Building Technologies Program 1 eere.energy.gov

Public Service of Colorado Ponnequin Wind Farm

BUILDING TECHNOLOGIES PROGRAM

Rulemaking Framework Meeting 

on Energy Conservation Standards 

for Residential Furnace Fans

Mohammed Khan

Department of Energy

Energy Efficiency & Renewable Energy

FurnFans-2010-STD-0011@ee.doe.gov 

June 18, 2010
Building Technologies Program 2 eere.energy.gov

• Introductions

• Role of the Facilitator

• Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; state 

your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introduction
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Agenda

9:00 – 9:05 am

9:05 – 9:15 am

9:15 – 9:20 am

9:20 – 9:50 am

9:50 – 10:00 am

10:00 – 10:45 am

10:45– 11:00 am

11:00 – 11:45 am

11:45 – 12:30 pm

Welcome

Attendee Introductions and Agenda Review

Introduction

Brief Opening Remarks from Interested Parties

Regulatory Authority and Rulemaking Authority

Scope of Coverage and Test Procedures

Break

Test Procedure Continued

Market and Technology Assessment, Screening Analysis, 

and Engineering Analysis
Building Technologies Program 4 eere.energy.gov

Agenda (Continued)

12:30 – 1:30 pm

1:30 – 2:00 pm

2:00 – 2:30 pm

2:30 – 3:00 pm

3:00 – 3:15 pm

3:15 – 3:45 pm

3:45 pm

Lunch

Markups for Product Price Determination, Energy Use 

Analysis, Life-Cycle Cost, and Payback Period Analysis

Shipments Analysis, National Impact Analysis, and 

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis, Employment Impacts, 

Environmental Impacts, and Regulatory Impact Analysis

Next Steps and Closing Remarks from Interested Parties

Adjourn
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Scope of Coverage and Test Procedures

NOPR Analyses

Closing Remarks

Public Meeting Agenda

4

5

6

2 Regulatory Authority

3 Rulemaking Overview

1 Introduction
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Purpose of the Framework Public 

Meeting

• Present the procedural and analytical approaches to evaluate energy 

conservation standards for residential furnace fans

• Provide a forum for public discussion of rulemaking issues

• Encourage interested parties to submit data, information, and written 

comments

• Inform interested parties of and facilitate the rulemaking process
Building Technologies Program 7 eere.energy.gov

Request for Comment

Issue Box In the Framework Document for Residential 

Furnace Fans, DOE welcomes comment. Throughout this 

presentation, specific issues will be raised for discussion on 

slides such as this one, with identifying numbers 

corresponding to those in the Framework. Nonetheless, 

comments concerning any part of the document or 

presentation are welcome.
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Feedback Is Requested 

Especially on Items Identified in Rulemaking Analysis Plan

• In all correspondence, please refer to the Residential Furnace Fans 

rulemaking by:

– Residential Furnace Fans Rulemaking;

– Docket Number EERE-2010-BT-STD-0011; and

– Regulatory Identification Number (RIN) 1904-AC22.

• Email: FurnFans-2010-STD-0011@ee.doe.gov

• Comment period closes July 06, 2010.

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945
Building Technologies Program 9 eere.energy.gov

Interested Parties Opening 

Statements

• At this time DOE welcomes opening remarks on the framework 

document for residential furnace fans.
Building Technologies Program 10 eere.energy.gov

Scope of Coverage and Test Procedures

NOPR Analyses

Closing Remarks

Public Meeting Agenda

1 Introduction

4

5

6

2 Regulatory Authority

3 Rulemaking Overview
Building Technologies Program 11 eere.energy.gov

Regulatory Authority

• Energy Policy and Conservation Act (EPCA) of 1975 

(Public Law 94-163):

– Amended by the Energy Policy Act (EPACT) of 2005 (Public Law 109-58) 

to grant the Secretary the authority to:

• “... consider and prescribe energy conservation standards or energy use 

standards for electricity used for purposes of circulating air through duct 

work.”(42 U.S.C. 6295(f)(4)(D))

– Amended by the Energy Independence and Security Act of 2007 (Public 

Law 110-140) to mandate that:

• A final rule establishing energy conservation or energy use standards to be 

published “not later than December 31, 2013.” (42 U.S.C. 6295(f)(4)(D)) 

• “Any new or amended energy conservation standard adopted after July 1, 

2010, shall address standby mode and off mode energy use pursuant to 42 

U.S.C. 6295(o).“ (42 U.S.C. 6295(gg)(3))
Building Technologies Program 12 eere.energy.gov

Scope of Coverage and Test Procedures

NOPR Analyses

Closing Remarks

Public Meeting Agenda

1 Introduction

4

5

6

2 Regulatory Authority

3 Rulemaking Overview
Building Technologies Program 13 eere.energy.gov

EPCA Factors

• 42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when 

setting energy conservation standards for residential furnace fans:

EPCA Factors DOE Analysis

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the product

Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers 

relevant

Environmental Assessment

Utility Impact Analysis

Employment Impact Analysis
Building Technologies Program 14 eere.energy.gov

Framework

Framework NOPR

Final

Rule

Today

• Today’s public meeting covers the Framework for Residential Furnace 

Fans.

• Federal Register Notice of Availability, 75 FR 31323, June 3, 2010. 

