Energy Conservation Standards 

Rulemaking Framework Document for 

Ceiling Fans and Ceiling Fan Light Kits
 

RIN: 1904-AC87
 

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

March 8, 2013 
TABLE OF CONTENTS
 

1 INTRODUCTION .................................................................................................................. 1
 

1.1 History of Ceiling Fan and Ceiling Fan Light Kit Standards and Authority ................... 2
 

2 SCOPE OF COVERAGE ....................................................................................................... 3
 

2.1 Ceiling Fans...................................................................................................................... 3
 

2.1.1 Definitions Related to Ceiling Fans.......................................................................... 5
 

2.1.1.1 Definition of “Hugger Fan”............................................................................... 6
 

2.1.1.2 Definition of “Standard Ceiling Fan” and “Multi-Mount Fan” ......................... 7
 

2.1.1.3 Definition of “Highly Decorative Fan” ............................................................. 7
 

2.1.1.4 Definition of “Outdoor Fan”.............................................................................. 9
 

2.2 Ceiling Fan Light Kits...................................................................................................... 9
 

3 Overview of the Rulemaking Process ..................................................................................... 9
 

3.1 Rulemaking Process and Participation of Interested Parties ............................................ 9
 

3.2 Preliminary Analysis ...................................................................................................... 11
 

3.3 Notices of Proposed Rulemaking ................................................................................... 13
 

3.4 Final Rule ....................................................................................................................... 14
 

4 TEST PROCEDURES AND REGULATORY METRICS .................................................. 14
 

4.1 Test Procedures .............................................................................................................. 14
 

4.1.1 Modes of Operation for Ceiling Fans and Ceiling Fan Light Kits ......................... 15
 

4.1.2 Preliminary Discussion of Test Procedures ............................................................ 16
 

4.1.2.1 Ceiling Fans..................................................................................................... 16
 

4.1.2.2 Ceiling Fan Light Kits ..................................................................................... 27
 

5 OVERVIEW OF ANALYSES FOR ENERGY CONSERVATION STANDARDS 

RULEMAKING............................................................................................................................ 31
 

6 MARKET AND TECHNOLOGY ASSESSMENT ............................................................. 34
 

6.1 Market Assessment ........................................................................................................ 34
 

6.1.1 Manufacturer Trade Group ..................................................................................... 35
 

6.1.2 Manufacturers and Market Shares .......................................................................... 35
 

6.1.2.1 Retailers........................................................................................................... 36
 

6.1.2.2 Major Manufacturers ....................................................................................... 37
 

6.1.2.3 Historical Shipments........................................................................................ 41
 

6.1.2.4 Saturation......................................................................................................... 44
 

6.1.2.5 Product Lifetime .............................................................................................. 46
 

6.1.3 Product Classes ....................................................................................................... 46
 

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6.1.3.1 Ceiling Fans..................................................................................................... 46
 

6.1.3.2 Ceiling Fan Light Kits ..................................................................................... 49
 

6.2 Technology Assessment ................................................................................................. 50
 

6.2.1 Improving Ceiling Fan Efficiency .......................................................................... 51
 

6.2.1.1 Motors.............................................................................................................. 52
 

6.2.1.2 Number of Blades ............................................................................................ 54
 

6.2.1.3 Blade Design.................................................................................................... 54
 

6.2.1.4 Blade Span....................................................................................................... 55
 

6.2.1.5 Occupancy Sensors.......................................................................................... 55
 

6.2.1.6 Potential Technology Options for Ceiling Fans .............................................. 56
 

6.2.2 Improving Efficiency of Ceiling Fan Light Kits ..................................................... 56
 

7 SCREENING ANALYSIS ................................................................................................... 57
 

8 ENGINEERING ANALYSIS............................................................................................... 58
 

8.1 Overview ........................................................................................................................ 59
 

8.2 Baseline Models ............................................................................................................. 60
 

8.3 Efficiency Levels............................................................................................................ 61
 

8.4 Cost-Efficiency Relationship and Analysis.................................................................... 62
 

8.5 Proprietary Designs ........................................................................................................ 64
 

8.6 Other Regulatory Changes Affecting the Engineering Analysis ................................... 64
 

9 MARKUPS ANALYSIS ...................................................................................................... 65
 

9.1 Description of Market Participants and Distribution Channels ..................................... 65
 

9.2 Markup Estimation Using Financial Statements and Regression Analysis ................... 65
 

10 ENERGY USE ANALYSIS................................................................................................. 67
 

11 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES ......................................... 68
 

11.1 Overview .................................................................................................................... 68
 

11.2 Energy Prices.............................................................................................................. 70
 

11.3 Discount Rates............................................................................................................ 71
 

11.4 Installation, Maintenance, and Repair Costs .............................................................. 71
 

11.5 Product Lifetime ......................................................................................................... 72
 

11.6 Energy Efficiency in the Base Case ........................................................................... 72
 

12 SHIPMENTS ANALYSIS.................................................................................................... 73
 

12.1 Base-Case Forecast ..................................................................................................... 73
 

12.2 Impacts of Standards on Ceiling Fan and Ceiling Fan Light Kit Shipments ............. 74
 

13 NATIONAL IMPACT ANALYSIS ..................................................................................... 74
 

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13.1 Projected Efficiency Trends ....................................................................................... 74
 

13.2 National Energy Savings ............................................................................................ 75
 

13.3 Net Present Value of Consumer Savings .................................................................... 76
 

14 CONSUMER SUBGROUP ANALYSIS ............................................................................. 77
 

15 MANUFACTURER IMPACT ANALYSIS......................................................................... 77
 

15.1 Sources of Information for the Manufacturer Impact Analysis .................................. 78
 

15.2 Industry Cash-Flow Analysis ..................................................................................... 79
 

15.3 Manufacturer Subgroup Analysis............................................................................... 79
 

15.4 Competitive Impacts Analysis.................................................................................... 80
 

15.5 Cumulative Regulatory Burden .................................................................................. 80
 

16 EMISSIONS ANALYSIS..................................................................................................... 81
 

17 MONETIZATION OF CO2 AND OTHER EMISSIONS REDUCTIONS .......................... 83
 

18 UTILITY IMPACT ANALYSIS.......................................................................................... 84
 

19 EMPLOYMENT IMPACT ANALYSIS .............................................................................. 84
 

20 REGULATORY IMPACT ANALYSIS............................................................................... 85
 

APPENDIX A – LIST OF ITEMS FOR COMMENT ................................................................. 87
 

APPENDIX B – DRAFT PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

QUESTIONAIRE ......................................................................................................................... 93
 

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LIST OF TABLES 

Table 2-1 Types of Ceiling Fans ................................................................................................6
 

Table 4-1 Energy Conservation Standards and Efficiency Metrics for Ceiling Fan 

Light Kits ...................................................................................................................27
 

Table 6-1 Market Shares of Ceiling Fan Retailers in 2011........................................................37
 

Table 6-2 Market Shares of Ceiling Fan Manufacturers............................................................39
 

Table 6-3 Sample List of ENERGY STAR Partners Manufacturing Version 3.0 

Qualified Ceiling Fans With and Without Light Kits ................................................40
 

Table 6-4 Historical Shipments and Market Shares of ENERGY STAR-Qualified 

Products Only.............................................................................................................42
 

Table 6-5 Historical Shipments of All Ceiling Fans With and Without Light Kits ...................42
 

Table 6-6 Comparison of Historical Shipments of Ceiling Fans from Different Data 

Sources.......................................................................................................................43
 

Table 6-7 Market Share by Blade Span ......................................................................................44
 

Table 6-8 Energy Conservation Standards and Efficiency Metrics for Ceiling Fan 

Light Kits ...................................................................................................................49
 

Table 6-9 Potential Technology Options for Ceiling Fans.........................................................56
 

Table 6-10 Potential Technology Options for Lamp....................................................................57
 

LIST OF FIGURES 

Figure 5-1 Flow Diagram of Analyses Conducted for an Energy Conservation 

Standard Rulemaking .................................................................................................33
 

Figure 6-1 Market Shares of Ceiling Fan Manufacturers in 2011 (NPD, 2011) .........................38
 

Figure 6-2 Market Shares of Ceiling Fans by Blade Span in 2011 .............................................43
 

Figure 6-3 Market Shares of Ceiling Fans by Blade Span for 2007–2011 ..................................44
 

Figure 6-4 U.S. Ceiling Fan Ownership by Region and Average Number of Ceiling 

Fans Per Household ...................................................................................................45
 

Figure 6-5 U.S. Ceiling Fan Usage by Region ............................................................................45
 

Figure 6-6 Depiction of Ceiling Fan System Components That Can be Improved to 

Reduce Energy Consumption ....................................................................................52
 

Figure 9-1 Home Improvement Retailer Distribution Channel for Ceiling Fans and 

Ceiling Fan Light Kits ...............................................................................................65
 

Figure 9-2 Electrical Wholesaler (Distributor) Distribution Channel for Ceiling Fans 

and Ceiling Fan Light Kits.........................................................................................65
 

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LIST OF ACRONYMS 

AC alternating current 

ACEEE American Council for an Energy-Efficient Economy 

AEO Annual Energy Outlook 

ALA American Lighting Association 

ANSI American National Standards Institute 

BLS Bureau of Labor Statistics 

BLDC brushless direct current (motors) 

BOM bill of materials 

BT Building Technologies Program 

CAIR Clean Air Interstate Rule 

CFL compact fluorescent lamp 

CFLK ceiling fan light kit 

CFM cubic feet per minute 

CFR Code of Federal Regulations 

CO2 carbon dioxide 

CRS cold-rolled steel 

CSL candidate standard level 

D.C. District of Columbia 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice 

EGU electricity generating unit 

EIA Energy Information Administration 

EISA 2007 Energy Independence and Security Act of 2007 

EPA U.S. Environmental Protection Agency 

EPACT 2005 Energy Policy Act of 2005 

EPCA Energy Policy and Conservation Act 

ES ENERGY STAR® 

F Fahrenheit 

FFC full-fuel-cycle 

FTC Federal Trade Commission 

FR Federal Register 

GHG greenhouse gas emissions 

GREET Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation 

GRIM Government Regulatory Impact Model 

Hg mercury 

hp horsepower 

HVAC heating, ventilation, and air conditioning 

IEC International Electrotechnical Commission 

IES Illuminating Engineering Society 

ImSET Impact of Sector Energy Technologies 

I-O input-output 

kWh kilowatt hour 

LCC life-cycle cost 

LED light-emitting diode 

v 
 

 

 

 

 

 

 

lm/W lumens per watt 

LMC Lighting Market Characterization 

MDF medium density fibreboard 

MIA manufacturer impact analysis 

MPC manufacturer production cost 

NAICS North American Industry Classification System 

NEMS National Energy Modeling System 

NEMS-BT National Energy Modeling System–Building Technologies 

NES national energy savings 

NESHAPs national emissions standards for hazardous air pollutants 

NIA national impact analysis 

NOPR notice of proposed rulemaking 

NOX oxides of nitrogen 

NPD NPD Group, Inc. 

NPV net present value 

OIRA Office of Information and Regulatory Affairs 

OMB U.S. Office of Management and Budget 

PBP payback period 

PM particulate matter 

RECS Residential Energy Consumption Survey 

RIMS II Regional Input-Output Modeling System II 

RLEUCS Residential Lighting End-Use Consumption Study 

RPM revolutions per minute 

SBA Small Business Administration 

SCC social cost of carbon 

SEC Securities and Exchange Commission 

SG&A selling, general, and administration costs 

SO2 sulfur dioxide 

TSD technical support document 

TSL trial standard level 

U.S.C. United States Code 

W watt 

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1 

RULEMAKING FRAMEWORK DOCUMENT FOR CEILING FANS AND CEILING 

FAN LIGHT KITS 

INTRODUCTION 

The U.S. Department of Energy (DOE) Appliances and Equipment Standards Program, 

within the Office of Energy Efficiency and Renewable Energy’s Building Technologies Program 

(BT), develops and promulgates energy conservation standards and test procedures for certain 

consumer appliances and commercial and industrial equipment. The process for developing 

standards involves analysis, public notice and comment, and consultation with interested parties. 

Interested parties include manufacturers, trade associations, consumers, energy conservation and 

environmental advocates, State and Federal agencies, and any other groups or individuals having 

an interest in these standards and test procedures. The DOE Appliance Standards Program 

Report to Congress,1

 initially submitted on January 31, 2006, and updated twice a year since first 

publication, identifies the numerous rulemakings for a variety of products that DOE has 

scheduled for completion and explains many of the techniques DOE will apply during the 

rulemaking process to meet this schedule. 

The purpose of this Framework Document is to describe the procedural and analytical 

approaches DOE anticipates using to evaluate potential amended test procedures and energy 

conservation standards or energy use standards for ceiling fans and ceiling fan light kits (CFLK) 

(section 1.1 provides a discussion of the statutory authority for this rulemaking). This 

Framework Document is also intended to inform interested parties of the process DOE will 

follow for the standards rulemaking for these products and to encourage and facilitate input from 

interested parties during the rulemaking. This document serves as the starting point for 

developing amended test procedures and energy conservation standards and is not a definitive 

statement on any issue to be determined in the rulemaking. 

This Framework Document is organized in the following manner. Section 3 provides an 

overview of DOE’s rulemaking process. Section 4 provides a preliminary discussion of test 

procedures. Sections 5 through 20 discuss analyses DOE intends to conduct to fulfill the 

statutory requirements for this particular energy conservation standards rulemaking. DOE will 

analyze potential amended energy conservation standards for ceiling fans and ceiling fan light 

kits to determine whether such standards are technologically feasible, are economically justified, 

and would result in significant energy savings. 

DOE will maintain information about this rulemaking on its website. 

1

 U.S. Department of Energy. Energy Conservation Standards Activities; Submitted pursuant to Section 141 of the 

Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, and in response to section 305 of the Energy 

Independence and Security Act of 2007 (EISA 2007), Pub. L. 110-140; U.S. Department of Energy (August 2012) 

(Available at: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/2012_aug_report_to_congress.pdf). 

1
 
 

Although DOE invites comment on all aspects of the material presented in this document, 

specific issues on which DOE seeks comment are set out in comment boxes like this one. 

DOE uses these comment boxes to highlight issues and ask specific questions on the 

approaches DOE plans to follow to conduct the analyses required for the energy 

conservation standards rulemaking. Such requests for feedback are numbered sequentially 

throughout the document and are compiled in Appendix A. 

1.1 History of Ceiling Fan and Ceiling Fan Light Kit Standards and Authority 

Title III, Part B2 of the Energy Policy and Conservation Act of 1975 (EPCA), Pub. L. 94­

163 (42 United States Code (U.S.C.) 6291-6309, as codified), established the Energy 

Conservation Program for Consumer Products Other Than Automobiles, a program covering 

most major household appliances and certain industrial and commercial equipment.3 This 

program authorized DOE to establish technologically feasible, economically justified energy 

conservation regulations for certain products and equipment that would be likely to result in 

substantial national energy savings. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) Amendments to Title 

III of EPCA have given DOE the authority to regulate the energy efficiency of several additional 

types of products and equipment, including certain ceiling fans and ceiling fan light kits, which 

are the focus of this document. (42 U.S.C 6295(ff)) 

The Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, amended EPCA and 

provided that DOE may establish energy conservation standards for ceiling fans and ceiling fan 

light kits, as well as requirements for determining whether these standards should be amended. 

(42 U.S.C. 6295(ff)) Specifically, EPACT 2005 set design standards for ceiling fans and 

provided that DOE may consider and issue energy efficiency or energy use standards for 

electricity used by ceiling fans to circulate air in a room. (42 U.S.C. 6295(ff)(1) and (6)) For 

ceiling fan light kits, EPACT 2005 set energy conservation standards for ceiling fan light kits 

with medium screw base sockets, as well as pin-based sockets. (42 U.S.C. 6295(ff)(2)-(3)) The 

statute also directed DOE to consider and issue requirements for other types of ceiling fan light 

kits (including candelabra screw base sockets) by January 1, 2007, and if DOE failed to issue 

such standards by the date specified, the statute provided for an alternative set of requirements 

for ceiling fan light kits manufactured after January 1, 2010. (42 U.S.C. 6295(ff)) After January 

1, 2010, DOE may again consider amended energy efficiency standards for ceiling fan light kits, 

standards that would apply to products manufactured not earlier than two years after the date of 

publication of the final rule. (42 U.S.C. 6295(ff)(5)) 

Under this statutory structure, DOE codified energy conservation standards and 

promulgated test procedures for ceiling fans and ceiling fan light kits, which are set forth in the 

Code of Federal Regulations (CFR). In a final rule technical amendment published in the 

Federal Register (FR) on October 18, 2005, DOE codified the statutory design standards for 

ceiling fans and the performance standards for ceiling fan light kits in the CFR at 10 CFR 

430.32(s). 70 FR 60407, 60413. An additional final rule technical amendment published in the 

2

 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 

3

 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012). 

2
 
 

 

Federal Register on January 11, 2007, codified standards for light kits with sockets other than 

medium-screw base or pin-based fluorescent lamps in the CFR. 72 FR 1270. In a final rule 

published in the Federal Register on December 8, 2006, DOE adopted test procedures for ceiling 

fans and ceiling fan light kits at 10 CFR part 430, subpart B, appendix U and appendix V, 

respectively. 71 FR 71340, 71366-67. 

2 SCOPE OF COVERAGE 

As noted above, EPACT 2005 included amendments to EPCA that provided for new 

Federal energy efficiency and water conservation test procedures and related definitions for 

certain consumer products and commercial and industrial equipment, including ceiling fans and 

ceiling fan light kits.

4 

2.1 Ceiling Fans 

EPCA defines a “ceiling fan” as "a nonportable device that is suspended from a ceiling for 

circulating air via the rotation of fan blades." (42 U.S.C. 6291(49)) Pursuant to EPCA, DOE 

intends to regulate the electrical energy consumption of ceiling fans. (42 U.S.C. 6295(ff)(6)(A)) 

In addition to giving DOE the discretion to issue electrical energy conservation standards for 

ceiling fans, EPCA also includes certain statutorily-prescribed design standards (including a 

requirement for (i) fan speed controls separate from any lighting controls; (ii) adjustable speed 

controls (either more than one speed or variable speed); and (iii) the capability for reverse action 

(other than fans sold for industrial or outdoor application or where safety would be an issue)). 

(42 U.S.C. 6295(ff)(1)(A)) The statutory design standards will remain in place and are not 

subject to review as part of this rulemaking process. 

As discussed below, DOE previously interpreted “hugger fans,” i.e., fans that are 

mounted flush to the ceiling, to fall outside the definition of “ceiling fan”, explaining that such 

fans are “mounted flush to” rather than “suspended from” the ceiling (71 FR 71340, 71343 (Dec. 

8, 2006)). DOE is in this rulemaking reconsidering this distinction. DOE also has never 

interpreted the statutory language “highly decorative fans for which air movement performance 

is a secondary feature.” (42 U.S.C. 6295(ff)(6)(B)(ii)) DOE is proposing to define this category 

of ceiling fans with reference to their revolutions per minute (RPM) and is considering whether 

to make them a separate, exempt product class. 

 Certain ceiling fans are mounted flush to the ceiling, for example, without a 

downrod. At the time DOE codified the standards prescribed by EPACT 2005 (including those 

for ceiling fans), DOE interpreted these “hugger fans” as falling outside the definition of covered 

ceiling fans, because they were not considered to be “suspended from a ceiling.” 71 FR 71340, 

71343 (Dec. 8, 2006). The previous interpretation of this definition exempted hugger fans from 

standards on the basis that they are “typically understood to be ceiling fans that are not 

suspended from the ceiling; instead, they are set flush to the ceiling.” Id. DOE interpreted the 

statutory term “suspended” to mean only “suspended from a downrod,” and concluded that 

4

 Test procedures for consumer products and certain commercial and industrial equipment: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial_equipment_test_procedures.html 

3
 
 

hugger fans are not suspended, and, therefore, not subject to EPCA requirements (including test 

procedures) applicable to ceiling fans. Id. 

Merriam-Webster’s Unabridged Dictionary defines “suspend” as, among other meanings, 

“to hang so as to be free on all sides except at the point of support.”5 DOE’s prior approach 

represents one plausible interpretation of this ambiguous statutory term. However, it is equally 

plausible to determine that a hugger fan is suspended from the ceiling as the motor housing is 

hung flush to the ceiling only at the point of support. Moreover, the presence or absence of a 

downrod does not appear dispositive as the basic fan mounting to the ceiling is the same 

regardless of a downrod. DOE has carefully reconsidered this issue and has tentatively 

concluded that hugger fans are “ceiling fans” within the scope of the statutory definition, 

particularly given the functional and mounting similarity of all such fans. This reinterpretation is 

also in line with the scope of CAN/CSA-C814-10, which includes hugger fans. 

Given that DOE’s prior interpretation has been in place for a number of years, DOE is 

proposing its revised interpretation as part of this notice-and-comment rulemaking. Specifically, 

DOE proposes to reinterpret the definition of “ceiling fan” to incorporate hugger fans. Under 

this reinterpretation, DOE would consider the following fans to be explicitly covered under the 

definition of “ceiling fan” in 10 CFR 430.2: 

1.	 Fans that are hung from a downrod or other means of suspension; 

2.	 Multi-mount fans (fans that are sold with the option of being hung with or without a 

downrod); and 

3.	 Fans that are mounted directly or closely to the ceiling. 

DOE contends that hugger fans generally are indistinguishable from other types of ceiling 

fans in that they move air via rotation of fan blades, are intended to improve comfort, and are 

rated on their ability to move air (as measured in cubic feet per minute). DOE believes the only 

distinguishing feature of hugger fans is that they are safe to use in rooms that have low ceilings; 

however, DOE acknowledges that such design may have performance characteristics that impact 

energy efficiency. Consequently, DOE will, on this basis, consider establishing a separate 

product class for hugger fans. 

The second part of DOE's proposed reinterpretation aims to acknowledge the existence of 

and to address multi-mount fans. Many ceiling fans are sold with multiple options for mounting 

the fan, including but not limited to flush with the ceiling. DOE is clarifying that any ceiling fan 

sold with the option of being mounted flush to the ceiling, but that also can be mounted such that 

it is not appropriate for rooms with low ceilings would be considered a “multi-mount fan,” which 

would also be included in the “ceiling fan” definition. 

Additionally, in issuing energy conservation standards for ceiling fans, EPCA directs 

DOE to consider establishing a separate exempted product class(es) for highly decorative fans 

5

 Merriam-Webster online (Last accessed March 8, 2013) (Available at: <www.merriamwebster.com/dictionary/suspended>). 

4
 
for which air movement performance is a secondary feature (42 U.S.C. 6295(ff)(6)(B)(ii)). As 

such, DOE is planning to define “highly decorative fans” with reference to their maximum 

rotational speed in revolutions per minute (RPM) and is considering establishing a separate 

product class for highly decorative fans that is exempt from energy conservation standards. 

DOE is also aware of the existence of fans that do not have external blades, but create 

airflow due to a set of internal disks or blades (e.g., a Dyson Air Mulitplier fan). DOE 

understands that ceiling fans of this type currently have very limited market share, if any. DOE 

notes that its statutory definition does not hinge on whether a given model has a certain type of 

blades. Thus, DOE tentatively believes that fans with internal blades that would meet the other 

criteria set forth in the ceiling fan would be covered by DOE’s regulatory scope. Consequently, 

DOE requests feedback on whether such ceiling fans should be considered as part of this 

rulemaking. 

Item 1 DOE seeks comments on its proposed reinterpretation 

of the ceiling fan definition. 

Item 2 DOE seeks comments on whether ceiling fans without 

external blades should be included in this rulemaking 

if they meet the definition of a ceiling fan. 

2.1.1 Definitions Related to Ceiling Fans 

DOE surveyed the market of currently available ceiling fans to better understand the 

different types and classifications currently being used by manufacturers to describe ceiling fans 

with different designs. DOE has observed a number of descriptions of ceiling fans in the market 

(that are not necessarily mutually exclusive), including: 

 Hugger 

 Low-profile 

 Flush-mount 

 Extended 

 Standard 

 Indoor 

 Outdoor 

 Damp-rated
 

 Wet-rated
 

 Decorative 

DOE believes that all of the ceiling fans described on this list are covered by the statutory 

definition of a “ceiling fan.” For the purposes of DOE’s regulations, DOE proposes to assign 

ceiling fans to one of four categories, distinguished by their functionality and physical 

characteristics. For example, DOE is proposing that a ceiling fan that could be described as 

either a “hugger” or “low profile” ceiling fan, could fall into the “hugger” DOE ceiling fan type 

5
 
 

because a fan with either description could be used in a room with a low ceiling. This approach 

is in contrast to the approach previously taken by DOE. Previously DOE interpreted a “hugger 

fan” with respect to the mounting method; DOE is now proposing to define a “hugger fan” with 

respect to the distance between the blades and the ceiling. Two other “special” categories of 

ceiling fans would be those fans designed for outdoor use and those fans for which air movement 

performance is not a primary feature. All other ceiling fans would be standard, indoor ceiling 

fans. 

Table 2-1 summarizes the various ceiling fan types that DOE is considering as part of this 

rulemaking, along with a description of their functionalities, and the common market 

terminology/descriptions. 

Table 2-1 Types of Ceiling Fans 

DOE Ceiling 

Fan Type Functionality Market Description May Include... 

Standard Indoor 

Suitable for use indoors, 

in rooms without low 

ceilings 

Standard, indoor, extended 

Hugger Suitable for use in 

rooms with low ceilings 

Hugger, low profile 

Outdoor Suitable for use in wet 

or damp environments 

Outdoor, damp-rated, wet-rated 

Highly 

Decorative 

Decorative only; air 

movement performance 

is not a primary feature 

Decorative 

A key issue in this rulemaking involves the need to provide clear definitions of the 

various types of ceiling fans. DOE intends to develop definitions that are based on physical 

characteristics of those types of ceiling fans, thereby providing clarity and specificity for 

interested parties when determining how a given basic model of ceiling fan falls into DOE’s 

regulatory structure. The following sections discuss DOE’s initial approach in terms of defining 

various types of ceiling fans. 

2.1.1.1 Definition of “Hugger Fan” 

There currently is no statutory or regulatory definition specific to ceiling fans designed 

for installation in spaces with low ceilings. Such models are variably referred to within the 

industry as “hugger fans,” “low-profile fans,” or “flush-mount fans.” Low-profile fans are 

mounted close to the ceiling (typically with the use of a base), which allows the motor housing to 

be slightly removed from the ceiling. In contrast, flush-mount fans typically have the motor 

housing mounted flush against the ceiling. Industry appears to have begun using the term 

“hugger fans” as a broad term used to describe fans that can be either low-profile or flush-mount. 

