UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY 

PRELIMINARY ANALYSIS PUBLIC MEETING ON

RESIDENTIAL FURNACE FANS ENERGY CONSERVATION STANDARDS

U.S. Department of Energy

1000 Independence Ave., SW

Washington, D.C. 20585

Room 8E-089 Review Center

Friday

July 27, 2012

Facilitator:

Doug Brookman

Public Solutions

Baltimore, MD
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Participants Identified: 

Karim Amrane

AHRI

Timothy Ballo

Earth Justice 

Alex Boesenberg

NEMA

Rob Boteler

Midec Motor Corporation

Adam Christiansen 

Appliance Standards Awareness Project

Michelle Cox

... Blake Corporation

Abigail Dakem

EPA

Tom Eckman

Northwest Power and Conservation Council

Michel Evanovich

Air Movement and Control Assoc. International, Inc.

Diane Jakobs

Rheem Manufacturing Company

Brian James

Southern California Edison

Paul Lin

Regal Beloit

Joanna Mauer

Appliance Standards Awareness Project

Sarah Medepalli

ICF International
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Craig Messmer

Unico, Incorporated

David Ransom, Esquire

McDermott Will & Emery

Steve Rosenstock

Edison Electric Institute

Aniruddh Roy

Air Conditioning, Heating, and Refrigeration Institute

Charlie Stephens

Northwest Energy Efficiency Alliance

Greg Wagner

Morrison Products

Meg Waltner

Natural Resources Defense Council

Ted Williams

American Gas Association

Dave Winningham

Allied Air Enterprises, Lennox

Participants from DOE:

Michael Kido

DOE General Counsel’s Office

Mohammed Khan

DOE

Ashley Armstrong

Department of Energy

Brenda Edwards

Department of Energy
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Participants from Consultants:

Sam Jasinski

Navigant Consulting Incorporated

Christopher Lau

Navigant Consulting

Detlef Westphalen

Navigant Consulting

Alex Lekov

Lawrence Berkeley National Laboratory

Victor Franco

Lawrence Berkeley National Laboratory

Gregory Rosenquist

Lawrence Berkeley National Laboratory

Bingyi Yu

Lawrence Berkeley National Laboratory

Participants via the web:

Rachelle Cocks

Regal Beloit

Terrell Small

Mortex

Anush Mystery (ph)

Dan Williams

Jim Vershaw

John Hunley

Linda Wilson

Tom Chase 
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AGENDA

 ITEM PAGE

Welcome, Doug Brookman 6

Welcome for DOE, Mr. Khan 6

Introductions 7

Agenda Review, Doug Brookman 10

Introductory Remarks and Overview

Mr. Khan 13

Opening Statements 14

Meeting Overview, Mr. Khan 26

Market and Technology Assessment, and

Screening Analysis

Mr. Jasinski 32

Engineering Analysis

Mr. Jasinski 85

Markups, Energy Use Characterization

LCC and Payback Period analysis

Mr. Lekov 144

National Impact Analysis, 

Shipments Analysis

Mr. Lekov 225

National Energy Savings, Net Present

Value, Mr. Lekov 239

Manufacturer’s Impact Analysis

Mr. Jasinski 249

Final Comments of interested parties 259

Closing Remarks, Mr. Khan 264
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Let’s get started. Good 

3 morning everyone and welcome. This is the U.S. 

4 Department of Energy’s Preliminary Analysis Public 

5 Meeting on Residential Furnace Fans Energy 

6 Conservation Standards.

7 Today is Friday, July 27, 2012 at the U.S. 

8 Department of Energy here in the Forrestal Building. 

9 My name is Doug Brookman from Public Solutions in 

10 Baltimore. 

11 We’re going to start off this morning with 

12 welcoming remarks from Mohammed Khan.

13 (Discussion about problems with microphone.)

14 Okay. I’ll speak loudly. We are going to 

15 start with welcoming remarks from Mohammed Khan, 

16 Department of Energy.

17 Welcoming Remarks

18 MR. KHAN: Good morning. Mohammed Khan, 

19 Department of Energy. First, I want to thank you for 

20 participating today. As you’ll find out, we have a 

21 lot of material to cover and we’re going to be 

22 appealing to you for your comments and input on this 
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1 material. We were here just over a month ago, having 

2 a meeting on the related rulemaking that we’re doing, 

3 which is the test procedure for furnace fans, and I 

4 think I see a lot of you here again today, and that’s 

5 great. And what I said at that meeting was of your 

6 comments are very important, but also explained that 

7 this rulemaking is unique really for two reasons. 

8 One, it’s a first time that we’re developing a 

9 standard and test procedure for furnace fans. The 

10 other reason is that it’s a product that is already a 

11 part of – or is a component of a product that we 

12 already cover. So that’s basically unchartered 

13 grounds, in a sense, but we look forward to your input 

14 today and I look forward to a great discussion. 

15 MR. BROOKMAN: Thank you. Let’s start with 

16 introductions. I’ll start over here to my left, 

17 please. Say your name and organizational affiliation, 

18 and you can get used to turning the microphones both

19 on and off. If we leave them on, then we get feedback 

20 in the system, please.

21 Introductions

22 MR. BOTELER: Rob Boteler. I work for Nidec 

23 Motor Corporation in St. Louis and I chair the energy 

24 committee for NEMA, the National Electrical 

25 Manufacturers Association.
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1 MR. BROOKMAN: Thank you. 

2 MR. LIN: Paul Lin, with Regal Beloit

3 manufacturer of electric motors.

4 MR. BOESENBERG: Alex Boesenberg, National 

5 Electrical Manufacturers Association, regulations.

6 MR. MESSMER: Craig Messmer, with Unico, 

7 Incorporated in St. Louis.

8 MR. WAGNER: Greg Wagner, with Morrison 

9 Products.

10 MS. JAKOBS: Diane Jakobs, with Rheem 

11 Manufacturing.

12 MR. ROY: My name is Aniruddh Roy, Air 

13 Conditioning, Heating, and Refrigeration Institute.

14 MR. CHRISTIANSEN: Adam Christiansen with

15 the Appliance Standards Awareness Project.

16 MR. WILLIAMS: Ted Williams, American Gas 

17 Association.

18 MR. JAMES: Brian James, Southern California 

19 Edison.

20 MR. WINNINGHAM: Dave Winningham, Allied 

21 Air, and Lennox.

22 MR. ROSENSTOCK: Steve Rosenstock, Edison 

23 Electric Institute.

24 MR. ECKMAN: Tom Eckman, Northwest Power and 

25 Conservation Council.
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1 MR. KIDO: Michael Kido, Department of 

2 Energy, Office of General Council.

3 MR. KHAN: Mohammed Khan, DOE.

4 MR. BROOKMAN: Please. Stand up.

5 MR. WESTPHALEN: Detlef Westphalen, Navigant 

6 Consulting.

7 MR. JASINSKI: Sam Jasinski, Navigant 

8 Consulting.

9 MR. FRANCO: Victor Franco, Lawrence 

10 Berkeley National Laboratory.

11 MR. LEKOV: Alex Lekov, Lawrence Berkeley 

12 National Lab.

13 (Several inaudible introductions.)

14 MS. MAUER: Joanna Mauer, Appliance 

15 Standards Awareness Project.

16 MR. RANSOM: McDermott Will and Emery.

17 MR. BROOKMAN: And let me just note for the 

18 record that those of you that didn’t speak into a 

19 microphone, we didn’t get all your names on the 

20 record, but most of you have -- hopefully all of you 

21 registered so we know who’s here.

22 One thing we have been doing recently is 

23 we’ve been asking those who have been joining us via 

24 the web to read their names so we know who is joining 

25 us via the web. Can you do that, and their 
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1 organizational affiliations are also there, that would 

2 be a good thing. They’re not, just names. Okay.

3 WEBMASTER: So we’ve got Anush Mystery (ph), 

4 Dan Williams, Jim Vershaw, John Hunley, Linda Wilson, 

5 Rachelle Cox, Terry Small, Tom Chase, and that’s it.

6 MR. BROOKMAN: Thanks to those of you that 

7 are joining us via the web.

8 Agenda Review

9 MR. BROOKMAN: All of you received a packet

10 of information as you came and registered this 

11 morning. Please take a peek at that, particularly the 

12 agenda, that’s where I’m starting with a brief review. 

13 Following this agenda review we’re going to 

14 have an overview presentation, the purpose of the 

15 public meeting, regulatory authority and rulemaking 

16 from Mohammed. Following that, those introductory 

17 remarks, there’s an opportunity for anybody who wishes 

18 to do so to make opening statements, summary 

19 statements surrounding the issues that are of concern 

20 to you today. 

21 And then from there we’ll launch straight 

22 into the more detailed comment that’s in this Power 

23 Point packet that all of you received. Market and 

24 technology assessment and screening analysis.

25 We’ll take a break mid-morning, round about 10:45 
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1 or so. Following that, engineering analysis, 

2 following that, markups, energy use characterization 

3 and LCC and payback period analysis. 

4 We’ll take lunch round Around about 12:30 or 

5 so. Immediately following lunch, or whenever we get 

6 there, LCC and payback period analysis continued, then 

7 national impact analysis. We’ll take a break mid8 afternoon, preliminary manufacturer impact analysis, 

9 next steps in the late afternoon, 3:30 or so, and then 

10 finally, closing remarks, another opportunity for 

11 anybody who wants to, to make additional comments or 

12 statements. So two opportunities for open ended 

13 comment. We do hope, however, that the bulk of the 

14 commentary will be focused in on the content that’s 

15 being presented because that will keep it organized 

16 for us.

17 I’d ask for your consideration, if you 

18 would, please. Many of you have attended these 

19 meetings previously. Please speak one at a time.

20 Please say your name for the record each time you 

21 speak. I’m going to be cuing individuals by name as 

22 best I can. I also wish to encourage follow on 

23 comments, sometimes the back and forth is very useful 

24 for the Department as they’re trying to consider this 

25 information. 
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1 If you keep the focus here, turn your cell 

2 phones on silent mode, limit the sidebar 

3 conversations. You will need to turn these 

4 microphones on and off please. We do have many web 

5 participants joining us. If those of you joining us 

6 via the web, if you would keep your telephones on 

7 mute, it will limit the amount of feedback we receive 

8 here in the room, and if you raise your hand, then we 

9 will find a way to fit you into the conversation as 

10 best we can that’s going on here. So please feel free 

11 to join us and be proactive. 

12 And then finally, as there are 100-and 

13 however many slides here, a lot of slides, I would ask 

14 for your consideration, please try to be concise 

15 today, share the air time. There’s a lot to cover. 

16 We’re going to do it very efficiently, I know we will, 

17 and so that’s the task for the day. Questions and 

18 comments on any of this? 

19 Okay, so then, we’re going to start off 

20 then, Mohammed Khan. And Mohammed, I’ve been asked, 

21 please use the Lavaliere microphone, as the other one 

22 provides feedback. You want to hit the microphone and 

23 introduce yourself, name and organizational 

24 affiliation.

25 MS. DAKEN: Abigail Daken, US EPA, Energy 
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1 Star Program.

2 MR. BROOKMAN: Thank you. 

3 Purpose of Public Meeting, Overview

4 MR. KHAN: Good morning everyone. Thank you 

5 for participating in today’s meeting on the U.S. 

6 Department of Energy’s preliminary analysis on energy 

7 conservation standards for residential furnace fans. 

8 My name’s Mohammed Khan and I’m the project manager 

9 for this rulemaking activity.

10 Today’s meeting serves multiple purposes. 

11 Mainly, our goal is to have a two-way discussion. We 

12 want to convey the key points and concepts associated 

13 with this rulemaking, as well as to hear and listen to 

14 your thoughts and potential concerns.

15 • So first the Department wants to present its 

16 methodologies and characterize its analysis to 

17 date. 

18 • Second, DOE wants to discuss specific issues 

19 and invites comment from all participants at 

20 today’s meeting, on the methodologies, 

21 assumptions and data sources used in the 

22 preliminary analyses. 

23 • The last thing we want to describe the 

24 downstream analyses and next steps in the 
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1 rulemaking process. 

2 But as Doug mentioned, if anyone has an 

3 opening statement they want to make, we can allow 

4 that.

5 MR. BROOKMAN: So let’s have opening 

6 statements. We’ll hear from Diane first. Please get 

7 that microphone close to you.

8 Introductory Statements

9 MS. JAKOBS: I don’t know, I’m just assuming 

10 that Sam did a lot of this work, and I just want to 

11 compliment him on the breadth of it. It’s really 

12 intimidating, all the detail. And just – I tried to 

13 go through it. I’ve got all my post it notes and 

14 things, and just in general, I think some of the 

15 costing – I checked with our procurement people and we 

16 might be using some of your numbers in our 

17 negotiations with Nidec and Regal Beloit, I think. It 

18 looks like you got a better deal than we do. And you 

19 used, it seems, like from ASHRAE 103 E-sub-AE, so I 

20 was kind of on familiar ground with that in some of 

21 your analysis, so that was good.

22 We did – you were asking us for data, and 

23 I’m on -- AHRI, we have been trying to collect data 

24 and just in our lab only, it was like Friday and 

25 Monday we got FER data for three samples and it looks 
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1 like your numbers are a little low compared to mine. 

2 So just in general, I think there’s a lot of good 

3 engineering work and certainly some economic analysis 

4 that I think I can learn a lot from, but I was very 

5 impressed. Thank you. 

6 MR. BROOKMAN: Thank you, Diane. Thank you. 

7 Other comments here at the outset. Your name, please. 

8 MR. ROY: Aniruddh Roy, Air Conditioning, 

9 Heating, and Refrigeration Institute. We’d like to 

10 make one comment with respect to the timing of today’s 

11 meeting. The test procedure has not been finalized 

12 yet and comments or the deadline for providing 

comments on the test procedure is July 30th 13 . And so we 

14 just wanted to comment on the timing of the energy 

15 conservation standards meeting. Because I think a 

16 bunch of the stakeholders are going to be submitting 

17 comments, or expected to provide something to DOE by 

July 30th 18 , and so we feel that the timing of this 

19 meeting is inappropriate, especially given the fact 

20 that that analysis takes into account the FER metric 

21 which hasn’t been – at least the test procedure hasn’t 

22 been finalized yet.

23 MR. BROOKMAN: Okay. Thank you. Yes, Adam.

24 MR. CHRISTIANSEN: This is Adam from ASAP. 

25 I’ve got some prepared comments that I’d like to 
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1 submit for the record. So the Appliance Standards 

2 Awareness Project leads a broad-based coalition effort 

3 that works to advance standards which deliver large 

4 energy savings, monetary savings, as well as 

5 environmental benefits. Thank you for the opportunity 

6 to participate in today’s workshop. We very much 

7 appreciate the significant work of DOE and its 

8 contractors to advance this important docket.

9 Standards for residential furnace fans have 

10 potential to deliver large benefits. Per DOE’s 

11 analysis in the PTSD we’re going to discuss today, the 

12 energy savings from these products could be as high as 

13 1.67 quads of primary energy. The national economic 

14 benefits of a strong, but reasonable standard could 

15 total between $3.8 and $10.7 billion dollars over the 

16 life of the standard. 

17 In general, we think the approach DOE has 

18 taken in this docket is reasonable. We are pleased to 

19 see that DOE has taken steps to address the 

20 complicated aerodynamics in cabinets. As DOE has 

21 noted these effects influence ultimate energy 

22 consumption of furnace fans. We’re also very 

23 supportive of an energy standard being developed on a 

24 rating method that includes measurements from multiple 

25 operating points. Single point rating methods are 
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1 simply not adequate to capture the complicated 

2 operation of a furnace fan in a meaningful way.

3 One area of concern for us that I’d like to 

4 highlight is the issue of the scope of coverage. DOE 

5 has excluded split system central air conditioning and 

6 heat pump blower coil units and single package central 

7 air conditioning heat pump units in the preliminary 

8 analysis. These products represent about 37 percent 

9 of products that contain furnace fans. It is unclear 

10 to us that the SEER and HSPF ratings fully capture the 

11 furnace fans. We think DOE should consider including 

12 in this rulemaking, air handlers that are part of a 

13 blower coil and single package central AC and heat 

14 pump systems. And we hope today’s hearing will offer 

15 an opportunity to discuss the issue.

16 Again, we look forward to participating in 

17 the hearing and engaging with DOE and other 

18 stakeholders in this rulemaking process and we’re 

19 looking forward to the discussion today.

20 MR. BROOKMAN: Thank you. I’m going to ask 

21 each of you to speak up. Hey, Greg, are you hearing 

22 okay back there now? Is it getting any better? 

23 Crackling. Yeah, we’ve got a guy working on it. 

24 We’ll see if we can improve that. There’s also a fair 

25 amount of feedback up here in the front, I don’t know 
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1 whether everybody can hear that or not, but we’ll be 

2 working on it. 

3 Karim, did you have a comment here at the 

4 outset? Get to the microphone, please.

5 MR. AMRANE: Karim Amrane, AHRI. I just 

6 wanted to restate a little bit this issue of the 

7 timing here. I think DOE has a process rule that 

8 basically lay out how things have to be done. They 

9 have to be done, and test procedures must come before 

10 energy efficiency standard. And here we are doing two 

11 things at the same time. DOE has spent a lot of time 

12 doing this analysis based on this metric that may or 

13 may not be what was going to end up being as test 

14 procedures. So again, either we are wasting our time 

15 today or DOE has already decided that that’s going to 

16 be the metric. So I would like to understand why DOE 

17 is doing two things at the same time. I would like an 

18 answer from DOE, maybe legal counsel as well.

19 MR. BROOKMAN: Do you want to do that now? 

20 I’m looking at Michael Kido.

21 MR. KIDO: The timing for this particular 

22 activity, just to emphasize, we’re at a preliminary 

23 stage right now. There’s no proposal right now with 

24 respect to the standards. My understanding is that 

25 with respect to the analysis that we’ve got right now, 
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1 because it’s preliminary, it is based on the procedure 

2 that has been proposed earlier. So this is an attempt 

3 to try to get some feedback with respect to the 

4 overall approach that the Agency is considering. 

5 If there’s a need for additional time to 

6 analyze what it is that the Agency is considering as 

7 part of today’s meeting, we can consider possibly 

8 looking at providing a longer comment period. That’s 

9 something that we could look at. But I think the way 

10 that you should view this particular meeting, it’s one 

11 that’s purely preliminary in nature.

12 MR. BROOKMAN: Okay. Thank you. Other 

13 comments here at the outset? Alex, please.

14 MR. BOESENBERG: Alex Boesenberg, National 

15 Electrical Manufacturers Association. I want to thank 

16 the Department for welcoming us here today and ... a 

17 month without a public meeting is ... (Problem with 

18 microphone.) So we weren’t sure if we needed to come. 

19 In fact, it was sort of a hunch to attend. We knew 

20 there were motors that drove fans, so we thought we’d 

21 show up, and the number of people who have said, oh, 

22 boy, we’re glad you’re here, makes us glad we came. 

23 My members will be listening from a motor 

24 standpoint. I’m going to be listening from a slightly 

25 larger systems standpoint as Mr. Khan already alluded 
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1 to, the fan itself is not only a component of a 

2 previously regulated product, but also there’s a fan 

3 in the housing of the motor that drives it and other 

4 effects. And I’m going to be watching for how the 

5 system is discussed because of the precedent that that 

6 sets for some of the rulemakings we have where it’s 

7 pretty hard to divorce the individual components. So 

8 I’m very interested in seeing how the Department 

9 approaches that and what that bodes for some of our 

10 other rulemakings that involve composite systems. 

11 Thank you. 

12 MR. BROOKMAN: Thank you. Yes, it is Craig, 

13 right?

14 MR. MESSMER: Craig Messmer. I want to let 

15 everybody rest assured that I will not be talking 

16 about small duct high velocity at this meeting, since 

17 it is excluded, thank you very much. But I will keep 

18 my comments to the topics, and the technical support 

19 document weighs about six and a half pounds, so you 

20 get an A-plus on the report. Thank you. 

21 MR. BROOKMAN: Okay. Steve Rosenstock.

22 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

23 Again, thank you. I thought the Department did a good 

24 job with the technical support document. We will have 

25 comments, but I think there’s some really bigger 
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1 issues for the Department in terms of not just 

2 furnaces and air conditioners, but also other products 

3 where they’re looking at components. For example, the 

4 DOE has rules on battery chargers now. Well, battery 

5 chargers are components of dozens and dozens of 

6 products, and so it’s always interesting, you look at 

7 the component, you make it more efficient, but what 

8 are you doing to the whole product? Is it making the 

9 whole product more efficient or are there laws of 

10 unintended consequences where the product can be –

11 you’re not changing the efficiency of the whole 

12 product, or even worse, you’re actually increasing the 

13 energy usage of the whole product. 

14 And I think going forward, there is possibly 

15 going to be a resource issue. You have a furnace fan 

16 rulemaking, you have an air conditioner heat pump 

17 rulemaking, you have a furnace rulemaking, and do you 

18 do them all together? Do you do them separately? You 

19 know, three separate tracks? You’re kind of talking 

20 about energy use for heating and cooling. 

21 So I think going forward, this component 

22 versus system is going to be a bigger issue, not just 

23 in terms of energy, but in terms of resources of DOE 

24 and stakeholders. Thank you. 

25 MR. BROOKMAN: Thank you. Steve was 
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1 speaking clearly. Greg, was that better or the same?

2 MR. WAGNER: The same.

3 MR. BROOKMAN: Okay. 

4 MR. WAGNER: Actually, that microphone is 

5 very clear.

6 MR. BROOKMAN: Okay. We’re still working on 

7 it. Yes, please, Dave.

8 MR. WINNINGHAM: Dave Winningham, Allied 

9 Air. First of all, I’d like to thank the Department 

10 for the detail of the work that went into this. A 

11 couple of key issues, I think, that the Department 

12 needs to consider.

13 The increasing burden that this and other 

14 metrics are placing on the HVAC manufacturers is 

15 increasing. As this proliferation of metrics 

16 increase, these costs are going to be passed along to 

17 the consumer. The net result of this could 

18 potentially be a reduction in the affordability of the 

19 products within this industry. I think we’ve seen 

20 some of that as we went from 10 SEER to 13 SEER.

21 While the energy conservation side of this 

22 is very important, we need to look at ways that we can 

23 reduce the burden of this and other metrics. The test 

24 procedure that has been proposed is a completely 

25 separate set up, completely separate test procedure 
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1 than the AFUE test procedure that is applied to the 

2 majority of the products that this is referenced to.

3 I would ask – and we will make comments in 

4 regard to the test procedure – that the Department 

5 look at ways that the data needed for these metrics be 

6 aligned with other test procedures and test setups.

7 I would also like to comment and second 

8 Diane’s findings that some of the assumptions going 

9 into – in regard to the cost differential of the 

10 components, as well as the performance of the 

11 products, needs to be reviewed thoroughly. I would 

12 agree that we could use some help negotiating our 

13 motor prices, because they don’t align with the 

14 Department’s assumptions.

15 MR. BROOKMAN: Okay. Thank you. Greg. 

16 Thank you for getting that close.

17 MR. WAGNER: Greg Wagner, Morrison Products. 

18 I want to echo the gentleman’s sentiments from the 

19 Edison Electric Institute. The combined rulemaking 

20 process of all the various standards that go into the 

21 various appliances creates a huge burden to comply 

22 with each one of these regulations. In addition to 

23 that, appliances being regulated as components versus 

24 being regulated as systems can lead to sub-optimal 

25 systems, rather than optimal overall energy use.
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1 In this case we’re looking at electrical 

2 energy versus performance of the appliance in the 

3 furnace case. Consumers are going to be looking at 

4 two different numbers, and they’re going to have to 

5 make a decision on which number is more important, the 

6 electrical or the furnace performance. So the 

7 question is going to be, how do they evaluate and how 

8 do they make choices based upon these two different 

9 numbers. So combining standards to where it reduces 

10 the regulatory burden is good. It also helps the 

11 consumer in making the appropriate choice for energy 

12 efficient designs.

13 MR. BROOKMAN: Okay. Other comments here at 

14 the outset? We have one individual, Terrell Small has 

15 raised his hand. Terrell, unmute your phone and 

16 hopefully as you speak, you should come here into this 

17 room.

18 MR. SMALL: Doug, can you hear me?

19 MR. BROOKMAN: Yes, we can hear you but 

20 speak up.

21 MR. SMALL: Yes, Doug. First, I’m sorry 

22 that I’m not up there. This is Terry Small with 

23 Mortex, and I’m sorry I’m not up there with you guys. 

24 I want to thank Mohammed and his team at DOE for all 

25 the hard work that went into this, including Sam and 
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1 his team, and of course you, Doug, for moderating it. 

2 We’re a small manufacturer that builds 

3 products in some of the niche markets that would be 

4 impacted by this. Some of the slices of the pie chart 

5 in the summary, the very thin ones, are where we are. 

6 And this is going to be a big burden on us, and of 

7 course our customers who will ultimately have to pass 

8 the cost of doing all this through to, particularly in 

9 this weak economy. We build to order, very low 

10 quantities. Some models that we offer are never built 

11 during the year, so the burden of having to test

12 something that you’re not selling is going to be 

13 particularly bad. I would highly recommend that AEDM 

14 be allowed that perhaps would lessen some of the 

15 testing burden. 

16 We also disagree with some of the production 

17 cost. We pay a lot more for our motors than is 

18 basically described in some of the economic analysis, 

19 so that in my mind, calls into question some of the 

20 initial economic analysis that was done.

21 And finally, I agree with Diane and the 

22 group that the values, what are called baseline 

23 values, look like to me that they may have been 

24 generated from published data, you know, which is 

25 maybe not the best way to generate that stuff. The 
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1 published data is based on ASHRAE 103, and whereas the 

2 test NOPR that DOE is proposing is amped (ph) at 210. 

3 I think that table is just completely premature. 

4 We’re thinking that some of our values will be above 

5 those values that are in that table.

6 But anyway, thank you for allowing us to 

7 participate in this.

8 MR. BROOKMAN: Yes, thank you. Terry, and 

9 to all of you via the webinar, the Department does 

10 wish to make this accessible to you, so if you wish to 

11 speak, raise your hand and we’ll fit you in. Final 

12 comments here at the outset before we move on. Okay, 

13 then to Mohammed.

14 Overview

15 MR. KHAN: First, let me thank everyone for 

16 those really good comments. I think it is on, let me 

17 just speak up. Again, let me just first thank 

18 everybody for those very good comments. Those were 

19 comments that – those are the kinds of comments that 

20 we’re looking for. Let me also add that with those 

21 comments, I’d like to get written comments and 

22 certainly any kind of data or information that you 

23 might have to support some of the assertions that I 

24 just heard. And, for example, the gentleman here to 

25 my left mentioned that in trying to bolster the 
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1 performance of the fan and motor assembly, it could 

2 have some unintended consequences, such as reducing 

3 the overall furnace performance, and there’s a risk of 

4 a consumer having to trade off one for the other. I 

5 think what I’d be interested in knowing is how far can 

6 we actually push that motor performance – fan assembly 

7 performance before there actually is a decline in the 

8 entire system? So if there’s any kind of data,

9 modeling, or information that you have on that, that 

10 would be great. So with that, I’m going to resume my 

11 presentation.

12 Comments. Comments are central to the 

13 success of this rulemaking. All participants are 

14 encouraged to submit summary comments and raise any 

15 additional issue relevant to the rule. As indicated 

16 in the Federal Register notice which was published on 

July 10th 17 , the close of the comment period is September 

10th 18 . 

19 Let me also point out here on this slide, 

20 the sample call-out box. We will use these throughout 

21 our presentation to identify certain issues the 

22 Department seeks detailed information on. For 

23 reference, please note that the numbering of the issue 

24 boxes correspond to the issues listed in the executive 

25 summary of the technical support document.
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1 Again, because your feedback is very 

2 important, I want to make sure everyone is clear on 

3 how to submit comments. This slide provides the

4 postal, courier, and e-mail addresses which are 

5 appropriate for submitting your comments. Please 

6 include the information here at the top so that your 

7 comment is properly identified and catalogued. While 

8 not provided on this slide, you may also submit 

9 comments via www.regulations.gov. Regulations.gov is 

10 a new, on-line tool for submitting comments on all 

11 federal government proposed rules. Let me also point 

12 out again that the comment period closes on September 

10th 13 .

14 Meeting Overview

15 This slide outlines the agenda for today’s 

16 meeting. Following my introduction and overview, we 

17 will discuss all of the preliminary analyses including 

18 the market and technology and screening analysis, 

19 engineering analysis, and all other analyses presented 

20 here before we describe the next steps.

21 So what’s driving this effort? The Energy 

22 Policy and Conservation Act, as amended by the Energy 

23 Policy Act of 2005, charges DOE to establish 

24 applicable energy conservation standards or energy use 

25 standards for electricity use for the purposes of 
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1 circulating air through ductwork. After being amended 

2 in 2007 by the Energy Independence and Security Act, 

3 EPCA requires DOE to address standby mode and off mode 

4 energy use in its standards that are adopted after 

5 July 2010. EISA 2007 also says that the energy use 

6 associated with standby mode and off mode must be 

7 integrated into the energy conservation standard 

8 unless existing standards already account for standby 

9 mode and off mode, or integration is not technically 

10 feasible. If integration is not technically feasible, 

11 EPCA requires separate standards for standby mode and 

12 off mode energy use.

13 This slide summarizes the Department’s

14 activities for furnace fans to date. As I said at the 

15 outset of our meeting, DOE currently does not have a 

16 test procedure or standard for furnace fans, but has 

17 made significant progress. For the test procedure 

18 which DOE is developing in parallel to the standards 

19 rulemaking, DOE published a Notice of Proposed 

20 Rulemaking on May 15, 2012, and on June 15 it held a 

21 public meeting. The comment period for the test 

procedure NOPR remains open until July 30th 22 . I 

23 encourage all of you to submit comments on the test 

24 procedure NOPR, so please appreciate that there are 

25 only three days left to do so.
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1 The energy conservation standard effort was 

2 initiated on June 3, 2010 when the Department 

3 published its framework document for its standards 

4 rulemaking. DOE then solicited and heard comments 

5 regarding the framework document at its June 18, 2010 

6 public meeting. 

7 And today we’re holding our public meeting 

8 for the preliminary technical support document which 

9 DOE published a notice for just over two weeks ago on 

July 10th 10 . I’d like to remind you that the comment 

11 period for this phase of the rulemaking closes on 

September 10th 12 .

13 One last point on this slide, DOE’s

14 preliminary analyses also was conducted using the test 

15 procedure proposed in the NOPR. And again, comment 

period for that ends July 30th 16 .

17 DOE proposed a performance metric for 

18 furnace fans that provides a measure for annual 

19 electricity consumption, normalized by annual 

20 operating hours and air flow. The FER equation 

21 reflects cooling, heating, and constant circulation 

22 operating times. Integrated fan efficiency rating or 

23 IFER modifies FER to account for standby mode and off 

24 mode operation, and is applicable to hydronic air 

25 handlers.
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1 In deciding whether a new or amended 

2 standard is economically justified, DOE must determine 

3 whether the benefits of the standard exceed its 

4 burdens. DOE is directed by EPCA to consider seven 

5 factors in making this determination. This slide 

6 lists the seven factors as well as the corresponding 

7 analyses that DOE performs. Throughout the day we 

8 will be describing the analyses in detail to make the 

9 relevance and relationships between each analysis and 

10 the seven EPCA factors.

11 This slide depicts the rulemaking stages and 

12 shows the sequence and relationships between the 

13 various analyses the Department conducts. DOE is 

14 currently in the preliminary activities phase wherein 

15 it conducts the sets of analyses shown here. What’s 

16 important to recognize here is that the results or 

17 outputs of the proceeding analyses are inputs to the 

18 downstream analyses. Because of this relationship, 

19 it’s important for the Department to receive your 

20 input on its methodologies and any relevant data to 

21 help insure accuracy and completeness.

22 Now just in case you haven’t already fully 

23 read each page of the Federal Register notice, and the 

24 17 chapters and the 17 appendices of the technical 

25 support document, we prepared this slide to point out 
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1 the key documents that describe the preliminary 

2 analysis activities.

3 • First is the executive summary that provides an 

4 overview of the preliminary activities in the 

5 TSD, summarizes key analysis results and lists 

6 the issues that the Department seeks your comment 

7 on.

8 • Chapter two of the preliminary TSD provides a 

9 review of analyses and a discussion of the 

10 comments DOE received from interested parties on 

11 the framework document, including DOE’s 

12 interpretations and responses.

13 • And finally, the Federal Register notice itself, 

14 which discusses in a broader sense, the 

15 rulemaking process, the preliminary activities 

16 analyses, and where to find the relevant 

17 documents on the DOE web page.

18 This concludes my portion of the 

19 presentation and we’ll proceed with the market and 

20 technology assessment and screening analysis portion.

21 MR. BROOKMAN: Next we’re going to hear from 

22 Sam Jasinski.

23 Market and Technology Assessment and

24 Screening Analysis
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1 MR. JASINSKI: Thank you, Mohammed. My name 

2 is Sam Jasinski from Navigant Consulting. I’m going 

3 to start by providing or giving a discussion about the 

4 market and technology assessment with a lead into the 

5 screening analysis. As Mohammed showed you, we 

6 provided these roadmaps to just to kind of show you 

7 how each analysis fits into the broader scope of the 

8 rulemaking process. 

9 The market and technology assessment has two 

10 essential parts, the market assessment and the 

11 technology assessment. The purpose of the market 

12 assessment is to provide a quantified and qualified 

13 characterization of the furnace fan, and in this case, 

14 residential HVAC market. As Mohammed described, the 

15 earlier – Mohammed described the statutory language 

16 that’s driving this rulemaking. DOE has interpreted 

17 that language to provide a tentative definition for 

18 furnace fan. Furnace fan means any electrically 

19 powered device used in a residential heating, 

20 ventilation, air conditioning product for the purpose 

21 of circulating air through the ductwork. 

22 DOE realizes that a significant number of 

23 products may fit this broad interpretation of the 

24 statutory language and the resulting definition. So 

25 this graphic here tries to provide a summary of HVAC 
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1 products or key HVAC products that contain a furnace 

2 fan, include a furnace fan, according to this 

3 definition. I don’t know how easy that is for 

4 everyone to see, but essentially the HVAC system here 

5 is simply applied to indoor and outdoor units. And 

6 the boxes in red indicate the components of HVAC 

7 systems that contain a furnace fan according to that 

8 definition.

9 On the left you can see a lone outdoor unit, 

10 it says weatherized and packaged unit. That’s 

11 essentially an entire HVAC system in itself. And to 

12 the right, leading out from the condensing unit – can 

13 you read this graphic? Each path represents a unique 

14 system. So for instance, a condensing unit can be 

15 paired with a coil only unit, and then a coil only 

16 unit can be paired with an electric furnace and 

17 modular blower. So that particular path would 

18 represent one variation of an HVAC system, and so 

19 forth.

20 As I mentioned, DOE realizes that a 

21 significant number of HVAC products contain a furnace 

22 fan according to that definition. The provisional 

23 scope of coverage includes furnace fans that are 

24 integrated in 63 percent of furnaces, air 

25 conditioners, and air handling units that include 
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1 furnace fans. 

2 In this pie chart here, provides a market 

3 share according to the same products that were shown 

4 in the previous graphic by shipments. The products to 

5 the left that are in black are those that are 

6 excluded, are not considered in this rulemaking, and 

7 those include single package central air conditioners 

8 and heat pumps, as well as split central air 

9 conditioners and heat pump or coil units. The 

10 remainder of the – yes.

11 MR. BROOKMAN: Let’s – Diane first. Go 

12 ahead.

13 MS. JAKOBS: Okay. Would you mind just 

14 going back a slide? So when you talk about coil only 

15 unit, I was trying – are you referring to like coil 

16 only ratings that we do?

17 MR. JASINSKI: Here this is just a 

18 representation of the product. So that would be the 

19 coil only component of a larger HVAC system.

20 MS. JAKOBS: Well, what’s a coil only unit? 

21 MR. JASINSKI: That’s the – what you’re 

22 referring to, that would be something – it’s not the 

23 coil only rating, it’s a coil that would be paired 

24 with a furnace, or with a modular blower. It’s 

25 essentially just the – it’s a coil that would be 
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1 paired with a condensing unit.

2 MS. JAKOBS: Oh, okay. So you’re talking 

3 about the coil only, so the homeowner buys it as a 

4 component and then it’s matched with –

5 MR. JASINSKI: Yes.

6 MS. JAKOBS: Okay. Thank you. 

7 MR. JASINSKI: Anybody else?

8 MR. BROOKMAN: Dave and then Abigail.

9 MR. WINNINGHAM: Yes, it appears as if you 

10 have a conflict in between your information. You show 

11 the indoor unit as a blower coil unit being covered in 

12 this slide. In the next slide, you show it not. And 

13 then in the introduction, 1.2 Excluded products, it 

14 specifically calls that, you know, “Excluded products, 

15 other products that incorporate furnace fans such as 

16 central air conditioning, CAC floor coil units.

