLANNERY: Tim Flannery, Minka. We 21 

### agree, as well. 22139

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### MS. KANTNER: DOE proposes to clarify 1 

### that for ceiling fans with non-vertical airflow, 2 

### the ceiling fan head should be adjusted such that 3 

### the airflow is as vertical as possible prior to 4 

### testing. If a ceiling fan cannot achieve 5 

### vertical airflow, DOE proposes to orient the 6 

### ceiling fan such that any remaining tilt is 7 

### aligned along one of the four sensor axes, and 8 

### then air velocity should only be measured along 9 

### that axis, and the axis oriented 180 degrees with 10 

### respect to that axis, and then airflow would be 11 

### measured along the -- would be calculated based 12 

### on the continuous set of sensors with the largest 13 

### air velocity measurements. This little 14 

### illustration here is supposed to indicate how 15 

### that might shift for a fan with a tilt. 16 

### MR. BROOKMAN: Yes, Bill. 17 

### MR. WALKER: Bill with Hunter. We don't 18 

### really have a dog in this hunt, but it doesn't 19 

### mean we might not at some point in time. It 20 

### seems kind of ambiguous to me that the airflow 21 

### should be calculated based on the continuous set 22140

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### of sensors with the largest air velocity 1 

### measurement. Where do you cut it off at? What 2 

### do you say -- okay, I'm going to use this sensor 3 

### but I'm not going to use this one, because, I 4 

### mean, it's a curve there. 5 

### MS. KANTNER: The number of sensors is 6 

### defined by the size of the fan. It would be same 7



### as -- 8 

### MR. WALKER: So you're still going to use 9 

### fan that -- okay. 10 

### MS. KANTNER: Exactly. You're just 11 

### allowing that to shift, in case that -- you've 12 

### got a different set that are maximizing the 13 

### airflow. 14 

### MR. WALKER: Eight inches larger than the 15



### -- 16 

### MS. KANTNER: Exactly. 17 

### MR. WALKER: Okay. 18 

### MR. BROOKMAN: Okay. Nathan. 19 

### MR. FRAMPTON: Nathan with Fanimation. 20 

### We agree. 21 

### MR. BROOKMAN: Thank you. Okay. 22141

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### MS. KANTNER: DOE proposes to calculate 1 

### high-volume ceiling fan efficiency based on 2 

### airflow and power consumption at high speed. For 3 

### ceiling fans up to 24 feet in diameter, DOE 4 

### proposes to test high-volume ceiling fans using a 5 

### test procedure based on AMCA 230. 6 

### MR. GATTO: Dave Gatto, Westinghouse 7 

### Lighting. I was just going to second Christian's 8 

### earlier comment that for fans less than 7 feet, 9 

### that they're tested in the same test method 10 

### procedure as what you're calling low-volume 11 

### ceiling fans. 12 

### MR. BROOKMAN: Yes. Christian. 13 

### MR. TABER: Christian Taber, Big Ass 14 

### Solutions. Obviously, I'm going to agree with my 15 

### own previous comments on this. In addition, AMCA 16 

### 230 is currently in a revision process. The 17 

### committee is, I would say, dramatically changing 18 

### the standard to make it much more usable and 19 

### consistent. There are words like "mental 20 

### averaging" and things in the current version of 21 

### the standard that are a little less than maybe 22142

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### ideal for a DOE test standard to be used. 1 

### I would highly recommend that either the 2 

### new version of the standard, if it's published in 3 

### time, or at least the language from the new 4 

### version of the standard be used. I don't know on 5 

### the timing of the actual publication of 230-14 or 6 

### -15, whenever it makes it out of the ANSI 7 

### process, but there are a lot of useful changes 8 

### that the committee has put together on it, that 9 

### would make it much more consistent and usable 10


### test. 11 

### And the other comment is, there is a 12 

### proposed change to this that says AMCA 230, but 13 

### with different room sizes. The room sizes 14 

### proposed by DOE are different than the room size 15 

### change proposed by the 230 committee. I would 16 

### ask that those two numbers be aligned. 17 

### MS. KANTNER: Are the numbers proposed by 18 

### the 230 committee publicly available? 19 

### MR. TABER: Yes. No, actually, no. 20 

### They're not publicly available, but they are 21 

### available from AMCA themselves. AMCA did not 22143

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### send a representative, but they would like to be 1 

### a part of it. 2 

### MR. BROOKMAN: Okay. Additional 3 

### thoughts, comments here? 4 

### MS. KANTNER: I think your previous 5 

### comment sort of gets at this slide. These are 6 

### DOE's proposals to modify the specified room 7 

### dimensions for high-volume ceiling fans in the 8 

### following ways. I think we've already talked 9 

### about that. 10 

### MR. BROOKMAN: So, Christian, you're 11 

### supportive? 12 

### MR. TABER: I am not supportive of the -- 13 

### Christian Taber, Big Ass Solutions. I am not 14 

### supportive of the proposed dimensions, for 15 

### example, the 44-inch minimum height clearance 16 

### above blade would result in at least two of our 17 

### models being starved and producing insufficient 18 

### airflow. The clearance above the blades is 19 

### generally larger for larger ceiling fans. There 20 

### are several manufacturers that would not have 21 

### optimal performance with the 44-inch clearance. 22144

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### So, again, I would point to the AMCA 230 1 

### revisions for suggested room heights. 2 

### MR. BROOKMAN: Okay. Thank you. 3 

### Additional thoughts here? Yes. 4 

### MR. GATTO: Dave Gatto, Westinghouse. I 5 

### won't dispute that with Christian. I'm not 6 

### really sure, but it could potentially affect 7 

### that. But I do agree with the greater than 10 8 

### foot for ceiling fans with blade fans of 6 feet 9 

### or greater. We don't currently play in that 10 

### particular one, but there are products that are 11 

### under consideration, that I think that's an 12 

### appropriate height. 13 

### MR. TABER: And I would -- if the 14 

### proposed change were accepted, to just all fans 7 15 

### feet in diameter or less, via the Energy Star 16 

### method, then I would obviously suggest that that 17 

### number change to greater than 7 feet. 18 

### MR. BROOKMAN: Okay. 19 

### MS. KANTNER: DOE proposes to test 20 

### standby power consumption in ceiling fans with 21 

### standby functionality for both low-volume and 22145

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### high-volume ceiling fans. 1 

### MR. BROOKMAN: Christian. 2 

### MR. TABER: Christian Taber, Big Ass 3 

### Solutions. One of the reasons for standby mode 4 

### is controls. Ceiling fans without complex 5 

### controls options or remotes really have no 6 

### standby power. Looking at our product line, we 7 

### have a fan with an occupancy sensor, and one of 8 

### the reasons it has standby power consumption is 9 

### because of that occupancy sensor. 10 

### Looking at the LBNL study, or survey that 11 

### was used for the high and low speed, there is a 12 

### section on it, on the operation of ceiling fans 13 

### when no one is present in the room, and it showed 14 

### that more than half of ceiling fans are run 15 

### during hours when no one is in the space. If a 16 

### penalty is to be imposed for standby power 17 

### consumption for controls, we would also propose a 18 

### credit be given for controls that reduce the 19 

### unnecessary operating hours of a fan. 20 

### Yesterday, in the lighting discussion, 21 

### was there any talk on occupancy sensors and a 22146

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### credit for that? 1 

### MR. BROOKMAN: I don't think so. 2 

### MS. ARMSTRONG: So, the answer is no 3 

### because what we've proposed for light kits is a 4 

### lamp efficiency other than luminaire, for most 5 

### parts, so the test procedure isn't reflective of 6 

### the controls, at this stage, although there was 7 

### some discussion about whether it should be. 8 

### MR. TABER: Okay. And if it's just a 9 

### lumens per watt, then that would maybe not make 10 

### sense. But for ceiling fans, since we're eating 11 

### all of the standby power of the unit, I would 12 

### propose that there be some sort of credit given 13 

### if there was a way to reduce annual operating 14 

### hours, via something like an occupancy sensor. 15 

### MS. ARMSTRONG: Okay. So we had the same 16 

### question. What is the delta for adding occupancy 17 

### sensor, in terms of wattage, for standby mode? 18 

### MR. TABER: I'm a mechanical engineer -- 19 

### MS. ARMSTRONG: Me, too. 20 

### MR. TABER: -- and so I would have to ask 21



### some -- 22147

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### MR. CYMBALSKY: You can use a watt meter. 1 

### MR. TABER: If an electrical is holding 2 

### it, yes, I can use a watt mater. I don't 3 

### actually know that. We can definitely provide 4 

### that information. 5 

### MS. ARMSTRONG: That would be great. 6 

### MR. BROOKMAN: Okay. Thank you. 7 

### Additional comments before we move on? Okay. 8 

### MS. KANTNER: Now we're moving on to the 9 

### effective date and compliance date. The 10 

### proposals for amending Appendix U would not 11 

### affect a manufacturer's ability to comply with 12 

### current energy conservation standards because DOE 13 

### does not currently have performance-based 14 

### standards for ceiling fans, as measured by 15 

### airflow efficiency. 16 

### DOE expects that any final rule will be 17 

### in effect 30 days after publication of the test 18 

### procedure final rule in the Federal Register. 19 

### Revised Appendix U must be used to determine any 20 

### representations of efficiency 180 days after the 21 

### publication of any final amended test procedures. 22148

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### MR. BROOKMAN: Dave. 1 

### MR. GATTO: Dave Gatto, Westinghouse. We 2 

### don't need to go through the whole thing again. 3 

### That revised Appendix U, though, I understand 4 

### it's in the statute. We would really appreciate, 5 

### as industry, some clarification on how that would 6 

### be applied, because I think that does create a 7 

### scenario where even if DOE is in agreement with 8 

### the extended timeline needed to meet the 9 

### compliance date, if we can't represent the 10 

### product performance, which is required under FTC, 11 

### we're kind of back in the soup again. 12 

### MS. ARMSTRONG: I think Hampton clarified 13 

### the fact that the 180-day time frame is in the 14 

### statute, for changing over representations. I 15 

### think what we need to hear from industry -- and I 16 

### think you somewhat addressed this this morning -- 17 

### your ask is a year before compliance with amended 18 

### standards, should DOE end up promulgating amended 19 

### standards as part of this latter half of this 20 

### rulemaking effort. But to the extent anyone has 21 

### comments on that, please submit them in writing. 22149

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### And then to answer the inventory 1 

### question, you know, it is my understanding -- and 2 

### Hampton is not here anymore -- just like DOE's 3 

### regs, it's with date of manufacture. So the date 4 

### of manufacture is synonymous with date of 5 

### importation, which is important in this space. 6 

### MR. BROOKMAN: Can you hang on a second. 7 

### Tim, she's answering the inventory question. 8 

### MS. ARMSTRONG: It's okay. So, I think 9 

### that, it's my understanding, and we can get 10 

### Hampton to confirm this, but that the dates are 11 

### synonymous with date of manufacture, so if 12 

### representations have to be changed over within 13 

### 180 days, that would be starting for manufactured 14 

### beginning 180 days after that point and going 15 

### forward, and that's also including date of 16 

### importation. 17 

### So you would be okay as long as things 18 

### are inventory here and cleared, but newly 19 

### manufactured, newly importing starting that date, 20 

### whatever that date may be, would be subject to 21 

### the new requirements. Okay? 22150

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### MR. BROOKMAN: Okay? Nathan. 1 

### MR. FRAMPTON: Did we sufficiently make 2 

### our case that we need a lot more time? 3 

### [Laughter.] 4 

### MS. ARMSTRONG: So, I would say your 5 

### concerns have been well heard. Now, what the 6 

### statute allows, we need to go back and look at 7 

### the statute, and look at the language, and see, 8 

### given your concerns and given what you've said 9 

### today, what DOE has the flexibility of doing. 10 

### MR. BROOKMAN: Terry. 11 

### MR. MCGOWAN: You don't have to answer 12 

### this right now, but I would like to go back to 13 

### the previous slide, if that's appropriate, and 14 

### I'm sorry to do this, but I didn't want the 15 

### moment to go by without recalling the discussion 16 

### we had yesterday, in a little more detail, 17 

### regarding controls, and I would like to see a 18 

### placeholder here for incorporating the effective 19 

### controls in both lighting and in fans, so that we 20 

### understand that future energy savings, as 21 

### efficiencies and efficacies peak out, are going 22151

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### to have to come from controls, and we should 1 

### consider carefully about including controls and 2 

### their effects, in some way, in this rulemaking. 3 

### And we can comment on that and propose 4 

### some ways, but I want to be sure it's there. 5 

### MR. BROOKMAN: Okay. Thank you. 6 

### Christian. 7 

### MR. BRUNDAGE: Don Brundage, Southern 8 

### Company. Just a suggestion. I'm trying to look 9 

### for ways to fit within the statute. Since you're 10 

### going to have several classes of products, if you 11 

### potentially said Class A of a product needs to 12 

### use the new test procedure on this date, and 13 

### issue a test procedure ruling later for a 14 

### different class of product within ceiling fans, 15 

### that might get you within the letter of the law 16 

### and reduce the burden on the manufacturers. 17 

### MS. ARMSTRONG: Okay. 18 

### MR. BROOKMAN: Christian: 19 

### MR. TABER: Christian Taber. I actually 20 

### had a question for Don. Do you remember, in 21 

### 90.1, ASHRAE Standard 90.1, building energy code, 22152

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### what the credit is for occupancy sensors on 1 

### lights when not required? Is it 10 percent? 2 

### MR. BRUNDAGE: It's something like that. 3 

### I don't recall. 4 

### MR. TABER: Okay. So just looking for 5 

### something that we could maybe reference for that 6 

### Standard 90.1 is energy code for nonresidential 7 

### buildings more than three stories, so that might 8 

### be a useful place to look. 9 

### MR. BROOKMAN: Okay. Thank you. I think 10 

### we're on effective date. Yes, David. 11 

### MR. TURNER: David from Hunter. 12 

### Actually, you say date of import is the correct 13 

### kind of cutoff? So -- and I just want to get my 14 

### head right here. So, import from China to 15 

### hitting the coast here is 30 to 45 days. So, 16 

### that would actually mean we need to be shipping 17 

### prior to the actual implementation or the final 18 

### rule being -- okay. 19 

### MS. ARMSTRONG: You wouldn't necessarily 20 

### need to be shipping, right? I mean, effective 21 

### date of 30 days, but you would have 180 days to 22153

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### change over representations. So after that 180- 1 

### day mark, which would give you plenty of days to 2 

### ship, 180 days from the publication of the test 3 

### procedure final rule, is what Hampton clarified 4 

### earlier, when the statute requires 5 

### representations turnover. 6 

### Now, this is all pending what we end up 7 

### doing in the final rule, but it's the 180-day 8 

### window you need to be concerned with. The 30-day 9 

### window means you can start using the test 10 

### procedure, for lack of a non-lawyerfied way of 11 

### saying it. 12


### MR. BROOKMAN: Dave. 13 

### MR. GATTO: Just real quick, because I 14 

### think you know where we're at. Dave Gatto, 15 

### Westinghouse Lighting. The challenge that 16 

### creates is that we really can't start using it 17 

### because we don't know, officially, that it's 18 

### official until it's done. If we all submitted 19 

### all of our products that needed testing so that 20 

### we can provide proper representation values in 21 

### that first 30 days, we would have to have results 22154

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### on all of those models within the next 60 days, 1 

### high side, to be able to meet the importation 2 

### date that the 180-day provision requires. 3 

### So, I know that -- I just really want to 4 

### make it as clear as possible that anything that 5 

### FTC and DOE and Laura, who is still here 6 

### somewhere, can do -- and we'll include it in the 7 

### comments, but the challenge it creates is it 8 

### could create a shortage of supply of the product, 9 

### so the consumer impact is going to be that they 10 

### wouldn't be able to get any ceiling fans for some 11 

### period of time, potentially an extended one. 12 

### MS. ARMSTRONG: So, your concerns have 13 

### been heard. I think, just by one ask, and this 14 

### is in response to Nathan's question if, "Ashley, 15 

### do you have all the information you need to 16 

### know?" if, in your comments, you can talk about - 17 

### - you know, obviously, this is pending on how we 18 

### end up finalizing the test procedure, but to the 19 

### extent your numbers would look different -- I'm 20 

### going to make up something -- but a ceiling fan 21 

### would be rated at 10 now, and will become rated 22155

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### at 8, that would be helpful. 1 

### What is the magnitude of the changes 2 

### we're talking about? Is everything going to look 3 

### different, or is it just a different methodology 4 

### but the numbers are going to look the same. 5 

### That's something that I think we -- that's a 6 

### piece of information, a piece of the puzzle that 7 

### also would be helpful in this space. 8 

### MR. GATTO: Dave Gatto, Westinghouse. I 9 

### just want to make sure that I understand. So for 10 

### new models, obviously, there is no 11 

### representation. It's first test data. But for 12 

### existing models -- 13 

### MS. ARMSTRONG: So this would be for 14 

### standard ceiling fans. 15 

### MR. GATTO: Anything that we're already 16 

### representing -- 17 

### MS. ARMSTRONG: It's not relevant for 18 

### hugger fans, because it's our interpretation that 19 

### you guys don't test, currently, hugger fans. We 20 

### had previously said they do not meet the 21 

### definition. They're not tested. You're not 22156

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### making representations. The test procedure is 1 

### not applicable to them. 2 

### MR. GATTO: So -- Dave Gatto, 3 

### Westinghouse. I'm not sure if what you're saying 4 

### is we wouldn't need to provide information on 5 

### hugger fans until the final rule? 6 

### MS. ARMSTRONG: So, I'm saying the change 7 

### -- it is my opinion here that the changes in 8 

### representation, the changes in the numbers is 9 

### irrelevant for hugger fans. 10 

### MR. GATTO: Right. There would be no 11 

### change from representation. 12 

### MS. ARMSTRONG: There would be a -- your 13 

### concerns with that one would be I have to now 14 

### test them -- 15 

### MR. GATTO: Okay. 16 

### MS. ARMSTRONG: -- and then I have to 17 

### comply with the design standards. What does that 18 

### do? However, it's not about -- for standard fans 19 

### it would be, I now have to retest them, and what 20 

### do the new ratings look like. 21 

### MR. GATTO: Okay. Yeah, that helps me. 22157

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### Thanks. I wanted to make sure I was really clear 1 

### on that. 2 

### MR. BROOKMAN: Christian. 3 

### MR. TABER: Christian Taber, Big Ass 4 

### Solutions. So just to clarify, you want someone 5 

### to run a standard ceiling fan under the current 6 

### test now, and then under the new, proposed tests 7 

### and see what the delta is, CFM per watt? 8 

### MS. ARMSTRONG: Roughly. Yeah. I mean, 9 

### are we talking 5-percent change or are we talking 10 

### 10-percent change, or are we talking some are the 11 

### same, some are different? It gets to the 12 

### magnitude of the percentage of models that would 13 

### necessarily have to -- 14 

### MR. TABER: The slide that I had up 15 

### earlier -- 16


### MS. ARMSTRONG: Yes. 17 

### MR. TABER: -- we saw a 30 to 50 percent 18 

### reduction in CFM per watt by the new test method, 19 

### so roughly half. 20 

### MR. BROOKMAN: Okay. Did we do this 21 

### sufficiently? 22158

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### MS. ARMSTRONG: Yes. 1 

### MR. BROOKMAN: I remember it now. Okay. 2 

### MS. ARMSTRONG: Actually, let me speak to 3 

### the next two slides, because I'm going to go 4 

### through these pretty quickly. This is something 5 

### I touched on yesterday, for those that were here. 6 

### One of the parts of DOE regulations that often 7 

### gets overlooked is the fact that we do have 8 

### sampling procedures that govern how you make 9 

### represented value. 10 

### What that means is two things. It says 11 

### how many units you must test of each basic model, 12 

### and then what is the associated tolerance that 13 

### you must apply to your raw test results for 14 

### individual units to come up with the readings 15 

### that then you would certify, put on disclosures, 16 

### use for Energy Star. 17 

### So I just want to introduce this. I'm 18 

### not going to go into it, but what's important is 19 

### the confidence limit, and what the confidence 20 

### limit is meant to say is to account for the 21 

### variability experience, not only in the test 22159

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### procedure but things coming off of the 1 

### manufacturing production line, if you do see 2 

### variability, like wood warping, or whatever. 3 

### So that's something we would be 4 

### interested in your feedback on. We've at least 5 

### proposed that you have to test no less than two 6 

### units. You may test more, at your discretion, 7 

### but you at least have to test two for each basic 8 

### model. So this wouldn't be a single-unit test to 9 

### get a number, and that's the number you use. 10 

### That's now how this works for DOE regulatory 11


### purposes. 12 

### MR. BROOKMAN: Any questions on the 13 

### sampling slide? 14 

### MS. ARMSTRONG: This is a difference. 15 

### Two fans, two speeds is the proposal, per what we 16 

### call basic models. It's not every model but it's 17 

### for basic model. You can do some groupings in 18 

### there, if you'd like. 19 

### MR. BROOKMAN: Bill. 20 

### MS. ARMSTRONG: My favorite topic. I had 21 

### to go there. I did have a slide on it. So, in 22160

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### DOE's rating regulations, DOE allows 1 

### manufacturers to group individual models into 2 

### this thing we call basic model, and what it 3 

### allows you to do is reduce your testing burden, 4 

### because you only have to test two units per basic 5 

### model, or at least two. You can test more if 6 

### you'd like, but at least two. 7 

### But, typically, the easiest way to do 8 

### this is different finishes. Non-efficiency 9 

### attributes, and even small changes in efficiency 10 

### attributes that you don't want to claim, it 11 

### allows you to group them for the purposes of 12 

### reducing your testing burden. 13 

### Now, the only caveat I will say, just so 14 

### that you're all aware, is if you do do groupings, 15 

### if DOE were to test one and find one non16 

### compliant, which, hopefully, would never occur in 17 

### this space, it would affect all the models in 18 

### that group. Basically, you're representing, this 19 

### is the group's efficiency. 20 

### And, so, some people in other industries 21 

### have found this of particular interest to them, 22161

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### as a way of significantly reducing your testing 1 

### burden. We leave that at your discretion. 2 

### MR. BROOKMAN: Okay. 3 

### MS. ARMSTRONG: We can have a whole other 4 

### day on that topic later, if you'd like. 5 

### [Laughter.] 6 

### MR. BROOKMAN: Okay. 7 

### MS. ARMSTRONG: So you can just move on 8 

### to Slide 51. 9 

### MS. KANTNER: Did you want to talk about 10 

### this, or should I continue? 11 

### MS. ARMSTRONG: It doesn't matter. You 12 

### can do it. 13 

### MS. KANTNER: Okay. DOE prepared an 14 

### initial regulatory flexibility analysis for this 15 

### rulemaking which describes the potential impact 16 

### on small businesses associated with ceiling fan 17 

### testing requirements. DOE estimated that there 18 

### were between 25 and 35 small business 19 

### manufacturers of low-volume ceiling fans and 20 

### between 15 and 25 small business manufacturers of 21 

### high-volume ceiling fans. 22162

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### The current DOE test procedure doesn't 1 

### specify the number of speeds to be tested, so we 2 

### compared the proposed DOE test procedure to the 3 

### current Energy Star test procedure, and the 4 

### differences between those two test procedures are 5 

### listed here, along with estimates of what the 6 

### differential impact will be. 7 

### In total, DOE estimates that the test 8 

### cost per basic model of standard or hugger 9 

### ceiling fan would be between $1,200 and $3,600 10 

### for a basic model of a standard or hugger ceiling 11 

### fan. Double that for a basic model of a multi12 

### mount ceiling fan, and between $2,600 and $4,000 13 

### for a multi-head ceiling fan. 14 

### DOE also estimated the expected costs 15 

### under the proposed rule for high-volume ceiling 16 

### fans -- and I should probably clarify that for 17 

### both low-volume and high-volume ceiling fans, 18 

### these numbers were based on quotes and estimates 19 

### given from testing facilities. 20 

### For high-volume ceiling fans, these were 21 

### the associated costs for the one-time cost, and 22163

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### then the cost to conduct a particular test. 1 