All three of these terms are used to describe ceiling fans that are to be installed in locations with 

6
 
low ceilings, where other types of fans may be unsafe. The close proximity of the ceiling to the 

fan blades decreases the fan’s efficiency at circulating air when compared to a suspended fan. 

DOE reviewed the market of currently available ceiling fans marketed as low-profile, 

flush-mount, and hugger fans to see if it would be possible to identify physical characteristics 

differentiating these types of fans from standard indoor fans suitable for non-space constrained 

environments. DOE found that manufacturers typically include schematics describing the 

vertical distance between the fan blades and the ceiling as part of the product literature for each 

model. Based on the variety of observed vertical distances described in the literature being used 

to describe various ceiling fans offered by different manufacturers, DOE found that there is not a 

common distance being utilized by industry that determines whether a fan is commonly referred 

to as low-profile, flush-mount, or hugger. To provide clarity as to how a manufacturer should 

determine whether its ceiling fan would qualifies as a “hugger fan” for DOE’s regulatory 

purposes under a new definition, DOE is seeking comment about whether there is a common 

maximum vertical distance that is used to determine whether a ceiling fan is safe for installation 

in locations with low ceilings. DOE is considering a definition of “hugger fan” as “a ceiling fan 

where the average vertical distance between the fan blades and the ceiling is no more than [a 

specified number of] inches,” where the specific distance will be determined as part of the 

rulemaking process. DOE would like to base the specific distance on feedback from 

manufacturers as to how they currently decide which fans can go in vertically space-constrained 

rooms. 

2.1.1.2 Definition of “Standard Ceiling Fan” and “Multi-Mount Fan” 

Once DOE has determined the physical characteristics that distinguish a hugger ceiling 

fan from a standard ceiling fan, DOE plans also to propose defining “standard ceiling fan,” 

which includes all other types of fans that are typically suspended from the ceiling through the 

use of a downrod. In addition, DOE will also propose a definition of a “multi-mount ceiling 

fan,” which will apply to those ceiling fans that can be used both in locations with low ceilings 

and in standard applications with the use of a downrod. 

Item 3	 DOE seeks comments on its proposed approach for 

developing definitions for the four types of ceiling fans, 

the vertical distance that is used to characterize whether 

a fan can safely be used in rooms with low ceiling 

heights, and any other physical characteristics used to 

determine the different types of ceiling fans currently on 

the market. 

2.1.1.3 Definition of “Highly Decorative Fan” 

EPCA requires that if DOE sets energy efficiency standards for ceiling fans, it must 

consider ''establishing separate exempted product classes for highly decorative fans for which air 

movement performance is a secondary design feature.'' (42 U.S.C. 6295(ff)(6)(B)(ii)) EPCA 

7 
 

 

does not, however, exempt highly decorative fans from the statutorily-prescribed design 

standards, instead requiring that all ceiling fans have speed controls separate from lighting 

controls and include adjustable speed controls; most fans also must have the capability of 

reversible fan action. (42 U.S.C. 6295(ff)(1)(A)) Because DOE has not established standards 

for ceiling fans beyond the design standards promulgated by statute, DOE has not yet needed to 

consider whether highly decorative fans should be a separate regulated or exempted product 

class. 71 FR 71340, 71343 (Dec. 8, 2006). 

However, because DOE intends to now consider energy efficiency standards for ceiling 

fans, it will be necessary to clarify the statutory language “highly decorative fans for which air 

movement performance is a secondary feature.” The air movement performance of a ceiling fan 

is determined by the blade geometry and velocity. Therefore, DOE believes that blade speed (in 

RPM) is a valid way to differentiate fans for which air movement performance is a secondary 

feature. 

During the rulemaking to codify the design standards prescribed by EPACT 2005, DOE 

received comment on decorative fans. At that time, the American Lighting Association (ALA) 

suggested defining “highly decorative fans” as ceiling fans with less than a 3:1 blade length to 

width ratio and a maximum 175 RPM at high speed down flow. 71 FR 71340, 71343 (Dec. 8, 

2006). 

The American Council for an Energy Efficient Economy (ACEEE) recommended that 

DOE develop a more limited definition that includes only “highly” decorative fans, and not fans 

just outside the normal range of blade length-to-width ratio and RPM. DOE’s analysis suggests 

that the normal range of blade length-to-width is 3.4 to 4.6, with 3.5 being typical; the normal 

range of RPM is 140-215 at high speed and 35-80 at low speed. Id. Further, ACEEE 

recommended that any product deemed exempt on the basis of being highly decorative must be 

clearly labelled as such, making customers aware that their primary function is for decoration 

and not air circulation. (EERE-2006-TP-0121-0069)6 

DOE is proposing to use a new regulatory term “highly decorative fan” to capture the 

“highly decorative fans for which air movement performance is a secondary feature” 

contemplated by EPCA. DOE is proposing that the new term “highly decorative fan” be defined 

as: "a ceiling fan that circulates air via the rotation of fan blades at a maximum rotational speed 

of 50 RPM." 50 RPM was chosen as the cut-off point for highly decorative fans because DOE 

has tentatively concluded that fans for which air movement performance is a secondary feature 

are unlikely to need to exceed this speed. 

Item 4 DOE seeks comments on its proposed definition of 

“highly decorative ceiling fans.” 

6

 Available at: http://www.regulations.gov/#!documentDetail;D=EERE-2006-TP-0121-0069. 

8 
 

2.1.1.4 Definition of “Outdoor Fan” 

DOE is considering defining “outdoor ceiling fans” as ceiling fans that have either a damp 

or wet rating. DOE understands that a manufacturer that wants to be able to advertise its ceiling 

fan as usable in damp or wet environments will seek to have them be either damp-rated or wetrated by a lab such as Underwriters Laboratory or Intertek. The damp or wet rating is a safety 

rating, required by building safety codes for installation in certain damp or wet locations, and 

corresponds to the use of a water-resistant housing for the motor and coating for the fan blades 

(in the case of damp-rated fans) or water-proof housing for the motor and coating for the blades 

(in the case of wet-rated fans). DOE seeks comment on the need to define “outdoor fans” 

separately and on using the damp or wet rating as the distinction. 

Item 5 DOE seeks comments on its proposed definition of 

“outdoor ceiling fans”. 

2.2 Ceiling Fan Light Kits 

EPCA defines a “ceiling fan light kit” as “equipment designed to provide light from a 

ceiling fan” that can be either integral to the ceiling fan or attachable (i.e., sold with or separate 

from the ceiling fan). Thus, all lighting equipment that is either built into, or designed to be 

attachable to, covered ceilings fans, is covered by Federal energy conservation standards. 

3 Overview of the Rulemaking Process 

This section summarizes DOE's energy conservation standards rulemaking process for 

ceiling fans and ceiling fan light kits. 

3.1 Rulemaking Process and Participation of Interested Parties 

EPCA requires that any standard DOE prescribes for consumer products must be 

designed to “achieve the maximum improvement in energy efficiency . . . which the Secretary 

[of Energy] determines is technologically feasible and economically justified.” (42 U.S.C. 

6295(o)(2)(A)) Moreover, EPCA states that the Secretary may not establish an amended 

standard if such standard would not result in “significant conservation of energy,” or “is not 

technologically feasible or economically justified.” (42 U.S.C. 6295(o)(3)(B)) When DOE 

evaluates any new or amended energy conservation standard for covered products under EPCA, 

DOE considers to the greatest extent practicable the following seven factors to determine 

whether a standard is economically justified: 

(1) The economic impact of the standard on the manufacturers and on the consumers of 

the products subject to such standard; 

(2) The savings in operating costs throughout the estimated average life of the covered 

products in the type (or class) compared to any increase in the price, or in the initial 

charges for, or maintenance expenses of the covered products which are likely to 

result from the standard; 

9
 
 

 

 

(3) The total projected amount of energy (or as applicable, water) savings likely to result 

directly from the standard; 

(4) Any lessening of the utility or the performance of the covered products likely to result 

from the standard; 

(5) The impact of any lessening of competition, as determined in writing by the U.S. 

Attorney General, that is likely to result from the standard; 

(6) The need for national energy and water conservation; and 

(7) Other factors the Secretary considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) 

Additional statutory requirements of general applicability for prescribing new or 

amended standards are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)-(iii), and (3)–(5). 

The processes for developing energy conservation standards and test procedures involve 

analysis, public notice and comment, and consultation with interested parties. Interested parties 

generally include manufacturers, trade associations, consumers, environmental and energyefficiency advocates, State and Federal agencies, and other groups and individuals having an 

interest in energy conservation standards and test procedures. DOE considers the participation of 

interested parties to be a vital part of the rulemaking processes for setting new and amended 

energy conservation standards and test procedures. Accordingly, DOE encourages the 

participation of all interested parties during the comment periods provided at each stage of the 

rulemaking. The broad array of interested parties who routinely provide comments promotes a 

balanced discussion of critical information required to conduct the standards and test procedure 

rulemakings, beginning with public comments on the Framework Document. 

In conducting the energy conservation standards and test procedure rulemakings, DOE 

involves interested parties through various means. As discussed in further detail below, the 

standards rulemaking process for ceiling fans and ceiling fan light kits will involve three public 

notices (in addition to the Framework Document), which are published in the Federal Register: 

(1) the preliminary analysis; (2) the NOPR; and (3) the final rule. After publication of the 

Framework Document, the preliminary analysis, and the NOPR, DOE will hold public meetings 

to solicit comment from interested parties in order to enhance the rulemaking process. The 

following outlines next steps for the ceiling fan and ceiling fan light kit energy conservation 

standards rulemaking: 

	 Preliminary Analysis (section 3.2). The preliminary analysis is designed to publicly vet 

the data, models, and tools that DOE intends to use in the rulemaking, and to facilitate 

public participation before the proposed rule stage. Using these models and tools, DOE 

performs preliminary analyses to assess candidate standard levels (CSLs), which span the 

range of efficiencies from baseline products to the most efficient technology. 

10
 
 

	 Notice of Proposed Rulemaking (section 3.3). For this rulemaking, the NOPR will 

present: (1) a discussion of comments received in response to the preliminary analysis; 

(2) DOE’s analysis of the impacts of potential standards on consumers, manufacturers, 

and the Nation; (3) DOE’s weighting of those impacts; and (4) any proposed standard 

levels for public comment. 

	 Final Rule (section 3.4). The final rule will present: (1) a discussion of and response to 

comments received on the NOPR; (2) the revised analysis (as appropriate) of the impacts 

of potential standards; (3) DOE’s weighting of the impacts; and (4) the new or amended 

standard levels (if any) that DOE is adopting. The final rule also will establish the 

compliance date for any adopted standards. 

3.2 Preliminary Analysis 

As part of an energy conservation standards rulemaking, DOE in its preliminary analysis 

typically identifies product technology options and makes a preliminary determination about 

whether to retain each option for detailed analysis or to eliminate it from further consideration. 

This process includes a market and technology assessment (section 6) and a screening analysis 

(section 7). DOE applies four screening criteria in the screening analysis to determine whether a 

given technology option should be eliminated from further consideration: (1) technological 

feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product 

utility or availability; and (4) adverse impacts on health or safety. Technologies that pass the 

screening analysis, which thereafter are referred to as design options, are evaluated in the 

engineering analysis (section 8) as methods of improving the efficiency of the covered products. 

DOE consults with interested parties and independent technical experts and researches 

industry literature to identify the key issues and design options or efficiency levels that DOE will 

consider in the rulemaking. This Framework Document, along with the accompanying public 

meeting announcement and request for public comment, initiates DOE’s dialogue with interested 

parties. This dialogue provides an opportunity for input into the structural and analytical 

approach planned for the subsequent energy conservation standards rulemaking. 

At the start of the preliminary analysis, DOE considers design options or efficiency levels 

for each product class. DOE uses these design options or efficiency levels to collect 

manufacturer cost data, historical shipments data, shipments-weighted average efficiency data, 

and preliminary manufacturer impact data (e.g., capital conversion costs, marketing costs, and 

research and development costs). As part of the preliminary analysis, DOE also conducts other 

principal analyses, many of which are described in this document, including: 

1.	 The engineering analysis (section 8); 

2.	 The consumer life-cycle cost (LCC) and payback period (PBP) analyses (section 11); 

3.	 The national impact analysis, which considers national energy savings (NES) and 

national consumer net present value (NPV) (section 13); and 

4.	 A preliminary manufacturer impact analysis (section 15). 

11
 
 

DOE will present the results of these analyses in the preliminary analysis technical 

support document (TSD), which will be made available at the time of publication of the 

preliminary analysis. 

DOE selects candidate standard levels from the energy efficiency or energy use levels 

considered in the preliminary analysis. Discussion of various CSLs in the preliminary analysis 

will facilitate review by interested parties of the spreadsheet models that underpin the analyses. 

DOE will use comments from interested parties to refine the models for the rulemaking analysis 

at the NOPR stage, where DOE will propose specific energy conservation standard levels for 

adoption. Based on the results, DOE selects CSLs from the energy efficiency or energy use 

levels considered in the preliminary analysis. In addition to the efficiency levels corresponding 

to the maximum technologically feasible (“max-tech”7) design and the efficiency levels 

corresponding to the minimum LCC point, DOE generally considers levels or design options that 

span the full range of technologically achievable efficiencies. DOE typically analyzes the 

following range of efficiency levels: 

	 The baseline efficiency level (i.e., the minimum level) typically represents products 

having the lowest energy efficiency currently sold on the market for a given product 

class. If minimum energy conservation standards already exist for a product, the baseline 

efficiency level typically is defined by the current energy conservation standard; 

	 The level that offers the minimum LCC or greatest LCC savings; 

	 The highest energy efficiency level or lowest energy consumption level that is 

technologically feasible (i.e., the “max-tech” level); and
 

	 Levels that incorporate noteworthy technologies or fill large gaps between other 

efficiency levels being considered. 

At the preliminary analysis stage, DOE uses analytical models and tools to assess the 

different product classes at each efficiency or energy use level analyzed. Many of these 

analytical models and tools are in the form of spreadsheets, some of which DOE uses to conduct 

the LCC and payback period (PBP) analyses and to determine the NES and NPV of prospective 

standards. Preliminary results may facilitate discussions among interested parties on potential 

joint recommendations for standard levels. 

DOE will make the spreadsheet tools and results of the preliminary analysis available on 

its website for review.8

 When it publishes the preliminary analysis, DOE will also make 

available a preliminary TSD, which will contain the details of all the analyses performed to date. 

7

 The “max-tech” represents the most-efficient design that is commercialized or has been demonstrated in a 

prototype with materials or technologies available today. “Max-tech” is not constrained by economic justification, 

and typically is the most expensive efficiency level considered in the engineering analysis. 8

 Materials associated with the ceiling fan and ceiling fan light kit rulemakings will be available on DOE’s websites 

at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/25 and 

http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/76 

12
 
 

After the preliminary analysis is published, DOE provides a public comment period and holds a 

public meeting to discuss these analyses. 

3.3 Notices of Proposed Rulemaking 

In developing the separate NOPRs for the test procedures and energy conservation 

standards for ceiling fans and ceiling fan light kits, DOE will first review and consider all the 

comments it receives within the stated comment period following publication of this Framework 

Document and all comments it receives on the preliminary analysis. DOE will publish a NOPR 

proposing test procedures for ceiling fans and ceiling fan light kits, which will be followed by a 

75-day public comment period that includes one public meeting. The NOPR proposing 

standards for ceiling fans and ceiling fan light kits will be followed by a 60-day public comment 

period that includes one public meeting. 

This process may result in revisions or refinements to the planned methodology for each 

analysis related to the energy conservation standards rulemaking. DOE is planning to conduct 

in-depth technical analyses for the energy conservation standards NOPR for ceiling fans and 

ceiling fan light kits, in the following areas: (1) engineering; (2) markups to determine product 

price; (3) energy-use characterization; (4) life-cycle cost and payback period; (5) national 

impacts; (6) manufacturer impacts; (7) utility impacts; (8) environmental impacts; (9) 

employment impacts; and (10) regulatory impacts. DOE will describe the methodology used and 

make the results of all the analyses available on its website for review and comment. 

This part of the analytical process culminates in the selection of proposed standard levels 

(if any) that DOE will present in the NOPR. DOE selects the proposed standard levels from the 

trial standard levels (TSLs)9

 analyzed prior to publication of the NOPR. The NOPR, published 

in the Federal Register, will document the evaluation and selection of any proposed standards 

levels, along with a discussion of other TSLs considered but not selected and the reasons DOE 

did not select them. Based on comments by interested parties, further revisions to the analysis 

and proposed standard levels may be undertaken for the final rule stage. 

For each product class, DOE will identify the max-tech level. Beginning with the maxtech level, DOE will weigh the benefits and burdens of each level to determine whether that level 

meets the criteria outlined in EPCA discussed above (section 3.1). If DOE proposes a lower 

level, it will sequentially explain the reasons for eliminating higher levels, beginning with the 

highest level considered. DOE will present the analytical results in the NOPR, and provide the 

details of the analysis in an accompanying TSD. 

DOE considers many factors in selecting proposed standards, as discussed in section 3.1. 

Those factors, which are enumerated in EPCA, take into consideration the benefits, costs, and 

other impacts of energy conservation standards. DOE encourages interested parties to develop 

joint recommendations for standard levels. DOE will consider such recommendations carefully 

in its decision process. 

9

 TSLs are assembled from the candidate standard levels analyzed for the individual product classes based on a set 

of criteria from the analytical results. 

13
 
When DOE publishes the NOPR proposing energy conservation standards for ceiling 

fans and ceiling fan light kits, it will provide the U.S. Department of Justice (DOJ) with copies of 

the NOPR and TSD to solicit feedback on the impact of the proposed standard levels on 

competition in the ceiling fan and ceiling fan light kit industries. DOJ will review these 

proposed standard levels to help assess any lessening of competition that is likely to result from 

the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (ii)) DOE will consider DOJ’s 

determination on the impacts of the proposed standard(s) on competition in preparing a final 

rule. As noted above, publication of the NOPR for energy conservation standards for ceiling 

fans and ceiling fan light kits will be followed by a 60-day public comment period that includes 

one public meeting. 

3.4 Final Rule 

After the NOPR is published, DOE will consider public comments it receives on the test 

procedures, proposed standards, and accompanying analyses. For the standards rulemaking, 

DOE will review the engineering and economic impact analyses and proposed standards based 

on those comments and consider modifications where necessary. Before the final rule is issued, 

DOE also will consider DOJ comments on the NOPR relating to the impacts of the proposed 

standard levels on competition to determine whether changes to the standard levels are needed. 

DOE will publish the DOJ comments and DOE’s response as part of the final rule. 

The standards rulemaking will conclude with publication of the final rule. DOE will 

select the final standard level based on the complete record of the standards rulemaking. The 

final rule will promulgate the final standard levels, identify the compliance date (or dates), and 

explain the basis for their selection. The final rule will be accompanied by a final TSD. The test 

procedure rulemaking will conclude with the publication of a final rule, which considers all of 

the comments DOE receives on its proposed test procedures. 

4 TEST PROCEDURES AND REGULATORY METRICS 

4.1 Test Procedures 

EPCA directs DOE to, where applicable, establish test procedures in conjunction with 

new or amended energy conservation standards for products including ceiling fans and ceiling 

fan light kits. (42 U.S.C. 6295(r)) EPCA also requires DOE to review test procedures for all 

covered products at least once every seven years. (42 U.S.C. 6293(b)(1)(A)) To fulfill those 

requirements, DOE is simultaneously initiating both a test procedure rulemaking and an energy 

conservation standards rulemaking for ceiling fans and ceiling fan light kits. DOE intends for 

each test procedure to include an efficiency descriptor and the methods necessary to adequately 

measure the performance of the covered products for the purposes of developing amended 

energy conservation standards. 

Also relevant to the development of a ceiling fan and ceiling fan light kit test procedure, 

the Energy Independence and Security Act of 2001 (EISA 2007) amended EPCA to require that 

any new or amended energy conservation standard adopted after July 1, 2010, address standby 

mode and off mode energy use pursuant to 42 U.S.C. 6295(o). (42 U.S.C. 6295(gg)(3)) 

Specifically, when DOE adopts new or amended standards for certain covered products after July 

14
 
1, 2010, the final rule, if justified by the criteria for adoption of standards in section 325(o) of 

EPCA, must incorporate standby mode and off mode energy use into a single standard if 

feasible, or otherwise adopt a separate standard for such energy use for that product. (42 U.S.C. 

6295(gg)(3)) EISA 2007 also directs DOE to update its test procedures to account for standby 

mode and off mode energy consumption, with such energy consumption integrated into the 

overall energy efficiency, energy consumption, or other energy descriptor, unless the current test 

procedure already accounts for standby mode and off mode energy use. (42 U.S.C. 

6295(gg)(2)(A)) Furthermore, if an integrated test procedure is technically infeasible, DOE must 

prescribe a separate standby mode and off mode test procedure for the covered product, if 

technically feasible. Id. Because the final rules for ceiling fans and ceiling fan light kits are 

scheduled for issuance after July 1, 2010, DOE plans to address the standby mode and off mode 

energy use of these products in both the test procedure and standards rulemaking. 

4.1.1 Modes of Operation for Ceiling Fans and Ceiling Fan Light Kits 

Ceiling fans and ceiling fan light kits have distinct modes of operation, and each mode 

has a corresponding rate or rates of electrical energy consumption. DOE plans to label those 

modes as active mode, standby mode, and off mode. DOE is proposing the following definitions 

related to potential ceiling fan and ceiling fan light kit modes of operation: 

	 Active mode is the mode of operation during which the ceiling fan blades are in motion. 

Ceiling fans are currently required to have adjustable speed controls (either more than 1 

speed or variable speed). Ceiling fans are also required to be able to operate such that the 

fan blades are rotating in the reverse direction of normal operation (with the exception of 

fans sold for industrial or outdoor applications or in cases where safety standards would 

be violated). When the blades rotate in reverse, the ceiling fan can enhance room heating 

by recirculating warm air trapped near the ceiling throughout the room. This direction 

usually only has one speed option. For ceiling fan light kits, active mode is the mode of 

operation during which the light is on. Standby mode is a power consumption mode that 

cannot be switched off, or influenced, by the user and that may persist for an indefinite 

time when the ceiling fan and/or ceiling fan light kit is connected to the main electricity 

supply and used in accordance with the manufacturer’s instructions. Standby mode is a 

non-operational mode when compared to the ceiling fan or ceiling fan light kit’s primary 

function -- moving air or providing light. Energy consumed by a motion sensor, remote 

control receiver, or other standby device that continues to draw power during fan and/or 

light inactivity, should be included when measuring standby power consumption. 

	 Off mode is defined as the condition when the ceiling fan and/or ceiling fan light kit is 

connected to the main power source but is not providing any standby mode or active 

mode function. For ceiling fans and/or ceiling fan light kits, this is the mode of operation 

during which the product is not powered, since ceiling fans and light kits are hard-wired 

into a home’s electrical system and draw no power when not in active mode or standby 

mode. 

15
 
 

 

 

 

 

 

4.1.2 Preliminary Discussion of Test Procedures 

 The following sections describe DOE’s current test procedures, review existing test 

procedures, and describe key issues and preliminary proposals for test procedure amendments for 

ceiling fans and ceiling fan light kits. 

4.1.2.1 Ceiling Fans 

Current DOE Test Procedure for Ceiling Fans 

EPCA directs DOE to base the test procedure for ceiling fans on the ENERGY STAR® 

Testing Facility Guidance Manual: Building a Testing Facility and Performing the Solid State 

Test Method for ENERGY STAR® Qualified Ceiling Fans, Version 1.1, published by the U.S. 

Environmental Protection Agency (EPA). (42 U.S.C. 6293(b)(16)(A)(i)) Accordingly, on 

December 8, 2006, DOE published a final rule in the Federal Register, which adopted Version 

1.1 of the ENERGY STAR test procedure for ceiling fans in Appendix U to Subpart B of 10 

CFR Part 430. 71 FR 71340. 

Review of Current Test Procedures for Ceiling Fans 

When establishing or amending test procedures, DOE begins by reviewing existing 

industry test procedures or testing methods currently used to measure the energy use or energy 

efficiency of the covered products. DOE’s test procedure review included the current Federal 

test procedure for ceiling fans, version 1.1 (2002) and 1.2 (2011) of the ENERGY STAR 

guidance manual, and the testing methods described in the Canadian Standards Association's 

Energy Performance of Ceiling Fans Standards (CAN/CSA-C814-10). 

DOE adopted a test procedure for ceiling fans in a final rule published in the Federal 

Register on December 8, 2006. 71 FR 71340. DOE’s test procedure is based on ENERGY 

STAR guidance manual version 1.1, which is incorporated by reference into appendix U to 

subpart B of 10 CFR part 430, along with additional requirements on power measurement, 

sensors, and sensor software used for performing the airflow test. . 

When developing product specification and testing criteria in 2002, EPA was unable to 

adopt an existing industry testing procedure for use in the ENERGY STAR program because 

there was no standardized test method available within the ceiling fan industry at the time.10 

Therefore, EPA partnered with Hunter Fan Company to develop the solid-state test method that 

allows for the measurement of total cubic feet per minute (CFM) and CFM/watt readings for 

multiple fan speeds. The resulting test procedure was set out in ENERGY STAR guidance 

manual version 1.1, which, as described above, formed the basis for DOE’s test procedure in 

2006. EPA later revised its test procedure in 2011, creating ENERGY STAR guidance manual 

version 1.2, which differs from version 1.1 in the key ways set forth below. (Hereinafter, the two 

guidance manuals will be referred to together as "the ENERGY STAR guidance manuals.") 