– Gives notice of the public meeting and availability of the Framework Document being 

discussed today

• Framework Document:

– Provides an overview of the rulemaking process

– Provides detailed descriptions of the analytical approach, tools, and models that will be 

used to evaluate new standards for residential furnace fans

– Provides a preliminary discussion of two approaches being considered to aid in 

developing a residential furnace fans test procedure

– Encourages interested parties to submit comments by July 06, 2010

– The Framework and materials from today’s public meeting are available online: 

http://www.eere.energy.gov/buildings/appliance_standards/residential/furnace_fans_framework.html
Building Technologies Program 15 eere.energy.gov

• Notice of Proposed Rulemaking 

– Discussion of comments received in response to this framework 

document

– Analysis of the impacts of potential standards on consumers, 

manufacturers, and the Nation

– Weighting of these impacts

– Proposed standard levels for public comment

• Final Rule 

– Discuss comments received in response to the NOPR

– Revise analysis of the impacts of standards

– Weight of the impacts of the final rule

– Determine the standard levels DOE will adopt

– Establish the compliance date for the adopted standards

Next Steps in Standards Rulemaking
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Scope of Coverage and Test Procedures

NOPR Analyses

Closing Remarks

Public Meeting Agenda

1 Introduction

4

5

6

2 Regulatory Authority

3 Rulemaking Overview
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• A furnace fan is an electrically-powered device used in residential 

central heating, ventilation, and air conditioning (HVAC) systems for the 

purposes of circulating air through duct work.

– A furnace fan consists of a fan motor and its controls, an impeller, and sheet metal 

housing.

• A furnace fan is typically integrated into central residential HVAC 

systems (referred to as furnace fan products), such as:

– gas-fired, oil-fired, and electric residential furnaces;

– split-system and packaged air conditioner and heat pump air handlers; and

– modular fan coils.

• DOE does not consider the following to be furnace fans:

– draft inducer fans;

– exhaust fans; and

– heat / energy recovery ventilators.

• EPCA does not specify which HVAC products use furnace fans or a 

range of any furnace fan characteristics, such as rated airflow capacity 

or rated motor horsepower, to aid in defining the scope of coverage.

Scope of Coverage
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Request for Comment

Item 1 DOE welcomes comments on its approach interpreting the relevant 

language in EPCA as referring to electricity used by any electrically-powered 

device used in residential central HVAC systems for the purposes of circulating 

air through duct work. Residential HVAC systems include, but are not limited 

to, furnaces, split-system and packaged central air conditioner and heat pump 

air handlers, and modular fan coils. 

Item 2 DOE seeks comment on any other residential central HVAC products 

that may also use furnace fans that should be included in the scope of 

coverage of this rule.

Item 3 DOE welcomes comments on its interpretation of the relevant language 

in EPCA as excluding electricity used by draft inducer fans, exhaust fans, and 

heat/energy recovery ventilators.

Item 4 DOE seeks comment on whether DOE should include a rated airflow 

capacity range or a rated horsepower range to help define test procedure 

applicability. 
Building Technologies Program 19 eere.energy.gov

• Active mode:

– The mode of operation during which the furnace fan product is powered 

and the impeller is in motion

• Standby mode:

– The mode of operation during which the furnace fan product is powered 

and the impeller is not in motion

• DOE believes furnace fan standby consumption is indistinguishable from the 

standby consumption of the furnace fan product because furnace fan 

controls are typically integrated into the controls of the furnace fan product.

• DOE accounts for furnace fan standby consumption in the rulemakings for 

associated products (residential CAC and residential furnaces and boilers).

• Off mode:

– The mode of operation during which the furnace fan product is not 

powered

• DOE believes that consumers are unlikely to place their HVAC systems in off 

mode, therefore, there will be no off mode electrical consumption for the 

furnace fan.

Operation Modes
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Request for Comment

Item 5 DOE requests comment on its assumptions for the 

electrical energy consumption expected in each mode of 

operation (i.e., active mode, standby mode, and off mode).
Building Technologies Program 21 eere.energy.gov

Test Procedures

• DOE is initially reviewing two approaches to aid in developing a 

furnace fan test procedure, including:

– Using a draft version of the Canadian Standard Association (CSA) C823 

Performance Standard for Air Handlers in Residential Space 

Conditioning Systems as a framework; or

– Using the blower (furnace fan) electricity measurement, BE, specified in 

the DOE test procedure for residential furnaces, as shown in 10 CFR 

Part 430 Appendix N., as well as additional specifications or 

modifications to extend it’s applicability to all furnace fan products, 

speed control settings, and operating functions and conditions.
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• Purpose: To calculate the Annual Electricity Consumption Rating 

(AECR) of air handlers based on the time-weighted sum of electricity 

consumption measurements for each available motor speed at 

various operating points

• Methodology: To superimpose a reference system load curve onto 

performance curves (airflow vs. external static pressure) for each 

speed control setting to determine the operating points and 

associated electricity consumption

• References: multiple existing industry test standards

– American National Standards Institute (ANSI)/Air Movement and Control 

Association (AMCA) 210-07 | ANSI/ American Society of Heating, 

Refrigerating, and Air-Conditioning Engineers (ASHRAE) 51-07 

Laboratory Methods of Testing Fans for Certified Aerodynamic 

Performance Rating

– ANSI/ASHRAE Std 37-2005 Methods of Testing for Rating Electrically 

Driven Unitary Air-Conditioning and Heat Pump Equipment

Summary of CSA C823
Building Technologies Program 23 eere.energy.gov

Request for Comment

Item 7 DOE welcomes comments on the use of Canadian 

Standard CSA C823 Performance Standard for Air Handlers in 

Residential Space Conditioning Systems, ANSI/AMCA 210-07 | 

ANSI/ASHRAE 51-07 Laboratory Methods of Testing Fans for 

Certified Aerodynamic Performance Rating, and NSI/ASHRAE 

Std 37-2005 Methods of Testing for Rating Electrically Driven 

Unitary Air-Conditioning and Heat Pump Equipment as 

reference test procedures. 