### MR. BROOKMAN: David, please. 2 

### Microphone. 3 

### MR. TURNER: David from Hunter, on this 4 

### slide. So I realize there's not a current test 5 

### procedure, so you used Energy Star. That's what 6 

### we're kind of discussing, so given that 5 to 10 7 

### percent of the current industry is Energy Star, 8 

### there's a 90-percent factor of fans that probably 9 

### aren't getting tested to that full effect there. 10 

### I don't know if that means the difference 11 

### is off. I mean, I don't know how you quantify 12 

### that. I just kind of wanted to get on the record 13 

### to say that there are a lot of fans out there, 14 

### upwards of three-quarters of the market that 15 

### probably aren't getting tested to that full 16 

### effect on the far left, so that difference is 17 

### probably greater, in the end. 18 

### MS. KANTNER: We were just trying to use 19 

### this as a point of reference, as far as what the 20 

### changes were. 21 

### MR. TURNER: Yeah, so I just wanted to 22164

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### get on the record for that. 1 

### MR. BROOKMAN: Okay. Thank you. Are we 2 

### ready to move on? 3 

### MS. KANTNER: Any comments on this slide? 4 

### Okay. 5 

### In summary, DOE estimated the number of 6 

### basic models per manufacturer and found between 1 7 

### and 80 for low-volume ceiling fans, and 1 and 30 8 

### for high-volume ceiling fans, and then based on 9 

### estimates of the median revenue came up with an 10 

### estimate at the bottom of this table for the test 11 

### cost as a fraction of median revenue, which was 12 

### between 0.01 percent and 1 percent for low-volume 13 

### ceiling fan small business manufacturers, and 14 

### between 0.05 percent and 1.5 percent for high15 

### volume small business manufacturers. 16 

### MS. ARMSTRONG: I don't think we need to 17 

### put up the next slide. Just ask for comment on 18 

### the small business impacts, whether it be an 19 

### estimate of the actual number of small businesses 20 

### or the impacts. If you have any specific 21 

### comments or changes, in addition to the ones that 22165

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### Hunter already made, we would welcome those and 1 

### your written comments in follow-on. 2 

### This does conclude the portion of the 3 

### test procedure rulemaking, so does anybody want 4 

### to make any other final comments about the test 5 

### procedure before we move on to lunch, and then 6 

### standards? 7 

### MR. BROOKMAN: Bill. Get that close. 8 

### MR. WALKER: Bill with Hunter. Are you 9 

### talking about, even Issue Number 19? 10


### MS. ARMSTRONG: Sure. 11 

### MR. WALKER: I mean, it's up there now. 12 

### MR. BROOKMAN: Yes, please. 13 

### MR. WALKER: So, a comment on how 14 

### calibration between testing facilities could be 15 

### facilitated, I think that's going to be somewhat 16 

### tough. Allen mentioned there were maybe three or 17 

### four labs, but there's a lot of certification or 18 

### verification bodies out there. They have to go 19 

### through that, too. I mean, that has to be a part 20 

### of it. 21 

### I can tell you that I tested a fan in my 22166

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### lab, and I had two other certification bodies 1 

### test it, same fan, same blades, exactly the same. 2 

### We got three different results. 3 

### MR. BROOKMAN: Significantly different? 4 

### MR. WALKER: I'm sorry? 5 

### MR. BROOKMAN: Significantly different? 6 

### MR. WALKER: Substantially different. 7 

### Energy Star versus non-Energy Star. So, you 8 

### know, the comment is, I don't know how it needs 9 

### to be accomplished, but it's got to be 10 

### accomplished somehow, and Hunter will work with 11 

### you to do that. 12 

### MS. ARMSTRONG: Yeah. So, I think 13 

### there's a couple of things. One of the things we 14 

### do, we'd be happy to engage in a round-robin, get 15 

### that set up, starting as soon as possible. Two 16 

### would be, that's one of the reasons we have our 17 

### reading requirements the way we set up. If you 18 

### work through the math, the certification 19 

### requirements do push manufacturers to rate 20 

### conservatively. 21 

### There's a reason for that. It does two 22167

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### things. One is the consumer gets that or better, 1 

### so it protects the consumer, and the savings that 2 

### we all want to deliver to the consumer. But, 3 

### two, it also somewhat protects you in your 4 

### ratings, if DOE were to pull a product from 5 

### market and test it at a third-party lab. 6 

### And then we do have tolerances, different 7 

### set of tolerances on the other side, for 8 

### enforcement-type purposes, which are above and 9 

### beyond the tolerances given, or provided for you 10 

### guys for certification testing, but it does make 11 

### it a lot harder for DOE to actually determine 12 

### that a product is not compliant, due to what we 13 

### all know will happen, which is lab-to-lab 14 

### variation. Okay? 15 

### MR. BROOKMAN: Okay. Additional closing 16 

### remarks at this time, before we go to lunch? 17 

### Great. Good progress this morning. 18 

### Let's go to lunch. It's now twelve, 19 

### approximately, so we will resume at one o'clock. 20 

### We're mindful that many persons present will be 21 

### departing at 3:00 or 3:15 or so, so we're going 22168

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### to go as rapidly as possible and still cover all 1 

### the content in what's listed in the slides when 2 

### we return and resume at one. 3 

### Please make sure to wear your badge. For 4 

### those of you that aren't familiar with the 5 

### facilities, a lot of folks will be going down to 6 

### the bottom floor and trooping about 100 yards 7 

### that way, to the big cafeteria. 8 

### This room will be supervised. You can 9 

### leave your stuff. You probably need an ID to get 10 

### back through the security portal, if you go to 11 

### the big cafeteria. 12 

### At one o'clock we'll resume. 13 

### [Recess taken from 12:05 to 1:01 p.m.] 14 

### Afternoon Session 15 

### MR. BROOKMAN: As we noted first thing 16 

### this morning, we are now going to move to the 17 

### energy conservation standards portion of the 18 

### meeting. We had a very productive discussion 19 

### this morning. I really appreciate everybody 20 

### being so forthcoming with their ideas and their 21 

### comments, and the Department will hope to see 22169

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### those comments amplified in writing. 1 

### So, now to Lucy deButts. 2 

### MS. DEBUTTS: Okay. This is Lucy here, 3 

### again. We're going to go quickly through some 4 

### slides, because we've covered a lot of territory 5 

### this morning, so the written comments can be 6 

### submitted. This is the information provided on 7 

### the slide. I just wanted to point out the 8 

### written comments on the energy conservation 9 

### standards is due on November 28th of 2014, and 10 

### it's coming up. 11 

### Opening remarks on this one? 12 

### MR. BROOKMAN: Yeah, any brief summary of 13 

### remarks here at the outset? David, I see you're 14 

### ready. 15 

### MR. TURNER: David at Hunter. Just a, if 16 

### there would be any consideration for an extension 17 

### on the written comment period, given for what 18 

### next week is, and where we all right now. John 19 

### and Ashley, there was a finger pointed at you by 20



### someone. 21 

### [Laughter.] 22170

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### MR. CYMBALSKY: So, I think this was 1 

### brought up yesterday. So are you asking for a 2 

### comment extension for both? For one? 3 

### MR. TURNER: The only one due next week 4 

### is the TSD comment, right? 5 

### MS. DEBUTTS: For standards. 6 

### [Discussion off mic regarding dates.] 7 

### MR. TURNER: Honestly, it's just the 8 

### holiday next week, plus not being able to get 9 

### together as much as we'd like, to make sure that 10 

### our unified response is as well thought out as we 11 

### want to. I don't know if we need much more than 12 

### a week or two, but the week of Thanksgiving, I 13 

### mean, half the week is dead already. 14 

### MR. CYMBALSKY: Okay. So if we say the 15 

### end of, the Friday of the first week of December? 16 

### MR. TURNER: That's the following week, 17


### correct? 18 

### MR. CYMBALSKY: December 6th or something 19 

### like that? 20 

### MR. TURNER: I think that would be a huge 21 

### help. 22171

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### MR. CYMBALSKY: Okay. Why don't you just 1 

### send me an e-mail with that request. 2 

### MR. TURNER: Thank you. 3 

### MS. DEBUTTS: Anything else? 4 

### MR. BROOKMAN: No opening comments? 5 

### We're going to launch straight into it, then. 6 

### Okay. 7 

### MS. DEBUTTS: Okay. So this slide was on 8 

### the screen for a while. This is the rulemaking 9 

### schedule. As you can see, we're projecting to 10 

### come up with third quarter of 2015 for the NOPR, 11 

### second quarter of 2016 for the final rule, and 12 

### compliance date will be in 2019. 13 

### We have discussed regulatory history. 14 

### Also, you can read about it. If you would like to 15 

### comment on it later, that's fine. 16 

### The preliminary analyses that were done 17 

### were composed of this analysis, described on the 18 

### slide, and we are going to go into detail later. 19 

### EPA also requests DOE to consider seven factors 20 

### that are listed on the current slide, and when we 21 

### did our printouts this week, considered all of 22172

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### them while proposing our levels. 1 

### And now we're going to go into scope 2


### coverage. 3 

### MR. BROOKMAN: We're going to do this as 4 

### expeditiously as possible, but that should not 5 

### diminish anyone's capacity to comment. If you 6 

### want us to slow down, if you've got something to 7 

### raise, raise it. Here we go. 8 

### MS. ARMSTRONG: We're going to jump to 9 

### the next one because we already went through this 10 

### this morning. 11 

### MS. KANTNER: I want to talk about the 12 

### highly decorative. 13 

### MS. ARMSTRONG: Oh yeah, highly 14 

### decorative. We do need to talk about that, 15 

### actually. But we already went over scope of 16 

### coverage this morning. It's the same thing for 17 

### standards. It's comparable other than this, that 18 

### one issue. 19 

### MR. BROOKMAN: Thank you, Ashley. 20 

### MS. KANTNER: In this rulemaking, DOE is 21 

### considering a definition for highly decorative 22173

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### ceiling fans. Specifically, DOE is considering 1 

### defining a highly decorative ceiling fan as "a 2 

### ceiling fan that operates at a maximum rotational 3 

### speed of 90 rpm and produces less than 2,000 CFM 4 

### of airflow on high speed." DOE considered 5 

### definitions based on CFM and RPM alone, and 6 

### believes that the combined definition is 7 

### preferable. Some large, high-volume ceiling fans 8 

### operate with a low RPM but produce very 9 

### significant airflow, and clearly have air 10 

### movement as a primary feature. 11 

### DOE also found examples of some smaller 12 

### fans, and by smaller I mean 26 inches in 13 

### diameter, or less, which did not produce 2,000 14 

### CFM but seemed, by all indications, to have air 15 

### movement as their primary purpose. 16 

### Any comments on that? 17 

### MR. BROOKMAN: Yes. Christian. 18 

### MR. TABER: Christian Taber, Big Ass 19 

### Solutions. Sorry. I have two issues, I guess. 20 

### The combination of RPM and CFM is better than 21 

### just RPM, because, obviously, our products move 22174

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### slow, and they move at a large CFM, but I think 1 

### it creates an issue, not our product, but looking 2 

### at some non-traditional ceiling fans. There's 3 

### one called Exhale, which is a centrifugal -- it's 4 

### not centrifugal -- it spins and blows air 5 

### outwards, so it's not going to be easily able to 6 

### measure using the Energy Star test rig. So 7 

### trying to prove that it moves less than 2,000 CFM 8 

### would be difficult. 9 

### Fanimation actually makes the FP-600. 10 

### It's the one with the blades that kind of go 11 

### like, around in this way. I don't know how you 12 

### would hook that up to a test stand, to try to get 13 

### at CFM. And so trying to prove that your fan 14 

### moves less than 2,000 CFM, when it's not really 15 

### intended as a ceiling fan that's highly 16 

### decorative, can be burdensome, so trying to get 17 

### out of this. 18 

### If we just did a tip speed, which is 19 

### fairly consistent across the industry -- not 20 

### everybody has the same tip speed, but a 21 

### decorative fan with something like, I think I 22175

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### have 680 feet per minute as its tip speed, would 1 

### be incapable of producing 2,000 CFM. So it would 2 

### kind of fall under both and it would just be one 3 

### very easy-to-prove metric. It moves this fast, 4 

### it's diameter, therefore it's this tip speed. So 5 

### it would be easy to show that you don't, you're 6 

### decorative and not designed to create airflow. 7 

### MR. BROOKMAN: Okay. Thank you. 8 

### Additional comments on highly decorative? Yes. 9 

### MR. MATTHEWS: Chuck Matthews, Matthews 10 

### Fan Company. Is the RPM really necessary for 11 

### this category? 12 

### MS. KANTNER: You mean including it in 13 

### the definition? I think, as -- 14 

### MR. MATTHEWS: Given the small percentage 15 

### of this product that's sold in the United States, 16 

### I'm just wondering if it's really necessary. 17 

### MR. CYMBALSKY: This is John from DOE. 18 

### Do you have a reaction to the Big Ass Solutions 19 

### tip speed, as opposed to what we are proposing 20 

### here? We're asking for your -- what would you 21 

### propose? Instead of asking us why this, how 22176

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### about, what's your idea? 1 

### MR. MATTHEWS: No RPM or tip speed. 2 

### MR. CYMBALSKY: So just CFM? 3 

### MR. MATTHEWS: Just CFM. I mean, given 4 

### that the primary purpose is maybe decorative, and 5 

### the fact that this product is not what is mostly 6 

### sold today in the U.S. -- it's a small percentage 7 

### of product, but it's still a product that is 8 

### somewhat popular with designers and architects. 9 

### MS. KANTNER: So would that CFM 10 

### requirement be as a function of blade span? 11 

### MR. MATTHEWS: I guess it would -- the 12 

### CFM, then, would decide whether it's highly 13 

### decorative or functional. 14 

### MS. KANTNER: I guess what I'm trying to 15 

### say is if you've got a small ceiling fan, it 16 

### seems like then you might produce 2,000 CFM, even 17 

### though that fan isn't -- 18 

### MR. MATTHEWS: Or less. Yeah. We've got 19 

### some small product. Some blades are like 12 20 

### inches in diameter, approximately 12 inches in 21 

### diameter, and so, therefore, approximately 2,000 22177

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### CFM in them is what we're producing, maybe a 1 

### little less. But these fans use high-velocity 2 

### motors, which are spinning at 90 RPMs. So it's a 3 

### decorative, functional product. It's utilitarian 4 

### in that it can direct airflow in a particular 5 

### direction. It's not designed, necessarily, to 6 

### cool down a room, but that product, then, might 7 

### not be for sale in the U.S., given this present 8 

### definition. So the removal of the RPM minimum -- 9 

### MR. BROOKMAN: If it was slightly higher, 10 

### would that do it? If it was 100 or 120, or 11 

### something? 12 

### MR. MATTHEWS: 1,100, perhaps. I mean, 13 

### these are high-speed blower motors that we're 14 

### using. But, again, they're not designed to cool 15 

### a room, either. They're designed to provide 16 

### directional airflow into a space directly 17 

### underneath or across a room. 18 

### MR. BROOKMAN: Okay. 19 

### MS. KANTNER: I guess I'm slightly 20 

### confused. They would still be allowed to be 21 

### sold. This is just a categorization. 22178

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### MS. ARMSTRONG: Yeah. It's a different 1 

### issue. 2 

### MR. MATTHEWS: Isn't this an exemption? 3 

### MS. ARMSTRONG: This is an exemption, but 4 

### to the extent that you wouldn't fall under the 5 

### exemption. You would just have to meet the 6 

### standards. 7 

### MR. CYMBALSKY: Meet the standard. 8 

### MR. MATTHEWS: And that's what I mean. 9 

### There's the potential that these products might 10 

### not meet the standards, and that's why I'm asking 11 

### for an exemption. 12 

### MR. TABER: Christian Taber, Big Ass 13 

### Solutions. Would it be possible that they 14 

### wouldn't qualify under the definition of a 15 

### ceiling fan? Because if it's mounted this way, 16 

### blowing that way, then I think it would be more 17 

### under the fan head pedestal type, the first slide 18 

### that there was the issue, which may have been the 19 

### reason for the question. 20 

### MR. MATTHEWS: That's another 21 

### possibility, yes. 22179

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### MR. TABER: I think it may be exempt for 1 

### that reason, not necessarily for this reason. 2 

### MR. MATTHEWS: I'm covering a couple of 3 

### bases, so -- 4 

### MR. BROOKMAN: Okay. Thanks for the 5 

### comment. Yes. Marianne. 6 

### MS. DIMASCIO: Marianne DiMascio, ASAP. 7 

### I think the concern is if there are many ways for 8 

### these to be exempt that people may use that to 9 

### get around standards, and it will have a higher 10 

### market share. It would be a loophole, so that 11 

### would be our concern. 12 

### MR. BROOKMAN: Okay. Yes, Christian. 13 

### MR. TABER: One other point. Christian 14 

### Taber, Big Ass Solutions. If we're going to 15 

### specify a CFM, then that CFM should be probably 16 

### based on the test method, since both give 17 

### different numbers. 18 

### MS. ARMSTRONG: Yep. 19 

### MR. BROOKMAN: Okay. 20 

### MR. TABER: Or if specified for both test 21 

### methods. 22180

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### MR. BROOKMAN: Dave. 1 

### MR. GATTO: Dave Gatto, Westinghouse. 2 

### Thanks, Christian. That's kind of where I was 3 

### going, is we set this bar based on the current 4 

### test procedure. If the new test procedure is 5 

### going to change the results, we could 6 

### inadvertently push products that are currently in 7 

### scope out of scope, which would be, I think, a 8 

### concern for Marianne. But also, for us, you 9 

### could end up with a product that's not going to 10 

### meet the efficiency standard because we based it 11 

### on a platform that isn't exactly what we're going 12 

### to get, in terms of the new test procedure 13 

### results. 14 

### MR. BROOKMAN: Okay. We're moving on, 15 

### then. 16 

### MS. KANTNER: So, next is the market and 17 

### technology assessment. I described the purpose 18 

### of the market and technology assessment 19 

### yesterday, so I think we'll just move on. In the 20 

### market assessment, DOE first categorized ceiling 21 

### fans into two types, high-volume and low-volume, 22181

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### and DOE estimated that the market share was about 1 

### 10 percent for high-volume and around 90 percent 2 

### for low-volume. There's a fair amount of 3 

### uncertainty in the high-volume numbers. 4 

### Within the low-volume category, DOE 5 

### categorized four types of low-volume ceiling 6 

### fans: standard, hugger, multi-mount, and highly 7 

### decorative, and found that each of those 8 

### categories was the percentage of market indicated 9 

### here, and this was based on models found in store 10


### surveys. 11 

### And this table summarizes DOE's market 12 

### estimate with respect to major manufacturers and 13 

### the market, historical shipments, the number of 14 

### ceiling fans in homes - the fraction of homes 15 

### with ceiling fans and the number of ceiling fans 16 

### in homes - and lifetime, for both low-volume and 17 

### high-volume ceiling fans. About 80 percent of 18 

### low-volume ceiling fans are sold through three 19 

### mass-market retailers, and DOE believes that low20 

### volume ceiling fans are manufactured overseas. 21 

### In contrast, as DOE understands it, most 22182

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### of the high-volume, large-diameter ceiling fans 1 

### are manufactured in the U.S., and DOE assumes 2 

### that most small-diameter, high-volume ceiling 3 

### fans are also manufactured overseas. 4 

### Shipments numbers we talked about 5 

### yesterday, so I'll just skip that. 6 

### DOE estimates that 73 percent of U.S. 7 

### households have ceiling fans, with an average of 8 

### 3.1 ceiling fans per household, and, again, there 9 

### was limited data available on high-volume ceiling 10 

### fans. 11 

### As far as lifetime, Appliance Magazine 12 

### estimated that the lifetime of a low-volume 13 

### ceiling fan was between 7 and 18 years, and DOE 14 

### assumed that the lifetime was the same for high15 

### volume ceiling fans, due to limited data to 16 

### indicate otherwise. 17 

### Then we have a couple of items for 18 

### comment, first on the manufacturing locations of 19 

### high-volume ceiling fans. 20 

### MR. BROOKMAN: Yes, Dave. 21 

### MR. GATTO: Dave Gatto, Westinghouse. 22183

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### We'll include this in the comments. For high1 

### volume, small-diameter fans, we agree with DOE's 2 

### analysis that the majority, if not all 3 

### manufacturing is in Asia. 4 

### MR. BROOKMAN: Thank you. 5 

### MR. GATTO: I'm sorry. I'm looking at 6 

### the other question, in case that's one I'm 7 

### supposed to do there, as well. No, I don't have 8 

### anything further to add. 9 

### MR. BROOKMAN: Christian. 10 

### MR. TABER: Christian Taber, Big Ass 11 

### Solutions. To comment on the high-volume, large12 

### diameter fans, for fans that are for sale in the 13 

### United States, I believe there is only one 14 

### manufacturer who is not located in the United 15 

### States, and they are in Canada. 16 

### MR. BROOKMAN: Moving on to high-volume. 17 

### MS. KANTNER: DOE also seeks comment and 18 

### data on the distribution of sizes and motor power 19 

### for both high-volume, large-diameter ceiling fans 20 

### and high-volume, small-diameter ceiling fans. In 21 

### particular, for high-volume, large-diameter 22184

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### ceiling fans, DOE assumed a 1-horsepower ceiling 1 

### fan is representative of the entire market and 2 

### requests comments on the accuracy of this 3 

### assumption. DOE also seeks comment and data on 4 

### the distribution of end users by industry and 5 

### application and the geographic distribution of 6 

### high-volume ceiling fans. 7


### MR. BROOKMAN: Dave. 8 

### MR. GATTO: Dave Gatto, Westinghouse. On 9 

### the high-volume, small-diameter fans, the 10 

### applications are primarily industrial and 11 

### commercial, unconditioned warehouse space, multi12 

### story warehouse. There are some light commercial 13 

### applications, as well, but it's almost zero 14 

### residential. 15 

### And there may be a slide for this, and I 16 

### think your previous slide told me why you 17 

### couldn't find them in the home center channel, 18 

### which is why I think the baseline that you 19 

### selected was incorrect, and we can provide 20 

### information to help you with that, as well. 21 

### MR. BROOKMAN: Christian. 22185

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### MR. TABER: For large-diameter -- sorry. 1 

### Christian Taber, Big Ass Solutions. For high2 

### volume, large-diameter fans, let's see, it is 1- 3 

### 1/2 times more likely that a 20-foot model would 4 

### have a 2-horsepower motor than a 1-horsepower 5 

### motor. A 20-foot diameter was assumed to be the 6 

### vast majority of the market. I think 67 percent 7 

### of the fans sold were estimated to be 20-foot 8 

### diameter fans. So a 1-horsepower would not be 9 

### representative of a 20-foot diameter fan. 10 

### And, in actuality, when we look at the 11 

### calculations included in here, the wattage of the 12 

### fan was 1,154 watts, which would be indicative of 13 

### a 1-1/2 horsepower or a 2-horsepower motor. So 14 

### the numbers used in the analysis were not 15 

### indicating a 1-horsepower motor, which would be 16 

### closer to 750 watts. 17 

### For the smaller diameters, for a 12-foot 18 

### diameter fan and an 8-foot diameter fan, 1 would 19 

### be more typical for a 12, and then a fractional, 20 

### maybe 3/4-horsepower would be more typical for 21 

### the smaller diameter. We do have comments that 22186

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### kind of break out for the industry how many of 1 

### each, in each category, what size, that kind of 2 

### details that out. 3 

### But our suggestion would be, for the 20- 4 

### foot fan, either a 1-1/2 or a 2, and then for the 5 

### smaller diameters, either a 1 or possible 3/4 or 6 

### 1/2. 7 

### MR. BROOKMAN: Thank you. Additional 8 

### comments before we move on? 9 

### MS. KANTNER: DOE estimated a current 10 

### household saturation rate for ceiling fans of 73 11 

### percent. DOE assumed that the residential market 12 

### for low-volume ceiling fans would continue to 13 

### penetrate until a saturation of 75 percent is 14 

### reached. Additionally, DOE estimated, on 15 

### average, that 3.1 ceiling fans are installed in 16 

### new installations, and DOE welcomes comment on 17 

### these assumptions. 18 

### MR. BROOKMAN: Yes, Dave. 19 

### MR. GATTO: Dave Gatto, Westinghouse. We 20 

### kind of covered this yesterday. We agree with 21 

### those assumptions as being the most reasonable to 22187

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### use. I'm not sure that we're going to agree with 1 