Specifically, version 1.2: 

10 http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/ceil_fans/ceiltestfinal.pdf?8360­

5206 

16
 
1.	 Provides an updated list of product vendors; 

2.	 Stipulates that velocity sensors be rated for ± 5% accuracy and standard flow ranges of 

0.15 to 10 m/s (approximately 30–1969 feet per minute), whereas version 1.1 required all 

instruments, including velocity sensors, to have tolerances within ± 1%; 

3.	 Relaxes the requirement for the ceiling to be stainless steel or sheet rock, allowing for the 

possibility of a drop ceiling with full coverage from wall to wall; 

4.	 Requires closing AC vents during testing (as opposed to merely recommending it in 

version 1.1); 

5.	 Describes methods for using a single arm of sensors or a set-up for four sensors to 

measure several places at once, updating all corresponding figures to coincide with this 

expansion; 

6.	 Specifies that no inside seam of the test cylinder be directly aligned with the velocity 

sensors when measuring airflows; 

7.	 Decreases the required room temperature from 76 °Fahrenheit (F) to 70 °F; 

8.	 Extends the warm-up time for the first test from 15 to 30 minutes, and specifies that the 

lowest speed be tested first; 

9.	 Repeats the procedure for all possible fan speed settings (as opposed to only the rated 

speed); 

10. Includes instruction to use the RMS sensor to calculate average power consumption; and 

11. Removes the requirement for a detailed calibration. 

DOE also reviewed the test procedures included in the Canadian Standards Association's 

Energy Performance of Ceiling Fans Standards (CAN/CSA-C814-10), which are broadly in line 

with DOE's test procedures for ceiling fans, albeit with the following modifications: 

1.	 A test set-up for hugger fans; 

2.	 A sampling plan/requirement, specifically "For each basic model of ceiling fan, a sample 

of sufficient size shall be tested to ensure that every represented fan efficacy value shall 

be not less than the greater of (a) the mean of the sample; and (b) the upper 95% 

confidence limit of the true mean divided by 1.10"; 

3.	 Requirement for standby power to be measured, according to another test procedure 

(CAN/CSA-C62301); 

4.	 Ceiling fans are run for 15 minutes with sensors on before testing begins, without the 

additional requirement for any AC equipment to be turned off, and then fans run for an 

additional 3 minutes before starting data acquisition; 

5.	 Required room temperature is 70 +/- 5°F, as opposed to 76 +/-2°F; 

6.	 Specified test cylinders sizes are slightly different for certain fan sizes. For example, a 

42" fan would be tested with a 52” cylinder instead of a 50" cylinder for the DOE test 

procedure; 

17
 
 

7. Does not include an internal calibration system between testing facilities. 

Item 6	 DOE seeks comment on the existence and applicability 

of any other test procedure that DOE could consider 

for measuring the airflow and electrical energy 

consumption of ceiling fans. DOE seeks comment as 

to what types of testing manufacturers currently 

conduct on ceiling fans and what test set-ups and 

methods are used. DOE has noticed, for example, that 

some hugger fans are marketed with a declaration of 

energy efficiency. DOE is interested in knowing how 

manufacturers have tested such ceiling fans. 

Key Issues for Consideration in Active Mode Test Procedures for Ceiling Fans 

DOE has identified a number of issues regarding the testing of ceiling fans and will 

consider the feedback received in response to this Framework Document in developing its 

proposed test procedures. 

Active mode is the primary mode measured under current test procedures for both DOE’s 

regulatory program and the ENERGY STAR program. DOE has identified a number of issues 

that currently are either not addressed regarding testing ceiling fans in active mode or that may 

require clarifications or modification of the current test procedures currently being used on 

which DOE requests feedback from interested parties. The issues (discussed in further detail 

immediately below) include: 

1. Accuracy of velocity sensors; 

2. Hugger fans; 

3. Multi-mount fans; 

4. Fans having non-flat or unusually shaped blades; 

5. Fans not exactly 8 inches smaller in diameter than an existing test cylinder; 

6. Fans with multiple fan heads; 

7. Fans where the airflow is not directed straight downwards; 

8. Fans sold with combined heaters; 

9. Testing at multiple fan speed settings; and 

10. Testing in reverse direction 

Accuracy of velocity sensors 

18
 
 

 

DOE conducted initial testing of five conventional ceiling fans according to the current 

ENERGY STAR test procedure and observed that, at low speed, the average air velocities varied 

widely depending on the position of the sensor-arm.11 For each fan, the air speed measured by at 

least one sensor varied by more than a factor of two between different sensor arm positions. This 

effect was less pronounced at higher fan speed settings when the average airspeed was greater. 

Given the symmetry of the test set-up, the variability of the average air velocities suggests that 

the accuracy of the velocity sensors may need to be reconsidered. 

Performance variability between ceiling fans within a specific fan model 

During initial testing of the five ceiling fans, DOE observed that the measured RPM for 

several fans was inconsistent with the RPM listed in the owner’s manuals or online. DOE is 

unsure what is contributing to this difference in results between the reported and measured 

values, but it could ultimately impact the repeatability of the test method. Consequently, DOE is 

seeking feedback on whether the representations of RPM are based on test procedure values and 

whether DOE should consider a larger sample size to determine certified ratings of ceiling fans 

of a given basic model. 

Hugger Fans 

DOE is proposing a new definition for “hugger fan”, which would include ceiling fans 

that are mounted flush with or close to the ceiling. The configuration of hugger fans with their 

proximity to the ceiling is not accounted for under the current DOE test procedure. Therefore, 

DOE is considering amending its test procedure to allow for the testing of hugger fans. DOE 

will investigate methodologies for testing hugger fans, including the use of an artificial ceiling, 

along the lines described in CAN/CSA-C814-10, “Energy Performance of Ceiling Fans.” DOE 

requests comments on potential approaches it should consider (including the use of an artificial 

ceiling) to enable hugger fans to be tested. 

Multi-Mount Fans 

Multi-mount fans are fans that can either be mounted flush with or close to the ceiling, or 

suspended from a downrod. DOE is not aware of any data on how often multi-mount ceiling 

fans are mounted with or without a downrod. DOE is considering testing multi-mounts as 

hugger fans, (i.e., mounted flush with or close to the ceiling) to provide for a conservative rating 

and allowing manufacturers to voluntarily run additional testing if they wish to make 

representations as a standard fan. DOE requests comments on its approach for multi-mount fans. 

Fans Having Non-Flat or Unusually Shaped Blades. 

Some fans on the market are not shaped in a traditional way that incorporates flat blades. 

The current DOE test procedure refers to fan blades, and the test set-up assumes a reasonably flat 

11 A rotating arm positions the sensors at 0, 90, 180, and 270 degrees for a portion of each test. 

19
 
 

blade design.12 The DOE test procedure specifies that a test cylinder, which measures airflow, 

be hung below the ceiling fan so that there is a 6-inch vertical gap between the middle of the fan 

blade tips and the top of the test cylinder. (If not all of the blades are the same height, the 

average of all of the blade heights is required to be 6 inches.) For fans having non-flat blades or 

unusual shapes, such as fans with airfoil blade shapes, gyro fans, ribbon fans, or fans that “orbit” 

by changing the tilt of the entire fan, it may be unclear as to how the “middle of blade tip” 

measurements should be made, and 6 inches from the tip may not be the correct clearance from 

the cylinder to set up a congruent test for airflow. 

DOE is considering investigating appropriate distances and measurement methodologies 

for ceiling fans that have non-flat and unusually shaped blades, with the aim of clarifying how 

such fans should be measured. As part of this investigation, DOE will consider the methodology 

set out in CAN/CSA-C814-10. DOE requests feedback as to whether it is necessary to develop 

specialized methodologies for testing various blade types and seeks suggestions as to how to 

clarify the test procedure to account for unusual configurations. 

Fans That Do Not Meet the 8-Inch Difference in Diameter Requirement with Existing 

Test Cylinders 

 The current DOE test procedures and the test procedure used for the ENERGY STAR 

program require that ceiling fans be tested in test cylinders exactly 8 inches larger in diameter 

than the ceiling fan.12 Therefore, the ability to test a unique fan sizes is limited by the 

availability of a corresponding test cylinder. Testing ceiling fans that are not exactly 8 inches 

smaller in diameter than an existing test cylinder currently requires the purchase or construction 

of a new cylinder. DOE is considering investigating to what degree maintaining the 8-inch 

requirement affects the accuracy and repeatability of the test results with an aim at reducing 

testing burden and potentially minimizing the number of test cylinders needed to characterize the 

variety of ceiling fans currently on the market. If DOE finds that it can obtain accurate and 

reliable results, DOE is considering either: (1) allowing testing of ceiling fans in cylinders within 

a specified tolerance of the current 8 inch requirement, or (2) developing a correlation between 

blade span and test cylinder size to account for the change in airflow. Either approach would 

limit the number of test cylinders that would need to be purchased to test fans with diameters that 

do not correspond to an existing test cylinder. DOE requests information on the effects of testing 

ceiling fans in cylinders having diameters other than 8 inches larger than the blade span of the 

ceiling fan and seeks comments on these potential modifications. 

Fans with Multiple Fan Heads 

The current test procedures for DOE and ENERGY STAR are unclear when it comes to 

some of the test set-up and conditions needed for testing multiple head fans. The geometry of 

multi-headed fans could result in: (1) most of the airflow from such fans missing a corresponding 

test cylinder, or (2) a significant additional cost burden to manufacturers to purchase an 

12 ENERGY STAR® Testing Facility Guidance Manual: Building a Testing Facility and Performing the Solid State 

Test Method for ENERGY STAR® Qualified Ceiling Fans, Version 1.1 (Available at: 

http://www.energystar.gov/ia/partners/manuf_res/downloads/ceiltestfinal.pdf) 

20
 
unusually large test cylinder to capture all of the airflow. In either case, complicated correction 

factors would be needed to make the test results comparable to fans with a single head. 

To measure airflow performance for multi-head fans, DOE is considering testing only 

one of the ceiling fan heads, with the other fan head motors turned off, and treating the fan head 

like a standard single-head ceiling fan. The airflow and airflow efficiency could be rated for the 

individual head. Total airflow for multiple heads could be determined by multiplying airflow 

from one fan by the number of heads, assuming all are of equal construction and diameter. The 

power consumption could be determined similarly. DOE requests comments on whether a single 

fan head can be isolated for testing. If this condition cannot be met, DOE requests comment on 

alternatives for testing multi-head fans. 

Fans Where the Airflow is Not Directed Vertically 

DOE has observed that some ceiling fans on the market can be oriented in various 

positions that direct the airflow and that sometimes, the fans cannot be pointed straight down. A 

downward orientation is important because the test cylinders and flow sensors are positioned 

directly beneath the fan in the current testing procedures. A non-vertical orientation would mean 

that some of the airflow produced by the fan would be undetected by the flow sensors. For fans 

that are oriented such that the airflow is not directed vertically, DOE is considering adjusting the 

fan such that the airflow is vertical prior to testing. DOE is also considering requiring that test 

labs use an adjustable mount to achieve a vertical orientation. Alternatively, DOE is considering 

testing in the non-vertical direction as specified in the installation manual and measuring the 

airflow, which could provide a conservative estimate of airflow for the ceiling fan. 

Fans Sold with Combined Heaters 

Consumer survey data for 2007–2011 purchased from the market research firm NPD 

Group, Inc. suggest that approximately 9 percent of ceiling fans are sold with combined heating 

elements, although it is unclear how much those heaters may be used. DOE has preliminarily 

concluded that it is not planning to consider the power consumption by the heater in this 

rulemaking and is proposing to specify in its test procedure that the heaters be switched off 

during testing. DOE requests comment on the exclusion of the heater usage as part of the ceiling 

fan testing procedure. 

Testing at Multiple Fan Speed Settings 

Current DOE standards for ceiling fans require that all ceiling fans have the ability to run 

at more than one speed (see section 2.1). Ceiling fans with multiple speed settings allow the user 

to change the airflow to meet varying climate control needs during active mode operation. 

During active mode operation, ceiling fans consume electrical energy at various rates depending 

on those speed settings. Consequently, ceiling fans have different airflow efficiencies (cubic feet 

per minute (CFM)/watt (W)) for each speed. The current DOE test procedure allows for 

measurement of airflow efficiency at any and all available fan speeds. DOE is considering 

various approaches for characterize the ceiling fan energy use at the various speed options 

available for each basic model. Specifically, DOE could require testing at a single speed or at 

multiple speeds. One option that limits test burden that DOE could consider would be to test at 

21
 
the highest fan speed setting. DOE requests feedback on the number of speeds that should be 

considered for testing which would reflect typical consumer operation. For consideration of 

multiple speeds or variable speed controls, DOE requests comments on how testing a discrete 

number of speeds would correspond to the various options offered by manufacturers. For 

example, if DOE required testing in “high,” “medium,” and “low” speeds, how would that 

correspond to the manufacturer settings in a 4-speed fan? DOE specifically requests feedback on 

how to define “high,” “medium,” and “low” speeds on fans with more than three speeds or 

variable speed controls. 

Testing in Reverse Direction 

As noted in section 1.2.1, ceiling fans manufactured after January 1, 2007 must be 

capable of reversible fan action, with certain limited exceptions. Specifically, this requirement 

does not apply to fans sold for industrial applications, fans sold for outdoor applications, and 

cases in which safety standards would be violated by the use of the reversible direction. DOE 

has concluded that these statutory exceptions to the reverse action design requirement in 42 

U.S.C. 6295(ff)(1)(A)(iii) will continue, even as DOE develops performance standards under 42 

U.S.C. 6295(ff)(6). On this point, DOE notes that fans sold for industrial applications are not 

covered products under EPCA’s definition of “consumer product.” DOE anticipates that fans 

sold for outdoor applications will be a separate product class (see section 6.1.3.1), and DOE is 

not aware of any residential ceiling fans for which safety standards would be violated by the use 

of reverse action. However, as a technical matter, DOE is still considering whether reverse 

action should be included in the test procedure for ceiling fans. 

DOE anticipates that for most ceiling fans, time spent in reverse will be marginal 

compared with the amount of time spent turning in the “forward” direction and that the share of 

time in both directions will differ greatly by region. DOE expects that most consumers use 

ceiling fans predominantly for cooling and that energy efficiency in the forward and reverse 

directions will typically be highly correlated. That is, a ceiling fan that is highly efficient in 

forward would also likely be highly efficient in reverse. DOE requests comment on the 

relationship between energy consumption in forward and reverse directions. 

Item 7 DOE requests comments on the accuracy tolerance of 

the velocity sensors for either the current DOE or 

current ENERGY STAR test procedures and potential 

sources of inaccuracy for low speed airflow 

measurements 

Item 8 DOE requests comments on the potential performance 

variability between ceiling fans for a specific fan 

model and the possibility of requiring a sample of 

ceiling fans to certify a model. 

22
 
Item 9 DOE requests comments on its proposal to investigate 

methodologies (including the use of an artificial 

ceiling) to enable hugger fans to be tested. DOE 

welcomes any information on how hugger fans 

currently are tested. 

Item 10 DOE requests comments on its proposal to test multimount fans in hugger fan configuration. 

Item 11 DOE is considering investigating appropriate 

distances and measuring methodologies for ceiling 

fans having non-flat and unusually shaped blades to 

clarify how such fans should be measured. DOE 

requests feedback as to whether developing such 

methodologies is necessary and helpful. DOE seeks 

suggestions as to how best to clarify the test procedure 

to account for those types of configurations. 

Item 12 DOE requests information on the effects of testing 

ceiling fans in cylinders having diameters other than 8 

inches wider than the blade span of the ceiling fan and 

seeks comments on the potential modifications to the 

test procedure described. 

Item 13 DOE requests comments on its proposed approach to 

testing ceiling fans with multiple fan heads. 

Item 14 DOE requests comments on its approach to testing 

ceiling fans where the airflow is not directed 

vertically. 

Item 15 DOE is proposing to specify in its test procedure that 

heaters be switched off during testing. DOE requests 

comments on its proposed approach. 

Item 16 DOE seeks comment on the possibility of testing at 

one, three, or all available fan speeds. Additionally, 

DOE seeks input on the amount of time spent at each 

fan speed setting. 

Item 17 DOE seeks on how to define “high”, “medium”, and 

“low” speeds on fans with more than three speeds or 

variable speed controls. 

23
 
Item 18	 DOE seeks comments and any available data 

regarding its view that energy consumption in forward 

and reverse are likely to be highly correlated. 

Key Issues for Consideration in Low-Power Mode Test Procedures 

DOE’s current test procedure for ceiling fans uses the metric CFM/watt and measures 

performance in active mode only. This approach reflects that fact that many ceiling fans 

consume energy only in active mode. Some ceiling fans, however, contain technologies such as 

remote-control and thermostat sensors that consume energy in standby mode. The current test 

procedure does not account for the energy consumed by such features. 

The Energy Independence and Security Act of 2007 (EISA 2007) amended EPCA to 

require DOE to consider standby mode and off mode energy consumption in amendments to both 

its test procedures and energy conservation standards. Specifically, EISA 2007 amended EPCA 

by adding the following provisions regarding standby mode and off mode energy use. 

(gg) STANDBY MODE ENERGY USE. -- 

(1) DEFINITIONS.— 

(A) IN GENERAL.—Unless the Secretary determines otherwise pursuant to 

subparagraph (B), in this subsection: 

(i) ACTIVE MODE.—The term “active mode” means the condition in 

which an energy-using product:— 

(I) is connected to a main power source; 

(II) has been activated; and 

(III) provides 1 or more main functions. 

(ii) OFF MODE.—The term “off mode” means the condition in which an 

energy-using product:— 

(I) is connected to a main power source; and 

(II) is not providing any standby or active mode function. 

(iii) STANDBY MODE.—The term “standby mode” means the 

condition in which an energy-using product:— 

(I) is connected to a main power source; and 

(II) offers 1 or more of the following user-oriented or protective 

functions: 

(aa) To facilitate the activation or deactivation of other 

functions (including active mode) by remote switch 

(including remote control), internal sensor, or timer. 

(bb) Continuous functions, including information or 

status displays (including clocks) or sensor-based 

functions. 

(B) AMENDED DEFINITIONS.—The Secretary may, by rule, amend the 

definitions under subparagraph (A), taking into consideration the most current 

versions of Standards 62301 and 62087 of the International Electrotechnical 

Commission. 

(2) TEST PROCEDURES.— 

(A) IN GENERAL.—Test procedures for all covered products shall be amended 

pursuant to section 323 to include standby mode and off mode energy 

consumption, taking into consideration the most current versions of Standards 

62301 and 62087 of the International Electrotechnical Commission, with such 

24
 
 

 

energy consumption integrated into the overall energy efficiency, energy 

consumption, or other energy descriptor for each covered product, unless the 

Secretary determines that:— 

(i) the current test procedures for a covered product already fully account 

for and incorporate the standby mode and off mode energy consumption 

of the covered product; or 

(ii) such an integrated test procedure is technically infeasible for a 

particular covered product, in which case the Secretary shall prescribe a 

separate standby mode and off mode energy use test procedure for the 

covered product, if technically feasible. 

* * * * * 

(3) INCORPORATION INTO STANDARD.— 

(A) IN GENERAL.—Subject to subparagraph (B), based on the test procedures 

required under paragraph (2), any final rule establishing or revising a standard for 

a covered product, adopted after July 1, 2010, shall incorporate standby mode 

and off mode energy use into a single amended or new standard, pursuant to 

subsection (o), if feasible. 

(B) SEPARATE STANDARDS.—If not feasible, the Secretary shall prescribe 

within the final rule a separate standard for standby mode and off mode energy 

consumption, if justified under subsection (o). 

(42 U.S.C. 6295(gg)(1), (2)(A), and (3)) 

As provided in the statutory excerpt above, DOE must consider the most current versions 

of Standards 62301 and 62087 of the International Electrotechnical Commission (IEC). (42 USC 

6295(gg)(2)(A)) The most current versions of those test procedures are IEC Standard 62301, 

Household electrical appliances—measurement of standby power (Second Edition 2011), and 

IEC Standard 62087, Methods of measurement for the power consumption of audio, video, and 

related equipment (Third Edition, April 2011). DOE reviewed both of these standards in 

preparation for this rulemaking. DOE found that IEC 62087 specifies methods of measurement 

for the power consumption of television receivers, videocassette recorders, set top boxes, audio 

equipment, and multi-function products for consumer use. IEC Standard 62087 does not, 

however, include measurement of the power consumption of appliances such as ceiling fans. 

Accordingly, DOE tentatively has concluded that IEC Standard 62087 is not applicable to ceiling 

fans and should not be considered further in this rulemaking. DOE found that IEC 62301 

specifies methods of measurement for electrical energy consumption in low-power modes for 

household appliances and products, including ceiling fans. Therefore, DOE believes IEC 62301 

is applicable to this rulemaking. 

Using the EPCA definitions quoted above for active mode, standby mode, and off mode 

for these products, DOE understands that ceiling fans without remote controls or other sensors 

have no standby mode or off mode electricity consumption. DOE acknowledges that ceiling fans 

with brushless DC motors could use standby mode or off mode electricity if a power switch is 

located between the converter and the motor. Ceiling fans with remote controls do not have a 

true off mode; when they are not in active mode, they are in standby mode, in which case 

electrical energy is consumed by the remote control receiver. 

DOE understands that the vast majority of ceiling fans sold in the U.S. lack remote 

controls or other sensors. These ceiling fans effectively do not have a standby mode and enter 

25
 
off mode when not in active mode. DOE requests comment on the number of fans that are sold 

with remote control sensors or other features that consume energy in standby mode. For fans 

that consume no energy in standby or off mode, a test procedure that measures fan performance 

in active mode is sufficient because active mode efficiency is the only factor in the ceiling fan’s 

overall energy efficiency. 

For the products that are equipped with remote control sensors or other features that 

consume energy in standby mode, DOE will investigate how much energy is consumed in the 

standby mode. The Department does not currently know the amount of such energy 

consumption, or how such energy use compares to energy consumption in the active mode for 

these fans. DOE requests stakeholder input on how much energy ceiling fans consume in 

standby mode (for those fans that have a standby mode), and how it compares to energy 

consumption by these fans in the active mode. Similarly, DOE is proposing to include testing of 

standby mode power consumption as part of the amended ceiling fan test procedure. 

If technically feasible, DOE plans to incorporate standby mode power consumption of 

ceiling fans into an integrated metric for each of those products that addresses overall energy 

efficiency, as directed by the statutory excerpt above. To create an integrated metric, one 

possible approach would be to combine the energy consumed in standby mode with the energy 

consumed in active mode according to the operating hours spent in each mode. The equation 

below illustrates an example of this approach: 

൬ 	 ൌ ܹ ሻ ⁄ܯܨܥሺ௔௡ி஼௘௜௟௜௡௚ ݕ݂݂݅ܿ݅݁݊ܿܧ ݕ݃ݎ݊݁ܧ ஺ܪܱ ൈ஺ ܯܨܥ

ܹ஺ ൈ ܱܪ ൅ ஺ܹௌ௕ ൈ ܱܪ௕

൰

 CFMA – Airflow in active mode. 

 OHA – Annual operating hours in active mode. 

 OHSb – Annual operating hours in standby mode. 

 WA – Power consumption in active mode. 

 WSb – Power consumption in standby mode. 

Note that with this type of equation, the energy efficiency of ceiling fans without any standby 

mode power consumption would simply reduce to the active mode airflow efficiency. DOE 

requests feedback on its planned approach to the energy efficiency metric for ceiling fans. 

To combine standby mode and active mode energy consumption into a single efficiency 

metric as described in the equation above would require estimates of the amount of time ceiling 

fans spend in each mode. DOE understands that ceiling fan usage patterns depend greatly on 

climate and geography (see section 6.1.2.4). It may be difficult to estimate a usage pattern (the 

number of hours in each mode) that is representative of typical ceiling fan usage if typical fan 

use could not be determined, if for instance there are wide regional differences or the data do not 

exist. DOE requests feedback on the feasibility of determining a representative national usage 

profile. 

26
 
Item 19 DOE requests comments on the amount of energy 

ceiling fans consume in standby mode and/or off mode 

and how it compares to energy consumption in active 

mode. 

Item 20 DOE requests feedback on its planned approach to use 

an integrated energy efficiency metric for ceiling fans. 

Item 21 DOE seeks information on the number of ceiling fans 

that are sold with remote controls or other devices that 

consume energy in standby mode and/or off mode. 

Item 22 DOE seeks input on average ceiling fan usage, 

including the amount of time spent in each mode, and 

the feasibility of determining representative national 

average hours of operation. 

4.1.2.2 Ceiling Fan Light Kits 

Current Test Procedures of Ceiling Fan Light Kits 

The current DOE standards for ceiling fan light kits (42 U.S.C. 6295 (ff)), which were 

established by EPACT (see section 1.1), use different test procedures, and in some cases 

different metrics, for different light kit product classes. The Federal standards for ceiling fan 

light kits with medium screw-based (class 1) and those with pin-based sockets (class 2) are based 

on the efficacy of the lamps packaged with the light kits. For class 1 and class 2 light kits, 

luminous efficacy is the metric (lumens emitted per watts consumed (lm/W)). Lamps used in 

class 1 light kits must meet the ENERGY STAR Program Requirements for Compact Fluorescent 

Lamps (CFLs), version 3.0 or have equivalent minimum efficacy. Lamps used in class 2 light 

kits must meet the combined lamp and ballast efficacy requirements set out in the ENERGY 

STAR Program Requirements for Residential Light Fixtures, version 4.0. The current DOE test 

procedure references the following IES test procedures, depending on the specific nature of the 

lamp: LM-66 (Electrical and Photometric Measurements of Single-Ended Compact Fluorescent 

Lamps) and LM-9 (Electrical and Photometric Measurements of Fluorescent Lamps). The 

standard for all other ceiling fan light kits (class 3) is based on maximum operating wattage. To 

date, DOE has interpreted that standard as a design standard that requires the inclusion of a 

wattage limiter in class 3 light kits; accordingly, DOE has not established a corresponding test 

procedure for class 3 ceiling fan light kits. 

Table 4-1 summarizes the metrics and test procedures required for compliance with 

DOE’s current standards for ceiling fan light kits. Only those IES test procedures that are 

relevant to the indicated class of ceiling fan light kits are included in the table. 

Table 4-1 Energy Conservation Standards and Efficiency Metrics for Ceiling Fan Light 

Kits 

27
 
 

Product Class Primary Requirement of 

Standard 

Energy Efficiency 

Metric 

[Corresponding 

Test Procedure] 

DOE and 

(Referenced) Test 

Procedures 

Class 1: Medium Package with lamps that Lamp efficacy CFR Appendix V 

screw base (E26) meet the ENERGY STAR 

Program Requirements for 

Compact Fluorescent 

Lamps, version 3.0, or with 

lamps having equivalent 

lm/W performance. 

(lm/W) of Subpart B of 

Part 430 

(IES LM-66) 

Class 2: Pin- The light kit must meet the Lamp efficacy CFR Appendix V 

based fluorescent ENERGY STAR Program 

Requirements for 

Residential Light Fixtures, 

version 4.0: Package with 

compliant lamps to fill all 

sockets. 