17 MR. JASINSKI: So it might be a little bit 

18 easier if these graphics were on the same slide, but 

19 the intent here is to show that DOE’s broad 

20 interpretation of the language would mean that – for 

21 this slide, the red only means that it would meet that 

22 definition. So according to the definition the blower 

23 coil only unit – I’m sorry, the blower coil unit 

24 contains a furnace fan according to that definition. 

25 However, for the preliminary scope of coverage of this 
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1 rulemaking, that’s being excluded. So it is a furnace 

2 fan, but it’s not being considered in this rulemaking.

3 MR. WINNINGHAM: Okay. Thank you. 

4 MR. BROOKMAN: Okay. Abigail.

5 MS. DAKEN: That was in fact my question. 

6 So I’m going to follow up with another one instead, 

7 which is, I assume you’re going to get into why you 

8 are not considering these later on in the 

9 presentation?

10 MR. JASINSKI: Yes – well, I’m not sure that 

11 it’s explicitly stated in the presentation. We 

12 provide details about the scope of coverage in chapter 

13 two as well as chapter three of the TSD.

14 MR. BROOKMAN: Joanna.

15 MS. MAUER: Joanna Mauer. So we recognize 

16 that fan energy is captured to some extent in the test 

17 procedures for central air conditioners and heat 

18 pumps. Our concern is that the external static 

19 pressures that are assumed in the test procedures for 

20 central AC and heat pumps are unrealistically low, 

21 point one to point two. DOE’s analysis of field data 

22 for the furnace fan test procedure rulemaking has 

23 shown that external static pressures in the field are 

24 more like point seven – sorry, point five to point 

25 seven, in that range. So clearly there’s a 
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1 significant difference. And we’re concerned that the 

2 central AC and heat pump test procedures don’t 

3 accurately reflect fan energy consumption in the 

4 field, and this can also result in air handlers not 

5 being able to provide sufficient air flow in the 

6 field, which can affect both comfort and heating and 

7 cooling efficiency.

8 Now, we’ve heard from manufacturers that

9 changing the external static pressure values in the 

10 central AC and heat pump test procedures would 

11 represent a significant burden because they’d have to 

12 re-rate all of their products. And we understand that 

13 concern, and we think a way around this is to include 

14 furnace fans that are part of blower coil and single 

15 package central AC and heat pump products in the 

16 furnace fan rulemaking. And the SEER and HSPF ratings 

17 could be left alone.

18 MR. BROOKMAN: Thank you. Charlie 

19 Stephens.

20 MR. STEPHENS: Charlie Stephens. We have 

21 some additional concern that these products that are 

22 indoor units for AC and heat pump systems are also 

23 sold separately. I know, I’ve installed or overseen 

24 the installation of a number of them myself, so I know 

25 it happens. And I also am someone who specifies these 
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1 things and I have to specify them typically by model 

2 number, or several model numbers because there’s no 

3 other metric to use for these things when they are 

4 sold separately as part of – when they’re not part of 

5 a split system. I can’t specify them by HSPF or SEER, 

6 you know, I’m only specifying an air handler. So it 

7 gets a little difficult at times to tell a contractor 

8 who doesn’t sell this brand but sells somebody else’s 

9 brand, exactly what it is you’re specifying because 

10 there is no metric for these things. There is no 

11 rating for these things, and some contractors, quite 

12 frankly, don’t understand the importance of what the 

13 specification is.

14 So these things are sold fairly commonly as 

15 air handlers for houses out where I live, and I think 

16 they need – we’re very concerned that they need some 

17 sort of a separate rating, regardless of the fact that 

18 they are often found as an indoor unit in a split 

19 system. So we would like to see the Department 

20 include those in some way. We would also like to have 

21 them included in a way that isn’t overly burdensome to 

22 test in addition to the other testing, so some 

23 consistencies would be nice. But in the meantime, we 

24 feel strongly that they should be included in this 

25 rulemaking.
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1 MR. BROOKMAN: Other comments here before –

2 Diane.

3 MS. JAKOBS: I’m not sure I followed which 

4 thing Charlie was talking about.

5 MR. BROOKMAN: Diane, you’ve got to get 

6 close to that microphone, please.

7 MS. JAKOBS: I’m sorry. I didn’t know which 

8 thing –

9 MR. STEPHENS: (off mic) The box that has 

10 black – not considered in this rulemaking.

11 MS. JAKOBS: So an air handler that would be 

12 matched with that heat pump. Okay. 

13 MR. BROOKMAN: Okay. Terry Small has his 

14 hand up. Terry, speak, please.

15 MR. SMALL: Yes, Terry Small with Mortex. 

16 Sam, I’m wondering, are you excluding, for instance, 

17 these type products that would be used in multifamily, 

18 perhaps considered commercial fan coils? They may 

19 have, particularly in the hydronic, you know, they may 

20 have a hot water source that’s a boiler or a big hot 

21 water heater, may have a chiller attached. Is all of 

22 that type product excluded from this?

23 MR. JASINSKI: The scope of coverage of this 

24 rulemaking is limited to residential products, so this 

25 was an issue that was brought up during the test 
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1 procedure public meeting also. We’re asking for 

2 manufacturers, especially of hydronic air handlers 

3 because they’re somewhat of an emerging product, to 

4 provide information about how they are used, so that 

5 we can consider factors like when they’re used in 

6 multifamily homes, to be sure that we keep the scope 

7 of coverage limited to residential products.

8 MR. SMALL: Well, you know that it’s been 

9 traditional that fan coils or ceiling mount units or 

10 wall mount units have been used in the larger 

11 multifamily apartment buildings, et cetera. So I think 

12 you need to be pretty specific. Of course, I guess 

13 you’re asking for comments, but I mean there’s a gray 

14 area here that is not well laid out in the way you 

15 described it here.

16 MR. BROOKMAN: Okay. Thank you. Final 

17 comments before we move on? Okay. 

18 MR. JASINSKI: So, with that identified in 

19 the scope of coverage, DOE has identified nine key 

20 product classes that represent most of the energy use 

21 associated with furnace fans considered in this 

22 analysis, because they are associated with the 

23 products that have the highest number of shipments. 

24 And because these are pretty important, I will go 

25 through the labor of reading through each one of 
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1 those.

2 MR. BROOKMAN: Sam?

3 MR. JASINSKI: Yes.

4 MR. BROOKMAN: Hold on a second, if you 

5 would please. Jim Vershaw has his hand up. Jim, does 

6 your comment relate to the previous slides?

7 MR. VERSHAW: Yes.

8 MR. BROOKMAN: Speak up.

9 MR. VERSHAW: This discussion about whether 

10 or not fan coil units and other things should be 

11 included in the standard points out the issue when you 

12 try to put standards around components of systems. 

13 The gentleman who was concerned about an air handler 

14 for special installations not having ratings, which 

15 really should be a system rating. This is going to 

16 create over and over and over, issues on how to 

17 regulate components of systems when we ought to look 

18 at the system level performance of these things. In 

19 particular with heat pumps and air conditioners in 

20 which blower coils are always part of the performance 

21 and the standard set at the certain external static 

22 pressure, we do that. If you start putting another 

23 standard on top of that – a consumer who only buys an 

24 air conditioning system or heater once or twice in his 

25 lifetime, will be totally confused as to what’s going 
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1 on and it will all be lost – all this effort will be 

2 lost on the consumer. It’s important that we start 

3 thinking about this in terms of systems. Thank you. 

4 MR. BROOKMAN: Thanks, Jim. Okay.

5 MR. VERSHAW: Oh, and one more thing. The 

6 gentleman who’s speaking right now – his voice is 

7 fading in and out and I’m having a hard time picking 

8 up everything he’s saying.

9 MR. BROOKMAN: Thanks – we’re working on it. 

10 We’re having trouble with the audio today. We’re 

11 going to ask him to speak loudly. So thanks for 

12 flagging that. Back to Sam.

13 MR. JASINSKI: Thank you. I’ll pick up 

14 where I left off. I want to read through the nine key 

15 product classes.

16 1. Non-weatherized, non-condensing gas furnace fans

17 2. Non-weatherized, condensing gas furnace fans

18 3. Weatherized gas furnace fans

19 4. Non-weatherized oil, non-condensing furnace fans

20 5. Non-weatherized electric furnace and modular 

21 boiler fans

22 6. Heating and cooling hydronic air handler fans

23 7. Manufactured home non-weatherized gas non24 condensing furnace fans

25 8. Manufactured home non-weatherized gas condensing 
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1 furnace fans

2 9. And lastly, manufactured home electric furnaces 

3 and modular boiler fans.

4 Important to note here is that DOE 

5 differentiated these product classes by application 

6 and internal structure that impacted air flow and 

7 furnace fan performance. 

8 DOE also identified 12 additional product 

9 classes that represent significantly fewer shipments 

10 and significantly less energy use for the preliminary 

11 analysis. DOE grouped each non-key product class 

12 with a key product class to which it is closely 

13 related in internal structure and fan performance 

14 related – I’m sorry, application and fan performance 

15 related internal structure, which as I mentioned, are 

16 the primary criteria for differentiating between the 

17 key product classes.

18 I’m going to toggle between the next slide 

19 and back to this one because I think it will provide a 

20 snapshot of what I mean here.

21 As I mentioned, here are the groupings. You 

22 can see on the left, the column on the left is the key 

23 product classes for this rulemaking, and then to the 

24 right you can see the proposed additional product 

25 classes that I’m speaking about that have the fewer 
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1 shipments and significantly less – contribute – I’m 

2 sorry, significantly less energy use than the primary 

3 product classes, and this shows the groupings. I won’t 

4 read through the 12 additional product classes, but 

5 that just provides a graphic for what I mean as to the 

6 method that is being used.

7 DOE assigned the baseline FER or IFER and 

8 analysis results of each key product class to the non9 key product classes with which it is grouped. And if 

10 DOE continues with this approach in the NOPR, it would 

11 result in proposed efficiency levels for each 

12 additional product class that is equivalent to the 

13 proposed efficiency level with the key product class 

14 with which it is paired.

15 So as an example, I’ll use the top one, if 

16 DOE continues with this approach, the baseline and 

17 analysis results for weatherized gas furnace fans 

18 would be assigned to weatherized non-condensing oil 

19 furnace fans, and the result would be that in the 

20 Notice of Proposed Rulemaking whatever efficiency 

21 level trials standard level was proposed for the 

22 weatherized gas furnace fan would also be proposed for 

23 weatherized, non-condensing oil furnace fans.

24 Anybody has any questions?

25 MR. BROOKMAN: Steve Rosenstock.
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1 MR. ROSENSTOCK: Steve Rosenstock, Edison 

2 Electric Institute. So is this another situation 

3 where the products on the left are being used as a 

4 proxy – the results are going to be proxy for the 

5 products on the right side of the table?

6 MR. JASINSKI: Yes.

7 MR. ROSENSTOCK: So, eventually, from the 

8 previous slide there’s nine product classes, and then 

9 with this there might be 21 product classes with the 

10 final rule. Is that –

11 MR. JASINSKI: Yes.

12 MR. ROSENSTOCK: Okay. Just to give –

13 MR. JASINSKI: Yes, and a clarification –

14 there’s only three key product classes shown here 

15 because all the 12 additional product classes are 

16 grouped with them. The six remaining key product 

17 classes don’t have any additional product classes.

18 MR. BROOKMAN: So if would be nine plus 

19 three?

20 MR. JASINSKI: No, it would be the nine plus 

21 the 12 that are shown here, so 21.

22 MR. BROOKMAN: Okay. Joanna.

23 MS. MAUER: Joanna Mauer. I just want to 

24 make sure I understand. Are you saying that the same 

25 FER values would be used for the other product 
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1 classes? The same values?

2 MR. JASINSKI: Yes.

3 MS. MAUER: So I guess what’s the benefit of 

4 having the separate product classes as opposed to 

5 combining them into one?

6 MR. JASINSKI: Well, as I’ll get to in the 

7 next slide, this is an issue that DOE is requesting 

8 comment on. Essentially because the products that 

9 make up the additional product classes have so few 

10 shipments, there’s not a lot of data readily available 

11 to perform a detailed analysis to the level that is 

12 possible for the key product classes. So a little 

13 early, I’ll ask that manufacturers and other 

14 interested parties provide comment on, and data, about 

15 shipments, the prevalence and also performance-related 

16 data for the 12 additional product classes.

17 MR. BROOKMAN: Diane. Close. Get that 

18 microphone close.

19 MS. JAKOBS: Close, okay. Just from your 

20 own FER values, it seems like the manufactured homes 

21 units, they were much lower, and we don’t build those, 

22 but I don’t know if there’s something special about 

23 those where they should be a key product class.

24 MR. JASINSKI: A major factor for the 

25 difference is that in the proposed test procedure, DOE 
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1 is proposing to use a reference system external static 

2 pressure of three-tenths inches water column for 

3 manufactured home products, whereas for the non4 manufactured home products, the proposed reference 

5 system external static pressure is – are on the order 

6 of half an inch water column, and point six five 

7 inches water column.

8 MS. JAKOBS: So it was point six five, so if 

9 you have a manufactured home furnace that doesn’t come 

10 with a coil, wouldn’t that have the point six five 

11 then too?

12 MR. JASINSKI: No, that would – that would 

13 have a point three inches water column. Any 

14 manufactured home product class would use that 

15 reference system external static pressure.

16 MS. JAKOBS: Okay. I’ll have to look at 

17 that. We talked about that in our meeting, and nobody 

18 was real forthcoming from the manufactured home group.

19 MR. JASINSKI: Comments are always welcome.

20 MS. JAKOBS: Okay. And I’ll just have to 

21 look into that, I don’t –

22 MR. BROOKMAN: Tom Eckman.

23 MR. ECKMAN: I think one of the – as I 

24 understand it, one of the reasons is because the 

25 manufactured homes don’t have return ductwork at all, 
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1 basically, a single return pickup in the – near the 

2 furnace, so there’s no – there’s a supply side, but 

3 there’s no return side ductwork.

4 MR. BROOKMAN: Thanks, Tom. Steve 

5 Rosenstock. 

6 MR. ROSENSTOCK: Again, Steve Rosenstock, 

7 EEI. This is kind of a – for that first category, is 

8 a weatherized gas furnace fan for single family home, 

9 non-manufactured home, is going to be used – is a 

10 proxy for the manufactured home even though they have 

11 significantly different external static pressures?

12 MR. JASINSKI: Yes. Well, yeah. In this 

13 case one approach that DOE could take is that it would 

14 use the same raw data from the weatherized gas furnace 

15 fan and potentially use a different reference system

16 external static pressure, so in that case one 

17 potential approach could be to assign a different 

18 baseline and different analyses result based on the 

19 lower external static pressure. But this is – these 

20 are the type of comment that DOE is asking for, really 

21 comments on what is the appropriate approach for 

22 handling the additional product classes in the absence 

23 of the amount of detailed data that’s available for 

24 the key product classes?

25 MR. BROOKMAN: Terry Smith, you’re next. 
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1 Pardon me, Terry Small. I apologize. Terry.

2 MR. SMALL: This is Terry Small with Mortex. 

3 I guess I’m a little confused. So on your baseline 

4 FER values, they were in the executive summary, there 

5 are nine product classes. Really that should have 

6 been 21 values including the additional product 

7 classes? If they all have different baselines? I’m 

8 confused.

9 MR. JASINSKI: So the approach that’s being 

10 presented here is that the baselines that are assigned 

11 to the key product classes, you would assign those to 

12 the additional product classes with which it’s

13 grouped. So essentially, anywhere you see a value for 

14 weatherized gas furnace fan, you would just duplicate 

15 that value for the additional product classes that are 

16 grouped with weatherized furnace fans. So if you 

17 expanded that table, there would be 21 values, but for 

18 each additional product class it would just be a 

19 duplication of whatever the value of the key product 

20 class for which it’s grouped. Does that answer –

21 MR. SMALL: Well just to comment. I think 

22 that the – certainly on some of these product classes, 

23 particularly the hydronic and all that, you’re going 

24 to have some huge variations once you get into the 

25 additional product classes. So I don’t think you’re 
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1 going to find that one size is going to fit all, but 

2 that’s just my opinion, thank you.

3 MR. BROOKMAN: Terry, those kinds of 

4 comments in detail will benefit the Department when 

5 you sent them in.

6 MR. JASINSKI: Yeah, to add to what Doug is 

7 saying – sorry.

8 MR. SMALL: And Doug, what’s interesting 

9 about is unfortunately – you know, we’re a small 

10 manufacturer. We just don’t have the resources. I 

11 mean I wish I had all of our product – I wish that 

12 there was a final test procedure then we could test 

13 our products in about a year’s time we could tell you 

14 where we thought we were. I mean, we’re completely 

15 flying in the dark on this. We’re not certain about 

16 the test procedure, and just to figure out where we 

17 are on all these different products is going to 

18 require quite a bit of testing.

19 MR. BROOKMAN: Thanks, Terry.

20 MR. SMALL: It’s almost as if we’re getting 

21 the carts in front of the horse pretty substantially 

22 on this, and I would really – I would really caution 

23 that we show down on this before we start setting 

24 values, but that’s my opinion, thank you.

25 MR. BROOKMAN: Thank you. Detlef.
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1 MR. WESTPHALEN: Detlef Westphalen, 

2 Navigant. I think one of the things with these 12 

3 additional product classes is that we’re not sure all 

4 of them exist. For instance, the manufactured home 

5 weatherized gas furnaces, and, you know, this is a 

6 framework, a structure with which to say okay, suppose 

7 significant quantities of these are sold. This is a 

8 proposed place to put them within the analysis 

9 structure. And so, you know, we’re presenting this 

10 and requesting comment and also information on, you 

11 know, are these important product classes and what 

12 kind of sales levels are associated with them and what 

13 kind of characteristics do they have that would allow 

14 us to determine, are these the appropriate alignments.

15 MR. BROOKMAN: Okay. Thank you. 

16 MR. JASINSKI: Yes, to add to what Detlef

17 said, in addition to comments on whether these 

18 products exist, and if they do what the level of 

19 shipments are, Terry Small mentioned that there are 

20 factors that would create discrepancies with the key 

21 product classes with which they’re paired. If in your 

22 comments you could detail what those are, that could 

23 provide information for DOE to modify the framework 

24 and could address those discrepancies.

25 MR. BROOKMAN: Final comments on these –
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1 actually I guess there are a couple of slides as they 

2 talk about these groupings. Okay. 

3 MR. JASINSKI: So as I said, this is just a 

4 callout box with the questions that we’ve been 

5 discussing. DOE is interested in comments here and 

6 written comments on the methodology for 

7 differentiating the product classes that I mentioned, 

8 by application, and internal structure. And DOE also 

9 seeks comment and data regarding the market for the 12 

10 additional product classes and their expected energy 

11 performance, specifically historical and future 

12 shipment data and energy performance data that would 

13 be useful to estimate FER or IFER for those product 

14 classes.

15 MR. BROOKMAN: We have another comment from 

16 Terry Small. Go ahead, Terry.

17 MR. SMALL: Yes, I’d just like to add one 

18 other thing. What is really interesting about this 

19 fantastic HVAC industry and market we have is that the 

20 industry has evolved such that it meets the needs of 

21 the consumer, particularly in indoor situations. No 

22 two houses are the same, and the application of HVAC 

23 to houses and apartments varies a lot so you have a 

24 lot of different products, a lot of different heat 

25 loads or cooling loads to meet. And I would be very 
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1 worried that if you set too low of a bar for the 

2 product class -- the overall nine product classes, you 

3 may wide that inadvertently some of these additional 

4 product classes that wouldn’t meet the value, to serve 

5 a particular application in people’s homes or 

6 apartments here in the US. It’s much easier to 

7 prescribe what is happening with an outdoor unit which 

8 sits outside the house or apartment, than it is what 

9 has to be fit into – and a lot of this could be 

10 replacement also remember, so there’s not very much 

11 new construction going on. Most of this is really, 

12 for the foreseeable future, going back in and 

13 replacing existing equipment. It could be a real 

14 problem. So I would recommend that you carefully look 

15 at these additional product classes and take into 

16 account, maybe the uniqueness of their design, and, 

17 you know, just the application. Thank you. 

18 MR. BROOKMAN: Thank you. We’re moving on, 

19 Sam.

20 MR. JASINSKI: Another important aspect of 

21 the market assessment, as I said, is to identify 

22 manufacturers and their market share. Here DOE found 

23 that the top seven gas furnace manufacturers represent 

24 99 percent of the gas furnace market. And the pie 

25 chart on the left shows that market distribution by 
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1 shipments – market share distribution by shipments. 

2 In addition, ten oil furnace manufacturers represent –

3 the top ten oil furnace manufacturers represent over 

4 90 percent of the market and here’s a table here that 

5 shows on the left, the manufacturers that have an 

6 estimated – at least an estimated market share of ten 

7 percent, and on the right, the remaining oil furnace 

8 manufacturers that are estimated to have a less than 

9 ten percent market share.

10 And just to note for related products and 

11 also products like modular blowers that are often part 

12 of the discussion for CAC and heat pump issues, the 

13 market share distribution is very similar to the gas 

14 furnace market share distribution. The manufacturers 

15 are the same and the percentages vary by only a few 

16 points.

17 MR. BROOKMAN: Craig.

18 MR. MESSMER: Yeah, looking at that pie 

19 chart, I didn’t see any -- this is Craig Messmer – I 

20 didn’t see any analysis in the technical support 

21 document for small companies. Is that in there? 

22 MR. JASINSKI: There’s no analysis yet. The 

23 analysis that would relate to small businesses would 

24 be something that would occur in the NOPR stage of the 

25 manufacturing impact analysis. So at this stage, in 
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1 the preliminary analysis, DOE is just striving to 

2 identify small business manufacturers, so that during 

3 the NOPR phase those small business manufacturers can 

4 be included in that manufacturing impact analysis.

5 MR. MESSMER: So that will be included in 

6 the cost benefit analysis, then?

7 MR. JASINSKI: Yes, so I guess it’s 

8 important to raise another request that if you are a 

9 small business manufacturer and you’re not included in 

10 that list that’s included in the preliminary technical 

11 support document, please let DOE know so that you can 

12 be included in those downstream analyses.

13 MR. MESSMER: Thank you. 

14 MR. JASINSKI: The second part of the market 

15 and technology assessment is the technology 

16 assessment, and the important outcome of the 

17 technology assessment is identification of 

18 technologies that manufacturers can use to improve the 

19 efficiency of furnace fans in their products. Here is 

20 a table that shows the technology options that DOE 

21 identified. 

22 • The first is inverter technology for PSC motors. 

23 These are motor controls that can be used to 

24 extend the air flow and flexibility of PSC 
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1 motors. Flexibility here just means the ability 

2 to match the demand.

3 • Second, X13 fan motors. I will say here that DOE 

4 is using X13 to – as a generic term for constant 

5 torque permanent magnet motors, and these motors 

6 are – well, we realize that X13 may be the name 

7 of a specific model by a specific manufacturer, 

8 but they’re often discussed in the industry and 

9 referred to as X13, so that’s the same – we’re 

10 continuing that convention here. And these are 

11 more efficient than PSC motors because they have 

12 typically – they’re more – they operate more 

13 efficiently and they also have an extended air 

14 flow range.

15 • ECM fan motors, again here, ECM is also 

16 trademarked, I believe. Here DOE is using this 

17 as a generic term for constant air flow permanent 

18 magnet motors. And these adds the energy 

19 benefits of X13 motors because they operate more 

20 efficiently and again, extend the air flow range 

21 available.

22 • Next, backward inclined impellors. These are 

23 impellors with backward facing inclined blades 

24 that can be more efficient than the standard or 
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1 forward curved impellers.

2 • Next, toroidal (ph) transformer. And here I 

3 noted that these are only for the standby and off 

4 mode product classes, or the product classes for 

5 which standby and off mode are being considered 

6 in this rulemaking. Toroidal (ph) transformer 

7 has an annular – well, I won’t read these in 

8 detail, but essentially their construction makes 

9 them more efficient than the conventional 

10 laminated core power transformers that are 

11 standard in products.

12 • Next, switching mode power supplies, similar to 

13 toroidal (ph) transformers for the standby and 

14 off mode product classes, and these are more 

15 efficient than the solid state power supplies –

16 I’m sorry, these are solid state power supplies 

17 that are more efficient than the conventional 

18 transformer-based power supplies.

19 • Next, fan housing design modifications. 

20 Optimizing the shape of the fan housing has the 

21 potential to increase furnace fan efficiency.

22 • Next, air flow path design. Modifying the HVAC 

23 product envelope and elements in the air flow 

24 path, such as the heat exchanger, to reduce 
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1 external static pressure also has the potential 

2 to improve efficiency of furnace fans.

3 • And lastly, ECM control relay. Again, also 

4 particular to standby and off mode product 

5 classes. This is the use of a control relay on 

6 an ECM to disconnect it when it’s not needed to 

7 eliminate the standby power that’s associated 

8 with the controls of the ECM motor.

9 Any questions before I move on?

10 MR. BROOKMAN: Brian, please.

11 MR. JAMES: Brian James, Southern California 

12 Edison, on behalf of the California IRUs. Backward 

13 inclined impellers isn’t necessarily a straightforward 

14 energy efficiency improvement. It is more efficient 

15 over a narrow range, but outside of that range it can 

16 actually be less efficient, as well as noisier in 

17 residential applications. So, that should be taken 

18 into consideration that it’s efficient only over a 

19 narrow range.

20 MR. BROOKMAN: Thank you. And this is the 

21 kind of comment the Department would wish to elicit in 

22 this spot, I believe, that is, comments on these and 

23 others that may be missed. Charlie Stephens.

24 MR. STEPHENS: Charlie Stephens. I’ve been 
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1 wondering since we started here where to address this, 

2 and I guess this is as good a place as any, so pardon 

3 me if I go backwards, but this touches on everything. 

4 I’ve been confused ever since I started reading the 

5 technical support document here, about whether we’re 

6 regulating fans or air handlers. And what I see here 

7 in the beginning, in the introduction is that, you 

8 know, a fan is a component of an HVAC product, and I 

9 presume that most of those HVAC products that we’re 

10 talking about are air handlers. Now that definition 

11 is entirely consistent with the list that I’m looking 

12 at here on the slide in terms of what design options 

13 you’re looking at. They pertain to the definition 

14 that DOE put forward of that being an electric motor 

15 and an impeller and a housing and a control, period. 

16 Not the cabinet, not the air flow path, nothing else. 

17 I mean there’s no other option I see here that relates 

18 to an air handler. These all relate, literally, to 

19 the fan.

20 And I can’t help but go back and think of an 

21 analogy here where DOE right now, for instance, is 

22 considering regulating pumps, which are in an 

23 electrically powered device for moving water through 

24 pipes. Not all altogether different from this, 

25 different fluid. And DOE – I mean the proposal I see 
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1 if you insist on the definition of fan that you have 

2 today, regulating – would you regulate pumps as a 

3 component of a residential or commercial appliance 

4 product, clothes washers? Are you going to regulate 

5 pumps by regulating the manufacturers of clothes 

6 washers? So if you insist on this thing being only 

7 about fans, I’m not sure I understand even the 

8 regulation proposals for hydronic air handlers. I 

9 mean if you get into that, there’s lots of things you 

10 could do to those to make them more efficient in terms 

11 of moving the air through them, but they have a fan. 

12 Hydronic air handlers have a fan in them like the 

13 others, but you seem to ambivalent about what you’re 

14 regulating here. And I think if you really are 

15 regulating air handlers, then this list is woefully 

16 short.

17 And, if on the other hand, you’re actually 

18 regulating fans, well, this is the right list. But I 

19 think the Department first and foremost needs to 

20 decide whether it’s regulating fans or air handlers. 

21 And if it’s air handlers in the end because you’re 

22 regulating the manufacturers of air handlers, then 

23 this list is not adequate, and we’ll add to it as we 

24 go through in our comments. But I think – I’ve been 

25 confused all the way through this document because 
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1 people seem to be using this term fan and air handler 

2 interchangeably. And based on your own definitions 

3 here, they’re not interchangeable.

4 MR. BROOKMAN: Thanks, Charlie. Yes, 

5 Abigail.

6 MS. DAKEN: To follow on a little bit on 

7 Charlie’s comment. I’m wondering about the air flow 

8 path design, if you’re regulating the fan itself and 

9 not the air handler, whether that’s appropriate to 

10 regulating the fan. 

11 The other comment I would make is that I’m 

12 sort of listening to people talking about improving 

13 the efficiency of the fan, and whether that is done at 

14 the cost of the efficiency of the entire system. I’d 

15 like to understand that better, but I wonder whether 

16 the difference that Charlie is referring to, between 

17 regulating air handlers and regulating fans, might 

18 help explain it.

19 MR. BROOKMAN: Greg. Thanks for getting 

20 that close.

21 MR. WAGNER: I’ll try. Greg Wagner. To 

22 give a little example on the efficiency of components 

23 versus systems, with the advent of 13 SEER, 14 SEER 

24 regulations, coils have grown in size to take up more 

25 space in the heating volume, if you will, inside any 
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1 residence, and so it’s reduced the size that’s 

2 available to furnaces, and as such, furnaces have 

3 shrunk in size since the advent of the 13 SEER 

4 regulation. That leaves less room for blowers and 

5 they’re less efficient when they’re smaller in size. 

6 So there are systems that have to be designed to meet 

7 the performance for the other regulations, and those 

8 drive what happens in terms of design options 

9 available to people that are putting together the 

10 furnace, the air handler systems.

11 MR. BROOKMAN: Okay. Yes, Diane.

12 MS. JAKOBS: There’s also – it’s just 

13 physics, but if you have higher velocity air you 

14 improve the heat transfer between the gas heat 

15 exchanger or the – any heat exchanger. So we can get 

16 a higher AFUE by increasing the air flow, which will 

17 burn more watts. So that’s kind of a – one goes up 

18 and one goes down.

19 MR. BROOKMAN: Thank you. Yes, Dave.

20 MR. WINNINGHAM: Yes, this is Dave from 

21 Allied. Just to kind of add to Diane’s, for our gas 

22 furnace, 80 percent versus a 90 percent furnace. The 

23 majority of the power consumption is on the gas side, 

24 but the heat exchanger for an 80 percent, for 

25 instance, typically less restrictive than a 90 
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1 percent, to extract more efficiency, you put a 

2 secondary coil which is going to typically either 

3 require more power in the blower system, so this 

4 additional metric could drive some unintended 

5 consequences as part of that.

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

7 please, Greg.

8 MR. WAGNER: I was just going to echo that 

9 that secondary heat exchanger is another one where it 

10 is energy consumed to pull out, extract, more energy 

11 and the cost difference between those, since you’re 

12 doing 98 percent in the gas part of it versus two 

13 percent in the electrical consumption, you want to get 

14 the most benefit from the gas part of it from an 

15 energy efficiency standpoint. So those are some 

16 things to answer your questions of the beginning, 

17 Mohammed, so that’s why system effects are the 

18 important part that we need to look at, not just 

19 components.

20 MR. BROOKMAN: Diane – follow on?

21 MS. JAKOBS: Okay. There is just one thing 

22 from your TSD that I learned, and I was aware of it in 

23 Rheem’s furnaces, but I thought I was a special case, 

24 but it looks like the – actually the condensing 

25 furnaces had lower FER values, or lower E-sub-AE 
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1 values than the non-condensing, which was the inverse 

2 of what I thought. But maybe because we all use, or 

3 almost all of us use these two ... coils, and to go back 

4 to Harvey’s air straighterners, maybe we’re helping 

5 them and so we have this space in there for the 

6 secondary coil. I don’t know it was just an unusual 

7 thing that I notice from your data. It is motor 

8 differences? I don’t know. It was weird. 

9 MR. JASINSKI: (comment off mic)

10 MS. JAKOBS: I think -- I know I’ve stated 

11 that but your data doesn’t reflect that. The 80-plus 

12 has lower electrical consumption.

13 MR. BROOKMAN: Do you have any follow on or 

14 should we move on?

15 MR. JASINSKI: We can move on. When we 

16 present the table based on value, we can explore that.

17 MR. BROOKMAN: Okay. 

18 MR. JASINSKI: Because that’ll – it’ll make 

19 it easier for everyone to see what she’s referring to.

20 MR. BROOKMAN: Yes, please.

21 MR. LIN: Paul Lin from Regal Beloit. This 

22 table, and I thought in the analysis you had a higher 

23 efficiency PSC in the analysis, but I don’t see that 

24 on your table here.

25 MR. JASINSKI: In the engineering analysis 
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1 when we get to it, there is an efficiency level that’s 

2 associated with an improved PSC, and an improved PSC 

3 in this sense just means a PSC motor that has – the 

4 baseline is described as a furnace fan that relies on 

5 a PSC motor that has three or fewer air flow control 

6 settings, improved – there are – an improved PSC in 

7 this analysis just refers to those that have more – a 

8 larger number of air control settings which 

9 contributes to a wider range of air flow and also 

10 flexibility.

11 MR. BROOKMAN: We have another individual 

12 who wants to – who’s raised his hand. Jim Vershaw, 

13 you’re next.

14 MR. VERSHAW: Hi, this is Jim Vershaw. I’m 

15 with Ingersoll Rand Trane. A few comments. At first 

16 I agree on the backward inclined impeller comment. If 

17 those were usable in the conventional furnaces, 

18 obviously they would have been used a long time ago. 

19 They are very loud and very tight tolerance, and 

20 they’re difficult to manufacture and they have a very 

21 limited area where you can actually use them with good 

22 efficiency.

23 Second comment has to do with improving the 

24 efficiency of fan systems on furnaces, remember that 

25 in the heating mode all of the heat goes into the 
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1 motor, either goes into moving the air or goes into 

2 the air stream, so as you take that efficiency of that 

3 motor up, you’re going to have to put more gas into 

4 the furnace to maintain the house load. So there is 

5 an effect on how much gas will be used versus how much 

6 electricity is going to be used.

7 The other issue is as you look at higher 

8 statics, remember the PSC motor will unload and 

9 actually use less energy at high statics, whereas the 

10 ECM, the ... DC motor will use more energy at the high 

11 statics. So as we start looking at different static 

12 points for measurement for fan versus for systems, 

13 that’s going to be very confusing as to what the 

14 system is really doing, and then the consumer will be 

15 unable to determine how to choose – how to utilize 

16 that information. Thanks.

17 MR. BROOKMAN: Okay. Thank you. We’re 

18 going to keep pressing on here.

19 MR. JASINSKI: After technology options are 

20 identified, DOE conducts a screening analysis, and the 

21 screening analysis is to evaluate the technology 

22 options according to the following criteria:

23 • technological feasibility, 

24 • practicability to manufacture, install, service
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1 • impacts on utility or product availability

2 • and lastly, impacts on health or safety.

3 The technology options that don’t meet these 

4 criteria are screened out or not considered in the 

5 downstream analyses.

6 DOE screened out three technology options. 

7 This table summarizes those technology options and 

8 the reasons they were screened out. First, housing 

9 design modifications. In this case DOE is requesting 

10 more data. DOE did not find any quantified data that 

11 quantified energy savings associated with specific 

12 design modifications to the housing. So if 

13 interested parties have that available, if they could 

14 provide that, DOE would really appreciate it.

15 Secondly, the air flow path design 

16 technology option, and this speaks to a lot of the 

17 discussion that was happening earlier. DOE is 

18 constantly considering the trade off between system 

19 efficiency and component efficiency because of the 

20 unique nature of this rulemaking. So in terms of how 

21 definitions are set, how product classes are 

22 differentiated, DOE is attempting to not neglect the 

23 fact that there are system impacts to the decisions 

24 that are made with regard to the framework and 
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1 methodologies that we are using. So this particular 

2 case, air flow path design was identified as a 

3 technology option because DOE recognizes that there 

4 is an impact on the fan efficiency related to the air 

5 flow path design. Similar to the test procedure, the 

6 fan being tested as it is factory installed in the 

7 HVAC product for similar reasons. But in this case, 

8 the air flow path design technology option was 

9 screened out because DOE understands that there are 

10 impacts on thermal performance. However, on 

11 quantifying them and understanding the tradeoffs is 

12 something that DOE requires more information for, and 

13 because of the impacts and a lot of the examples that 

14 were provided by manufacturers here, there is a 

15 chance that if overall system efficiency is impacted, 

16 that product utility could be impacted. And as I 

17 stated earlier, one of the screening analysis

18 criteria is product utility. So for those reasons, 

19 the air flow path design was preliminary screened out 

20 for this analysis.