### how the shipment analysis played off of this, 2 

### when we get there. 3 

### MR. BROOKMAN: Okay. 4 

### MS. KANTNER: There is currently only one 5 

### product class for ceiling fans. Pursuant to 6 

### EPCA, DOE establishes product classes based on 7 

### three criteria: energy used, capacity, and other 8 

### performance-related features, including utility. 9 

### DOE is considering five separate ceiling fan 10 

### product classes, based on capacity and utility, 11 

### where utility might include the ability to be 12 

### installed safely in rooms with low ceilings, or 13 

### in general residential applications. 14 

### Specifically, DOE is considering three 15 

### product classes for low-volume ceiling fans -- 16 

### hugger, standard, and highly decorative, with the 17 

### definitions discussed earlier -- and DOE is 18 

### considering two product classes for high-volume 19 

### ceiling fans, based on fan diameter. 20 

### MR. FRAMPTON: This is Nathan with 21 

### Fanimation. One question, and it affects this 22188

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### slide and a couple of others. Were there any 1 

### tests done on high-velocity fans that have DC 2 

### motors, because I'm not aware of any products 3 

### that have high-velocity DC motors. 4 

### MR. BROOKMAN: Yes. Aris. 5 

### MR. MARANTAN: Aris Marantan, Navigant 6 

### Consulting. I'm not aware of any, and we did not 7 

### test any that had DC motors for high-volume, 8 

### small-diameter. 9 

### MR. BROOKMAN: thank you. Don Brundage. 10 

### MR. BRUNDAGE: For the larger ceiling 11 

### fans that would just be used in a commercial and 12 

### industrial setting, I have some concern over -- 13 

### you're doing this under 10 CFR 430 with the 14 

### exemptions, with the preemption of other 15 

### efficiency standards. It would probably be more 16 

### appropriate to do this, the large ones, as an 17 

### ASHRAE product and not have preemption on how you 18 

### would do that in the context of one rulemaking. 19 

### But it's going to limit the ability to use them 20 

### in building codes, because, essentially, with a 21 

### covered product, you typically are not showing 22189

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### any sort of efficiency standards within the 1 

### building codes, to avoid the preemption issues. 2 

### Thank you. 3 

### MR. BROOKMAN: Please. 4 

### MS. NOLL: This is Elizabeth Noll, NDRC. 5 

### I was wondering if DOE looked at the high-volume 6 

### ceiling fan with respect to airflow as opposed to 7 

### diameter, and if they have any reaction on the 8 

### two approaches, if they could explain that? 9 

### MS. KANTNER: I'm sorry. Can you restate 10 

### that? 11 

### MS. NOLL: So, with the product classes, 12 

### the efficiency standards will be based on, with 13 

### respect to diameter, and if they looked at 14 

### efficiency with respect to airflow as an 15 

### alternative approach. 16 

### MS. KANTNER: I believe we looked at both 17 

### and we found that there was a very high 18 

### correlation between the split between these 19 

### diameters and where the various capacity ranges 20 

### were, of airflow, so we felt like this was maybe 21 

### a simpler one. 22190

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### MS. NOLL: Okay. Thank you. 1 

### MR. TABER: Christian Taber, Big Ass 2 

### Solutions. Obviously, I would just point back to 3 

### our previous comments on the simplification of 4 

### classes. 5 

### MR. BROOKMAN: Okay. Additional comments 6 

### on product classes? Yes. Marianne. 7 

### MS. DIMASCIO: This may go into the next 8 

### section, but I'm wondering if you've looked at 9 

### specific consumer utility for non-conventional 10 

### blades. 11


### MR. CYMBALSKY: So -- 12 

### MS. DIMASCIO: Is there any consumer 13 

### utility for them? 14 

### MR. CYMBALSKY: This is John from DOE. 15 

### So, part of the rule, we look at the utility 16 

### side. If what you're saying is do consumers 17 

### derive utility from a conventional fan blade 18 

### shape that we're all used to seeing versus like 19 

### airfoil blade -- is that -- I believe there are 20 

### utility concerns there, sure. 21 

### MS. DIMASCIO: Okay, because the question 22191

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### I have is, it seems that those blades constrain 1 

### the standard, so if there's a utility, would it 2 

### make sense to have a separate product class for 3 

### those? 4 

### MR. CYMBALSKY: I think you'll see that 5 

### our analysis looked at the shapes of the blades. 6 

### I think we'll see that later. 7 

### MS. DIMASCIO: Okay. 8 

### MR. BROOKMAN: Okay. 9 

### MS. KANTNER: So, moving on. DOE is also 10 

### clarifying the status of multi-mount ceiling 11 

### fans. As we discussed earlier, the test 12 

### procedure is proposing to test them both in the 13 

### standard and hugger configurations, and DOE is 14 

### considering requiring multi-mount ceiling fans 15 

### meet the potential energy conservation standards 16 

### for both standard and hugger product classes. 17 

### And DOE seeks comment on the product 18 

### classes under consideration for ceiling fans, and 19 

### DOE also seeks comment on its approach to highly 20 

### decorative ceiling fans. I think we talked about 21 

### that last one a little bit already. 22192

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### MR. BROOKMAN: Comments here. Okay. 1 

### Nothing at this time. 2 

### MS. KANTNER: All right. DOE 3 

### investigated the following technology options to 4 

### improve ceiling fan efficiency, in three main 5 

### categories. Among the more efficient motor 6 

### technology options considered were more efficient 7 

### direct-drive, single-phase induction motors; 8 

### geared, single-phase induction motors; brushless 9 

### direct current motors; and three-phase induction 10


### motors. 11 

### Among the more efficient blade options 12 

### DOE considered were fewer fan blades, twisted 13 

### blades, curved or airfoil blades, blade 14 

### attachments, beveled blades, and blade materials. 15 

### DOE also considered ceiling fan controls, 16 

### specifically occupancy sensors. 17 

### DOE is also tentatively not including 18 

### wind or temperature sensors as a technology 19 

### option at this time. DOE is not aware of any 20 

### ceiling fans that include wind sensors, and only 21 

### one ceiling fan model that includes temperature 22193

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### sensors. DOE is also not aware of any data that 1 

### would indicate how such products would translate 2 

### into energy savings, as used in the field. 3 

### And then we have a couple of items for 4 

### comment on this. DOE requests information on the 5 

### availability of ceiling fans including wind and 6 

### temperature sensors, and any data on the 7 

### potential energy savings associated with such 8 

### products. 9 

### MR. TURNER: David from Hunter. We would 10 

### agree with the approach not including them, and 11 

### we don't know of any products out there. 12 

### MR. BROOKMAN: That's what I wanted to 13 

### know, the volume is -- okay. 14 

### MR. TABER: Christian Taber, Big Ass 15 

### Solutions. As the manufacturer of the fan with 16 

### the temperature sensor in it, I think we're fine 17 

### with not including the temperature sensor. The 18 

### occupancy sensor, I think would be the one of 19 

### more interest to us. But the temperature sensor 20 

### does bring up the point that the fan, paired with 21 

### air conditioning, does provide an overall 22194

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### positive, and that's really the purpose that that 1 

### sensor serves, is to work in conjunction with a 2 

### thermostat, to reduce overall energy consumption. 3 

### MR. BROOKMAN: Okay. 4 

### MS. KANTNER: And DOE requests comments 5 

### on these technology options being considered and 6 

### any additional options that should be included. 7 

### MR. BROOKMAN: You should go back to the 8 

### list, so they can see it. Any additional 9 

### options, comments on these. Yes, Christian. 10 

### MR. TABER: Christian Taber, Big Ass 11 

### Solutions. The more efficient blades -- and 12 

### we've commented on this a couple of times, and 13 

### I'm trying to think of the right way to say it, 14 

### so bear with me if I'm babbling. But all those 15 

### things kind of go together. Fewer fan blades, by 16 

### themselves, doesn't necessarily equal a more or 17 

### less efficient fan. 18 

### Angle of attack -- all factors kind of go 19 

### together into one, and simply stating that fewer 20 

### fan blades makes a fan more efficient, there are 21 

### one-bladed fans on the market and they are not 22195

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### any more efficient, necessarily, than a five1 

### bladed fan. There's a specific interest in our 2 

### industry in that some manufacturers tout the 3 

### number of blades as the reason why their fan is 4 

### more efficient, which is not necessarily true. 5 

### So, we would prefer a more holistic 6 

### approach of fan blade design, which includes all 7 

### of those things as one, not necessarily each 8 

### individually taken up. 9 

### MR. BROOKMAN: Okay. Dave. 10 

### MR. GATTO: Dave Gatto, Westinghouse. 11 

### Just to circle back briefly, I do agree with 12 

### Hunter that there aren't any, other than 13 

### Comprishing [ph] and that fell into the, I think, 14 

### high-volume, large-diameter. As it relates to 15 

### occupancy sensors, for low-volume, and even, to 16 

### an extent, to the high-volume, small-diameter -- 17 

### the occupancy sensor with fans, we've provided 18 

### these comments. That can be a very tough thing 19 

### to manage, particularly in a residential space. 20 

### What I would suggest to DOE is to 21 

### consider the fact that that energy-saving option 22196

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### is not only available, it's part of multiple 1 

### national and local building codes, but typically 2 

### it's the room occupancy sensor that's controlling 3 

### multiple devices. So even in the event that we 4 

### would want to consider -- and I think you 5 

### selected this out in the next couple of slides, 6 

### which we'd agree with -- I would just kind of 7 

### caution you that if we decide to bring it back 8 

### in, you're going to end up with multiple 9 

### occupancy sensors, potentially, because the fan 10 

### to come with one, the room might have one to meet 11 

### local code, and now you're actually driving up 12 

### standby power with no additional benefit. 13 

### MR. BROOKMAN: Yes. Aris. 14 

### MR. MARANTAN: Aris Marantan, Navigant 15 

### Consulting. I want to thank you, Christian, for 16 

### your comment on the holistic approach to the fan 17 

### design option. I do want to try and maybe get 18 

### some more information from you on how we might be 19 

### able to account for that in the analysis. As 20 

### you'll see later, in the engineering analysis, we 21 

### try to cost different design options, try to find 22197

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### out the incremental increasing cost for an 1 

### approach, as well as the incremental increase in 2 

### efficiency, so we would welcome any input you 3 

### have on that for the holistic design approach. 4 

### MR. BROOKMAN: Thank you. Moving on. 5 

### Oh, sorry, David. 6 

### MR. TURNER: David from Hunter. As we 7 

### indicated in our initial comments that, in the 8 

### retail space, fans have a high aesthetic appeal 9 

### and that has to be considered whenever we start 10 

### talking about changing something that's seen by 11 

### the consumer and is part of their choice of what 12 

### fan to buy. If we start changing the aesthetics, 13 

### then customer utility is affected, as far as 14 

### consumer choice. So I just wanted to reinforce 15 

### that. 16 

### MR. BROOKMAN: Okay. 17 

### MS. KANTNER: And now Sam Jasinski of 18 

### Navigant will present the screening analysis. 19 

### MR. JASINSKI: Thanks, Colleen. Good 20 

### afternoon. My name is Sam Jasinski from Navigant 21 

### Consulting. Today I'll be discussing the 22198

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### screening analysis. The purpose of the screening 1 

### analysis is to evaluate the technology options 2 

### that we were just discussing, using four criteria 3 

### prescribed by EPCA, that are listed here. In 4 

### doing so, DOE will only consider, in its 5 

### downstream analyses, particularly the engineering 6 

### analysis, technologies from that list that are 7 

### technologically feasible, practicable to 8 

### manufacture, install, and service, do not have 9 

### adverse impacts on product utility or product 10 

### availability, or adverse impacts on health or 11 

### safety. 12 

### So I'll cycle through the product classes 13 

### and discuss specifically which of the technology 14 

### options got screened in or out for each. Here's 15 

### the low-volume ceiling fan product class, and as 16 

### you see on the slide, we categorized the 17 

### technology options in three broad categories -- 18 

### more efficient motors, more efficient blades, and 19 

### ceiling fan controls. 20 

### For the low-volume ceiling fan product 21 

### class, more efficient direct-drive single-phase 22199

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### induction motors and brushless DC motors will be 1 

### considered. Geared induction motors, three-phase 2 

### induction motors will not, mostly because DOE is 3 

### not currently aware of commercially available 4 

### products that use these. For the three-phase 5 

### induction motors, there is also a utility 6 

### concern, or practicability to install concern 7 

### because low-volume ceiling fans are mostly used 8 

### in residential or commercial applications where 9 

### three-phase electricity is not used. 10 

### For the blade designs, these are also 11 

### mostly screened out. Due to the sensitivity 12 

### that's been raised by Hunter Fans and others, DOE 13 

### is aware that there is a sensitivity in this 14 

### market to the physical appearance of fans, and a 15 

### lot of these have impacts on those. DOE is 16 

### preliminarily screening them out because of those 17 

### impacts on utility, but is welcoming comments to 18 

### get a better understanding of how these specific 19 

### design options might impact utility to be 20 

### considered further in the next iteration of the 21 

### analysis. 22200

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### Some that are screened out for other 1 

### reasons, fans with fewer fan blades. DOE does 2 

### not currently have sufficient information to show 3 

### that this will actually improve efficiency. 4 

### There are also concerns that they will increase 5 

### noise, which is a reduction in utility to 6 

### consumers. For blade attachments, very 7 

### similarly, DOE does not have sufficient data to 8 

### show that these will improve efficiency, and DOE 9 

### is also not currently aware of any commercially 10 

### available products that use them. 11 

### In the last category, ceiling fan 12 

### controls, DOE is aware of one particular product 13 

### that uses occupancy controls, the SenseME from 14 

### Big Ass Solutions. However -- actually, let me 15 

### rephrase that. It's not yet commercially 16 

### available but they are taking preorders. Is it 17 

### commercially available now? At the time of the 18 

### analysis it was not commercially available. It 19 

### was available for preorders. 20 

### Something else that DOE considers is 21 

### intellectual property. We understand that there 22201

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### might be some intellectual property surrounding 1 

### this, so preliminarily it's screened out for now 2 

### until DOE can get more details and information 3 

### about the commercially available product and 4 

### whether or not there are intellectual property 5 

### concerns that DOE needs to be aware of. 6 

### Any comments on the screening analysis 7 

### for low-volume ceiling fans? 8


### MR. BROOKMAN: Dave. 9 

### MR. GATTO: Westinghouse Lighting. 10 

### Westinghouse agrees with DOE's screen in/screen 11 

### out. We'll have further comments on brushless DC 12 

### motors and the efficiency versus cost when we get 13 

### to that slide. 14 

### MR. BROOKMAN: Okay. Thank you. David, 15 

### do you want to comment here? Okay. 16 

### MR. TURNER: To make sure I understand 17 

### this screen properly, you analyzed a list of 18 

### potential options. These are the ones that you 19 

### decided to move forward looking at or not looking 20 

### at. But when we get to the individual options at 21 

### the EL levels -- I always get that wrong when 22202

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### we're in fans -- then, at that point, we can 1 

### provide comments on whether we think those ELs 2 

### are appropriate or not. So, yeah. 3 

### MR. CYMBALSKY: That'll be at 3:30. 4 

### [Laughter.] 5 

### MR. GATTO: Dave Gatto, Westinghouse. I 6 

### made sure that some of the fan guys were staying 7 

### with me to the end of the day. 8 

### MR. BROOKMAN: Christian, do you have 9 

### another comment? 10 

### MR. TABER: Yeah, just a comment on the 11 

### occupancy sensors, or a question, actually, more 12 

### than anything else. As far as when something is 13 

### screened out, what does that officially mean? 14 

### MR. JASINSKI: Officially it means that, 15 

### for this iteration of the analysis, it will not 16 

### be considered in the engineering analysis, which 17 

### means DOE does not go through the process of 18 

### determining whether or not it's economically 19 

### justified, which means there won't be any 20 

### implications in where the level is set, depending 21 

### on any efficiency or cost impacts for using that 22203

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### technology option. 1 

### MR. TABER: So would that mean that there 2 

### could be no credit given in the test metric for 3 

### that item, if it was not included in the 4 

### engineering analysis? 5 

### MS. ARMSTRONG: No. They're separate 6 

### decisions. 7 

### MR. TABER: Okay. That's fine. What we 8 

### would say is, essentially, on the occupancy 9 

### sensors, the fan has been available since 10 

### September of 2014. If you all would like to -- I 11 

### can't remember the exact wording that you used, 12 

### but further investigate that sensor, we would be 13 

### more than glad to allow you to play with one. 14 

### MR. JASINSKI: Thanks. Next I'll move on 15 

### to the high-volume ceiling fans. This slide is 16 

### specifically regarding the high-volume, small17 

### diameter ceiling fans. Again, in the high18 

### efficiency motors category, brushless DC motors 19 

### are screened in. More efficient direct-drive, 20 

### single-phase induction motors were screened out, 21 

### mostly because we believe that most of the 22204

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### commercially available products are already using 1 

### the most efficient single-phase induction motors 2 

### currently. Therefore, there won't be any 3 

### improvement in efficiency by adopting them. They 4 

### already have a high market penetration. 5 

### Geared induction motors were screened out 6 

### because DOE is not currently aware of any 7 

### commercially available products that use those. 8 

### Three-phase induction motors were screened out 9 

### for similar reasons to the low-volume ceiling 10 

### fans, mostly because DOE is not currently aware 11 

### of any commercially available products that use 12 

### it, and there are concerns about practicability 13 

### to install, because of the lack of three-phase 14 

### electricity in most of the applications where 15 

### these are used. 16 

### For the more efficient fan blades, 17 

### airfoil blades and curved blades are in. DOE is 18 

### aware of commercially available products that use 19 

### those. For the others, those are screened out 20 

### for similar reasons to the other fan blade 21 

### technologies, for low-volume ceiling fans. Fans 22205

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### with fewer blades was screened out because, 1 

### again, DOE does not have sufficient data at this 2 

### time to show that fewer fan blades would improve 3 

### efficiency. 4 

### Twisted fan blades, DOE is aware of only 5 

### a very few number of products that have these 6 

### technologies, and, again, there are some patent 7 

### and intellectual property concerns for those. 8 

### Blade attachments, DOE currently doesn't have 9 

### enough information to show that these will 10 

### positively impact efficiency. For alternative 11 

### blade materials, a similar case. DOE is aware of 12 

### very few products that use alternative materials, 13 

### but there are very few, and, again, there are 14 

### concerns whether there is intellectual property 15 

### surrounding those that might make them 16 

### impractical to manufacture on a large commercial 17 

### scale. 18 

### Same story with the occupancy sensors 19 

### here. I think we've covered that sufficiently, 20 

### unless there are more comments. 21


### MR. BROOKMAN: Dave. 22206

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### MR. GATTO: Sorry. Dave Gatto, 1 

### Westinghouse. On occupancy sensor, Pekka 2 

### couldn't be here from Lutron, but he texted me, 3 

### so he's clearly listening in. So while I'm not 4 

### speaking for him, if I say this wrong, it's his 5 

### fault. 6 

### Occupancy sensors for fans are also -- 7 

### and we're glad you screened it out -- a concern 8 

### for bedroom applications, because, typically, 9 

### even though there may be an occupancy sensor the 10 

### lighting in that room, and other products, the 11 

### ceiling fan, the consumer expectation is that it 12 

### will continue to run and keep them cool at night. 13 

### So, again, it's just one more reason we agree 14 

### with the thinking behind screening that out. 15 

### MR. BROOKMAN: Yes, Christian. 16 

### MR. TABER: So there are -- sorry. 17 

### Christian Taber, Big Ass Solutions. There are 18 

### ways to deal with that. You can, for example, 19 

### include a schedule in the setup with the 20 

### occupancy sensor. So, our product, for example, 21 

### the occupancy sensor can be set in the bedroom to 22207

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### run from 8 a.m. until 10 p.m., and then from 10 1 

### p.m. until 8 a.m. the occupancy sensor would be 2 

### disabled. 3 

### MR. BROOKMAN: Okay. 4 

### MR. TABER: So there are technological 5 

### ways to get around those issues. 6 

### MR. BROOKMAN: So, additional comments on 7 

### small-diameter ceiling fans, and what's been 8 

### screened in and screened out. I guess we're 9 

### about to move on to large-diameter. 10 

### MR. JASINSKI: For large-diameter fans, 11 

### geared motors, three-phase induction motors, and 12 

### brushless DC motors were screened in. More 13 

### efficient direct-drive, single-phase induction 14 

### motors were screened out, mostly because most of 15 

### these are fans installed in industrial 16 

### applications where three-phase electricity is 17 

### used, and in the cases where these motors might 18 

### be used, they're already representative of the 19 

### baseline, so there's no room for improvement 20 

### there. 21 

### For more efficient fan blades, airfoil 22208

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### blades, fans with fewer blades, and curved blades 1 

### were screened in. DOE is aware of commercially 2 

### available products that use these. Twisted 3 

### blades, this is one where, for this particular 4 

### product class, DOE is aware of very few fans that 5 

### use these commercially, and where they do, again, 6 

### there are patent concerns and intellectual 7 

### property concerns. 8 

### Blade attachment -- DOE, at this time, 9 

### does not have sufficient information to determine 10 

### whether or not they actually improve efficiency, 11 

### so they were screened out preliminarily. If DOE 12 

### receives more information to the contrary, that 13 

### can be considered for the next iteration of the 14 

### analysis. 15 

### Alternative blade materials, similar to 16 

### the small-diameter. DOE is only aware of very 17 

### few models that use this technology, with the 18 

### concerns about intellectual property. DOE also 19 

### does not have enough information at this time to 20 

### be sure that they positively impact efficiency. 21 

### And then, in this category, the discussion 22209

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### surrounding occupancy sensors is very similar. 1 

### MR. BROOKMAN: Comments here? Yes, 2 

### Christian. 3 

### MR. TABER: Christian Taber, Big Ass 4 

### Solutions. Blade attachments. The DOE 5 

### statements here were that only one manufacturer 6 

### uses blade attachments, that there is 7 

### insufficient evidence that blade attachments 8 

### improve efficiency. Comments from manufacturers 9 

### indicated that blade attachments do not aid in 10 

### efficiency. Basically, blade attachments are 11 

### used on more than 50 percent of the available 12 

### high-volume, large-diameter fans. We'll be 13 

### submitting data that shows the difference between 14 

### the exact same fan with and without blade 15 

### attachments that can be used. 16 

### I'm trying to think if there's anything 17 

### else. Obviously, the use of blade attachments is 18 

### common in the aerospace industry. There are a 19 

### number of articles on that. And there are really 20 

### only three manufacturers that do not use blade 21 

### attachments, and of the major players in the 22210

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### industry, there is only one. So they are much 1 

### more common in the industry to have than to not 2 

### have. 3 

### MR. JASINSKI: Thanks. Yeah, we 4 

### appreciate that and we appreciate any data that 5 

### you can provide. If you were paying close 6 

### attention, you could see how repetitive I get in 7 

### saying that DOE is not currently aware of, and 8 

### things to that nature. So DOE is not making the 9 

### statement that these -- they're not concluding 10 

### that these technologies are not commercially 11 

### available or that they don't improve efficiency. 12 

### It's mostly we're dependent on what information 13 

### we can gather that's either through public means 14 

### or, as we'll talk about later, there's other 15 

### mechanisms through manufacturer interviews that 16 

### are protected under NDA, things to that nature. 17 

### So if you are aware of commercially 18 

### available products that use the technologies that 19 

### were screened out, or have information about how 20 

### they impact efficiency, cost, all of those 21 

### things, the Department would really appreciate 22211

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### that, and those things can be considered in the 1 