(lm/W) 

(outdoor fixtures 

may alternatively 

comply by 

including automatic 

daylight shutoff and 

motion sensor 

controls) 

of Subpart B of 

Part 430 

(IES LM-9) 

Class 3: All other Shall not be capable of Wattage None 

light kits not operating with lamps that 

included in Class total more than 190 watts. 

1 or Class 2 

Review of Current Test Procedures for Ceiling Fan Light Kits 

The ENERGY STAR program requirements included by referenced in the DOE test 

procedures for ceiling fan light kits are no longer current. The current ENERGY STAR Program 

Requirements for CFLs is version 4.3 and it is being replaced by the ENERGY STAR Program 

Requirements Product Specification for Lamps. The ENERGY STAR Program Requirements for 

Residential Light Fixtures have been replaced by the ENERGY STAR Program Requirements for 

Luminaires. Currently the DOE test procedures for class 1 lamps do not include test procedures 

for LED lamps, which can be used in ceiling fan light kits with medium screw based sockets. 

DOE is currently developing test procedures for LED lamps. The current program requirements 

for luminaires now require different test methods for light kits with direction and non-directional 

lighting. While the former still uses lamp photometry, the latter uses luminaire photometry. 

Moreover, the IES test procedures referenced in the ENERGY STAR test procedures have been 

updated. For example, the current version of LM-66 is LM-66-11, whereas the version 

referenced in current DOE test procedure is LM-66-00. 

Preliminary Proposals for Test Procedure Amendments 

28
 
To eliminate the confusion of multiple metrics and test procedures, and to reduce the cost 

of testing for ceiling fan light kits, DOE is considering adopting a single metric, luminous 

efficacy, for all ceiling fan light kits. All test lamp test procedures would reference the existing 

DOE test procedure, if such a test exists for a given lamp type, or would include a separate 

method of test, where needed. Testing would apply to the models of lamps packaged with, or 

integrated into, the ceiling fan light kit. Ceiling fan light kit manufacturers would be required to 

package with lamps that individually or together meet the light kit efficacy requirements set forth 

by this rulemaking. Ceiling fan light kit manufacturers could rely upon lamp manufacturers for 

the testing and rating of the bulbs that are to be packaged with the light kits. Applying this 

proposed approach to all ceiling fan light kits would eliminate the need to include wattage 

limiters in class 3 light kits. 

For ceiling fan light kits packaged with consumer replaceable lamps (e.g., screw-based 

sockets, pin-based fluorescents, replaceable light-emitting diodes (LEDs)), DOE is considering 

requiring testing based on lamp system photometry, where the lamp system includes the 

reference ballast or driver, if a ballast or diver is necessary to operate the lamps. 

Lamps with existing DOE test procedures would be tested according to their DOE test 

procedure. For the types of lamps currently included in ceiling fan light kits there are currently 

DOE test procedures of medium screw based incandescent lamps and medium screw based 

compact fluorescent lamps (CFLs) that are integrally ballasted. DOE test procedures are under 

development for LED lamps and are being updated for other types of CFLs. For lamps used in 

ceiling fan light kits for which DOE test procedures do not exist, DOE is considering the latest 

version of the appropriate IES test procedure for the appropriate type of lamps incorporated into 

ceiling fan light kits: 

LM-9: Electrical and Photometric Measurements of Fluorescent Lamps 

LM-20: Approved Method for Photometric Testing of Reflector-Type Lamps 

LM-45: Electrical and Photometric Measurements of General Service Incandescent 

Filament Lamps 

LM-66: Electrical and Photometric Measurements of Single-Ended Compact Fluorescent 

Lamps 

LM-79: Electrical and Photometric Measurements of Solid-State Lighting Products 

DOE is aware that ceiling fan light kits with LEDs may be designed such that the light 

source component (i.e. LED package, array, module, or light engine) cannot be easily removed 

or replaced by the end user, thus requiring replacement of the entire ceiling fan light kit. For 

these ceiling fan light kits with inseparable LED lighting components, DOE is considering the 

inseparable solid-state lighting (SSL) luminaire test procedures specified in the latest version of 

ENERGY STAR Program Requirements for Luminaires. DOE is also considering photometric 

testing of the LED light engine. 

DOE is considering two approaches to using the luminous efficacy of the packaged lamps 

(or integrated light sources) to determine ceiling fan light kit efficacy. The first follows the 

29
 
current approach in which all individual lamps packaged with the ceiling fan light kit (or 

integrated into the ceiling fan light kit) must meet a minimum standard. The second approach 

would define ceiling fan light kit efficacy as the total lamp lumens divided by the total input 

wattage, where this metric would be derived from data reported for lamp certification, requiring 

that lamps lumens and watts are reported individually. 

The two approaches to using lamp efficacy in support of a ceiling fan light kit energy 

conservation standard would yield different results under the following conditions: If the 

packaged lamps perform better than the minimum required, and if lamps with different efficacies 

used in the same ceiling fan light kit. The first approach is advantageous for its simplicity. The 

latter is advantageous in that is offers additional flexibility in meeting the standard in cases 

where different types of lamps are used in the same ceiling fan light kit. It also provides 

consumers with a more accurate indication of the actual performance of the ceiling fan light kit 

as purchased, as opposed to just an indication of its minimum performance requirement. 

Item 23 DOE requests comments on its proposal to use 

luminous efficacy as the efficiency metric for all 

ceiling fan light kits. 

Item 24 DOE requests comment on the proposal to base test 

procedures to determine ceiling fan light kit efficiency 

on the following IES lamp photometry test procedures: 

LM-9, LM-66, LM-45, and LM-79, depending on light 

source type. 

Item 25 DOE requests information on the existing and/or 

future market availability of ceiling fan light kits with 

inseparable LED lighting components. 

Item 26 DOE requests comment on using guidance provided in 

the latest version of the upcoming ENERGY STAR 

Program Requirements for Luminaires for testing 

ceiling fan light kits with inseparable LED lighting 

components. 

Item 27 DOE requests comment on the advantages or 

disadvantages of defining ceiling fan light kit efficacy 

as the total lamp lumens divided by the total input 

wattage. 

30
 
 

5 

Standby Power 

DOE test procedures for ceiling fan light kits currently do not address standby mode. 

DOE believes that ceiling fan light kits do not consume power in off mode and should consume 

power in standby mode only if they are controlled via remote control. If the standby sensor and 

controller are shared between the ceiling fan and the ceiling fan light kit, DOE plans to account 

for the energy consumption in standby mode under the ceiling fan efficiency metric and not 

under the ceiling fan light kit luminous efficacy metric. DOE is not currently aware of any 

ceiling fan light kits sold with a separate remote or sensor, which operates independently from 

the ceiling fan controls (that is, for which the control circuits are separate). 

Item 28 DOE requests input on whether ceiling fan light kits, 

or ceiling fan light kit controls, exist that have a 

standby mode and that operate independent of the 

ceiling fan. If such devices exist, DOE requests 

comment what fraction of controllers that are of this 

type, the power draw in standby mode, and the 

fraction of time they spend in standby mode. 

Item 29 DOE requests feedback on its planned approach to 

attribute all standby power to the ceiling fan if ceiling 

fan standby is managed by a controller that is shared 

between the ceiling fan light kit and its ceiling fan. 

OVERVIEW OF ANALYSES FOR ENERGY CONSERVATION STANDARDS 

RULEMAKING 

DOE performs a range of analyses to ensure that it selects energy conservation standards 

that achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified and will result in significant energy savings, as required by EPCA. 

Economic justification includes the consideration of economic impacts on manufacturers and 

consumers, national benefits (including environmental impacts), issues of consumer utility, and 

impacts from any lessening of competition. DOE expects the selection of standards to achieve 

the maximum energy savings that are technologically feasible and economically justified without 

imposing excessive financial burden on any particular party. 

31
 
Figure 5-1 summarizes the analytical components of DOE's standard-setting process. 

The analyses are listed in the third column. Each analysis requires a set of key inputs comprising 

data and information required for the analysis. The identified approaches are the methods that 

DOE will use to obtain key inputs, which may vary depending on the information in question. 

For example, some key inputs can be found in public databases. In support of this rulemaking, 

DOE will collect other information from interested parties or experts having special knowledge, 

and DOE itself will develop relevant information independently. The results of each analysis are 

key outputs that feed directly into the rulemaking. Arrows indicate the flow of information 

among the various analyses. DOE ensures a consistent approach to its analyses throughout the 

rulemaking by considering each analysis as a part of the overall standard-setting framework. 

32
 
 

 

 

 

 

 

 

Approaches Key Inputs Analyses Key Outputs 

Preliminary Analysis (based on Framework Document) 

Market and Technology 

Assessment 

• Product Classes 

• Technology Options 

• Characterize Industry 

• Market Segmentation 

• Non-Regulatory Programs 

• Identify Firms/Products 

• Historical Shipments 

• Analysis of Market Data 

Screening Analysis 

Engineering Analysis 

Markups for 

Equipment Price 

Determination Life-Cycle Cost and 

Payback Period 

Analysis 

National Impact 

Analysis 

Energy Use 

Analysis 

Shipments 

Analysis 

• Cost-Efficiency Relationship 

• Life-Cycle Costs 

• Payback Periods 

• National Energy Savings 

• Net Present Values 

• Efficiency-Level Approach 

• Design Option Approach 

• Energy Prices 

• Installation Costs 

• Maintenance & Repair Costs 

• Accounting Approach 

• Backcast and Forecast 

• Market Saturation 

• Define Distribution Channels 

• Economic Census Data 

Analysis 

• Retail Price Collection and 

Analysis 

Design Options 

Product Classes 

Retail Prices 

Design Energy 

• Efficiency/Performance 

• Manufacturing Cost 

Candidate 

Standard 

Levels 

• Analysis of Energy Use 

Data 

Technology Options 

• Design Options 

• Energy Price Forecasts 

• Site-to-Source Factors 

• Energy-Efficiency Levels 

• Analysis of Product Data 

• Installation 

Costs 

• Maint Costs 

• Repair Costs 

• UEC 

• Energy 

Prices 

• Annual Energy Use (UEC) 

Preliminary 

Manufacturer Impact 

Analysis 

• Manufacturer Prices 

• Average Costs 

• Conversion Capital Expenditures 

• Direct Employment Impacts 

• Product Prototypes 

Energy-Efficiency 

Levels 

Utility Impact 

Analysis 

Revise Preliminary 

Analyses 

Consumer 

Sub-Group Analysis 

Manufacturer Impact 

Analysis 

Employment Impact 

Analysis 

• Industry Cash Flow 

• Sub-Group Cash-Flow 

• Direct Employment Impacts 

• Competitive Impacts 

• Cumulative Regulatory Burden 

• National Employment Impacts 

• Stakeholder Comments 

• Demographics 

• Manufacturer Interviews 

• GRIM Analysis 

• Emission Rates 

• National Energy Savings 

• Manufacturer Prices 

• Average Costs 

• Manufacturer Financial Data 

Preliminary Analysis 

Environmental 

Assessment 

Regulatory Impact 

Analysis 

• Emission Estimates 

• Utility Load Factors 

• National Energy Savings 

• Non-Regulatory 

Alternatives 

• NEMS-BT 

• IMSET 

• NEMS-BT 

• Direct Employment Impacts 

• National Energy Savings 

• National Product Costs 

• National Operating Costs 

• Utility Impacts 

• Life-Cycle Costs 

• Payback Periods 

• National Energy Savings 

• Net Present Values 

• Trial Standard Levels (TSLs) 

TSLs 

Final Rule Analysis 

Revise Analyses • Revised Results • Stakeholder Comments 

• Department of Justice Review 

Preliminary TSD 

NOPR TSD 

Final Rule TSD 

Figure 5-1 Flow Diagram of Analyses Conducted for an Energy Conservation 

Standard Rulemaking 

33 
6 MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment will provide information about the ceiling fan and 

ceiling fan light kit industries, and the performance attributes of these products. DOE uses this 

information throughout the rulemaking. It is important to perform the market and technology 

assessment at the outset of the rulemaking in order to develop product classes and to identify 

design options or efficiency levels for each product class of ceiling fan and ceiling fan light kit 

being considered in this rulemaking. 

6.1 Market Assessment 

In the market assessment, DOE will characterize qualitatively and quantitatively the 

structure of the markets for ceiling fans and ceiling fan light kits. DOE will identify and 

characterize the manufacturers of the products, estimate market shares and trends, address 

regulatory and non-regulatory initiatives intended to improve the efficiency or reduce the energy 

consumption of covered products, and explore the potential for technological improvements in 

the design and manufacturing of such products. 

The market assessment enables DOE to gather data that will help identify issues 

important to the rulemaking (e.g., potential small business impacts, competitive disruptions, and 

other factors that may arise from enacting standards). The market assessment will establish the 

context for this rulemaking and will serve as a resource to guide the analyses that follow. For 

example, DOE will use historical product shipments and prices as a starting point for forecasting 

future shipments and prices. Market structure data will be particularly useful for assessing 

competitive impacts for the manufacturer impact analysis. The assessment also enables DOE to 

start updating design options by reviewing product literature, industry publications, and company 

websites. 

There may be limited public information on national shipments, manufacturing costs, 

channels of distribution, product lifetimes, and manufacturer market shares of ceiling fans and 

ceiling fan light kits. Such data represent an important input for analyses that determine whether 

energy conservation standards or energy use standards are economically justified and will result 

in significant energy savings. Therefore, DOE encourages interested parties to submit data that 

will improve DOE’s understanding of the ceiling fan and ceiling fan light kits markets. These 

data may be provided under a confidentiality agreement with DOE’s contractor responsible for 

this part of the rulemaking analysis. In other rulemakings, DOE’s contractors routinely work 

with confidential data provided by manufacturers and other organizations in preparing 

aggregated results for DOE’s analyses. These aggregated results do not divulge the sensitive, 

individual raw data, but enable other interested parties to comment on the aggregated dataset. 

Alternatively, interested parties may submit confidential data to DOE, indicating in 

writing, which data should remain confidential. Interested parties must submit confidential 

information to DOE according to the procedures outlined in 10 CFR 1004.11. Pursuant to 10 

CFR 1004.11, any person submitting information that he or she believes to be confidential and 

exempt by law from public disclosure should submit two copies. One copy of the document 

must include all the information believed to be confidential, and the other copy must have the 

34
 
 

 

information believed to be confidential deleted. DOE will make its own determination about the 

confidential status of the information and treat it accordingly.13 

Item 30 DOE requests information that would contribute to the market 

assessment for ceiling fans and ceiling fan light kits covered in this 

rulemaking (e.g., current product features and efficiencies, trends 

in product features and efficiency, and historical product 

shipments and prices). 

Item 31 DOE welcomes input on estimates of market shares, products, 

features, and trends for the ceiling fans and ceiling fan light kits 

covered in this rulemaking. 

6.1.1 Manufacturer Trade Group 

DOE recognizes the importance of trade groups in disseminating information and 

promoting the interests of the industry that they support. DOE identified the ALA as the primary 

group that supports, and has an interest in, ceiling fans and ceiling fan light kits. The ALA is a 

trade organization that represents lighting (including ceiling fan light kits) and ceiling fan 

manufacturers, designers, retail showrooms, and distributors working to promote the sale and 

proper use of quality residential lighting products. The ALA provides specific information 

regarding the selection, benefits, and proper use of ceiling fans. The ALA also advocates the 

interests of the industry regarding Federal and State legislative and regulatory issues. 

Ceiling fan light kit manufacturers do not manufacture their kits’ light sources, which 

manufacturers are required to package with their light kits, according to current energy efficiency 

standards. (42 U.S.C. 6295(ff)) Traditional lighting companies such as General Electric, 

Philips, and OSRAM SYLVANIA generally produce the light sources (consumer replaceable 

lamps), which are purchased by the ceiling fan light kit manufacturers. The National Electrical 

Manufacturers Association represents those traditional light source companies. 

6.1.2 Manufacturers and Market Shares 

This section describes major ceiling fan and ceiling fan light kits retailers and 

manufacturers and their market shares, historical shipments, saturation levels, and product 

lifetimes. 

13 Factors that DOE considers when evaluating requests to treat submitted information as confidential include: (1) a 

description of the items; (2) whether and why such items are customarily treated as confidential within the industry; 

(3) whether the information is generally known by or available from other public sources; (4) whether the 

information has previously been made available to others without obligation concerning its confidentiality; (5) an 

explanation of the competitive injury to the submitting person which would result from public disclosure; (6) a date 

after which such information might lose its confidential character; and (7) why disclosure of the information would 

be contrary to the public interest. 

35
 
 

6.1.2.1 Retailers 

Ceiling fans and ceiling fan light kits generally are available to consumers from so-called 

brick-and-mortar retailers, Internet sellers, and ceiling fan and lighting showrooms. 

Brick-and-mortar retailers have a physical retail building that consumers can visit to view 

products and make purchases. There are several sub-types in this category, including: 

	 Mass market retailers—national chain stores such as home centers, discount stores, 

and hardware stores; 

	 Regional stores, which may have multiple outlets like the mass market retailers, but 

are limited to a single region; 

	 Specialty stores, which usually offer a broad range of products in a narrow product 

category and can be mass market, regional, or independent owners having a single 

retail outlet; and 

	 Club or warehouse stores, which require a membership fee for customers to gain 

access to the goods, which usually are sold in bulk. 

Online sales may be via a division of any of the brick-and-mortar retailers, sometimes 

called “clicks and bricks,” or via a dedicated online retailer. 

Ceiling fan and lighting showrooms typically offer direct-to-builder services as well as a 

front showroom for consumer purchases. Several products will be displayed in the showroom 

similar to other retailers but consumer options are vastly expanded through the ability to order 

through manufacturer catalogues. These showrooms may also offer other builder items such as 

ventilation fans and exit signs. Many of these showrooms also offer sales via the Internet. 

DOE has considered national data from the NPD Group to describe retailers’ market 

shares. NPD does not collect point-of-sales data for ceiling fans and ceiling fan light kits. 

Instead, it surveys a representative sample of consumers who recently purchased a ceiling fan. 

In describing their techniques, NPD stated that they reach out to “approximately 200,000 

panelists each month (equivalent to 100,000 completes) and ask them about their appliance 

purchasing. Specifically, we ask them the appliance purchased, where purchased at, brand 

purchased and price paid as well as a number of other purchase drivers (the “why’s”) regarding 

their purchase. From there, we project this information, using the Census population, to be 

representative of a total U.S. market size estimate. Additionally, we use actual retail POS [pointof-sale] data to inform our consumer-driven market size estimates.” (NPD, personal email 

communication, June 4, 2012.) 

Three so-called “big-box” retailers (Home Depot, Lowe’s, and Wal-Mart) comprise 

approximately 80 percent of the market for ceiling fans purchased in the United States in 2011, 

as shown in Table 6-1. 

36
 
 

 

Table 6-1 Market Shares of Ceiling Fan Retailers in 2011 

Retailer 

Market 

Share % 

Home Depot 36 

Lowe's 32 

Wal-Mart 11 

Menards 4 

Lighting and Electrical Supply 

Store 2 

Ace Hardware 2 

Kmart 1 

Sears 1 

Target 1 

Costco Price Club 1 

Others 9 

Total 100 

Source: NPD Group, 2011. 

6.1.2.2 Major Manufacturers 

Six brands represented more than half of ceiling fan sales in the United States in 2011: 

Casablanca, Emerson, Hunter Fans, Hampton Bay, Harbor Breeze, and Westinghouse.14 

Of those six brands, three (Hunter Fans, Hampton Bay, and Harbor Breeze) represented 

more than 45 percent of the market in 2011. Hampton Bay is a Home Depot brand, and Harbor 

Breeze is a Lowe’s brand. Casablanca is owned by Hunter Fans. A breakdown of ceiling fan 

brands’ market shares based on NPD data is set out in Figure 6-1. 

14 Consumer survey data for 2011 purchased from NPD Group, Inc. 

37
 
Figure 6-1 Market Shares of Ceiling Fan Manufacturers in 2011 (NPD, 2011) 

Generally speaking, the companies that manufacture and market ceiling fan light kits are 

the same companies that produce ceiling fans. According to the ALA, in big-box retail outlets, 

about 90 percent of ceiling fans sold are pre-packaged with light kits produced by or for the fan 

manufacturer, and although only about 50 percent of ceiling fans sold in lighting showrooms 

come pre-packed with light kits, about 95 percent can accommodate them. Also according to 

ALA, about 50 percent of ceiling fans have built-in (non-detachable) light kits. Given the high 

percentage of ceiling fans that were sold by big-box retailers in 2011 (as shown in Table 6-1), 

and the fact that light kits, having no moving parts, should last at least as long as fans and are, 

therefore, unlikely to be replaced during the lifetime of the fan, the light kit market clearly also is 

dominated by the big-box retailers, the largest of which produce their own brands. However, 

light kits are also available for independent purchase, especially online, and most detachable 

light kits can be used with most fans that accept ceiling fan light kits. Therefore, the light kit 

market may not be identical to the ceiling fan market (for which more data are available), but it 

should be similar. 

Findings from surveys conducted for this rulemaking in four Home Depot stores in 

California and Massachusetts and from data purchased from NPD substantiate the ALA 

estimates. Eighty-nine percent of 96 models of ceiling fan sold in the Home Depot stores 

included light kits. According to NPD (2011) consumer surveys, 88 percent of ceiling fans sold 

nationally included light kits. 

 Market shares for ceiling fans for years between 2007 and 2011 are listed in Table 6-2. 

38
 
 

 

 

 

 

 

Table 6-2 Market Shares of Ceiling Fan Manufacturers 

Rank Brand 2007 

% 

2008 

% 

2009 

% 

2010 

% 

2011 

% 

1 Other 43.6 46.4 43.8 41.3 41.8 

2 Hunter 18.6 15.5 15.9 17.3 17.7 

3 Hampton Bay 14.6 12.5 14.6 13.6 15.6 

4 Harbor Breeze 11.8 11.6 11.9 13.2 11.9 

5 Casablanca 4.8 5.1 3.7 5.1 5.0 

6 Westinghouse 3.4 4.1 3.8 3.5 3.1 

7 Emerson 1.9 1.9 2.3 2.2 2.5 

8 Aloha Breeze 0.0 0.9 2.1 1.9 1.1 

9 Impressions 0.4 1.0 0.6 0.5 0.5 

10 Ace 0.0 0.1 0.3 0.4 0.3 

11 Encon 0.3 0.2 0.2 0.4 0.2 

12 Minka Aire 0.2 0.3 0.1 0.1 0.2 

13 Monte Carlo 0.6 0.5 0.5 0.5 0.0 

Total share of top 6 

brands % 

55.0 50.6 52.2 54.9 55.7 

Total share of top 3 

brands % 

44.9 39.5 42.4 44.1 45.2 

Source: NPD Group, 2007-2011. 

Most ceiling fans available on the U.S. market are manufactured (components and 

assembly) in Asia by a variety of manufacturers of various sizes, some of which maintain a 

steady presence in ceiling fan manufacturing and some of which remain only for short periods. 

Therefore, it is difficult to create a complete and accurate list of ceiling fan manufacturers. 

Ceiling fan companies undertake design reviews at least annually to select manufacturers for 

their products. Sometimes more than one factory supplies the same model of ceiling fan, and the 

same factory may make ceiling fans for multiple brands.15 In 2012, for example, manufacturers 

of the Home Depot brand (Hampton Bay), included Air Cool Industrial Co., King of Fans, and 

Hong Kong China Electrical Manufacture Co. Ltd.16 Manufacturers of the Lowe’s brand, Harbor 

Breeze, included Artisan Industrial Co Ltd., Chien Luen Industries Co. Ltd. Inc., China, 

Fanimation Inc., Hong Kong China Electrical Manufacture Co. Ltd., Landmark Enterprise, and 

Litex Industries Inc./Ellington Fans.16 

15 Opinion Dynamics Corporation for The Consortium for Energy Efficiency, Residential Lighting Fixture Market 

Assessment: Ceiling Fans and Outdoor Lighting (2000), and Vin Mehta, personal communication (August 2012). 16 ENERGY STAR. Fans, Ceiling for Consumers.(2012) (List as of August 16th 2012; last accessed August 30, 

2012) (Available at: 

http://www.energystar.gov/index.cfm?fuseaction=find_a_product.showProductGroup&pgw_code=CF); The 

California Energy Commission, Appliance Efficiency Database (2012) (Last accessed August 30, 2012) (Available 

at: http://www.appliances.energy.ca.gov/QuickSearch.aspx). 

39
 
In 2012, ceiling fan manufacturers that appeared on product lists for ENERGY STAR 

and the California Energy Commission16 included: Air Cool Industrial Co., Ltd.; Aloha 

Worldwide Co.; Artisan Industrial Co Ltd., China; Banvil 2000; Big Ass Fans; Canarm Ltd.; 

Casablanca Fan Company; Ceiling Fans Direct Inc.; Chien Luen Industries Co. Ltd., Inc.; 

Concord Fans; Craftmade International Inc., Emerson Electric, Company, Encompass Lighting 

Group LLC, Epiphany Lighting; Fanimation Inc.; Furn Fan Corporation; Grainger Industrial 

Supply; Gulf Coast Fans Inc.; HD Supply Facilities Maintenance; Hong Kong China Electrical 

Manufacture Co. Ltd.; Hunter Fan Company; Kendal Lighting; Kichler Lighting; King of Fans; 

King One Products Co.; Lamps Plus Corporate; Landmark Enterprise; Light Process Company; 

Litex Industries, Inc./Ellington Fans; Minka Group; Modern Fan Company; Monte Carlo Fan 

Company; Nicor Inc.; Orgill Inc.; Palm Coast Imports; Progress Lighting; Project Lighting 

Company, Inc.; Quorum International; Regency Ceiling Fans; Royal Pacific Ltd.; Savoy House; 

Sea Gull Lighting Products LLC; Sunset Lighting and Fans; Sunway Fan Company, Inc.; Vaxcel 

International Trading Co. Ltd.; Volume International Corporation; Westinghouse Lighting 

Corporation; Westwind Products Inc.; Yellow Energy; and Yu Yuan Industrial Co., Ltd. 

An August 2012 sample list of ENERGY STAR partners who manufacture ceiling fan 

products qualified for ENERGY STAR version 3.0 is provided in Table 6-3. Note that this list is 

updated regularly as new products are certified. 