21 Lastly, ECM control relay. This is the 

22 standby and off mode technology option where relay 

23 would be used to eliminate the standby power 

24 consumption of ECM motors when they’re not being 

25 used. Again, this impacts product utilities, 
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1 specifically reliability, because the control – if 

2 ECM motor controls are turned off and on repeatedly, 

3 DOE has received comments that that could shorten the 

4 life of the motor which has an impact on product 

5 utility.

6 So after the screening analysis, DOE 

7 retained six technology options for the following 

8 engineering analysis. For more information about the 

9 screening analysis, you can refer to Chapter 4 of the 

10 TSD.

11 MR. BROOKMAN: Let’s just pause there. 

12 Comments on these technology options which the 

13 Department is suggesting in a preliminary way might 

14 be screened out. Adam.

15 MR. CHRISTIANSEN: So just with regard to 

16 the fan housing design modification, I believe – I’d 

17 have to go back to my computer, but I believe there 

18 was a study done in early 2007 –

19 MR. BROOKMAN: Louder, Adam.

20 MR. CHRISTIANSEN: Sorry. I believe there 

21 was a study done early 2000’s by GE that they looked 

22 at things like inlet cone of the fan housing, some 

23 curved sections, you know, improving the outlet 

24 dimensions of the fan, and they actually quantified 

25 some of those energy savings in that report. Those 
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1 are things that don’t necessarily take up a whole lot 

2 of space within an air handler, and I think DOE 

3 should – I’ll forward along the document to the 

4 appropriate person if you don’t know what I’m talking 

5 about, but I think it’s something that should be 

6 looked at.

7 MR. BROOKMAN: Craig Messmer and then to 

8 Diane.

9 MR. MESSMER: Craig Messmer. Can you 

10 explain what you meant by air flow path design? Is 

11 it just the fan scroll housing? Is it the inlet 

12 conditions or the discharge?

13 MR. JASINSKI: (off mic)

14 MR. BROOKMAN: Sam, sorry, your microphone 

15 is not working.

16 MR. JASINSKI: Sounds like it’s on now, 

17 sorry. Yes, the air flow path technology options 

18 here refers to the envelope –

19 PARTICIPANT: It’s off again, sorry.

20 MR. BROOKMAN: Use this one.

21 MR. JASINSKI: Thanks. Does that answer 

22 your question?

23 MR. MESSMER: Yes, and to follow up on that. 

24 What is the baseline air flow path design? I think 

25 you’re going to find that products from different 
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1 manufacturers have different air flow path designs, 

2 and you’re going to have a widely different FER for 

3 different manufacturers. And if we don’t establish 

4 what the baseline is, so how do we know what the 

5 improvements are going to be in the future, or even 

6 if the FER baseline is valid.

7 MR. JASINSKI: Yeah, in this particular 

8 case, DOE did not assign a baseline value because it 

9 was screened out, meaning because the air flow path 

10 design technology option was not considered in the 

11 engineering analysis.

12 MR. MESSMER: I guess what I’m saying is 

13 that it should be.

14 MR. JASINSKI: Okay. 

15 MR. BROOKMAN: It should be screened out.

16 MR. MESSMER: No. It should be considered.

17 MR. BROOKMAN: It should be considered. 

18 Thank you. That’s clarification. Diane. Please.

19 MS. JAKOBS: I wanted to go back to your 

20 comment about –

21 MR. BROOKMAN: To Adam’s comment. Yes.

22 MS. JAKOBS: -- the paper about – we’ve 

23 looked at that paper too and at ASHRAE just last 

24 month, I was talking to some of Greg’s engineers 

25 about whether what’s important is that we’re getting 
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1 close to the wheel in that study, or they’re giving 

2 more space between the sides of the housing and the 

3 wall of the jacket. Because one of the things, 

4 because we have all these components, they all have 

5 to fit together and mix and match. We have fixed 

6 widths, so we’re trying to get a lot of air flow. 

7 We’re trying to use the space we have, and I know our 

8 old Rheem air handler design had really tight – the 

9 sides of the housing were tight to the wheel, and we 

10 felt like that improved our air flow. It was very 

11 difficult manufacturing and we’re always fighting 

12 about – because in manufacturing they had trouble 

13 getting the wheel into the housing and people on the 

14 line would pry it apart and then it would be out of 

15 alignment. 

16 But Craig’s engineers there told me that it 

17 was really that we had more room between the side of 

18 the jacket and the housing, it wasn’t – so all these 

19 things all work together, the air is everywhere and 

20 it’s hard to distinguish exactly what – you know, you 

21 change one thing and you might be changing something 

22 else without realizing it.

23 MR. JASINSKI: So are you suggesting that 

24 air flow path design should be screened out or should 

25 be retained or what?
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1 MS. JAKOBS: Well, as a manufacturer if I 

2 was starting from scratch and I could redesign my air 

3 handler furnace, I would work on air flow path 

4 design, because that doesn’t cost me anything.

5 MR. BROOKMAN: Charlie, I see Dave’s not in 

6 his ..., Dave do you want to jump in here?

7 MR. WINNINGHAM: Yes, I would encourage that 

8 the path design needs to be included. There are 

9 various configurations and designs of blowers, the 

10 development angle, the tolerances, the type of wheel, 

11 the angle of the blades into the wheel, the internal 

12 restrictions – all of these things are – can be 

13 critical and can have a significant difference on the 

14 performance. You know, we’re all trying to squeeze 

15 it into the smallest possible envelope, but there 

16 needs to be a consideration for the design path, or 

17 the air path because that can be a much more cost18 effective option to improve efficiency, rather than 

19 adding, you know, premium components.

20 MR. BROOKMAN: Okay. Thank you. Charlie 

21 Stephens.

22 MR. STEPHENS: Charlie Stephens. I would 

23 concur with all of the comments that have gone before 

24 me here, and the Department seems to, in screening 

25 this out – I mean assuming we’re – the subject of 
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1 this rulemaking is actually air handlers. Air flow 

2 path design, based on my own experience in the field, 

3 can often improve thermal performance when the air 

4 flow path is improved, and can improve the product 

5 utility, but the Department seems to have assumed 

6 that it’s negative, or that because it’s potentially 

7 negative that it should be screened out. I strongly 

8 disagree with that, based – I’m not going to name the 

9 products that I have worked with, but believe me some 

10 of them could have improved everything with a better 

11 air flow path. And I think it is a way to achieve 

12 efficiency relatively cost-effectively.

13 MR. BROOKMAN: Several people are in the 

14 queue. We’re going to go in this order as 

15 efficiently and concisely as possible. Greg. And 

16 then Abigail, and then Steve, and then Adam, briefly.

17 MR. WAGNER: Okay. Greg Wagner. All these 

18 – certainly the first two options, the fan housing 

19 design and the air path design are significant 

20 players in the performance and efficiency of these 

21 products that we’re looking to cover here, and you 

22 can see in the E-sub-AE and the other numbers you’ve 

23 been using that there’s a broad distribution of 

24 electrical consumption, and it’s a function of those 

25 different designs. And the question of how do you 
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1 get a baseline, which I think this is targeting to 

2 where you start a baseline and then what is the max 

3 technology piece, may be difficult to find because of 

4 those parameters that are outside the scope of what 

5 this is, which is a function of heat exchangers and 

6 other things inside this unit. So I understand why 

7 it’s screened out, but to the point of everybody 

8 making these comments, those things do affect the air 

9 flow efficiency.

10 MR. BROOKMAN: Abigail.

11 MS. DAKEN: So I heard somebody say that the 

12 fan is testing in situ in the HVAC product in which 

13 its intended, and what I’m hearing the manufacturers 

14 say is that as long as that is the case, they will in 

15 fact be modifying the air flow design to try to 

16 achieve higher efficiency. And so it seems strange 

17 not to take it into account in the analysis, though 

18 obviously, it’s going to be complicated.

19 MR. BROOKMAN: Thank you. Steve Rosenstock.

20 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

21 Again, I guess I was a little – when I saw that in 

22 the document, I was a little confused about it in 

23 terms of are you talking about the air flow path 

24 that’s really controlled by the manufacturer, the air 

25 flow path that’s really a function of the house, the 
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1 duct work that’s in the house, the existing house, or 

2 the new house in terms of how you can modify that 

3 path to make the fan system more efficient, I guess. 

4 Or are you just talking about the air flow path just 

5 within the fan housing unit, and that’s it? Because 

6 it seemed like you’re saying product envelope. I 

7 thought you were talking a little bit almost about 

8 the duct work where the fan is being placed, or am I 

9 misinterpreting? Again, --

10 MR. JASINSKI: The scope does not include 

11 the duct work of the house.

12 MR. ROSENSTOCK: Specifically just talking 

13 about within the fan unit, regardless of where –

14 MR. JASINSKI: Right. Yes, the HVAC product 

15 itself.

16 MR. ROSENSTOCK: Okay. That threw me off a 

17 little bit, thank you very much.

18 MR. BROOKMAN: Adam, thank you for being 

19 patient.

20 MR. CHRISTIANSEN: This is Adam from ASAP. 

21 I know I commented on the fan housing before, but I’m 

22 encouraged by the conversation here about maybe 

23 considering the air flow path design as well, so I 

24 would support that as well.

25 MR. BROOKMAN: Okay. Thank you. We’re 
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1 moving on to the next slide.

2 MR. JASINSKI: I would also – I’ll just say 

3 that to include the air flow path design, DOE would –

4 the type of information that would be very helpful 

5 from industry participants and interested parties 

6 would be specific, quantified savings related to 

7 specific design changes, but also to echo what 

8 Mohammed said to open the meeting, is that DOE is 

9 also very interested in understanding where the 

10 limits of those design modifications are as it 

11 relates to impacting the overall system efficiency 

12 negatively. So to include a design option for the 

13 fan housing design and air flow path design, that’s 

14 the type of information that DOE’s continually 

15 looking for and would appreciate from interested 

16 parties.

17 MR. BROOKMAN: Diane. Oh, let’s hear from 

18 Mohammed. Go ahead, Mohammed.

19 MR. KHAN: Sorry, Diane, I’ll make this very 

20 brief. I just want to add on to what Sam just 

21 mentioned, looking – we’re asking for the data about 

22 the improvements that can be made with changing the 

23 air flow path design. I would like to see that data 

24 also include not only what levels of improvements 

25 that you can make with whatever kind of changes, but 
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1 also include the cost element of it, so, you know, 

2 how much – and I heard you earlier, Diane, saying 

3 that, I think your words were, it doesn’t cost 

4 anything. But there’s always some cost associated 

5 with anything. So that was it, thanks.

6 MR. BROOKMAN: Diane, follow on.

7 MS. JAKOBS: One of the problems with what 

8 you’re asking – you know I certainly want to help you, 

9 but like Rheem has one design, Lennox has one design. 

10 You know we all have our individual designs, and we 

11 certainly have opinions about each others designs, but 

12 we don’t spend a lot of time testing each others 

13 furnaces. So I don’t know if – I know I was – if we 

14 can use the data from the AHRI directory, I don’t know 

15 if you can use the E-sub-AE and characterize heat 

16 exchangers and try to sort out the data that way, but 

17 certainly at the very maximum each individual 

18 manufacturer could do is give information about their 

19 own equipment, and you would have to analyze it, and 

20 you shouldn’t play favorites.

21 MR. JASINSKI: We would love to do that.

22 MR. BROOKMAN: Yes, please, Craig.

23 MR. MESSMER: Craig Messmer, just to follow 

24 up with what Diane said and what I was trying to drive 

25 at before, there is such a wide variety of air flow 
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1 path designs in the industry, when you do the 

2 baseline, you have to establish what that’s going to 

3 be and what the air flow path is. You can have the 

4 same motor, the same fans, the same everything and the 

5 air flow path can make or break you on the FER. So

6 there has to be some discussion on this, at least with 

7 the baseline. Otherwise you could pick an FER that 

8 only one manufacturer could, in fact, achieve, and 

9 that would not be good.

10 MR. BROOKMAN: This was very useful, this 

11 last discussion. Now we’re going to the last slide. 

12 MR. JASINSKI: And this is just sort of a 

13 summary of the results after the screening analysis. 

14 These are the remaining six technology options that 

15 were considered in the engineering analysis.

16 MR. BROOKMAN: So comments on the remaining 

17 six? Joanna.

18 MS. MAUER: Joanna Mauer. Just a question. 

19 Can you explain what you mean, the third option, ECM 

20 fan motors where it says multi-staging? Can you 

21 explain what you mean by the multi-staging?

22 MR. JASINSKI: Yes. They are used typically 

23 with a furnace that also – a furnace or HVAC that has 

24 multi-stage heating, and DOE found that in using the 

25 FER metric or IFER metric, multi-staging contributes 
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1 to the efficiency improvements of that ECM fan motor, 

2 so it’s sort of a joint technology option that’s used 

3 together. So there’s efficiency benefits of the motor 

4 technology as I stated earlier, that it operates more 

5 efficiently and has a wider air flow range, but also 

6 that it’s usually used in multi-stage products, multi7 stage heating products.

8 MR. BROOKMAN: Diane.

9 MS. JAKOBS: Well, we were just – Greg was 

10 asking if we used PSCs and X13s in the multi-stage, 

11 and we do. But we did a – we set up data collection 

12 equipment with our modulating furnace and to just kind 

13 of explain how it works, our modulating furnace goes 

14 from 40 percent capacity to 100 percent, and what 

15 happened was the furnace would run almost continuously 

16 at 40 percent, and the blower is backed off and 

17 running at a lower speed, but over a longer period of 

18 time. So that’s kind of the trade off that you would 

19 address in the test procedure. But if you’re going to 

20 imagine it’s running at 40 percent of the speed at a 

21 longer time, so it’s not on and off like most people 

22 are familiar with.

23 MR. BROOKMAN: Steve Rosenstock. 

24 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

25 Again, I’ll just say for with the multi-stage 
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1 effecter, you’re also lowering the fan speed. However, 

2 the efficiency metric as proposed is only based on the 

3 maximum fan speed, correct?

4 MR. JASINSKI: No. the efficiency metric 

5 has the consumption from each of three rated air flow 

6 control settings. So if you look at the top of the 

7 equation, you’ll see that it’s – actually, I’ll just 

8 go back to the slide so that everybody can see what 

9 I’m referring to. So if you look at the equation, the 

10 top is a summation of the operating hours times the 

11 power consumption in each rated mode. So for FER it 

12 would be cooling times the maximum – the power 

13 consumption in the maximum air flow control setting. 

14 The heating hours would be multiplied by the power 

15 consumption in the heating mode, or the heating air 

16 flow control setting, and then finally constant 

17 circulation.

18 MR. BROOKMAN: Diane, go ahead.

19 MS. JAKOBS: And it’s actually, for multi20 stage, you had us collect the watts at the lowest 

21 heating speed, but then there’s a ratio and we 

22 increase the hours.

23 MR. JASINSKI: Right. These details are 

24 provided in the test procedure NOPR. I don’t have a 

25 slide that can show that, but what she’s referring to 
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1 is that the trade off that she mentioned earlier is 

2 that you may be running the fan at a lower air flow 

3 control setting, but the hours are increased to 

4 account for that. So each of these variables CH, HH, 

5 CCH, those are the hours that DOE is assigning to 

6 those modes of operation, those are set values based 

7 on analysis that DOE conducted. 

8 So, for instance, CH is set at 640 hours, 

9 heating hours is 830 hours, and then constant 

10 circulation is 400. But for multi-staging to account 

11 for that trade-off, the heating hours of 830 heating 

12 hours, for a multi-stage unit, would be divided by 

13 what’s called the heat capacity ratio, and that’s the 

14 output – ratio of the output capacity in the lowest 

15 heat setting divided by the output capacity in the 

16 highest heat setting, usually results in something

17 around point seven, just for reference. And so that 

18 would expand the 830 heating hours to, I think it’s 

19 1185, I’m not sure.

20 MR. ROSENSTOCK: Can you adjust the air flow 

21 in the denominator as well?

22 MR. JASINSKI: The air flow in the 

23 denominator is the max – only in the maximum, yes.

24 MR. ROSENSTOCK: But you adjust the hours.

25 MR. JASINSKI: Yes.
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1 MR. ROSENSTOCK: Thank you. 

2 MR. BROOKMAN: Final comments on this slide? 

3 These issues, product classes, technology options are 

4 very, very important. We spent a fair amount of time 

5 on them. If we need to spend more time on them when 

6 we return, we can and might, but now it’s time to take 

7 a break.

8 It’s now 10:45. Surprisingly, we are 

9 tracking the agenda, which is a surprise to me, but 

10 let me know – we did have almost an extra half hour in 

11 there because we were efficient on the front end, so 

12 when we return we’ll have to remain efficient to get 

13 through the remainder of the day.

14 Here in the Forrestal Building you must wear 

15 this badge visible above your waist. There are 

16 restrooms on both ends of the hall. If you’re going 

17 to go for coffee, on the ground floor, which is 

18 directly below us, go quickly if you’re going to go 

19 get coffee because we will resume at 11 o’clock. 

20 And thanks for a good start. We really 

21 gained ground on the content here. This was good.

22 (Whereupon, at 11:15 a.m., the meeting was 

23 recessed for a 22 minute period.)

24 MR. BROOKMAN: So our apologies to those 

25 that were joining us via the web. We somehow got 
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1 adisconnect going there, and we, for those that are 

2 joining us by the web again, we’ve delayed the meeting 

3 so that you could be included, and I’m pleased you’re 

4 back with us. We are going to resume with Sam and 

5 launch into engineering analysis.

6 Engineering Analysis

7 MR. JASINSKI: Thanks, Doug. Yes, so I’ll 

8 move on to the engineering analysis. Here’s the “you 

9 are here” slide. The purpose of the engineering 

10 analysis is to evaluate technologies that reduce 

11 furnace fan electrical consumption and characterize 

12 the relationship between the cost to the manufacturer 

13 of implementing those technologies and the expected 

14 energy consumption reduction.

15 To the left you can see a very stylized 

16 representation of the expected relationship between 

17 the cost and efficiency. And essentially, the primary 

18 outcome of the engineering analysis are a set of cost 

19 efficiency curves, one for each key product class in 

20 this particular rulemaking that looks somewhat similar 

21 to that. And those results feed into our downstream 

22 analyses such as the life-cycle cost and payback 

23 period analysis, national impacts, and so on which 

24 will be discussed in further detail later on in the 

25 presentation.
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1 For the engineering analysis, here’s a list 

2 of some of the central sources of information that 

3 were used, publications like Appliance Magazine, the 

4 performance directories from AHRI, and if we look as 

5 far back as GAMA, manufacturer interviews, product 

6 tear-downs, and manufacturing cost modeling, and also 

7 product energy testing was also conducted for this 

8 rulemaking.

9 As I mentioned, DOE tests and tears down 

10 products. DOE acquired units for testing and tear 

11 down to assist in development of the FER and IFER 

12 values. This table here just provides a general 

13 overview of the types of products that DOE selected 

14 for testing and tear down. Twenty-six units were 

15 selected, six manufacturers were represented. DOE 

16 typically tries to select test and tear down units to 

17 span a number of manufacturers and even within –

18 usually tries to select products within the same 

19 product line of a single manufacturer. And in this 

20 particular case, the selections fell in that air flow 

21 capacity range, 800 to 2200 CFM, and that’s typically 

22 the maximum air flow capacity. 

23 DOE also tries to select products that span 

24 the available range of efficiencies, and in this 

25 particular case, DOE targeted these technology 
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1 variations which we’ve kind of touched on in previous 

2 discussions: the motor type, PSC, constant torque, 

3 brushless permanent magnet – referred to as X13, 

4 constant volume brushless permanent magnet – referred 

5 to as ECM. Again, the air flow capacity range. Heat 

6 exchanger type – there are a number of different types 

7 of heat exchangers, depending on the application. 

8 Some examples are clam shell, tubular, drum, hydronic 

9 – and those refer a lot to the application, as I 

10 mentioned, but also the geometry of the heat 

11 exchanger. 

12 DOE also tried to isolate the variation 

13 between non-condensing and condensing units. As was 

14 discussed earlier and mentioned, there are impacts on 

15 fan performance when there is the presence of that 

16 secondary condensing heat exchanger. And finally, DOE 

17 also tried to investigate different fan housing 

18 designs. DOE is aware that there is at least one 

19 proprietary design available.

20 MR. BROOKMAN: Aniruddh.

21 MR. ROY: Aniruddh. Aniruddh, with an H.

22 MR. BROOKMAN: Aniruddh.

23 MR. ROY: Or Roy is fine as well. 

24 MR. BROOKMAN: No, no. I want to get it 

25 right.
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1 MR. ROY: Sam, one question I have for you 

2 on on this slide is, you know, with respect to the 

3 table ES.3.3 and 3.4, you have the backward incline 

4 impellor technology in there. Was that also 

5 considered under these technology variations?

6 MR. JASINSKI: So these represents the units 

7 that were selected for test and tear down. To DOE’s 

8 knowledge there is not a commercially available 

9 product that includes a backward incline impeller, so 

10 information – I’ll get into this – but information for 

11 design options that are not commercially available in 

12 an HVAC product, DOE relied on publications that had 

13 detailed data about expected impacts on energy 

14 performance and cost, if available.

15 MR. ROY: Okay. So the 63 percent reduction 

16 that is shown in that table is based on that data?

17 MR. JASINSKI: The ECM –

18 MR. ROY: For that max tech –

19 MR. JASINSKI: Yes.

20 MR. ROY: Okay. 

21 MR. JASINSKI: It’s based on test and tear 

22 down data as well as data from those reports.

23 MR. ROY: Okay. Thank you.

24 MR. JASINSKI: Anyone else? To develop the 

25 cost efficiency curves, DOE goes through the following 
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1 four steps:

2 • First, DOE defines baseline specifications for 

3 each product class;

4 • Next, DOE identifies design options from the 

5 baseline to max tech as a pathway for improving 

6 the efficiency of the furnace fan;

7 • Next, DOE conducts tear down analysis for the 

8 selected products spanning the available range of 

9 efficiencies;

10 • And then finally, DOE uses a cost model to 

11 generate cost efficiency curves which account for 

12 the full production costs.

13 As I mentioned, the first step is specifying 

14 the baseline. DOE selected baseline models typical of 

15 the least efficient furnace fans used in commercially 

16 available HVAC models. For products that have 

17 previous standards, usually the baseline is set at 

18 whatever the current standard during that rulemaking, 

19 or previous standard. However, because furnace fans 

20 are not previously regulated, there is no previous 

21 standard, and so DOE selected the baseline to be 

22 typical of the least efficient furnace fan that’s 

23 commercially available.

24 Across all product classes, a baseline 
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1 furnace fan includes a PSC motor with three or fewer 

2 air flow control settings, a forward curved impeller, 

3 a standard sheet metal fan housing, a linear power 

4 supply – and again, this is referring specifically to 

5 those product classes where standby and off mode is 

6 considered – and a laminated core power transformer.

7 Any comments on the baseline specifications?

8 DOE, as I mentioned, DOE reviewed –

9 MR. BROOKMAN: No comments on baseline 

10 specification? I just thought I would give you a 

11 chance. Okay. Go ahead.

12 MR. JASINSKI: DOE’s publicly available 

13 information, as well as the FER values and IFER values 

14 that were calculated using the test data to determine 

15 the baseline FER ratings that correspond with those 

16 baseline specifications – we have a question?

17 MR. BROOKMAN: Steve Rosenstock.

18 MR. JASINSKI: On this slide or the –

19 MR. ROSENSTOCK: Thirty-four, the previous –

20 yes, that slide, thank you. So you test data from the 

21 manufacturer or you did your own testing?

22 MR. JASINSKI: It’s a combination of both.

23 MR. ROSENSTOCK: Combination.

24 MR. JASINSKI: DOE was able to find 

25 performance data in specification sheets from 
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1 manufacturers, but then as I mentioned, DOE also used 

2 some – used its own test data for –

3 MR. ROSENSTOCK: Were they the same tests?

4 MR. JASINSKI: Meaning?

5 MR. ROSENSTOCK: Same external static 

6 pressure, same –

7 MR. JASINSKI: Yes.

8 MR. ROSENSTOCK: Okay. Next thing is, 

9 basically on this table, for baseline sample, I want 

10 zero for those cases, right, by way of a dash?

11 MR. JASINSKI: No, it’s not zero. This is –

12 the dash here just represents not applicable in this 

13 particular standard. I’ll explain. So, standby and 

14 off mode for a lot of these products is already being 

15 considered in other rulemaking activities. So, for 

16 instance, furnaces and also some products that might 

17 fall into the CAC scope of coverage, there are test 

18 procedures and standards, either already specified or 

19 being proposed for those particular products. So 

20 their standby is not going to be included in this 

21 rulemaking. 

22 However, for hydronic air handlers, there’s

23 no previous standard and there are no standards or 

24 proposed test procedures for standby and off mode for 

25 those products, therefore that’s being covered in this 
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1 rulemaking.

2 MR. BROOKMAN: Greg and then to Charlie. 

3 Steve, you weren’t done. I’m sorry.

4 MR. ROSENSTOCK: No. So – so basically 

5 because the furnace system has a standby test 

6 procedure or off mode, you’re not going to worry about 

7 it for this, but doesn’t federal law says for any 

8 product with – that you’re doing an efficiency 

9 standard that you have to look at standby?

10 MR. JASINSKI: Yes, I’ll let Michael Kido 

11 speak to the statute.

12 MR. ROSENSTOCK: Okay. 

13 MR. KIDO: Yes, that’s correct, but given 

14 that there’s already some coverage of that particular 

15 level of energy consumption in another portion, we’re 

16 already considering that element as part of another 

17 test procedure. That’s the way we’re viewing it.

18 MR. ROSENSTOCK: Thank you. Okay, again, it 

19 was just – so you’re saying there are some standby 

20 watts but you’re not going to worry about it for this.

21 MR. JASINSKI: I think the confusion here –

22 and I think there’s some detail provided, I believe, 

23 especially in the test procedure NOPR, but the 

24 justification behind this proposed approach is that 

25 the fan is integrated – so well integrated into the 
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1 controls of the HVAC product, that there’s no 

2 distinguishable – that it’s difficult to differentiate 

3 the standby specific to the fan, as opposed to the 

4 standby of the entire product. So the standby of the 

5 entire product for those other products which I’ve 

6 already covered, is already being considered in those 

7 other rulemaking activities. There’s no additional 

8 standby watts that aren’t being considered. What 

9 we’re saying is the same standby consumption of these 

10 products is covered – is considered entirely by those 

11 other rulemakings. And so the similar case would be 

12 for hydronic air handlers, for this particular 

13 rulemaking, we are proposing to account for all 

14 standby and off mode consumption of hydronic air 

15 handlers.

16 MR. BROOKMAN: Greg, I think Charlie has a 

17 comment that relates to this. Charlie, go ahead.

18 MR. STEPHENS: Yeah, I would suggest that 

19 that’s not true. As I suggested earlier, some of the 

20 air handlers that we’re concerned with are air 

21 handlers that are also used as an indoor unit with a 

22 heat pump system, for instance, in our part of the 

23 world. I believe the Department hasn’t finalized that 

24 test procedure yet, to my knowledge, but I believe the 

25 proposals show standby consumption for those systems 
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1 with an outdoor unit to be on the order of 33 watts. 

2 Now the vast majority of that standby power is not in 

3 the air handler, it’s in the outdoor unit. Now while 

4 you may be accounting for the standby consumption in 

5 the air handler portion, it is not 33 watts, I can 

6 assure you. And so you really do – if you’re going to 

7 regulate an air handler, again, this is still a 

8 question I realize, but if you’re going to regulate 

9 the air handler it’s not the same number that you’re 

10 going to have associated with these other rulemakings. 

11 It’s going to be a different number. It may be a 

12 component in that other number, but when you sell this 

13 thing as an air handler and not a heat pump system, 

14 split system, those numbers are not the same and you 

15 need to get the right numbers on this product when 

16 it’s sold as an air handler.

17 Secondly, by incorporating standby for 

18 hydronic for air handler here, you have grossly 

19 distorted the ratings for these things and how much 

20 energy they use. In the examples that are published 

21 in the PTSD, you’ve got a PSC equipped air handler, 

22 and you’ve got an ECM equipped hydronic air handler. 

23 The hydronic ECM air handler uses approximately one24 half of the electricity annually, based on your 

25 calculations, as the PSC air handler, and yet its 
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1 efficiency rating is approximately eight times as 

2 good. So you’ve got a rating here that says it uses 

3 one-eighth of the energy, but it actually uses half 

4 the energy when you look at the numbers in kilowatt 

5 hours. That is a highly misleading arrangement. And 

6 so I would suggest to you that you need to fix that.

7 MR. BROOKMAN: Thank you. Greg, and then to 

8 Diane.

9 MR. WAGNER: Okay. Two – this is Greg 

10 Wagner. Two comments. One to dovetail with what you 

11 were just talking about, with regard to the 

12 differences in product classes. This gets back to 

13 what we originally talked about in terms of scope, 

14 scope of what the law and regulations covers and the 

15 fact that these products haven’t been covered 

16 previously for the standby watts, indicates they are a 

17 separate class, and are not covered by this standard. 

18 So that’s just further indication regarding scope.

19 To on to a question I have for Sam, you 

20 mentioned that when you did this baseline 

21 analysis,that you did some testing and you took 

22 literature from the manufacturers. Your testing was 

23 to the standard as it’s outlined currently, is that 

24 correct?

25 MR. JASINSKI: Yes.
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1 MR. WAGNER: And you used the AMCA 210 type 

2 of test process. The manufacturers don’t use the AMCA 

3 210, so your numbers and their numbers are going to be 

4 different. They use either ASHRAE 37 which is 

5 different from the ASHRAE 51 equivalent to the AMCA 

6 210, or they use another test which is that 103 test. 

7 So you can’t add apples and oranges together.

8 MR. BROOKMAN: You think it would be 

9 substantially different?

10 MR. WAGNER: Yes, there’s different 

11 corrections for density, and different method of 

12 testing, and this is what we covered in the last 

13 session and we did that in our written comments. And 

14 we’ll certainly reflect all those differences.

15 MR. BROOKMAN: Thank you. Diane, and then 

16 back to Steve.

17 MS. JAKOBS: I did (off mic) ...

18 MR. JASINSKI: Diane, I think the microphone 

19 is – there’s trouble with the microphone.

20 MR. BROOKMAN: Is the mic on?

21 MS. JAKOBS: Oh, I pressed the button twice, 

22 I guess. I had three samples of one furnace model, 

23 and I got 405, 415, 416. So I mean it sounds like a 

24 little bit, but compared to 380, that’s more than ten 

25 percent, I think. 
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1 MR. JASINSKI: So your samples were non2 weatherized, non-condensing?

3 MS. JAKOBS: Non-weatherized, non4 condensing. And before – I want to take back my –

5 well, I’m not sure about my comment before. Part of 

6 it, I might have mixed myself up, whether a good 

7 number was higher or lower, but I do think that this 

8 differentiation between condensing and non-condensing, 

9 you know, is only 13 points on your chart, and that 

10 might reflect – it’s really what we were talking about 

11 the air flow path and how you design it and what motor 

12 speeds you select, that a non-condensing gas furnace 

13 might use more watts to provide the same comparable 

14 performance. So it’s one of the things, it depends on 

15 your design because turbulent air is good for heat 

16 transfer and we can get our AFUE up, but it’s not as 

17 good for the fan watts, so those are all interact.

18 MR. BROOKMAN: Craig.

19 MR. MESSMER: Craig Messmer. Looking at the 

20 FER, I’m not at all thrilled by dividing it by the 

21 maximum CFM. It’s going to skew a lot of numbers. 

22 Some of that’s going to depend on the design of the 

23 product itself. Not everybody’s – if it’s a heating 

24 product, the intent is BTUs and here you’re kind of 

25 dividing it by CFM. Nobody cares about the CFM, they 
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1 only care about the BTUs. If you’re just going to do 

2 the fan itself, then I don’t see why you’d want to 

3 divide by the maximum CFM to get an FER. It should be 

4 an averaged number based on the CFM that’s operating 

5 at the different multi speeds, for example. So I 

6 think that we’re getting numbers that are so massaged 

7 that you’re not going to have any reality to them.

8 MR. BROOKMAN: Steve.

9 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

10 was just also kind of curious if there was information 

11 out – you know, the new boiler standards kick in in 

12 September for higher AFUE, and then the automatic 

13 temperature resets control mandates, and then the 

14 furnaces kick in in May, next year, for all of them 

15 that are not in the condensing furnaces. And then you 

16 have the small motor efficiency standards kick in in 

17 2015, which I think there’s some correlation between 

18 those small motors that are covered by DOE and then 

19 the motors going into the furnaces. I believe a lot 

20 of the same models are covered by – again, the 

21 manufacturers will let me know which ones are –

22 there’s no correlation? They’re different fans? 

23 Okay. Scratch that one, then. 

24 I’m just kind of curious then if – I mean 

25 it’s really just for the boilers, if that makes a 
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1 difference in terms of some of these ratings.

2 MR. JASINSKI: I don’t believe so.

3 MR. ROSENSTOCK: Okay. Thank you. 

4 MR. JASINSKI: Rob.

5 MR. BOTELER: Yeah, the small motor 

6 regulation that goes into effect in 2015, it only 

7 handles general purpose open motors. It does not 

8 handle the type of motors that OEM specific.

9 MR. JASINSKI: Thanks.

10 MR. BROOKMAN: Let’s move on.

11 MR. JASINSKI: Okay. Just a couple of 

12 bullets, and I hope I remember all of these. As Greg 

13 Wagner mentioned, there was some discussion during the 

14 test procedure public meeting about the data that was 

15 used to generate these values, and how manufacturers 

16 using different setups might impact that. After the 

17 framework document, or during the framework document 

18 public meeting, DOE identified AMCA 210 as a standard, 

19 and there were a lot of interested parties that 

20 commented that that was a widely used and widely known 

21 standard, and also was used to generate the air flow 

22 performance tables that can be found in a lot of 

23 specification sheets. I think there are even some 

24 specification sheets that reference the standard in a 

25 footnote. So it is important to get comments that 
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1 might indicate whether or not those values would be 

2 different. And if manufacturer – comments related to 

3 how familiar manufacturers are with AMCA 210 and 

4 whether or not they use that or test setups according 

5 to AMCA 210 is important. 

6 To Craig’s comments, the – normalizing by 

7 maximum air flow capacity – we’ll get to this request 

8 for comment. The intent here is two things. There’s 

9 a relationship between – the higher efficiency motors 

10 react differently to increased external static 

11 pressures. For an ECM motor, it will consume more 

12 power to maintain a constant air flow at higher 

13 external static pressures, whereas a PSC will provide 

14 less air flow and therefore the consumption will go 

15 down. So normalizing by the maximum is a means to try 

16 to limit how sensitive the rating metric is to that, 

17 so that higher efficiency motors are not being 

18 penalized because they’re still providing more air 

19 flow. 

20 And on the other side, is it’s also a 

21 mechanism to try to reduce the sensitivity of the 

22 metric to changes in capacity because DOE expects that 

23 air flow – maximum air flow capacity is specified with 

24 some relationship to BTUs, as you mentioned. I know 

25 there are a lot of numbers out there, you know, 
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1 anywhere between 350 to 450 CFM per ton. Ton here is 

2 a reflection of the capacity. So that’s just an 

3 overview. Comments regarding those assumptions and 

4 whether or not normalizing achieves those goals is 

5 something that DOE is very interested in.

6 MR. BROOKMAN: Diane.

7 MS. JAKOBS: So one thing that I was a 

8 little bit concerned about, these numbers, they look 

9 kind of similar to what – if you were just going to 

10 measure the CFM and measure the watts in an 

11 installation, you would get kind of same order of 

12 magnitude numbers. And we’re already having trouble 

13 now where there are some hand held tests, combustion 

14 analyzers, and people are trying to, in the field, 

15 commission their equipment. And they’re saying that 

16 we’re not meeting our AFUE rating because they have 

17 this hand held analyzer that they’re testing their 

18 installed unit on, and I wish that we could do AFUE 

19 testing with a hand held analyzer, but it’s much more 

20 complicated than that. And those numbers, they look 

21 kind of the same, so I was thinking that the IFER, 

22 actually looked better because it was significantly 

23 different but my friends pointed out that we were 

24 already on the path to submitting standby watts. But 

25 these are similar order of magnitude numbers to what 
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1 they’re talking about in California, but a different 

2 test procedure, but so – just for what that’s worth. 

3 Thank you. 

4 MR. BROOKMAN: Thank you. Okay. Jim 

5 Vershaw, you’re next.

6 MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 

7 I think I made this comment during the test procedure 

8 thing. But we do not use AMCA 210 for either our 

9 furnaces or our air handlers. If we were making a fan 

10 only, we would, but this is an appliance that 

11 generates heating and cooling, and that falls under 

12 ASHRAE 37, and of course, furnaces are tested under 

13 ASHRAE 103. So the numbers that you’re going to get 

14 using 210 are going to be different than what you 

15 find, at least in our literature.