### next iteration of the analysis. 2 

### MR. TABER: I have a couple more. Sorry. 3 

### This is my world. 4 

### MR. BROOKMAN: Please. 5 

### MR. TABER: Fans with fewer blades is 6 

### screened in, in this case. In previous slides it 7 

### was screened out, for all of the other 8 

### technologies, primarily due to a lack of 9 

### available data, as there is no standard method of 10 

### test in the circulator fan industry, and every 11 

### company kind of does their own thing. Also, as 12 

### the only manufacturer that makes fans with 13 

### different blade counts, it's surprising that the 14 

### DOE was able to find reliable information that 15 

### shows that fewer blades actually increase 16 

### efficiency. 17 

### Again, it goes back to the more holistic 18 

### approach of the number of blades does not 19 

### determine the efficiency. Cord width, angle of 20 

### attack, blade attachments, all paired with the 21 

### number of blades determine, I may go with a 22212

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### smaller number of blades but a wider cord for a 1 

### specific fan. For another fan, I may go with a 2 

### larger number of blades and a narrower cord, with 3 

### a more steep angle of attack. It all depends on 4 

### the fan to determine what the optimum efficiency 5 

### is, and I think including it here while excluding 6 

### it for the others is a little concerning. 7 

### MR. JASINSKI: I believe, in this 8 

### particular case, DOE was able to find two models 9 

### that were identical, aside from blade count. Did 10 

### we test those, or did we get the performance 11 

### information from spec sheets, Aris? 12 

### MR. MARANTAN: Aris Marantan, Navigant. 13 

### We got that from spec sheets. We did identify 14 

### specific set of fans from the same manufacturer 15 

### with different blade counts. 16 

### MR. TABER: As the only manufacturer that 17 

### does different blade counts, that would be 18 

### typical of one product model out of an entire 19 

### industry. 20 

### MR. JASINSKI: So you're saying it's not 21 

### typical? 22213

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### MR. TABER: I would say it would be a 1 

### gross generalization of something that may or may 2 

### not always be true. 3 

### MR. JASINSKI: Okay. Thanks. 4 

### MR. TABER: Sorry. I'm trying to think - 5



### - 6 

### MR. BROOKMAN: Okay. Moving on. 7 

### MR. JASINSKI: Thanks. I'll hand it over 8 

### to Aris to talk about the engineering numbers. 9 

### MR. BROOKMAN: Dick has a comment before 10



### we move on. 11 

### MR. UPTON: I'm not an engineer, number 12 

### one. You're speaking significantly of your 13 

### commercial product, are you not? 14 

### MR. TABER: Christian Taber, Big Ass 15 

### Solutions. Well, I guess one of the other things 16 

### that's in here is the statement that HVLD fans 17 

### are only used in industrial settings. Generally 18 

### speaking, the DC motored fans -- for example, our 19 

### Isis or Element or Essence lines are not 20 

### necessarily industrial fans. The smaller21 

### diameter, high-volume, large-diameter can be used 22214

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### in commercial more than industrial. The high1 

### volume, large-diameter 16-, 18-, 20-, 24-foot, 2 

### those are primarily industrial environments, so 3 

### it kind of depends. 4 

### Noise is also a concern for us. It is 5 

### not necessarily a concern in our industrial 6 

### product lines, but one of the primary reasons 7 

### that we don't use geared motors with VFDs in some 8 

### of our products is that they are going into 9 

### acoustically sensitive spaces, so if there are 10 

### noise concerns with small-diameter fans going to 11 

### fewer blades, there would also be concern on our 12 

### part for large-diameter fans going to fewer 13 

### blades for noise, for the commercial side of our 14 

### product lines. 15 

### MR. UPTON: You answered my comment. 16 

### Significantly commercial? 17 

### MR. TABER: It depends, but yeah. 18 

### MR. UPTON: Application. 19 

### MR. TABER: For the smaller fans, it 20 

### would be generally be more of the commercial 21 

### line, and for the larger fans, it would be more 22215

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### the industrial line. 1 

### MR. BROOKMAN: Okay. Thank you. 2 

### MR. MARANTAN: Thank you, Sam. Okay. 3 

### Now that we've discussed the screening criteria 4 

### and what remains, we conduct the engineering 5 

### analysis from those remaining technologies. So 6 

### we call those the design options that are part of 7 

### the next analysis, which is engineering. 8 

### Okay. The purpose of the engineering 9 

### analysis is to determine the relationship between 10 

### manufacturer's selling price and efficiency. The 11 

### methodology consists of five steps, which are 12 

### outlined on this slide. The first step is to 13 

### choose product classes and representative sizes. 14 

### These are the ones that are to be analyzed. The 15 

### second step is to select baseline efficiency 16 

### levels. These are based on common features and 17 

### bottom-of-the-market efficiency. 18 

### The third step is to identify higher 19 

### efficiency units. So for each representative 20 

### product class and size, we identify the 21 

### efficiency and cost of more efficient units, 22216

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### based on design option modeling, product testing 1 

### and teardowns. 2 

### The fourth step is to develop efficiency 3 

### levels for the analysis, that range from the 4 

### baseline all the way up to max-tech, and the 5 

### fifth step is to determine the cost-efficiency 6 

### relationship. So the results of engineering 7 

### analysis is a set of cost-efficiency curves, in 8 

### terms of MSP versus efficiency, for each product 9 

### class and representative size analyzed. These 10 

### cost-efficiency curves are then used as inputs to 11 

### the subsequent economic analysis, such as the 12


### LCC. 13 

### I'll begin by describing the analysis 14 

### conducted for low-volume first, and then we'll 15 

### get into the analysis for high-volume after that. 16 

### Okay. The first step consists of 17 

### choosing product classes and representative 18 

### sizes. For low-volume ceiling fans, two products 19 

### classes and five representative size were 20 

### identified. These are standard fans in 44 21 

### inches, 52 inches, 60 inches, and hugger fans in 22217

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### 44- and 52-inch sizes. These representative 1 

### sizes were chosen because they broadly represent 2 

### the range of sizes available in each product 3 

### class. Also, manufacturers stated that these 4 

### sizes represent a large percentage of the sales 5 

### and shipments for low-volume ceiling fans. 6 

### So I'll pause here if there are any 7 

### comments on this table of representative sizes 8 

### and classes. 9 

### MR. TURNER: David from Hunter. We would 10 

### agree with that assessment, that those are the 11 

### most widely used blade diameters. Yes, shipped, 12 

### sold, imported. 13 

### MR. MARANTAN: Okay. The second step 14 

### consists of selecting baseline efficiency levels. 15 

### Because there is currently no performance 16 

### standards for ceiling fans, just design 17 

### requirements, currently, baseline efficiency 18 

### levels were selected based on common features and 19 

### bottom-of-market efficiencies. However, in 20 

### conducting the analysis, we found that the most 21 

### common types of ceiling fans on the market was 22218

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### not the least efficient. 1 

### Most low-volume ceiling fans on the 2 

### market, and most ceiling fan sales, consist of 3 

### fans with four or five flat blades that are made 4 

### of wood or wood composites like plywood or MDF, 5 

### and also have single-phase induction motors. 6 

### However, the least efficient fans on the market 7 

### consist of unconventional blades, which, for 8 

### example, are ones shaped like palm leaves. Fans 9 

### with unconventional blades are generally less 10 

### efficient than similarly sized fans with flat 11 

### blades. 12 

### So, because unconventional-blade fans 13 

### tend to have lower performance characteristics 14 

### but serve a specific market niche, the cost and 15 

### efficiency of both types were analyzed 16 

### separately. The results of both types were then 17 

### combined to create an aggregate curve. We chose 18 

### to use an aggregate curve for flat and 19 

### unconventional-blade fans, as opposed to defining 20 

### two separate product classes, because fans with 21 

### flat blades and fans with unconventional blades 22219

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### are functionally indistinguishable. Both fan 1 

### types move air via the rotation of blades, 2 

### improve comfort by this air movement, and can be 3 

### used in similar spaces. Further, since flat 4 

### blade and unconventional-blade fans on the market 5 

### appear to operate within the same CFM range, they 6 

### both have the same product capacity. 7 

### So, again, I'll pause here for any 8


### comments. 9 

### MR. BROOKMAN: Marianne. 10 

### MS. DIMASCIO: If we could insert my 11 

### earlier comment in here, this is what I was 12 

### talking about, the palm blades. When you said 13 

### airfoil, I misspoke. So I was talking about 14 

### this. 15 

### MR. CYMBALSKY: I went the other way on 16 

### it. 17 

### MS. DIMASCIO: Yeah. 18 

### MR. BROOKMAN: Okay. Thank you. 19 

### MR. MARANTAN: Okay. Continuing. This 20 

### slide gives a little more detail on how we went 21 

### about selecting the baseline efficiency levels. 22220

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### The following tables show the efficiencies of the 1 

### market-minimum flat blade and unconventional2 

### blade fans identified in the market. I'd like to 3 

### note that the efficiencies for the hugger product 4 

### class are based on the use of an artificial 5 

### ceiling, as proposed in the test procedure NOPR. 6 

### The efficiencies provided in this table are 7 

### calculated based on an aggregate efficiency 8 

### formula that was also described in that test 9 

### procedure NOPR. 10 

### As described previously, the baseline 11 

### efficiency is the efficiency of the least 12 

### efficient fan identified on the market, for each 13 

### product class and representative size. 14 

### Therefore, the baseline efficiency selected for 15 

### low-volume ceiling fans was identified as the 16 

### efficiency of the market-minimum, unconventional17 

### blade fans. The baseline efficiencies for the 18 

### aggregate curve are circled in the table here. 19 

### So, again, I'll pause here for comments. 20 

### MR. BROOKMAN: Christian. 21 

### MR. TABER: Christian Taber, Big Ass 22221

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### Solutions. So, I just want to make sure I've got 1 

### this straight in my head. The hugger fans were 2 

### tested with a false ceiling, so that's the new 3 

### proposed test method? That's their CFM per watt? 4 

### MR. MARANTAN: Correct. That's the values 5 

### with the asterisks. 6 

### MR. TABER: And then the standard ceiling 7 

### fans were tested via the current Energy Star 8 

### method, or via the new method minus the drop 9 

### ceiling? 10 

### MR. MARANTAN: The values on this table 11 

### are using the current Energy Star method. In our 12 

### TSD, Chapter 5, engineering analysis, we provide 13 

### both. 14 

### MR. TABER: Okay. 15 

### MR. MARANTAN: Okay. Continuing. The 16 

### third step consists of identifying higher 17 

### efficiency units above the baseline. DOE 18 

### identified a selection of fans for analysis that 19 

### spanned a range of the manufacturers and 20 

### efficiencies of commercially available products, 21 

### and incorporate the design options being 22222

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### considered in this rule. The units selected were 1 

### tested and then disassembled for costing 2


### purposes. 3 

### Next, estimates of the factory cost were 4 

### developed for each unit torn down, and a bill of 5 

### materials was developed. This information was 6 

### used to calculate the cost of each individual 7 

### component, for example, blades, motor, motor 8 

### housing, packaging controls, and final assembly. 9 

### Then, component costs and other inputs to the 10 

### cost model were validated against manufacturer 11 

### input. 12 

### Finally, a cost model was developed to 13 

### estimate the factory cost of the fans that were 14 

### not specifically torn down. The models were 15 

### developed such that when design specifications 16 

### for a certain fan are entered, it estimates the 17 

### factor cost, based on the average component costs 18 

### that were developed in the tear-downs. 19 

### I'll pause here. All right. 20 

### The next step in the analysis is to 21 

### develop efficiency levels for the curves. DOE 22223

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### examined each design option being considered, to 1 

### see how much each would increase the efficiency 2 

### and cost of a baseline ceiling fan. From here, 3 

### cost and efficiency deltas were developed for 4 

### each design option. To calculate these deltas, 5 

### we identified fan technology pairs for each of 6 

### the design options, based on a variety of 7 

### sources, including test data, manufacturer 8 

### specifications, retail prices, manufacturer 9 

### interviews, and the tear-down analysis. 10 

### A fan technology pair is a pair of 11 

### ceiling fans in the same product class with the 12 

### same blade diameter, where one fan possesses a 13 

### particular design option being considered, while 14 

### the other fan does not, and all other features 15 

### remain the same in both fans. We tested at least 16 

### one fan technology pair for each design option, 17 

### and used the results to calculate the change in 18 

### efficiency, or efficiency delta, and the change 19 

### in cost, or cost delta, for that particular 20 

### design option. The efficiency and cost deltas 21 

### were then compared to and combined with catalog 22224

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### data and input from manufacturers to arrive at a 1 

### final estimate of the efficiency improvement 2 

### attributable to that design option. 3 

### So, you can see here, at the bottom of 4 

### this slide, the design options, in terms of 5 

### increasing efficiency deltas, were determined to 6 

### be (1) fan optimization, (2) larger direct-drive 7 

### motor, and (3) a DC motor. 8 

### MR. BROOKMAN: Bill. 9 

### MR. WALKER: Bill with Hunter Fan. So, 10 

### for the larger direct-drive motors, can you 11 

### expand a little bit on what size motor you went 12 

### from to what size motor you went to? 13 

### MR. MARANTAN: I don't remember exactly 14 

### the sizes that were used. We could look that up 15 

### for you. I can get -- 16 

### MR. BROOKMAN: Do you have -- does this 17 

### not make sense to you, or is it -- 18 

### MR. WALKER: Well, one consideration I 19 

### would have, just going to a larger motor, (1) 20 

### you're going to increase your tip speed. Do you 21 

### know that you stayed within the tip speed 22225

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### requirements of UL when you went to the larger 1


### motor? 2 

### MS. KUMAR: This is Mythri Kumar from 3 

### Navigant Consulting. Yes, we kept within the tip 4 

### speed of the UL. 5 

### MR. WALKER: Okay, and then the first 6 

### question, what size motor did you go from and to? 7 

### Do you know? 8 

### MS. KUMAR: We went from 153-15 to a 172- 9 

### 14. 10 

### MR. WALKER: 153-15 to a what? 11 

### MS. KUMAR: 172-14. 12 

### MR. WALKER: 172-14. 13 

### MS. KUMAR: But we also used efficiency 14 

### delta information from manufacturer interviews 15 

### and combined both our test results, and those 16 

### results we got from manufacturer interviews to 17 

### come up with the efficiency delta. 18 

### MR. BROOKMAN: Okay. Yes. Dave. 19 

### MR. GATTO: Dave Gatto, Westinghouse. 20 

### Just while you've got that information available, 21 

### did you record the wattage at each motor size? 22226

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### MS. KUMAR: This is Mythri Kumar from 1 

### Navigant Consulting. Yeah. Yes, we did. We 2 

### recorded both the CFM and wattage. 3 

### MR. GATTO: Do you have that in front of 4 

### you? It's okay if you don't. Just -- 5 

### MS. KUMAR: How about I look it up and 6 

### get back to you? 7 

### MR. GATTO: Yeah. I don't have a problem 8 

### letting her get back. 9 

### MR. BROOKMAN: That's okay. Okay. 10 

### David? 11 

### MR. TURNER: David with Hunter. Aris, 12 

### can you take us through exactly what's included 13 

### in fan optimization, the different items? 14 

### MR. MARANTAN: Sure. For the fan 15 

### optimization, we considered that manufacturers 16 

### would make small adjustments to existing fans 17 

### that they already produce, and these would 18 

### include things such as changing the blade pitch 19 

### and adjusting the RPM of the fan rotation, so 20 

### very nominal changes. 21 

### MR. WALKER: You said adjusting the RPM, 22227

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### just redesigning the motor? Or adjusting RPM 1 

### how? 2 

### MR. MARANTAN: Well, I think we're not 3 

### exactly sure what the manufacturers would choose 4 

### to do, in terms of that, but what we've heard was 5 

### small adjustments such as that would be 6 

### considered. 7 

### MR. BROOKMAN: Yes, please. Chuck. 8 

### MR. MATTHEWS: Chuck Matthews, Matthews 9 

### Fan Company. I know, with our product, we've 10 

### always tried to produce as much CFM as possible, 11 

### but once you increase the angle of the blade iron 12 

### to the -- once you increase the angle of the 13 

### blade iron, you would also increase heat rise on 14 

### the motor, and then you run afoul of UL rules and 15 

### guidelines, and CSA also. So it's not a question 16 

### of just increasing blade iron pitch. If that 17 

### were the case, we would've already done that. 18 

### But sometimes we're already operating at the 19 

### highest level, the highest pitch we can, so that 20 

### our motors operate safely. 21 

### MR. BROOKMAN: Okay. Thank you. Yes. 22228

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### Additional comments here? Bill. 1 

### MR. WALKER: Hunter just agrees with 2 

### that. It is a tradeoff there. 3 

### MR. BROOKMAN: Okay. 4 

### MR. MARANTAN: Okay. The last step 5 

### consists of determining the cost-efficiency 6 

### relationship. DOE created two separate cost7 

### efficiency curves by applying the efficiency and 8 

### cost deltas for each design option to the cost 9 

### and efficiency values of the market-minimum fans. 10 

### The first point in the curve represents the 11 

### market-minimum fans, and each subsequent point 12 

### represents design options applied to the baseline 13 

### design. 14 

### As mentioned earlier, two cost-efficiency 15 

### curves were developed, based on the two market16 

### minimum low-volume ceiling fans, one for 17 

### unconventional blades and one for flat blades. 18 

### This was done for each product class and 19 

### representative size. Unconventional blade fans 20 

### make up about 2 percent of the market while flat21 

### blade fans make up about 98 percent of the 22229

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### market. These relative market shares were then 1 

### used to aggregate the two cost efficiency curves 2 

### into a single curve for each product class and 3 

### representative size. 4 

### The resulting efficiency levels for the 5 

### aggregate curves are shown in the table here, and 6 

### I also have a graphic on the next slide. This 7 

### slide shows, graphically, how the two individual 8 

### curves were aggregated. The green curve 9 

### represents the unconventional-blade fans, which 10 

### are 2 percent of the market; the red curve 11 

### represents the flat-blade fans, which represent 12 

### 98 percent of the market; and the black curve 13 

### represents the aggregated curve, which is based 14 

### on the relative weightings of the green and the 15 

### red curve. 16 

### You'll see here that the baseline 17 

### efficiency level of the aggregate curve is the 18 

### least efficient fan on the market, and the max19 

### tech efficiency level of the aggregate curve is 20 

### the maximum efficiency of the unconventional21 

### blade fans. 22230

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### MR. GATTO: Dave Gatto, Westinghouse 1 

### Lighting, and I want to preface this with I don't 2 

### have an objection to the curve itself, but I 3 

### would ask DOE, did you consider that the 4 

### potential, when you aggregate this way, the 5 

### unconventional-blade options may not be able to 6 

### meet the standard, which would remove a 7 

### decorative utility? 8 

### So, again, I don't really have a -- from 9 

### a Westinghouse Lighting standpoint, it's more of 10 

### a, how did DOE bake that in, the fact that 11 

### there's a utility there that you recognize 12 

### consumers want, that potentially could be weeded 13 

### out because of the way you did the aggregate 14 

### curve. And I actually agree with the math. I'm 15 

### saying how did you account for that, or did you? 16 

### MR. CYMBALSKY: We did. Actually, I can 17 

### answer this question. I was actually there and 18 

### was drawing the plot. So, yes, we did exactly do 19 

### that with this graph. So, as Aris pointed out, 20 

### you could see that the max-tech actually 21 

### represents the unconventional-blade, for that 22231

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### reason. That's how we preserved the utility. 1 

### MR. BROOKMAN: Additional thoughts, 2 

### comments? We're going to keep moving then. 3 

### MR. MARANTAN: Okay. Since research 4 

### indicated that low-volume ceiling fans are 5 

### manufactured overseas, a factory markup of 1.2 6 

### was used to calculate the manufacturer production 7 

### cost, or MPC. This was determined based on DOE 8 

### experience with other rules that involve units 9 

### produced overseas and sold into the United 10


### States. 11 

### Next, a manufacturer markup of 1.37 was 12 

### determined, based on an examination of data 13 

### obtained from publicly traded ceiling fan 14 

### manufacturers, and an aggregation of data from 15 

### manufacturer interviews. This markup was applied 16 

### to the MPC to calculate the manufacturer selling 17 

### price, or MSP. Using this analysis, DOE was able 18 

### to determine a set of cost-efficiency 19 

### relationships for each design option in the form 20 

### of MSP versus efficiency and CFM per watt, for 21 

### each product class and representative size. 22232

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### MR. GATTO: Dave Gatto, Westinghouse 1 

### Lighting. Sorry. Just a question. I know I 2 

### provided a lot of information, and I'm sure the 3 

### others did, to Mythri, or whoever you work with 4 

### on the manufacturing interview. So, 1.2, does 5 

### that include the, was it 4.7 tariff, or are you 6 

### leaving that out, because, currently, ceiling 7 

### fans are subject to a duty that applies on top of 8 

### the factory cost. 9 

### MR. MARANTAN: We did not leave it out 10 

### but that's not part of the 1.2. It's part of the 11 

### distribution channel. 12 

### MR. GATTO: So, I'm not sure what that 13 

### means. The MPC is -- 14 

### MS. ARMSTRONG: It's in the markup 15 

### analysis. 16 

### MR. MARANTAN: It's the next section of 17 

### the analysis. 18 

### MR. GATTO: Okay. Thanks. 19 

### MR. MARANTAN: Okay. This slide shows 20 

### example results of the engineering analysis. DOE 21 

### plotted the efficiency and aggregated CFM for all 22233

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### representative sizes at each efficiency level and 1 

### connected the points with straight lines. The 2 

### resulting graph shows the baseline efficiency 3 

### level, with the various candidate standard levels 4 

### above the baseline as a function of fan diameter. 5 

### And I will note that we have a series of tables, 6 

### also, in Chapter 5, Section 10 of the TSD, that 7 

### describes all the results for every product class 8 

### and representative size. 9 

### MR. CYMBALSKY: This is John at DOE. So, 10 

### we're going to push the fast-forward button here. 11 

### We're going to flip a little bit, but, from what 12 

### I heard, there are some stakeholders who want to 13 

### make comments on the prices. Can you skip to 14 

### Slide 129, please? 15 

### Okay. So we just did the engineering 16 

### analysis for this product, as we're going to go 17 

### back, but I think it's appropriate now to bring 18 

### up what we think about the installed costs for 19 

### the options that you just saw. So, here they 20 

### are. You can look at the numbers, and this is, I 21 

### think, where some folks wanted to comment, if I 22234

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### understood correctly. 1 

### So, I wanted to give you that 2 

### opportunity. We're after two o'clock now, so 3 

### we'll just open it up here. 4 

### MR. TURNER: Can you explain -- so, I 5 

### think yesterday when we were going over -- this 6 

### is David from Hunter -- when we were going over 7 

### the light kits, the cost delta between the 8 

### different efficiency levels was just, on light 9 

### kits, it was just the bulbs and the associated 10 

### hardware that would make it LED, which was the 11 

### CSL category. So, the difference between EL3 and 12 

### 4, I guess, what changes with the fans, so that 13 

### we know that -- how do you get to the 120 to 149? 14 

### MR. MARANTAN: EL4 is the efficiency 15 

### level for a DC motor, and so it's just the 16 

### incremental difference between a DC motor and the 17


### AC motor. 18 

### MR. TURNER: So that's the only 19 

### difference between the two efficiency levels? 20 

### MR. MARANTAN: Yeah, and then that's 21 

### marked up throughout the distribution chain, as 22235

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### well, so there's markups along the distribution 1 

### channel, and that's how we arrive at the 2 

### installed costs. 3 

### MR. TURNER: So that's a retail 4 

### difference of $29? 5 

### MR. MARANTAN: The numbers you see here. 6 

### MR. BROOKMAN: Yes. Nathan. 7 

### MR. FRAMPTON: Nathan with Fanimation. 8 

### The difference isn't just AC versus DC, though, 9 

### right? It's EL2 plus DC? 10 

### MR. BROOKMAN: Correct. It's additive. 11 

### MS. KANTNER: Can I provide a quick 12 

### clarification? EL4 doesn't represent DC motors 13 

### for all fans. It only represents for those that 14 

### have unconventional blades. Most fans at EL4 15 

### have AC motors, right? 16 

### MR. MARANTAN: Yes. It represents the 17 

### aggregation that we did in that last step, as 18 

### well. 19 

### MR. WALKER: I'm confused, all of a 20 

### sudden. 21 

### MR. TURNER: I'm very confused. 22236

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### MR. BROOKMAN: If you go back to 90 -- 1 