Table 6-3 Sample List of ENERGY STAR Partners Manufacturing Version 3.0 

Qualified Ceiling Fans With and Without Light Kits 

ENERGY STAR Partner 

Ceiling 

Fan Only 

Ceiling Fan with 

Light Kit 

Air Cool Industrial Co., Ltd. X X 

Artisan Industrial Co., Ltd. X 

Banvil 2000 X 

Big-Ass Fans X 

Chien Luen Industries Co. 

Ltd., Inc. X X 

Concord Fans X 

Emerson Electric Company X 

Epiphany Lighting X 

Fanimation Inc. X X 

Generation Brands X 

HD Supply Facilities 

Maintenance X 

Hunter Fan Company X X 

Kendal Lighting X 

Kichler Lighting X X 

King of Fans X X 

Lamps Plus Corporate X 

Litex Industries, Inc./ 

Ellington Fans X 

Minka Group X X 

40
 
 

 

ENERGY STAR Partner 

Ceiling 

Fan Only 

Ceiling Fan with 

Light Kit 

Orgill, Inc. X 

Progress Lighting X 

Quorum International X X 

Ralada International Ltd., X 

Regency Ceiling Fans X 

Royal Pacific Ltd. X 

Savoy House X 

Summerwind International 

Limited X X 

Sunway Fan Company, Inc. X 

Volume International 

Corporation X 

Westwind Products Inc. X 

Yellow Energy X 

Yu Yuan Industrial Co., Ltd. X 

Source: EPA, Fans, Ceiling for Consumers (2012) (List updated August 16, 2012; last accessed August 30, 2012) 

(Available at. 

http://www.energystar.gov/index.cfm?fuseaction=find_a_product.showProductGroup&pgw_code=CF). 

6.1.2.3 Historical Shipments 

In evaluating overall U.S. shipments, DOE has considered data from three sources: (1) 

NPD; (2) ENERGY STAR; and (3) Appliance Magazine. DOE collated the data sets for their 

different time periods and different methodologies based on considering the market from 

different viewpoints. 

NPD data were described in section 6.1.2.1. Shipments data from Appliance Magazine 

were extracted from that source’s annual statistical review of the U.S. appliance industry.17 

Appliance Magazine sources may include Appliance Magazine, the Air-Conditioning and 

Refrigeration Institute; Association of Home Appliance Manufacturers; Consumer Electronics 

Association; Gartner; Gas Appliance Manufacturers Association; Hearth, Patio & Barbeque 

Association; International Data Corporation; Outdoor Power Equipment Institute; and the Water 

Quality Association. The data have not included exports since 1997. 

ENERGY STAR shipments and market share data are reported for two categories, 

namely ENERGY STAR-qualified ceiling fans with and without light kits. ENERGY STAR 

takes partner-reported data to be representative of qualified ceiling fan shipments without 

adjusting for partners who do not report their shipments. This means that the ENERGY STAR 

data represent a conservative estimate, although the response rate among ceiling fan 

manufacturers is typically high, for example, 89 percent in 2010. 

In order to estimate the market share of ENERGY STAR-qualified ceiling fans, 

ENERGY STAR estimates U.S. shipments based on modeled and documented data. Ceiling fan 

17 Appliance® Statistical Review, Annual Report, Appliance Magazine (2003-2006) 

41
 
industry data are used as a direct input whenever possible and compared to forecast assumptions 

to ensure data comparability. Industry sources may include ceiling fan manufacturer 

associations, publications, and commercially-available market research. 

Market shares for ENERGY STAR-qualified products, as reported by ENERGY STAR, 

are shown in Table 6-4. Market shares of qualifying ceiling fans sold with light kits are low, 

because only pin-based fluorescents could qualify under the existing ENERGY STAR 

requirements. 

Table 6-4 Historical Shipments and Market Shares of ENERGY STAR-Qualified 

Products Only 

Year Ceiling Fans Ceiling Fans Light Kits Manufacturer Reporting 

Without Light with Light Kits Only Information 

Kits 

Total % Total % Total % No. Partners % 

U.S. ES* U.S. ES U.S. ES Respondents 

2004 2,631,000 34 166,000 2 24,900 1 23 91 

2005 3,022,565 39 368,355 4 130,276 6 25 100 

2006 1,845,052 24 117,289 1 11,952 1 27 93 

2007 2,646,934 34 132,100 1 21,120 1 29 97 

2008 2,500,309 32 126,769 1 45,436 2 32 100 

2009 1,266,000 16 219,000 2 61,000 3 37 100 

2010 1,394,000 18 304,000 3 171,000 8 46 89 

Source: http://www.energystar.gov/index.cfm?c=partners.unit_shipment_data. 

Note: Reported ENERGY STAR units shipped are values reported by manufacturers, and they are not amended for 

missing data.
 

*ES = ENERGY STAR.
 

Historical NPD shipments data are shown in Table 6-5. Note that the NPD consumer 

survey did not specifically ask whether the ceiling fan light kit was already integrated with the 

ceiling fan at the time of purchase or simply purchased at the same time. 

Table 6-5 Historical Shipments of All Ceiling Fans With and Without Light Kits 

Number of 

Units 

2007 2008 2009 2010 2011 

With Light 

Without Light 

Not Specified 

14,899,594 

2,176,229 

3,970,371 

15,485,300 

2,226,826 

3,080,311 

16,015,248 

2,106,832 

3,561,611 

14,414,909 

2,184,390 

2,830,707 

14,597,241 

2,035,746 

2,140,867 

Total 21,046,194 20,792,436 21,683,691 19,430,006 18,773,853 

Source: NPD Group (2007-2011). 

Overall shipments based on NPD, ENERGY STAR, and Appliance Magazine data are 

fairly consistent, as shown in Table 6-6. The ENERGY STAR shipments data for all U.S. ceiling 

fans included in Table 6-6 have been calculated from the estimates of shipments and market 

shares of ENERGY STAR-qualified ceiling fans. ENERGY STAR shipments are divided by 

42 
     

 

 

market share to estimate the total U.S. shipments for ceiling fans both with and without light kits. 

The total U.S. shipments are the sum of the U.S. shipments for those two categories. 

Table 6-6 Comparison of Historical Shipments of Ceiling Fans from Different Data 

Sources 

Total No. of Units 

’000 2003 2004 2005 2006 2007 2008 2009 2010 2011 

ENERGY STAR 

Appliance 

Magazine 

NPD 

16,664 

15,500 

N/A 

16,038 

16,700 

N/A 

16,959 

16,800 

N/A 

19,417 

17,000 

N/A 

20,995 

N/A 

21,046 

20,490 

N/A 

20,792 

18,863 

N/A 

21,684 

17,878 

N/A 

19,430 

N/A 

N/A 

18,774 

Sources: NPD (2007-2011); ENERGY STAR (2007-2010); and Appliance Magazine (2003-2006). 

DOE also examined the market makeup on the basis of blade span. More than half of 

ceiling fans sold have blade spans of between 42 and 52 inches. About a quarter have blade 

spans of between 30 and 40 inches. This trend seems reasonably consistent over time. Figure 

6-2 shows market shares of ceiling fans by blade span in 2011. 

30‐40 in

23%

42‐52 in

51%

54 in or

larger

9%

Don't know

5%

Not

Specified

11%

2011

Source: NPD (2011). 

Figure 6-2 Market Shares of Ceiling Fans by Blade Span in 2011 

Market shares by blade span between 2007 and 2011 are displayed in Figure 6-3 and 

Table 6-7. 

43
 
 

 

     

0%

10%

20%

30%

40%

50%

60%

2007 2008 2009 2010 2011

Market share

Year

30‐40 in

42‐52 in

54 in or larger

Don't know

Not Specified

Source: NPD (2007–2011). 

Figure 6-3 Market Shares of Ceiling Fans by Blade Span for 2007–2011 

Table 6-7 Market Share by Blade Span 

Ceiling Fan 

Size 

2007 % 2008 % 2009 % 2010 % 2011 % 

30-40 in. 

42-52 in. 

54 in. or larger 

Don't know 

Not specified 

18 

51 

8 

4 

19 

19 

53 

8 

5 

15 

21 

51 

7 

6 

17 

22 

51 

7 

6 

15 

23 

51 

9 

5 

11 

Source: NPD (2007–2011). 

Note: Values may not add to 100% due to rounding 

6.1.2.4 Saturation 

According to the 2009 Residential Energy Consumption Survey (RECS),18 73 percent of 

U.S. homes had ceiling fans in 2009. Ownership varied significantly by region, ranging from 57 

percent to 85 percent. Figure 6-4 shows U.S. ceiling fan ownership by region. Figure 6-5 shows 

usage by region. 

18 U.S. Department of Energy–Energy Information Administration, Residential Energy Consumption Survey 

(RECS), 2009 RECS Survey Data (2011) (Last accessed Sept. 7, 2012) (Available at: 

http://www.eia.gov/consumption/residential/data/2009/). 

44
 
   

   

   

   

   

               

   

           

   

     

       

     

0% 20% 40% 60% 80% 100%

New England

Middle Atlantic

East North Central

West North Central

South Atlantic

East South Central

West South Central

Mountain North

Mountain South

Pacific

Households in Millions

U.S. Census Division

U.S. Ceiling Fan Ownership by Region and Average

per Household 2009

3+

2

1

0

Source: RECS (2009). 

Figure 6-4 U.S. Ceiling Fan Ownership by Region and Average Number of Ceiling Fans 

Per Household 

0.0

10.0

20.0

30.0

40.0

50.0

60.0

Percentage of households with a ceiling fan

Census Division

2009

Used only a few days or nights,

when really needed

Used quite a bit

Used just about all summer

Not used at all

Source: RECS (2009). 

Figure 6-5 U.S. Ceiling Fan Usage by Region 

45
 
 

 

6.1.2.5 Product Lifetime 

DOE has begun to investigate life expectancy of ceiling fans. Data from Appliance 

Magazine suggest significant variation in the life expectancy of ceiling fans, between 7 and 18 

years.19 Estimates represent expert judgment of Appliance Magazine staff. DOE also notes that 

ceiling fan motors often come with a limited lifetime warranty for the motor, and that a 30-year 

warranty is required for the motor in order for a ceiling fan to qualify for ENERGY STAR. 

DOE anticipates that lifetimes of ceiling fans will vary greatly depending on intensity of usage. 

The variation in usage among regions will be an important factor for DOE to consider. DOE has 

not found significant data on life expectancy of ceiling fans and is unaware of any data on the 

relationship between usage and life expectancy. Therefore, DOE seeks comments, input, and 

data on ceiling fan life expectancy and, in particular, the relationship between ceiling fan usage 

and ceiling fan life expectancy. 

DOE has not found independent data on ceiling fan light kit lifetimes. But DOE does not 

believe that it will need information on ceiling fan light kits lifetimes for this rulemaking, for 

reasons explained in section 11.5. 

Item 32	 DOE seeks input and data on ceiling fan life expectancy and, in 

particular, the relationship between ceiling fan usage and ceiling 

fan life expectancy. 

6.1.3 Product Classes 

When necessary, DOE divides covered products into classes by: (1) the type of energy 

used; (2) the capacity of the product; or (3) any other performance-related feature that justifies 

different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE 

then conducts its analysis and considers establishing separate standard levels for each product 

class. The following sections discuss DOE's approach to establishing product classes for ceiling 

fans and ceiling fan light kits. 

6.1.3.1 Ceiling Fans 

As mentioned previously, DOE defines the term “ceiling fan” to mean “a nonportable 

device that is suspended from a ceiling for circulating air via the rotation of fan blades.” It 

defines “ceiling fan light kit” as “equipment designed to provide light from a ceiling fan that can 

be integral, such that the equipment is attached to the ceiling fan prior to the time of retail sale; 

or attachable, such that at the time of retail sale the equipment is not physically attached to the 

ceiling fan, but may be included inside the ceiling fan at the time of sale or sold separately for 

subsequent attachment to the fan.” 10 CFR 430.2. 

19 Appliance Magazine, The 22nd Portrait of the U.S. Appliance Industry (2001). 

46
 
DOE proposes that product classes be determined on the basis of functionality delivered 

to the consumer. DOE does not plan to differentiate product classes based on the type of energy 

used, because all ceiling fans and ceiling fan light kits are powered by electricity. Neither does 

DOE plan to differentiate product classes based on capacity (or blade span, as applied to ceiling 

fans) of the product, because DOE instead plans to account for blade span by developing a 

relationship between efficiency and blade span and applying it to the engineering analysis. DOE 

plans to examine a range of blade sizes to determine if there is a functional relationship between 

fan efficiency and blade size. In analyzing the cost of efficiency improvements (described in 

subsequent sections of this document), DOE plans to examine representative ceiling fan blade 

span sizes as part of the process of developing a continuous specification relating airflow 

efficiency or energy consumption limits to blade span. For example, ceiling fan standards could 

be in a form in which the minimum efficiency for a given fan is determined by an equation that 

takes into account the fan’s blade span. 

In DOE’s previous rulemaking addressing ceiling fans, DOE did not establish any 

product classes for ceiling fans. 71 FR 71340 (Dec. 8, 2006). In that rulemaking, DOE did not 

establish standards for ceiling fans beyond the design standards in section 325(ff) of EPCA, 

which apply to all ceiling fans. (42 U.S.C. 6295(ff)). DOE also interpreted hugger fans as falling 

outside the definition of “ceiling fan” and did not define “highly decorative fans for which air 

movement performance is a secondary design feature.” Thus, the requirement for DOE to 

consider whether highly decorative fans should be a separate exempted product class did not 

need to be addressed at that time. 71 FR 71340, 71343 (Dec. 8, 2006). In this rulemaking, DOE 

proposes to reinterpret the definition of “ceiling fan” to include hugger fans. DOE also must 

consider establishing “separate, exempted product classes for highly decorative fans for which 

air movement performance is a secondary design feature.” (42 U.S.C. 6295(ff)(6); see section 

2.1) Accordingly, in this rulemaking DOE is considering establishing separate product classes 

for both hugger fans and highly decorative fans for which air movement performance is a 

secondary design feature. 

With regard to hugger fans, DOE contends that they, like other types of ceiling fans, 

move air via the rotation of fan blades, are intended to improve comfort, and are rated on their 

ability to move air (as measured in CFM). DOE has tentatively concluded that the only 

distinguishing feature of hugger fans is that they can be used in rooms with lower ceilings. 

Using typical ceiling fans (i.e., ones with a downrod) in rooms having lower ceilings can create 

safety issues, thereby making hugger fans useful in those circumstances. For these reasons, DOE 

is proposing to establish a separate product class for hugger fans. 

As noted above, DOE is proposing to define “highly decorative fans for which air 

movement performance is a secondary feature” as“a nonportable device that is suspended from a 

ceiling, and that circulates air via the rotation of fan blades at a maximum rotational speed of 50 

RPM.” DOE is considering establishing a separate product class for this category if it finds that 

there are fans that meet this definition. 

DOE notes that most ceiling fans are sold with a rating that specifies the type of 

environment in which they can be safely used (e.g., indoor, wet, or damp). Wet-rated or damprated ceiling fans are suitable for use outdoors and in humid environments such as bathrooms. 

47
 
 

Both types may be classified together as outdoor ceiling fans. As with other ceiling fan types, 

they move air via rotation of fan blades, are intended to improve comfort, and are rated on their 

ability to move air (as measured in CFM). Such ceiling fans are designed somewhat differently 

than indoor ceiling fans in that the blades often are made of different material (or with a different 

finish), and the motor housing is sealed to prevent damage from water or water vapor. DOE is 

considering creating a separate product class for outdoor ceiling fans in order to take into 

account the additional costs associated with these products. DOE seeks comment on whether it 

would be appropriate to differentiate product classes for ceiling fans based on the type of 

environment in which they can be used. 

Most ceiling fans are aimed at conventional indoor use. In order to distinguish these fans 

from outdoor fans, DOE proposes to create a product class for indoor ceiling fans. 

DOE is considering creating the following product classes based on functionality 

delivered to the consumer. At this time DOE knows of no performance-related features that 

would require establishing additional product classes beyond the following. 

1.	 Indoor ceiling fans. These products represent the bulk of the market. Air 

movement performance is a primary feature, but these products may not be 

suitable for use in damp or wet conditions and are not designed to be mounted 

flush with the ceiling. 

2.	 Hugger fans. These products also have air movement performance as a primary 

feature, but they can be used in rooms that have low ceilings. DOE is proposing 

to include multi-mount fans in this product class. 

3.	 Highly decorative ceiling fans. These are products for which aesthetics and 

ambiance are of primary concern and for which air movement performance is a 

secondary feature. 

4.	 Outdoor ceiling fans. These products can be used in wet or damp conditions, for 

instance in bathrooms or on a covered porch. Air movement performance is a 

primary feature for these fans. 

DOE seeks comment on its approach for differentiating product classes for ceiling fans 

and on any other potential methods for establishing product classes that fulfill the requirements 

of 42 U.S.C. 6295(q). 

Item 33 DOE welcomes comments on whether it should establish a 

separate product class for hugger fans. 

48
 
Item 34 DOE welcomes comments on whether it should establish a 

separate product class for “highly decorative fans for which air 

movement performance is a secondary feature.” DOE also seeks 

input on whether such ceiling fans should be subject to or 

exempted from energy conservation standards. 

Item 35 DOE seeks input on whether the differences between the 

construction of outdoor and indoor ceiling fans warrants 

establishing a separate product class for outdoor ceiling fans. 

Item 36 DOE seeks feedback from interested parties on its general 

approach to developing product classes. 

6.1.3.2 Ceiling Fan Light Kits 

As previously discussed, DOE currently divides ceiling fan light kits into three products 

classes, depending on the type of light socket: (class 1) medium screw based, (class 2) pin-based 

fluorescent, and (class 3) all other types. Table 6-8 summarizes the primary requirements of the 

energy conservation standards for the different product classes and the energy efficiency metrics 

used. 

Table 6-8 Energy Conservation Standards and Efficiency Metrics for Ceiling Fan Light 

Kits 

Product Class Primary Requirement of 

Standard 

Energy Efficiency 

Metric 

[Corresponding 

Test Procedure] Source 

Class 1: Medium 

screw base (E26) 

Package with compact 

fluorescent lamps (CFLs) 

that meet the ENERGY 

STAR requirements for 

CFLs, version 3, or with 

lamps having equivalent 

lm/W performance. 

Lamp efficacy 

(lm/W) 

CFR 430.32(s)(2); 

42 U.S.C. 

6295(ff)(2) 

Class 2: Pinbased fluorescent The light kit must meet the 

ENERGY STAR 

requirements for 

residential light fixtures, 

version 4.0 and be 

packaged with lamps to fill 

all sockets. 

Lamp efficacy 

(lm/W) 

CFR 430.32(s)(3); 

42 U.S.C 

6295(ff)(3) 

Class 3: All other 

light kits not 

included in Class 

1 or Class 2 

Shall not be capable of 

operating with lamps that 

total more than 190 watts. 

Wattage limit CFR 430.32(s)(4); 

42 U.S.C 

6295(ff)(4) 

49
 
 As mentioned in section 4.1.2.2, DOE is considering combining or restructuring ceiling 

fan light kit products classes from the current three into one or two product classes if the 

following conditions are met: (1) DOE finds that a common efficiency standard level is 

technically feasible and economically justified, (2) it does not result in backsliding within any of 

the original product classes, and (3) and if the products are found to offer the same consumer 

utility. Separate product classes typically are established when products offer significantly 

different consumer utility. DOE is not aware of any differences in consumer utility among the 

three product classes. 

DOE believes that the current system, in which multiple metrics are utilized for 

compliance, is atypical and unnecessarily complicated. DOE is considering moving to a single 

metric (lumens per watt (lm/W)) for all product classes (see section 4.1.2.2). DOE is also aware 

that there are ceiling fan light kits that are packaged with or have integrated dimming 

functionality and that these products may offer unique performance characteristics and consumer 

utility over ceiling fan light kits that are not packaged with dimming functionality, but which 

may allow for separately packaged dimming functionality. 

Item 37 DOE requests feedback on the possibility of combining or 

restructuring product classes for ceiling fan light kits specifically 

on: (i) significant consumer utility differences among ceiling fan 

light kits; (ii) which products should be combined; and (iii) what 

issues should be considered. 

Item 38 DOE requests feedback the consumer utility of ceiling fan light kits 

that are packaged with dimming functionality. 

6.2 Technology Assessment 

The technology assessment centers on understanding how ceiling fans and ceiling fan 

light kits use energy and on identifying potential technological changes that may improve the 

efficiency of these products. Measures that improve the energy efficiency of the product are 

called “technology options,” and they are based on existing technologies, as well as prototype 

designs and concepts. In consultation with interested parties, DOE will develop a list of 

technology options for consideration in this rulemaking. Following research into this list of 

technology options, DOE will consider each one against four screening criteria: (1) technological 

feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product 

utility or availability; and (4) adverse impacts on health or safety. The screening analysis is 

discussed in further detail in section 7. Those technology options that pass the four screening 

criteria become “design options” and will be considered in the engineering analysis as 

appropriate ways of improving the efficiency and will assist DOE in determining the “max-tech” 

design. 

The following sections discuss potential technology options for ceiling fans and ceiling 

fan light kits. 

50
6.2.1 Improving Ceiling Fan Efficiency 

Ceiling fan airflow efficiency is the ratio of the volume of air moved by the fan in a given 

interval of time to the amount of electricity consumed. This air movement depends on three 

factors: (1) blade design (including number and shape of blades); (2) motor type and design; and 

(3) installation location (the distance from the ceiling and from the floor/person being cooled). 

The three factors can be subdivided into the following seven factors. 

1.	 Blade pitch, which is the angle of the blade relative to the fan. The steeper the 

blade pitch, the more air the blade will move with each sweep. A steep pitch, 

however, also increases the amount of energy required to move the fan. Thus, a 

balance is sought between maximizing blade pitch without overworking the 

motor. Since the optimal pitch depends on the size, shape, and speed at which a 

ceiling fan is operating, it is difficult to isolate it as a separate variable, and 

instead, it will be incorporated into the general analysis of fan blade shape. 

2.	 Blade shape and width. As with pitch, the shape and width of the fan blade will 

have a large impact on the amount of air the fan can move and the energy needed 

to move it. A wider blade will move more air, but it will place a greater burden 

on the motor. 

3.	 Number of blades. Fewer blades increase efficiency and RPM but can also have 

an impact on air noise due to the increased RPM. 

4.	 Blade span. Longer blades move more air than smaller blades at a given RPM. 

As with wider blades, longer blades may place a greater burden on the motor, or 

require a larger motor. 

5.	 RPM, which is the number of blade rotations in a minute and a measure of the 

ceiling fan speed. There are tradeoffs between greater airflow and increased 

energy consumption at higher RPMs, as well as safety issues associated with very 

high RPMs. Ceiling fans sold in the U.S. are required to have adjustable speed 

controls and typically have 3 or 4 RPM options. Since RPM is directly related to 

airflow and airflow is addressed through the other factors listed here, DOE does 

not consider RPM a separate design option. 

6.	 Height from ceiling and floor. Fans that are mounted closer than 9 inches to the 

ceiling are more likely to wobble and shudder because of resonance effects on the 

shorter pendulum arm resulting from any imbalance of the blades or electrical 

forces in the motor. Fans that are mounted close to the ceiling cannot efficiently 

move as much air, because the proximity of the ceiling limits access to air supply 

and restricts heat dissipation from the motor, thereby requiring motors that do not 

produce as much heat. 

7.	 Motor. Different types of ceiling fan motors are capable of different levels of 

electrical efficiency. 

51
 
 

 

 

 

 

In addition to these seven factors that can influence airflow efficiency, occupancy sensors 

can also have an impact on the overall efficiency of a ceiling fan. Occupancy sensors can save 

energy by signaling to a ceiling fan to power down if a room is unoccupied. 

Figure 6-6 shows some of the key elements of a ceiling fan that can be improved to 

reduce energy consumption. 

Source: Sathaye et al. (2012).20

Occupancy Sensor 

Switch 

Blade 

Motor 

Electronic Speed Control (for 

brushless DC motor) 

Capacitor Speed Control 

(for AC induction motor) 

Image Sources
 

Fan: Aavaas (2011).
 

Sofa: shutterstock (2011). 

Sensor: Schneider Electric (2011). 

Figure 6-6 Depiction of Ceiling Fan System Components That Can be Improved to 

Reduce Energy Consumption 

The key design factors that can be modified to affect the efficiency of ceiling fans are 

motors and fan blades. 

6.2.1.1 Motors 

The electric motor that powers the fan is among the most important factors in 

determining the energy efficiency of a ceiling fan. The primary component of ceiling fan motors 

is the rotor that converts electromagnetic force into mechanical rotation to drive the fan blades. 

The rotor consists of a stack of steel sheets that has slots set at a specific angle and injected with 

aluminium. The stator contains the main and auxiliary windings that create the magnetic force 

used to drive the fan rotor. Magnetic force travels along the stationary slots of the stator to the 

rotor through the air gap between stator and rotor, driving the rotor. Higher quality motors tend 

to use silicon steel, which reduces loss of power in the rotor compared to cold-rolled steel (CRS) 

which is often used in cheaper motors. 

20 Sathaye, N., Phadke, A., Shah, A., and Letschert, V. (LBNL, EETD), Potential Global Benefits of 

Improved Ceiling Fan Energy Efficiency (2012). 

52
 
 

The most common ceiling fan motor is a single-phase induction motor (permanent-split 

capacitor type) with an external rotor. The efficiency of such motors can be improved by 

increasing the size of (or the quality of steel used in) the stator and rotor stack, improving the 

lamination design, increasing the cross section of copper wiring, or operating the fan at reduced 

speed through capacitor speed control. 

Most induction motors are mounted to the fan blades directly. This configuration is 

known as direct-drive and means that the fan and motor rotate at the same speed. In principle, 

ceiling fans could attach the fan blades to the motor via a geared mechanism that allows the fan 

blades to rotate at a different speed than the motor (a technology used in many industrial fans). 

This would enable higher motor speeds for a given fan RPM, which could increase overall 

efficiency. 