16 MR. BROOKMAN: Yes, Dave.

17 MR. WINNINGHAM: This is Dave from Allied. 

18 I would echo what Jim has said. We do not use AMCA 

19 210 either at Allied or at Lennox to generate air flow 

20 tables. And would also recommend that these baseline 

21 numbers be thoroughly reviewed before any minimum 

22 threshold level is established.

23 MR. JASINSKI: So once the baseline has been 

24 established, DOE identifies intermediate efficiency 

25 levels as a path to more efficient products. Each 
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1 efficiency level above the baseline is defined by a 

2 specific design option used to achieve that level. 

3 DOE determined average percentage reductions in FER or 

4 IFER for each efficiency level and applied these 

5 reductions across all product classes. The reasoning 

6 behind that is DOE found that manufacturers use 

7 similar components and design paths to improve 

8 efficiency across all product classes that DOE is 

9 examining. DOE does not expect that the percent 

10 reduction FER associated with each design option, 

11 whether commercially available or prototype, will 

12 differ across product classes.

13 DOE based the reductions in FER associated 

14 with commercialized technologies on measurements or 

15 publicly available performance information, and DOE 

16 based the FER reductions associated with prototype 

17 technologies or those that aren’t in commercial 

18 applications on research reports that included 

19 detailed performance data.

20 This table provides a snapshot of those 

21 percent reductions in FER. As I mentioned, DOE 

22 assigned the percentage reductions in FER to each 

23 efficiency level to obtain FER values for intermediate 

24 efficiency levels. DOE also assigned a reduction in 

25 standby watts for the standby design options.
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1 MR. BROOKMAN: Steve Rosenstock.

2 MR. ROSENSTOCK: Steve Rosenstock, EEI. And 

3 again, I know we had the discussion about standby 

4 before, but again, since you’re analyzing this 

5 component as a stand alone appliance, was there any 

6 information about the standby power usage of these 

7 components, and in some cases did they ever increase, 

8 let’s say, with level four, or the multi staging 

9 control added a couple watts just because it’s 

10 tracking everything.

11 MR. JASINSKI: Yeah, those – that standby 

12 consumption, in consideration of that, is considered 

13 in the other rulemaking, so for instance, in this 

14 particular case, in the components of the fan that are 

15 being analyzed, I think the analysis shows that an ECM 

16 motor contributes anywhere between three to five watts

17 of standby and that is for the products where you see 

18 a non-applicable – those watts are included in the 

19 analysis and standards that are being considered or 

20 specified in those other rulemakings.

21 MR. ROSENSTOCK: Okay, and -- Steve 

22 Rosenstock, EEI – thank you for that. Suppose the 

23 baseline is, I’ll just say one watt. I don’t know 

24 what it is for the baseline unit. But then you get to 

25 level four and it’s five watts, you’re saying, oh, 
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1 I’ll do that in another analysis. Well, hold on a 

2 second. You were analyzing this component. If you’re 

3 ignoring those watts, that’s reducing the energy 

4 savings, that’s going to have an impact on your energy 

5 analysis and your life-cycle cost analysis and all the 

6 other analyses. Isn’t it? I understand what you’re 

7 saying. It’s really covered in another – in the 

8 overall system standby, but since you’re analyzing 

9 this component as a stand alone appliance, by not 

10 looking at it – if it were zero, great, it’s no 

11 problem. It makes no difference whatsoever. But 

12 there is a difference upwards or downwards, it could 

13 have an impact on the rest of the – it won’t have an 

14 impact on the metric, but it will have an impact on 

15 the energy savings and life-cycle cost analysis.

16 MR. JASINSKI: Those costs and benefits are 

17 included in the other rulemaking, so those –

18 MR. ROSENSTOCK: But there’s a separate cost 

19 and benefit analysis for this rulemaking.

20 MR. JASINSKI: Yes.

21 MR. ROSENSTOCK: Okay. So, and again, it’s 

22 a component system issue is you’re saying we’re going 

23 to do the standby for the system, but not going to 

24 worry about the standby for the component. It’s kind 

25 of a dichotomy there.
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1 MR. BROOKMAN: I see Alex wishes to comment. 

2 Find a microphone, Alex. Maybe that one right over 

3 there. Yes, coming back to you, Diane.

4 MR. LEKOV: Alex Lekov, Lawrence Berkeley 

5 National Laboratory. So to answer these impacts are 

6 included in the life-cycle cost analysis, and it will 

7 be explained in the follow up slides, when we get to 

8 this point.

9 MR. BROOKMAN: Okay. Thank you. Diane.

10 MS. JAKOBS: Just kind of to emphasize how 

11 intertwined all these parts are, on a furnace, our 

12 biggest source of standby watts is actually a 

13 transformer that you need when you run the air 

14 conditioning. So, at Rheem we talked about moving 

15 that transformer outside, so the guys downstairs would 

16 have to worry about it, but that didn’t fly. So they 

17 work as a system, and we assume they’re all going to 

18 work together and it’s hard to attribute specific 

19 components to different modes of operation. It’s 

20 difficult.

21 MR. BROOKMAN: Okay. Thank you. Keep going 

22 – oh, Greg, go ahead.

23 MR. WAGNER: Greg Wagner. Question about 

24 the efficiency number that you have there under number 

25 five, the center column, what’s the basis for that?
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1 MR. JASINSKI: The basis for that is 

2 research reports and data that was acquired using a 

3 prototype furnace that had a backward incline impeller 

4 installed.

5 MR. WAGNER: The one that was referenced in 

6 the TSD?

7 MR. JASINSKI: Yes.

8 MR. WAGNER: Okay. I reviewed that report, 

9 and that’s testing a blower only. Isn’t that tested 

10 in a unit? And it was one data point, and gentleman 

11 from Southern California Edison pointed out that as 

12 you vary performance, those numbers change. 

13 Additionally, that blower component was tested by 

14 Lawrence Berkeley, and they put a report out in 

15 September 2005 and in it, on Page 41, they basically 

16 say they see no efficiency gain from using that in it, 

17 in a furnace system. So I guess, do you look at all 

18 the literature, or just part of the literature?

19 MR. JASINSKI: No, we look at all the 

20 literature. A lot of the issues that you are raising, 

21 there’s a request for comment to get more information 

22 about the performance across the entire range of 

23 operation. The 2005 report that you mention, we do 

24 have access to some of the raw data for that, and that 

25 testing was done with the prototype. And here, the 
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1 prototype I’m referring to is the premium ECM motor 

2 with the backward inclined impeller. A premium ECM 

3 motor here is a motor that is narrower, that is the 

4 diameter is smaller so there’s less interference with 

5 the blower inlet, but it also operates at higher RPM 

6 which is characteristic of a motor that’s paired with 

7 a backward incline prototype, and that prototype was 

8 installed in the – in a furnace, so that raw data was 

9 taken while it was installed in situ, to my knowledge. 

10 So some of the analysis is also done on that raw data 

11 that was used for that 2005 study that you mentioned.

12 And, as a preface to the comments that we’re 

13 requesting, DOE is very aware that there are varying 

14 degrees of performance and DOE is asking for data and 

15 comments to understand what the expected relative 

16 efficiency of operation would be for implementing a 

17 backward incline impeller, among many other issues.

18 MR. WAGNER: Well, this ten percent used 

19 later to drive your energy savings, I notice.

20 MR. JASINSKI: Yes, I can say that with the 

21 raw data we saw anywhere from – a lot of the reports 

22 don’t – obviously don’t use the rating metric that 

23 we’re proposing, that DOE is proposing. But the 

24 benefits – there’s a wide range between, like you 

25 said, in some cases, very small to much larger than 
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1 ten percent, and that’s impact on FER. So DOE is 

2 proposing to use ten percent in the preliminary 

3 analysis and also asking for comment about the 

4 appropriateness of that number.

5 MR. WAGNER: Well, I just want to go back to 

6 the report that you referenced. Wegman (ph) in blower 

7 only, did have one point that was ten percent, but the 

8 rest of it was two to four percent in the other 

9 systems they analyzed. But the specific one that got 

10 to ten percent when Ian Walker and company out of 

11 Lawrence Berkeley tested it, they report that they 

12 didn’t see any improvement or enhancement.

13 MR. JASINSKI: Sure. The ten percent 

14 reported in that is not using – this is ten percent in 

15 FER, so the FER is actually a little bit more 

16 sensitive. So a ten percent reduction there would 

17 actually be something along the lines of 20 – a lot 

18 larger percent reduction in FER. So this is not 

19 simply taking the ten percent from that report and 

20 plugging it into our analysis.

21 MR. WAGNER: I would say it’s less sensitive 

22 because you have multiple operating points and the 

23 efficiency is going to change over those operating 

24 ranges, as pointed out earlier, and shown in the 

25 report, and it would actually reduce those numbers, 
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1 not increase them.

2 MR. BROOKMAN: Okay. Thank you. Detlef.

3 MR. WESTPHALEN: Detlef Westphalen, Navigant 

4 Consulting. I guess we wrestled with some of this 

5 data as well, and, you know, some of this work was 

6 going on over a number of years, not all of it was 

7 made public. Some of the reports that were made 

8 public showed less benefit than some of the other data 

9 that was – that we were eventually able to obtain.

10 So, the story is not all in the reference. 

11 That just happens to be the public reference that 

12 could be cited. And so one of the questions is, 

13 whether more of this data could be made public, but 

14 that’s not for me to answer.

15 MR. BROOKMAN: Let me just note that this is 

16 important stuff and we’re diving rather deep it seems 

17 to me. We need to make sure we come up high enough so 

18 we cover all this material. Diane, go ahead.

19 MS. JAKOBS: I just want to say that I think 

20 it was several years ago, maybe about the time you 

21 came to ... to visit Sam, but I did try to get – I was 

22 on the CSA823 committee, and I did try to get a hold

23 of this prototype to test it in one of our furnaces, 

24 and I talked to Lau and Regal Beloit, and there seemed 

25 to be some intellectual property, they didn’t know if 
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1 they could share with me, and because you have to run 

2 the wheel, you know, it’s not just a matter of getting 

3 that particular wheel, you have to run it at much 

4 higher RPM, so I was trying to get the motor and the 

5 control that I never did get it. I tried for six 

6 months or something, so I did try to test this in our 

7 furnace, and was unsuccessful.

8 MR. BROOKMAN: We’ve had a lot of comments 

9 on slide 36 and there are many other equivalent slides 

10 which follow, so let’s press on.

11 MR. JASINSKI: Okay. 

12 MR. BROOKMAN: Final comment from Craig, and 

13 then we’re moving on.

14 MR. MESSMER: Craig Messmer. I see these 

15 percentages on this chart and I looked in the TSD, I 

16 don’t know where they come from. Are you going to 

17 explain where these come from? Because 45 percent, 59 

18 percent, are pretty big numbers.

19 MR. BROOKMAN: You’re referring again to 

20 slide 36?

21 MR. MESSMER: Yes.

22 MR. BROOKMAN: Keep going, Sam. Sam, are 

23 you saying where these --

24 MR. JASINSKI: As I mentioned, we used the 

25 publicly available performance data that was in 
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1 specification sheets to derive FER values and IFER 

2 values, in addition to the testing that was done by 

3 DOE.

4 MR. MESSMER: And you did it at the static 

5 pressures required by the new FER --

6 MR. JASINSKI: Yes.

7 MR. MESSMER: -- test procedures? Because 

8 the motors aren’t really that much more efficient. 

9 But, that’s okay.

10 MR. BROOKMAN: So in your comments, right. 

11 Okay, then on to the next.

12 MR. JASINSKI: For all product classes 

13 except hydronic air handlers, DOE analyzed four 

14 efficiency levels in addition to the baseline and the 

15 max tech for a total of the baseline plus five 

16 additional efficiency levels. Here are the results 

17 for the primary – or excuse me, the non-hydronic key 

18 product classes. We won’t spend too much time reading 

19 each of the numbers unless someone has prepared a 

20 specific comment about the values. If not, written 

21 comments on these levels would be appreciated.

22 MR. BROOKMAN: If there are overarching 

23 comments on these numbers as we had in the previous 

24 slide, then I think that would be helpful. Then we 

25 will move on.
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1 MR. JASINSKI: For furnace fans using 

2 hydronic air handlers, DOE considered two additional 

3 efficiency levels, efficiency levels six and seven, 

4 and those are using the design options that reduce 

5 standby and off mode energy consumption. Here’s the 

6 analogous table for hydronic air handler furnace fans. 

7 So as you see, the baseline through – well, one 

8 through five have the same design options, and then 

9 there are the two additional, the switching mode power 

10 supply and toroidal (ph) transformer for six and 

11 seven.

12 MR. BROOKMAN: Brian first.

13 MR. JAMES: Brian James, Southern California 

14 Edison. Just a point of clarification. Are six and 

15 seven an add-on to five?

16 MR. JASINSKI: Yes.

17 MR. BROOKMAN: Diane.

18 MS. JAKOBS: Well, we have a hydronic air 

19 handler and we – the way we advertise it, we match it 

20 with a condensing tankless water heater which would –

21 if you looked at the efficiency of the condensing 

22 water heater, and you looked at this, you would assume 

23 that your operating costs would be much lower than a 

24 condensing furnace. And I don’t think that’s true at 

25 all. So I think that this is misleading because I 
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1 think you can, in the same installation, have a choice 

2 between a direct – you need to make a direct 

3 comparison between a gas furnace and a hydronic air 

4 handler.

5 MR. JASINSKI: Yeah, I don’t mean to speak 

6 for Diane, but I think this comment is related to the 

7 discussion earlier about how the metrics for hydronic 

8 air handlers uses the integrated fan efficiency rating 

9 which includes standby and off mode and therefore is 

10 normalized by total annual hours because it includes 

11 those, which makes these numbers a lot less in 

12 comparison. So correct me if I’m wrong, but –

13 MS. JAKOBS: Yeah, I mean – I like these 

14 numbers better. But, you know, just because of the 

15 waiting for the standby mode at the much lower watts 

16 level, they just look like you’re saving money, and 

17 you would not be.

18 MR. BROOKMAN: Okay. Thank you. 

19 MR. JASINSKI: So now, just a request for 

20 comment about the rating metrics, that they will not 

21 be dependent on capacity because they are normalized 

22 by the maximum air flow capacity. This is something 

23 that I asked earlier. If anybody has comments related 

24 to how the proposed metric is impacted by capacity.

25 MR. BROOKMAN: Move on.
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1 MR. JASINSKI: After establishing FER 

2 values, the next part of the engineering analysis is 

3 to develop costs for these values. The manufacturing 

4 cost models were developed by DOE as part of the 

5 efficiency level approach. First, bills of material 

6 are generated during product tear down analysis and 

7 entered into a cost model. The cost model generates 

8 manufacturing material, labor, and overhead costs. 

9 The physical tear down, as I mentioned earlier, is 

10 conducted on representative products that were 

11 selected based on the criteria that I spoke about, and 

12 as part of this preliminary manufacturer interviews 

13 are conducted to further refine some of the inputs for 

14 this cost model. And that flow chart there provides a 

15 graphic for what I just described.

16 This is a lot of detail about what is 

17 included in the cost of production numbers in terms of 

18 the structure and classification of the manufacturing 

19 cost. I won’t go into a lot of detail about these, 

20 but you have this slide for reference, and it’s also 

21 included in Chapter 5 of the TSD.

22 MR. BROOKMAN: Rob.

23 MR. BOTELER: We had a couple of comments 

24 earlier about the cost of the ECMs and one of the 

25 things that we as motor manufacturers noted is we’re 
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1 not aware of any conversations with Navigant to 

2 actually get motor costs from us. Maybe they got 

3 motor costs from the air handler manufacturers, but 

4 they didn’t get them from us so we’re not sure if they 

5 are correct in your calculations.

6 MR. JASINSKI: Typically, manufacturer 

7 interviews are conducted mostly during the NOPR phase, 

8 and my understanding is that typically manufacturer 

9 interviews are targeted towards the HVAC product 

10 manufacturers, so those prices, if we do get any, 

11 would come from them.

12 MR. BROOKMAN: Diane.

13 MS. JAKOBS: I mean certainly we did talk to 

14 you, I don’t know. Two weeks ago, I took the same 

15 heat exchanger and the same jacket and we offer it 

16 with a PSC motor X13 and ECM. I did one, one sample,

17 and it was – our cost for the X13 was almost double 

18 what is in this table. And then we had AHRI group 

19 that we’ve been discussing all this, and I asked if 

20 other manufacturers saw the similar pattern. So I had 

21 agreement from other manufacturers. If you gave us 

22 that small a data set, we would criticize you, but 

23 that’s what we have. That’s just what I did for a 

24 check.

25 MR. JASINSKI: There will be an opportunity 
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1 during the NOPR where extensive manufacturing 

2 interviews are conducted to have these types of 

3 conversations and refine the analysis.

4 MR. BROOKMAN: Alex.

5 MR. BOESENBERG: Alex Boesenberg, NEMA. I 

6 would encourage the Department and Navigant on those 

7 interviews to bear in mind, when you make the cost 

8 scaling factors, that certainly I heard more than one 

9 fan manufacturer here mention that they do, some of 

10 them do pretty small runs, which means that you don’t 

11 get the economies of scale that may be reflected in 

12 those original estimates. If it’s a million motors a 

13 year, not buying a million at once, maybe only a few 

14 hundred, and that of course results in a lot less 

15 savings, so please bear that in mind. Thank you. 

16 MR. BROOKMAN: Yes, Dave.

17 MR. WINNINGHAM: I would concur with Diane’s 

18 comments. We actually analyzed about six furnaces 

19 with similar configuration with the exception of the 

20 motor and the controls, and found a distinctly 

21 different – difference in price delta. I would also 

22 recommend that as you look at this price delta, to 

23 include all aspects of the installed cost. Because, 

24 in many cases, the higher efficiency motors require 

25 additional controls and wiring that goes along with 
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1 them, and make sure that you’re including those costs 

2 as part of that.

3 MR. JASINSKI: Sure. Thank you. And I 

4 guess it would be good to mention that -- a lot of 

5 manufacturers are mentioning that they’re doing 

6 analyses – if you can share that data in your written 

7 comments, that would be really appreciated, but also, 

8 as a note, if there is information that you are 

9 wanting to protect, the manufacturer interviews are 

10 conducted under NDA agreements so that might be 

11 another opportunity to provide data that you might not 

12 want to submit publicly.

13 MR. BROOKMAN: Diane.

14 MS. JAKOBS: We kind of brought it up, that 

15 everything’s going so fast, but, you know, if you’re 

16 interested in one little data point, it seems trivial, 

17 but if that’s still interesting, I guess –

18 MR. JASINSKI: Every little bit helps.

19 MS. JAKOBS: Thank you. 

20 MR. BROOKMAN: Charlie Stephens.

21 MR. STEPHENS: Just a quick point of 

22 clarification. Charlie Stephens. Are these fan costs 

23 and fan pricing, or air handlers?

24 MR. JASINSKI: Yeah, I’ll get into that, 

25 I’ll show you specifically what’s included in the –
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1 MR. STEPHENS: Okay. Thank you. Because 

2 the design options only so far, are fan related.

3 MR. BROOKMAN: Let’s proceed then.

4 MR. JASINSKI: So to answer Charlie’s 

5 question, the costs used in the engineering analysis 

6 represent the cost of the furnace fan, and not the 

7 cost of the entire HVAC product. The following 

8 components are included in the manufacturer production 

9 cost, MPC, estimates: 

10 • the fan motor and integrated controls, 

11 • the primary control board,

12 • the impeller,

13 • the fan housing,

14 • and components used to direct or guide air flow.

15 And the last one is somewhat ambiguous, but 

16 I will explain that. When reverse engineering these 

17 products, there are elements that are easily 

18 distinguishable as intended specifically to direct air 

19 flow, maybe over the heat exchanger, or – and these 

20 would be typically, you know, sheet metal or something 

21 like that. Those elements were included in the costs 

22 because they’re expected to have an impact on the 

23 efficiency, therefore we want to include them in the 

24 cost.
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1 MR. BROOKMAN: Greg.

2 MR. WAGNER: Were motor mounting 

3 arrangements also considered? I don’t see that up on 

4 there. In other words, there’s something that holds 

5 the motor in place.

6 MR. JASINSKI: Yes.

7 MR. WAGNER: Okay. Just not listed.

8 MR. JASINSKI: So the fan motor and 

9 integrated controls – yeah, it’s not explicit, and so 

10 as a point of clarification, the fan motors are 

11 typically considered a purchase part and in a lot of 

12 cases, that – the mount may come as part of that 

13 purchased part as an assembly from a component 

14 supplier. But, DOE does reverse engineer them also to 

15 get costs, whether it’s a purchased part or – but it 

16 is included.

17 MR. BROOKMAN: Terry Small, you’re next.

18 MR. SMALL: Terry Small at Mortex. I just 

19 wanted to ask, it looks to me that you’re basing your 

20 manufacturing cost on a manufacturer that would be 

21 making one and a quarter million fan furnaces a year. 

22 And that may be indicative of a residential furnace 

23 manufacturer, sort of what I would call a high volume, 

24 low mix manufacturer. But a lot of these product 

25 classes, including the additional product classes, the 
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1 volumes are such that they’re really low volume, high 

2 mix, and that would be completely inappropriate, those 

3 manufacturing costs, for some of the smaller 

4 manufacturers. So could you address that?

5 MR. JASINSKI: Sure. I think the next slide 

6 will – it’s a good segue into the next slide.

7 So as many interested parties have 

8 commented, DOE separated furnace and product classes 

9 into high volume and low volume product classes to 

10 account for factors that impact manufacturers’ 

11 production cost and purchasing power. For instance, 

12 some products – DOE is aware that some products are 

13 produced at significantly higher volumes than others. 

14 Some manufacturers offer most types of HVAC products, 

15 while others only focus on small niches. 

16 So high volume manufacturers operating in 

17 lower volume adjacent markets are expected to have the 

18 same purchase part price efficiencies consistent with 

19 their overall purchasing volume. This just means that 

20 even if a particular HVAC manufacturer is offering a –

21 one product that has a very low volume of shipments, 

22 if that manufacturer also produces another product 

23 that has a high volume of shipments, they will get the 

24 same – similar pricing because they can purchase 

25 motors that might be used in both.
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1 And then lastly, low volume operations, were 

2 modeled to have lower production volumes and fewer 

3 shifts per day, to account for the fact that not all 

4 manufacturers have production volumes on the order of 

5 1.25 million units per year. And at the bottom here, 

6 you can see – these are the products – this is the 

7 separation of product classes into high volume and low 

8 volume. So all product classes – oil furnaces and 

9 hydronic air handlers were classified as low volume 

10 product classes. The rest were high volume. 

11 And the math here is right. Like, non12 weatherized gas furnaces, that accounts for condensing 

13 and non-condensing. So not all nine product classes 

14 are listed here, but all the products are.

15 MR. BROOKMAN: Greg.

16 MR. WAGNER: Greg Wagner. In the third 

17 bullet item, you mention that the high volume 

18 manufacturers are going to get – expected to get the 

19 same purchasing power for all products. That may or 

20 may not be true, because small volume products are run 

21 through different processes than high volume products, 

22 and so there are different costs based upon volumes of 

23 production. You can’t make that, I guess, universal 

24 blanket statement there.

25 MR. BROOKMAN: Diane.
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1 MS. JAKOBS: To make things harder for you, 

2 our hydronic air handler uses the same blower system 

3 as a gas furnace. So even though we’re not selling a 

4 lot of them, you know, they’re coming from the same 

5 pool that we have for gas furnaces.

6 MR. JASINSKI: That’s exactly the third 

7 point, that for someone in that situation, you’re 

8 using – you’re ordering one component for both the 

9 small production volume and large production volume 

10 together.

11 Do DOE uses a design option approach to 

12 estimate the cost of technologies not commercially 

13 available in furnace fan applications. These are 

14 essentially the design options that aren’t offered in 

15 products that can be torn down. So here you have the 

16 table that shows the efficiency level and design 

17 option, and then the high volume and low volume 

18 estimated manufacturer production cost.

19 And just as an explanation, so the inverted 

20 controls for the PSC motor, this cost is based on a 

21 reverse engineering inverter that can and was used in 

22 a furnace fan application. There’s the specific model 

23 that was used, and that comes out to, as you can see, 

24 $12.00 for the high volume, and $16.00 for the low 

25 volume, and that’s only the cost for the inverter.
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1 Next, the premium ECM, multi-staging and the 

2 backward curved impeller, DOE used a ten percent 

3 markup on the estimated cost for an ECM as the added 

4 cost for the premium ECM motor. As a reminder, the 

5 premium ECM motor is that ECM motor that’s a little 

6 bit narrower and operates at higher RPM, which is –

7 DOE expects is required for backward curved impellers. 

8 DOE used photographs and specifications found in 

9 research reports to determine cost model inputs to 

10 estimate the MPC of the backward curved impeller. It 

11 turned out to be $12.00 for low volume and $12.32 for 

12 the high volume.

13 MR. BROOKMAN: Greg.

14 MR. WAGNER: On that BC wheel technology –

15 backward inclined wheel technology requires much 

16 tighter tolerances in order to be effective. How is 

17 that accounted for, because the tolerances are on an 

18 order of magnitude tighter in order to get the same 

19 effect. In addition to that, the motor mounts and the 

20 support structure, et cetera, were going to have to be 

21 significantly beefed up in order to be able to be 

22 shipped in process. So I would question those dollar 

23 numbers on those bases alone.

24 MR. JASINSKI: In this particular case, the 

25 cost model for a standard forward curved was – the 
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1 products were compared and as I said, the inputs for a 

2 backward curved were determined, based on the 

3 differences identified between the two. So if there 

4 are other factors that would need to be included in 

5 that cost, written comments or comments during 

6 interviews that would tell us what else needs to be 

7 included, and how much that costs so we can use those 

8 as inputs, would be greatly appreciated.

9 And then finally, the efficiency – excuse me 

10 – the estimates for efficiency levels six and seven 

11 are identical to those used in the HVAC products, the 

12 other standby and off mode rulemakings.

13 MR. BROOKMAN: Craig.

14 MR. MESSMER: Just going back to that slide, 

15 you really think that you could make those products 

16 for $12.00? And the backward curved impeller and 

17 motor for $107?

18 MR. JASINSKI: Based on our analysis.

19 MR. MESSMER: Okay. You have that somewhere 

20 that we can take a look at that and comment on it?

21 MR. JASINSKI: Yes, it’s in the TSD, and if 

22 you provide written comments explaining why that 

23 should go up, then that would be appreciated.

24 MR. MESSMER: There’s so much detail in the 

25 TSD that would tell you not how those are derived.
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1 MR. JASINSKI: Well, there’s detail about 

2 the methodology used and the cost model. So if you 

3 can talk about maybe a particular component that’s not 

4 being included that’s necessary, I think you mentioned 

5 that the mounts need to be different or if you can 

6 explain the different processes, the cost model used 

7 can account for most of those variations, we just need 

8 – DOE just needs to know what those variations are.

9 MR. MESSMER: Well, given they’re not used 

10 currently, there’s not a good model to give you that 

11 guidance. But what I’m suggesting is there wasn’t any 

12 details in the TSD to be able to make that kind of 

13 evaluation of how you generated your costs.

14 MR. JASINSKI: Well, as I’m saying, nothing 

15 – I’m not leaving any details out. Essentially, you 

16 look at the standard forward curved impeller that’s 

17 included in current models and by observation you 

18 compare the design, based on what type of processes 

19 DOE expects are used, what types of materials, that’s 

20 put in the cost model, and the cost model uses 

21 assumptions about material prices and all those other 

22 costs that this slide shows, to generate the estimated 

23 manufacturer production cost. If there’s something 

24 missing or something that shouldn’t be included, or 

25 something that needs to be tweaked, those are things 
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1 that we can use to change our inputs to the cost 

2 model, to generate different values. But for this 

3 particular case, that was the methodology used. So if

4 that methodology needs to be changed, DOE would 

5 appreciate comments on what we left out, or how it 

6 should be done different, and that way we can refine 

7 the analysis.

8 MR. BROOKMAN: Mohammed.

9 MR. KHAN: Mohammed Khan, DOE. First, I 

10 appreciate the fact that, you know, in some instances 

11 there might not be a full enough description on the 

12 methodology for you to comfortably be able to comment 

13 on. However, if you’re able to look at these numbers 

14 as you are right now, and it seems to be that you 

15 believe that they’re off, they’re probably too low, 

16 and you know that they should be much higher, based on 

17 your expertise and your manufacturing knowledge, your 

18 manufacturing processes, it would be very helpful for 

19 us for you to comment on what your process is and how 

20 you know these prices should be higher based on your 

21 knowledge alone, rather than not being able to comment 

22 on our methodology. But just give us what you know 

23 and then we can certainly take that information into 

24 account. Thanks.

25 MR. MESSMER: Well, to that point, we 
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1 manufacture a product that’s not like these currently, 

2 but the product that we manufacture would be in a 

3 different process than what would be used for the 

4 manufacture of these types of products in the 

5 tolerance level that’s described in the literature and 

6 other places that we know is necessary to apply that 

7 technology, would have a different manufacturing 

8 process all together. So using the same metric for 

9 evaluating one technology versus the other wouldn’t 

10 necessarily be appropriate.

11 MR. JASINSKI: So if you, in your written 

12 comment for example, if you could explain the process 

13 that would be used, that’s an input we can use in the 

14 cost model that would change the result. And in 

15 addition to what Mohammed said, another very important 

16 factor in refining these costs are the inputs that we 

17 get from manufacturers who have the expertise and who 

18 are actually producing them. So those are also 

19 considered. It’s not just what the model generates.

20 So the next few slides are comments specific 

21 to each of the design options. This one in particular 

22 is comment on inverter driven PSC fan motors. DOE 

23 requests data and energy-related – data regarding the 

24 energy performance and costs. As I said, DOE based 

25 its cost on a reverse tear down of an inverter that 
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1 can be used in these applications, and the energy 

2 performance information was taken from a product that 

3 was formerly commercially available that used this 

4 technology.

5 Here’s a snapshot of the engineering 

6 analysis results. Essentially the data used that make 

7 up the cost efficiency curve. At the top you can see 

8 – this is for the high volume, key product classes. 

9 At the top you can see the manufacturer production 

10 cost. And as I mentioned, because DOE doesn’t expect 

11 that manufacturers are using different components or 

12 pathways to improve efficiency across different 

13 products, then the same manufacture production cost is 

14 applied across all product classes here.

15 Here’s that same data, just in graphical 

16 representation. And as you can see, it reflects the

17 stylized version that I showed earlier where, as FER 

18 decreases, meaning the energy consumption decreases, 

19 the estimated manufacture production cost increases.

20 MR. BROOKMAN: Yes, Dave.

21 MR. WINNINGHAM: This is Dave from Allied 

22 Air. A question on EL-4 where you’ve got an ECM plus 

23 multi-staging. Is the additional cost – the furnace 

24 fan is one component of that multi-staging, but there 

25 are other components that go into that multi-staging, 
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1 is that at all accounted for in your –

2 MR. JASINSKI: Yes. The increased cost of 

3 the primary control board is included, in addition to 

4 wiring, and also the gas valve.

5 MR. BROOKMAN: Diane, you wish to comment on 

6 these numbers?

7 MS. JAKOBS: It would be the control, the 

8 gas valve, the wire harnesses, and the motor.

9 MR. JASINSKI: Uh-huh. Here are the results 

10 for the low volume key product classes, again, non11 weatherized oil, non-condensing and hydronic air 

12 handlers. As you can see those manufacture production 

13 costs are higher to reflect the fact of the low volume 

14 – the factors that I spoke about earlier in terms of 

15 the differences in volume.

16 And here are those in graphic form. As 

17 you’ll notice, the hydronic air handler curve has two 

18 additional points, and those are related to the 

19 standby and off mode design options.

20 One particular issue that DOE requests 

21 comment on is the turn down ratio of the different 

22 motor technologies. Here the turn down ratio is the 

23 ratio of the minimum motor speed to the maximum motor 

24 speed. DOE has preliminarily found that high 

25 efficiency motors, on average, have lower turn down 
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1 ratios, which indicates that it has a wider range of 

2 achievable speeds. So DOE seeks comment on the 

3 typical turn down ratios that can be achieved 

4 technically and in practice by each motor technology. 

5 And I provided – there’s a list here of the motor 

6 technologies of interest.

7 MR. BROOKMAN: Yes, Paul.

8 MR. LIN: Paul Lin from Regal Beloit. In 

9 the TSD, I’m not sure if I – maybe I missed it – where 

10 you talked about what speeds you assumed on the turn 

11 down? You did in the detailed report on the speeds.

12 MR. JASINSKI: Yes, it’s the maximum and the 

13 minimum.

14 MR. LIN: No, in evaluating the turn down 

15 ratio for a PSC, the high efficiency, did you specify 

16 what RPM you were turning down to in the FER, in 

17 detail?

18 MR. JASINSKI: No, I think – in the TSD we 

19 just provided the actual turn down ratios, but I can 

20 explain that what was done, is for all the units that 

21 we had information for, the performance information is 

22 usually in the form of a table of air flow and CFM 

23 across a range of external static pressures for each 

24 available air flow control setting. So to generate 

25 those ratios, the air flow at something close to the 
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1 proposed reference standard, external static pressure, 

2 the air flow in the minimum was divided by the air 

3 flow in the maximum at that external static pressure 

4 for each model that we had that information for. And 

5 then, you know, generated average values based on 

6 that. But I believe the table with the percentages is 

7 in there, that’s how that information was generated.

8 MR. BROOKMAN: No additional comments on 

9 turn down ratio?

10 MR. JASINSKI: DOE requests comment on 

11 proprietary permanent brushless magnet motor 

12 technology. DOE is aware that there might be 

13 intellectual property around some of the higher 

14 efficiency motor technologies, so DOE seeks comment on 

15 the validity of its premise that alternative motor 

16 technologies can achieve comparable performance, i.e., 

17 the turn down ratios and efficiency, at comparable 

18 cost to the brushless permanent magnet motor 

19 technology offered by Regal Beloit. Many interested 

20 parties have commented that there are issues related 

21 to this, so DOE seeks comment on the validity of that 

22 assumption. And essentially the availability, cost 

23 and relative performance of alternatives.

24 MR. BROOKMAN: Yes, please, Steve.

25 MR. ROSENSTOCK: Steve Rosenstock, Edison 
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1 Electric Institute. In terms of this, do we have any 

2 information about the patents length of these 

3 manufacturers? I mean of these patents for whichever 

4 aspects of the technology. You know, a typical patent 

5 can last as long as 17 years. So depending on – and 

6 they can be extended as well. So again, I don’t know 

7 what the time frame for the expiration of the patent 

8 is after, let’s say, 2020. I don’t know exactly how 

9 these other manufacturers are going to use similar 

10 technologies without – they’d have to pay a licensing 

11 fee or something.

12 MR. BROOKMAN: Diane.

13 MS. JAKOBS: Part of it, it isn’t just the 

14 motor technology, it’s the good job that GE and Regal 

15 Beloit have done in providing us engineering tools, so 

16 that we can easily apply their products. And I know 

17 Rheem has been approached by manufacturers from other 

18 countries and they, on the surface, seem to have this 

19 similar motor technology, but they want us to provide 

20 them the program. Well, we use a Regal Beloit program 

21 to program the motors, so it’s all kind of tied in 

22 that we don’t – we program the motors, but we use 

23 engineering tools from Regal Beloit in order to do 

24 that. So I guess we’re not as smart as maybe we could 

25 be, but that’s kind of where we are. We depend on the 
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1 vendor to provide the technology for us to use this 

2 ECM technology.

3 MR. BROOKMAN: Okay. 

4 MR. JASINSKI: Yeah, just as a follow on. 

5 The crux of this is that the MPC estimates reflect 

6 what DOE expects are current manufacture production 

7 costs, but DOE is trying to understand the market 

8 factors that need to be considered to understand what, 

9 in the presence of standards and in the absence of 

10 standards, I think we’ll talk about these different 

11 scenarios, what will happen to our assumptions and 

12 costs.

13 MR. BROOKMAN: Rob.

14 MR. BOTELER: Rob Boteler with NEMA. Yeah, 

15 just to pick up on that comment, that’s exactly right. 

16 What the motor manufacturers in the US do, is we have 

17 labs where we actually bring in the fan equipment from 

18 our customer, and we go through a characterization 

19 process for our ECM that’s in a lot of cases, unique 

20 to each manufacturer’s application. So it’s not just 

21 an off the shelf product that’s available.