### MR. TURNER: I'm on 90. 2 

### MR. BROOKMAN: And then you see EL3 is 3 

### EL2 plus larger direct-drive motors, and EL4 is 4 

### EL2 plus DC. 5 

### MR. TURNER: Just to clarify, is EL2 6 

### something that's an existing product, or did you 7 

### take an EL1 product and make modifications? 8 

### MS. ARMSTRONG: I think what you're 9 

### asking is, we start up -- they're cumulative, 10 

### right? This is what this shows. So, if you're 11 

### asking, we take a baseline product. We would 12 

### then modify it each step of the way, and the cost 13 

### deltas you see are the deltas with respect to 14 

### those designs. 15 

### MR. TURNER: Right. I understand that. 16 

### So, on EL2, is that a modification that the DOE 17 

### tested, or is that a product that exists on the 18 

### market? 19 

### MR. MARANTAN: The EL2 is based on EL1 20 

### plus the fan optimization deltas that were 21 

### calculated in the previous step, so those deltas 22237

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### were based on an examination of products with and 1 

### without that particular design option. 2 

### MS. ARMSTRONG: So products on the market 3 

### today. 4 

### MR. BROOKMAN: Yes, please. Marianne. 5 

### MS. DIMASCIO: Marianne DiMascio, ASAP. 6 

### So, based on Colleen's comment about EL4, saying 7 

### that that is really for the unconventional 8 

### blades, I guess I'd ask my question again, of why 9 

### wouldn't you have separate categories for 10 

### unconventional blades and regular blades, or 11 

### classes? 12 

### MR. CYMBALSKY: So that goes back to the 13 

### utility issue, where we combined the curves. 14 

### MS. DIMASCIO: Right. Is there an answer? 15 

### MR. BROOKMAN: He thought he answered it. 16 

### MR. CYMBALSKY: It's one curve. 17 

### MS. DIMASCIO: Right. Is there a reason 18 

### you would not have two separate classes there, 19 

### one for the unconventional blades and then one 20 

### for the others? 21 

### MS. ARMSTRONG: I think we felt that this 22238

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### was the right way to do this, so obviously that's 1 

### out for thought. 2 

### MR. CYMBALSKY: Yeah. You can comment on 3 

### that, but I think this way, actually preserves 4 

### the utility from the unconventional blades. 5 

### MR. BROOKMAN: Clark. 6 

### MR. LINSTONE: I'm sorry. I'm still not 7 

### -- Clark Linstone, Lamps Plus. I'm still not 8 

### clear on just, for DC motor with conventional 9 

### blades, that is under EL -- what? 10 

### MR. CYMBALSKY: If you go back to the 11 

### graph where you -- yeah, that. So we're looking 12 

### at the black line here. So you could see the end 13 

### of the black line is what EL4 represents. 14 

### MR. FRAMPTON: They use green to get to 15 

### black, but there's no red. 16 

### MS. ARMSTRONG: I mean, black is so 17 

### closed to red, but -- 18 

### MR. BROOKMAN: Okay. Thank you. 19 

### MR. CYMBALSKY: Now let's return to Slide 20 

### 129, and get your thoughts, comments on these 21 

### cost figures. 22239

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### MR. GATTO: I'm going to encourage other 1 

### fan guys to chime in, but I'm just going to say 2 

### that because I was confused when I reviewed this 3 

### in the original document, when I first reviewed 4 

### it, because I kind of had that same perception of 5 

### how the ELs were calculated, so, the one comment 6 

### I would make is that I think the installed cost 7 

### for EL0 is probably 30 to 40 percent high. I 8 

### think what's missing there, because I don't 9 

### believe Navigant received any direct information 10 

### from the two largest retailers, is there's a 11 

### large segment of volume that's associated with 12 

### fans that are direct factory to the two largest 13 

### retailers. 14 

### You may have captured the efficacy of 15 

### those fans by looking at market data, but I don't 16 

### know that you captured the installed cost, 17 

### because the sheer volume that those two, or even 18 

### if you count three, the way you guys had it laid 19 

### out in the TSD, that would shift that needle 20 

### down. I think $107 might be appropriate if 21 

### looked at the fan manufacturers represented here, 22240

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### but I don't think it represents the market, if 1 

### that makes sense. 2 

### MR. CYMBALSKY: John with DOE. So if I 3 

### go to Home Depot and I bought the baseline unit, 4 

### and have somebody install it for me, you think 5 

### it's not $107? 6 

### MR. GATTO: So, I was under the 7 

### impression that you were not including 8 

### installation cost, in terms of contractor cost, 9 

### that it was -- 10 

### MR. CYMBALSKY: This is just the off-the11 

### shelf cost. Okay. 12 

### MR. GATTO: Yeah, so I could be wrong, 13 

### John, so could Navigant confirm that it's off14 

### the-shelf cost versus installed with contractor 15 

### cost, because that might change my answer. 16 

### MS. KANTNER: Colleen Kantner, Lawrence 17 

### Berkeley National Lab. I can confirm that that 18 

### did not include installation costs. 19 

### MR. GATTO: I think this came up in the 20 

### earlier one, where the exposure to DYI product, 21 

### and we agreed, as an industry, that you would 22241

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### leave it out of the installed cost. 1 

### MR. CYMBALSKY: So this is the retail 2 

### price. 3 

### MR. GATTO: That being the retail, I 4 

### don't know what the right number is, but I think 5 

### if you went to Home Depot, you wouldn't 6 

### necessarily, for that low-efficiency fan, pay -- 7 

### I hate to say anywhere close, but it would 8 

### probably be $30, or possibly more, less. 9 

### MR. CYMBALSKY: We'll go to the one in 10 

### Manhattan and we'll see how much it costs. 11 

### MR. GATTO: I don't have a response that 12 

### I can give on the record. 13 

### MR. BROOKMAN: Additional thoughts on 14 

### these cost figures. Yes, please. Clark. 15 

### MR. LINSTONE: Clark Linstone, Lamps 16 

### Plus. I think Dave Gatto's point is very 17 

### important, because the sheer volume of the lower18 

### cost fans is very significant in this market. 19 

### We're retail and kind of the mid and higher price 20 

### points, but everything we've seen, in terms of 21 

### just the sheer volume at the lower price points, 22242

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### it's very significant to this discussion. 1 

### MR. BROOKMAN: Okay. 2 

### MR. CYMBALSKY: This is John from DOE. 3 

### So, do you think the whole curve shifts down, or 4 

### are you just focused on the lower ELs here, such 5 

### that the spread would be bigger, or are we 6 

### talking about shift in the curve? 7 

### MR. GATTO: Dave Gatto, Westinghouse 8 

### Lighting, and that's why I kind of spoke it the 9 

### way I did, John. I don't know that I have the 10 

### answer to that. I think the lower end, 11 

### particularly EL0, because that's the baseline, I 12 

### think that would definitely shift it. It might 13 

### not shift much at 1, but it might a little bit if 14 

### you factored them in, because they do have quite 15 

### a bit of $99 fans that are probably at that EL1 16 

### level. I think, at the top end -- and I'm going 17 

### to loudly encourage my competitors, my 18 

### compatriots -- I'm just going to use a different 19 

### word here -- 20 

### [Laughter.] 21 

### MR. GATTO: -- to chime in. I think at 22243

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### EL4, now that I understand that EL3 and 4 are 1 

### direct-drive with optimization and DC, I think 2 

### those numbers are probably low. I think what you 3 

### really have is a bell curve, and the bottom end 4 

### is a little high and the top end is a little low. 5 

### But it may be a lot high or a lot low on the top 6 

### end, and you guys really have to weigh in here. 7 

### MR. BROOKMAN: David. Oh, go ahead. 8 

### Nathan, go ahead. 9 

### MR. FRAMPTON: This is Nathan with 10 

### Fanimation. I agree. I think EL0 is too high, 11 

### and I think EL4 is too low. 12 

### MR. BROOKMAN: If you can -- is it 13 

### possible to say what you think it is? 14 

### MR. FRAMPTON: I mean, right here I'd 15 

### just be, not guessing, but I'd rather do that in 16 

### a formal comment. 17 

### MR. BROOKMAN: Doug. 18 

### MR. TURNER: This is Dave from Hunter. 19 

### I'm with Nathan. I'd rather do that in a written 20 

### comment, but I can say that EL4, the lowest 21 

### retail DC motor fan on the market, the lowest, is 22244

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### $149, and if that's being used as -- I mean, 1 

### everything else is, well, it ramps up from there, 2 

### I guess, so I don't think that should be used as 3 

### the, kind of the baseline for EL4, because it's 4 

### the lowest available right now. 5 

### MR. CYMBALSKY: Clarification there. So, 6 

### you're saying there -- but there is one that is 7 

### $149? 8 

### MR. TURNER: I believe so. 9 

### MR. CYMBALSKY: Okay. Thank you. 10 

### MR. BROOKMAN: Nathan. 11 

### MR. FRAMPTON: Nathan with Fanimation. 12 

### The model he's speaking of is a loss leader 13 

### across all factory manufacturer distributor. 14 

### MR. BROOKMAN: Okay. Colleen. 15 

### MS. KANTNER: Hi. I just wanted to 16 

### clarify again that only 2 percent of the fans 17 

### that were included in that price had DC motors, 18 

### at EL4. 19 

### MR. BROOKMAN: Okay. Nathan. 20 

### MR. FRAMPTON: I thought EL4 was DC 21 

### motors, so wouldn't all in that category be DC 22245

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### motor? 1 

### MS. KANTNER: Colleen Kantner, Lawrence Berkeley 2 

### National Lab. That was only for the 3 

### unconventional blades. 4 

### MR. MARANTAN: I can clarify here. If we 5 

### go back to Slide 90, 91, you'll see here, on the 6 

### black curve, the top end is EL4. That particular 7 

### point represents the top end of the green, which 8 

### is the 2 percent that Colleen was speaking of, 9 

### that had the DC motors, and 98 percent of the red 10 

### at that point, which do not. 11 

### MR. GATTO: Dave Gatto, Westinghouse 12 

### Lighting. I think that if EL4 requires a DC 13 

### motor with a palm blade -- as, an example, 14 

### unconventional blade -- and I'm going from 15 

### looking at what the metrics were and plugging it 16 

### into some calculators, I think the concern I 17 

### would have is that setting the standard that a DC 18 

### motor fan with an unconventional blade can meet, 19 

### I agree with DOE that preserving the utility is 20 

### important, even though it's only a small 21 

### percentage of the marketplace. 22246

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### I think that averaging the price of that, 1 

### unless your EL4 is a CFM per watt that a non-DC 2 

### motor fan could hit with a flat blade, then that 3 

### would be a challenge. That wouldn't make sense 4


### to me. 5 

### So, again, it's more about the analysis. 6 

### So, if a DC motor fan with a flat blade is 7 

### required to hit EL4, then you really need to use 8 

### the weighted average of pricing based on DC motor 9 

### fan, which is what would be needed to meet that 10 

### efficiency level. 11 

### Am I saying that right? I know, John, 12 

### this is one of those things where I may not be 13 

### saying it right, but I think you know where I'm 14


### at. 15 

### MR. CYMBALSKY: Yeah. So, it depends on 16 

### where on that red line the motor swap-out is. 17 

### MR. GATTO: Yes. I agree, I think, but 18 

### if we don't know where that is, then I don't know 19 

### how to say whether that $149 price is 20 

### appropriate, or it's way too low, and I want to 21 

### be able to give valid feedback to DOE, or I think 22247

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### we all do. 1 

### MS. ARMSTRONG: Okay. So I think there's 2 

### a more disaggregated example in the appendix of 3 

### the TSD that I'm going to point you to, where you 4 

### can see the red line and the green line in 5 

### tabular format. So I think that will help get to 6 

### the answer, because it seems like we're blurring 7 

### lines with the weighted average of getting to the 8 

### black line. So this will help you get your -- I 9 

### think get us more, better feedback on what 10 

### designs are implemented where, for discretely, 11 

### for the red line and the green line. 12 

### MR. GATTO: That would be great. 13 

### MS. ARMSTRONG: It's in the appendix. 14 

### So, I don't know exactly, but I'll point you to 15 

### the right direction. 16 

### MR. BROOKMAN: What is it? 17 

### MS. KUMAR: It's Appendix 5A. 18 

### MR. BROOKMAN: 5A. Appendix 5A. Nathan, 19 

### do you want to comment here? 20 

### MR. FRAMPTON: I'm not sure I totally 21 

### understand, but if EL4 is a DC motor with 22248

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### unconventional blades, then the $149 is grossly 1 

### too low. 2 

### MR. CYMBALSKY: No. So, again, it's 2 3 

### percent of that value represents that. Ninety4 

### eight percent represents the point on the red 5 

### line. Okay. So the point way up on that red 6 

### line is the DC motor, the endpoint, so we're 7 

### marching back from that. 8 

### MS. ARMSTRONG: Take a look at the table, 9 

### and if it's still unclear, let us know. I think 10 

### the aggregation of the cost, the weighting of the 11 

### cost, is what's causing confusion. If you were 12 

### to see that the green line was actually, you 13 

### know, double it -- I have no idea what it is, but 14 

### I'm just making something up -- then maybe it 15 

### makes a little more sense to you. 16 

### MR. FRAMPTON: I understand the black 17 

### line. I just don't understand the -- 18 

### MS. ARMSTRONG: Yeah. So, we do it step19 

### by-step to get the green line, and then we do it 20 

### step-by-step to get the red line, and the numbers 21 

### are very different, and then the weighted average 22249

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### is the aggregate of the number that you're 1 

### referencing. So, let's take it back to the 2 

### original table first. 3 

### MR. CYMBALSKY: But we all agree that the 4 

### black line preserves the market for these 5 

### unconventional blades, right? That's the whole 6 

### point here. 7 

### MR. GATTO: Dave Gatto, Westinghouse. I 8 

### think so. I haven't looked at it in that much 9 

### detail, but if it's built the way you've 10 

### described it, I think, yes. I think that was 11 

### what we were hoping for. I have to look at the 12 

### detail, but I appreciate that you went in that 13 

### direction. 14 

### MR. BROOKMAN: Let me note that it's 15 

### 2:25, and if some of you are heading out of here 16 

### at 3:00, then let's keep zeroing in on comments 17 

### that you wish to make, maybe about costs, maybe 18 

### about other things. 19 

### Do you want to comment on the hugger 20 

### results, or do you want to move on to a different 21 

### section? David. 22250

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### MR. TURNER: Is there another section 1 

### where we would make comments on the LCC? 2


### MR. BROOKMAN: Yes. 3 

### MR. CYMBALSKY: The question I have now, 4 

### we could repeat what we just did for the two 5 

### other types, so going through the engineering 6 

### analysis for the high-volume stuff, or we can 7 

### table that and you can all comment on that in 8 

### your written comments, and it's up to everyone 9 

### here, for the sake of time. What makes more 10 

### sense to you guys -- because it's just going to 11 

### be repetitive for the different classes? 12 

### MR. GATTO: Dave Gatto, Westinghouse. 13 

### We'll provide this in written comments. The 14 

### baseline selected for high-volume, small-diameter 15 

### is the only place, I think, we have any comments 16 

### there, was, admittedly, thank you to Navigant, 17 

### most likely because you couldn't find them, but 18 

### we believe the least efficacious product out 19 

### there is 95 CFM per watt, not 231, and we'll 20 

### provide a number of -- it's the 56-inch fan, I'm 21 

### sorry, the 56-inch baseline fan. The majority of 22251

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### sales in that 56-inch fan are just a spinner. 1 

### They're in the $95 to $115 range in the 2 

### marketplace. And there may be higher out there, 3 

### but I'm just saying that, at the least 4 

### efficacious, which was the baseline selection, I 5 

### just think you picked the one that you found at a 6 

### major home center, but that's not really the 7 

### market for these products. 8 

### MR. BROOKMAN: Okay. David. 9 

### MR. TURNER: Sorry. I just know if this 10 

### is the correct spot, and we've addressed it in 11 

### other written comments, but about our concerns 12 

### with DC motor as a mandate. Do we lay those out 13 

### here, or do we just put them in written comments? 14 

### MR. CYMBALSKY: So, there's no proposal 15 

### here. I understand your concerns with the DC 16 

### motor. We've heard them. I want to make it 17 

### clear that we are not proposing any level here. 18 

### All we're showing is what's available on the 19 

### market and what the engineering cost curves look 20 

### like, based on what we've done. Certainly you're 21 

### free to comment and think that that shouldn't be 22252

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### a proposal, but I think, at the proposal stage, 1 

### is where you really come out. If DOE were to 2 

### propose that, then, obviously, you'll have strong 3 

### comment. We're not doing that here. All we're 4 

### showing is, this is the range of possibilities, 5 

### and we're taking comment on the numbers that are 6 

### backing up those range of possibilities. But 7 

### you're free to make that comment, as well. 8 

### MR. TURNER: It might be best in the 9 

### written comment, because I know we're time10 

### pressed. But we will be commenting. I 11 

### understood what you said, though. 12 

### MR. CYMBALSKY: These numbers are just 13 

### numbers, and there's no -- we didn't check a box 14 

### next to the EL or CSL here. 15 

### MR. BROOKMAN: Dick. 16 

### MR. UPTON: Thank you for just keeping an 17 

### open mind, which is what I'm hearing you say, and 18 

### we appreciate that. 19 

### MR. CYMBALSKY: Absolutely. There have 20 

### been no decisions made whatsoever on what the 21 

### standards will be. We are not anywhere close to 22253

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### doing that. 1 

### MR. BROOKMAN: What is the most 2 

### productive thing for us to pursue in the next 3 

### half an hour? 4 

### MR. CYMBALSKY: There are definitely a 5 

### few topics that I think most people -- 6 

### MR. UPTON: What do you want to cover, 7 

### John, while you've got us? 8 

### MR. CYMBALSKY: So, I would say there's 9 

### the whole issue of cooling versus fan use, and 10 

### shipments, are ones that I've heard were 11 

### important to you all. So we can cover that next. 12 

### MR. BROOKMAN: Okay. What slide is that 13 

### about. 14 

### MR. CYMBALSKY: 114. That's right, and 15 

### Aris is standing up there. You don't have to 16 

### stand up there anymore. I think I'll take the 17 

### arrows for this one. 18 

### MS. ARMSTRONG: You don't have to stand 19 

### up there, either. 20 

### MR. CYMBALSKY: Yeah. Okay. So Slide 21 

### 114. We've heard a lot of public comment about 22254

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### the use of ceiling fans and the use of either 1 

### room air conditioning or central air 2 

### conditioning, so we did actually do an RFI on 3 

### this topic in October. We looked at lots of 4 

### different studies out there. I think we worked 5 

### with the industry to try to come up with more 6 

### data on this issue. 7 

### And what we showed yesterday -- we didn't 8 

### really go into shipments yet today, but we showed 9 

### yesterday, I think, and most of you were here, 10 

### that based on the numbers that you saw in the 11 

### previous table, with the costs, DOE does not 12 

### believe there is a significant impact on the 13 

### shipments, based on the numbers that we've seen. 14 

### And so it is DOE's position that if 15 

### shipments are not impacted by the ELs proposed 16 

### here -- and, again, we didn't pick one -- we 17 

### don't see this interaction as being an issue. So 18 

### I'm just going to make that statement and then 19 

### let you guys react to it. 20 

### MR. TURNER: David with Hunter. And this 21 

### might be my inexperience with how these processes 22255

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### go. It's kind of my first one. The EL0 has a 1 

### $42 jump to EL4. Am I reading that right -- 2 

### that's a $42 retail increase over what that 3 

### product is now? I just want to make sure I'm -- 4 

### MR. CYMBALSKY: So, but weighted, based 5 

### on the fact that 98 percent of EL4 in that 6 

### number, I believe will not be a DC motor, because 7 

### we're not at the top of that red line. For 2 8 

### percent it would be, the unconventional blades, 9 

### on that max-tech would have a DC motor, so 2 10 

### percent, and then 98 percent of the product of 11 

### that price, of that weighting, would not, would 12 

### have a more efficient AC, I'm guessing, by where 13 

### it is on the curve. 14 

### MR. TURNER: But the $149 is 15 

### representative of -- it's got the weighting in 16 

### there? 17


### MR. CYMBALSKY: Yes. 18 

### MR. TURNER: So $149 is where the retail 19 

### would end up? 20 

### MR. CYMBALSKY: Right. So of that, 2 21 

### percent of that number would be higher, because 22256

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### it had the DC motor in it, and 98 percent would 1 

### be -- 2 

### MR. TURNER: So $148 is the 98 percent? 3 

### MR. CYMBALSKY: Yeah. Something like 4 

### that. 5 

### MR. TURNER: I guess that would be where 6 

### -- when the statement was made that shipments 7 

### won't be impacted with a large shift in retail 8 

### like that, from a baseline product, or even the 9 

### EL1 of the aggregated market minimum, that's 10 

### where I think the industry disagrees that with 11 

### that big of a retail jump, there is going to be 12 

### an impact in shipments, and based upon the 13 

### studies, one being the LBNL study that certain 14 

### people do offset their AC usage with ceiling 15 

### fans, that there will be a shipment impact, and, 16 

### therefore, an energy offset. 17 

### MR. CYMBALSKY: What I'm understanding 18 

### from your comment is that you see -- we're going 19 

### to just talk room AC here. Does that simplify 20 

### it, window units, or -- 21 

### MR. TURNER: Uh -- 22257

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### MR. CYMBALSKY: Because you're talking 1 

### about shipments, right? So people are going to 2 

### either purchase a ceiling fan -- 3 

### MR. TURNER: My offset was, instead of 4 

### purchasing a ceiling fan, they would use their 5


### HVAC -- 6 

### MR. CYMBALSKY: Whatever is already 7 

### installed in their house. 8 

### MR. TURNER: Mm-hmm. And, Colleen, I 9 

### don't know if you can comment. That's what this 10 

### would be, correct? This is from the LBNL study, 11 

### the impact on air conditioning usage? Yeah. 12 

### MR. CYMBALSKY: So it really comes down to 13 

### -- so if we, so, we -- okay, so back to Slide 14 

### 129. So you're saying that at EL4, and I'm just 15 

### going to look at the top table, the difference of 16 

### $42, you'd say, would do what to shipments? We 17 

### think it's negligible, so you think what would 18 

### happen? If it's a million units -- what would 19 

### happen? 20 

### MR. TURNER: Rather than throwing a 21 

### number at you right now, we'd like to probably 22258

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### present something in written comments, and then 1 

### we also kind of talked about potentially trying 2 

### to get you sell-through data to show what that 3 

### true $107 or baseline product is, because the 4 

### home centers haven't been represented, or their 5 

### sell-through hasn't been necessarily represented, 6 

### because there are a lot of direct-from-factory. 7 

### So, when that $107 may not be a true number, so 8 

### then, if it drops $20 to $30, then that jump to 9 

### $148 or $149 would be even large. 10 

### I don't want to just throw a number out, 11 

### as far as a percentage drop in shipments, but we 12 

### would certainly like to get more information, 13 

### hopefully, to you in our written comment. But I 14 

### think that's our -- at least that's, you know, I 15 

### don't want to speak for everybody, but that's my 16 

### disagreement, that shipments wouldn't be impacted 17 

### at all, and based upon the -- I'm looking at the 18 

### LBNL study now -- but based on a few other 19 

### studies, there would be an offset of people using 20 

### their HVAC more. 21 

### MR. CYMBALSKY: Only if they don't buy 22259

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### the ceiling fans, -- 1


### MR. TURNER: Correct. 2 

### MR. CYMBALSKY: -- so let's put aside 3 

### that second impact first. I want to focus on the 4 

### shipment. So, let's just say EL3. Forget about 5 

### EL4 for now. Let's step back. So that's a $13 6 

### difference in cost to the consumer. Do you think 7 

### a $13 delta retail cost is going to impact, 8 

### significantly impact the shipments of ceiling 9 

### fans? 10 

### MR. TURNER: Maybe. 11 

### MR. SMITH: Hey, John, Van Smith. Maybe 12 

### you could just help us understand the analysis 13 

### here. I'm looking at the TSD and it says, for 14 

### example, a relative price increase of 10 percent, 15 

### which would be maybe $13, results a 3.4-percent 16 

### decrease in shipments. So, that's on 9-16 of the 17 

### TSD. Can you walk us through how -- 18 

### MR. CYMBALSKY: So, that's right. That's 19 

### the number that we think it is, and I'm saying -- 20 

### so that's a 3 percent. I'm asking for your input 21 

### on that. I'm hearing Dave say it's a big impact 22260

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### to the shipments, and you read the number we 1 