Item 8 DOE seeks comment on the existence and applicability 

of any other industry test procedure that DOE could consider 

for use in measuring the airflow and electrical energy 

consumption of furnace fans. In addition, DOE seeks comment 

as to what types of testing manufacturers currently conduct on 

furnaces fans and what test set-ups and methods are used.
Building Technologies Program 24 eere.energy.gov

• Airflow (cfm) vs. Static Pressure (in.w.c).

• A separate performance curve for each available speed control setting over 

a range of operating conditions (e.g. static pressures)

CSA C823: Performance Curves Static Pressure (in.w.c.)

Air Flow (CFM)

Performance Curves

Speed Control Settings
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Request for Comment

Item 9 DOE welcomes comment on the CSA CS823 

methodology used to develop performance curves. 

Item 10 DOE seeks comment on the appropriate total number 

and range of static pressures necessary to encompass the 

expected operating conditions for furnace fans for the purposes 

of developing performance curves without being unduly 

burdensome. DOE also seeks data, which would show that 

testing at a reduced number of static pressures would provide 

similar results as testing over the entire range of static 

pressures.

Item 11 DOE seeks comment on the CSA C823-specified 

method of selecting furnace fan speed control settings for 

testing. DOE also seeks comment on the relationship between 

speed control setting or speed tap and use in heating, cooling, 

or circulation functions of active mode furnace fan operation.
Building Technologies Program 26 eere.energy.gov

CSA C823: Reference System Load 

Curve

• Illustrates relationship between static pressure, PS, and airflow, Q, as determined by 

the physical characteristics, K, of the test system

• Determines performance at common operating conditions to allow for comparison 

across products

• The draft version of CSA C823 uses 0.5 (in.w.c.) in the default heat speed control 

setting as the reference system. Static Pressure (in.w.c.)

Air Flow (CFM)

Reference System Load Curve

PS = K x Q2

PS = 0.5 (in. w. c.)

Q2
Building Technologies Program 27 eere.energy.gov

Request for Comment

Item 12 DOE requests comment on the use of 0.5 (in w.c.) in 

the default heating speed control setting to define the reference 

system and resulting rating point. DOE requests comment on 

whether changes are necessary to the reference system 

criteria to more accurately reflect furnace fan operation in the 

U. S.

Item 13 DOE welcomes comment on the methodology outlined 

in CSA C823 to develop the reference system load curve.
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• Intersection of performance curves and reference system load curve

• Represent expected airflow performance of the system

• Electricity consumption at operating points will be used for 

calculating Annual Electricity Consumption Rating (AECR)

CSA C823: Operating Points Static Pressure (in.w.c.)

Air Flow (CFM)

Reference System 

Load Curve

Performance Curves

Electricity Consumption

Operating Points

Electricity Consumption (W)
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Request for Comment

Item 14 DOE welcomes comment on the methodology CSA 

C823 currently uses to identify furnace fan operating points. 
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• Time-weighted sum of electricity consumption at each speed control 

setting’s respective operating point

• AECR = (AHeatH x ECh) + (AHeatHreduced x EChreduced) + (ACoolH x ECc) + 

(ACircH x ECcirc) + (AstdbyH x ECstdby)

– AHeatH = annual heating hours;

– ECh= electrical energy consumption rating while performing the heating function;

– AHeatHreduced = annual reduced capacity heating hours (air-handler operating);

– EChreduced = electrical energy consumption rating for operation in performing the 

reduced heating function;

– ACoolH = annual cooling hours;

– ECc = electrical energy consumption rating while performing the cooling function; 

– ACircH = annual circulating hours;

– ECcirc = electrical energy consumption rating while performing the circulation 

function; 

– AStdbyH = annual standby hours; and

– ECstdby = electrical energy consumption rating for standby mode.

CSA C823: Annual Electricity 

Consumption Rating (AECR)
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Request for Comment

Item 15 DOE seeks input on the CSA C823 equation for annual 

energy consumption rating (AECR).

Item 16 DOE requests comment on the annual hourly multiplier 

methodology specified in CSA C823, as well as if and how this 

methodology and the annual hourly multiplier values could be 

modified to more specifically address furnace fan operation in 

the United States.
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• Purpose: Use metrics and methods from the existing DOE test 

procedures of associated products to minimize the burden of rating 

furnace fan efficiency

• Methodology: Develop a rating method to determine an annual 

electrical energy consumption descriptor (kWh) based on the blower 

(furnace fan) power measurement, BE, as specified in the DOE 

residential furnace test procedure with additions and modifications to 

encompass all furnace fan products, speed control settings, and 

functions

• Reference:

– ANSI/ASHRAE Standard 103-1993, Method of Testing for Annual Fuel 

Utilization Efficiency of Residential Central Furnaces and Boilers

Residential Furnace Blower 

Electricity (BE) Test
Building Technologies Program 33 eere.energy.gov

• BE measurements are only specified for residential furnaces, not the 

other furnace fan products tentatively covered by this rulemaking.

• BE is only measured while the residential furnace is performing the 

heating function, not while performing other functions (i.e., 

circulation).

• BE is only measured at a minimum specified external static pressure 

in one or two speed control settings, not during other typical 

operating conditions and in other available speed control settings.