The most efficient ceiling fans on the market have brushless direct current (BLDC) 

motors. BLDC motors are permanent magnet synchronous alternating current (AC) motors 

driven by a converter plus inverter combination control system. In this configuration, the motor 

displays characteristics of direct current motors; thus, they are called brushless direct current 

motors. Because there is no electrical current flowing in the rotor of a BLDC motor, there are no 

rotor energy losses, thereby resulting in greater efficiency. While a typical ceiling fan has an 

efficiency of about 86 CFM/W, fans that have a BLDC motor are capable of efficiency ratings of 

more than 300 CFM/W. These fans tend to be higher-end products, and the increase in 

efficiency is likely attributable not only to the motor type but also to other design features (e.g., 

the blade shape and number of blades). Another advantage of these motors is that they tend to be 

smaller and make less noise than those found in traditional ceiling fan motors. One disadvantage 

of BLDC motors is that the lifetime of the motor may be less than the lifetime of an induction 

motor due to the electronic controls required to run the BLDC motor. 

Although BLDC motors are more common in premium fans (in terms of other features 

such as materials and design), some manufacturers include more-expensive BLDC motors in 

lower-priced, conventional ceiling fans, which may have been achieved by compromising on 

other features, such as including a less expensive remote control.21 BLDC motors require 

additional controls to enable them to function on AC current in a typical home. The additional 

controls increase the cost of BLDC motors compared to induction motors. Generally, excluding 

the additional controls which are necessary for it to function in a home, the costs of a BLDC 

motor are comparable to the costs of some induction motors. DOE seeks input on cost 

differences between BLDC motors and induction motors. 

The following are types of motors that can be used in ceiling fans. 

	 Direct-drive single-phase induction motors. This is the most common type of motor used 

in ceiling fans. Fan blades are mounted directly to the motor, and the motor is made to 

operate at the same speed as blade rotation. 

	 Geared single-phase induction motors. Most ceiling fan motors are not as efficient as 

they could be, because they are low-speed direct-drive motors. Induction motors can be 

21 See: http://www.hansenwholesale.com/ceilingfans/reviews/ceiling-fans-dc-motors.asp. 

53
 
made more efficient if they are designed for much higher RPM. By including a gear 

mechanism, higher RPM motors can be used in ceiling fans. DOE is not aware of any 

ceiling fans currently on the market that use gear driven motors, though such motors are 

used in industrial fans. 

	 BLDC motors. BLDC motors require less electricity and copper wiring to produce the 

same amount of power. The rotor magnetic field in BLDC motors is stationary, which 

reduces rotor losses and makes them significantly more efficient. Typically, ceiling fans 

that have a BLDC motor are approximately 300 percent more efficient than conventional 

ceiling fan motors. 

	 Three-phase induction motors. Due to recent developments in the electronics of control 

systems, single-phase induction motors may be able to be replaced by more efficient 

three-phase induction motors. Three-phase motors are more efficient due to their simpler 

motor circuit, which results in lower losses. DOE is not aware of any ceiling fans 

currently on the market that use three-phase induction motors, although fans with threephase motors are commonly used in industrial and commercial locations. Modern 

electronics can efficiently transform a single-phase system commonly used in residential 

locations into a three-phase system for these motors. 

6.2.1.2 Number of Blades 

The number of blades in a ceiling fan affects its efficiency. In general, ceiling fans that 

have fewer blades are more efficient, because they are subject to less air resistance. However, 

fans that have fewer blades have also been known to generate more noise during operation 

because of the additional space between the blades. Unwanted noise is why most residential 

ceiling fans are sold with five blades. DOE understands that by redesigning the blade shape, it 

may be possible to reduce the number of blades without increasing the noise level. 

6.2.1.3 Blade Design 

Optimizing fan blade design requires a delicate balance between many, sometimes 

conflicting, elements. For flat blades, the steeper the blade pitch, the more air that the blade will 

move with each sweep. Blade pitch, however, also increases the amount of energy required to 

move the fan. Therefore, it is important to balance maximizing the blade pitch with not 

overworking the motor. 

The shape, weight, aerodynamic drag and material of a ceiling fan blade can significantly 

affect the efficiency of a ceiling fan. Advanced fan blade technologies consist of modified 

structural configurations of the blade shape to minimize drag and maximize air displacement. 

Among the possible “styles” of modification that can result in better fan efficiency are: (1) 

twisted blades, where the blade pitch decreases from where the blade attaches to the motor 

casing to the blade tip; (2) upswept blade tips or attachable clips that can be added to a fan blade 

to increase airflow or reduce drag; and (3) airfoil blades that may appear traditionally shaped 

from below, but which have an aerodynamic shape similar to the wing of an airplane. Blade 

design can significantly affect efficiency, with reported examples demonstrating more than a 

54
 
 

doubling of efficiency.22 For safety, edges of residential ceiling fans must be smooth and well 

rounded, which has the added benefit of reducing drag. 

The most common materials used for ceiling fan blades are wood and medium-density 

fibreboard (MDF). Plywood blades with a laminate coating are more resistant to warping than 

MDF and other cheaper woods. Blades made from MDF (often found on lower-end ceiling fans) 

are typically heavier than plywood, and the edges cannot be as rounded, which results in lessefficient blades. Blades made from metal (generally steel or aluminium) are less common in 

residential ceiling fans due to the increased risk of injury and noise. Aluminium blades are more 

malleable and can be more easily shaped that steel blades. Blades can also be made of injection 

molded resin, a material that is resistant to warping and weather conditions, and also can be 

molded into aerodynamically advantageous shapes. 

6.2.1.4 Blade Span 

DOE has found that residential ceiling fans are currently available with a wide range of 

blade spans. The size of the ceiling fan will depend on the size of the room in which it is to be 

used, and guidelines for selection of the correct fan size are available.23 Ceiling fans cool the 

occupants directly beneath them, so larger fans will cool a larger occupied area. Since blade 

span is typically chosen based on room size, DOE does not intend to consider blade span among 

its design options for ceiling fans. Instead, as discussed in section 6.1.3.1, DOE plans to develop 

a continuous specification relating airflow efficiency to blade span. 

DOE has begun researching the relationship between blade span and energy efficiency 

and has found that, for all types of ceiling fans, efficiency tends to increase with blade span. To 

investigate this, DOE considered airflow and power (in watts) separately and has initially found 

that both of these parameters seem to increase with blade span, but that the rate of increase seems 

significantly higher for airflow than power. 

6.2.1.5 Occupancy Sensors 

Occupancy sensors use technologies that detect the presence of people through 

movement and body heat. If used with an occupancy sensor, a ceiling fan could power down if it 

senses that a room is unoccupied. By limiting the hours of active mode operation to times when 

people are in the path of the fan, an occupancy sensor could reduce the overall energy 

consumption of a ceiling fan. Currently, very few ceiling fans, if any, are sold with occupancy 

sensors. To ensure that all power-saving technologies are properly accounted for, DOE is 

considering whether or not to include occupancy sensors as a technology option for ceiling fans. 

If occupancy sensors have a meaningful impact on overall fan energy consumption, then DOE 

could explore applying a credit to those fans that are equipped and sold with sensors. DOE 

requests information on the prevalence of occupancy sensors in the ceiling fan market and their 

effectiveness in terms of reducing energy consumption. . 

22 For example: Parker, D., Hua, G. & Hibbs, B., High Efficiency Ceiling Fan, United States Patent, Number 

6039541 (2000) (Available at: http://www.haikufan.com/our-fan/sustainability/). 23 See for example: http://www.energystar.gov/index.cfm?c=ceiling_fans.pr_ceiling_fans_basics and 

http://www.ceiling-fans.biz/products/Ceiling-Fans-Sizing/347.html. 

55
 
6.2.1.6 Potential Technology Options for Ceiling Fans 

DOE will consider more-efficient blades and motors, and may consider ceiling fan 

controls, as energy efficiency technology options. These technologies are listed in Table 6-9. 

Table 6-9 Potential Technology Options for Ceiling Fans 

More-Efficient Motors 

1. More-Efficient Direct-Drive Single-Phase Induction Motors 

2. Geared Single-Phase Induction Motors 

3. Brushless DC Motors 

4. Three-Phase Induction Motors 

More-Efficient Blades 

5. Fans with Fewer Blades 

6. Twisted Blades 

7. Airfoil Blades 

8. Blade Attachments 

9. Alternative Blade Materials 

Ceiling Fan Controls 

10. Occupancy Sensors 

Item 39 DOE welcomes comments on the preliminary technology options 

identified in this section (i.e., high-efficiency motors and highefficiency fan blades for ceiling fans) and whether there are other 

technology options it should consider. In commenting on 

technology options, please discuss their impacts (if any) on safety, 

performance, and consumer utility. 

Item 40 DOE requests input on whether it should include occupancy 

sensors as an energy efficiency option for ceiling fans and on how 

these could be taken into consideration in its rulemaking. 

6.2.2 Improving Efficiency of Ceiling Fan Light Kits 

DOE will consider lamp type as the primary energy efficiency technology option for this 

rulemaking. At the highest level, lamps are distinguished by both their lighting technology (light 

source type) and socket type. Light source type has the most direct influence on the overall 

efficiency of the light kit. The efficacies of light sources commonly used in light kits range from 

below 15 lm/W, for incandescent sources, to over 60 lm/W for certain CFL and LED 

technologies. Table 6-10 shows the light source types and socket types currently included in 

ceiling fan light kits, based on a survey of light kits sold online and based on an in-store survey 

conducted for this rulemaking in four “big box” retail outlets in California and Massachusetts. In 

addition, DOE may consider new lamp technologies (e.g., Zhaga-standard LED lamps) that are 

just entering the market. In some cases, any light source type can be and are used with particular 

56
 
 

 

7 

socket technologies (e.g., medium screw base and candelabra base). In other cases, only certain 

light source types are allowed to be used for certain socket types. For example, the American 

National Standards Institute (ANSI) standard for GU-24 sockets specifically excludes their use 

for incandescent lamps.24 

Table 6-10 Potential Technology Options for Lamp 

Lamp Type 

Light Sources 

Standard Incandescent 

Halogen Incandescent 

CFL 

LED 

Socket Types 

2GX13 

E-11 Mini Candelabra 

E-12 Candelabra 

G10q 

G9 

GU-10 

GU-24 

E-26 Medium 

2GX13 

Item 41	 DOE welcomes input on the potential technology options for 

ceiling fan light kits and on other technology options that should 

be considered. 

SCREENING ANALYSIS 

The purpose of the screening analysis is to eliminate, or screen out, technology options 

that DOE will not analyze further in the engineering analysis or downstream analyses because 

they do not meet four key criteria. DOE will follow the process set forth below to screen out 

technology options. 

DOE will develop a list of technology options (through its own research and in 

consultation with interested parties) for consideration in the engineering analysis (section 8). 

This initial list of identified candidate technology options will encompass all those technologies 

that may be technologically feasible. Thereafter, DOE will review each technology option or 

24 American National Standard for Electric Lampholders (ANSI_ANSLG C81.62-2009), page 50, tablenote (3). 

57
 
 

 

 

best available technology in light of the following four criteria, as provided in sections 4(a)(4) 

and 5(b) of the Process Rule25: 

1. Technological feasibility. DOE will screen out technologies that are not incorporated in 

commercially-available products or working prototypes. 

2. Practicability to manufacture, install, and service. If DOE determines that mass 

production and reliable installation and servicing of the technology could not be achieved 

on the scale necessary to serve the relevant market by the time of the compliance date of 

the standard, it will not consider that technology further. 

3. Adverse impacts on product or equipment utility or availability. If DOE determines that 

a technology will have a significant adverse impact on the utility of the relevant product 

for significant consumer subgroups, or will result in the unavailability of any covered 

product type with performance characteristics (including reliability), features, size, 

capacities, and volumes that are substantially the same as products generally available in 

the United States at the time, it will not consider that technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider that technology 

further. 

DOE will fully document its reasons for eliminating any technology options during the 

screening analysis and will publish this documentation for interested parties’ review and 

comment as part of the NOPR. Technology options that are not screened out by the above four 

criteria will be considered design options in the development of cost-efficiency curves in the 

engineering analysis. 

Item 42	 DOE welcomes comments on any technologies listed in section 6.2 

(or others not identified) that it should not consider based on any 

of the four screening criteria. If so, which screening criteria apply 

to the cited technology or technologies? DOE also welcomes 

comments on how the above four screening criteria might apply to 

any additional technology option(s) that an interested party 

recommends to DOE. 

ENGINEERING ANALYSIS 

After conducting the screening analysis described in section 7, DOE will perform an 

engineering analysis based on the remaining design options that are available to improve ceiling 

fan and ceiling fan light kit efficiency. The engineering analysis consists of estimating the 

energy consumption and cost of products at various levels of increased efficiency. Section 8.1 

25 The Process Rule establishes procedures, interpretations, and policies to guide DOE in the consideration and 

promulgation of new or amended energy conservation standards under EPCA and is found at 10 CFR part 430, 

subpart C, appendix A. 

58
 

8 
provides an overview of the engineering analysis. Section 8.2 discusses baseline models. Section 

8.3 discusses efficiency levels. Section 8.4 describes DOE’s planned approach to the costefficiency relationship and analysis. Section 8.5 addresses proprietary designs. Section 8.6 

discusses cumulative regulatory burdens that might affect the engineering analysis. 

8.1 Overview 

The purpose of the engineering analysis is to determine the relationship between 

manufacturer selling price and efficiency for residential ceiling fans and ceiling fan light kits. In 

determining the cost-efficiency relationship, DOE estimates the increase in manufacturer selling 

price associated with design changes that increase efficiency relative to the baseline models 

(which, in most cases, are the most typical, lowest-efficiency products currently sold on the 

market). DOE will develop cost estimates for ceiling fans and ceiling fan light kits at a range of 

efficiency levels based on the technologies incorporated into products at those levels and the 

associated changes in material, labor, shipping, and overhead costs. This relationship between 

price and efficiency serves as the basis for cost/benefit calculations to individual consumers in 

the LCC analysis and to the Nation in the NIA. 

The engineering analysis will focus on identifying and evaluating commercially-available 

ceiling fans and ceiling fan light kits that incorporate design options that improve efficiency. 

The analysis will also identify the highest efficiency that is technologically feasible within each 

product class (i.e., the “max-tech” model). DOE may determine the max-tech model by 

investigating the existence of any prototypes with higher efficiency than commercially-available 

models. 

For ceiling fans, DOE has proposed developing a number of product classes (see section 

6.1.3.1 on product classes). As a preliminary step in this analysis, DOE may determine an 

appropriate subset of product classes to analyze. DOE would extrapolate the results of this 

analysis to the remaining product classes. The number of product classes chosen to be 

representative will depend on whether appropriate relationships between engineering results can 

be developed between the various product classes. 

For each representative product class of ceiling fans, DOE may analyze a subset of 

representative units at selected fan sizes (determined by blade span). Once DOE has identified 

cost-efficiency relationships at those selected sizes, it is considering scaling the results to cover 

the full range of blade spans. This will lead towards development of a continuous specification 

relating efficiency to a ceiling fan’s blade span. Possible methods for developing the relationship 

between efficiency and blade span include performing selected performance testing of ceiling 

fans and conducting a statistical analysis of manufacturer catalogs and website information in 

addition to other publicly-available data sources. 

Once DOE establishes the representative product classes and representative fan sizes 

(together, “representative product groups”), it will select a baseline model as a reference point 

for each representative product group from which to measure changes resulting from the design 

options. DOE will then develop separate cost-efficiency relationships for each representative 

product group analyzed. 

59
 
 

 

DOE proposes the following two-part method for determining the cost-efficiency 

relationship for ceiling fans: 

1.	 Developing a detailed bill of materials (BOM) for baseline models in each 

representative product class and size bin through product teardowns. 

2.	 Calculating the incremental cost of adding specific design options to a baseline 

model. 

For ceiling fan light kits, DOE plans to base its analysis primarily on the design option 

approach. 

To develop the relationships between efficiency and technology options for both ceiling 

fans and ceiling fan light kits, DOE intends to utilize publicly-available data, including data from 

government databases, manufacturer catalogs and websites, where the technology options used 

can be identified, as well as selected product testing for ceiling fans. DOE encourages interested 

parties to submit test data or other information that will improve DOE’s understanding of ceiling 

fan and ceiling fan light kit performance. Using this data, which will allow DOE to determine 

the incremental costs of changes in material, labor, shipping, and overhead from the baseline, 

DOE will develop cost estimates for design options (which it will also use in the manufacturer 

impact analysis, section 15). 

Item 43	 DOE seeks stakeholder comment on these and other potential 

approaches to determining the cost-efficiency relationship for 

ceiling fans and ceiling fan light kits. 

8.2 Baseline Models 

For each product class and representative size bin in the case of ceiling fans, and for each 

product class in the case of ceiling fan light kits, DOE will identify a baseline model ceiling fan 

and ceiling fan light kit to serve as a reference point against which DOE can measure changes 

resulting from potential energy conservation standards. DOE will develop a separate efficiency 

curve for each baseline model directly analyzed. Should DOE develop a scaling method, as 

described in more detail in section 8.4 a separate curve for each baseline model and product class 

may not be necessary. 

Selection of the baseline model is a critical aspect of DOE’s analytical approach. The 

baseline model should represent the characteristics of a typical ceiling fan or ceiling fan light kit 

in a given representative product group. Normally, the baseline model is a model that just meets 

current energy conservation standards. However, because performance-based energy 

conservation standards for ceiling fans do not currently exist, DOE will select baseline models 

typical of the least-efficient residential ceiling fan models offered for sale in the market in a 

given product class and representative size bin. Selection of the baseline model for each 

representative size bin will involve consideration of ceiling fan features and performance 

characteristics, such as motor type, blade shape and span, and fan efficiency. 

60
 
As previously indicated, when amending standards, the baseline efficiency for products 

classes is typically set at their existing standard. Given the proposal to use luminous efficacy as 

the efficiency metric for all ceiling fan light kits, the baseline for class 1 (medium screw base) 

and class 2 (pin-based fluorescent) light kits would, therefore, be determined by their current 

efficacy-based standards. For class 3 products (all other light kits), which are currently based on 

a fixed wattage limit, DOE will need to determine an equivalent efficacy standard. To determine 

the equivalent lm/W baseline, DOE is considering identifying baseline models for current class 3 

products that just comply with the standard, and dividing their lumen output by the watts 

consumed. If DOE combines either two or all three existing product classes for ceiling fan light 

kits into a single product class, DOE would set the baseline at the highest of the existing 

standards for the product classes to be combined. This approach would guarantee that the energy 

use of any individual light kit sold could not drop below the existing standard set for the current 

product classes (ensuring no back-sliding on a product class-by-class basis). 

Item 44	 DOE welcomes comments on its proposed approach and on the 

selection and appropriate features and performance 

characteristics of baseline models for each representative product 

group for ceiling fans. 

8.3 Efficiency Levels 

To establish the efficiency levels DOE intends to consider, DOE will identify the highest 

efficiency that is technologically feasible within each product class (i.e., the max-tech model) 

and analyze the design options and costs associated with improving ceiling fan and ceiling fan 

light kit efficiency from the baseline through the max-tech models. DOE intends to collect 

efficiency data from various sources including manufacturer catalogs and websites to establish 

the range of efficiencies currently available on the market. DOE will also use these data to 

categorize relationships between efficiency and technological options, where the technological 

options used can be identified. 

DOE notes that the maximum efficiency levels available in current ceiling fan and ceiling 

fan light kits may not necessarily correspond to the max-tech levels. It is possible that some of 

the design options that have met the screening criteria (i.e., passed the screening analysis) may 

be working prototypes that are not yet commercially available and, therefore, would not be found 

in today’s available maximum-efficiency products. DOE seeks stakeholder input to determine 

appropriate max-tech efficiency levels. 

Item 45 DOE seeks input from stakeholders regarding the range of 

efficiency levels that should be examined as part of its analysis for 

ceiling fans and ceiling fan light kits. 

Item 46 DOE seeks input from interested parties on a methodology that 

would be appropriate for determining the max-tech models for 

each ceiling fan and ceiling fan light kit analyzed. 

61
 
 

8.4 Cost-Efficiency Relationship and Analysis 

The engineering analysis primarily involves estimating the energy consumption and cost 

of products at various levels of efficiency. Those estimates are then used to identify the costefficiency relationship for the products. DOE typically structures its estimation of the costefficiency relationship around one of three methodologies: (1) the design-option approach, which 

calculates the incremental cost of adding specific design options to the baseline model; (2) the 

efficiency-level approach, which calculates the incremental costs of achieving increases in 

energy efficiency, without regard to the particular design options used to achieve such increases; 

and (3) the reverse-engineering cost-assessment approach, which involves a “bottom-up” 

manufacturing cost assessment based on a detailed bill of materials being analyzed. Which 

methodology to use for the engineering analysis depends on the product, the technologies under 

study, and any historical data DOE can utilize. DOE plans to use separate approaches for ceiling 

fans and ceiling fan light kits, as explained below. 

For ceiling fans, DOE tentatively has decided to use the design option approach to 

identify incremental improvements in efficiency for each product and the reverse-engineering 

approach to develop a cost assessment for each baseline model. If a relationship between various 

product classes or representative size bins can be quantified, DOE may select a representative 

product class or size bin to analyze and develop a scaling method to derive results for the other 

product classes or representative size bins. If not, DOE could conduct a separate analysis for 

each product class and representative size bin. DOE anticipates, for example, that there may be a 

scaling between the incremental cost of hugger fans and that of indoor ceiling fans for a given 

efficiency improvement at a given size. If that is the case, DOE will consider using a scaling 

factor between those two product classes. Also, certain components of indoor and outdoor 

ceiling fans may be similar. For example, the motors in different baseline models may be the 

same, but the housing and the blade materials may be different. If that is the case, DOE will be 

able to use the same cost estimates for certain elements (i.e., the motors) across the two product 

classes while developing different costs for other elements, such as the housing and blade finish. 

Before performing the engineering analysis, DOE plans to test a number of ceiling fans 

according to the DOE test procedure being developed. The testing would enable DOE to gather 

measured data on ceiling fan efficiency to support the engineering analysis. 

 DOE plans to disassemble and inventory the ceiling fan components for selected fan 

models and to identify manufacturing processes required to fabricate them. This approach will 

allow DOE to derive the material and labor costs and generate BOMs for baseline ceiling fans in 

each product class and representative size bin. The BOMs describe the products in detail, 

including manufacturing steps required to make and/or assemble each part. DOE will then 

develop a cost model to convert the BOMs for baseline models and the cost of the design options 

associated with different efficiency levels into manufacturer production costs (MPCs). By 

applying derived manufacturer markups to the MPCs, DOE will calculate the manufacturer 

selling prices and construct industry cost-efficiency curves. As a compliment to this work, DOE 

may also evaluate retail prices to estimate manufacturer selling prices, as well as review data 

collected from manufacturers about prices, efficiencies, and other features of various models of 

62
 
 

 

ceiling fans, and interview manufacturers about the techniques and associated costs used to 

improve efficiency. 

In order to determine the cost-efficiency relationship for ceiling fan light kits, DOE plans 

to determine the energy efficiency by lamp efficacy alone, and only the costs of the lamps and 

their associated sockets (not the light kits themselves) will be included in the cost analysis. DOE 

believes this approach is appropriate because changing the lamp type will incur no additional 

costs in the light kits, assuming that all of the socket types are already represented. Given that 

the analysis plans to consider all socket types in use in light kits, the latter is guaranteed. Given 

that ceiling fan light kit manufacturers generally purchase rather than manufacture the lamps and 

associated sockets used in their light kits, DOE will use bulk retail purchase prices of these 

products in its analysis, corrected for manufacturer discounts. DOE is considering obtaining its 

efficacy data from DOE’s Compliance Certification Database26 if available and adequate and 

from DOE’s LED Lighting Facts database of verified products27 for LED lamps, supplemented 

by other government sources, manufacturer catalogues, and manufacturer interviews, as 

necessary. Efficiency levels will be based on population data for lamps having the same lumen 

output ranges and source types as those currently used in light kits. 

DOE recognizes that ceiling fans and ceiling fan light kits can have both a functional use 

and decorative features. Costs associated with a product's basic functionality may be 

independent of costs associated with style or aesthetics. In the cost-efficiency analysis, DOE 

will attempt to isolate costs associated with functionality. Wherever possible, products that are 

stylistically similar will be used to determine cost variations related to functional components. 

The proposed baseline model for ceiling fan light kits, for example, would have standard 

decorative features, as determined by the features of products that have the largest sales volumes. 

Manufacturer interviews are also expected to help isolate costs associated with functionality 

from those associated with aesthetics. 

Item 47 DOE seeks comments on its proposed methods for determining 

costs associated with incremental efficiency improvements in both 

ceiling fans and ceiling fan light kits. 

Item 48 DOE welcomes comments on how ceiling fan efficiency varies with 

airflow capacity, motor type, motor rated horsepower, blade span, 

number and design of blades, or any other ceiling fan parameter. 

DOE also seeks comments on how ceiling fan light kit efficiency 

varies with bulb type, number of bulbs, or any other ceiling fan 

light kit parameter. 

Item 49 DOE welcomes comments on the proposed method for isolating 

costs associated with decorative features from costs associated 

with functional features in ceiling fans and ceiling fan light kits 

26 See: http://www.regulations.doe.gov/certification-data/. 27 See: http://www.lightingfacts.com/products. 

63 
8.5 Proprietary Designs 

In its engineering and economic analyses, DOE will consider all design options that are 

commercially available or present in a working prototype, including proprietary designs that 

meet the screening criteria discussed in section 7. DOE will consider a proprietary design in the 

subsequent analyses, however, only if it does not represent a unique path to a given efficiency 

level. If the proprietary design is the only approach available to achieve a given efficiency level, 

then DOE will eliminate that efficiency level from further analysis. DOE will reject a standard 

level that can only be met with a single proprietary technology because it could result in an anticompetitive market, a principle consistently applied in past DOE rulemakings as economically 

unjustifiable. However, if a given energy efficiency level can be achieved by a number of design 

approaches, including a proprietary design, DOE will continue to examine the given efficiency 

level, despite the proprietary nature of that one design. 

DOE is sensitive to manufacturer concerns about proprietary designs and will take steps 

to maintain the confidentiality of any proprietary data provided by manufacturers. This 

information will provide input to the competitive impacts assessment and other economic 

analyses. 

Item 50	 DOE seeks information on proprietary designs of which it should 

be aware for both the ceiling fans and ceiling fan light kits under 

consideration in this rulemaking. If such proprietary designs exist, 

DOE would like to acquire the cost data necessary for evaluating 

those designs. 