### have, so we're asking for comment on that, I 2 

### think, right here. 3 

### MR. SMITH: Okay. So I read that 4 

### correctly and I see that that results in 3 5 

### million reduced units later on in the same 6 

### chapter of the TSD, so we would think that's 7 

### significant, that those units, the absence of 8 

### those units would have a potential impact on air 9 

### conditioning usage for homes that would otherwise 10 

### have those units. 11 

### MR. CYMBALSKY: And, so, of those 3 12 

### million, all those 3 million homes already have 13 

### air conditioning? 14 

### MR. SMITH: I'd have to go back and look. 15 

### According to the RECS data, I think a large 16 

### portion of them do. 17 

### MR. CYMBALSKY: I thought the other -- 18 

### John from DOE again. So the other comment was 19 

### about the low-income, so I just want to make sure 20 

### we cover all the topics that you raised. I'm 21 

### assuming that this impact's probably focused on 22261

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### the lower side of the market. Correct? 1 

### MR. GATTO: Dave Gatto, Westinghouse, 2 

### and, yeah, I think that's where I was, John, that 3 

### if that $107 is overstated, and the low-income 4 

### market's actually purchasing at, say, $69, then 5 

### the delta is much larger than we, than is 6 

### represented here. So, I don't know that I would 7 

### necessarily disagree, and even if I did, I 8 

### couldn't provide data to back it up with a 9 

### fractional that Mohan covered yesterday, the 10 

### fractional impact. 11 

### I think what happens is that if we're 12 

### analyzing a 10-percent reduction but it's really 13 

### a 10-percent price premium and it's really a 40- 14 

### percent pricing premium, that would change that 15 

### 3-point to whatever. I would probably, honestly, 16 

### since I know it's coming from a lot of aggregated 17 

### data over a lot of decades, I would probably 18 

### agree with what the percentage that was used. I 19 

### think the challenge is if that EL0 number is not 20 

### accurate, then that fractional increase is much 21 

### bigger than what we're calculating. Does that 22262

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### make sense? 1 

### MR. CYMBALSKY: Yep. I understand that. 2 

### So to make an analogy, so room air conditioners, 3 

### I see in a similar situation here where they're 4 

### used by a similar set of -- the impact you're 5 

### worried about, I think, is the same. So -- and 6 

### we've gone through several rounds of standards 7 

### with room air conditioners, and we didn't see 8 

### this phenomenon, so I guess I'll just throw it 9 

### out there to the people at the table, why ceiling 10 

### fans would be different than room air 11 

### conditioners. I think they're serving a similar 12 

### market. 13 

### MR. BROOKMAN: Don Brundage. 14 

### MR. BRUNDAGE: Well -- Don Brundage, 15 

### Southern Company -- I'm not a manufacturer, but, 16 

### intuitively, I think, as we've discussed, your 17 

### low end, if you raise it by $15 or so, your low 18 

### end product goes from, perhaps, $60 to $75, and I 19 

### think, to me, ceiling fans do a different 20 

### substitutionary effect than room air 21 

### conditioners, because room air conditioners are 22263

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### not really to supplement the, to use instead of 1 

### the central air conditioning. 2 

### They're to solve a specific need for a 3 

### specific location that's not served by central 4 

### air, added-on room, or that sort of thing, where 5 

### you really don't have air conditioning. You're 6 

### not choosing to put on a central air or put on a 7 

### room air conditioner. You've got a place that 8 

### doesn't have a central air or has a room that's 9 

### not connected to central air. So a ceiling fan 10 

### is not going to have the same substitutionary 11 

### effect there that a room air conditioner would. 12 

### You're really looking at ceiling fans 13 

### being used as a substitute on some days for 14 

### central air, or to run central air at higher 15 

### temperatures. So I think it's a little 16 

### different, and the market will drop. 17 

### The other important thing is that you are 18 

### using less energy with a ceiling fan than you 19 

### would with a room air conditioner. You're 20 

### probably using more energy for the same amount of 21 

### BTUs of cooling with a room air conditioner than 22264

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### you would with a central system. So the 1 

### substitutionary effects hurts overall energy 2 

### consumption. If you get rid of the ceiling fans, 3 

### you're going to end up using more energy, so 4 

### saving a few percent on the efficiency of a 5 

### ceiling fan is going to hurt overall energy 6 

### consumption if the central air runs more. Thank 7


### you. 8 

### MR. BROOKMAN: Christian. 9 

### MR. CYMBALSKY: Can I respond to that? 10 

### MR. BROOKMAN: Please do. John, please. 11 

### MR. CYMBALSKY: Okay. So if -- in your 12 

### estimation, what would be the delta monthly cost 13 

### on the electricity bill for someone who did what 14 

### you just described? 15 

### MR. BROOKMAN: Christian? 16 

### MR. TABER: I can answer that one, kind 17 

### of, sort of. So, the Cal Berkeley study that I 18 

### usually reference for this would be roughly a 5- 19 

### percent decrease in air conditioning costs per 20 

### degree of Fahrenheit rise. So a typical 21 

### residential ceiling fan in a space can provide 22265

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### anywhere from 3 to 5 degrees of cooling via 1 

### elevated air speed, so you'd be looking at 15 to 2 

### 25 percent less energy consumption if you reset 3 

### your thermostat appropriately. I don't know what 4 

### the dollar amount is that works out to. That can 5 

### be done with RECS data. Off the top of my head, 6 

### my guess would be, I don't know, $60, $100 a 7 

### year, something like that, depending. 8 

### Also, to answer an earlier question, 87 9 

### percent of homes in the United States have air 10 

### conditioning, according to RECS. 11 

### MR. CYMBALSKY: So, $60, so that's -- 12 

### MR. TABER: If you asked me to hold to 13 

### that number, I definitely wouldn't, but that's a 14


### guess. 15 

### MR. CYMBALSKY: I'm just trying to do the 16 

### math in my head, how much a 15 -- in a summer 17 

### month, let's say, and let's say what you're 18 

### saying is true, this low-income person, in the 19 

### first month and a half, maybe, depending on how 20 

### hot it is, would spend more on their electricity 21 

### than they would on the incremental cost of this 22266

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### EL3. So that's the economic decision. 1 

### MR. BROOKMAN: Colleen. 2 

### MS. KANTNER: Colleen Kantner, Lawrence 3 

### Berkeley National Lab. I just wanted to provide 4 

### a little context to that 13 million drop in 5 

### shipments. That's out of cumulative shipments, 6 

### over 30 years, at a total of about 486 million, 7 

### so it's a 3-percent drop. 8 

### MR. BROOKMAN: Okay. Thank you. 9 

### Additional thoughts on this topic of low income? 10 

### That's one you raised earlier as being something 11 

### that you thought was important to cover. Dick? 12 

### MR. UPTON: You ought to go back to the 13 

### issue for the low-end purchaser, and I don't know 14 

### the answer, so it's a question. What's the 15 

### increased factor cost for that entry-level, as 16 

### opposed to low-term savings on energy? Do they 17 

### see a payback, or do they just see the opening 18 

### additional cost, that's the impact, and so they 19 

### walk away, as opposed to realizing, hey, for the 20 

### more efficient product I'm going to save that 21 

### amount of money over X amount of time? 22267

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### MR. CYMBALSKY: Right. So what I'm 1 

### seeing, again, back to Slide 129, is -- and I'm 2 

### not saying, we're not proposing anything. This 3 

### is just -- there's a phrase for this and I'm not 4 

### going to say it on the record, but this is just 5 

### for fun. 6 

### [Laughter.] 7 

### MR. CYMBALSKY: So, EL3 -- I'm just 8 

### saying EL3 -- it's a 1.8-year simple payback. 9 

### So, if they pay the extra $13, you know, this 10 

### pays back in 1.8 years, and the life of the fan 11 

### is 13.8. So, I'm just relating this to other 12 

### rules that we do. That's a pretty low payback 13 

### for the lifetime. Sometimes we have rules where 14 

### you have 10-year payback and 15-year life, so, I 15 

### mean, this one, for that EL level -- and, again, 16 

### this is just for an example. 17 

### MR. UPTON: My question really goes to 18 

### Southern's comment of what's the barrier for -- 19 

### damn, the price has gone up, and they don't even 20 

### see X years out, at all. It's just the immediate 21 

### price increase for them. 22268

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### MR. CYMBALSKY: No. I think that the 1 

### subgroup analysis, when we do it -- we haven't 2 

### done that yet; we described that yesterday -- 3 

### certainly DOE understands that the low-end 4 

### people, that there is a cash constraint and that 5 

### is an issue. I guess the point I was making, 6 

### based on what we heard, was that if there is a 7 

### big switch in -- let's say their ceiling fan 8 

### happened to fail on a month right when this 9 

### standard kicked in, and let's just assume it was 10 

### a $13 difference, and assume it was a foregone 11 

### purchase of a new ceiling fan. My question was, 12 

### how much more are they paying in cooling if they 13 

### do what I just heard they would do? 14 

### I know these numbers don't match my math, 15 

### but I was just doing it in my head. It would 16 

### seem to me, in a couple of hot summer months, if 17 

### people react the way you said they would react, 18 

### they would have already made their money back by 19 

### purchase a ceiling fan. 20 

### I guess I said that in a convoluted way 21 

### the first time, so I wanted to clarify the logic 22269

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### in my head, based on what you were saying. 1 

### MR. BROOKMAN: David. 2 

### MR. TURNER: Dave from Hunter. My 3 

### comment, that, which, I agreed that when you look 4 

### at it from a holistic standpoint like that, but 5 

### then a lot of the studies have found that it's 6 

### not necessarily people setting their AC from 70 7 

### to 72, 73. It's that they're not setting it from 8 

### 70 to 68, because they're kind of subconsciously 9 

### being more comfortable but not setting their AC 10 

### down. So, they may not know that, oh, man, I 11 

### could have recouped the cost of that if I'd have 12 

### made that purchase. Does that make sense? I'm 13 

### probably saying in a convoluted way. 14 

### MR. CYMBALSKY: No. This is a very 15 

### sticky issue, obviously. That's why we're 16 

### talking about it. I guess what I'm saying is 17 

### that -- look. We understand the low-income 18 

### impact and we want to obviously get it right. 19 

### From what I heard, in terms of what the reaction 20 

### would be if they didn't have a ceiling fan, I 21 

### guess my reaction back is that that same low- 22270

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### income person, in 6 weeks' time, when they get 1 

### their next electricity bill, will say, "Holy you2 

### know-what, I should've spent that 15 bucks." 3 

### Maybe. This is just the logic in my head, based 4 

### on what I'm hearing here. 5 

### So, I don't want to talk about the 6 

### interaction, the interplay. I want to really 7 

### stick to the shipments, because without that 8 

### issue, the other issue goes away, right? So I 9 

### want to really focus on, let's get that right. 10 

### What is that shipment rebound, if you will, based 11 

### on the $13 or $29, or whatever the price 12 

### difference is. 13 

### Here we have the first ELs, no price 14 

### difference at all, so I think we could all agree 15 

### if the consumer doesn't see a price increase 16 

### there will be no shipment change. So it's just 17 

### looking at EL3 and EL4 in this example. These 18 

### are the comments. We want to get this right, so 19 

### this is why it's a healthy conversation to have 20 

### here. 21 

### MR. BROOKMAN: Don Brundage. 22271

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### MR. BRUNDAGE: Well, I agree with what 1 

### you say. The other aspect of it is low-end 2 

### consumers are not going to have access to the 3 

### data we have here, or probably have the analytic 4 

### talent that's in this room to analyze it. It may 5 

### be more like, I don't have the extra money. But 6 

### I'm not saying that we wouldn't, that it's not 7 

### reasonable, if these numbers work out to be 8 

### valid, to do a 1.8 payback. I mean, that's below 9 

### the 3-year payback prescriptive test that you've 10 

### got to find some really good reason not to accept 11 

### it. 12 

### But with the substitutionary effects on 13 

### other air conditioning, I would not support 14 

### pushing up to the sort of things you do on other 15 

### rulemakings lately, up into the high single-digit 16 

### paybacks. I think it is reasonable to hold it 17 

### down, to try to keep the price increase from 18 

### going up too much, but it's hard not to justify a 19 

### 1.8-year payback to go ahead and do it. Thank 20


### you. 21 

### MR. CYMBALSKY: And then just one last 22272

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### comment I have on the low-income, and I'm not 1 

### going to disagree with anything that's been said, 2 

### but I think the low-income people actually are 3 

### the same people who might not be able to afford 4 

### high electricity bills, month to month, and that 5 

### they tend to be conscious of that. So, to the 6 

### extent that they don't have the ceiling fan, what 7 

### we need to ask ourselves is, on their behavior, 8 

### they still know they can't afford the electricity 9 

### bill either, so, you know, we've got to think 10 

### this through holistically. And I think, for the 11 

### high-end consumers, you know, $13 or whatever it 12 

### is -- 13


### MR. BROOKMAN: Dave. 14 

### MR. GATTO: Dave Gatto, Westinghouse. 15 

### Yeah, John, I agree with you, and, again, I've 16 

### said it before. I come to applaud DOE for 17 

### looking at it. A 1.8 payback period is well 18 

### reasonable, and I think that even at the median 19 

### and upper-level income levels it's a nominal 20 

### difference, and they understand the math, in a 21 

### lot of cases. So we appreciate where you're at. 22273

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### I think where I would leave it is, you've 1 

### given us clear acceptance that if we can provide 2 

### the information needed to adjust the calculation, 3 

### which is really what's going to drive the 4 

### shipment difference, I don't know, as an 5 

### industry, that we can provide that without some 6 

### help from other stakeholders that so far have not 7 

### provided the information. I don't know that we 8 

### can give you legitimate data that would tell you 9 

### what that price sensitivity is, but I do think 10 

### that there's enough data on hand that if you came 11 

### back with a proposal that included, as you did 12 

### here, that as long as we're in agreement with the 13 

### underlying installed cost base, we're probably 14 

### going to agree with what the rebound effect is, 15 

### in terms of price sensitivity. 16 

### So I didn't want to suggest that we 17 

### didn't agree with your number. It's more of a, 18 

### your starting point, I think, it's throwing the 19 

### number off. 20 

### MR. CYMBALSKY: That's a great comment, 21 

### and we'll obviously take it in at the next phase. 22274

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### Anything else on this topic? I know it 1 

### was one we wanted to cover. Okay, thanks. 2 

### MR. BROOKMAN: Any other topics that we 3 

### wish to raise before people start heading out the 4 

### door? Dave. 5 

### MR. TURNER: Dave from Hunter. Just with 6 

### the new AcuPOLL data, which we'll submit in 7 

### written comment. That might affect the payback 8 

### period if the costs come down, and that's what 9 

### we're going to exhibit. But, yeah, we'll submit 10 

### it for your full viewing. It's difficult to go 11 

### over if you guys haven't seen it yet. 12 

### MR. BROOKMAN: Colleen. 13 

### MS. KANTNER: Colleen Kantner, Lawrence 14 

### Berkeley National Lab. When you submit the 15 

### average fraction of time at each speed, it would 16 

### be very helpful if you provided some of the raw 17 

### data, because we like to use that data to build 18 

### the energy use distributions that are used in the 19 

### LCC analysis, and it would be helpful for those 20 

### things to be consistent. 21 

### MR. TURNER: Sure. I'm sure we own that 22275

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### data, since we paid for the survey, so I should 1 

### be able to get it to you. 2


### MS. KANTNER: Great. 3 

### MR. BROOKMAN: Christian? 4 

### MR. TABER: Christian Taber, Big Ass 5 

### Solutions. At some point, I would like to 6 

### discuss energy use characterization of high7 

### volume, large-diameter fans, but since I'm the 8 

### only one in the room that's interested in that, 9 

### it doesn't have to be now. 10 

### MR. CYMBALSKY: Right, and I definitely 11 

### had a feeling you were going to say that. So I 12 

### think -- I just wanted to get a lot of the bigger 13 

### cross-cutting topics out of the way. 14 

### MR. BROOKMAN: Let me take an actual 15 

### poll. How many of you need to leave at 3:00 or 16 

### 3:15, or so. One, two. How many of you need to 17 

### leave at 3:30? How many of you need to leave at 18 

### 4:00? 19 

### So what I'm going to suggest -- let me 20 

### see. It's now almost -- 21 

### MR. CYMBALSKY: Can I raise my hand? 22276

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### [Laughter.] 1 

### MR. BROOKMAN: Yeah. It seems like most 2 

### of the folks that have participated in the 3 

### conversation all day long are going to still be 4 

### here at four o'clock. It's now 10 minutes until 5 

### 3. We got back from lunch at one. Maybe we 6 

### should take a short break, and then maybe we 7 

### should try and pick up where we left off with the 8 

### slides, at page 90, and go rapidly, just kind of 9 

### page through them, and then we'll stop for 10 

### anybody that wishes to make a comment along the 11 

### way. Okay? 12 

### So let's take a short break. Let's take 13 

### a 10-minute break, and we'll resume at three 14 

### o'clock, and for those of you that need to leave 15 

### us, we're so glad you could join us, and the 16 

### Department looks forward to receiving all your 17 

### detailed comments. And we'll resume at three 18 

### o'clock, here in the room. At 3:05. 19 

### [Recess taken from 2:53 to 3:07 p.m.] 20 

### MR. BROOKMAN: If we go back to 90, is 21 

### that you? Aris? 22277

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### MR. MARANTAN: Yes. 1 

### MR. CYMBALSKY: So, we were going to 2 

### resume where we kind of broke off, in the 3 

### engineering, but I'm going to propose, unless 4 

### someone really wants to talk about the details, 5 

### that are essentially repeating what we just did, 6 

### for the two other types, if it's more 7 

### constructive for everybody's time, I would 8 

### suggest we just skip over. I know there were 9 

### some questions about the energy use portion of 10 

### the deck, and unless anyone has any objections, I 11 

### would propose to kind of just go to that, Section 12 

### 6, so that would be after the markups. So 13 

### starting on Slide 109. Any objections? 14 

### Seeing none, why don't we do that, and 15 

### I'd ask Colleen and whoever else is presenting, 16 

### just try to hit the high points and get through 17 

### this in quick order. I've got gloves. I'm 18 

### renting it. They work with your cell phone, too. 19 

### They have the little things on it. 20 

### [Laughter.] 21 

### MS. KANTNER: Colleen Kantner, Lawrence 22278

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### Berkeley National Lab. The purpose of the energy 1 

### use characterization is to develop distributions 2 

### of annual energy consumption representative of 3 

### purchasers in the U.S., where annual energy use 4 

### is the site energy use associated with operating 5 

### the product, and these distributions are used in 6 

### the LCC and payback period analyses. 7 

### So we develop purchaser samples, we 8 

### develop distributions of operating hours at each 9 

### speed, and then determining energy use is fairly 10 

### straightforward from that. To account for 11 

### variability in energy consumption, DOE develops a 12 

### Monte Carlo sample of 10,000 purchasers. Low13 

### volume ceiling fans are assumed to be in the 14 

### residential sector. DOE believes that some low15 

### volume ceiling fans are installed in commercial 16 

### settings, but that the hours of use for these 17 

### fans would be similar to the hours of use for 18 

### ceiling fans in residential settings. Purchasers 19 

### were drawn randomly from the set of households in 20 

### RECS that use ceiling fans. 21 

### High-volume ceiling fans were assumed to 22279

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### be used in the commercial and industrial sectors 1 

### only. 2 

### The operating hours used were from a 3 

### survey of ceiling fan owners performed by 4 

### Lawrence Berkeley National Lab, with an average 5 

### of 6.45 hours per day. I think we've talked 6 

### about the fraction of time at each speed a fair 7 

### amount already, so I'll skip over that. And then 8 

### DOE sampled from census-division-specific hours 9 

### of use distributions for each ceiling fan in the 10 

### Monte Carlo sample. 11 

### For high-volume ceiling fans, there were 12 

### not a lot of publicly available data, so we used 13 

### feedback from manufacturer interviews. We 14 

### assumed an average of 12 hours per day, and the 15 

### way that was broken out was we assumed that 80 16 

### percent of the time is spent at medium speed, 10 17 

### percent of the time was spent at high speed, and 18 

### 10 percent of the time was spent at low speed. 19 

### And since we didn't have any data to suggest 20 

### otherwise, we assumed that there was no 21 

### difference in operating hours, either by 22280

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### geographic location or season. 1 

### The power during operation for low-volume 2 

### ceiling fans came from engineering analysis, and 3 

### I just wanted to clarify that, in theory, the 4 

### energy consumption of multi-mount ceiling fans 5 

### depends on both the potential standard for the 6 

### hugger and standard product classes, but for this 7 

### preliminary analysis, DOE assumed that when 8 

### analyzing a given efficiency level for the 9 

### standard product class, an equivalent standard 10 

### was in place for the hugger product class, and 11 

### vice versa. 12 

### MR. BROOKMAN: Yes. Okay. Keep going. 13 

### MS. KANTNER: For high-volume ceiling 14 

### fans, the power at high speed was provided by the 15 

### engineering analysis, and DOE used ratios between 16 

### speeds from the low-volume engineering analysis 17 

### to determine power at low and medium speed. This 18 

### meant that medium was assumed to represent 53 19 

### percent of high-speed power, and low speed 23 20 

### percent of high-speed power. If anyone has 21 

### comments on those numbers, we're happy to hear 22281

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### them. 1 

### MR. BROOKMAN: Christian. 2 

### MR. TABER: Christian Taber, Big Ass 3 

### Solutions. My comments are going to kind of mix 4 

### the last two slides together. So, to look at 5 

### this, what I did was take 53 percent of high6 

### speed power and I translated that into percent of 7 

### maximum RPM. Fifty-three percent of maximum 8 

### power roughly translates to 80 percent of maximum 9 

### speed, and 23 percent of high-speed power 10 

### translates to roughly 60 percent of maximum 11 

### speed. So if you can go back up a slide. 12 

### So, the way that that would work out is 13 

### that 10 percent of the time the fan is running at 14 

### maximum RPM, 80 percent of the time it is running 15 

### at 80 percent of maximum RPM, and 10 percent of 16 

### the time it is running at 60 percent of maximum 17 

### RPM. For a 20-foot, large-diameter fan, 80 18 

### percent of maximum speed is going to generate 19 

### anywhere from 200 to 300 feet per minute of air 20 

### speed, which is going to be roughly a 10-degree 21 

### cooling effect. 22282

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### To assume that in the winter a 10-degree 1 

### cooling effect is desirable is obviously not 2 

### true, so that led me to believe that the fan was 3 

### reversed. There is one manufacturer of high4 

### volume, large-diameter ceiling fans that 5 

### recommends that their fan be reversed. Eighty 6 

### percent operating speed would be typical of their 7 

### recommendation for that operation, but it is not 8 

### typical of the industry. The industry, as a 9 

### whole, with that one exception, recommends 10 

### operating in the forward direction at low speed. 11 

### That would be roughly 25 percent of maximum RPM 12 

### and roughly 5 percent of maximum power. 13 

### So my recommendation would be, if we 14 

### don't want to do any geographical location or 15 

### seasonal difference, that, essentially, 6 months 16 

### of the year we should be running at around 5 17 

### percent of power, so there should be a very low 18 

### speed included in this. I ran through the 19 

### numbers and will provide that in detail comments, 20 

### I believe we actually already have. 21 

### I took Purchaser Index 346 out of the 22283

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### Monte Carlo analysis, and compared this method to 1 