• BE is a power measurement (W), which will require additional 

calculations and assumptions to be converted to an annual electrical 

energy consumption descriptor (kWh).

BE Test: Limitations
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Request for Comment

Item 17 DOE seeks comment on the potential merits of using the BE 

measurement specified in DOE’s existing residential furnaces test 

procedure (10 CFR part 430, subpart B, appendix N) as the basis for 

its furnace fan test procedure. 

Item 18 DOE seeks comment on additional rating methods that would 

be necessary to cover the power consumption of furnace fans used in 

residential central HVAC products other than furnaces. 

Item 19 DOE seeks comment on how the BE measurement could 

estimate the power consumption of the furnace fan in the circulation 

function and account for furnace fan operation within an appropriate 

range of static pressures and in an appropriate number of speed 

control settings. 

Item 20 DOE seeks comment on the appropriate annual hourly 

multipliers to determine the number of hours annually that the furnace 

fan operates in each speed control setting or function.
Building Technologies Program 35 eere.energy.gov

Scope of Coverage and Test Procedures

Closing Remarks

Public Meeting Agenda

1 Introduction

4

6

2 Regulatory Authority

3 Rulemaking Overview

5 NOPR Analyses
Building Technologies Program 36 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 37 eere.energy.gov

Market and Technology Assessment

Purpose

• Characterize the markets, the residential furnace fan industry, and the 

measures which improve furnace fan efficiency

Method

• Identify and characterize manufacturers of residential furnace fans

• Estimate historical shipments and trends in the market

• Identify regulatory and non-regulatory initiatives intended to improve 

the efficiency of the products covered under this rulemaking 

• Characterize products currently available on the market

• Identify technologies that could improve efficiency
Building Technologies Program 38 eere.energy.gov

Request for Comment

Item 21 DOE seeks comment on whether the manufacturers of 

furnace fans are also the manufacturers of the products that 

utilize furnace fans. 

Item 22 DOE welcomes input on estimates of market shares, 

products, features, and trends related to electricity 

consumption for the furnace fans covered in this rulemaking.
Building Technologies Program 39 eere.energy.gov

Product Classes

• DOE divides covered products into classes by:

• the type of energy used;

• capacity of the product; or 

• other performance-related features that justify different standard levels, 

such as features affecting consumer utility. (42 U.S.C. 6295(q))

• Based on the criteria above, DOE could consider using rated airflow 

capacity and/or rated fan motor horsepower to differentiate product 

classes.

– Rated airflow capacities range from approximately 400 cfm to 2,200 

cfm (in highest speed control setting).

– Rated horsepower ranges from approximately 1/5 horsepower to 1 

horsepower.
Building Technologies Program 40 eere.energy.gov

Request for Comment

Item 23 DOE welcomes comments on whether to use rated 

airflow capacity, rated motor horsepower, or an alternative 

approach to defining product classes in accordance with the 

requirements of 42 U.S.C. 6295(q.). DOE also seeks comment 

on how each of these specifications influences furnace fan 

product design decisions.

Item 24 DOE seeks input on appropriate rated airflow or rated 

motor horsepower bins. Specifically, DOE is interested in 

information that could be used to determine the number of bins 

or range of each bin.
Building Technologies Program 41 eere.energy.gov

Technology Assessment

• DOE uses information about existing and past technology options 

and prototype designs to identify technologies manufacturers could 

use to meet or exceed energy conservation standards.

• DOE will consider only technologies that improve the efficiency of 

the furnace fan.

– These are the technologies manufacturers are most likely to implement 

in response to new energy conservation standards.
Building Technologies Program 42 eere.energy.gov

• Technology options

– High-efficiency furnace fan motors

• High-efficiency permanent split capacitor (PSC) motors or Electronicallycommutated motors (ECM)

– Improved impellers

• Optimized for specific applications

Technology Assessment

Item 25 DOE welcomes comments on the preliminary 

technology options identified in this slide (i.e., high-efficiency 

furnace fan motors and improved impellers) and whether there 

are other technology options it should consider. In commenting 

on technology options, please discuss their impacts, if any, on 

safety, performance, and consumer utility.
Building Technologies Program 43 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 44 eere.energy.gov

Screening Analysis

Impacts on health or safety.

Impacts on product utility or availability to 

consumers; and

Practicability to manufacture, install, and service;

Technological feasibility;

Purpose

• Screen out technology options that DOE will not consider in the 

engineering analysis for residential furnaces

Approach

• 10 CFR Part 430, Subpart C, Appendix A, 4(a)(4) and 5(b) direct 

DOE to evaluate each technology option based on the following 

criteria:
Building Technologies Program 45 eere.energy.gov

Request for Comment

Item 26 DOE welcomes comments on how the above four 

screening criteria might apply to any additional technology 

option(s) that an interested party recommends to DOE.
Building Technologies Program 46 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 47 eere.energy.gov

Engineering Analysis: Purpose

• A key factor in setting the standard is the increased cost of a 

more efficient product.

• The Engineering Analysis determines the relationship between 

cost and efficiency.

Rulemaking Analyses

• Life-Cycle Cost and 

Payback Period

• Manufacturer Impact 

Analysis 

• Employment Impact 

Analysis

Manufacturer Selling Price –

Efficiency Relationship

Manufacturer 

Selling Price

Efficiency Level
Building Technologies Program 48 eere.energy.gov

Engineering Analysis: Methodology

 Define characteristics of models in each product class, which 

will serve as reference points to assess changes due to more 

stringent standard levels.

 Identify more-efficient substitutes from a database of 

commercially-available furnace fans.