22 MR. BROOKMAN: Okay. Move on to six.

23 MR. JASINSKI: DOE is requesting comments on 

24 high efficiency fan motor control cost. DOE would 

25 like information regarding whether or not more costly 
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1 primary control boards that are required to be paired 

2 with higher efficiency motors, and this, just as a 

3 clarification or a preface, DOE is aware that ECM or 

4 higher motor efficiency technologies come with their 

5 own integrated controls, but this request for comment 

6 is aimed at trying to understand the impacts on the 

7 primary control board of the HVAC product, whether or 

8 not those become more complicated, and in turn, more 

9 costly when being paired with those higher efficiency 

10 motor technologies.

11 MR. BROOKMAN: Terry Small, you’re next.

12 MR. SMALL: Terry Small, Mortex. I’d like 

13 to point out that right now the watts spread, the 

14 number of manufacturers, and usage in PSC motors gives 

15 a lot of flexibility for both big and small 

16 manufacturers to use the technology. If we end up 

17 outlawing PSC motors, which I don’t know whether 

18 that’s the hidden agenda here, I think you will – then 

19 we’re relying on one or two manufacturers of the more 

20 efficiency technologies for motors. That would be a 

21 real disservice to the consumer. Thank you. .

22 MR. BROOKMAN: Thank you. Other comments on 

23 high efficiency fan motor control costs? Yes, Diane.

24 MS. JAKOBS: We talked about it in 2010, but 

25 one of the issues with the programmable motors is 
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1 replacement in the field. And I think you added 

2 something in there for that, but when we started out 

3 we ended up with kind of a special motor for every 

4 furnace model, and then to replace it, a lot of our 

5 customers, our distributors didn’t want to stock all 

6 of these flavors of ECM motors, and because they’re 

7 expensive. So it turns out that maybe to replace your 

8 ECM motor you have to air freight it in, because no 

9 one keeps it in stock. You have to get it directly 

10 from the manufacturer. And we’ve tried to do some 

11 things to get around that, but I don’t know how 

12 widespread it is in the industry. So that issue of 

13 where does the program reside for this programmable 

14 motor? Does it sit in the motor or in the furnace? 

15 And then there are safety implications if – it’s like 

16 all our components don’t really talk to each other, 

17 they kind of assume each individual component knows 

18 what it’s supposed to be doing and if there’s a 

19 mismatch it might be a safety hazard.

20 MR. BROOKMAN: Okay. Paul, did you have a 

21 comment?

22 MR. LIN: I was just going to comment that 

23 there exists more than one or two motor manufacturers 

24 that provide ECM technology, so that there’s a breadth 

25 of manufacturers that provides motor technology 
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1 relative to the access as well as a fully ... ECM.

2 MR. BROOKMAN: Okay. I have a comment from 

3 Jim Vershaw. Jim, you’re next.

4 MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 

5 On issue four, the turn down, you’ve got to remember 

6 that there is an upper end to how fast typical blower 

7 wheels can be turned and a lower end to what bearings 

8 can handle the motors. That kind of limits your turn 

9 down. So please be aware that if you’re going to try 

10 to go above 11, 1200 RPM, you’re going to have to 

11 change the blower wheel and make it more expensive. 

12 So maybe if your analyses are going above that RPM, 

13 you’ve got to be aware of that.

14 On issue six, on the fan control, yes. The 

15 furnace controls change with fan type, or motor type I 

16 mean. You will get substantially different needs for 

17 different types of motors, and usually they’re more 

18 complex as you go up in motor complexity as well. 

19 Thanks.

20 MR. BROOKMAN: Okay. Thank you. On to 

21 issue seven.

22 MR. JASINSKI: Issue seven is regarding 

23 backward inclined impellers, and we’ve touched on some 

24 of these a little bit already, so DOE seeks comment on 

25 the expected efficiency improvements across the range 
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1 of operating conditions in residential applications. 

2 This request speaks to the issue that’s been raised 

3 about how the relative performance is different under 

4 different operating conditions. So DOE is requesting 

5 information to understand that so that it can be 

6 reflected in the analysis.

7 MR. BROOKMAN: I think we already received 

8 one comment on this, did we not? Additional comments 

9 on backward inclined impellers? Diane.

10 MS. JAKOBS: I was working on this a couple 

11 of years ago, but there’s an ISO standard – I think it 

12 was someone from Lau who was telling me about it, but 

13 there are different levels and he had a graph where he 

14 showed where for different diameters and for larger 

15 diameters, it is significantly more efficient, but he 

16 had them where they were crossing, just in the ten 

17 inch area where we are. And since that was my project 

18 in advanced R&D that was a kind of disappointing 

19 revelation, but we’re kind of – for residential 

20 furnace fans and diameter of wheels that we’re using, 

21 there seems to be certain tradeoffs in that area, and 

22 where if you were going to a commercialized unit where 

23 they are more and more common, that there’s clearly an 

24 advantage. But in our specific size, there is some 

25 issues where the trend is not what it is at larger 
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1 diameters.

2 MR. BROOKMAN: Okay. Greg.

3 MR. WAGNER: Greg Wagner. I commented a 

4 bunch on this earlier, but I’ll just reiterate that 

5 the literature that you reference in some of the 

6 testing shows that there are varying degrees of 

7 performance improvements and reduction, depending on 

8 where you’re operating it in the system. So it’s not 

9 a universal – that it translates into appliances.

10 MR. BROOKMAN: Okay. Additional comments?

11 MR. JASINSKI: One that we didn’t touch on 

12 and I’ll mention it is the DOE is seeking comment on 

13 whether the backward inclined impeller could impact 

14 product offerings that might – if it’s incompatible 

15 with certain designs or components currently used in 

16 furnaces. That’s important information to understand 

17 how implementing them might impact the mix of product 

18 offerings.

19 MR. BROOKMAN: Greg.

20 MR. WAGNER: I’ll comment on that one. 

21 Specifically to that with the implementation of 13 

22 SEER furnaces in particular, and other products like 

23 that, have shrunk in size because of available space 

24 to fit them in most homes. They have eight foot 

25 ceilings as a max, and so when you’re putting in a 
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1 bigger coil to do the air conditioning part, the other 

2 remaining parts of the system are shrunk down. Back 

3 when Wegman (ph) and those guys did the research in 

4 2003, that wasn’t part of the equation. Since then, 

5 furnaces have gone from 46 to 52 inches down to about 

6 33, 34 inches, principally. So there’s even less 

7 space today for the air moving section, if you will. 

8 So to your comment about designs and impact, that’s a 

9 significant impact on being able to implement some of 

10 these technologies perhaps, in many applications.

11 MR. BROOKMAN: Thank you. Other comments?

12 MR. JASINSKI: Regarding the air flow path 

13 design, DOE seeks comment on air flow path design 

14 changes that could result in improved air flow 

15 efficiency, and in addition to that, cost and 

16 efficiency data related to those air flow path design 

17 improvements, and also the expected tradeoffs between 

18 air flow efficiency and thermal efficiency or system 

19 efficiency for those designs. But I think these are

20 issues that we have already touched on in depth, but 

21 written comments would be really appreciated.

22 MR. BROOKMAN: Yes, and if you want to call 

23 out any specifically that you don’t think we’ve 

24 covered sufficiently, that would be okay, but – Jim 

25 Vershaw, you’re next.
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1 MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 

2 Back to the previous issue, if you look at the Wegman 

3 (ph) report, once you get above 1200 CFM –

4 MR. BROOKMAN: Jim, see if you can speak up, 

5 please.

6 MR. VERSHAW: Okay. I am. If you look at 

7 the Wegman (ph) report, the results above 1200 CFM 

8 showed that FC wheels are actually more efficient than 

9 BI wheels. So I think you’ve got to be careful on the 

10 backward inclined as far as capacities. You get 

11 above three tons of air flow, the performance is going 

12 to fall off unless you essentially different wheel 

13 diameters and speeds. Thanks.

14 MR. BROOKMAN: Thank you. Okay. And 

15 comments on air flow path design. We’ve covered this 

16 somewhat, maybe fully. Additional comments? Terry 

17 Small, you’re next.

18 MR. SMALL: Hi. This is Terry Small with 

19 Mortex. On issue eight, and this we’ve had a lot of 

20 discussion on it. But I think what was interesting, 

21 I’m a bit dismayed that the word safety has never 

22 crept into the discussion so far. And so much of air 

23 path design is around the safety aspects of whether it 

24 would be a heat exchanger, or a natural gas furnace, 

25 or resistance heat, where you’re worried about where 
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1 the limits operate, even on a hydronic unit. So I 

2 think that the air path design is very much to be 

3 determined more by safety, which of course is a 

4 liability to manufacture. We’re less concerned about 

5 efficiency when it comes to safety. Any comments on 

6 that?

7 MR. JASINSKI: Yeah, I would just say that 

8 one of the major screening criteria is we evaluate 

9 technology options for their health and safety 

10 impacts, so if there are specific health and safety 

11 impacts that would be related to any type of air flow 

12 path design, DOE would really appreciate comments 

13 regarding that, so that it can be considered in the 

14 screening analysis.

15 MR. BROOKMAN: Additional comments on air 

16 flow path design? And then we have kind of a summary 

17 box, correct?

18 MR. JASINSKI: Right, just other comments or 

19 recommendations related to the analyses I’ve 

20 presented: the market and technology assessment, the 

21 screening analysis, and the engineering analysis in 

22 general.

23 MR. BROOKMAN: Any overarching comments at 

24 this point? Okay, so it’s now 12:30. I’m going to 

25 suggest we pause for lunch, and I think we need it. 
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1 We’ve covered a lot of ground. It’s been very, very 

2 productive conversation. I appreciate especially all 

3 of you coming forward with such good comments. 

4 You’re probably familiar – many of you 

5 worked in this building before. Once again, you must 

6 wear this badge. This room will be locked during 

7 lunch, or it will be supervised, so you can leave your 

8 stuff here. There’s a big cafeteria, down to the 

9 ground floor about 100 yards in that direction after 

10 you get to the elevator. It’s 12:30. We will take a 

11 full hour for lunch, because that’s about how long it 

12 takes, which means we’ll resume at 1:30. We’re a 

13 little behind on everything, but we’ll catch it up. 

14 You may need an ID to get back in. Sometimes 

15 they require it, sometimes they don’t, but you’ll have 

16 to go back through security portal – what do they call 

17 those things. So anyways, thanks for a good morning, 

18 we’ve got more to cover, but we’ll get there, and 

19 we’ll see you back here to start at 1:30.

20 (Whereupon, at 12:30 p.m., the meeting in 

21 the above captioned matter was adjourned for lunch 

22 recess, to reconvene at 1:30 p.m.)

23
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1 AFTERNOON SESSION

2 1:31 p.m.

3 MR. BROOKMAN: We’re still a few folks 

4 short, but let’s start back up. Thanks for coming 

5 back. Thanks for being on time. We’re now going to 

6 proceed with Markups, Energy Use Characterization, and 

7 LCC, and payback period analysis and hear from Alex 

8 Lekov.

9 Markups, Energy Use Characterization

10 MR. LEKOV: Alex Lekov, Lawrence Berkeley 

11 National Laboratory. So we completed engineering 

12 analysis, and now we’re continuing on the economic 

13 analysis with the focus on the impacts on the 

14 consumers and follow up by national impact analysis.

15 So here is the diagram showing where this 

16 belongs in the flow of the overall analysis, and 

17 directly switching to my first topic, which are the 

18 markups. But here is essentially, it is a component 

19 of the overall economic analysis. 

20 So markups or product price determination, is 

21 used to characterize the channels, how a product are 

22 distributed as well, to determine the price paid by 

23 the consumers for baseline and higher efficiency 

24 products. 

25 So in this part of the presentation, I also 
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1 will be talking about the energy use characterization, 

2 which essentially develops the energy consumer savings 

3 for the considered efficiency levels. And those will 

4 be tied in the overall life-cycle cost and payback 

5 analysis, which also are developed for all analyzed 

6 efficiency levels.

7 Here is the overall flow. What you see here 

8 is the typical life-cycle cost analysis. Essentially, 

9 it’s based on total installed cost for the products, 

10 and lifespan operating expenses. This is the total 

11 installed cost represented by the upper part of the 

12 chart, lifetime operating expenses represented by the 

13 lower part of the chart. All the components, as you 

14 see them on this chart, will be discussed in some 

15 detail in the next slides.

16 So, starting with the markups. Markups 

17 relate consumer price to cost of goods sold. The 

18 markups are not the same for baseline and for the 

19 higher efficiency standard. This is a methodology 

20 that DOE developed over the years and it’s been the 

21 same for many rulemakings, some of you participated 

22 over the last period. So we have baseline and 

23 incremental markups. The incremental markups do not 

24 include the component of the cost that are not 

25 impacted by the higher efficiency product, and that 
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1 would be primarily the direct labor cost, which 

2 includes salaries, renting occupants.

3 DOE’s approach also developed the markup 

4 originally for all geographical areas considered in 

5 the analysis. The lower of the slide shows the 

6 sources for development of the markup for all market 

7 participants. I suggest not to read it in details, 

8 manufacturer markup comes from engineering, wholesale, 

9 and mechanical contractors come from Hardy (ph) and 

10 AMCA reports. General contractors markups, as well as 

11 manufactured home. Manufacturer and contractors come 

12 from different table of 2007 economic census. And the 

13 sales taxes are coming from what’s called Sales Tax 

14 Cleaning House Data, which essentially includes this 

15 data – reports this data by state.

16 As mentioned in the beginning, one of the 

17 purposes of the markup analysis is to identify the 

18 channels, the distribution channel for the product. 

19 The important thing here is to highlight that furnace 

20 fans are essentially components of a furnace fan 

21 equipment. Therefore, they’re distributed as part of 

22 the equipment. Therefore, the channel shown here, the 

23 two market segment, replacement and new construction, 

24 are for the furnace fan equipment, and you’re familiar 

25 with similar charts which were shown during the 
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1 residential furnace rulemaking, residential ... 

2 rulemaking. There is a separate channel for 

3 manufactured homes.

4 So, with that, here is our first question. 

5 DOE in this analysis did not consider a distribution 

6 channel for replacing furnace fans which are already 

7 included in installed equipment. So the question here 

8 is if such things exist, what’s the market share if it 

9 exists? So any information on this topic will help 

10 DOE to determine whether such distribution channels 

11 should be included in the analysis.

12 MR. BROOKMAN: Diane.

13 MS. JAKOBS: Okay. This one thing I went in 

14 – we have a man who’s in charge of quality, and I went 

15 and talked to him about replacement rates for higher 

16 efficiency motors versus PSC motors, and we went back 

17 and forth, and we came up with that we’re seeing a 

18 failure rate of double in higher efficiency motors 

19 than we do with the PSC. And you have to keep in mind 

20 that our focus is on the warranty part because that’s 

21 what we’re paying. But he said they start out pretty 

22 even the first year, and it can get much, much worse 

23 if there’s a specific problem. But he was saying 

24 overall he would say it was double the failure rate.

25 So something is going on there, and just the 
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1 idea that you have a copper control board in a air 

2 stream that might have moist air, that that’s not a 

3 failure that can happen on a PSC motor. It’s only 

4 because you’ve added this electronic control that 

5 you’ve added another failure mode. 

6 So you’re saying for replacing furnace fans, 

7 usually because the set screw is jammed onto the 

8 shaft, you know, they probably end up replacing 

9 several components even though maybe the motor control 

10 board is the only component that you end up doing a 

11 whole assembly. So I’m not exactly – I know in the 

12 analysis you excluded the warranty period, but 

13 actually if we have a lot of warranty cost, we’re 

14 going to put that in our original sale price. So, you 

15 know, I don’t know how to handle it, but that bit of 

16 information that the higher efficiency motors pretty 

17 much have double the failure rate.

18 MR. BROOKMAN: Do they have different 

19 maintenance requirements or anything like that? No, 

20 they’re not.

21 MR. LEKOV: So let me connect to your 

22 statement. I believe you are referring to replacement 

23 in case of failures. Those, you will see a little bit 

24 further, those are accounted in the analysis. Here is 

25 the primary issue is a replacement – whether such 
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1 things exist – a replacement for efficiency reasons.

2 MS. JAKOBS: Ah, like –

3 MR. LEKOV: That they’re already – in the 

4 frequency, you’ll see the detailed analysis, there is 

5 a whole slide on this topic. It has been accounted 

6 for.

7 MS. JAKOBS: We are not excited about that 

8 at all because of the safety implications. So we 

9 discourage it. I know it exists.

10 MR. BROOKMAN: Steve Rosenstock.

11 MR. ROSENSTOCK: Steve Rosenstock, EEI, but 

12 it’s also replacement in case of current motor 

13 failure, right? That would also fall under that? 

14 That they’ve decided not to replace the whole unit, 

15 but just the fan because that’s all that needed to be 

16 replaced and the old fan is shot, so replace it with a 

17 new fan?

18 MR. LEKOV: I would say the repair and 

19 maintenance slide will probably talk more about this 

20 aspect of it. Okay. Thank you. 

21 So with that, here are the results. 

22 Essentially, the average markups for the market 

23 participants as explained in the introductory slide 

24 showing them for mobile home and non-mobile home 

25 classes, but the baseline and incremental markup and 
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1 also the market participant. Note that those are 

2 average values. 

3 The LCC analysis and the salary (ph) – we do 

4 this several times – represent actually distribution 

5 of values. So the households are getting different 

6 within the range of this average.

7 Maybe more informative is this one, that’s 

8 the final, actually, average markup by product class. 

9 MR. BROOKMAN: Yes, Craig.

10 MR. MESSMER: I have a question on the 

11 incremental markups you have. This is Craig Messmer, 

12 I’m sorry. You’ve got a lower value. Is that 

13 incremental going to apply to once it is the new 

14 baseline? I mean if you go to a higher standard which 

15 becomes the baseline, you don’t really have an 

16 incremental markup any more, correct? Isn’t that now 

17 what the same markup would be for the baseline? I 

18 mean, I don’t understand why they’re different. 

19 You’ve got a much lower markup for the incremental 

20 cost than you do for the baseline cost. And I read 

21 the document, and I know there’s a graph and curve 

22 that you used to come up with that, but if you have –

23 if you have an option to a piece of equipment, yes, it 

24 might have a smaller markup for that option, but if 

25 it’s the baseline unit, it’s going to have the same 
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1 markup for the whole unit.

2 MR. LEKOV: Yes, the baseline markup is the 

3 baseline. If the unit is a baseline unit, then the 

4 baseline markup is applied to the baseline unit.

5 MR. MESSMER: Okay. But why is the 

6 incremental lower then?

7 MR. LEKOV: The incremental markup indicates 

8 that not all cost are additionally marked up when the 

9 equipment becomes more efficient. And as I already 

10 stated, this is the only difference is the direct 

11 labor cost, essentially. The salaries don’t change 

12 it, the people. If they can – for example, a 

13 distributor, salaries are the same; renting in the 

14 warehouse is the same; utilities that he pays inside 

15 are the same. This is our interpretation, and that’s 

16 the basis of this.

17 MR. MESSMER: Right. Go back to – I mean 

18 one of the things in the document you show that the 

19 X13 to the consumer is going to be an extra $50 or 

20 $60, compared to the baseline. So that’s telling me 

21 that the margin for that $60 is going to be – it’s 

22 going to be much smaller than what the margin was for 

23 the base cost.

24 MR. LEKOV: So just go – to highlight this, 

25 this incremental markup applied to the incremental 
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1 cost only.

2 MR. MESSMER: That’s what I’m saying. No, I 

3 get that. I just don’t think it’s valid is all. 

4 Enough said.

5 MR. BROOKMAN: Okay. Thank you. Other 

6 comments on these two markup slides?

7 MR. LEKOV: So this was the questions about 

8 any recommendation aspect of the markup analysis. And 

9 with that –

10 MR. STEPHENS: Yes, I do have one.

11 MR. BROOKMAN: Yes, Charlie.

12 MR. STEPHENS: Only on manufactured homes, 

13 your numbers on the manufactured homes, new 

14 construction, look a little high to me. And I don’t 

15 know if it stems from your terms of reference – you 

16 called it, I think, in the chain, a contractor, a 

17 manufactured home contractor. Where we live, they’re 

18 called a dealer.

19 MR. LEKOV: Correct.

20 MR. STEPHENS: And they sell the home and 

21 they do arrange for the setup, which doesn’t really 

22 have to do with the mechanical system, typically. But 

23 I’m trying to understand, when you say contractor, 

24 where do you get your markup for a manufactured home, 

25 as I say in our region, dealer, for the thing? Is he 
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1 a contractor, or is he a dealer?

2 MR. LEKOV: So the one for new construction, 

3 you are correct, dealer or builder or general 

4 contractor, this is the term of the participant. And 

5 here are the sources that are used for the derivation 

6 of this particular markup. As you see, the general 

7 contractor markups comes from financial data from 2007 

8 economic census, specifically from the residential 

9 building construction sector tables.

10 MR. STEPHENS: Well, yeah, and I guess what 

11 I’m getting at here is in the bullet on manufactured 

12 home, manufacturer and contractor markups. 

13 Manufactured home, manufacturing sector, I understand 

14 that, and that’s for the making and assembling of the 

15 home and the installation of the – the buying and the 

16 installation of the HVAC system and components. But 

17 then you have all other specialty trade contractors. 

18 The people who sell the new home are not a contractor. 

19 They’re more akin to a car dealer. They sell a home 

20 like a car dealer sells a home, and there is a markup, 

21 but I don’t think the markup is a contractor’s markup. 

22 A typical contractor’s markup where we are is like 

23 1.3. I think that you’ll find if you actually look –

24 I don’t think that source is where you’re going to 

25 find the right numbers is what I’m getting at here. I 
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1 think you need to look more closely into how 

2 manufactured homes are sold, because I’ve never heard 

3 the term contractor applied to that level in the 

4 chain.

5 MR. LEKOV: Okay. 

6 MR. BROOKMAN: Thanks, Charlie. Yes, Tom.

7 MR. ECKMAN: And I would recommend that DOE 

8 consult the group that’s working on the new 

9 manufactured housing standards for the markups in that 

10 sector, since you have another rulemaking that’s 

11 proceeding down those lines. Access to that 

12 information should be readily available.

13 MR. BROOKMAN: Thank you. 

14 MR. LEKOV: Thank you. So with that, 

15 switching to the next precursor to the life-cycle cost 

16 analysis, which is the energy use characterization. 

17 And the purpose of it is to determine the annual 

18 energy cost. In order to do this, energy consumption 

19 of the furnace and product in the individual 

20 households needs to be determined with associated 

21 energy prices. 

22 So it came through this morning, the way the 

23 energy use is determined in its essence, is sum of the 

24 energy use at each operating mode: heating, cooling, 

25 and constant ventilation for each household. The 
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1 primary components are the operating hours and power. 

2 In addition to this, the analysis account for the 

3 effect of more efficient fans on the overall energy 

4 use of the household space conditioning equipment. 

5 The next slides will go in details of all those.

6 MR. ROSENSTOCK: Quick question.

7 MR. BROOKMAN: Steve, please.

8 MR. ROSENSTOCK: Are there plans to use some 

9 of the RECS 2009 data for this analysis as you go on 

10 through the NOPR stage?

11 MR. LEKOV: Absolutely. The NOPR phase will 

12 be based on RECS 2009, and we already started to 

13 download the tables.

14 So in order to do the energy use analysis, 

15 you need to have a sample of households. So if we 

16 start with RECS 2005, and apply a set of criteria –

17 see the small four criteria at the bottom, and they 

18 determine whether the household actually includes the 

19 furnace end product. Once this is determined, we –

20 you can tend to physically think of it as RECS 5000 

21 households. We apply the selection criteria down to 

22 3000. Now we are here at the house – we’re splitting 

23 this mobile home versus non-mobile home part of the 

24 sample. 

25 I’ll focus more on the non-mobile home part. 
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1 We look at the households, separate them by fuel type. 

2 And as you see here, on the right side are the nine 

3 key product classes as discussed this morning. So the 

4 primary and most interesting point is how we develop 

5 the sample for the gas households.

6 So first, the entire sample is applied for 

7 non-motorized gas for the condensing, non-motorized 

8 gas for the ... After that, we select just the 

9 households that are in the center region to use for 

10 the sampling for non-condensing, non-motorized furnace 

11 fans. We add another criteria, household – to the 

12 center sample – households that include central air 

13 conditioning equipment to identify the weatherized gas 

14 furnace fans. To this sample, to the sample that is 

15 for the center region, has central AC, we apply the 

16 criteria which is listed right there, that has gas 

17 water heater with some limitation on the square 

18 footage, to isolate the sample for hydronic air 

19 handler heating and cooling. 

20 So that’s how primary the entire sample is 

21 developed and used in the Monte Carlo simulations for 

22 the determining the energy consumption for each 

23 household.

24 MR. BROOKMAN: Joanna Mauer.

25 MS. MAUER: Alex, can you just explain again 
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1 why the identification of a house that has central AC 

2 indicates that it would be a weatherized gas furnace 

3 fan?

4 MR. LEKOV: So everything is based on the 

5 available data. Weatherized gas furnace is 

6 essentially a package that includes heating and 

7 cooling, so from the sample we are removing the ones 

8 that don’t have cooling. They are not weatherized 

9 furnace fan ...

10 MR. BROOKMAN: Abigail.

11 MS. DAKEN: So, Alex, this is essentially a 

12 follow on question because I didn’t quite understand 

13 the response. When you say has central AC, does that 

14 mean that the household has central AC, or that 

15 central AC is included in the same product?

16 MR. LEKOV: So, step back. For the non17 condensing, non-weatherized furnace fans we’re using 

18 the entire sample that is incident US. Now, the same 

19 example, we look at households that must have central 

20 air conditioning. So I hope this answered the 

21 question. So –

22 MS. DAKEN: I’m sorry, would that include 

23 households that had –

24 MR. LEKOV: -- in order to qualify for as a 

25 weatherized gas furnace fan product, the household 
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1 needs to have a central air conditioning.

2 MS. DAKEN: So a household that has a split 

3 system, central air conditioner, with an indoor coil 

4 and an outdoor coil, and then a non-weatherized gas 

5 furnace, would end up in your weatherized gas sample?

6 MR. LEKOV: Yes, it’s going to be in this 

7 sample.

8 MS. DAKEN: Okay. Thank you. 

9 MR. BROOKMAN: Ted Eckman.

10 MR. ECKMAN: So how does this account for –

11 how does this market share allocation using RECS 

12 either 2005 or 2009, account for the federal standards 

13 change in 2013 for condensing versus non-condensing 

14 requirements?

15 MR. LEKOV: So I think we’ll answer this 

16 when we talk about the baseline efficiency 

17 distribution.

18 So we have the sample now and we’re starting 

19 to calculate the energy use. Here is the chart. 

20 Essentially, the household reflects the formula which 

21 you saw in the beginning. Furnace fan energy use you 

22 need to determine power, you need to determine the 

23 operating powers for each household. In addition, for 

24 each household we calculate the impact on the energy 

25 use. So the power requires the determination of fan 
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1 performance curves and system curves. The operating 

2 powers, there are two separate methodologies for 

3 heating and cooling operating, and for continuous fan 

4 operating powers. The details are on the next slide.

5 So, starting with fan power determination. 

6 This chart is just an illustration. Here is – I’ll go 

7 in additional details of describing how each of these 

8 are derived. So, in essence, from the manufacturer 

9 data we are deriving the fan performance curves in 

10 terms of air flow, the upper three, for each of the 

11 operating modes. Simultaneously with this, develop 

12 the power curves as the bottom three lines. And this 

13 we impose the system curves that’s for this particular 

14 household, which allows to determine the operating 

15 mode at each of these three modes, and to arrive at 

16 the furnace fan power as shown on the right side. So 

17 that’s the schematic. This is just one general 

18 presentation for a specific furnace fan design.

19 MR. BROOKMAN: Diane, please.

20 MS. JAKOBS: I just want to point out that 

21 if you look at this graph, I mean there’s not any 

22 strange peaks, it’s all kind of even flat if you look 

23 at the bottom three curves, and it’s kind of – it’s 

24 like the fan laws govern that at higher static, the 

25 energy consumption goes down. So there’s not a lot of 
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1 weird things going on. There’s all this thing about 

2 manufacturers will game the system by only having one 

3 point. I mean this is kind of how they work, so –

4 MR. LEKOV: So that’s an illustration, I 

5 hope the more specific slides will get us deeper in 

6 this discussion. Okay. So --

7 MR. BROOKMAN: Before we move on, Paul.

8 MR. LIN: Just one comment. I see that 

9 you’ve used three different fan speeds for the three 

10 different settings. Sometimes manufacturers utilize 

11 only two speeds of the three or four speeds that are 

12 available in the motor. So on a heat and a cool, it 

13 could be one of two speeds, and the constant fan could 

14 be one of the heating or cooling speeds, and not the 

15 low speed.

16 MR. LEKOV: So this topic has been discussed 

17 in detail in the furnace fan test procedure 

18 discussion, and this morning also quite a bit was 

19 touched upon. There is a – exactly – there may be 

20 some simplified cases that will not have settings for 

21 all three.

22 So let’s start with a system curve 

23 variation. It’s needed because it is how the 

24 operation of the furnace fan in the individual 

25 household is determined. And it is characterized by 
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1 assigning an external static pressure value at the 

2 maximum cooling air flow operating mode. How is 

3 actually this incorporated in the analysis. As 

4 mentioned multiple times, DOE compiled a number of ESP 

5 measurement from 27 studies that includes furnace fan, 

6 single family and manufactured homes. Now, once we 

7 have this sample, here the table shows – illustrates 

8 this kind of – hopefully in a more clear way. We 

9 split the sample to two parts for non-mobile home 

10 products and mobile home products. After that we 

11 tender those two larger samples, looking at the sample 

12 whether it has air conditioning coil or not. As a 

13 result of this we are coming with two sets of data 

14 which essentially represents a distribution of values 

15 which are after that, randomly sampled for the 

16 households that meet these conditions.

17 MR. BROOKMAN: Diane, go ahead.

18 MS. JAKOBS: I just want to point out one 

19 thing. So, on the previous graph, manufacturers have 

20 to have three coefficients to describe one fan motor 

21 curve. Where we can describe every duct system with 

22 just one coefficient. So, I mean, it just seems 

23 disproportionate. I know this is an engineering 

24 assumption that people do to do load calculations and 

25 design ductwork, and it’s simplified. But, you know, 
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1 the degree of accuracy is suspect. I mean it 

2 represents something, but I don’t know that – I 

3 seriously doubt that you have it – while you have it 

4 under system curve derivation, I don’t think you 

5 looked at whether the system curve represented the 

6 1300 field conditions. You were just looking for the 

7 average static. If someone asked me to estimate a 

8 system curve, I’m sure I would come up with the same 

9 thing, I don’t know how accurate it is. I mean I kind 

10 of doubt it’s very accurate.

11 MR. BROOKMAN: Steve.

12 MR. ROSENSTOCK: Just as a quick question, 

13 in terms of – again, there’s all this data, you show 

14 the averages. Do you have any sort of standard 

15 deviations, or do you have the median value that –

16 again, just for all the numbers that you were 

17 collecting, that type of data might be useful for us 

18 to see any sort of correlation, or just in terms of 

19 the range of values that you got in the field.

20 MR. LEKOV: So we can affirm the furnace fan 

21 test procedure proceedings, DOE published a list of 

22 all 27 studies, and the data is available.

23 MR. BROOKMAN: Greg.

24 MR. WAGNER: Greg Wagner. I looked through, 

25 not all 27 of them, but ten-plus of them, I’ve 
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1 forgotten now how many, and I couldn’t find a 

2 standardized methodology, or a method that, again, 

3 would allow you to average those. They’re not taken 

4 in the same fashion in each of those test setups. So 

5 I would just say that averaging this is putting 

6 together a pile of stuff that’s not necessarily 

7 equivalent. So if you look at study to study, they’re 

8 not the same test setup.

9 MR. LEKOV: Maybe part to answer, DOE’s 

10 analysis does not use average rates. Those are 

11 distributions, very wide distributions per sample, but 

12 this is just to show where the average of this 

13 distribution is.

14 MR. BROOKMAN: Additional comments on this?

15 MR. LEKOV: So we got the system curve, now 

16 let’s focus on the fan performance curves. So first 

17 step DOE did is to derive the average fan performance 

18 curve, a set of average fan performance curves. So 

19 those were done for the six efficiency levels,

20 essentially representing design options. In addition 

21 to this, at each of these efficiency levels, DOE 

22 developed a separate fan curve for the seven fan sizes 

23 listed here, from one through five turns. So if you 

24 think of a metric six by seven, starting with the 42 

25 reference performance curves. 
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1 Here’s the small picture in the bottom shows how this 

2 was developed. 

3 In essence, DOE took the manufacturers’

4 public literature for every single model, something 

5 between 700 and 800 models. We extracted all the 

6 performance data, flow and function of ... and we 

7 develop – see how for each pressure there is a range 

8 of values. So for each of these cases we fit the 

9 curve to represent the range of this reported 

10 operating conditions.

11 Now once this is available, it’s a need to 

12 fit it to match the FER values derived in the 

13 engineering analysis. This morning has been 

14 explained, I believe, in good details, that a single 

15 FER value was derived for each of these – for each 

16 product class and for each efficiency level. However, 

17 there are some differences between the set we 

18 developed, which is based on 800 models and accounts 

19 for the sizes compared to engineering. There are not 

20 very large differences. So, adjustment factors were 

21 derived to DOE’s performance curve to match the FER

22 values as described in the engineering analysis.

23 So as a result of this, since we need to do 

24 it for each product class for each efficiency level, 

25 and in addition to this, need to be done for all nine 
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1 product classes, the sample answer with 376 furnace 

2 fan performance curves and those are the curves that 

3 are used in the Monte Carlo simulation when we do the 

4 sample – we do the sampling. So again, there is a DOE 

5 developed 100 representative performance curves to fit 

6 as close as possible to the operating conditions in 

7 the individual households.

8 MR. BROOKMAN: Diane.

9 MS. JAKOBS: All right, you said you used 

10 fan performance curves from literature. It’s unusual 

11 to show the watts, so really you’re talking about the 

12 air flow, right?

13 MR. LEKOV: You are right that some 

14 manufacturers – not all manufacturers, report the 

15 watts curve, but there are some that report the watt.

16 MS. JAKOBS: I’m aware of two.

17 MR. LEKOV: Yeah. It’s a pretty significant 

18 sample.

19 MS. JAKOBS: It’s a small group.

20 MR. LEKOV: Yeah.

21 MS. JAKOBS: So you only used their furnaces 

22 in your analysis, the ones that had –

23 MR. LEKOV: No, we used all that have air 

24 flow, and for the watts curve we used the ones that 

25 are from available manufacturers, which is a little 
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1 bit smaller sample.

2 MS. JAKOBS: The TSD in the references, it 

3 shows like specific furnace specification sheets – are 

4 those the only furnaces that you used in your analysis 

5 then? So did you list which manufacturers furnaces 

6 data sheets you used?

7 MR. LEKOV: It’s the spreadsheet actually 

8 includes the entire sample – is correct? Yeah.

9 MS. JAKOBS: But I mean, I don’t – you can’t 

10 have any Rheem data, right, because we don’t publish 

11 it.

12 MR. LEKOV: Yes, there are other companies 

13 have also the watts data, but Rheem has the air flow 

14 data.

15 MS. JAKOBS: So that’s what I was – so did 

16 you use our air flow data?

17 MR. LEKOV: Yes.

18 MS. JAKOBS: Okay. But somehow it’s 

19 divorced from the watts part of it because we didn’t 

20 give you that information. I’m just kind of a little

21 confused about – there’s kind of a part about what is 

22 a static and what is a CFM, and then there’s a part 

23 about – to calculate FER you have to have the –

24 MR. LEKOV: Both of them. Okay. I could –

25 maybe we could elaborate on the derivation of how this 
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1 is used in actual sample for the manufacturer that 

2 reports just the air flow data.

3 MR. BROOKMAN: Yes, Victor.

4 MR. FRANCO: Hi, Victor Franco from Lawrence 

5 Berkeley National Lab. So actually we have air flow 

6 data for a lot of the manufacturers, especially non7 weatherized gas furnaces. We only have for, as you 

8 mentioned, for only a few manufacturers the watts per 

9 CFM. To generate the air flow curves, we used – we 

10 try to use all the data. For the watts per CFM, we 

11 used to derive the power curves, we used the 

12 literature from just the available data. We have some 

13 test data that we were able to map also to some of the 

14 manufacturers, that was the 26 models that were 

15 tested, so that helps increase the number of 

16 manufacturers.

17 MR. BROOKMAN: Greg.

18 MR. WAGNER: When you did the testing, you 

19 did it to the AMCA 210 that’s described in the –

20 MR. LEKOV: That’s probably – Sam?

21 MR. JASINSKI: Yes.

22 MR. BROOKMAN: Sam says yes.

23 MR. WAGNER: I mentioned it this morning, 

24 but again, there’s a difference in the way the 

25 correction factors are used between AMCA 210, ASHRAE 
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1 51 and the ASHRAE 37 that all these charts and data 

2 will be, and that is in ASHRAE 37 they correct as if 

3 it’s a constant mass flow, so therefore you’re 

4 correcting to standard CFM. In AMCA 210 you’re 

5 correcting as if it’s a constant volume pump and 

6 you’re adjusting your pressure and power. So they are 

7 two different methodologies for correcting to standard 

8 air density. So the data is not – you’ve got apples 

9 and oranges again.