8.6 Other Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE considers the effects of the full complement 

of regulatory burdens (including those outside DOE’s statutory standards rulemaking process) 

that can affect manufacturers of covered products. Some regulatory requirements potentially 

could affect the energy efficiency or energy consumption of the ceiling fans and ceiling fan light 

kits covered under this rulemaking. DOE will attempt to identify all regulatory requirements that 

could affect the engineering analysis. Evaluating such requirements is closely related to the 

cumulative regulatory burden assessment that DOE will conduct as part of the manufacturer 

impact analysis. Based on consideration of the comments received on the engineering analysis, 

DOE will make any necessary changes to its analysis. Those changes will be reflected in the 

NOPR. 

Item 51 DOE welcomes comments on regulatory burdens and changes that 

should be considered in the engineering analysis of ceiling fans 

and ceiling fan light kits. 

Item 52 DOE welcomes comments on other engineering issues that could 

affect the engineering analysis. 

64
 
9 MARKUPS ANALYSIS 

Because DOE uses retail (consumer) price data in its LCC, PBP, and national impact 

analyses, DOE typically uses manufacturer-to-consumer markups to convert estimates of the 

manufacturer selling price derived from the engineering analysis (section 8) to consumer prices. 

The manufacturer-to-consumer markups are in addition to the markups on production costs that 

DOE uses in estimating manufacturer selling price in the engineering analysis. To validate those 

markups, DOE will collect data on current market prices. 

9.1 Description of Market Participants and Distribution Channels 

In generating end-user price inputs for the LCC analysis and NIA, DOE must identify 

distribution channels (i.e., how the products are distributed from the manufacturer to the 

consumer), and estimate relative sales volumes through each channel. DOE is considering two 

main distribution channels for ceiling fans and ceiling fan light kits: (1) home improvement 

retailer and (2) electrical wholesaler (distributor). Figure 9-1 shows how DOE plans to 

characterize the home improvement retailer distribution channel for ceiling fans and ceiling fan 

light kits: 

Distribution Channel 1: 

Figure 9-1 Home Improvement Retailer Distribution Channel for Ceiling Fans and 

Ceiling Fan Light Kits 

Figure 9-2 shows how DOE plans to characterize the electrical wholesaler (distributor) 

distribution channel for ceiling fans and ceiling fan light kits: 

Distribution Channel 2: 

Figure 9-2 Electrical Wholesaler (Distributor) Distribution Channel for Ceiling Fans 

and Ceiling Fan Light Kits 

9.2 Markup Estimation Using Financial Statements and Regression Analysis 

To estimate distribution channel markups, DOE will rely on economic data from public 

sources and industry input to determine the extent to which products are marked up from the 

65
 
 

 

 

 

manufacturer to the consumer. Publicly-owned companies are required to disclose financial 

information on a regular basis by filing various forms with the U.S. Securities and Exchange 

Commission (SEC). Filed annually, SEC Form 10-K provides a comprehensive overview of the 

company’s business and financial conditions. To estimate retailer and wholesaler markups, DOE 

will analyze both economic Census data from the U.S. Census Bureau28 and financial data from 

available 10-K reports for publicly-owned home improvement retailers and electrical 

wholesalers.29 

In addition to developing manufacturer and retailer markups, DOE will also develop and 

include sales taxes to calculate appliance retail prices. DOE will use an Internet source, the Sales 

Tax Clearinghouse, to calculate applicable sales taxes.30 

DOE will also use collected retail price data to validate the overall manufacturer-toconsumer markup. DOE has purchased ceiling fan consumer survey data for 2007–2011 from 

NPD Group, Inc. (NPD), which provides an estimate of sales-weighted retail price data. In 

addition to purchasing consumer survey data, DOE has conducted in-store site visits, and may 

also consult retailers’ Internet sites. 

This analysis will generate end-user prices for each potential efficiency level, assuming 

that each level represents a new minimum efficiency standard. DOE will make this assumption 

to capture the effect on retail prices that may be produced by manufacturers’ higher production 

volumes of more-efficient products as required by the standard. Because DOE expects to 

develop a range of price estimates, it may describe new retail prices within a range of 

uncertainty. If the results of DOE’s analysis show a large range of retail prices for each product, 

DOE will develop probability distributions of retail price to use as inputs to the LCC and PBP 

analysis in order to determine the impact of uncertainty on the economic feasibility of amended 

energy conservation standards. 

Item 53 DOE welcomes suggestions and comments concerning its 

proposed approach for estimating end-user prices for ceiling fans 

and ceiling fan light kits. 

Item 54 DOE welcomes suggestions and comments concerning its assumed 

distribution channels for ceiling fans and ceiling fan light kits, and 

data and/or estimates regarding relative sales volumes through 

each channel. 

Item 55 DOE welcomes comments on typical manufacturer, retailer, 

wholesaler, and contractor markups associated with ceiling fans 

and ceiling fan light kits. 

28 Economic census data from the U.S. Census Bureau are available at: http://www.census.gov/econ/census/#. 29 10-K reports are filed with the U.S. Securities and Exchange Commission and are available at 

www.sec.gov/index.htm. 30 See http://www.thestc.com/. 

66 
 

10 ENERGY USE ANALYSIS
 

The purpose of the energy use analysis is to estimate the annual energy usage of the 

baseline and higher-efficiency ceiling fans and ceiling fan light kits considered in this 

rulemaking, as described in the engineering analysis for representative U.S. homes, and to assess 

the energy-savings potential of increased product efficiencies. This analysis, which is meant to 

represent typical energy usage in the field, is an input to both the LCC and PBP analysis and the 

NIA. The energy use analysis enables DOE to determine the LCC and the PBP of more-efficient 

products in relation to the baseline product and to establish the savings in consumer operating 

costs at various product efficiency levels. 

For ceiling fans and ceiling fan light kits, energy use is derived by multiplying the 

product input power rating by the annual operating hours. Input power ratings for representative 

baseline and higher-efficiency products are developed in the engineering analysis (section 8). 

For most ceiling fans, this energy use will just correspond to the energy use in active mode. For 

those ceiling fans and ceiling fan light kits which consume power in standby mode, the energy 

use in standby mode will be derived by multiplying the power consumed in standby mode by the 

annual operating hours in standby mode. The energy use in standby mode will then be added to 

the energy use in active mode. 

To estimate annual energy use for ceiling fans, DOE plans to research available ceiling 

fan and heating, ventilation, and air-conditioning (HVAC) usage studies, as well as regional 

residential utility monitoring studies. Because energy use by ceiling fans varies greatly based on 

consumer usage patterns, DOE will conduct further research to establish a range of energy use 

for ceiling fans. The Energy Information Administration (EIA)’s Residential Energy 

Consumption Survey31 is one source for defining the range of energy use for ceiling fans. DOE 

will also consider ceiling fan sales data collected as part of its market and technology assessment 

(section 6), which will help characterize the prevalence of ceiling fan use by geographic region. 

Since usage varies significantly between regions, and DOE considers that usage and ownership 

levels are likely correlated (i.e., regions with more ceiling fans are likely to use ceiling fans 

more), national averages may give a distorted picture of regional impacts and make a distribution 

analysis impossible. DOE plans to estimate a regional distribution of operating hours that 

accounts for geographic location, climate and season, market penetration, and ceiling fan usage 

patterns. 

To estimate annual energy use for ceiling fan light kits, DOE plans to consider data from 

a number of sources including DOE’s Residential Lighting End-Use Consumption Study 

(RLEUCS), anticipated 2013,32 2010 U.S. Lighting Market Characterization (LMC)33 and the 

EIA’s 2009 RECS to estimate a distribution of operating hours. RLEUCS leverages several 

31 U.S. Energy Information Administration, Residential Energy Consumption Survey, 2009 RECS Survey Data. 

(2009) (Last accessed August 14, 2012) (Available at: www.eia.gov/consumption/residential/data/2009/). 32 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Residential Lighting End-Use 

Consumption Study: Estimation Framework and Baseline Estimates (2013) (Available at: 

http://www1.eere.energy.gov/buildings/ssl/m/tech_reports.html). 33 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Final Report: 2010 U.S. 

Lighting Market Characterization (2012) (Available at: 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf). 

67
 
 

recent national and regional datasets, linking lamp usage from end-use metering studies with 

household characteristics and lighting inventory profiles to estimate residential lighting energy 

usage. The LMC, which is based on thousands of building audits and surveys, indicates the 

occurrence of certain room types within a given building type and the operating hour 

characteristics in these rooms. LMC data can be associated with RECS data, which provide 

information on the distribution of U.S. buildings by building type and Census Division. 

For the NOPR stage of this rulemaking, DOE may conduct a sensitivity analysis to 

determine how high and low estimates of energy use might affect the economic feasibility of any 

potential energy conservation standards. 

Item 56	 DOE welcomes comments on its proposed methodology to 

determine annual operating hours and energy use for covered 

ceiling fans and ceiling fan light kits, and how operating hours 

may vary (e.g., by product type and application, geographical 

location, season). 

11 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES 

This section describes the life-cycle cost and payback period analysis that DOE will 

perform for ceiling fans and ceiling fan light kits, including how DOE develops the inputs to the 

calculations. The LCC analysis establishes the total cost of an appliance over its lifetime 

(including purchase price, installation cost, and operating costs). The PBP analysis calculates the 

amount of time required for energy cost savings to pay back any increased cost of a higherefficiency product. 

11.1 Overview 

The effects of energy conservation standards on consumers of a product include a change 

in operating cost (usually decreased) and a change in purchase price (usually increased). DOE 

analyzes the net effect of amended standards on consumers by evaluating changes in the LCC of 

owning and operating the product, as well as the PBP of higher-efficiency products. The LCC of 

a product is the cost a product incurs over its lifetime, taking into account both purchase price 

and operating expenses. The PBP represents the time it takes to recover the additional installed 

cost of the more-efficient device through annual operating cost savings. 

DOE analyzes the net effect on consumers by calculating the LCC and PBP using the 

engineering performance data (section 8), the energy-use and end-use load characterization data 

(section 10), and the markups (section 9). Inputs to the LCC calculation include the total 

installed cost to the consumer (purchase price plus any installation cost), operating costs (energy 

expenses, and, if applicable, repair costs and maintenance costs), the lifetime of the product or 

other defined period of analysis, and a discount rate. Additional inputs to the payback period 

calculation include the installed cost to the consumer and first-year operating costs. 

DOE considers both LCC and PBP to determine the impacts of potential energy 

conservation standards on consumers of the covered products. However, because calculation of 

68
 
LCC uses a discount rate (that depends on consumers’ cost of financing) and takes into account 

changing energy prices over time, it is considered by DOE to be a better indicator of the 

economic impacts of standards on consumers. 

DOE plans to perform the LCC and PBP analyses using a spreadsheet model combined 

with a commercially-available software add-on program used to conduct stochastic analysis 

using Monte Carlo simulation and probability distributions to account for uncertainty and 

variability among the input variables. Each Monte Carlo simulation will consist of 10,000 LCC 

and PBP calculations. The model will perform each calculation using input values that are either 

sampled from probability distributions and household samples or characterized with single point 

values. The analytical results are a distribution of 10,000 data points showing the range of LCC 

savings and PBPs for a given efficiency level relative to the base-case efficiency forecast. For 

any sensitivity analyses it conducts, DOE will account for correlations that may exist between 

inputs. 

Since ceiling fan usage varies significantly between regions, and DOE considers that 

usage and ownership levels are likely correlated (i.e., regions with more ceiling fans are likely to 

use ceiling fans more), national averages may give a distorted picture of regional impacts and 

make a distribution analysis impossible. DOE, therefore, proposes to undertake its LCC and 

PBP analysis on a regional basis. 

DOE will also determine as part of the LCC and PBP analyses whether there may be a 

rebound (or “take back”) effect associated with more-efficient ceiling fans and/or ceiling fan 

light kits. The “take-back” in energy consumption associated with the rebound effect typically 

involves greater use that can result from increases in energy efficiency and the associated 

reduction in operating costs. The rebound effect assumes that consumers will increase their 

overall annual usage of a more-efficient product, thereby decreasing their overall annual savings. 

The following sections discuss the methodologies DOE plans to use to develop several of 

the inputs to the LCC and PBP analysis, including: (1) energy prices; (2) discount rates; (3) 

maintenance, repair, and installation costs; and (4) product lifetime. The other inputs to the LCC 

and PBP analysis—namely, manufacturer costs, annual energy consumption, and markups for 

the determination of consumer retail prices—have been discussed previously. 

DOE is also required to perform a PBP analysis to determine whether the rebuttable 

presumption of economic justification applies (where the higher installed cost of more-efficient 

equipment is less than three times the value of the lowered operating costs in the first year of the 

energy conservation standard). (42 U.S.C. 6295(o)(2)(B)(iii)) To determine the rebuttable 

presumption PBP, DOE will determine the value of the first year’s energy savings by calculating 

the quantity of those savings in accordance with DOE’s test procedure. Although DOE will 

examine the rebuttable-presumption criteria, DOE determines whether potential standards are 

economically justified through an analysis of the economic impacts of increased efficiency 

pursuant to section 325(o)(2)(B)(i) of EPCA. (42 U.S.C. 6295(o)(2)(B)(i)) The results of this 

analysis serve as the basis for DOE to definitively evaluate the economic justification for a 

potential standard level (thereby supporting or rebutting the results of any preliminary 

determination of economic justification). 

69
 
 

In preparing the NOPR, DOE carefully reviews all the comments it receives on the 

preliminary analysis LCC analysis, makes any necessary revisions to the analysis, and if 

necessary, evaluates additional parameters not included in the preliminary analysis. 

Item 57	 DOE welcomes comments from interested parties as to whether a 

more-efficient ceiling fan or ceiling fan light kit would be expected 

to be used more and whether such a rebound effect should be 

considered separately for this product. 

11.2 Energy Prices 

DOE plans to derive average monthly electricity prices for the 27 geographic areas used in 

RECS 2009 by using the latest data from EIA and monthly energy price factors. DOE will 

develop the 27 regional energy prices based on the household population in each region. DOE 

will assign an appropriate price to each household in the RECS sample, depending on its 

location. 

To calculate electricity prices for residential consumers in each of the above geographic 

areas, DOE will use information provided by electric utilities as summarized in the most recent EIA 

Form 861 data.34 These data, which cover the residential, commercial, and industrial sectors for every 

utility serving final customers, are published annually and include annual electricity sales in kWh, 

revenues from electricity sales, and number of customers. DOE’s calculation of an average 

residential electricity price proceeds in two steps: (1) for each utility, estimate an average residential 

price by dividing residential revenues by residential sales; and (2) calculate a regional average price, 

weighting each utility that has customers in a region by the number of residential customers served in 

that region. 

In its LCC analysis, DOE will use projections of national average electricity prices to 

residential consumers to estimate future energy prices. DOE will use the most recent available 

edition of EIA’s Annual Energy Outlook (AEO) as the source of projections for future energy 

prices. 

Item 58 DOE seeks stakeholder input on the planned approach for 

estimating current and forecasted energy prices. 

34 EIA’s 2008 Form 861 data and EIA’s Form 826 (Available at: 

http://www.eia.doe.gov/cneaf/electricity/epm/table5_3.html). 

70 
 

 

 

 

11.3 Discount Rates 

The calculation of LCC requires use of an appropriate discount rate to determine the 

present value of a product’s lifetime operating expenses. The discount rate used in the LCC 

analysis represents the rate from an individual consumer’s perspective.35 

For consumers of ceiling fans and ceiling fan light kits, DOE plans derive the discount 

rates from estimates of the “finance cost” to purchase residential products. The finance cost can 

be interpreted as: (1) the financial cost of any debt incurred to purchase products (principally 

interest charges on debt), or (2) the opportunity cost of any equity used to purchase products 

(principally interest earnings on household equity). Much of the data DOE uses to determine the 

cost of debt and equity comes from the Federal Reserve Board’s triennial Survey of Consumer 

Finances.

36 

Item 59	 DOE welcomes input on the planned approaches for estimating 

discount rates for consumers of ceiling fans and ceiling fan light 

kits. 

11.4 Installation, Maintenance, and Repair Costs 

DOE does not currently plan to consider installation costs for ceiling fans and ceiling fan 

light kits because DOE does not believe that the installation cost will be affected by changes in 

product efficiency. 

DOE will evaluate how any maintenance and repair costs may change with increased 

efficiency for ceiling fans and ceiling fan light kits. Often, small incremental changes in product 

efficiency incur little or no change in maintenance and repair costs over baseline products. For 

products with significant energy-efficiency improvements over the baseline, there may be 

increased maintenance and repair costs, because such products are more likely to incorporate 

technologies that are not widely available or used. 

DOE will estimate maintenance and repair costs at each considered efficiency level using 

a variety of sources, including RS Means,37 manufacturer literature, and information from expert 

consultants. DOE will account for regional differences in labor costs by using RS Means data. 

Item 60 DOE welcomes comments on appropriate maintenance and repair 

costs for ceiling fans and ceiling fan light kits. 

35 The consumer discount rate differs from the discount rates used in the national impact analysis, which are 

intended to represent the rate of return on capital in the U.S. economy, as well as the societal rate of return on 

private consumption. Refer to section 13.3for additional information.
 36 Available at http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html. 37 RS Means Company, Inc., RS Means Residential Cost Data (31st Annual Edition ed. 2012) (Available at: 

http://rsmeans.reedconstructiondata.com/). 

71 
 

11.5 Product Lifetime 

Product lifetime is the age at which a product is retired from service. DOE plans to use 

information from various literature sources and industry experts and input from manufacturers 

and other interested parties to determine a range for the lifetime of ceiling fans. 

DOE has begun to investigate life expectancy of ceiling fans. Data from Appliance 

Magazine suggests significant variation in the life expectancy of ceiling fans ranging between 7 

and 18 years (Appliance Magazine, 2001).38 Estimates represent expert judgment from 

Appliance Magazine staff. 

DOE anticipates that there will be significant differences in lifetimes of ceiling fans 

depending on usage. Since usage varies significantly between regions, this will be an important 

factor for DOE to consider. DOE has not found significant data on life expectancy of ceiling 

fans and is unaware of any data on the relationship between usage and life expectancy of ceiling 

fans. Therefore, DOE seeks comments, input, and data on ceiling fan life expectancy and, in 

particular, on the relationship between ceiling fan usage and ceiling fan life expectancy. 

Assuming that DOE adopts ceiling fan light kit standards based on lamp efficacy and a 

packaging requirement (see section 4.1.2.2), the relevant lifetime depends on the nature of the 

light kit and the packaged lamps. For the purpose of calculating energy savings, the relevant 

lifetime is the lifetime of the packaged lamp (or light engine for light kits with integrated 

lighting) unless it exceeds the ceiling fan lifetime, in which case the relevant lifetime is the 

ceiling fan lifetime. The ceiling fan lifetime rather than the ceiling fan light kit lifetime is used 

because the fan, having moving parts, is likely to have a shorter life, and the available data 

suggest that when the fans ceases to function, its light kit is also retired. (Light kits are generally 

purchased packaged with or built into fans, in the major big-box markets, and they are generally 

purchased at the same time as fans in showrooms.) 

Item 61	 DOE welcomes comments on appropriate lifetimes for both ceiling 

fans and ceiling fan light kits covered in this rulemaking. DOE is 

particularly interested in regional lifetime data and data on the 

relationship between ceiling fan usage and ceiling fan life 

expectancy. 

11.6 Energy Efficiency in the Base Case 

To estimate the share of consumers that would be affected by a standard at a particular 

efficiency level, DOE’s LCC and PBP analysis will consider the projected distribution (i.e., 

market shares) of product efficiencies that consumers will purchase in the first compliance year 

under the base case (i.e., the case without amended energy conservation standards). Projected 

market shares will use available data on recent market trends in ceiling fan and ceiling fan light 

kit efficiency and will take into account the potential impacts of the ENERGY STAR program 

and other programs or policies that may affect the demand for more-efficient ceiling fans and 

38 Appliance Magazine, The 22nd Portrait of the US Appliance Industry (2001). 

72
 
 

ceiling fan light kits (such as consumer rebate programs or State tax credits to consumers that 

encourage the purchase of more-efficient products). DOE will consider how the trends in ceiling 

fan and ceiling fan light kit efficiency are likely to influence the distribution of more-efficient 

products. 

Item 62	 DOE seeks comments on the appropriate distribution of energy 

efficiencies for both ceiling fans and ceiling fan light kits in the 

absence of amended energy conservation standards. 

12 SHIPMENTS ANALYSIS 

DOE typically develops shipment forecasts of products to calculate the national impacts 

of potential energy conservation standards on energy consumption, net present value (NPV), and 

future manufacturer cash flows. DOE is considering developing shipments forecasts (from the 

assumed compliance date of a new standard to 30 years after compliance is required) based on an 

analysis of key market drivers for ceiling fans and ceiling fan light kits. 

In order to develop forecasts using this methodology, DOE must rely on the lifetime 

function of the product. DOE has begun to investigate life expectancy of ceiling fans and 

anticipates that there will be significant differences in lifetimes of ceiling fans dependent on 

usage. Since usage varies significantly between regions, the lifetime factor in itself (when 

combined with shipments data) may not result in a reliable projection of future stock. As 

discussed in section 11.5, DOE assumes that light kits are retired at the end of the fan’s lifetime. 

However, unlike in section 11.5, for the shipments calculations for light kits, the relevant lifetime 

is not the lamp lifetime but the fan lifetime, at which point the light kit is retired. 

In order to avoid over-reliance on lifetime data, DOE is considering an alternative 

approach in which it projects future stock levels for ceiling fans directly using current values and 

forecasts of national and regional ownership levels, regionally differentiated usage patterns, and 

regional population projections. DOE is considering using available stock and shipments data 

(such as from EIA’s RECS and the shipments sources discussed in section 6.1.2.3) to estimate 

lifetimes. In this situation where lifetimes are highly uncertain, DOE considers this method 

likely to provide more robust results. 

Item 63 DOE welcomes comments on the approach described to forecast 

shipments of ceiling fans and ceiling fan light kits. 

12.1 Base-Case Forecast 

 To evaluate the impacts of potential energy conservation standards, DOE will develop a 

base-case shipments or stock forecast against which to compare forecasts for higher efficiency 

levels. (The latter are also referred to as standards-case forecasts.) DOE designs the base-case 

forecast to depict what it anticipates would happen to energy consumption and costs over time if 

DOE does not adopt new energy conservation standards for the products covered under this 

73
 
 

rulemaking. When it develops base-case shipments forecasts, DOE plans to calibrate its 

shipments or stock model against historical shipments or stock levels. 

With regard to historical product saturation rates, EIA’s RECS and the shipments sources 

discussed in section 6.1.2.3 provide relevant data. DOE plans to use these sources to establish 

product saturation rates. To determine replacement shipments, DOE will use the same product 

lifetimes and retirement functions that it generates for the LCC and PBP analysis. In addition, 

DOE will consider other market segments as appropriate, such as households that may purchase 

additional units. 

Item 64	 DOE seeks input on historical shipments and stock data for ceiling 

fans and ceiling fan light kits, including the distribution of 

shipments by efficiency. 

12.2 Impacts of Standards on Ceiling Fan and Ceiling Fan Light Kit Shipments 

DOE intends to evaluate whether standards that require more-efficient ceiling fans and/or 

ceiling fan light kits would have an impact on the number of fans and/or light kits shipped. DOE 

will consider application of elasticity parameters that relate changes in shipment quantities to 

changes in the installed cost of products with ceiling fans. 

Item 65	 DOE welcomes comments on whether energy conservation 

standards might affect shipments of ceiling fans and ceiling fan 

light kits, as well as the anticipated extent of such impacts, if any. 

13 NATIONAL IMPACT ANALYSIS 

In the national impact analysis, DOE estimates national energy savings from new or 

amended energy conservation standards and the net present value of total consumer benefits. 

The NIA considers: (1) NES attributable to each potential standard; (2) monetary value of the 

NES to purchasers of the considered equipment; (3) increased total installed cost of the 

equipment because of standards; and (4) NPV of the difference between the operating cost 

savings and increased total installed cost. DOE performs all NIA calculations using a computer 

spreadsheet model.39 The spreadsheets combine the calculations for determining the NES and 

NPV for each considered product class with input from the shipments model. 

13.1 Projected Efficiency Trends 

A key component of DOE’s NIA analysis, namely DOE’s estimate of NES and NPV, is the 

product energy efficiencies forecasted over time for the base case (without new standards) and 

each standards case. Forecasted efficiencies represent the shipment-weighted energy efficiency 

39 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at: 

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

74
 
 

 

 

of the covered ceiling fans and ceiling fan light kits during the forecast period (i.e., from the 

assumed compliance date of a new or amended standard to 30 years after compliance is 

required). 

Section 12 describes how DOE plans to develop a base-case energy efficiency 

distribution (which yields a shipment or stock-weighted average efficiency) for each of the 

ceiling fan and ceiling fan light kit product classes for the first year of the forecast period. To 

forecast base-case efficiencies over the entire 30-year forecast period, DOE intends to 

extrapolate from the historical trends to the extent that is possible and reasonable. 

The market-share efficiency data will enable DOE to estimate the effect that new or 

amended standards may have in the year manufacturers must begin to comply with them. DOE 

has used “roll-up” and/or “shift” scenarios in its standards rulemakings. Under the “roll-up” 

scenario, DOE assumes: (1) product efficiencies in the base case that do not meet the standard 

level under consideration would “roll-up” to meet the new standard level; and (2) product 

efficiencies above the standard level under consideration would not be affected. Under the 

“shift” scenario, DOE retains the pattern of the base-case efficiency distribution but re-orients 

the distribution at and above the new minimum energy conservation standard. DOE will 

evaluate whether one of these approaches is more reasonable for ceiling fans and ceiling fan light 

kits. After DOE establishes average efficiency for the assumed compliance date of a standard, it 

estimates future efficiency by using an appropriate rate of forecasted efficiency growth as for the 

base-case efficiency trend. 

Item 66 DOE seeks comments on the appropriate assumptions to use 

regarding long-run changes in ceiling fan and ceiling fan light kit 

energy efficiency independent of amended energy conservation 

standards. 

Item 67 DOE seeks comments on the use of the “roll-up” and “shift” 

efficiency scenarios to characterize the impact that potential 

standards would have on the product efficiency distributions. 

13.2 National Energy Savings 

DOE will calculate annual national energy savings for each standards case analyzed. The 

energy savings are measured over the entire lifetime of products purchased in the 30-year 

shipments projection period.40 

To estimate the primary energy savings resulting from electricity savings at building 

sites, DOE will develop annual conversion factors based on the version of the National Energy 

Modeling System (NEMS) that corresponds to the latest version of AEO. For electricity, the 

40 In the past, DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured 

over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of 

national energy savings to be consistent with the approach used for its national economic analysis. 