 Develop bill of materials (BOM) for baseline furnace fans and 

higher efficiency levels by disassembling select models.

 Determine manufacturer production cost for baseline furnace 

fans and higher efficiency levels based on BOMs from the 

teardown analysis and manufacturing cost model.

Identify

Efficiency Levels

Perform 

Teardown 

Analysis

Develop

Manufacturer 

Production Cost

Define Baseline 

Models
Building Technologies Program 49 eere.energy.gov

• DOE estimates the manufacturer production costs of products 

through “teardown analysis” (i.e., reverse engineering of products).

– DOE physically disassembles products to examine existing designs.

– DOE records all characteristics of each component including the 

manufacturing processes required for fabrication to create a BOM.

• DOE will select furnace fans for teardown analysis across the full 

range of efficiencies analyzed in each product class that are:

– representative of the product class;

– manufactured in considerable volume;

– from the same manufacturer and product series to the extent possible;

– made by manufacturers with large market shares, with the exception of 

the max-tech products; and

– minimize the occurrence of non-efficiency-related premium features.

Engineering Analysis: Teardown 

Analysis
Building Technologies Program 50 eere.energy.gov

Request for Comment

Item 28 DOE seeks comments on its approach to calculating 

the cost-efficiency relationship for furnace fans.

Item 29 DOE welcomes comments on the methodology for 

selecting commercially-available furnace fans with 

incrementally increasing efficiency from the baseline model to 

max-tech for characterizing the efficiencies of furnace fans 

currently offered for sale. 

Item 30 DOE welcomes comments on how furnace fan 

efficiency varies with airflow capacity, motor type, motor rated 

horsepower, number of speed control settings, or any other 

furnace fan parameter.
Building Technologies Program 51 eere.energy.gov

• DOE will consider all commercially-available or working prototypes 

that meet screening criteria.

– If a proprietary design is the only approach to achieving a particular 

efficiency level, that level will be eliminated from analysis.

– Standard levels that can only be achieved by using a single proprietary 

technology will be rejected because it is economically unjustifiable.

Engineering Analysis: Proprietary 

Designs

Item 31 DOE seeks information on proprietary designs of 

which it should be aware for the furnace fans under 

consideration in this rulemaking and, if such proprietary 

designs exist, how DOE can acquire the cost data necessary 

for evaluating these designs.
Building Technologies Program 52 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 53 eere.energy.gov

Markups for Product Price 

Determination

• Purpose

– Determine consumer furnace fan prices based on manufacturer costs

– Characterize furnace fan distribution channels and market segments

• Method

– DOE will estimate the consumer prices by applying markups consisting of 

distribution channel markups and sales tax to manufacturer selling price estimates. 

• Inputs

– Financial Statements: 

• Wholesalers: HARDI Profit Survey Report (2008)

• Contractors: ACCA Financial Analysis for the HVACR Contracting Industry 

(1995, 2005)

– U.S. Census Bureau data:

• Builders: Single-Family Housing Construction, Construction Industry Series 

(1997 and 2002 Economic Census, U.S. Department of Commerce)

• Outputs

– Baseline and incremental markups:

• Baseline markups relate price to cost prior to a change in efficiency.

• Incremental markups relate the incremental change in consumer price to the 

incremental change in cost of goods sold.
Building Technologies Program 54 eere.energy.gov

Furnace Fan 

Product 

Manufacturer

Distributor Mechanical 

Contractor

Distribution Channels

• Mechanical Contractors include mechanical contractors, dealers, and 

installers. 

Furnace Fan 

Product 

Manufacturer

Distributor General 

Contractor

• General Contractors include builders because builders serve the same 

function in the HVAC marketplace as general contractors.
Building Technologies Program 55 eere.energy.gov

Request for Comment

Item 34 DOE requests comments on the planned distribution 

path for the furnace fans covered under this rulemaking and 

whether DOE should consider any additional paths. DOE also 

requests information on the relative fraction of shipments 

expected for each path.

Item 35 DOE requests feedback on the overall markups for the 

furnace fans covered under this rulemaking for each path in the 

distribution chain.
Building Technologies Program 56 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 57 eere.energy.gov

Energy Use Analysis

Purpose

• Identify the energy use of furnaces fans in the field and, thereby, the energy 

savings potential of energy efficiency improvements

Method

• Estimate household heating and/or cooling load using adjusted 

heating/cooling equipment energy use* from RECS 2005

• Using heating and/or cooling load, determine heating/cooling equipment 

operating hours (includes accounting for furnace fan heat contribution)

• Using equipment operating hours, estimate furnace fan operating hours at 

each active mode (heating, cooling, and continuous ventilation)

• Estimate furnace fan electricity consumption for each considered efficiency 

level**

*Energy use for RECS 2005 homes adjusted using 30-year average heating degree data by Census Division or large state as well as 

adjusted for projected improvements in building thermal efficiency and changes in house floor area between 2005 and 2015 

(standards effective date).

**Total energy consumption is adjusted to account for increased furnace gas use and reduced AC equipment electricity use due to 

higher furnace fan efficiency.
Building Technologies Program 58 eere.energy.gov

Request for Comment

Item 36 DOE seeks comments on the planned approach for 

determining the energy consumption of furnace fans in 

residential buildings.