10 MR. BROOKMAN: Sam Jasinski.

11 MR. JASINSKI: Yes, Sam Jasinski, Navigant 

12 Consulting. Like I said, we’re interested to look at 

13 the comments and make sure we understand what the 

14 differences might be between the test method that we 

15 used, which is proposed in the NOPR and based largely 

16 on AMCA 210 versus ASHRAE 37. But some of those test 

17 models, some of the models that were tested were 

18 compared to the performance data that were published 

19 in the specification sheets, and the raw data did not 

20 differ too dramatically between what we took for 

21 measurements using AMCA 210 and the measurements that 

22 were in the specifications sheets, which according to 

23 manufacturers, was taken with ASHRAE 37. So this is a 

24 very important issue and one that we want to make sure 

25 that we understand completely, so that the values that 
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1 we’re – the test procedure that we’re using is 

2 appropriate, but also that the values we’re basing our 

3 analyses on to conservation standard, are also 

4 appropriate.

5 MR. WAGNER: Greg Wagner again. I would 

6 suggest you take a look at that test data and process 

7 then because there should be a difference that is 

8 noticeable. Having done enough of these tests where 

9 we typically are running AMCA 210 because we make belt 

10 fans, but we also work with our customers and do 

11 testing with the ASHRAE 37 mode. And there’s a 

12 distinct different between those curves, and it’s a 

13 clear DC offset that you’re going to see between those 

14 two. So if you’re matching up, that means one of the 

15 two sets of data is probably all wrong. So I would 

16 just caution that there’s some systematic error 

17 probably involved there.

18 MR. BROOKMAN: Okay. Thank you. Are we 

19 ready.

20 MR. LEKOV: So now we have the methodology. 

21 Here are illustrations of the results. This is the 

22 performance curve for a very specific case, non23 weatherized gas furnace fan, non-condensing, three ton 

24 size, heating mode. And here are how the fan 

25 performance curves will look in this particular case.
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1 MR. BROOKMAN: Steve.

2 MR. ROSENSTOCK: Steve Rosenstock, EEI. You 

3 said that the average ... static pressure was about 

4 either point – 0.73 or 0.52, depending on central air 

5 conditioning in the previous slide. It ranges from 

6 0.52 to 0.73, whether you have central air 

7 conditioning or not, correct?

8 MR. LEKOV: The average value is 0.65

9 because you need to weight it for –

10 MR. ROSENSTOCK: Okay. So again, looking at 

11 this graph, going from 0.52 to 0.75, the air flow 

12 ranges, I’ll say from around 790 CFM to as much as 

13 1100 CFM. For that furnace, what is the required CFM 

14 to meet the needs of that house?

15 MR. LEKOV: So, first, again this is a non16 condensing, non-weatherized furnace fan, so the value 

17 in terms of power that you need to utilize reflects 

18 the three operating modes. The required CFM will be 

19 the CFM depending – for this particular product class, 

20 the average values it will be different depending in 

21 the distribution of the average value which is 0.65.

22 MR. ROSENSTOCK: I guess – Steve Rosenstock, 

23 EEI. My point being is if there’s a need inside that 

24 house for at least, say 1000 CFM, some of the products 

25 will not meet the required CFM. Or am I missing 
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1 something?

2 MR. BROOKMAN: Charlie.

3 MR. LEKOV: Yeah, the –

4 MR. BROOKMAN: We also have – why don’t you 

5 go first. Please say your name again.

6 MR. FRANCO: Victor Franco, LBNL. So we 

7 consider the requirements that the household needs in 

8 terms of an air flow. If – what’s usually done in the 

9 field is if the air flow requirements need to be at a 

10 certain level, you change the air flow setting. So 

11 what’s on the LCC spreadsheet then, the air flow 

12 setting for like say the PSC needs to be higher, it’ll 

13 go to the higher air flow setting. So it will consume 

14 more energy to meet the requirements.

15 MR. BROOKMAN: Charlie.

16 MR. STEPHENS: Charlie Stephens. I’ll just 

17 add that in the field what a house needs is a very 

18 fungible term. The average oversizing factor in the 

19 field is what results in some fairly short cycle 

20 times, so houses almost always get more than they 

21 need, based on the habits of most contractors out 

22 there, more air flow than they really require. So, 

23 you know, I’m looking at the error bands, if you will, 

24 in the field in these actual houses that we’re trying 

25 to use as representative of the whole population of 
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1 house, and quite frankly, there’s a lot of mushiness 

2 out there in those houses and I think what we’re 

3 trying to do here is land on an average set of values 

4 to sample from on either side of average values and 

5 try to come up with something that is a reasonable 

6 approximation. And again, when we get down to this, 

7 we’re looking at this from candidate standard level to 

8 candidate standard level. We’re looking at 

9 differences in the end.

10 And I don’t see any real problems here with 

11 the methodology that’s going on. I just talked to my 

12 field tech during lunch who also added that he finds 

13 remarkable agreement between field conditions and how 

14 an air handler behaves under certain external static 

15 conditions, and the manufacturers literature in most 

16 cases. So it’s actually more predictable than you 

17 think, and the least predictable part of this is the 

18 house itself, and how this thing is matched to a duct 

19 system in a house. So I think the methodology we see 

20 here is actually a pretty good, reasonable 

21 approximation given how messy it is in the real world.

22 MR. BROOKMAN: Go ahead, Victor, go ahead.

23 MR. FRANCO: Just a clarification. The 

24 adjustment is made more in terms of the safety 

25 requirements. So for example, there are some 
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1 households that when sampled, they might go into one 

2 point something static pressure, and at that level 

3 you’re going over the bounds of what you need in terms 

4 of air flow. So -- for those households. So there is 

5 obviously a band that is acceptable. Over that band 

6 is where – and that’s a smaller effect in terms of how 

7 many households actually change air flow settings.

8 MR. BROOKMAN: Diane.

9 MS. JAKOBS: Well, that was one of my – that 

10 was related to my question. I’m kind of surprised by 

11 this linear line for the X13. Are you saying that 

12 that one maybe you change the motor speed as you went 

13 up in static or –

14 MR. LEKOV: No. That’s --

15 MS. JAKOBS: I think after your last reply, 

16 that’s not what you were saying.

17 MR. BROOKMAN: Victor, go ahead, and then 

18 back to Paul.

19 MR. FRANCO: So on the X13 is actually 

20 mostly based on Lennox data for a couple series of 

21 models, and test data. And for this specific three 

22 ton unit, that’s a flat for actually for other curves 

23 that we have. It’s actually more like the PSC, it’s a 

24 little bit more of a curve, but it is decreasing, it’s 

25 decreasing faster than the PSC curve usually. But it 
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1 depends on the fan size and the product class.

2 MR. LEKOV: And also here, to bring up here 

3 note – see the distributions, so it is essentially 

4 representing performance conditions – a set of 

5 performance conditions at static pressure, so this 

6 allows to account for a number of models from 

7 different manufacturers if we have – if the data is 

8 available.

9 MR. BROOKMAN: Paul. Wait, Diane’s not 

10 finished. Keep going.

11 MS. JAKOBS: Well, I mean, that’s one way to 

12 look at it that you’re accounting for this broad band 

13 by drawing a single line, or you could think that 

14 you’re only accounting for a thin line and you’re not 

15 accounting for the broad band. So it’s a matter of 

16 opinion, you know, whether selecting one thing is 

17 really, you know, do you – as an engineer, you always 

18 have a broad band, nothing’s ever exactly correct. So 

19 there’s always the choice. You can pick the top, you 

20 can take – so –

21 MR. LEKOV: As you said, it’s a methodology.

22 MS. JAKOBS: The watts will change

23 dramatically.

24 MR. BROOKMAN: Okay. Paul.

25 MR. LIN: I guess the comment, and I’ll 
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1 defer to a lot of our OEMs, but when I look at this 

2 curve, usually your PSC motor is designed at one 

3 specific point in terms of the fan load. As you 

4 increase the load on a PSC motor, it’s not going to 

5 deliver more air flow versus a discrete torque or 

6 constant torque ECM motor. So to see a static 

7 pressure rise with more air flow on the PSC motor 

8 versus an X13, to us, it doesn’t look right. The data 

9 that we’ve taken relative to an X13 motor versus a PSC 

10 motor on a higher static environment, we see more air 

11 flow delivery from an X13 versus a PSC high static. 

12 So, from this graph, I’m not seeing how it relates the 

13 data we’ve taken in our air flow chamber.

14 MR. BROOKMAN: Thank you. 

15 MR. LEKOV: So –

16 MR. BROOKMAN: Wait just a second. Go ahead 

17 Victor.

18 MR. FRANCO: Just to point, this is for 

19 heating mode, this is for air flow – the curves for 

20 cooling would be different. I don’t know if that’s 

21 the maximum air flow, but that’s the design that you

22 were looking.

23 MR. BROOKMAN: Paul.

24 MR. LIN: Well, whether it’s heating or 

25 cooling, it’s a load on the motor, and regardless, the 
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1 motor doesn’t know whether it’s in heating or cooling. 

2 It’s only going to deliver its design load point, and 

3 it’s only got so much torque available. As you 

4 increase the load on the motor, on the PSC motor, it’s 

5 going to fall off that curve, and deliver less. 

6 Whereas an X13 will deliver up to a certain point and 

7 then it’ll start falling off like a PSC motor. And 

8 then if you look at a fully variable PSM motor, you’ll 

9 ramp the load up until the current limit, and then 

10 it’ll start falling off. So that’s why I’m saying the 

11 curves don’t look like the data that we have in our 

12 lab.

13 MR. FRANCO: So one possibility – again, 

14 Victor Franco – is this is an average. Since this was 

15 based on one manufacturer, the other data is based on 

16 more manufacturers. This depend on the air flow 

17 setting for the heating speed, so potentially that’s –

18 that could be the –

19 MR. BROOKMAN: Sam Jasinski.

20 MR. JASINSKI: Yeah, just as a point of 

21 clarification that might help with the conversation, 

22 is the green curve, the PSC with controls – that 

23 refers to a model that uses a PSC that’s driven by an 

24 inverter. So just in the conversation, comparing the 

25 X13 to the – there’s two PSC curves there – you may be 
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1 referring to the comparison with the red one, but the 

2 green one, as a clarification for everyone else, the 

3 with controls is referring with that inverter 

4 technology that we spoke about during the engineering 

5 analysis, if that changes anything.

6 MR. BROOKMAN: Mohammed.

7 MR. KHAN: Yes, this is Mohammed. Thank 

8 you, Sam, that’s a very good clarification. And I 

9 don’t know if the gentleman was going to respond to 

10 that, but since I have the mic, I was just going to 

11 ask you if you could please share that particular data 

12 specifying exactly what kind of PSC, with or without 

13 controls, the exact test condition specifications, and 

14 then we might be able to look at that and see how that 

15 might compare or marry up or doesn’t marry up to the 

16 distribution that Alex was talking about.

17 MR. LIN: Yes, this is Paul Lin again. I 

18 think what we’re going to do is submit some of that 

19 data that we’ve taken in the lab. We’ve taken 

20 manufacturer A, B, and C furnaces and applied a PSC 

21 motor to it and then in the same box, applied the X13 

22 and then applied a fully variable system in the same 

23 box and compared static pressure versus CFM and we 

24 were doing that not for this particular rulemaking, we 

25 were actually responding to utility questions relative 
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1 to static pressure and watts with various ECM motors. 

2 And so it just happens that this particular data is 

3 useful for this rulemaking.

4 But one comment about the averaging is,

5 although the average data shows that, I think it’s –

6 if you look at each individual case, it’s the same 

7 thing, which is the X13 is going to deliver more air 

8 flow than the PSC motor, the red line. And even 

9 though you have an average, that kind of skews that 

10 rule that we’ve seen in the lab, which is – you almost 

11 define physics here.

12 MR. BROOKMAN: Both Greg and Diane I’ve seen 

13 simultaneously.

14 MS. JAKOBS: Okay. Ladies first. Just from 

15 our understanding, you know, these guys they come and 

16 they explain this new whiz-bang thing and we try to 

17 make sense out of it in our applications, but the PSC, 

18 it drops down and – the red line -- it drops down 

19 pretty severely. And then when we got the blue, the 

20 two blues, you know, it’s almost a straight line 

21 across. So static pressure is like out of the 

22 equation. And then the way I understood X13, it’s 

23 kind of a compromise between the two. It’s better 

24 than a PSC and not as constant as the ECM.

25 MR. BROOKMAN: Craig.
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1 MR. MESSMER: Having stared at millions of 

2 these curves, but looked at them in an opposite 

3 direction than what you guys publish them for whatever 

4 reason, normally flow is on the bottom and the static 

5 pressure going up the vertical axis, it takes me a 

6 little while to get used to looking at this way. But 

7 I can tell you that, to echo what these folks are 

8 saying, those curves don’t look quite right, and the 

9 PSC would be a more vertical curve in this type of 

10 arrangement. But that’s also dependent upon where 

11 you’re operating that PSC motor relative to its peak 

12 efficiency point. 

13 So averaging a bunch of curves using a 

14 variety of different designs is going to give you 

15 really odd looking results that don’t necessarily 

16 reflect the typical or a median type of an 

17 arrangement. So to summarize, I guess, what you’re 

18 getting is a blending here that’s giving an odd 

19 looking curve to this process, and that’s what these 

20 folks are looking at and trying to figure out why this 

21 doesn’t look right.

22 MR. LEKOV: So Craig, it would be great if 

23 we hear about an alternative methodology, instead of 

24 averaging for a range of existing model data, what are 

25 other options, and DOE will look at those.
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1 MR. MESSMER: I’m not sure where you’re 

2 going with this, so I don’t know how to pose –

3 MR. LEKOV: What would be an alternative 

4 approach to the averaging that is done this way here, 

5 basically deriving the performance curve –

6 MR. BROOKMAN: Diane, you want to start –

7 MR. LEKOV: -- for a range of available 

8 data.

9 MR. MESSMER: No, my question is I don’t 

10 know where you’re going, what’s the end goal of this 

11 use of these performance curves.

12 MR. LEKOV: So these performance curves are 

13 after that used to determine the energy use of 

14 specific households that under these conditions, 

15 normalized – for example, this specific case.

16 MR. MESSMER: (off mic)

17 MR. BROOKMAN: Diane.

18 MS. JAKOBS: Well, I think if I was doing 

19 it, because you have such a large range of data, 

20 instead of just averaging it, I think I would want to 

21 look at like on either range, because it seems to me 

22 you’re distorting the shapes of the motor curves. So 

23 it seems like it might be better to select one from 

24 the high range and one from the low and look at it, 

25 you know, at least as a sanity check.
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1 MR. LEKOV: Yeah, that’s an alternative.

2 MS. JAKOBS: Yeah, that’s what you just 

3 asked.

4 MR. LEKOV: Yes. 

5 MR. BROOKMAN: We’re going to keep moving 

6 ahead.

7 MR. LEKOV: So the same sample, here are the 

8 power curves. So on the left side, in terms of watts 

9 per CFM, on the right side, the watts which ... more 

10 clearly show for the same four designs.

11 MR. ROSENSTOCK: Doug?

12 MR. BROOKMAN: Yes, please, Steve.

13 MR. ROSENSTOCK: Steve Rosenstock, EEI, and 

14 I’m looking at the – and again, I appreciate the 

15 graphs – I’m looking at the graph on the right and so 

16 what I’m seeing here is – and again, remembering the 

17 static – average external static pressure that you had 

18 was from 0.52 to 0.73 in a previous slide – in terms 

19 of a non-weatherized, non-condensing gas furnace, what 

20 this graph tells me is that for those operating 

21 conditions, 0.52 to 0.73, and again I don’t know what 

22 the standard deviation is, that the PSC fan with the 

23 controls is going to use more energy than the baseline 

24 PSC fan. Is that correct? That’s what this graph 

25 says. And the reason I ask that is because in the 
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1 technical support document later on, it’s saying that 

2 the annualized energy savings with the PSC with 

3 controls and I’m not sure how you get there from this 

4 graph.

5 MR. LEKOV: So remember that the household 

6 is not getting the average value – it’s a range of 

7 static pressures, so could be from much lower from 

8 what you are stating –

9 MR. ROSENSTOCK: Or it could be higher.

10 MR. LEKOV: -- or it could be higher.

11 MR. ROSENSTOCK: So again, I don’t know if 

12 it’s an average or a median, but again, looking at 

13 this graph and then looking at the – I’m just 

14 wondering if again, I don’t know what percentages 

15 within that range of operating performance or external 

16 static pressures, but let’s say 80 percent of the 

17 homes are within that 0.5 to 0.8 external static 

18 pressure range – again, I don’t have the exact number 

19 – I’m still not seeing – and later on in this 

20 analysis, in this preliminary analysis, how you’re 

21 getting any annual energy savings from going to PSC 

22 with controls.

23 MR. LEKOV: So with the PSC with controls is 

24 a very specific design. It’s essentially based on –

25 it’s included as an efficiency level in this analysis 
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1 and is based on actually single prototype developed 

2 five years ago and not in manufacturing. And the 

3 purpose of this specific design is to allow for a wide 

4 range of rotational speed and appropriate CFMs while 

5 using a PSC motor. So as Sam pointed, this is a 

6 design with inverter. As a result of this, it has 

7 certain advantages if you’re going to, let’s say, use 

8 it at constant ventilation. But on the other hand, if 

9 you use it at some higher static pressure in heating 

10 and cooling for longer hours, it may end up with 

11 results that you notice.

12 MR. ROSENSTOCK: But again – Steve 

13 Rosenstock, EEI – but based on your field results, 

14 again, you show that the average was 0.73 for the 

15 households with central air conditioning, so again, I 

16 don’t know what the variation throughout the day or 

17 throughout the season is, but if it’s not more than 

18 0.2, it would be 0.53 to 0.93 – aren’t you going to 

19 have a higher energy usage with that product?

20 MR. LEKOV: It’s much wider than what you’re 

21 just saying. But yes, that’s correct in some fraction 

22 of households.

23 MR. ROSENSTOCK: Because I didn’t see it 

24 anywhere, I’m not sure what that range is, so –

25 MR. LEKOV: In some fraction of households 
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1 you end up with higher energy ...

2 MR. ROSENSTOCK: Thank you. 

3 MR. BROOKMAN: Victor, and then coming to 

4 Greg and then to Charlie. Yes.

5 MR. FRANCO: Victor Franco. Just to add 

6 then, the results you’ll find a little bit of this 

7 discrepancy. On the heating and cooling in general, 

8 it’s similar or lower performance or more energy use 

9 and the main advantage is on the constant fan. So on 

10 average you could get some energy savings in terms of 

11 electricity, and that’s what you’ll see in the end 

12 results.

13 MR. BROOKMAN: I’m not sure, but I have this 

14 general impression we’re gaining on it here, I think, 

15 and I think the Department is earnestly seeking your 

16 comment on these methodologies and how to make sense 

17 of them from experts such as sit in this room, so Greg 

18 is first, and then Charlie.

19 MR. WAGNER: Real quick, I had a similar 

20 sentiment than when you look at these it’s going to 

21 look like it’s going to use more energy and since 

22 you’re saying that on average it’s always above that 

23 0.5, it will use more energy. But this is the problem 

24 with also tying it to static pressures versus putting 

25 it against flow. If you had flipped these curves 
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1 around and put them in a normal way, you would see it 

2 against flow and you’d have different numbers and 

3 different results, and it might be more indicative 

4 because the green line delivers more air and it 

5 wouldn’t have to run as long, so it might make more 

6 sense. But this whole business of shoving stuff 

7 together like this when they have different shapes of 

8 curves, you’re going to get skewed results that look 

9 like this.

10 MR. BROOKMAN: Okay. Charlie.

11 MR. STEPHENS: Yeah, this is Charlie. I 

12 think – I don’t think I’d necessarily characterize it 

13 as skewed results. What you’re doing here is 

14 statistical analysis. You’re trying to represent –

15 you’re trying to come out with a single number at any 

16 given box in a matrix, based on thousands of samples. 

17 And when you sample all around, you’re going to have 

18 houses that have no air conditioning; houses that have 

19 200 hours a year of air conditioning like we do and 

20 where you’ve got 18-2200 hours of heating; you’re 

21 going to have houses that have low static pressure in 

22 the duct system. There’s going to be all different 

23 kinds of things, and you’re sampling from all of those 

24 houses, and then looking at the net result in the end 

25 and trying to put a single number in a box. The 
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1 single number could have to do with the fact that you 

2 selected a different manufacturer’s system whose 

3 motors and fans run at a different point on that 

4 curve, above or below it. Or it could be just that 

5 it’s a different static pressure, or it could be that 

6 – there’s enough variables here that you just have to 

7 statistically have to try to come out with some sort 

8 of central variable that gives you an answer in the 

9 end, because the Department’s required to come to an 

10 answer.

11 We do this with our field data all the time, 

12 and we actually go out and measure things. But we 

13 still, in the end, if we want to come up with some one 

14 number we have to somehow average and smush all that 

15 together with some reasonable answer, knowing that 

16 there is a distribution around the answer, you know, a 

17 standard deviation, if you will, around that answer. 

18 All we do is acknowledge that and say, yep, it’s this 

19 plus or minus whatever, and is it reasonable within 

20 that range. And I think in the end, we’re all going 

21 to have to look at the results and ask if it’s 

22 reasonable within that range. 

23 But again, I don’t find anything that 

24 bothers me based on my own statistical work with real 

25 data from the field, doing exactly the same thing as 
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1 we’re doing here, only from – with field data.

2 MR. BROOKMAN: Okay. Thank you. Diane – we 

3 need to move on here shortly.

4 MS. JAKOBS: Okay. I just wanted to make 

5 one point. So we talked about the field static is so 

6 much higher than what’s assumed for the coil only 

7 rating. And if you think back to when we developed, 

8 our industry with DOE, that at the time it was 

9 developed for the SEER rating, 0.2 inch static, if 

10 you’re looking at the red line, that was a 

11 conservative number. I mean the watts went down, and 

12 it was only when we added the ECM and X13 where the 

13 slope is the opposite and it’s rising. So it’s not 

14 like someone specifically tried to game the rating and 

15 make things look in a way that was misleading, it’s 

16 more like new technology has changed the original 

17 assumptions.

18 And I’m on a lot of standards committees and 

19 one of the things we’ve struggled with was this thing 

20 about not backsliding. And if you want to update 

21 things for new technology, but it’s going to cost the 

22 efficiency to go in the wrong direction, you’re not 

23 allowed to do it. So it’s really hard to know what, 

24 what do you do? Because sometimes we make a whole 

25 bunch of assumptions when we put together these energy 
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1 descriptors and as the industry learns, as installers 

2 learn, some of those assumptions aren’t so good any 

3 more. But if you implement it into the rating, it may 

4 cause your energy descriptor to actually show an 

5 improvement for the same unit, and you’re not allowed 

6 to do that.

7 MR. BROOKMAN: Okay. Thank you. Dave.

8 MR. WINNINGHAM: Just a general comment here 

9 that the control points of the static pressure ranges 

10 – we’re selecting here from the field data – and 

11 really in a lot of cases, outside of what a 

12 manufacturer would recommend. And we’re in the 

13 process of setting a metric in which we measure them 

14 that is outside of those boundaries. And if you look 

15 at these curves, what they would suggest is a large 

16 energy saving would be to shift that point to the left 

17 to reduced static pressures where you see the biggest 

18 improvement between the technologies. Because as you 

19 go out to the right, they’re converging and you really 

20 aren’t seeing the benefit of the other technologies to 

21 the same magnitude. And while the manufacturers have 

22 a concern around safety and reliability of the 

23 equipment and the installation, there’s an obvious 

24 performance difference here that I think DOE needs to 

25 take into consideration.
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1 I understand, you know, the people who are 

2 specifying want to have something that’s real world, 

3 but what we have here is a comparison tool. So to 

4 compare one product to another, and I think as we’re 

5 looking at that we should align it around where it’s 

6 designed to operate.

7 MR. BROOKMAN: Okay. Thank you. 

8 MR. LEKOV: Okay. So now we have the fan 

9 performance and the power. The next point is we need 

10 the operating hours. So the operating hours for each 

11 product, they’re essentially heating or cooling ... and 

12 capacity. For this analysis those values were 

13 adjusted for –

14 MR. BROOKMAN: Alex, pardon me for 

15 interrupting. I forgot and I dropped Jim Vershaw out 

16 of the queue. Jim, I presume your comments relate to 

17 the previous discussion, so Jim, why don’t you do that 

18 now. I apologize, Alex.

19 MR. VERSHAW: Can you hear me?

20 MR. BROOKMAN: Yes.

21 MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 

22 One of the things that really pointed up -- that last 

23 chart pointed out to me was how much the continuous 

24 fan hours and watts can skew what’s going to happen in 

25 the real world. If you could end up with a system 
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1 that could come up with a lower FER and yet if you 

2 don’t use continuous fan, you’ll use more energy, 

3 looking at the red and the green lines. And I’ve just 

4 got to wonder the value of putting in the continuous 

5 fan in this thing versus the number of people who do 

6 use continuous fan – and I think those are based maybe 

7 on a couple of states in the far north. I’m really 

8 concerned that we can end up with some unintended 

9 consequences by having that included in this whole 

10 calculation.

11 MR. BROOKMAN: Okay. Thank you. Alex, back 

12 to you. I apologize.

13 MR. LEKOV: All right. Continuing with the 

14 derivation of the operating curves in heating and 

15 cooling mode. As I said, basically, function of ... and 

16 capacity of the equipment, corrected for fan ... ratio 

17 and as well an adjustment factor applied. The 

18 adjustment factor is important basically it includes 

19 statistical data, predictions regarding the future 

20 building shell efficiency in terms of physical size of 

21 the household and shell attributes. And this is from 

22 EIA’s 2012 data. Also the result is adjusted for the 

23 average climate conditions. The data we have is for 

24 2005. We used the AA methodology to average it over 

25 the ten years period and there are two other 
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1 conditions which are included in this adjustment 

2 factor.

3 MR. BROOKMAN: Steve.

4 MR. ROSENSTOCK: Question on the last slide. 

5 Steve Rosenstock, Edison Electric Institute. In terms 

6 of building shell efficiency, I don’t know if I found 

7 that section in the technical support document. For 

8 the new homes is this assuming that all new homes will 

9 meet IECC 2009 or IECC 2012?

10 MR. LEKOV: This is based on the EIA’s 

11 forecast for the integrity of the envelope in 2018.

12 MR. ROSENSTOCK: Okay. Steve Rosenstock, 

13 EEI. In terms of forecast for new homes, I would 

14 suggest using the values shown in IECC 2012 because 

15 DOE came out with their final determination and states 

16 are supposed to update their codes by the spring of 

17 2014. So you might want to use that for you new homes 

18 portion of your analysis. Thank you. 

19 MR. LEKOV: Thank you. Now, for constant 

20 fan mode, it’s based on fan constant circulation study 

21 conducted in Wisconsin and Minnesota. DOE based the 

22 adjustment for the national sample using this dataset. 

23 However, it’s very different for the other regions in 

24 the United States. For the south hot, humid region, 

25 it’s ten percent of the value used from these studies, 
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1 and for the north and south hot and dry, it’s half of 

2 it. The table shows actually the results from the 

3 study on the left side, and if you go right on the 

4 side, you see it drops half and drops by 90 percent in 

5 the last column. So those are the values used in the 

6 analysis.

7 MR. BROOKMAN: Diane.

8 MS. JAKOBS: I looked at this and I thought 

9 it made a really strong case that we shouldn’t 

10 consider circulating fan mode. I mean, 97 percent in 

11 the south don’t use it, and 84 percent in the north 

12 don’t use it, so I don’t see how this supports the 

13 idea that actually – because of – for a gas furnace, 

14 because of the hours, we’re actually attributing 20 

15 percent of our FER value to the constant fan motor. 

16 But hardly anyone uses it, and then, you know, so it’s 

17 like – I forget – I think it was like 34 percent for 

18 heating and something – whatever it adds up to, to air 

19 conditioning, is less. So I would look at this data 

20 and I would interpret it completely differently, and I 

21 would say constant fan circulation is not a 

22 consideration.

23 We were on the – Greg and I were on a CSCA23 

24 committee – in Canada, that’s different. They have a 

25 ventilation requirement in their building code, and 
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1 there are a lot of people using the constant fan with 

2 a duct to the outside air, and they are using it. But 

3 here in the States I don’t see that we are using it.

4 MR. BROOKMAN: Charlie.

5 MR. STEPHENS: Charlie Stephens. I hope to 

6 be able to provide some data on this. I would 

7 disagree. Five years ago, I would have agreed with 

8 Diane, but based on recent trends, both in ventilation 

9 and in the sales of rather expensive filtrations 

10 systems that contractors really love to sell, there is 

11 a substantial increase in the use of circulation mode 

12 where I live in the four states of the Pacific 

13 Northwest, and I hope to be able to document that.

14 MR. BROOKMAN: New home construction?

15 MR. STEPHENS: Mostly in new home 

16 construction, but also in older homes as well because 

17 again, this is an adjunct of a filtration system. 

18 What’s being sold is a $400 to $500 dollar electronic 

19 filtration system, generally, and to use it and to 

20 make it effective, you have to circulate the air in 

21 the house. And we’ve got a number of houses that 

22 circulate 24/7, 8760 a year, at some speed that we’ve 

23 encountered out there. They’re always running at some 

24 speed. And that’s not the norm, but there are some 

25 out there that actually do this. 
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1 And it’s only – from what we can tell, it’s 

2 only in the last five years or so where this is 

3 becoming ubiquitous enough that we’re actually quite 

4 concerned about it. As I say, the driver is only half 

5 filtration, the other half is this ventilation 

6 requirement where one way to meet that is to let fresh 

7 air in. April Air is an outfit that makes the 

8 connection to the outdoors. It’s done on a timer. It 

9 is a – if you have a ducted system in the Pacific 

10 Northwest, it’s common to just put a hole to the 

11 outside with a damper on it, and you run your air 

12 handler in circulation mode on a timer, so many hours 

13 a day, typically about eight hours a day. 

14 And this is new because the ventilation 

15 requirements are just now starting to come into the 

16 code everywhere. And I would suggest that DOE not 

17 only here, but in other places in the analysis, pay 

18 more attention to the last five years. In some cases 

19 your data only seems to go through about 2006 or 

20 2007o, and I’m talking about financial data here too, 

21 we somehow stop short of 2008. There’s a lot of 

22 trends going on out there right now that I would 

23 suggest are not temporary, and I think we really need 

24 to bring some of this up to date. And circulating 

25 mode is one of those places that needs to be brought 
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1 up to date, and I hope, as I say, to provide some 

2 data.

3 MR. BROOKMAN: Thank you. Greg. Oh, 

4 actually, Greg – Dave, do you want to follow on?

5 MR. WINNINGHAM: Actually, this is a 

6 question for Charlie. Charlie in the instances where 

7 you’re using constant circulation, are you looking for 

8 a lower constant circulation value? Because there’s 

9 equipment that’s designed different ways. You can 

10 have a cooling speed, a heating speed, and a lot of 

11 equipment uses one of those two steps for constant 

12 circulation. Other manufacturers will choose to have 

13 a constant circulation value that’s much lower. One 

14 of the outcomes of this could be that more 

15 manufacturers, an effort to drive an FER number up, 

16 drop that circulation speed and value.

17 MR. STEPHENS: Yeah, I – that’s true. 

18 Everything you just said is true and I had an alarming 

19 report just last week of one manufacturer who may have 

20 a single speed for circulation, and it’s the highest 

21 speed, which concerns us somewhat.

22 MR. BROOKMAN: Okay, Greg. Thank you.

23 MR. WAGNER: This is Greg Wagner. I was 

24 just going to say that since we’re talking about 

25 anecdotal – as Diane said, we’ve served on committee 
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1 up there in Canada, and they did expressly talk about 

2 this in the circulating mode because of that 

3 requirement of internal – of bringing in external –

4 outside air and circulating for ventilation purposes 

5 on a continuous basis. What they’re finding though, 

6 is that most people wind up turning them off once they 

7 get their first electric bill, so it’s not being used 

8 nearly as much as what is reported. So that runs 

9 counter a little bit to what Charlie’s saying, but I 

10 suppose if you’re putting –

11 MR. BROOKMAN: This is Canadians, right?

12 MR. WAGNER: Well, no, I’m saying I suppose 

13 if you put in a really expensive house and have a lot 

14 of money, you will keep running things continuously 

15 and have that nice ventilation system going, because 

16 you can afford to do that.

17 MR. BROOKMAN: Okay. Keep going.

18 MR. LEKOV: This is the slide that request 

19 comment on this topic. I know we got some and 

20 probably more are coming in the written comments. 

21 Here I will just acknowledge that the impact of more 

22 efficient furnace fan is accounted for the heating –

23 as an impact on the heating and cooling compilation, 

24 and it’s a connection to Steve Rosenstock’s this 

25 morning. Question here, it shows that for all 
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1 products other than air handlers, essentially the 

2 analysis are accounting for the difference in power 

3 between the PEC and ECM and X13 motors from the 

4 furnaces and the air conditioning rule – the numbers 

5 are coming from the rule and explain there. So that’s 

6 how it’s accounted for.

7 For the hydronic air handlers, it’s simply 

8 included in the metric, as explained this morning.

9 MR. BROOKMAN: Steve.

10 MR. ROSENSTOCK: Steve Rosenstock. I really 

11 appreciate that, and just as a quick follow up, when 

12 it says the difference is three watts, is that a three 

13 watt increase or decrease?

14 MR. LEKOV: The furnace fan products with 

15 ECM motors use three watts more, from eight to 11.

16 MR. BROOKMAN: Thank you. 

17 MR. LEKOV: So the next slide are an example 

18 showing the results for non-weatherized gas furnace 

19 both non-condensing and condensing. This is the 

20 energy use.

21 MR. BROOKMAN: Joanna.

22 MS. MAUER: Joanna Mauer. Has DOE provided 

23 either average annual electricity use or electricity 

24 use savings for the three different modes of operation 

25 separately? I was trying to find it and I wasn’t able 
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1 to find it in the TSD or the spreadsheet.

2 MR. LEKOV: They’re probably not in the TSD.

3 MS. MAUER: Okay. 

4 MR. LEKOV: The spreadsheet may allow for 

5 this derivation, but it would be a separate run.

6 MS. MAUER: I see, so it’s not something you 

7 have. The comment is that I think it would be helpful 

8 if DOE is able to provide that kind of information.

9 MR. BROOKMAN: Okay. Paul.

10 MR. LIN: Paul Lin. So I just want to make 

11 sure I understood. Additional fuel use is because of 

12 the higher efficiency of the motors?

13 MR. LEKOV: Yes.

14 MR. LIN: And was the high efficiency on the 

15 cooling side taken into account, because you didn’t 

16 have to reheat, or recool?

17 MR. LEKOV: Yes.

18 MR. BROOKMAN: Diane.

19 MS. JAKOBS: I just want to point out the 

20 units are different, and if you get it all in kilowatt 

21 hours, that the last column is more significant. So 

22 there’s a conversion there. But just comparing the 

23 first two columns, so for X13, you’re going to use 

24 half of the electrical – so if the annual electric use 

25 is 508, then the savings would be 290. So are you 
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1 going to cut your electric bill in half, is that what 

2 you’re saying? For the furnace?

3 MR. LEKOV: That’s the average value 

4 compared to the baseline. From 798 will drop to 508.

5 MR. BROOKMAN: From the baseline.

6 MS. JAKOBS: Okay. But if you’re looking at 

7 different columns –

8 MR. ROSENSTOCK: Thirty-six percent.

9 MS. MAUER: -- so it’s 798 minus 290 is 508. 

10 Oh, okay.

11 MR. ROSENSTOCK: Thirty-six percent. Steve 

12 Rosenstock EEI. That’s an estimated 36 percent 

13 reduction. 

14 MS. MAUER: Oh.

15 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

16 Just a quick one, non-weatherized furnace fan, non17 condensing and condensing, for the annual electric use 

18 that’s both in the heating and cooling mode?

19 MR. LEKOV: Total. Total.

20 MR. ROSENSTOCK: Total, so –

21 MR. LEKOV: And continuous.

22 MR. ROSENSTOCK: So – and that’s kind of 

23 average for those with and without the central air 

24 conditioning, right?

25 MR. LEKOV: The entire sample, yes.
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1 MR. ROSENSTOCK: For the entire sample. 