### how we would typically see a fan run. The total 2 

### energy consumption for this scenario was 2,595 3 

### kilowatt hours, which pretty much exactly matched 4 

### DOE's numbers, so I was able to back into that. 5 

### Run the way that we would recommend it, that fan 6 

### would use about 1,139 kilowatt hours, so it's 7 

### less than half of the DOE-calculated numbers. 8 

### So, for one manufacturer, this would 9 

### definitely be true, but for the industry as a 10 

### whole, this would be a gross overestimation of 11 

### our annual energy consumptions. 12 

### MS. KANTNER: And we very much welcome 13 

### any information. 14 

### MR. TABER: You've got all of the 15 

### spreadsheets and all the math, and all that. 16 

### MR. BROOKMAN: That's great. Thank you 17 

### very much. Thank you. 18 

### Additional thoughts along these lines, 19 

### operating hours and power drain operation? 20 

### Nothing additional here? Okay. 21 

### MS. KANTNER: As far as -- we already 22284

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### talked about that one. With regards to standby 1 

### power consumption for low-volume ceiling fans, 2 

### DOE assumed that there was standby for all DC 3 

### fans, which, again, is 2 percent of ceiling fans 4 

### at EL4. DOE also assumed that there was standby 5 

### for all AC ceiling fans that were used with a 6 

### remote control, which DOE estimated to be 7.4 7 

### percent of fans, based on an LBNL study. The 8 

### power consumption during standby was assumed to 9 

### be 1.4 watts, based on manufacturer feedback. 10 

### For high-volume ceiling fans, standby 11 

### power consumption was assumed for all DC-motor, 12 

### small-diameter fans. Standby was assumed for all 13 

### large-diameter ceiling fans, based on the 14 

### variable frequency drive. Power consumption 15 

### during standby was assumed to be 1.4 watts. It 16 

### was assumed to be the same as the power 17 

### consumption in standby for low-volume ceiling 18 

### fans, based on not having better data. 19 

### Ceiling fans with standby functionality 20 

### were assumed to be in standby mode during all 21 

### hours not in active mode, and we welcome comments 22285

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### on all of these. 1 

### MR. BROOKMAN: Christian. 2 

### MR. TABER: Christian Taber, Big Ass 3 

### Solutions. I don't actually have an issue with 4 

### the numbers. I just have an issue with the 5 

### because of variable frequency drive. There are 6 

### high-volume, large-diameter fans that use direct7 

### drive motors. There are standby losses or 8 

### standby energy consumption for those fans, but 9 

### they don't have the variable frequency drive. So 10 

### I think just the striking of "because of variable 11 

### frequency drive" would make it fine. It's just a 12 

### nuance, but there are a lot of fans that don't 13 

### have VFDs. 14 

### MS. KANTNER: So they would all have 15 

### standby, but only some of them have the variable 16 

### frequency drive? 17 

### MR. TABER: Right. 18 

### MS. KANTNER: Okay. 19 

### MR. BROOKMAN: Yes, Dave. 20 

### MR. GATTO: Just one quick question. On 21 

### the small-diameter, what was the percentage 22286

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### breakdown of DC versus non-DC? That part I don't 1 

### remember. It might be in there, and if it is, 2 

### you don't have to chase it down for me. But for 3 

### small-diameter fans -- 4 

### MS. KANTNER: For high-volume, small5 

### diameter fans? 6 

### MR. GATTO: High-volume, small-diameter, 7 

### where you would be calculating standby power. 8 

### MS. KANTNER: We assumed that all the 9 

### ceiling fans that were at EL4 were DC and would 10 

### have standby power. Are you asking about the 11 

### market distribution? 12 

### MR. GATTO: Yeah. Maybe that's what it 13 

### is. What's the percentage you allocated to that? 14 

### MS. KANTNER: Mo, maybe you can help me 15 

### out here. 16 

### MR. GATTO: And if you don't have it 17 

### readily available, I don't mind if we keep moving 18 

### and just circle the data back to me. Sort of 19 

### scrambling over here. Sorry, guys. 20 

### MR. GANESHALINGAM: Hello. This is Mohan 21 

### Ganeshalingam from Lawrence Berkeley National 22287

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### Labs, and I believe, in 2012, when we were 1 

### looking at the data, there were 0 percent. 2 

### MR. GATTO: Thank you. 3 

### MS. KANTNER: I think we talked about 4 

### this topic already. So, here we see energy use 5 

### and energy savings results for a 52-inch, low6 

### volume standard ceiling fan at each EL. Note 7 

### that the numbers in this table represent an 8 

### average of a distribution. The distribution for 9 

### EL3 is presented here, just for illustrative 10 

### purposes, where the red line indicates the mean 11 

### of the distribution. And, as you can see, some 12 

### ceiling fan owners use more or less energy than 13 

### that. 14 

### And here are the energy use results for 15 

### low-volume ceiling fans, with the results for 44- 16 

### inch, 52-inch, and 60-inch standard ceiling fans 17 

### in the top table, and 44-inch and 52-inch hugger 18 

### fans in the bottom table. I just want to note 19 

### that the results for each EL are based on using 20 

### the same purchaser sample and the same hours of 21 

### use, and this is true at all ELs and for both 22288

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### product classes. 1 

### And here are the energy use results for 2 

### high-volume ceiling fans, with the results for 3 

### the high-volume, small-diameter fans with 36 4 

### inches and 56-inch diameters on top, and 8-foot, 5 

### 12-foot, and 20-foot diameters on the bottom. 6 

### I think we've talked about both of these 7 

### things already, so let's move on. 8 

### MR. BROOKMAN: Additions before we move 9 

### on? Okay. 10 

### MS. KANTNER: Next up is the life-cycle 11 

### cost analysis. The purpose of the life-cycle 12 

### cost analysis is to provide an economic 13 

### evaluation from the end-user's perspective. The 14 

### life-cycle cost is the total purchaser cost over 15 

### the life of a product, and the payback period is 16 

### the time required to recover the increased 17 

### purchase price of a more efficient product 18 

### through reduced operating costs. 19 

### The LCC uses the same purchaser samples 20 

### developed in the energy use analysis. The LCC 21 

### determines total installed cost for each EL, 22289

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### operating costs for the first year and the 1 

### lifetime of the product, and then calculates the 2 

### payback period by dividing an increase in 3 

### installed cost by the average decrease in first4 

### year operating costs. 5 

### The LCC is just the sum of the installed 6 

### cost and lifetime operating costs. And I just 7 

### want to note that LCC savings are calculated with 8 

### respect to the efficiency of a product a 9 

### purchaser would purchase in the absence of a new 10 

### standard. 11 

### I think we talked about purchaser samples 12 

### already in the energy use analysis. They're the 13 

### same here. 14 

### We used a distribution of fan diameters 15 

### in the market for low-volume ceiling fans, and 16 

### feedback from fan manufacturers for high-volume 17 

### ceiling fans, to come up with these distributions 18 

### of fans by blade span. Does anyone have any 19 

### comments on this? I'll note that on the high20 

### volume side, there was not a lot of information. 21 

### MR. BROOKMAN: Yes, Dave. 22290

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### MR. GATTO: Dave Gatto, Westinghouse. I 1 

### think on the low-volume it would be in line with 2 

### where I think it would be, but I haven't done the 3 

### analysis. On the high-volume, small-diameter, 4 

### it's really tough. It's probably more like 85/15 5 

### to the 56-inch. Christian, maybe you want to 6 

### weigh in there, but I know it's a much higher 7 

### percentage of the volume that we see in the 8 

### marketplace. That's a guess. 9 

### MR. BROOKMAN: Christian. 10 

### MR. TABER: Christian Taber, Big Ass 11 

### Fans, or Big Ass Solutions. Sorry. I keep 12 

### struggling with that. I would generally say 13 

### that, yeah, if I see a high-volume, small14 

### diameter fan on a project, it tends to be of a 15 

### larger diameter, a lot more than 2-to-1. But 16 

### that's ancillary. That's just what I see pass 17 

### through my desk. And then for our distribution, 18 

### we definitely trend highly to the 20- and 24-foot 19 

### diameter fans. Larger products are, by far, the 20 

### bulk, so that would be representative. 21 

### MR. BROOKMAN: Thank you. 22291

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### MS. KANTNER: Great. Thank you. Again, 1 

### to estimate the average LCC savings of an 2 

### efficiency level, DOE first considers the 3 

### expected market distribution by efficiency level 4 

### in the base case. For low-volume ceiling fans, 5 

### this was largely based on models available in6 

### store. DOE also assumed that the same 7 

### distribution for standard and hugger fans existed 8 

### in 2013, but they differed slightly by 2019, 9 

### based on the consumer choice model that will be 10 

### discussed later in the shipments analysis. 11 

### For high-volume ceiling fans, the 12 

### efficiency distribution is based on models 13 

### available on manufacturer websites. 14


### MR. BROOKMAN: Dave. 15 

### MR. GATTO: Dave Gatto, Westinghouse 16 

### Lighting. The only thing I would say about the 17 

### low-volume percentage of each EL is that, not 18 

### from our own product line but I think if you 19 

### looked at the actual home center units moved, if 20 

### we had that data or if you had that data, I think 21 

### it might shift more to the hugger. That's a 22292

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### guess, but just from the price points that are 1 

### out there, and there's two different product 2 

### types, I would guess that the volume might be 3 

### higher. 4 

### MS. KANTNER: You're talking about 5 

### huggers relative to standard fans, or are you 6 

### talking about ELs within the hugger product 7 

### class? 8 

### MR. GATTO: Really, I'm talking about the 9 

### current EL0, that the current distribution might 10 

### skew towards hugger, due to the unit volume 11 

### associated with the lower-priced products, but it 12 

### is a little bit of a wild guess. But it's just 13 

### based on what we see in the marketplace and where 14 

### we know the consumer choice point is for that 15 

### particular product. 16 

### MS. KANTNER: Okay. 17 

### MR. TURNER: We agree that the lower 18 

### price points are generally huggers, so those sub19 

### $30, $40. 20 

### MR. CYMBALSKY: This is when the standard 21 

### would come into play. 22293

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### MR. TURNER: Yeah. 1 

### MR. CYMBALSKY: So I guess my question to 2 

### the folks around the table is, let's forget about 3 

### 2019 for the moment, but just today, because I 4 

### think we know what we're doing today, do we think 5 

### that these -- 6 

### MS. KANTNER: Hopefully. 7 

### MR. CYMBALSKY: Well, I think. I heard, 8 

### out in the hallway we might be able to get some 9 

### numbers here. Do we think these percentages are 10 

### -- I think what I'm hearing is maybe EL0 and 1 11 

### would have much higher percentages. Did I 12 

### interpret those comments correctly? 13 

### MR. GATTO: Dave Gatto, Westinghouse. 14 

### Yes. I think that's what I'm saying, is that 15 

### because there's some missing data, that I think 16 

### that the results here are skewed towards what we 17 

### know, or what DOE and Navigant knows, but it's 18 

### one of those things where we know we have a 19 

### pretty big gap in our knowledge base for this 20 

### particular topic. 21 

### MR. CYMBALSKY: Right, and my sense in 22294

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### this product -- and correct me if I'm wrong -- is 1 

### that absent a government intervention here, with 2 

### the standard, we think the market wouldn't move 3 

### up without any little extra nudging. 4 

### MR. GATTO: It's tough. At the lower 5 

### end, my personal -- Dave Gatto, Westinghouse 6 

### Lighting -- my personal opinion is it's lower and 7 

### probably not at the median end. We all compete 8 

### with each other, so their efficiency is actually 9 

### one -- this is a similar lamp. This is a place 10 

### where efficiency and high CFM and CFM per watt 11 

### actually plays a role in our ability to compete. 12 

### So we're constantly looking for those 13 

### extra tweaks anyway. So I think in the absence 14 

### of a rule, maybe EL1, but definitely EL2, and I 15 

### think that that's not accurate. But for EL0 and 16 

### 1, it's going to stay right where it is, along as 17 

### there's no change in the standard, because that's 18 

### what drives the price point. 19 

### MR. CYMBALSKY: Right. Got it. 20 

### MR. GATTO: Is that where you were at? 21 

### MR. CYMBALSKY: That's exactly what I was 22295

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### saying. So you'll play in the higher ELs and 1 

### those will shift. But, yeah, I think we're on 2 

### the same page. 3 

### MR. GATTO: Okay. 4 

### MS. KANTNER: Next is the total installed 5 

### cost, and this is just the purchase price 6 

### provided by the markups analysis, and price 7 

### learning is incorporated to account for decreases 8 

### in manufacturing costs, due to production 9 

### experience, by the compliance data, and, again, 10 

### more detail on this is going to be provided in 11 

### the shipments sections. 12 

### Recall that the remote control cost was 13 

### added to 7.4 percent of low-volume AC ceiling 14 

### fans. The remote control was already included in 15 

### the price of DC fans, from an engineering 16 

### analysis. 17 

### Sales tax is also applied, and is 18 

### determined based on the geographic location of 19 

### the purchaser. Installation cost was not 20 

### included because it does not appear to vary with 21 

### efficiency level. 22296

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### Next up is annual energy cost. Annual 1 

### energy consumption was provided by the energy use 2 

### analysis, and electricity prices were estimated 3 

### using data from EIA, and note that estimated 4 

### price varies based on geographic location and 5 

### economic sector. 6 

### MR. BRUNDAGE: Don Brundage, Southern 7 

### Company. I think one of the issues, when we're 8 

### talking about very inexpensive ceiling fans, is 9 

### that low-income consumers are probably more 10 

### likely to do it do-it-yourself and have a zero 11 

### installation cost. I think that's one of the 12 

### factors that's different from your analysis, 13 

### compared to effective low income of making a 14 

### small change in the purchase price. 15 

### So if there was some assumption of a 16 

### larger percentage of being do-it-yourselfer, and 17 

### have a zero installation cost in some of the 18 

### considerations for the low-end market or for 19 

### effect on low-income consumers, that's probably 20 

### reasonable. Thank you. 21 

### MR. BROOKMAN: Thank you. 22297

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### MS. KANTNER: Next we have repair and 1 

### maintenance costs. Maintenance costs were not 2 

### included in the LCC calculation because DOE did 3 

### not find evidence that it varies with efficiency 4 

### level. As far as repair cost, we should first 5 

### clarify that the repair cost we're talking about 6 

### here is the cost to a consumer to repair a 7 

### ceiling fan, because it may cost something to the 8 

### consumer even if it's still under warranty. They 9 

### may still pay to have the fan taken down and put 10 

### it back up after it's fixed. Any costs that 11 

### might be borne by the manufacturer are not 12 

### included here. 13 

### DOE included a repair cost for 6.5 14 

### percent of DC fans, and note that this isn't the 15 

### total number of DC fans that might require 16 

### repair, but the estimated percentage of DC fans 17 

### in excess of AC fans that DOE expected would need 18 

### repair. And this was based on an estimate from a 19 

### ceiling fan industry consultant. 20 

### For low-volume ceiling fans, based on 21 

### feedback from manufacturer interviews, DOE 22298

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### estimated a repair cost of $150, and this was 1 

### assumed to be the same for standard and hugger 2 

### ceiling fans. Since DOE didn't have any data to 3 

### suggest otherwise, DOE assumed that this would be 4 

### the same for high-volume, small-diameter ceiling 5 

### fans. For high-volume, large-diameter ceiling 6 

### fans, DOE estimated a repair cost of $1,000, and 7 

### this was based on estimates of the installation 8 

### costs for these types of ceiling fans. 9


### MR. BROOKMAN: Dave. 10 

### MR. GATTO: Dave Gatto, Westinghouse 11 

### Lighting. I'm not sure how to ask this. So, 12 

### you're estimating the repair cost for more than 13 

### the installed cost of the fan. Is that accurate? 14 

### That's how I'm reading this. Maybe I'm reading 15 

### this wrong. But if the EL0, 1, and 2 are $107 16 

### installed cost, you're estimated the repair cost 17 

### for those models was $150? 18 

### MS. KANTNER: Yeah. I'll note that we 19 

### didn't include installation costs in the cost for 20 

### the ceiling fans. 21 

### MR. GATTO: You're including it here. 22299

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### MS. KANTNER: This is mostly based on an 1 

### installation cost. This is the cost to take it 2 

### down, have somebody fix it, and put it back up. 3 

### MR. GATTO: To have somebody fix it. 4 

### MS. KANTNER: Well, if it's under 5 

### warranty. 6 

### MR. CYMBALSKY: Like swap the motor out, 7 

### essentially? 8 

### MR. GATTO: Okay. That's helpful. I 9 

### think that I'm just going to repeat a little bit 10 

### of where Don was a few minutes ago, that I think 11 

### at the low end, you'd just buy a new one. If 12 

### it's under warranty, we take care of it. If it’s 13 

### not under warranty, there would be no repair 14 

### cost. If you wanted to include replacement cost 15 

### in there, that might make sense. 16 

### MS. KANTNER: And, to note, we didn't 17 

### assume any repair costs in this analysis for AC 18 

### fans. It was only for DC fans where repair costs 19 

### were relevant, so there may be a different 20 

### tradeoff. 21 

### MR. GATTO: Well, then, I don't know that 22300

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### the low-income really applies here. So, thank 1


### you. 2 

### MR. CYMBALSKY: My question to the 3 

### manufacturers is the middle bullet. So they 4 

### assume the second middle bullet. This is 5 

### actually appropriate for ceiling fans. The 6 

### assumed failure would occur in the middle of the 7 

### fan's lifetime. I think people would have strong 8 

### opinions on this, maybe? For a DC fan. So we're 9 

### saying it's, what, a 13.8-year lifetime? 10 

### MS. KANTNER: Yes. It was 7 years in. 11 

### MR. CYMBALSKY: So 7 years in. 12 

### ALLEN ROO: Allen Roo with Emerson. The 13 

### first DC fan we produced was approximately 7 14 

### years ago, and as of yet we've not seen a spike 15 

### in anything, but, at this point, the motor itself 16 

### is not repairable. You basically throw the fan 17 

### away. Under our warranty program, we'll let you 18 

### repurchase a new fan at a negotiated price. If 19 

### it's the controller that's at fault, it is 20 

### repairable. And, basically, you don't have to 21 

### take the fan down. You just repair it on the 22301

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### ceiling. It's a plug-and-play type operation. 1 

### MR. BROOKMAN: Thank you. 2 

### MS. KANTNER: All right. Let's move on 3 

### to lifetime. DOE estimated the lifetime 4 

### distribution from a combination of shipments data 5 

### and the age distribution of ceiling fans found in 6 

### an LBNL study. DOE assumed that the lifetime 7 

### distribution would take the form of a Weibull 8 

### function, and found a mean of 13.8 years. 9 

### Any comments on the lifetime? 10 

### MR. BROOKMAN: We mentioned this before, 11 

### I think, but did we get confirmation on it? The 12 

### lifetime. 13 

### MR. TURNER: David Turner from Hunter 14 

### Fan. We agree with the 13.8 assumption. 15 

### MR. BROOKMAN: Okay. 16 

### MS. KANTNER: How about the assumption 17 

### that the lifetime distribution would be the same 18 

### for high-volume ceiling fans? 19 

### MR. GATTO: Dave Gatto, Westinghouse 20 

### Lighting. For high-volume, small-diameter, the 21 

### warranty return is extremely low. I don't know 22302

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### how to answer that. I think that it's not 1 

### fashion-oriented, but because it's in commercial 2 

### space, the space might change. I think my answer 3 

### last time was I don't have a better number to 4 

### give you. It might be longer than 13.8, but I 5 

### don't have any way to give you a backup for what 6 

### it would be. 7 

### Christian, you may have an opinion, so 8 

### you may have to just go with that. 9 

### MR. TABER: Christian Taber, Big Ass 10 

### Solutions. I'm going to echo, kind of, the I 11 

### don't have a better number to give you. High12 

### volume, large-diameter fans were invented about 13 

### 13.8 years ago -- 14 

### [Laughter.] 15 

### MR. TABER: -- so I don't know. 16 

### MR. BROOKMAN: Okay. They're at the mean 17 

### of their life right now. 18 

### [Laughter.] 19 

### MS. KANTNER: Next is discount rates. 20 

### Maybe we can just skip this slide. We talked 21 

### about discount rates yesterday and they're pretty 22303

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### much the same here. 1 

### And here are the LCC results for low2 

### volume ceiling fans, with standard ceiling fans 3 

### shown in the top table and hugger ceiling fans in 4 

### the bottom table. Again, the results include 5 

### installed costs, which we talked about already, 6 

### first year's operating cost, lifetime operating 7 

### cost, lifecycle cost, and simple payback period, 8 

### which may be compared to the average lifetime. 9 

### And, again, all of these results for each EL 10 

### represent the average outcome if all 10,000 11 

### purchasers in that Monte Carlo sample purchased 12 

### at that EL, and the same sample is used at each 13


### EL. 14 

### The hugger results are pretty similar to 15 

### the standard results. Any comments? 16 

### MR. CYMBALSKY: I think we beat this one 17 

### a little bit. 18 

### MS. KANTNER: And here are the results 19 

### for high-volume ceiling fans, with small-diameter 20 

### ceiling fans show in the top table and large21 

### diameter ceiling fans shown in the bottom table. 22304

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### Any comments? 1 

### MR. GATTO: Dave Gatto, Westinghouse 2 

### Lighting. I think I'm in agreement with this, in 3 

### general, for the high-volume, small-diameter. 4 

### Installed cost, I'm assuming left install cost 5 

### out. You're assuming it's the same at each EL? 6


### MS. KANTNER: Yes. 7 

### MR. GATTO: So then, yeah, I'm think I'm 8 

### okay here. 9 

### MR. BROOKMAN: Okay. Additional 10


### comments? 11 

### MS. KANTNER: Okay. We have a few items 12 

### for comment. DOE requests information and 13 

### comment on the market shares by efficiency level 14 

### for each product class. I think maybe we already 15 

### discussed that one. 16 

### MR. BROOKMAN: I think we've done all of 17 

### them. 18 

### MS. KANTNER: We discussed all of these? 19 

### Okay. 20 

### MR. BROOKMAN: And we've done them as 21 

### we've been going along, as well. So on to 22305

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### shipments. 1 

### MS. KANTNER: All right. Up next is 2 

### Mohan Ganeshalingam, who is going to present the 3 

### shipments analysis and the national impact 4 

### analysis. 5 

### MR. CYMBALSKY: This is John with DOE. I 6 

### propose that Sections 9, 10, and 11, there's 7 

### really -- we'll do closing remarks, but I think 8 

### I'll just say preliminary NIA and NOPR analyses. 9 

### Just stuff for the future. We covered it 10 

### yesterday. There's no reason to go through it 11 

### again. We don't have any information per se to 12 

### present. It's just process stuff. So we'll 13 

### finish up here. I think the shipments, obviously 14 

### we've talked about a lot, but if we need to 15 

### discuss more, let's do it here, and then we'll 16 

### close up for the day. 17 

### MR. BROOKMAN: Okay. Additional thoughts? 18 

### Comments on shipments? 19 

### MR. GANESHALINGAM: All right. Thank 20 

### you. Good afternoon, everyone. I am Mohan 21 

### Ganeshalingam from Lawrence Berkeley National 22306

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### Labs. So, yeah, I'll be covering shipments and 1 

### national impact analysis, or NIA, for short. 2 

### We went over a lot of this yesterday, so 3 

### I'll try to breeze through some of this. The 4 

### purpose of the shipments analysis is to project 5 

### future shipments of ceiling fans over the 6 

### analysis period, from 2019 to 2048. DOE projects 7 

### shipments in the base case and under the impacts 8 

### of a potential amended energy efficiency 9 

### standard. Shipments are then just aggregated 10 

### into product classes and efficiency levels, over 11 

### time. 12 

### DOE's method for estimating shipments 13 

### uses a stock-accounting method calibrated to 14 

### historical shipments data. DOE identifies the 15 

### market segments that drive shipments over time 16 

### and projects their contribution to total 17 

### shipments. In this analysis, DOE accounts for 18 

### shipments due to product replacements, 19 

### installations into new constructions, and 20 

### installations into existing buildings that did 21 

### not previously have a ceiling fan. 22307

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### Shipments are then disaggregated by 1 