Item 37 DOE welcomes comments from interested parties as to 

whether a more-efficient furnace fan would be expected to be 

used more and whether such a rebound effect should be 

considered separately for this product.
Building Technologies Program 59 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental

Impacts

Analysis
Building Technologies Program 60 eere.energy.gov

Life-Cycle Cost and Payback Period 

Analyses Approach

Purpose

• Assess the net LCC impacts and PBP for the consumers of residential 

furnace fans under the considered efficiency levels

Method

• LCC equals total installed cost plus the sum of operating costs 

discounted to a particular base year

• Analysis will model the uncertainty and variability of inputs using 

Monte Carlo approach and probability distributions

• Analysis will be implemented in MS Excel® spreadsheet combined 

with Crystal Ball®

First Cost

(Consumer Price +

Installation Cost)

Operating Expenses

Combine Changes 

in Costs

LCC Results

Convert to Present Value
Building Technologies Program 61 eere.energy.gov

Life-Cycle Cost and Payback Period 

Analyses
Building Technologies Program 62 eere.energy.gov

Energy Prices

• DOE will derive average monthly energy prices using recent EIA data 

for each of the Census divisions and large states to establish 

appropriate energy prices for each sample household.

• DOE will use projections of national average residential energy prices 

(from the most recent EIA Annual Energy Outlook (AEO)) to forecast 

future energy prices for the LCC analysis.
Building Technologies Program 63 eere.energy.gov

Life-Cycle Cost Discount Rates

• DOE uses the discount rate to determine the present value of lifetime 

operating expenses.

• DOE will derive the discount rates from estimates of the “finance cost” 

to purchase residential products using the Federal Reserve Board’s 

Survey of Consumer Finances. The finance cost can be interpreted 

as: 

– the financial cost of any debt incurred to purchase products 

(principally interest charges on debt); or 

– the opportunity cost of any equity used to purchase products 

(principally interest earnings on household equity). 

Item 38 DOE seeks input on its DOE’s planned approach for 

estimating discount rates for consumers of residential furnace 

fans.
Building Technologies Program 64 eere.energy.gov

Installation, Maintenance, and Repair 

Costs

• Installation

– DOE does not plan to estimate installation costs because they are considered 

part of the manufacturing cost of a furnace.

• Maintenance and Repair

– DOE will evaluate how maintenance and repair costs change with increased 

efficiency for furnace fans. Data sources will include: 

• RS Means;

• manufacturer literature; and

• expert consultants.

– DOE will account for regional differences in labor costs. 

– The repair cost includes the installation of a replacement furnace fan.

Item 39 DOE welcomes comments on the appropriate 

methods and data sources for assessing changes in installation 

costs and maintenance and repair costs for more efficient 

furnace fans.
Building Technologies Program 65 eere.energy.gov

Furnace Fan Lifetimes

• DOE plans to use information from various literature sources and 

industry experts and input from manufacturers and other interested 

parties to determine a range for the lifetime of furnace fans.

Item 40 DOE seeks comments on appropriate lifetimes for the 

furnace fans covered in this rulemaking.
Building Technologies Program 66 eere.energy.gov

Energy Efficiency in the Base Case

• DOE will develop projected market shares of products by efficiency 

under the base case for each Census Division and large state. 

• DOE will use data on recent market trends in residential furnace and 

air conditioner efficiency, as well as potential impacts of the ENERGY 

STAR program and other policies that may affect the demand for more 

efficient furnace fans.

Item 41 DOE seeks comments on the appropriate distribution 

of energy efficiencies for residential furnace fans in the 

absence of amended energy conservation standards.
Building Technologies Program 67 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 68 eere.energy.gov

Shipment Analysis

Purpose

• Estimate furnace fan shipments in the base case and standards 

cases

Method

• The model will apply accounting methodology to determine:

– replacements in kind (replace with same equipment type and same 

fuel);

– new housing installations; and

– conversions from non-central heating to central heating with furnace 

fans;

– fan retrofits into existing furnaces and cooling products if the fan fails.

• DOE intends to evaluate whether standards that require more-efficient 

furnace fans would have an impact on the number of fans shipped. DOE will 

consider application of elasticity parameters that relate changes in shipment 

quantities to changes in the installed cost of products with furnace fans. 
Building Technologies Program 69 eere.energy.gov

Base Case Shipments Forecast

• Replacements: DOE will develop retirement functions from the lifetime estimates and 

apply them to the existing products. The existing stock of products will be developed from 

historical shipments data. 

• New Construction: DOE will use estimates of forecasted new housing construction and 

saturation rates of various furnace and cooling product types in new housing. In projecting 

future new housing saturation rates of residential furnaces and cooling products, DOE will 

consider expected trends in builder and consumer preferences, including competition 

among space heating and cooling products. 

• First Time Owners: DOE plans to derive a historical rate of product adoption for the noncentrally-heated market. DOE plans to project future adoption rates by considering the 

historical trend as well as market saturation.

• Retrofits: DOE will estimate these shipments from the fan lifetime distribution.

• Sources: Appliance Magazine, AHRI data, EIA’s AEO, U.S. Census Bureau’s 

Characteristics of New Housing, and American Housing Survey data.
Building Technologies Program 70 eere.energy.gov

Request for Comment

Item 42 DOE seeks input on historical shipments data for furnace fans, 

including the distribution of shipments by efficiency. 

Item 43 DOE welcomes comments on the methodology described to 

forecast shipments of furnace fans.

Item 44 DOE welcomes comments on whether energy conservation 

standards might affect shipments of furnace fans, as well as the 

anticipated extent of such impacts, if any.
Building Technologies Program 71 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 72 eere.energy.gov

National Impact Analysis

Purpose

• Assess the aggregate impacts at the national level of potential 

energy conservation standards for each of the product classes, as 

measured by the net present value of total consumer economic 

impacts and the national energy savings

Method

• DOE calculates annual equipment expenditures by multiplying the 

price per unit by forecasted shipments.