2 Okay. Very good. Thank you. 

3 MR. BROOKMAN: Tom Eckman.

4 MR. ECKMAN: This is based on the RECS 

5 distribution? Or is this per standard household?

6 MR. LEKOV: That’s a result of everything I 

7 explained, all ten slides, the entire methodology when 

8 you derive the system curves, the performance curves, 

9 get to a specific household, do the calculation, do 

10 the sampling in a Monte Carlo, and you arrive at this 

11 average value.

12 MR. ECKMAN: And the AEO estimates of annual 

13 energy use for heating and cooling, or the RECS 

14 estimates?

15 MR. LEKOV: The starting points are the RECS 

16 estimates.

17 MR. ECKMAN: And you convert to AEO going 

18 forward, for projections? I just don’t know how these 

19 weights – the underlying question that is whether or 

20 not the new furnace standards which – and the new air 

21 conditioner standards which go into effect during the 

22 period of time before this standard would go into 

23 effect, will change the annual loads you’re using here 

24 to derive these savings, because the minimum values 

25 for both AC SEERS –
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1 MR. LEKOV: Those are accounted for.

2 MR. ECKMAN: -- ... going forward basis, using 

3 the AEO data.

4 MR. LEKOV: That is correct.

5 MR. ECKMAN: Okay. 

6 MR. BROOKMAN: Greg. Alex, one more --

7 MR. WAGNER: I’m confused. When we look at 

8 that chart you just had, you look at the condensing 

9 versus the non-condensing, we see the condensing uses 

10 less watts of electricity in the baseline. All the 

11 way down, I guess. But on your FER data in the key 

12 product classes, it’s the other way around. Why would 

13 there be a difference between the two?

14 MR. LEKOV: So this is energy use, kilowatt 

15 hours. The FER is normalized watts per CFM.

16 MR. ROSENSTOCK: The run times are less on 

17 the condensing side because they’re higher efficiency.

18 MR. LEKOV: Yeah.

19 MR. WAGNER: No? I don’t know how – it’s 

20 kilowatt hours, so you’re accounting for an annual run 

21 time in that, but we are accounting for run time in 

22 the FER as well. I guess they’re just flipped from 

23 each other and so it makes – begs the question of, you 

24 know, what’s the FER measuring, or is it an accurate 

25 reflection of what the energy use between the two 
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1 different blowers would be?

2 MR. BROOKMAN: So, we’re due for a break. 

3 It’s now three o’clock. Let’s see if we can do this 

4 in ten minutes. And resume at 3:10, and then maybe 

5 Alex and others can put their heads together and see 

6 if they can unscramble this – what seems to be 

7 divergent results. Okay. 

8 So we’re taking a break now. Everybody get

9 up, move. We’re going to resume in ten.

10 (Whereupon, at 3:00 p.m., the meeting was 

11 recessed for a 10 minute period.)

12 MR. BROOKMAN: I’ve asked Alex to pick up 

13 where we left off, which he says he’s in a position to 

14 explain the divergence that Greg was referring to. 

15 Alex.

16 MR. LEKOV: So here is the explanation. 

17 We’re talking about non-condensing furnace fan product 

18 and condensing furnace fan product. The sample for 

19 non-condensing is primary from the south where the 

20 condensing includes the north. The south is dominated 

21 by the cooling coil which is at high speed. So, while 

22 you have a large heating coil, but lower operating 

23 point. So that’s kind of mathematically how you are 

24 getting to this.

25 So with that now we’ll go through the life-
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1 cycle cost and payback period analysis. Basically we 

2 have the total installed cost, have the lifetime 

3 operating expenses, and applying a number of economic 

4 parameters to arrive at the life-cycle cost as well as 

5 the payback period. Most of you are familiar with 

6 DOE’s approach to the life-cycle cost analysis. The 

7 primary thing here is that it’s performed from the 

8 consumer perspective. The analysis models, the 

9 uncertainty and variability of input, using Monte 

10 Carlo approach, and is implemented in the Excel 

11 spreadsheet with CrystalBall software.

12 Starting with the components of the life13 cycle cost analysis. Consumer price, not much to say 

14 here. We have manufacturer cost. For above baseline 

15 standard to the markups were explained. Applying 

16 sales tax, arrive at consumer price. 

17 Installation cost. Installation cost for 

18 furnace fans, there is not much because the furnace 

19 fan product is installed in the factory as a part – it 

20 becomes part of the furnace fan equipment. There is 

21 one exception in this analysis for the external ECM 

22 furnace fan installation, we add some for installation 

23 cost primarily for check up and adjust the air flow.

24 Now the next component is you need energy 

25 prices, because energy prices multiply energy use 
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1 you’re getting the cost of energy is part of the 

2 operating expenses. So in this shipments analysis we 

3 are using the average marginal monthly prices, and 

4 those are essentially a product of three components 

5 which are the average annual energy prices, using 

6 monthly price factors, and marginal price factors. 

7 So, here are the sources listed for all these three 

8 components using this methodology. And I could go in 

9 some details. In essence, the average annual prices 

10 are for 2010 from these sources. The monthly energy 

11 prices are essentially the same sources, but over a 20 

12 year period. And the marginal energy prices are from 

13 the RECS 2005 data, it actually provides the billing 

14 data for these regions.

15 MR. ROSENSTOCK: Question?

16 MR. LEKOV: Yes.

17 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

18 understand this and I guess my question is again, for 

19 the updated analysis, well especially for natural gas 

20 since the bottom’s kind of fallen in terms of natural 

21 gas prices compared to four or five years ago, will 

22 those projections be updated based on, I’ll say either 

23 AEO 2012 or other more recent forecasts?

24 MR. LEKOV: Yes.

25 MR. ROSENSTOCK: Thank you.
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1 MR. LEKOV: And in line with what Steve just 

2 said, here is the methodology how we calculate the 

3 energy prices over the entire analysis period, and its 

4 primary source is the most current version of AEO 

5 2012. So for the next round of this rulemaking, it 

6 will be updated with the most current AEO data.

7 Repair and maintenance. 

8 MR. BROOKMAN: These are annualized, right? 

9 I’m sorry, go ahead.

10 MR. LEKOV: Yeah, they are annualized. 

11 MR. BROOKMAN: Yes, Paul.

12 MR. LIN: Paul Lin. Just maybe just a 

13 question, because a lot of times I look at EIA data, 

14 because we try to factor in some savings calculations 

15 for some of our products. But if you look at 

16 California relative to the EIA data, it looks fairly 

17 low. I don’t know if you take it into account the 

18 tier levels. As you consume more and more energy in 

19 California, you get more and more charges.

20 MR. LEKOV: So the answer is it is by 

21 geographical area, so we applied it by geographical 

22 area, and for the next round of analysis it will be 

23 even much more detailed than the 14 areas. It will be 

24 27 areas because 2009 will have the RECS data and 

25 we’ll be able to apply that.
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1 MR. LIN: But my point though is that in the 

2 EIA data, I think California was like 15 or 17 cents 

3 average, and I know that that’s not an average 

4 consumer price based on bills, because the 15 may be 

5 on the early stages of the tiers, but not at the end. 

6 That’s where the consumer actually ends up paying. 

7 You probably –

8 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

9 Well, if you look at the – there’s only a few 

10 utilities that have that sort of increasing price 

11 tiers. Most utilities don’t have anything like that. 

12 They have seasonal pricing that will vary, but – what? 

13 Congratulations. So and – even in California, it’s 

14 revenue divided by sales is how they come up with the 

15 annualized value. California is – and Hawaii are kind 

16 of at the high end. There are many other parts of the 

17 country where the annualized price is like seven cents 

18 for residential. And especially some of those going 

19 to time-of-day pricing, some of them are getting 

20 prices as low as off-peak, three cents, four cents 

21 kilowatt hour. So prices are all over the map, but 

22 this again is a nationalized average, which I think is 

23 what this graph is showing, it’s not – it’s not bad at 

24 all.

25 MR. BROOKMAN: Okay. So let’s –
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1 MR. ROSENSTOCK: But there are going to be 

2 some very regional specific, just like with natural 

3 gas, there are certain parts of the country that are 

4 going to be much more expensive than others.

5 MR. LEKOV: So getting into the repair and 

6 maintenance part, essentially, repairs occur if the 

7 fan motor lifetime is less than the furnace equipment 

8 lifetime. We determined the failure year, expressed 

9 essentially the motor lifetime expressing operating 

10 cost, divided by the furnace fan annual operating 

11 cost, the labor cost is coming from the RSMeans data 

12 and we – this is essentially through the center of the 

13 sample, we determine which households will encounter 

14 this expense. The maintenance cost is essentially 

15 just in this analysis, assumes that will be a blower 

16 checking as part of regular equipment maintenance, and 

17 it happened that we had a survey regarding the 

18 maintenance frequency of these type of equipment and 

19 we used from RSMeans the labor hour cost.

20 MR. BROOKMAN: Charlie Stephens.

21 MR. STEPHENS: I have one question here to 

22 make sure I understand the effect of your analysis 

23 methodology here, which is annualized repair costs. 

24 If the – I’m just going to throw out some example 

25 numbers. If the furnace lifetime is say 18 years and 
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1 the motor failure for those that fail is 12 years, how 

2 many motor replacements will I pay for?

3 MR. LEKOV: Essentially one. You have, 

after the 12th 4 year, another one comes.

5 MR. STEPHENS: But you’re annualizing these 

6 costs. Are you annualizing the next motor replacement 

7 in year 13?

8 MR. LEKOV: Yes.

9 MR. STEPHENS: Then you really should not 

10 annualize these costs. You need to put these costs 

11 into the analysis. Because what you just told me is 

12 that by the time I hit the end of the furnace 

13 lifetime, I’ve paid for one and a half motor 

14 replacements, and that’s not what actually happens.

15 MR. LEKOV: No, you’re paying for a whole 

16 motor. This is how it’s included in the analysis.

17 MR. STEPHENS: Well, are you annualizing the 

18 cost, or are you imposing them in year 12?

19 MR. LEKOV: It’s annualized over the period 

20 with the total cost, I believe.

21 MR. STEPHENS: Well, you really need –

22 there’s a difference, when you’re using discount 

23 rates, and depending on the discount rate the effect 

24 changes, but you really need to impose those costs. 

25 You don’t pay those on an annual basis, you pay them 
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1 when they happen in the year they occur. And I’ve 

2 made this comment before. You shouldn’t be 

3 annualizing repair costs that occur every 12 or 15 

4 years. If it’s every one or two years, that’s fine, 

5 but when you start doing that and annualizing it, you 

6 actually distort the analysis financially. So you 

7 really need to change that part of the analysis and 

8 not annualize the repair costs.

9 MR. BROOKMAN: Tom, you want to follow on?

10 MR. ECKMAN: Yes, treating it as a periodic 

11 capital replacement X years out, and then it’s a 

12 discounted value back to the –

13 MR. LEKOV: So in the year of the 

14 replacement?

15 MR. ECKMAN: Yeah.

16 MR. BROOKMAN: Good. Okay. Thank you. 

17 Yes, Craig.

18 MR. MESSMER: Craig Messmer. Okay. The 

19 lifetime of the motor you said is in terms of 

20 operating hours, and it was based on the small motor 

21 ruling. Does that differentiate the life of the motor 

22 if it’s an EC motor or if it’s a PSC motor, because 

23 they will be different? EC motors have a 

24 significantly shorter life span that PFC motors.

25 MR. LEKOV: We use a distribution of more 
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1 the left. I don’t believe that we used – that we 

2 differentiated.

3 MR. BROOKMAN: So in your supportive data, 

4 Craig, that would be helpful.

5 MR. MESSMER: I’m going to have to defer to 

6 my compatriots here that are motor manufacturers to 

7 tell us what the expected life is of these motors.

8 MR. LIN: Well, in the small motor rule, 

9 that talks to cap start, cap run, cap start induction 

10 run, and polyphase motors, and they’re all fixed speed 

11 motors. So there’s no consideration in there for ECMs 

12 whatsoever. So they’re not in the small motor rule.

13 MR. MESSMER: Okay. So that’s inappropriate 

14 to use that data then. We need something else, right.

15 MR. BROOKMAN: Paul, first.

16 MR. LIN: From a specification standpoint, I 

17 could be wrong, but I remember ECM motor life 

18 specifications from manufacturers to be the same as a 

19 PSC motor, on your specs.

20 MR. BROOKMAN: Diane.

21 MS. JAKOBS: I think that’s true, but I 

22 don’t think that’s – well, when I talk about what our 

23 actual returns are and our warranty costs, that’s what 

24 we ask for. That’s not how it’s playing out.

25 MR. BROOKMAN: Dave, you’re next.
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1 MR. WINNINGHAM: Yeah, I would agree with 

2 that, and I think the expectation is for them to be 

3 the same, but I think in the real world, they’re not. 

4 More complex systems in our products tend to have 

5 different failure rates, higher failure rates. And I 

6 think for each of these technology levels you need to 

7 take that into account, into your life-cycle cost, 

8 because, you know, a lot of times you will have a 

9 motor and a control, and they’re going to replace the 

10 whole thing. And we need to account for those costs 

11 accurately to come to the right conclusion here.

12 MR. BROOKMAN: Diane.

13 MS. JAKOBS: I think with the PSC motor that 

14 the bearings are probably the weak point, and then as 

15 we add the control board to the assembly, the control 

16 board with all the components and the potting (ph) and 

17 all that, that that’s a weak link in the device. So 

18 we have a different failure mode with the high 

19 efficiency motors.

20 MR. BROOKMAN: Okay. Thank you. 

21 MR. LEKOV: Another important component is 

22 to determine the lifetime. So, in general, it’s 

23 assumed that a furnace fan lifetime equals the furnace 

24 equipment lifetime. For the individual product cost 

25 there is a different methodology for determining the 
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1 equipment lifetimes, and it’s based on an analysis for 

2 not only the ... furnaces, it’s based on the analysis 

3 which were performed also for the furnace rule, and it 

4 uses a combination of shipment data, REX data on the 

5 age of the furnaces, and the historical HS data on the 

6 stock.

7 For the mobile home and electric furnaces, 

8 we use the decision ... survey, and those are the 

9 sources and the methodologies used for the 

10 determination of the furnace fan lifetime. 

11 The average values are summarized in this 

12 table for the individual product cost.

13 MR. BROOKMAN: Steve Rosenstock.

14 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

15 can’t remember – I’m trying to think in the – I’m just 

16 kind of – and again, maybe other people – in the small 

17 motor rule, I can’t remember – what was the lifetime –

18 I thought it was like a 15-year lifetime for those 

19 motors that were under the small motor rule.

20 MR. LEKOV: So I would just like to –

21 essentially we are talking about the entire furnace 

22 fan component here, in terms of assumptions for the 

23 lifetime. The failure of the motor is accounted in 

24 the repair and maintenance, the right rate.

25 MR. LIN: Paul Lin. I think you just be 
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1 careful with taking the small motor and then cross2 referencing that over to an HVAC motor. The design of 

3 a general purpose duty small electric motor as defined 

4 by the DOE standard is much different than an HVAC 

5 motor. There’s different requirements and loads on 

6 those motors. Diane mentioned the bearing being the 

7 weakest link on most HVAC motors. It’s sleeve bearing 

8 on the PSC and ball bearing on the ECM. And on the 

9 general purpose, small electric motor, they’re all 

10 larger ball bearings with, I would say, higher loads 

11 and a lot of times there are different application 

12 environments that may reduce the life or may increase 

13 the life relative to the HVAC environment. So I think 

14 drawing a comparison between the two may not be 

15 accurate. The HVAC motor is an air-cooled rated 

16 motor, whereas the small electric motor is not. So 

17 there’s a big difference between the two.

18 MR. BROOKMAN: Okay. Steve.

19 MR. ROSENSTOCK: Steve Rosenstock. Yeah, 

20 again, thank you for that. Just kind of following on, 

21 so you would say that the HVAC motors would tend to 

22 have a longer life based on the operating conditions?

23 MR. LIN: I think the HVAC motors have a 

24 more benign environment versus the small electric 

25 motors.
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1 MR. ROSENSTOCK: Okay. Thank you. 

2 MR. BROOKMAN: And would you say, looking at 

3 this table that this is an accurate reflection?

4 MR. LIN: Paul Lin. This table here is 

5 referring to the appliance equipment.

6 MR. BROOKMAN: Yeah.

7 MR. LIN: Is not referring to the life of 

8 the motor, so I can’t fault the distinction between 

9 the two.

10 MR. BROOKMAN: So we can – go ahead. Diane.

11 MS. JAKOBS: Diane again. Yes, I think this 

12 reflects the life of our furnaces, and especially, you 

13 know, after 15 years, you have to change the motor 

14 out, you’re good to go for another ten years or more.

15 MR. BROOKMAN: Okay. So this winter I could 

16 be in trouble, right? Go ahead, Craig.

17 MR. MESSMER: Is this slide saying that the 

18 furnace fan is the life of the unit?

19 MR. LEKOV: The furnace as a whole analysis 

20 in terms as it’s a unit in the analysis, the furnace 

21 fan product equals the life of the equipment.

22 MR. MESSMER: Okay. They typically get 

23 replaced when the motor gets replaced?

24 MR. LEKOV: Correct.

25 MR. MESSMER: So –
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1 MR. LEKOV: Oh, that’s a comment.

2 MR. MESSMER: They change out both parts at 

3 the same time.

4 MR. BROOKMAN: Okay. Diane.

5 MS. JAKOBS: So you’re saying when you get a 

6 new furnace, you don’t keep your furnace fan because 

7 it has some life left in it, you’re done with it when 

8 you replace your whole furnace system.

9 MR. LEKOV: That’s correct.

10 MR. BROOKMAN: Okay. Dave.

11 MR. WINNINGHAM: And just back to the life 

12 issue. The motor side of it can be one thing, but how 

13 a manufacturer applies it – and some manufacturers may 

14 choose to be more aggressive than others and to the 

15 operating window that they’re placing that motor in. 

16 So I don’t think that just a generic statement around, 

17 you know, the expected life of an HVAC motor is, you 

18 know, from the suppliers is X because in most cases 

19 we’re specifying to them what we need from them for 

20 performance and we kind of choose where we’re going to 

21 operate it in regard to temperature rise and bearing 

22 temperatures.

23 MR. BROOKMAN: Okay. 

24 MR. LEKOV: So, DOE uses discount rates to 

25 determine the lifetime of the operating expenses for 
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1 the product, and the methodology is to derive those 

2 discount rates from estimates of the finance cost to 

3 purchase a residential product from the large federal 

4 reserve board survey of consumer finances. The 

5 sources at the last bullet. There are actually a 

6 number of surveys, each of them contain 200,000 data 

7 points, and the finance cost is essentially 

8 represented as the financial cost of any debt incurred 

9 to purchase the product or as an opportunity cost.

10 Now, here essentially, the interest rates 

11 that are encountered in both new construction and 

12 replacement, I will repeat – this is a question –

13 those are real interest rates. They account for the 

14 inflation. In essence it’s when people ask how we 

15 compare with the current one, you add three, 

16 approximate.

17 MR. BROOKMAN: Steve.

18 MR. ROSENSTOCK: Steve Rosenstock, EEI. So, 

19 the – for the mortgage, it’s basically assuming that 

20 it’s a real rate of three percent, but the nominal 

21 rate of six percent. Is that a good way of kind of 

22 looking backwards over the last, I’d say, 20-plus 

23 years.

24 MR. LEKOV: ’89 through 2007, about 200,000 

25 data points. And I guess the issue with replacements, 
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1 again, there’s no data from 2010. I know it would be 

2 a real interest rate of – a nominal interest rate of 

3 about eight percent. Looking back over 20 years, that 

4 might be a little on the low side, just because 

5 interest rates were a lot higher in the late 80s, 

6 early 90s. So, again, it’s kind of in the weeds, but 

7 again – and especially in terms of replacement, 

8 especially after the recession, I have no idea how 

9 more people are financing the replacements but it’s 

10 much harder – I think it’s probably much harder for a 

11 lot of people to get loans or home equity loans than 

12 it was just seven years ago, so that might also push 

13 up the real rates as well.

14 MR. BROOKMAN: Other comments on discount 

15 rates?

16 MR. LEKOV: Product assignment in the base 

17 case. Base case product efficiency assignment 

18 reflects the projected market share of products at 

19 different efficiency levels, and it reflects the fact 

20 that not all consumers purchase products at the 

21 current minimum standard, as well as the LCC 

22 recognizes that the consumers already purchase 

23 products at efficiency greater than or equal to 

24 projected standard level. So they are not impacted by 

25 the standard.
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1 The approach taken is – the sources for the 

2 methodology are explained here in the bullets. 

3 Basically, we’re using historical data that comes from 

4 sales of furnace by efficiency and by product class 

5 which is not available, so we use stakeholder comments

6 from the furnace rule which stated that the ECM share 

7 rose from ten to 30 percent within the last five 

8 years. Just for the PSC product classes, there was no 

9 data, so it was assumed that 50 percent are at the 

10 baseline level and 50 percent are at improved PSC 

11 motors, and there are no designs representing PSC with 

12 controls.

13 Regarding the market share projections for 

14 the ECM motors. So if it’s done based on the fraction 

15 of motors – fraction of equipment with ECM motors in 

16 the current directories, which is 45 percent in 2010, 

17 we assume that this fraction of 45 percent will 

18 actually meet the market share in 2080. And the 

19 market share in replacement versus new construction 

20 was determined from Canadian survey. 

21 MR. BROOKMAN: Diane.

22 MS. JAKOBS: I know in 2010 public meeting I 

23 said that 30 percent of our sales were going to ECMs, 

24 and back then when we had, I don’t know, tax rebate it 

25 was called, and we’re all geared up, you know, 
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1 everybody’s going high efficiency, and last year it 

2 all turned back around and everybody wants to buy the 

3 bottom. So you don’t have that graph, but it’s in 

4 here, you know, where it shows this big bleep, and 

5 then you go up from there. We’ve actually come way 

6 back down. And I don’t know where it’s going to be. 

7 We’re kind of focused on the lower end of our offering 

8 because that seems to be where we need to be 

9 competitive.

10 MR. BROOKMAN: It’s come all the way back 

11 down to where it was? Wow. Dave.

12 MR. WINNINGHAM: Yeah, I don’t have the 

13 data specific, but it has – it is turned more complete 

14 down.

15 MR. BROOKMAN: Okay.

16 MR. LEKOV: So I assume it’s also at the 

17 comments right now. And here are the life-cycle cost 

18 and payback analysis report from DOE’s preliminary 

19 analysis for the furnace fan products. 

20 MR. BROOKMAN: Craig.

21 MR. MESSMER: It’s Craig Messmer. I didn’t 

22 read all the way through the technical document, but 

23 the lifetime operating cost includes the cost of the 

24 repair, the replacement of the motor as well? The 

25 average lifetime operating cost?
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1 MR. LEKOV: As part of the operating 

2 expense.

3 MR. MESSMER: Well, somebody’s getting a 

4 good deal. Thank you. 

5 MR. BROOKMAN: Well, I mean – Craig, you 

6 should feel free to offer you additional thoughts on 

7 this, how this could be improved.

8 MR. MESSMER: I mean, replace an EC motor, I 

9 mean I’ve seen prices in contractors that charge 

10 customers over $5-600 dollars sometimes, and this is 

11 already $800 for the average lifetime, operating cost 

12 for the whole unit. So if you replace that motor one 

13 time, you have nothing left for the electricity for 

14 the whole use. So I’m not – you don’t really say what 

15 the repair costs are, do you?

16 MR. LEKOV: I don’t think it’s listed here, 

17 but it’s in the TSD.

18 MR. MESSMER: Okay. I’ll have to take a 

19 look at that more carefully, because I think it may be 

20 under-reported.

21 MR. BROOKMAN: Charlie Stephens.

22 MR. STEPHENS: Charlie Stephens. Yeah, I 

23 think you’ve got to remember this is all rolled up 

24 into one number. Not everyone out there got repaired. 

25 So the overall number of homes that had a motor 
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1 replaced might be three percent or four percent or 

2 something of the total. So, when I weight that in the 

3 costs, it’s not $500 bucks, it’s not even $100 

4 dollars, it’s probably more like $45 dollars or 

5 something because it’s only a fraction of the homes 

6 that actually had to replace a motor. So this is a 

7 very rolled-up set of numbers. And it’s more like an 

8 expected value in a distribution, really.

9 MR. BROOKMAN: I saw Dave first.

10 MR. WINNINGHAM: Well, just to echo what 

11 Craig had mentioned. I think the markup in the after 

12 market for replacement parts, you know, after the 

13 warranty period is much, much higher than what you 

14 would find for an OEM. That combined with the 

15 difference in failure rates, I think we need to be 

16 careful that we include a realistic view of that in 

17 these life-cycle cost.

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

19 MR. ROSENSTOCK: Steve Rosenstock, EEI. It 

20 might be — and again, I think I’m going to agree, 

21 because if you take a look between three and four, in 

22 a previous slide, the savings were about the same, 290 

23 versus 265 kilowatt hours, but life-cycle cost changes 

24 between three and four are quite dramatic, both 

25 because of initial cost and lowered reduced lifetime 
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1 energy savings, plus, probably, some of the repair 

2 costs. So go from a five year payback to a 22 year 

3 payback, something’s going on there.

4 MR. BROOKMAN: Paul.

5 MR. LIN: Paul Lin. Just wanted to comment 

6 because I’ve heard some of our OEMs talk about 

7 replacement of the whole ECM. We spend a tremendous 

8 amount of energy and time educating the contractor 

9 base that – of how to diagnose between a control 

10 failure versus a motor failure. So we offer control 

11 only replacement, as well as a motor only replacement, 

12 to try to tackle the total cost of install. So it’s 

13 not – so after the markup, it’s not the whole motor. 

14 It’s hopefully a smaller portion of the cost than what 

15 it used to be.

16 MR. BROOKMAN: Okay. Tom Eckman.

17 MR. ECKMAN: I have a question, this is to 

18 the manufacturers and motor manufacturers, both, 

19 whether the X13 type technology suffers the same fate 

20 because it has a control board too. Is it a higher 

21 frequency replacement item than the ECM? And is it 

22 like the ECM in terms of magnitude, that it’s double 

23 your PSCs?

24 MR. BROOKMAN: Diane.

25 MS. JAKOBS: Just this specific point in 
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1 time, X13s are more of a problem for us this month 

2 than ECMs. But they’re newer, so I don’t know that 

3 that reflects on the technology. It’s both. When I 

4 was talking about double, we were talking about –

5 MR. LIN: Both X13s and ECMs.

6 MS. JAKOBS: Yes.

7 MR. BROOKMAN: Dave, you want to weigh in 

8 here?

9 MR. WINNINGHAM: Yeah, I think, you know, 

10 looking at the various technologies and looking at 

11 what the real world failure rates from various 

12 manufacturers would be a good exercise. We’re not 

13 here to say it’s poor motor designs, but we do see 

14 higher ORT (ph) rates and failure rates in the field 

15 of more technical products.

16 MR. BROOKMAN: Okay. Terry Small, I see 

17 you’ve raised your hand. You’re next.

18 MR. SMALL: Terry Small with Mortex. I 

19 think this just proves that the consumer might know 

20 something that we don’t know. I really think that 

21 choice three, the X13, the payback period from our 

22 experience of what we’re paying for the motors is 

23 going to be much lower, you know, it might be eight or 

24 ten years. And I’m not sure that’s an acceptable 

25 payback period when you consider you’re making some 
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1 generous assumptions about discount rates, et cetera. 

2 So, maybe the consumer actually is voting on an 

3 economic basis when they’re tending to stick with PSC 

4 motors. It’s my opinion.

5 MR. BROOKMAN: Okay. Thank you. Final 

6 comments on this chart. Noting that you have plenty 

7 of time to write copious comments and send them in.

8 MR. LEKOV: So DOE invites comments and 

9 recommendations regarding overall life-cycle cost 

10 analysis.

11 MR. BROOKMAN: Joanna, you have a question?

12 MS. MAUER: Why was 2018 chosen as the first 

13 year of the analysis period?

14 MR. LEKOV: That’s the five year period 

15 after the final rule.

16 MS. MAUER: And why is the assumption that 

17 the standard would have gone into effect five years 

18 after the final rule?

19 MR. ROSENSTOCK: That’s typical. Steve 

20 Rosenstock, EEI. That’s typical for motors, five year 

21 lead time.

22 MS. MAUER: This is on furnace fans, so I’m 

23 asking about furnace fans. 

24 PARTICIPANT: (comment off mic)

25 MS. MAUER: So again, this is not furnace, 
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1 the furnace rulemaking, but a furnace fan rulemaking.

2 MR. BROOKMAN: And we can accept an 

3 affidavit on that point.

4 National Impact Analysis, Shipments Analysis

5 MR. LEKOV: We discussed the consumer, let’s 

6 now focus on the nation. The national impact analysis 

7 has shipments and – shipments component and national 

8 impact analysis component. So, the national impact 

9 analysis, we need an estimate for the national energy 

10 savings as well as the national economic impacts, 

11 which are presented in terms of NPVs. 

12 Now, here is the process. Essentially, 

13 starting with some inputs which come from the life14 cycle cost -- primarily from the life-cycle cost 

15 analysis and the results from the shipments model, 

16 we’re going into the calculation process to determine

17 the national energy savings and national consumer 

18 economic impacts. And after that, those are reported 

19 in terms of quads and net present value by estimating 

20 the savings over the period, 2018 and 2047, and same 

21 for the NPV calculations for the products.

22 Starting with the shipments analysis. The 

23 shipments projections are done by markets. Three 

24 markets are identified for the furnace fan products: 

25 New construction, replacement, new owners. The new 
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1 constructions are coming from new housing construction 

2 projections and historical market share. The 

3 replacements are using the product lifetime applied to 

4 the product stock. There is a market segment called 

5 new owners, this is for the existing buildings that 

6 acquire furnaces or furnace fans for the first time, 

7 and it’s in this particular market to include also 

8 consumers that switch between the furnace fan product 

9 classes.

10 In addition, the projected shipment inputs 

11 are done separately by region, north and south, and in 

12 accounting for impacts of standard levels, the 

13 shipments are adjusted using the price LCC. And I’ll 

14 be talking in more details during the next several 

15 slides.

16 Now, same thing here what I just said 

17 verbally, it’s presented on this graphic.

18 Now, shipments model input. Very busy 

19 slide, but essentially includes all the information if 

20 you want to read it. What are the sources for the 

21 historical shipments? What’s happened in the 

22 replacement shipments? Shipment sources for the 

23 shipments to new housing. We’re talking also about 

24 how we develop the so-called new owners, and I was 

25 pointing to the source of calculation of condensing 
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1 and non-condensing market shares.

2 MS. JAKOBS: Can I ask a question?

3 MR. BROOKMAN: Yes, Diane.

4 MS. JAKOBS: So I’m looking ahead at the 

5 graphs, but –

6 MR. LEKOV: Which one? The shipments model 

7 results?

8 MS. JAKOBS: Yeah, the historical one, that 

9 looks familiar. And the next one, though – so the 

10 next one, you’re kind of assuming we’re going to go 

11 back to 1992 and just go back on our old trajectory, 

12 which I really wish would happen. So part of your 

13 analysis – you’re so detailed – but are there housing 

14 projections? I mean there are a lot of houses that 

15 have been foreclosed on, and they’re not – no one’s 

16 living there any more. All that -- is a housing stock 

17 expected to go back to where it used to be.

18 MR. LEKOV: So the slides here, the model 

19 explains how we arrived. Those are all those details 

20 of the shipments model that utilize the sources listed 

21 here to arrive at this conclusion.

22 MS. JAKOBS: But you don’t really talk about 

23 how many houses there are that are going to need this 

24 equipment, and that might –

25 MR. LEKOV: No, in fact, that’s an 
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1 accounting which is done exactly this way within the 

2 spreadsheet. That’s published on the DOE website.

3 MR. BROOKMAN: Charlie.

4 MR. STEPHENS: Alex, I can tell by looking 

5 at your graph there and knowing what your furnace 

6 lifetimes are, that there’s something wrong with your 

7 model already because when you see a 50 percent or 

8 nearly 50 percent drop in 2008 shipments, which I 

9 think most of us know was due to housing start 

10 failure, there should be an echo of that about one 

11 furnace lifetime later, and there’s not even a tiny 

12 ripple in your projections out there. All those 

13 houses that didn’t get built, that didn’t get new

14 furnaces, aren’t going to get replacement furnaces 

15 either. So I don’t know where that echo is, but there 

16 should be one there.

17 MR. LEKOV: So this reflects essentially the 

18 AEO’s projection of the new housing start projection. 

19 So this is what it is.

20 MR. STEPHENS: This is all shipments, right?

21 MR. LEKOV: Correct.

22 MR. STEPHENS: Including replacements?

23 MR. LEKOV: Including replacements.

24 MR. STEPHENS: There should be an echo of 

25 what you’re seeing on the left there. If I play out 
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1 your furnace lifetimes, you know, there should be an 

2 echo of that somewhere, and it’s not there. So I 

3 don’t know where your model went wrong.

4 The other thing is that I’ve got a bunch of 

5 houses that are being built for me right now in a 

6 pilot program that aren’t going to use any air 

7 handlers or ducted systems because they’re design 

8 space heating loads are between 12 and 15,000 BTU per 

9 hour. So this is a trend – the codes are going there, 

10 and there aren’t any furnaces, ducted systems that are 

11 small enough for these houses, and so the people who 

12 are building these houses are using other means. And 

13 I think it’s a trend that you need to pay attention 

14 to, because by the time you get out 20 years from 

15 where we are now, which is way less than 20 years from 

16 the time this takes effect, 2018, things will have 

17 moved to the point where, unless we reinvent the air 

18 handler and the furnace, I don’t know that you’re 

19 going to maintain anything that looks like an increase 

20 here.

21 And I don’t – I’m not going to say anything 

22 about AEO, but the fact is that the trends in the 

23 marketplace that we’re seeing, and that in part, my 

24 organization is actually driving, suggests that any 

25 increase out there is probably ill-advised in your 
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1 projections.

2 MR. BROOKMAN: Steve.

3 MR. ROSENSTOCK: Steve Rosenstock, EEI. You 

4 always have to make a projection and I think that I 

5 would say that this numbers look a little ambitious 

6 for a couple of reasons. Number one, the era 

7 especially from 2000 to 2007, was the housing bubble 

8 and new homes were being built at a rate like – single 

9 family homes, about 1.2, 1.4 million per year. And 

10 the latest numbers that I saw in terms of houses built 

11 are about 600,000, and I think that might even include 

12 multi-family as well as single family. And new home 

13 sales, single family home sales were – well, they 

14 jumped up to all of 350,000 on a seasonally adjusted 

15 average. So I don’t know how long it will take. It 

16 might be much more of gradual slope than what’s being 

17 shown here, that there’s going to be some sort of 

18 explosion starting in like 2013 or so. And the 2009, 

19 2010 and even maybe some of the other numbers were 

20 helped by federal tax incentives that disappeared. I 

21 believe they expired at the end of 2011 or 2010, I 

22 can’t remember – no, 2010, that was when the rush was. 

23 They were in effect from 2009 to 2010. So again, 

24 there’s – again, I’m trying to – I know it’s AEO, but 

25 I don’t know what economic factors are going to lead 
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1 to this explosion of shipments back to where it was in 

2 – during the housing bubble. Again, this is just 

3 personal opinion that that I think that rise is going 

4 to be much more gradual than what’s being shown here. 

5 Again, thank you.

6 MR. BROOKMAN: Yes.

7 PARTICIPANT: I think another thing you’re 

8 seeing evidence of here, and that bled over from the 

9 2006 minimum efficiency increases, particularly on the 

10 air conditioning and heat pump side, is that people 

11 chose to repair instead of replace. And I think that 

12 is still an ongoing trend, and as we look at rules 

13 that potentially put into place more expensive 

14 equipment, that trend could possibly continue and 

15 actually be a detriment to seeing increased energy 

16 savings by people being able to afford newer higher 

17 efficiency equipment.

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

19 MR. WAGNER: I would echo that, that you do 

20 see more replacement parts being sold. Also if you 

21 would look at the use of room air conditioners, those 

22 sales have continued to increase. So people are 

23 finding other alternatives to the expensive options of 

24 new equipment.

25 MR. LEKOV: Are there any observations 
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1 regarding heating equipment?

2 MR. WAGNER: The repair, again, they’re 

3 doing what they can to repair.

4 MR. LEKOV: Repair is in essence, a delay.

5 MR. WAGNER: A delay, correct. Replace 

6 components. Parts.

7 MR. BROOKMAN: Okay. Thank you. Yes, Alex.

8 MR. BOESENBERG: Alex Boesenberg, NEMA. For 

9 what it’s worth, there are some comments in the 

10 distribution transformers rulemaking that are very 

11 similar in that the – some of the proposed increased 

12 efficiencies, utilities directly stated they would 

13 repair existing units to old efficiency levels rather 

14 than buy new. So there’s other industries with the 

15 exact same trend, largely owing to the economy and 

16 first price cost – first purchase cost, whatever you 

17 call that.