### product class and efficiency level, using a 2 

### consumer-choice model to project purchasing 3 

### decisions for each year in the analysis period. 4 

### For low-volume ceiling fans, the consumer-choice 5 

### model assumes consumers are only sensitive to 6 

### first cost, and for high-volume ceiling fans, the 7 

### model assumes consumers are sensitive to first 8 

### cost and operating cost. 9 

### So, just diving a little bit deeper into 10 

### the assumptions that we make in our analysis, 11 

### this table is for low-volume ceiling fan inputs, 12 

### and the data source for those inputs. For 13 

### replacements, DOE used historical shipments from 14 

### Appliance Magazine, NPD, and Energy Star, and 15 

### then applied a retirement function to those 16 

### historical shipments, to derive the number of 17 

### replacements that we shipped in each year. 18 

### New construction, DOE estimated the 19 

### number of shipments to new construction using 20 

### estimates of new housing starts from the Annual 21 

### Energy Outlook 2014, and assumed that 73 percent 22308

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### of new houses were installed with ceiling fans, 1 

### with an average installation of 3.1 fans per 2 

### home. 3 

### For existing buildings, DOE performed 4 

### analysis, looking at the increase of ceiling fans 5 

### found in households between RECS 1993 to RECS 6 

### 2009, indicating that the number of ceiling fans, 7 

### or the fraction of households with ceiling fans 8 

### was increasing with time, but the rate of 9 

### increase was slowing. So, in 2009, that 10 

### saturation was at 73 percent, and DOE put a cap 11 

### at 75 percent for its analysis. 12 

### And for market shares, those are based 13 

### off of model counts from in-store visits and 14 

### online retailers, to derive the current 15 

### efficiency distribution and product class market 16 

### shares. 17 

### For sector usage, estimates from 18 

### manufacturers indicated that about 5 percent of 19 

### low-volume ceiling fan shipments were to the 20 

### commercial sector, or used in the commercial 21 

### sector. However, in our analysis we assumed that 22309

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### there would be similar usage between ceiling fans 1 

### in residential and commercial sectors, so they 2 

### ended up all being analyzed as low-volume ceiling 3 

### fans in the residential sector. 4 

### For market shares by product class, we 5 

### estimated that, from in-store visits and online 6 

### retailer data, we found that about 53 percent 7 

### were multi-mount, 26 percent were standard, 21 8 

### percent were hugger. And then based off of 9 

### results from the AcuPOLL survey, which asked 10 

### about installation configuration of ceiling fans, 11 

### we assumed that 73 percent of the multi-mount 12 

### fans would be installed as standard fans, and 27 13 

### percent would be installed as hugger, and we sort 14 

### of ran with those numbers through our analysis, 15 

### so they were treated as standard or hugger, 16 

### according to those proportions. 17 

### Now, a couple of items for comment. DOE 18 

### estimated that 21 percent of fans are hugger, 26 19 

### percent of fans are standard, and 53 percent are 20 

### multi-mount, and we open this up to comment, and 21 

### if anyone would like to provide us data, that 22310

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### would be very useful. 1


### MR. BROOKMAN: Dave. 2 

### MR. GATTO: I think the only comment I'd 3 

### make - we've covered a lot of this -- is that the 4 

### hugger market share is probably skewed in the 5 

### same manner that we talked about elsewhere, 6 

### because the unit volume -- if you looked at 7 

### there's 100 fans at a particular retailer and 21 8 

### percent of them were huggers, what you might be 9 

### missing is the unit volume associated with the 10 

### five least expensive fans, which are probably all 11 

### hugger. 12 

### So if we can get that, that would be 13 

### great. If not, I don't think we really have 14 

### anything other than anecdotal to give you, to 15 

### change what you did. 16 

### MR. GANESHALINGAM: Okay. Thank you. 17 

### And then, also, for ceiling fan installation 18 

### configurations, DOE requests information 19 

### regarding the similarity of installation 20 

### distributions between all ceiling fans and the 21 

### subset of multi-mount ceiling fans. DOE also 22311

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### requests information or comment on the assumption 1 

### that close-mount ceiling fans should be 2 

### categorized as standard ceiling fans and not 3 

### hugger ceiling fans. 4 

### MR. BROOKMAN: David. 5 

### MR. TURNER: David from Hunter Fan. I 6 

### would agree with the percentage breakdowns you 7 

### have. I assume a lot of it is from the AcuPOLL 8 

### data, which we all pretty much -- 9 

### MR. GANESHALINGAM: So, I think from that 10 

### AcuPOLL data is where we get this 73/27, and I 11 

### think that was assuming that close-mount was 12 

### categorized as standard. 13 

### MR. BROOKMAN: Thank you. 14 

### MR. GANESHALINGAM: So, on to high-volume 15 

### ceiling fan inputs and assumptions. As we 16 

### already discussed, we used the same retirement 17 

### function for high-volume, small-diameter ceiling 18 

### fans as we did for low-volume ceiling fans. To 19 

### get the total number of shipments, we scaled the 20 

### shipments of low-volume ceiling fans by 12 21 

### percent, which assumes a similar penetration of 22312

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### high-volume, small-diameter fans into commercial 1 

### industrial faces, as low-volume ceiling fans into 2 

### commercial spaces. 3 

### I'll stop here for comment, if anyone has 4 

### any on that. 5


### MR. BROOKMAN: Dave. 6 

### MR. GATTO: I'm just going to say that, 7 

### in general, I think I agree with that for the 8 

### same reason we said earlier, that I don't have 9 

### any reason to disagree with it. 10 

### MR. GANESHALINGAM: Okay. Thank you. 11 

### And then for the large-diameter fans, we assumed 12 

### linear shipments trend associated with new 13 

### installations, starting in 2000, when these 14 

### products started to come onto the market, and we 15 

### kept that linear trend out to 2013, to match 2013 16 

### estimate for stock, which I believe was at about 17 

### 50,000. So, we continued to use that linear 18 

### trend as what we expect new installations to be 19 

### over the course of our analysis period, and then 20 

### we factor in the replacements of those fans. 21 

### And we invite comment on that assumption. 22313

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### All right. So, and this is just a 1 

### schematic, showing, essentially, what I've 2 

### already talked about, that we take into account 3 

### the different market segments that feed into 4 

### total shipments, replacements, new construction, 5 

### and new installations. That gives us a total 6 

### shipment, which we then disaggregate using a 7 

### consumer choice model into shipments by product 8 

### class and efficiency level. 9 

### So, the retail price associated with each 10 

### efficiency level will impact projected market 11 

### share over the course of the shipments analysis 12 

### period. DOE accounts for price learning in its 13 

### estimate of ceiling fan prices over the analysis 14 

### period. Price learning is the systematic 15 

### decrease in manufacturing cost due to production 16 

### experience. The idea here being that as the 17 

### cumulative number of units produced increases, 18 

### manufacturers are able to reduce manufacturing 19 

### cost via optimized manufacturing methods and 20 

### economies of scale. 21 

### For ceiling fans, DOE only applied price 22314

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### learning to those ceiling fans which had DC 1 

### motors, and, specifically, only to the electronic 2 

### components associated with the controls in the DC 3 

### motor. The cost for controls were estimated to 4 

### be the incremental cost between a DC fan and an 5 

### AC motor fan. So, for instance, it would be 6 

### between EL3 and EL4, from the engineering 7 

### analysis. That incremental cost is what we would 8 

### apply price learning to, and, in this case, we 9 

### used a price learning rate of 6 percent, which 10 

### was based off of a producer price index for 11 

### semiconductor components and these components 12 

### used in the controls should track the larger 13 

### industry of semiconductor components. 14


### MR. BROOKMAN: Dave. 15 

### MR. GATTO: Dave Gatto, Westinghouse 16 

### Lighting. Just one quick question. So, price 17 

### learning through -- what was the time frame, 18 

### because that bottoms out. 19 

### MR. GANESHALINGAM: Well, I guess -- so, 20 

### you're right. It does flatten out over time. We 21 

### didn't fix it, I guess. 22315

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### MR. GATTO: Okay. I don't know that it 1 

### would represent a really big deal in the 2 

### analysis, but I would just suggest that there's a 3 

### diminishing return there, where it's going to end 4 

### up at a mature price where it doesn't move a 5 

### whole lot. 6 

### MR. GANESHALINGAM: And since we're only 7 

### applying it to that incremental price -- 8 

### MR. GATTO: Oh, I'm sorry. So that's the 9 

### 2 percent of the -- 10 

### MR. GANESHALINGAM: So, I guess -- 11 

### MR. GATTO: All right. 12 

### MR. CYMBALSKY: So it's 6 percent of -- 13 

### MR. GANESHALINGAM: Yeah. It's 6 percent 14 

### of that incremental -- 15 

### MR. CYMBALSKY: Over 30 years. 16 

### MR. GANESHALINGAM: -- of that 2 percent. 17 

### MR. GATTO: All right. Thanks. So it's 18 

### probably nominal, if I took calculator out. So, 19 

### thank you. 20 

### MR. CYMBALSKY: You don't need a 21 

### calculator. 22316

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### MR. GANESHALINGAM: Okay. So, DOE 1 

### adopted a learning rate of 6 percent applied to 2 

### the cost premium associated with a brushless DC 3 

### motor, based on information from a technical 4 

### expert for low-volume ceiling fans. DOE requests 5 

### stakeholder input on the validity of this 6 

### learning rate, as applied to low-volume and high7 

### volume ceiling fans. 8 

### MR. BROOKMAN: I'm thinking we've covered 9 

### this. 10 

### MR. GANESHALINGAM: One item I would like 11 

### to touch on is the magnet used in DC motors. DOE 12 

### requests information on the type of magnet used 13 

### in DC motors and the associated cost of that 14 

### magnet. 15 

### MR. BROOKMAN: Yes. Christian. 16 

### MR. TABER: Christian Taber, Big Ass 17 

### Solutions. I'm not a magnet guy, but we have 18 

### one, and he is going to supply comments and 19 

### details on the magnets we use, the other types of 20 

### magnets, and their relative costs, in his 21 

### opinion. 22317

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### MR. BROOKMAN: Thanks very much. Yes, 1 

### Bill. 2 

### MR. WALKER: Bill with Hunter Fan. I'm 3 

### not a magnet guy, either, but in some analysis 4 

### that we've done lately, recently, we've seen a 5 

### lot of ferrite. Cost-wise, I can't tell you. I 6 

### don't know. But ferrite has been the main one. 7 

### MR. BROOKMAN: Okay. 8 

### MR. GANESHALINGAM: Great. Thank you. 9 

### So, onto the consumer-choice model. The 10 

### consumer-choice model is an econometric model, 11 

### used to estimate market shares for each EL, based 12 

### on consumer sensitivity to first cost and 13 

### operating cost. The model calculates a 14 

### probability a consumer will chose each efficiency 15 

### level by looking at parameters that influence 16 

### consumer decisions. 17 

### In our implementation, the consumer18 

### choice models considers consumer sensitivity to 19 

### first cost for low-volume ceiling fans, and, in 20 

### the case of high-volume ceiling fans, first cost 21 

### and operating cost. And this basically allows 22318

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### for voluntary purchases of more efficient 1 

### technologies. 2 

### For high-volume ceiling fans, the relative 3 

### weighting of sensitivity to first cost and 4 

### operating cost was estimated using the current 5 

### market share distribution for high-volume ceiling 6 

### fans, and for low-volume ceiling fans, the 7 

### sensitivity to first cost was estimated using 8 

### market data from NPD, which gave the distribution 9 

### of sales as a function of retail price. 10 

### So that diagram that you see on the right 11 

### here is the distribution from NPD and the fit, 12 

### which is an exponential fit, is in red, and that 13 

### essentially gives us our sensitivity to first 14 

### cost, which is used in our consumer-choice model. 15 

### If anyone has any comments on that. 16 

### MR. TURNER: On the Issue 33? 17 

### MR. GANESHALINGAM: That and also, I 18 

### guess, just general methodology here. 19 

### MR. TURNER: Well, on the Issue 33, I 20 

### would say, when we say product classes, we're 21 

### talking about hugger, low-volume. Because there's 22319

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### an aesthetic and a style design piece to ceiling 1 

### fans, I think there's definitely some crossover 2 

### with them. Somebody may go in looking for a 3 

### hugger close to the ceiling, but if they find a 4 

### fan that they think fits their home better, 5 

### they'll make it work. I don't know what 6 

### percentage would go to that, but there is some 7 

### crossover between products. 8 

### MR. GANESHALINGAM: Okay. Is that 9 

### something you would imagine changing with time? 10 

### So we have sort of the fraction of market share 11 

### appropriate to hugger versus standard. 12 

### MR. TURNER: Oh, as far as huggers 13 

### becoming more popular or less popular? 14 

### MR. GANESHALINGAM: Yeah, exactly. 15 

### MR. TURNER: No? I mean, the crossover 16 

### effect is still going to be there, going forward 17



### -- 18 

### MR. GANESHALINGAM: Yeah, right. 19 

### MR. TURNER: -- but as far as the overall 20 

### market share of huggers or standard fans, without 21 

### a crystal ball I wouldn't say it's going to 22320

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### change too much. 1 

### MR. GATTO: Dave Gatto, Westinghouse 2 

### Lighting. Yeah, I agree with Dave Turner. I 3 

### think that because when you pick -- like if we 4 

### use the current definition that you're proposing 5 

### at 10 inches, there's a lot of products that are 6 

### really in a narrow band around that. So there's 7 

### some utility reasons people would not switch 8 

### classes. Outside of that, it tends to be more 9 

### decorative, or some other particular function. 10 

### I think rather than product class 11 

### switching -- and you've got it kind of captured 12 

### here -- because of the first cost is really where 13 

### the sensitivity is, I think the consumer choice 14 

### point would not be between classes. It would be 15 

### between buying a fan or not buying a fan. 16 

### MR. TURNER: David from Hunter. 17 

### Actually, I was thinking of, in my brain, of what 18 

### a hugger was. There would probably be a shift to 19 

### huggers at some point, because standard fans 20 

### could potentially roll into the hugger category 21 

### now, versus what we call them today. In my head, 22321

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### that makes sense, because it's a distance-based 1 

### thing. 2 

### MR. GATTO: Dave Gatto, Westinghouse. 3 

### And just to be careful, I made an assumption that 4 

### what you're calling standard and hugger in the 5 

### analysis is based on the proposed definition. 6 

### MR. GANESHALINGAM: That's correct. 7 

### MR. GATTO: Okay. So I think they did 8 

### that, but I didn't actually ask the question, so 9 

### I'm glad you said it that way or I might have 10 

### assumed that, and you were actually using our 11 

### definition in the analysis. So, thanks. 12 

### MR. CYMBALSKY: And, of course, Dave set 13 

### up the last slide of the day with his previous 14


### comment. 15 

### MR. GANESHALINGAM: So the impact of 16 

### standards, DOE expects that an increase in price, 17 

### due to the implementation of an amended 18 

### efficiency standard could lead to a decrease in 19 

### shipments. DOE estimates this impact using a 20 

### relative price elasticity. I think we've talked 21 

### a little bit about this. Another thing we 22322

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### considered is since ceiling fans are often 1 

### packaged with CFLKs, a ceiling fan light kit, a 2 

### CFLK standard will also impact ceiling fan 3 

### shipments, even in the absence of a ceiling fan 4 

### standard. 5 

### So, DOE also includes this impact in its 6 

### analysis, and the range of CFLK standard 7 

### scenarios are considered and the results 8 

### presented in the TSD chapter. 9 

### MR. GATTO: Dave Gatto, Westinghouse 10 

### Lighting. I think we talked about the price 11 

### elasticity within fans, not to death, but 12 

### definitely enough where I think you guys know 13 

### where we're at, and I'm wondering if Ashley 14 

### intentionally let this be the last slide so she 15 

### wouldn't have to be here for them, when she 16 

### pushed me off to today. 17 

### What I would say is that I don't -- and 18 

### it could, in part, John, be because the analysis, 19 

### when you combine them, throws the math off, but I 20 

### think that if you have a four-time increase in 21 

### CFLK pricing and even a moderate increase in fan 22323

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### pricing -- so when you were talking about 10 1 

### percent -- I think that when you look at the 2 

### percentage of the market, 88 percent that are 3 

### packaged with, then what that really would result 4 

### in, to me, is either we would follow that and 5 

### consumers wouldn't buy fans, or, more likely, 6 

### that you'd see fan light kits come off of fan. 7 

### There are two challenges with that. One 8 

### is that that will make consumers unhappy, because 9 

### this thing goes in the middle of a room and 10 

### typically there is a light fixture there. And I 11 

### don't know that this can be analyzed, but the 12 

### corresponding -- I don't know if rebound effect 13 

### is what you would want to call it, but the 14 

### potential energy usage effect of that would be 15 

### that if the fan doesn't have a light, and you 16 

### need to have a light in the room, they're going 17 

### to shift to an alternate light source -- floor 18 

### lamp, table lamp, multiple wall sconces -- 19 

### because the fan is going to take the place of the 20 

### centrally located light source, and because of 21 

### the way the definition is written, you can't make 22324

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### a luminaire that's not a covered product and 1 

### stick it on a fan, because as soon as you do, 2 

### it's CFLK. 3 

### MR. BROOKMAN: Don Brundage. 4 

### MR. BRUNDAGE: I wasn't here yesterday 5 

### for the ceiling fan light kits, but it just seems 6 

### like you're delivering light more efficiently 7 

### from the center, on the ceiling of the room, and 8 

### it's going to take more light if you substitute 9 

### it from floor lamps or luminaires, or whatever. 10 

### I think there's some substitutionary 11 

### effects. I don't really understand the logic of 12 

### even regulating ceiling fan light kits. It's 13 

### just another place to stick a light bulb into. 14 

### You don't regulate the efficiency of a lamp 15 

### somebody sticks on the floor. You regulate the 16 

### efficiency of the light bulbs you could 17 

### potentially put into it. 18 

### MR. CYMBALSKY: It's essentially a lamp 19 

### standard. I know you weren't here. It's a lamp 20 

### standard. They can explain it to you, but it is 21 

### a lamp standard. 22325

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### MR. BRUNDAGE: Okay. 1 

### MR. GATTO: And, Don, we can talk 2 

### offline, but, yeah, I agree with John. 3 

### Basically, DOE did hear us, and they went with a 4 

### lamp standard. I think the challenge that I'm 5 

### proposing back to DOE is that it's a lamp 6 

### standard that's above the current federal lamp 7 

### standard for light bulbs by themselves, so that 8 

### that substitution effect would be that you would 9 

### put a fixture that does not have a regulation on 10 

### what efficacy label you can use, and you'd use 11 

### what's available in the market, which potentially 12 

### could be less efficient -- not suggesting it 13 

### would be. I know the LEDs, we all agree, are 14 

### moving towards adoption. 15 

### MR. CYMBALSKY: Right. I mean, it's the 16 

### bulbs you would use. If you can envision a light 17 

### kit with three lamps in it, are you saying now 18 

### you'd need four fixtures around the room instead 19 

### of three overhead? I think that's what you're 20 

### getting at. 21 

### MR. BRUNDAGE: Yeah. That's what I'm 22326

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### getting at. It's going to require more light to 1 

### inefficiently deliver into probably the corners 2 

### of the room instead of central from the middle, 3 

### directly down onto what you want to illuminate. 4 

### MR. GATTO: Dave Gatto, Westinghouse, and 5 

### I agree with that. I don't know what the effect 6 

### is. I know we don't really have a sense of it. 7 

### I think the thing that I'm trying to impress upon 8 

### DOE is that you're talking about the amount of 9 

### light that you need. What I'm saying is that the 10 

### amount of light that you need is going to be 11 

### produced by a less-efficient light bulb because 12 

### there's no standard on the corresponding product 13 

### that the consumer would select. 14 

### I know you know that. I just want to be 15 

### on the record with it, so we're clear. 16 

### MR. CYMBALSKY: Okay. Anything else on 17 

### shipments, because this is where we're going to 18 

### end for the day. 19 

### MR. BROOKMAN: We covered national impact 20 

### analysis in considerable depth yesterday. So, 21 

### now, anybody that wishes to make closing remarks, 22327

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### final statements about things that we haven't 1 

### covered sufficiently. Chuck. 2 

### MR. MATTHEWS: I'd like to make an 3 

### addendum to Slide 66, a little slow where the 4 

### process goes. Something was said by the woman 5 

### who was sitting here. She thought there might be 6 

### a loophole created for manufacturers to create 7 

### more products if the wing tip speed or the RPMs 8 

### were removed from the highly decorative 9 

### definition. I don't believe so, and I don't 10 

### believe my fellow manufacturing folks here would 11 

### suggest that either, because it's still a very 12 

### small niche market. It's a highly decorative, 13 

### small niche market. The vast majority of 14 

### customers do want high CFMs to come from a 15 

### ceiling fan, and so these particular products are 16 

### few in number, and wouldn't represent any sort of 17 

### advantage loophole if that definition were 18 

### amended to remove the RPMs. 19 

### MR. BROOKMAN: Okay. Thank you. Final 20 

### concluding remarks? Bill. 21 

### MR. WALKER: Bill with Hunter. Just a 22328

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### question, clarification for my benefit. So, 1 

### we've established that the Energy Star test 2 

### procedure is going away as it currently exists, 3 

### and you're proposing the new test procedure, and 4 

### that EPA will come up with the requirements for 5 

### that Energy Star program at some point in time. 6 

### So, fans outside of the Energy Star 7 

### program, or outside of Energy Star requirements - 8 

### - you've got the EL0 through 5, or whatever -- 9 

### and you maybe not can answer this question right 10 

### now, but do you see that there will be efficiency 11 

### levels associated with each fan, and that will be 12 

### on the carton, or do you see that, no, you're 13 

### going to go to a, all fans will be EL2 and that 14 

### efficiency level will be some certain standard 15 

### CFM per watt -- or can you answer that? 16 

### MR. CYMBALSKY: The way we have it set up 17 

### here is each of those product classes would be 18 

### evaluated individually. 19 

### MR. WALKER: Okay. And you would just 20 

### rate it? I mean, if you came in at a certain 21 

### level, you would have an EL1 fan, or whatever. 22329

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### Is that what you're saying? 1


### MR. CYMBALSKY: Sure. 2 

### MR. WALKER: Okay. And just one more, 3 

### important information from Navigant. David 4 

### requested that wattage and CFM per watt. You 5 

### don't have to do it right now, but if I can get 6 

### it after the meeting. 7 

### MS. KUMAR: Yeah, sure. 8 

### MR. WALKER: We can talk after this. I 9 

### think that's important information. 10 

### MR. BROOKMAN: David. 11 

### MR. GATTO: Dave Gatto, Westinghouse 12 

### Lighting. Dick had to leave, but on behalf of 13 

### ALA and the fan manufacturers that were 14 

### participating here, we appreciate DOE's time. We 15 

### definitely appreciate the amount of engagement 16 

### you've allowed, both in the public meeting 17 

### setting and offline conversations. It's very 18 

### encouraging to get the kind of dynamic and dialog 19 

### that you've provided, rather than simply, here's 20 

### what we're doing and figure it out for 21 

### yourselves. So we just want to say thank you. 22330

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### MR. CYMBALSKY: This is John from DOE. 1 

### And I appreciate that, and I think it's a two-way 2 

### street. We engaged in all our rulemakings, and 3 

### the fact here is that you guys engage too. So, 4 

### without that, I don't think we get the level of 5 

### cooperation from each other, so DOE definitely 6 

### appreciates the level of effort that all of you 7 

### went through to read this document. We've seen 8 

### the comments and we really appreciate the level 9 

### of effort and the amount of data that's been 10 

### provided thus far, and I know you'll provide 11



### more. 12 

### We talked about the comment extension, 13 

### and I think we're looking at December 9th. It's a 14 

### Monday. For those of us that work over the 15 

### weekend, that gives you a couple of extra days. 16 

### MR. GATTO: Michael Weems is going to 17 

### email you tomorrow. 18 

### MR. CYMBALSKY: So, again, if there's 19 

### nothing else, thanks, everyone, for coming. We 20 

### really appreciate it. I think it was very 21 

### productive couple of days. 22331

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### [Whereupon, at 4:00 p.m., the Public 1 

### Meeting concluded.] 2

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### CERTIFICATE OF COU RT REPORTER

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### I , Brian Knieser , the officer before whom

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### the foregoing proceedings were taken , do hereby

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### certify that the foregoing pages are a correct

5 

### and accurate transcription of the proceedings

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### that were recorded by me and thereafter reduced

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### to typewriting under my direction ; that I am

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### neither counsel for , related to , nor employed by

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### any of the parties associated with these proceedings

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