• The difference between base- and standards-case scenarios gives 

the national energy bill savings and increased expenditure in 

dollars.

• The difference each year between energy bill savings and 

increased equipment expenditures is the net savings (if positive) 

and net costs (if negative).
Building Technologies Program 73 eere.energy.gov

National Energy Savings Flow 

Diagram

Base Case

Annual Energy

Consumption

2044

Base Case

Annual Energy

Consumption

2017

Base Case

Annual Energy

Consumption

2016

Base Case

Annual Energy

Consumption

2015

Shipments

Analysis StandardsCase Projection

Base-Case 

Projection

Base Case

Annual Energy

Consumption

2044

Base Case

Annual Energy

Consumption

2017

Base Case

Annual Energy

Consumption

2016

Standards Case

Annual Energy

Consumption

2015

Base-Case

Cumulative

Energy Use

Standards-Case 

Cumulative

Energy Use

Site to Source

Energy

Conversion

National Energy

Savings
Building Technologies Program 74 eere.energy.gov

National Consumer Net Present 

Value Flow Diagram

Shipments

Analysis StandardsCase Projection

Energy

Cost

(2015 –

2044)

Base-Case 

Projection

Operating Cost 

Savings

Total Equipment

Cost Increase

Discount 

Rate

Net Present

Value

Maint &

Install Cost

(2015 –

2044)

Product 

Cost

(2015 –

2044)

Energy

Cost

(2015 –

2044)

Maint &

Install Cost

(2015 –

2044)

Product

Cost

(2015 –

2044)
Building Technologies Program 75 eere.energy.gov

• DOE has used both the “roll-up” and “shift” scenarios for estimating 

the impact of standards on product efficiency distributions.

– “Roll-up” scenario:

• DOE assumes that product efficiencies in the base case that do not meet 

the standard level under consideration would “roll-up” to meet the new 

standard level, and product efficiencies above the standard level under 

consideration would not be affected.

– “Shift” scenario:

• DOE retains the pattern of the base-case efficiency distribution but re-orients 

the distribution at and above the new minimum energy conservation 

standard. 

• DOE will evaluate whether one of these approaches is more 

reasonable for furnace fans, or whether it would be preferable to use 

both scenarios in its calculation of national impacts. 

Standards-case Efficiency 

Distributions
Building Technologies Program 76 eere.energy.gov

Request for Comment

Item 45 DOE seeks comments on the appropriate assumptions to use 

regarding long-run changes in furnace fan energy efficiency independent 

of amended energy conservation standards.

Item 46 DOE seeks comments on the use of the “roll-up” and “shift” 

efficiency scenarios to characterize the impact that potential standards 

would have on the product efficiency distributions.
Building Technologies Program 77 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 78 eere.energy.gov

Life-Cycle Cost Subgroup Analysis

Purpose

• Analyze the economic impacts of standards on consumers, including 

subgroups who may be disproportionately impacted compared with 

the general user population (e.g., low-income consumers or senior 

citizens)

Method

• Extend the LCC analysis to examine the impacts for defined 

subgroups

• Use inputs specific to each of the considered consumer subgroups

Item 47 DOE welcomes comments from interested parties on 

which, if any, consumer subgroups should be considered when 

developing energy conservation standards for furnace fans.
Building Technologies Program 79 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 80 eere.energy.gov

Manufacturer Impact Analysis

Purpose

• Assess the impacts of amended standards on manufacturers

• Identify and estimate impacts on manufacturer subgroups that may be 

more severely impacted than the industry as a whole

• Examine the impact of cumulative regulatory burden on the industry

Method

• Analyze industry cash flow and net present value through use of the 

Government Regulatory Impact Model (GRIM)

• Interview manufacturers to refine inputs to the GRIM, develop 

subgroup analyses, and address qualitative issues

Output

• Industry net present value (INPV) impacts

• Subgroup net present value (NPV) impacts

• Other impacts
Building Technologies Program 81 eere.energy.gov

MIA Methodology

• The MIA consists of three main phases: 

Industry 

profile

Develop 

straw-man 

GRIM*

Develop 

interview 

guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Phase 1 Phase 2 Phase 3
Building Technologies Program 82 eere.energy.gov

• DOE recognizes that small businesses may be disproportionately 

affected by the promulgation of amended energy conservation 

standards for residential furnace fans.

• Residential furnace fan manufacturing is classified under NAICS 

333415, “Air-Conditioning and Warm Air Heating Equipment and 

Commercial and Industrial Refrigeration Equipment Manufacturing.”

• The size threshold for a small business is 750 employees or fewer.

Small Business Impacts

Item 48 DOE seeks comments on the subgroups of furnace fan 

and furnace fan product manufacturers that it should consider 

in a manufacturer subgroup analysis.
Building Technologies Program 83 eere.energy.gov

• Regulations that could impact the industry:

– Energy Conservation Standards for Residential Furnaces and Boilers; 

and

– Energy Conservation Standards for Residential Central Air Conditioners 

and Heat Pumps.

Cumulative Regulatory Burden

Item 49 DOE welcomes comments on what other existing 

regulations or pending regulations it should consider in its 

examination of cumulative regulatory burden.
Building Technologies Program 84 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 85 eere.energy.gov

Utility Impact Analysis

Purpose

• Assess selected impacts on energy supply that would result from the 

imposition of standards

• The Department proposes to use National Energy Modeling System 

(NEMS)-Building Technologies (BT), a variant of the NEMS used by 

EIA for their AEO report, as the basis of the Utility Impact Analysis.