18 MR. BROOKMAN: We kind of moved very quickly 

19 over the first slide, the precursor slide, the inputs. 

20 If that’s okay, that’s great, and we move to the 

21 graphics. Additional comments on all of those, and 

22 maybe you can keep going, Alex, talk about the line 

23 graph.

24 MR. LEKOV: So basically this is the outcome 

25 of the shipments model. Here shows the baseline –
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1 this is essentially a line from the previous chart, 

2 and shows the standard cases, and as here, ... there is 

3 a, in case of higher cost, we’re seeing a drop in the 

4 purchases, and delay, essentially, which is a little 

5 bit further.

6 MR. BROOKMAN: Yes, Diane.

7 MS. JAKOBS: If you just look at like the 

8 foreseeable – I mean, it starts at 2015, so like 2016, 

9 2017, they’re going to go up at an amazing rate, which 

10 will be good, and then – I wish this was true. I 

11 would echo Steve’s comments. It’s so hard because 

12 it’s been so erratic, and we have – even if you look 

13 at the slide before, we had all this – a whole bunch 

14 of sales, and those furnaces are going to wear out. 

15 So maybe it’s going to be compounded, but just like 

16 this dip is going to be echoed in 15 years, I can see 

17 it’s really hard to make this assumption, and this 

18 seems to be very aggressive.

19 MR. BROOKMAN: Thank you. 

20 MR. LEKOV: So, from here we have the 

21 shipments results. We’re going to calculate the 

22 national impacts, and here are the inputs that go into 

23 the national impact analysis. Annual energy 

24 consumption per unit, this is from the life-cycle cost 

25 analysis. Shipments, from the model just described. 
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1 The equipment stock from uses annual shipments and the 

2 lifetime of the product. And the national annual 

3 energy consumption is essentially a product of the 

4 annual energy consumption and the equipment stock.

5 Here it’s important to say that DOE actually 

6 applied a rebound impact for this product, thus 

7 reducing the economic national economic benefits, and 

8 those came from the – they are based on the 2009 

9 Wisconsin study. They were applied– somewhat 

10 differently to the north and south. And in addition 

11 to this, the national impact analysis using .. source 

12 conversion factors for converting the ... energy 

13 consumption into primary or source energy consumption, 

14 and those are from NEMS (ph)

15 In this case, DOE particularly requests 

16 comments on the values used to characterize the 

17 rebound effect.

18 MR. BROOKMAN: Steve Rosenstock.

19 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

20 Again, I don’t know if I’m sure that study is 

21 available, but in terms of that field study, there was 

22 a state standard requiring ECM furnace fans, is that 

23 what I’m reading?

24 MR. LEKOV: No, it’s based – actually the 

25 study did a targeted replacement of furnace fans with 
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1 – furnaces with PEC to ECM models, and they over a 

2 period of time, they calculated how people are using a 

3 constant ventilation, constant circulation. And they 

4 found that it’s quite significantly more people are 

5 using constant ventilation.

6 MR. ROSENSTOCK: So, but those are replacing 

7 the furnace, not just the furnace fan in those cases, 

8 is that correct? Again, it’s a component system thing 

9 again, because I think that’s going to play a big role 

10 in terms of – my opinion – it’ll play a big role in 

11 the rebound effect.

12 MR. LEKOV: My understanding is they’re 

13 replacing the entire equipment.

14 MR. ROSENSTOCK: The entire furnace, okay. 

15 Two comments. Again, we’re just looking at this 

16 component. I’d be very surprised to see rebound 

17 effects that high because you have the same furnace. 

18 If and some – you’re just looking at the component, 

19 you’re just replacing the fan, you’re not replacing 

20 the rest of the furnace for some reason, again, just 

21 looking at the fan as a component, because that’s what 

22 this analysis is about, the furnace efficiency is the 

23 same. The thermostat settings are the same. I don’t 

24 see how much of a rebound effect you’re going to get 

25 because in many people’s eyes, you may or may not get 
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1 that much energy savings. You replace a furnace, I 

2 think some of these rebound effects might be available 

3 because, again, people might think oh, I’ve got a much 

4 more efficient furnace, I can raise the thermostat a

5 little bit. So I think if we’re just looking at the 

6 fan, especially I think a 20 percent number might be a 

7 little on the high side. I don’t know about the 10 

8 percent, but, and again, but if you’re assuming –

9 again, just for the fan, those numbers might be high, 

10 but if it’s the whole furnace, 20 percent might still 

11 be a little on the high side, but again, that’s just 

12 my thoughts on that. Again, it’s all a matter of how 

13 we’re looking at this analysis.

14 MR. BROOKMAN: Mohammed.

15 MR. KHAN: Mohammed Khan, DOE. I just want 

16 to point out that if you’re in the constant 

17 circulation mode, only, so you’re just running the fan 

18 that’s in the furnace or AC unit or air handler, 

19 whatever you want to call it, you’re not heating or 

20 cooling. You’re just moving air. So I would think it 

21 wouldn’t matter.

22 MR. BROOKMAN: Charlie Stephens.

23 MR. STEPHENS: Charlie Stephens. I 

24 mentioned this earlier and I don’t want to go into it 

25 in great depth, we’re running late, but you’re not 
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1 just moving air. You’re filtering air. And you’re 

2 going to say in a lot of cases I don’t know whether 

3 there’s a correlation or a causation here. I don’t 

4 know. I’m not convinced that people are doing this 

5 because they bought an ECM equipped furnace, or 

6 because the contractor sold them a great electronic 

7 filter system and promised them really good indoor air 

8 quality if only they added another $500 bucks to the 

9 job, and I don’t know whether it mattered what kind of 

10 furnace they put in or not. But I know that every 

11 time I’ve had interaction with these contractors and 

12 people who have, there has been an attempt to upsell a 

13 filtration system, and it almost always comes with 

14 circulation attached. And the other piece is 

15 ventilation. There is ventilation going on here, and 

16 they are sometimes using this in a ducted system. 

17 They’re using the air handler to distribute the fresh 

18 air that they bring in on the return side.

19 So that’s a trend and you can’t ignore these 

20 things because they’re going on. But I don’t think 

21 you can attribute it as rebound effect to the choice 

22 of an ECM motor. If you require ventilation because 

23 the code says you have to have ventilation and you 

24 choose this inlet fresh air to do it, it doesn’t 

25 matter what furnace you picked, or what the motor is, 
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1 you’re going to have to run it so many hours a day, 

2 regardless of what’s in there. So then you save a 

3 little energy if you pick the more efficient fan. 

4 But, you know, the fact is, to really apply 

5 rebound effect, there has to be a cause and effect, 

6 and I’m not convinced that these things are related. 

7 The choice of an ECM motor results in more circulation 

8 time.

9 MR. BROOKMAN: Diane.

10 MS. JAKOBS: I read this paper a long time 

11 ago, and I’m from Chicago, and I’m close to Wisconsin. 

12 But my impression from reading it was more that during

13 the shoulder months, that people open the window and 

14 run their circulation fan to distribute the air. So 

15 it’s not necessarily a filtering, that it was just to 

16 distribute the air within the house. And it seemed 

17 like it was a pretty good study, that there was a 

18 significant reason for where they went from PSC to 

19 ECM, and it seemed like a good study.

20 MR. BROOKMAN: Okay. Thank you. 

21 MR. LEKOV: So, here is an illustration of 

22 how the ECM market share, in the absence of standards, 

23 was calculated. It reflects the two, the ten percent 

24 and the 30 percent point, and 45 percent in 2018.

25 MR. BROOKMAN: Go ahead, Diane.
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1 MS. JAKOBS: So in your curve there, I would 

2 go back down to 15 percent in 2011, and see what that 

3 does to your curve. It would probably make it go way 

4 up, right. But – there was a significant event when 

5 the tax rebates ended.

6 MR. LEKOV: So more data points would be 

7 appreciated.

8 MR. BROOKMAN: Okay. Thank you. 

9 National Energy Savings and Net Present Value

10 MR. LEKOV: So, I’ll go directly to the –

11 those are the national energy savings for the product 

12 classes based on the preliminary analysis. 

13 MR. BROOKMAN: Joanna.

14 MS. MAUER: Joanna Mauer. In the TSD there 

15 is some discussion of double counting of cooling 

16 savings. Is that relevant to the scope that’s 

17 included in the preliminary analysis, the issue of 

18 potential double counting of energy savings?

19 MR. LEKOV: The scope was discussed this 

20 morning, and the equipment that includes -- some 

21 furnace fan equipment is not considered in this 

22 rulemaking, and it was listed on one of the first 

23 slides this morning.

24 MS. MAUER: And is that equipment that’s 

25 excluded where potential issue of double counting 
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1 would come in, not for the equipment that has been 

2 included in the scope.

3 MR. BROOKMAN: Let’s hear from Sam Jasinski.

4 MR. JASINSKI: So one of the key product 

5 classes, weatherized gas furnaces, actually includes 

6 the central air conditioner component, so it does have 

7 a SEER rating, so that one would be subject to the CAC 

8 rulemaking, and that is where – an example of where 

9 this double counting may occur, and has to be 

10 considered in the energy savings.

11 MR. BROOKMAN: So for those of us that don’t 

12 know, what is double jumping?

13 MR. JASINSKI: Double counting is –

14 MR. BROOKMAN: Oh, double counting. 

15 MR. JASINSKI: Yes. Essentially the SEER 

16 rating used for CAC and heat pump products does 

17 consider the fan electricity consumption to a certain 

18 degree, so Alex can explain in more detail, but 

19 measures were taken to be sure that any savings 

20 attributable to the SEER standard would not double 

21 counted in these numbers.

22 MR. BROOKMAN: Got you. Okay. I obviously 

23 mis-heard the term. Okay. Other – so there’s a lot 

24 of content here in these two slides. Comments on what 

25 you see here. 
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1 MR. LEKOV: So those are the results on the 

2 national energy savings and the net present value. 

3 They are listed in the technical support document 

4 also.

5 MR. ROSENSTOCK: And Doug, just real quick. 

6 This is Steve Rosenstock, EEI. This is 2018 to 2048?

7 MR. LEKOV: Correct.

8 MR. ROSENSTOCK: Thank you. 

9 MR. BROOKMAN: Thank you, Steve. Greg.

10 MR. WAGNER: So if I’m reading this right, I 

11 look at column three and four, going from an X13 to an 

12 ECM, we save less energy?

13 MR. LEKOV: Over the analysis period, 

14 depending on the product class. So looking at the 

15 three and four, X13 versus ECM, product classes are 

16 listed on the left side, you compare the values next 

17 to each other.

18 MR. WAGNER: This is energy savings in 

19 quads?

20 MR. LEKOV: Correct.

21 MR. WAGNER: I guess I’m –

22 MR. BROOKMAN: Dave.

23 MR. WINNINGHAM: I think this points to a 

24 disconnect back to our summary results page, where 

25 earlier we had shown the EL levels and the approximate 
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1 savings for X13 of 45 percent, and 59 percent for the 

2 ECM, where your results page showed for non3 weatherized, non-condensing showed a 35 percent 

4 savings for X13, and only a 33 percent savings for ECM 

5 plus multi-stage. So, I guess I am very concerned 

6 that the EL levels shown as a percentage don’t align 

7 with the data that has been presented. They have 

8 taken them to the extreme edge of a single category.

9 MR. WAGNER: And this is Greg. And the same 

10 thing holds for the next column, column four to column 

11 five. That’s nowhere near that ten percent level that 

12 was talked about earlier for that technology. So how 

13 did that go from ten to 30? Or 50 on say, NWGC?

14 MR. LEKOV: For which product class?

15 MR. WAGNER: Non-weatherized gas condensing, 

16 column four to column five. It’s about 50 percent 

17 jump.

18 MR. LEKOV: Between the ECM and the ECM with 

19 backward impeller?

20 MR. WAGNER: Yeah. I’m guessing, and I 

21 don’t know how these were derived, but there’s some 

22 kind of glitch in this modeling? These numbers don’t 

23 match up with those EL levels that Dave was just 

24 talking about.

25 MR. BROOKMAN: Okay. While he’s searching 
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1 there, Jim Vershaw, you’re next.

2 MR. VERSHAW: Okay. Jim Vershaw, Ingersoll 

3 Rand. Based on the conversation on the projected 

4 shipments, doesn’t discussion about these numbers 

5 become mute? If those numbers were wrong, doesn’t it 

6 change all these numbers?

7 MR. BROOKMAN: Jim, several individuals in 

8 the room are nodding their heads in sympathy. So 

9 thank you for the comment.

10 MR. VERSHAW: And -- okay. 

11 MR. BROOKMAN: Additional thoughts or 

12 comments on these two very busy tables? Nothing 

13 additional? Okay. Yes. Diane.

14 MS. JAKOBS: So this table – is it saying 

15 that –

16 MR. BROOKMAN: Which one, Diane?

17 MS. JAKOBS: I’m sorry, net present value 

18 results. If the interest rates go up to seven percent 

19 from current three percent that the savings will be 

20 negative?

21 MR. LEKOV: So remember that one-year change 

22 in the interest rate is not going to impact the 

23 distributions for the interest rate is over a 20 year 

24 period.

25 MR. ECKMAN: This is just the discounting of 
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1 the values, right, according to federal requirements, 

2 either three or seven, so you’re just following OEM –

3 OMB. Get the right.

4 MR. BROOKMAN: Tom, state it again.

5 MR. LEKOV: Talking here about the discount 

6 rates?

7 MR. ECKMAN: Yeah.

8 MR. LEKOV: Okay. Yeah, those usually DOE 

9 presents two cases at three and seven percent. That’s 

10 just the options here. And both of them are used when 

11 a selection is made, when the potential standard 

12 levels are considered, both of those values are used.

13 MS. JAKOBS: So does negative mean you’re 

14 not saving money?

15 MR. LEKOV: Correct.

16 MR. BROOKMAN: And Greg, go ahead.

17 MR. WAGNER: And these are based upon the 

18 previous slide, the quads saved and the projected 

19 increase in sales combined?

20 MR. LEKOV: It’s not the savings, it’s the 

21 economic impact nationally, on all consumers.

22 MR. WAGNER: Okay. We’re going to be going 

23 back and revisiting these things, looking at those 

24 growth rates, as well as the projected numbers?

25 MR. LEKOV: No, those three and seven 
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1 percent –

2 MR. WAGNER: No, not the discount rates, 

3 those are the numbers you use. But the other 

4 projection numbers, is this going to be rerun? Taking 

5 a look at these anomalies that are going on here?

6 MR. LEKOV: So DOE will utilize all and any 

7 inputs that -- we’ll consider all and any inputs that 

8 are coming from the interested parties.

9 MR. BROOKMAN: Yes, Paul.

10 MR. LIN: Paul Lin. I just want to clarify 

11 slide 105, page 105, your subsection of ECM market 

12 share. That is assuming that there is no, just 

13 natural progressing in the market, that there is no 

14 mandate to move towards an ECM, correct?

15 MR. LEKOV: That’s the base case, correct.

16 MR. BROOKMAN: Yes, Tom.

17 MR. ECKMAN: Not to add a lot of work, but I 

18 think part of the confusion in folks’ mind as we go 

19 through this is that we have a rolling up of multiple 

20 cases here that is strongly influenced by the location 

21 of the equipment, and by the association of that 

22 equipment with these product classes. So some are 

23 cooling, some are heating and cooling, and some are 

24 just primarily heating. And so the benefits are 

25 different by candidate standard level based on whether 
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1 it’s a cooling piece of equipment or a non-cooling 

2 piece of equipment. And so these can look really 

3 weird when you see a summary because the population 

4 behind each one of those is really different.

5 So it may be useful if we see some of the 

6 geographic distributions. So we know that this is 

7 representing the south and the southwest. This is 

8 representing the north and the north – because when 

9 you look at these, they don’t make a lot of sense 

10 intuitively because you’re getting these weights 

11 together, and the population is migrating to the south 

12 and the southwest where there’s more cooling, so the 

13 benefits for cooling get larger for some technologies 

14 than for others. So I’m just – it’s kind of a mind 

15 warp to look at this and make intuitive sense out of 

16 it when you know that the impacts are different by 

17 candidate standard level because they have either 

18 larger cooling benefits than their adjoining 

19 companion.

20 MR. LEKOV: In the past, DOE responded to 

21 interested parties request for such scenario.

22 MR. ECKMAN: Yeah, I’m not so much 

23 interested in scenarios, but seeing some of the 

24 derivation of the – the precursor tables before these 

25 that show – that can tell us that this is a product 
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1 that has really – its location is in the cooling 

2 climates. We had that one table where we had 

3 condensing, non-condensing, but this is just a 

4 manifestation of that, where you could look at it side 

5 by side, and some of these are bigger than the 

6 adjoining number – gets larger because it’s in a 

7 cooling climate than the preceding candidate standard 

8 level which should be more efficient, but they’re –

9 I’m not being real clear here but –

10 MR. LEKOV: No, I understand.

11 MR. ECKMAN: It’s just hard to – the 

12 generalization that the national level makes less 

13 sense than it does at the regional level.

14 MR. BROOKMAN: Right. Okay.

15 MR. LEKOV: But on the other hand also, just 

16 remember that there is no original standard for 

17 furnace fan products. So the results need to be 

18 presented also as a whole. What you’re asking is for 

19 more information –

20 MR. ECKMAN: Just in order to interpret 

21 them, seeing the sub-national level gives – it’s 

22 easier to grasp what I’m looking at because I know 

23 there’s a difference in technology here.

24 MR. BROOKMAN: Let’s move on.

25 MR. LEKOV: So, this is an additional point, 
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1 relating to some analysis that DOE performed. In

2 2011, DOE published a notice of policy stating 

3 intention to incorporate full fuel cycle metric into 

4 the cost benefits analysis. In essence, an additional 

5 multiplier or conversion factor is applied to the 

6 energy savings associated with either primary fuels 

7 used by the product and for these particular products, 

8 this methodology was applied, and results similar to 

9 these previous two tables that you saw, but including 

10 the full fuel cycle of impacts are presented in the 

11 technical support document.

12 MR. ROSENSTOCK: Comment?

13 MR. BROOKMAN: Please, Steve.

14 MR. ROSENSTOCK: Steve Rosenstock, Edison 

15 Electric Institute. We will make written comments, 

16 but we’re very – we think that there are significant 

17 problems with doing the full fuel cycle analysis. The 

18 numbers shown in the technical support document refer 

19 to a paper that was published elsewhere, so there was 

20 the methodology and the results, but there is no 

21 information about the actual derivation of the values 

22 shown in the table. And I think there are special 

23 issues when you’re looking at the full fuel cycle, you 

24 really have to go international for any, especially 

25 for fuel oil, and I believe that there is just quite a 
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1 huge variation in terms if you’re looking upstream in 

2 terms of the energy use with energy production, 

3 especially for fuel oil, that could be understated. 

4 And on the electric side, it’s overstated. So I think 

5 there are issues with using it. We objected before. 

6 We maintain our objections and we will write and file 

7 written comments. Thank you. 

8 MR. BROOKMAN: Okay. Thank you. We’re 

9 going to move on.

10 MR. LEKOV: So comments on the full fuel 

11 cycle and DOE invites comments and recommendations on 

12 any aspect of national impact analysis. Go ahead, 

13 Sam.

14 MR. BROOKMAN: So now back to Sam Jasinski.

15 Manufacturer Impact Analysis

16 MR. JASINSKI: Thank you Alex, thank you

17 Doug. I will give a brief overview of the preliminary 

18 manufacturer impact analysis. As I mentioned earlier, 

19 the bulk of the manufacturer impact analysis is 

20 actually conducted during the Notice of Proposed 

21 Rulemaking. But during the preliminary analysis 

22 activities, DOE makes an effort to set the stage for 

23 the analysis in the NOPR by basically starting to put 

24 together an industry overview and also identify key 

25 issues. Here’s the “you are here” slide, to show you 
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1 where it falls within the grand scope of the 

2 rulemaking. 

3 During the preliminary manufacturer impact 

4 analysis, DOE identified 11 small business 

5 manufacturers associated with these products. As I 

6 mentioned earlier, if there are others that aren’t 

7 identified in the – in Chapter 3 of the TSD, please 

8 let DOE know. Also as part of the preliminary 

9 manufacturer impact analysis, DOE conducted onsite and 

10 telephone interviews, not on the scale that it will 

11 during the Notice of Proposed Rulemaking, but again, 

12 as part of the preliminary activities. We did have 

13 the pleasure of receiving some feedback from 

14 manufacturers during preliminary interviews. 

15 The interview topics included the 

16 engineering analysis, overview, methodology, and 

17 results. Key issues as identified and defined by the 

18 manufacturer, current market conditions, such as 

19 shipment, market share, product mix, et cetera. 

20 Potential impacts of new energy conservation 

21 standards, especially with a focus on potential 

22 conversion costs, and then finally, a discussion about 

23 cumulative regulatory burdens. As we’ve heard, there 

24 are a lot of state, federal, and international 

25 standards, as well as some voluntary programs that –
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1 regarding the efficiency of furnace fan products.

2 Some of the key issues that were identified 

3 during these interactions with manufacturers -

4 preliminary interactions with manufacturers: 

5 • higher up-front costs for consumers. 

6 Manufacturers are concerned that higher initial 

7 cost can lead to consumer switching to less 

8 efficient products, essentially by making a 

9 component more expensive, in higher efficiency 

10 products, the overall – consumers will switch to 

11 systems that are overall less efficient, to reach 

12 lower price points, or the same price point that 

13 they would have prior to standards.

14 • Secondly, higher initial cost may also push 

15 consumers to repair, as we’ve heard, rather than 

16 replace units.

17 • Another key issue are conversion costs. 

18 Stringent standards may require significant 

19 capital conversion costs to implement the 

20 technologies that we’ve identified, to reach the 

21 higher efficiency levels.

22 • And finally, reduction in innovation. 

23 Manufacturers are concerned that a new furnace 

24 fan standard would take resources away from 
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1 development of new products and in addition, 

2 higher standards for furnace fans place new 

3 constraints on manufacturers and may limit their 

4 options for maximizing maximum system efficiency, 

5 essentially resources are finite for 

6 manufactures, and the more targets you give them, 

7 the more it takes away – it adds constraints they 

8 have to focus those resources on meeting those 

9 specific standards as opposed to focusing on 

10 innovation on overall systems.

11 MR. BROOKMAN: Many of you are familiar with 

12 manufacturer impact analysis or preliminary 

13 manufacturer impact analysis. Comments on those 

14 before we move on. Yes, Paul.

15 MR. LIN: Paul Lin with Regal Beloit. Just 

16 to maybe touch on some earlier comments from Diane 

17 relative to cost of AC of the X13 motor being two 

18 times of what you guys are showing here in the 

19 preliminary analysis. I wish we were – maybe we need 

20 to adjust our pricing to Rheem when we go back, but I 

21 think maybe the bigger issue is maybe some comments 

22 could be given from Navigant and DOE on this report in 

23 terms of the product mix. Because I think the product 

24 mix has a large deal in coming up with an average X13 

25 cost. A higher horsepower will have a lot higher cost 
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1 versus – so we have a third, a half, three-quarter, 

2 and one horsepower. So if you look at a model by 

3 model basis from a third horsepower to a one 

4 horsepower, there is significant cost delta between 

5 that. So, depending on your mix analysis on getting 

6 together an average product cost, that’s the 

7 assumption. What is the assumption on your horsepower 

8 range to come up with your average cost? I think 

9 that’s maybe some of the discrepancy that the OEMs may 

10 see relative to the costs that you have in your 

11 analysis.

12 MR. BROOKMAN: Mohammed.

13 MR. KHAN: This is Mohammed Khan, DOE. We 

14 try to make our samples as statistically 

15 representative as possible. And I’m not really sure 

16 how many samples were really used, but maybe Sam could 

17 comment on that.

18 MR. JASINSKI: Yes, so for this particular 

19 rulemaking activity, as I said earlier, we had 26 

20 units selected for test and tear down. But because 

21 there are a lot of similarities with previously 

22 regulated and products that are being currently 

23 regulated where similar analyses have been done, we do 

24 have data beyond those 26 units, and I’ll call them 

25 cost factors that you mention, are something that we 
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1 tried to account for in the analysis. So when we do 

2 the tear downs and select products across what’s 

3 commercially available, capacity and horsepower, 

4 things of that nature are taken into consideration so 

5 that we can try to understand how the cost of, for 

6 instance, a motor, would scale with horsepower.

7 MR. BROOKMAN: Is that mix listed in the 

8 TSD?

9 MR. JASINSKI: No, we try to prevent – keep 

10 details about the selections protected so that it’s 

11 hard to disaggregate the results.

12 MR. BROOKMAN: Diane.

13 MS. JAKOBS: This kind of goes back to the 

14 test procedure, but in the NOPR for the test 

15 procedure, you came up with four hours for an average 

16 testing time to calculate FER. And in my personal 

17 experience now running it, that’s correct. Only you 

18 went on to say that wasn’t a burden, and that would be 

19 horrible for us. So, I don’t know, we might – it’s a 

20 huge impact to double the amount of testing we have to 

21 do. And you’ve seen our air flow test stands, and –

22 but just in the analysis you went through something 

23 and said it was two and a half percent of the sales 

24 price or something, but for a manufacturer impact, 

25 just the amount of test time that’s required, is a big 
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1 deal for us, and that’s kind of reflected in our 

2 participation.

3 MR. BROOKMAN: So send those details in. 

4 Yes?

5 MR. JASINSKI: Yes, absolutely. Information 

6 that would help DOE quantify the burden in terms of 

7 hours to test or the equipment necessary –

8 MS. JAKOBS: So that would be like an 

9 increase in R&D test time. I have trouble quantifying 

10 that.

11 MR. JASINSKI: Well, just number of hours, 

12 things like that, help.

13 MS. JAKOBS: Well, I can say I agree with 

14 you on the hours, just does it give me heart 

15 palpitations or not. But it’s also – we have to – we 

16 verify our ratings every year, so it’s not just when 

17 you design the equipment and release it, it’s ongoing 

18 cost that will go on forever, so it’s a big deal for 

19 us at four hours.

20 MR. BROOKMAN: Okay. We’ve also heard from 

21 Terry Small. Terry, you’re next, and then Steve 

22 Rosenstock.

23 MR. SMALL: Terry Small, Mortex. I know on 

24 one of the pages there’s a discussion on the PSC 

25 market and eliminating it. I think that the forecast 
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1 is pretty optimistic, the paybacks are optimistic, and 

2 the payback on going to the PSC motor, the improved 

3 motor with an additional speed or two for continuous 

4 air flow to really get what Charlie wants, means to me 

5 that I think we ought to be careful not to eliminate 

6 PSC motors in general. I think that would be a great 

7 mistake for the country. It’s my opinion. Thank you. 

8 MR. BROOKMAN: Thank you. Okay. Steve.

9 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

10 Again, in terms of the up front cost for consumers, 

11 just to kind of follow up with what Alex said, if 

12 there’s a space, it might not be a bad idea to kind of 

13 describe what happens, especially in the northern 

14 region of the US, combination of the higher furnace 

15 system standard AFUE in the north, plus the highest 

16 furnace fan standard. Because for new furnaces, the 

17 consumer’s going to face the cost increase due to 

18 both. And the higher the percentage, the higher the 

19 likelihood of possible people trying to repair rather 

20 than replace. Thank you. 

21 MR. BROOKMAN: Thank you. Okay. Additional 

22 comments on this?

23 MR. JASINSKI: So the presentation as it’s 

24 posted in the packet includes some slides that 

25 describe the next steps. Each is generally just an 
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1 overview.

2 MR. BROOKMAN: Paul.

3 MR. LIN: Paul Lin. Is there a target date 

4 that you’re targeting to release the NOPR?

5 MR. JASINSKI: The NOPR? It’s hard to say. 

6 The statutory deadline is 2013, so it’s going to be 

7 between now and then, I think. 

8 MR. LIN: That’s a forecast we can believe.

9 MR. JASINSKI: Yeah.

10 MR. BROOKMAN: Yes, Aniruddh.

11 MR. ROY: I have a comment with regards to 

12 what was said earlier on the components and system 

13 level efficiencies. Is DOE planning to do any kind of 

14 study on furnaces, for example, let’s say there’s a 

15 high efficiency AFUE furnace that may not be as 

16 efficient on the furnace fan side versus something 

17 that’s very efficient on the furnace fan side but 

18 maybe not as high in AFUE, and combining that with the 

19 full fuel cycle analysis that you are referring to, is 

20 there any plans to do that kind of study in the 

21 future?

22 MR. JASINSKI: Well, a specific study, I 

23 don’t know about a targeted study, but hopefully as 

24 we’ve shown throughout the analysis, it is something

25 that DOE is concerned with. So any information that 
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1 we can get through comments, and obviously through our 

2 own efforts, we will constantly keep that in 

3 consideration to make sure that if at all possible, 

4 what we are doing does not negatively impact overall 

5 system efficiency.

6 MR. ROY: Okay. But currently there’s no 

7 data available to show that, right, that comparison?

8 MR. JASINSKI: I’m not going to say that 

9 there’s no data, but we need more –

10 MR. ROY: I mean in the TSD.

11 MR. JASINSKI: Oh, in the TSD, there is no 

12 data presented in the TSD along those lines.

13 MR. ROY: Thank you.

14 MR. BROOKMAN: So we’ve covered all the 

15 material that we came here to cover, and I want to 

16 thank everyone and also at this point, provide an

17 opportunity for any final comments from anybody in the 

18 room, things that didn’t get covered adequately, final 

19 remarks. Yes, Craig.

20 Closing Remarks

21 MR. MESSMER: Craig Messmer, I don’t really 

22 have any remarks other than thank you. And, you know, 

23 if we ever have a question on clarification on what 

24 we’ve read here, is it possible for us to contact 

25 someone and have some sort of discussion, sidebar or 
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1 something, because, you know, we covered a lot of 

2 topics here and I don’t think we covered them 

3 adequately and had enough of an exchange between the 

4 manufacturers and the DOE in this case. So is there 

5 another method of talking to you about it?

6 MR. BROOKMAN: Michael Kido.

7 MR. KIDO: There’s a – you can have an ex 

8 parte communication with the Agency. There’s actually 

9 a process that you can follow in doing that, and if 

10 you give me your e-mail, I can just e-mail to you, 

11 there’s a Federal Register notice that outlines the 

12 process, and it’s a very short notice. So basically 

13 what that would entail is, you know, there’s a meeting 

14 between, say, company X and DOE, and then there’s a 

15 certain amount of time that has to – well, within a 

16 certain amount of time you have to submit a memo to 

17 very specific e-mail address that handles all the ex 

18 parte communications between the Agency and outside 

19 parties. And that memo essentially just briefly 

20 summarizes the nature of the discussion. And that’s 

21 just to insure that there’s transparency in the whole 

22 process. Everyone knows who DOE has met with and what 

23 was discussed. So if you want, I can send you that, 

24 and if anyone else wants that, just give me your e25 mail address and I’ll e-mail it out to you.
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1 MR. KHAN: Mohammed Khan, DOE. I think your 

2 question was whether or not you could hear directly 

3 from DOE as follow on about maybe any further 

4 interpretation about any of the technical information 

5 that was provided, you can certainly do – go through 

6 the process that Michael Kido has talked about 

7 already. You can certainly contact me directly, and 

8 depending on the questions, it may be something I may 

9 not be able to respond to from the DOE perspective, 

10 process wise, but it might also be something that we 

11 can have a discussion on. So it really depends on 

12 what the nature is.

13 MR. MESSMER: Okay. Good. That’s what I 

14 wanted to hear. Thank you. 

15 MR. BROOKMAN: Yes, Paul and then Aniruddh, 

16 and then I will also hand out these evaluation forms. 

17 You can pass them down. Paul.

18 MR. LIN: Could we ask an advocate directly, 

19 questions, or is it – or do we have to follow the 

20 process for whether it would be Navigant versus DOE?

21 MR. BROOKMAN: Michael.

22 MR. KIDO: If it’s purely a technical 

23 question, you just say, for example, you’ve got a 

24 question about the formula or the basis for the 

25 analysis that we’ve got in the TSD, something like 
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1 that, you can contact Navigant directly. If it’s an 

2 issue regarding policy like for example, you know, 

3 you guys really should do this versus that, then 

4 you’re probably going to want to have a discussion 

5 with us, and then that will have to be a discussion 

6 that’ll be subject to the ex parte requirements. 

7 MR. BROOKMAN: Other remarks here as we 

8 close? Diane.

9 MS. JAKOBS: I’ve got a lot to say and I 

10 really enjoyed this discussion today. It’s fun to talk 

11 to a lot of smart people about an important subject 

12 and I’m really encouraged. But I’m also chairman of 

13 the AHRI ad hoc furnace fan committee, and there’s so 

14 many things that we’re supposed to submit comments on, 

15 is there any – I don’t know if someone could give me a 

16 hint maybe about a priority things where – you know, 

17 it seemed like you said that the X13 curve on the 

18 graph was based on one furnace, maybe you need more 

19 furnaces. And then we were talking about the drop in 

20 sales in ECM motors. Aniruddh said that we could look 

21 at sales, that that’s information that maybe AHRI 

22 collects. So if there’s some particular question you 

23 want to make sure that we don’t miss as our time runs 

24 out, you know, please let me know somehow. Thank you. 

25 MR. BROOKMAN: Thank you. Aniruddh.
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1 MR. ROY: As Diane mentioned, again Aniruddh 

2 Roy. Under AHRI, as Diane mentioned we have an ad hoc 

3 committee that has developed some modifications to the 

4 existing or the proposed FER metric, and we will be 

submitting that in our comments on July 30th 5 . However, 

6 it’s just a series of steps that’s proposing the 

7 modifications, it’s not the actual test procedure with 

8 edits in it. We are going to be starting to work on 

9 that as well as we will be providing data sometime in 

10 August to DOE to support our arguments. And we feel 

11 that the modified FER metric is – it’s significantly 

12 less burdensome in form of testing, as well as 

13 reporting to the manufacturers. But not only that, it 

14 also meets DOE’s goals from the preliminary analysis 

15 that’s occurred, it looks like the FER and the 

16 modified FER values are almost the same. And so I 

17 think that’s something that DOE and other stakeholders 

18 will be happy with. So please look out for those 

19 comments, and we can discuss it after DOE has reviewed 

20 it.

21 MR. BROOKMAN: Additional remarks? Tom.

22 MR. ECKMAN: Again, I want to thank DOE and 

23 the contractors for spelling things out. I have one 

24 comment on the utility impact analysis which we went 

25 by briefly. I understand its purpose. I would ask 
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1 that DOE in the outputs also specify what the present 

2 value cost reductions might be from the reduction in 

3 capacity required to meet the standards. Right now as 

4 change in energy sales and prices, the mix of 

5 generation, and the difference in capacity, there’s a 

6 dollar value associated with the difference in 

7 capacity, and I think that should be incorporated in 

8 the analysis.

9 MR. BROOKMAN: Thank you. Steve Rosenstock.

10 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

11 Following up on that, since certain standards will 

12 increase the amount of furnace energy use, the fossil 

13 fuel use, then in terms of energy production, then if 

14 there’s any increases on the production needed for 

15 fossil fuels, that that should be accounted for as 

16 well. Thank you. .

17 MR. BROOKMAN: Thank you. Other remarks 

18 here as we move towards closure? So then, for my 

19 part, I thank you. We had a very productive meeting. 

20 We covered a tremendous amount of material. You all 

21 were very forthcoming with a lot of very, very good 

22 information. I appreciate your good humor and your 

23 tenacity. I really do. I turn it back to Mohammed 

24 Khan for closing remarks.

25 Closing Remarks from DOE
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1 MR. KHAN: Mohammed Khan, DOE. Very briefly 

2 because we went over our scheduled time, and I 

3 apologize for that. But this morning I said I looked 

4 forward to a very good discussion exchange, and I 

5 think my expectations were exceeded. So I appreciate 

6 everyone’s participation and we look forward to 

7 getting your written comments as well. Thank you. 

8 MR. BROOKMAN: Safe travels home.

9 (Whereupon, at 4:30 p.m., the meeting in the 

10 above captioned matter was adjourned.) 

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REPORTER'S CERTIFICATE

This is to certify that the attached proceedings 

before:

U.S. DEPARTMENT OF ENERGY

In the Matter of:

PRELIMINARY ANALYSIS PUBLIC MEETING ON 

RESIDENTIAL FURNACE FANS ENERGY CONSERVATION STANDARDS

Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law Judge 

or the Agency.

Further, I am neither counsel for or related to any 

party to the above proceedings.

Wendy Greene 

 Official Reporter

Dated: August 1, 2012