• DOE will model the energy savings impacts from the considered 

standard levels using NEMS-BT to generate forecasts that deviate 

from the AEO reference case.

• Outputs of the utility impact analysis include forecasts of electricity 

generation and avoided capacity resulting from the considered 

standard levels.

Method
Building Technologies Program 86 eere.energy.gov

Request for Comment

Item 50 DOE seeks input on its plans to use NEMS-BT to 

conduct the utility impact analysis for the products covered 

under this rulemaking.
Building Technologies Program 87 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 88 eere.energy.gov

Employment Impact Analysis

Purpose

• Assess the overall impact on national employment from the 

considered efficiency levels

• Focus on indirect employment impacts

– Indirect employment impacts result from shifting consumer 

expenditures among goods and services and changing equipment and 

energy costs.

– Direct employment impacts are estimated in the manufacturer impact 

analysis.

Method

• DOE intends to use the Impact of Sector Energy Technologies 

(ImSET) model for the evaluation of indirect employment impacts. 

(Note: ImSET is an update of IMBUILD)

Item 51 DOE requests comments on its approach to assessing 

employment impacts on the products covered under this 

rulemaking.
Building Technologies Program 89 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 90 eere.energy.gov

Environmental Assessment

Purpose

• To report environmental impacts resulting from amended energy 

conservation standards, including changes in power plant 

emissions, as well as site emissions due to the use of gas and oil 

furnaces

Method

• DOE intends to assess the environmental impacts using NEMS-BT. 

– The result is an estimate of national emission reductions of CO2, NOx,

and mercury.

– NEMS-BT estimates site SO2 and NOx emitted by fossil-fuel fired 

appliances using emissions factors.
Building Technologies Program 91 eere.energy.gov

Monetization of Emission Reductions

• DOE intends to use the most current Social Cost of Carbon (SCC) values 

developed by interagency reviews.

– SCC is intended to be a monetary measure of the incremental damage 

resulting from greenhouse gas (GHG) emissions, including but not limited to 

agricultural productivity loss, human health effects, property damage from rising 

sea level, and changes in the ecosystem.

• At present, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010 are $4.7, $21.4, 

$35.1, and $64.9 per metric ton in 2007 dollars. 

– For emission reductions that occur in later years, these values grow in real 

terms over time.

• DOE will also estimate the potential monetary benefit of reduced NOx

emissions resulting from the considered standard levels.
Building Technologies Program 92 eere.energy.gov

Request for Comment

Item 52 DOE seeks input on its plans to use NEMS-BT to 

conduct the environmental assessment for the products 

covered by this rulemaking.

Item 53 DOE requests comments on the approach it plans to 

use for estimating monetary values associated with emissions 

reductions, or any widely-accepted values that could be used in 

DOE’s analyses.
Building Technologies Program 93 eere.energy.gov

Steps in the Standards Rulemaking: 

NOPR

Framework NOPR Final

Rule

Effective

Date

Engineering 

Analysis

Markups to 

Determine 

Product 

Price

Energy Use 

Analysis

Screening 

Analysis

Life-Cycle 

Cost & 

Payback 

Period 

Analyses

Shipments 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact

Analysis

Market and 

Technology 

Assessment

National 

Impact 

Analysis

Utility

Impact

Analysis

Employment

Impacts

Analysis

Regulatory

Impact

Analysis

Environmental 

Impact 

Analysis
Building Technologies Program 94 eere.energy.gov

Regulatory Impact Analysis

Purpose

• To investigate the national impacts of non-regulatory alternatives 

compared with mandatory energy conservation standards

• The non-regulatory alternatives that may be considered include: 

– consumer rebates; 

– consumer tax credits; 

– manufacturer tax credits; 

– voluntary efficiency targets; 

– early replacement; and

– bulk government procurement.

Method

• Modify NES spreadsheet model to consider non-regulatory scenarios

• Estimate impacts of non-regulatory scenarios based on experience with 

the considered policies

• Output will include National Energy Savings and Net Present Value of 

the non-regulatory alternatives
Building Technologies Program 95 eere.energy.gov

Request for Comment

Item 49 DOE welcomes comments on what other existing 

regulations or pending regulations it should consider in its 

examination of cumulative regulatory burden.
Building Technologies Program 96 eere.energy.gov

Scope of Coverage and Test Procedures

Closing Remarks

Public Meeting Agenda

1 Introduction

4

6

2 Regulatory Authority

3 Rulemaking Overview

5 NOPR Analyses
Building Technologies Program 97 eere.energy.gov

How to Submit Written Comments

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

• In all correspondence, please refer to the Residential Furnace Fans 

rulemaking by:

– Residential Furnace Fans Rulemaking;

– Docket Number EERE-2010-BT-STD-0011; and

– Regulatory Identification Number (RIN) 1904-AC22.

• Email: FurnFans-2010-STD-0011@ee.doe.gov

• Comment period closes July 06, 2010.
Building Technologies Program 98 eere.energy.gov

Relevant URLs

• DOE Appliance Standards

– http://www.eere.energy.gov/buildings/appliance_standards/

• DOE Furnace Fan

– http://www.eere.energy.gov/buildings/appliance_standards/residential/furn

ace_fans.html

• DOE Furnace Fan Framework

– http://www.eere.energy.gov/buildings/appliance_standards/residential/furn

ace_fans_framework.html