75
 
 

conversion factors change over time in response to projected changes in generation sources (i.e., 

the types of power plant projected to provide electricity). 

DOE intends to determine whether there may be a rebound effect associated with moreefficient ceiling fans and/or ceiling fan light kits. If data indicate that there may be a rebound 

affect and allow for the quantification of this effect for ceiling fans and/or ceiling fan light kits, 

DOE will account for the rebound effect in its calculation of NES. 

DOE has historically presented NES in terms of primary energy savings. On August 18, 

2011, DOE published a Federal Register notice announcing its intention to use full-fuel-cycle 

(FFC) measures of energy use and greenhouse gas and other emissions in the national impact 

analyses and emissions analyses included in future energy conservation standards rulemakings. 

76 FR 51281. While DOE stated in that notice that it intended to use the Greenhouse Gases, 

Regulated Emissions, and Energy Use in Transportation (GREET) model to conduct the analysis, 

it also said it would review alternative methods, including the use of NEMS. After evaluating 

both models and the approaches discussed in the August 18, 2011 notice, DOE has determined 

NEMS is a more appropriate tool for this purpose. 77 FR 49701 (Aug. 17, 2012). Therefore, 

DOE intends to use the NEMS model to conduct FFC analyses. The method used to derive the 

FFC multipliers will be described in the preliminary TSD. 

13.3 Net Present Value of Consumer Savings 

The inputs for determining NPV of the total costs and benefits experienced by consumers 

of the considered appliances are: (1) total annual installed cost; (2) total annual savings in 

operating costs; (3) a discount factor; (4) present value of costs; and (5) present value of savings. 

DOE calculates net savings each year as the difference between the base case and each standards 

case in terms of the total savings in operating costs and total increases in installed costs. DOE 

calculates savings over the life of each product. DOE calculates NPV as the difference between 

the present value of operating cost savings and the present value of total installed costs. 

DOE calculates increases in total installed costs as the difference in total installed cost 

between the base case and a standards case. DOE expresses savings in operating costs as 

decreases associated with the lower energy consumption of products bought in the standards case 

compared to the base case. Total savings in operating costs are the product of savings per unit 

and the number of units of each vintage that survive in a given year. DOE also incorporates the 

impact of “price learning” into its analysis, to capture the reduction in product prices with 

cumulative production. 

Based on U.S. Office of Management and Budget (OMB) guidelines for Federal 

agencies, DOE will conduct two NPV calculations, one using a real discount rate of 3 percent 

and another using a real discount rate of 7 percent (OMB, Circular A-4: Regulatory Analysis 

(2003)). The discount rates for the determination of NPV are in contrast to the discount rates 

used in the LCC analysis, which are designed to reflect a consumer’s perspective. The 7-percent 

real value is an estimate of the average before-tax rate of return to private capital in the U.S. 

economy. The 3-percent real value represents the “societal rate of time preference,” which is the 

rate at which society discounts future consumption flows to their present value. 

76
 
14 CONSUMER SUBGROUP ANALYSIS
 

At the NOPR stage of this rulemaking, DOE will conduct a consumer subgroup analysis. 

In this analysis, DOE assesses consumer impacts of any new or amended standards by dividing 

consumers into subgroups and accounting for variations in key inputs to the LCC analysis. A 

consumer subgroup comprises a subset of the population likely, for one reason or another, to be 

affected disproportionately by new or amended energy conservation standards (e.g., low-income 

consumers, seniors). The purpose of a subgroup analysis is to determine the extent of any such 

disproportional impact. DOE will work with industry and other interested parties early in the 

rulemaking process to identify any consumer subgroups for consideration. 

In comparing potential effects on different consumer subgroups, DOE will evaluate 

variations in energy prices, energy use profiles, and purchase prices that might affect the LCC of 

a new or amended energy conservation standard for identified consumer subgroups. 

Item 68	 DOE welcomes input from interested parties regarding which, if 

any, consumer subgroups should be considered when developing 

potential energy conservation standards for ceiling fans and 

ceiling fan light kits. 

15 MANUFACTURER IMPACT ANALYSIS 

DOE conducts its manufacturer impact analysis (MIA) consistent with the Report to 

Congress, “Energy Conservation Standards Activities” (Jan. 31, 2006) (required report under 

Section 141 of the Energy Policy Act of 2005) (Standards Activities), available at 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.p 

df. 

Prior to 2006, DOE did not report any MIA results during the preliminary analysis phase; 

however, under the format established by the “Energy Conservation Standards Activities,” DOE 

now collects, evaluates, and reports preliminary information and data in the preliminary analysis. 

(See Standards Activities, p. 48) Such preliminary information includes the anticipated 

conversion costs by efficiency level and the corresponding anticipated impacts on direct 

employment. DOE solicits further information during the preliminary analysis phase through the 

manufacturer interviews conducted as part of that phase’s engineering analysis. A draft set of 

questions to be used for those interviews is contained in Appendix B. 

DOE intends the MIA to help assess the potential impacts of amended energy 

conservation standards on manufacturers of ceiling fans and ceiling fan light kits. In addition to 

financial impacts, a wide range of quantitative and qualitative effects may occur following 

adoption of an amended standard that may require changes to the manufacturing practices for 

these products. DOE identifies these potential effects through interviews with manufacturers, as 

well as other stakeholders and experts. 

For the NOPR, DOE supplements the results of the preliminary MIA with more-detailed 

analyses, as described in sections 15.1 through 15.5. Specifically, DOE carries out an industry77
 
wide cash flow analysis using the Government Regulatory Impact Model (GRIM), identifies and 

analyzes subgroups of manufacturers whose businesses vary significantly from the industry as a 

whole, performs a competitive impacts assessment, and reviews the cumulative regulatory 

burden for the industry. 

15.1 Sources of Information for the Manufacturer Impact Analysis 

Many of the analyses described earlier provide important information that DOE uses as 

inputs for the MIA. Such information includes financial parameters developed in the market 

assessment (section 6), manufacturing costs and prices from the engineering analysis (section 8), 

retail price forecasts (section 9), and shipments forecasts (section 12). DOE supplements this 

information with information gathered during manufacturer interviews, as discussed below. 

During the preliminary analysis phase, DOE conducts detailed interviews with 

manufacturers to gain insight into the range of possible impacts from potential amended energy 

conservation standards. These interviews will coincide with preliminary technical interviews for 

the engineering analysis. 

During the NOPR phase, DOE will conduct more detailed MIA interviews with 

manufacturers. The interview process plays a key role in the MIA by providing an opportunity 

for directly affected parties to express their views on important issues. During the interviews, 

DOE solicits information on the possible impacts of potential amended standards on 

manufacturing costs, product prices, sales, direct employment, capital assets, and industry 

competitiveness. Both qualitative and quantitative information are valuable in terms of this 

analysis. DOE schedules interviews well in advance to provide every opportunity for key 

individuals to be available to participate. In addition, DOE provides manufacturers with the 

questionnaire before the interviews to facilitate the gathering of the appropriate information. 

Although a written response to its questionnaire is acceptable, DOE prefers an interactive 

interview process, because it helps clarify manufacturer responses and provides the opportunity 

to identify additional issues. 

DOE asks interview participants to identify all confidential information provided in 

writing or orally, and DOE determines whether the information submitted is entitled to 

confidential treatment. DOE will protect confidential information from disclosure, consistent 

with applicable law. It considers information gathered, as appropriate, in the energy 

conservation standards decision-making process. However, DOE does not make confidential 

information available in the public record. DOE also asks participants to identify all information 

that they wish to have included in the public record but that they do not want to have associated 

with their interview (thereby identifying that particular manufacturer). DOE incorporates such 

information into the public record, but reports it without attribution. 

DOE collates the completed interview questionnaire results and prepares a summary of 

the major issues and outcomes. This summary becomes part of the TSD produced in a 

rulemaking. 

78
 
 

15.2 Industry Cash-Flow Analysis 

The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of new or amended energy conservation standards on the industries 

that produce the products covered by the standard. 

The GRIM analysis uses a number of inputs—annual expected revenues; manufacturer 

costs such as costs of goods sold; selling, general, and administrative (SG&A) costs; taxes; and 

capital expenditures (both ordinary capital expenditures and those related to standards)—to 

determine a series of annual cash flows beginning from the announcement of the new or 

amended standards and continuing throughout the analysis period. DOE compares the results 

against base-case projections that involve no amended standards. The financial impact of new or 

amended standards is the difference between the two sets of discounted annual cash flows. Other 

performance metrics, such as return on invested capital, also are available from the GRIM. 

DOE gathers the inputs needed for the GRIM from two primary sources: (1) the analyses 

conducted to this point; and (2) interviews with manufacturers and other stakeholders. 

Information gathered from previous analyses includes financial parameters, manufacturing costs, 

price forecasts, and shipments forecasts. Interviews with manufacturers and other stakeholders 

are essential in supplementing this information. 

15.3 Manufacturer Subgroup Analysis 

It is possible that the use of average industry cost values may not adequately assess 

differential impacts among subgroups of manufacturers. DOE recognizes that smaller 

manufacturers, niche players, and manufacturers exhibiting a cost structure that differs 

significantly from the industry average may be affected differently by new or amended 

standards. Ideally, DOE would consider the impact on every firm individually. In highly 

concentrated industries, this may be possible. In industries having numerous participants, 

however, DOE uses the results of the market and technology assessment to group manufacturers 

into subgroups, as appropriate. 

Small businesses, as defined by the Small Business Administration (SBA) for ceiling fan 

and ceiling fan light kit manufacturers, are enterprises with 750 employees or fewer. Small 

business size standards are listed by North American Industry Classification System (NAICS) 

code and industry description. Ceiling fan and ceiling fan light kit manufacturing is classified 

under NAICS 335210, “Small Electrical Appliance Manufacturing.”41 A search of small 

businesses of this NAICS code listed in the U.S. Small Business Association website42 indicates 

that there may be up to 10 small businesses that manufacture ceiling fans and/or ceiling fan light 

kits that could potentially be covered by this rulemaking. However, as this NAICS code covers 

all small electrical appliance manufacturing, it is not clear how many of these manufacturers 

produce ceiling fans and ceiling fan light kits. As part of its subgroup analysis, DOE would 

identify small businesses that manufacture these products and interview small businesses 

affected by the rulemaking to determine if there are differential impacts on these companies that 

41 http://www.naics.com/free-code-search/naicsdescription.php?code=335210. 42 http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm. 

79
 
may result from amended energy conservation standards. DOE examines publicly-available data 

and contacts manufacturers, when needed, to determine if they meet the SBA’s definition of a 

small manufacturing facility and if their manufacturing facilities are located within the United 

States. 

The detailed manufacturer subgroup impact analysis entails calculating cash flows 

separately for each defined class of manufacturer. For ceiling fans and ceiling fan light kits, 

DOE is interested in feedback about potential subgroups, including small businesses. DOE will 

conduct a Regulatory Flexibility Act analysis to determine the impacts of any amended standards 

on small businesses. 

Item 69	 DOE seeks comment on the appropriate manufacturer subgroups, 

if any, for ceiling fans and ceiling fan light kits that DOE should 

consider in a manufacturer subgroup analysis. 

15.4 Competitive Impacts Analysis 

EPCA directs DOE to consider any lessening of competition that is likely to result from 

an imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and 6316(a)) It further directs the 

Attorney General to determine in writing the impacts, if any, of any lessening of competition 

likely to result from standards. (42 U.S.C. 6295(o)(2)(B)(ii)) 

DOE makes a determined effort to gather and report firm-specific information regarding 

financial and other impacts associated with amended energy conservation standards, and it will 

then report the anticipated aggregated impact of the amended standard on manufacturers. A key 

aspect of the competitive impacts analysis focuses on assessing the impacts on smaller 

manufacturers. DOE bases this assessment on manufacturing cost data and on information 

collected from interviews with manufacturers. These manufacturer interviews focus on 

gathering information that will help in assessing asymmetrical cost increases to some 

manufacturers, increased proportion of fixed costs potentially increasing business risks, and 

potential barriers to market entry (e.g., proprietary technologies). DOE provides the Attorney 

General with a copy of the NOPR and the TSD for consideration in the evaluation of the impact 

of amended standards in terms of the lessening of competition. DOE publishes the AttorneyGeneral’s letter and addresses any related comments in the final rule. 

15.5 Cumulative Regulatory Burden 

Other regulations (Federal, State, local, or international) may apply to manufacturers of 

ceiling fans and ceiling fan light kits covered under this rulemaking, as well as to other products 

made by the same manufacturers. Multiple regulations may result in a significant, cumulative 

regulatory burden on these manufacturers. Accordingly, DOE carefully considers the 

overlapping effects of amended DOE standards and other regulatory actions on manufacturers of 

ceiling fans and ceiling fan light kits. 

80
 
 

Item 70	 DOE welcomes comments on what other existing regulations or 

pending regulations it should consider in its examination of 

cumulative regulatory burden. 

16 EMISSIONS ANALYSIS 

In the emissions analysis, DOE will estimate the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2), and mercury (Hg) from 

potential amended energy conservation standards for ceiling fans and ceiling fan light kits. In 

addition, DOE will estimate emissions impacts in production activities (extracting, processing, 

and transporting fuels) that provide the energy inputs to power plants. These are referred to as 

“upstream” emissions. Together, these emissions account for the full-fuel-cycle. In accordance 

with DOE’s FFC Statement of Policy (76 FR 51281 (Aug. 18, 2011)), the FFC analysis also 

includes impacts of standards on emissions of methane and nitrous oxide, both of which are 

recognized as greenhouse gases. 

DOE will conduct the emissions analysis using emissions factors derived from data in the 

latest available version of EIA’s Annual Energy Outlook(AEO), supplemented by data from other 

sources. EIA prepares the Annual Energy Outlook using NEMS. Each annual version of NEMS 

incorporates the projected impacts of existing air quality regulations on emissions. 

Sulfur dioxide (SO2) emissions from affected electric generating units (EGUs) are subject 

to nationwide and regional emissions cap-and-trade programs. Title IV of the Clean Air Act sets 

an annual emissions cap on SO2 for affected EGUs in the 48 contiguous States and the District of 

Columbia (D.C.). SO2 emissions from 28 eastern States and D.C. were also limited under the 

Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), which created an allowancebased trading program that operates along with the Title IV program. CAIR was remanded to the 

U.S. Environmental Protection Agency (EPA) by the U.S. Court of Appeals for the District of 

Columbia Circuit (D.C. Circuit) (see North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008)), 

but it remained in effect. On July 6, 2011, EPA issued a replacement for CAIR, the Cross-State 

Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). The AEO 2012 NEMS assumes 

the implementation of the CSAPR.43 

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an energy conservation standard could be used to permit offsetting increases in SO2 

emissions by any regulated EGU. In past rulemakings, DOE recognized that there was 

uncertainty about the effects of efficiency standards on SO2 emissions covered by the existing 

43 On December 30, 2011, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and told EPA 

to continue administering CAIR. See EME Homer City Generation, LP v. EPA, Order, No. 11-1302, Slip Op. at *2 

(D.C. Cir. Dec. 30, 2011). On August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME 

Homer City Generation, LP v. EPA, No. 11-1302, 2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 2012). The court 

again ordered EPA to continue administering CAIR. AEO 2012 had been finalized prior to both these decisions; 

however. DOE understands that CAIR and CSAPR are similar with respect to their effect on emissions impacts of 

energy conservation standards. 

81
 
 

 

cap-and-trade system, but it concluded that negligible reductions in power sector SO2 emissions 

would occur as a result of standards. 

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 

2011. 77 FR 9304 (Feb. 16, 2012).44 In the final MATS rule, EPA established a standard for 

hydrogen chloride as a surrogate for acid gas hazardous air pollutants (HAP), and also 

established a standard for SO2 (a non-HAP acid gas) as an alternative equivalent surrogate 

standard for acid gas HAP. The same controls are used to reduce HAP and non-HAP acid gas; 

thus, SO2 emissions will be reduced as a result of the control technologies installed on coal-fired 

power plants to comply with the MATS requirements for acid gas. AEO 2012 assumes that, in 

order to continue operating, coal plants must have either flue gas desulfurization or dry sorbent 

injection systems installed by 2015. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 

emissions when electricity demand decreases (e.g., as a result of energy efficiency standards). 

Emissions will be far below the cap that would be established by CSAPR, so it is unlikely that 

excess SO2 emissions allowances resulting from the lower electricity demand would be needed 

or used to permit offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE 

believes that efficiency standards will reduce SO2 emissions in 2015 and beyond. 

CSAPR established a cap on NOX emissions in 28 eastern States and the District of 

Columbia. Energy conservation standards are expected to have little effect on NOX emissions in 

those States covered by CSAPR because excess NOX emissions allowances resulting from the 

lower electricity demand could be used to permit offsetting increases in NOX emissions. 

However, standards would be expected to reduce NOX emissions in the States not affected by 

CSAPR, so DOE estimates NOX emissions reductions from potential standards in the States 

where emissions are not capped. 

The MATS limit mercury emissions from power plants, but they do not include emissions 

caps, and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. For 

this rulemaking, DOE will estimate mercury emissions reduction using emissions factors based 

on the latest version of AEO, which incorporates the MATS. 

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOx. The monetary benefits that DOE estimates for 

reductions in SO2 and NOx emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM. 

44 On July 20, 2012, EPA announced a partial stay, for a limited duration, of the effectiveness of national new source 

emission standards for hazardous air pollutants from coal-fired and oil-fired electric utility steam generating units. 

See: http://www.epa.gov/airquality/powerplanttoxics/pdfs/20120727staynotice.pdf. 

82
 
 

 

 

Item 71 DOE seeks input on its approach to conduct the emissions analysis 

for the products covered by this rulemaking. 

17 MONETIZATION OF CO2 AND OTHER EMISSIONS REDUCTIONS 

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the amended energy 

conservation standard levels considered. 

In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2, DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or 

agreed to by an interagency process. The SCC is intended to be a monetary measure of the 

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

to, net agricultural productivity loss, human health effects, property damage from sea level rise, 

and changes in ecosystem services. Any effort to quantify and to monetize the harms associated 

with climate change will raise serious questions of science, economics, and ethics. But with full 

regard for the limits of both quantification and monetization, the SCC can be used to provide 

estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2015, expressed in 2011$, were $6.1, $25.4, 

$41.0, and $77.7 per metric ton avoided. For emissions reductions that occur in later years, these 

values grow in real terms over time. Additionally, the interagency group determined that a range 

of values from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although DOE will give preference to consideration of the global benefits of 

reducing CO2 emissions. To calculate a present value of the stream of monetary values, DOE 

will discount the values in each of the four cases using the discount rates that had been used to 

obtain the SCC values in each case. 

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also estimates the potential monetary benefit of reduced NOX emissions resulting 

from the standard levels it considers. For NOx emissions, available estimates suggest a very 

wide range of monetary values, ranging from $460 to $4,722 per ton in 2011$).45 In accordance 

with OMB guidance, DOE conducts two calculations of the monetary benefits derived using 

each of the economic values used for NOx, one using a real discount rate of 3 percent and 

another using a real discount rate of 7 percent.46 

45 For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs (OIRA), 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates 

on State, Local, and Tribal Entities. 46 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
 

83
 
 

 

DOE is investigating the appropriate valuation of Hg emissions. It currently does not plan 

to monetize estimates of reduced Hg emissions in this rulemaking. 

Item 72 DOE requests comments on the approach it plans to use for 

estimating monetary values associated with emissions reductions. 

18 UTILITY IMPACT ANALYSIS 

In the utility impact analysis, DOE analyzes the changes in electric installed capacity and 

generation that result for each trial standard level. The utility impact analysis uses a variant of the 

DOE/EIA’s National Energy Modeling System.47 NEMS is a public domain, multi-sectored, partial 

equilibrium model of the U.S. energy sector. Each year, DOE/EIA uses NEMS to produce an energy 

forecast for the United States, the Annual Energy Outlook. DOE uses a variant of this model, 

referred to as NEMS-BT,48 to account for selected utility impacts of new or amended energy 

conservation standards. DOE’s analysis consists of a comparison between model results for the most 

recent AEO Reference Case and for cases in which energy use is decremented to reflect the impact of 

potential standards. For the analysis of standards on ceiling fans and ceiling fan light kits, DOE 

will use the version of NEMS based on the latest available AEO. 

Item 73 DOE welcomes input from stakeholders on its proposed approach 

to conduct the utility impact analysis. 

19 EMPLOYMENT IMPACT ANALYSIS 

Employment impacts include direct and indirect impacts in the domestic workforce 

resulting from new or amended energy conservation standards. Direct employment impacts are 

any changes in the number of employees of manufacturers of the product subject to standards. 

The MIA addresses impacts in the number of employees working for the manufacturers. Indirect 

employment impacts from standards consist of the net jobs created or eliminated in the national 

economy, other than in the manufacturing sector being regulated, caused by: (1) reduced 

spending by end users on energy; (2) reduced spending on new energy supply by the utility 

industry; (3) increased spending on new products to which the new standards apply; and (4) the 

effects of those three factors throughout the economy. 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare sector employment statistics developed by the Labor 

Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of the 

number of jobs per million dollars of economic activity in different sectors of the economy, as 

47 For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration 

documentation. A useful summary is National Energy Modeling System: An Overview 2003, DOE/EIA-0581 (March 

2003). 

48 DOE/EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is run 

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it by the name NEMSBT. (BT is DOE’s Building Technologies Program, under whose aegis this work has been performed.) 

84
 
 

 

well as the jobs created elsewhere in the economy by this same economic activity. Data from 

BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and 

indirectly) than expenditures in other sectors of the economy.49 There are many reasons for these 

differences, including wage differences and the fact that the utility sector is more capitalintensive and less labor-intensive than other sectors. Energy conservation standards have the 

effect of reducing consumer utility bills. Because reduced consumer expenditures for energy 

likely lead to increased expenditures in other sectors of the economy, the general effect of 

efficiency standards is to shift economic activity from a less labor-intensive sector (i.e., the 

utility sector) to more labor-intensive sectors (e.g., the retail and service sectors). 

In the NOPR stage of this rulemaking, DOE plans to estimate indirect national 

employment impacts using an input/output model of the U.S. economy called Impact of Sector 

Energy Technologies version 3.1.1 (ImSET).50 ImSET is a special-purpose version of the “U.S. 

Benchmark National Input-Output” (I–O) model, which was designed to estimate the national 

employment and income effects of energy-saving technologies. The ImSET software includes a 

computer-based I–O model having structural coefficients that characterize economic flows 

among 187 sectors most relevant to industrial, commercial, and residential building energy use. 

DOE notes that ImSET is not a general equilibrium forecasting model and understands 

the uncertainties involved in projecting employment impacts, especially changes in the later 

years of the analysis. Because ImSET does not incorporate price changes, the employment 

effects predicted by ImSET may over-estimate actual job impacts over the long run. DOE may 

consider the use of other modeling approaches for examining long-run employment impacts. 

Item 74 DOE welcomes feedback on its proposed approach to assessing 

national employment impacts. 

20 REGULATORY IMPACT ANALYSIS 

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis that 

will address the potential for non-regulatory approaches to supplant or augment energy 

conservation standards to improve the efficiency of ceiling fans and ceiling fan light kits on the 

market. DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, 

utilities, and other interested parties can result in substantial efficiency improvements. DOE 

intends to analyze the likely effects of non-regulatory initiatives and compare such effects with 

those projected to result from amended energy conservation standards. DOE will attempt to base 

its assessment on the actual impacts of any such initiatives to date, but will also consider 

information presented regarding the impacts that any existing initiative might have in the future. 

DOE intends to analyze policies such as consumer rebates, consumer tax credits, manufacturer 

49 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input-Output 

Modeling System (RIMS II), U.S. Department of Commerce (1992) (Available at: 

http://www.bea.gov/scb/pdf/regional/perinc/meth/rims2.pdf). 50 J. M. Roop, M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies, PNNL-18412,
 

Pacific Northwest National Laboratory (2009) (Available at: 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf ).
 

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tax credits, voluntary energy efficiency targets (e.g., the ENERGY STAR program), early 

replacement, and bulk government purchasing. 

If DOE proposes energy conservation standards for ceiling fans and ceiling fan light kits 

and the NOPR constitutes a significant regulatory action, DOE would prepare and submit to 

OMB for review the assessment of costs and benefits required under section 6(a)(3) of Executive 

Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993). 

Item 75	 DOE requests any available data or reports that would contribute 

to the Regulatory Impact Analysis for ceiling fans and ceiling fan 

light kits covered in this rulemaking. In particular, DOE seeks 

information on the effectiveness of existing or past programs for 

these products that are similar to the policies noted above. 

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APPENDIX A – LIST OF ITEMS FOR COMMENT 

This appendix lists all the items for comment contained in this Framework Document and 

the page numbers on which those items can be found. 

Item 1 DOE seeks comments on its proposed reinterpretation of the ceiling fan 

definition. ...................................................................................................................5 

Item 2 DOE seeks comments on whether ceiling fans without external blades 

should be included in this rulemaking if they meet the definition of a 

ceiling fan...................................................................................................................5 

Item 3 DOE seeks comments on its proposed approach for developing definitions 

for the four types of ceiling fans, the vertical distance that is used to 

characterize whether a fan can safely be used in rooms with low ceiling 

heights, and any other physical characteristics used to determine the 

different types of ceiling fans currently on the market. .............................................7 

Item 4 DOE seeks comments on its proposed definition of “highly decorative 

ceiling fans.” ..............................................................................................................8 

Item 5 DOE seeks comments on its proposed definition of “outdoor ceiling fans”. ............9 

Item 6 DOE seeks comment on the existence and applicability of any other test 

procedure that DOE could consider for measuring the airflow and 

electrical energy consumption of ceiling fans. DOE seeks comment as to 

what types of testing manufacturers currently conduct on ceiling fans and 

what test set-ups and methods are used. DOE has noticed, for example, 

that some hugger fans are marketed with a declaration of energy 

efficiency. DOE is interested in knowing how manufacturers have tested 

such ceiling fans. ........................................................................................................18 

Item 7 DOE requests comments on the accuracy tolerance of the velocity sensors 

for either the current DOE or current ENERGY STAR test procedures and 

potential sources of inaccuracy for low speed airflow measurements.......................22 

Item 8 DOE requests comments on the potential performance variability between 

ceiling fans for a specific fan model and the possibility of requiring a 

sample of ceiling fans to certify a model. ..................................................................22 

Item 9 DOE requests comments on its proposal to investigate methodologies 

(including the use of an artificial ceiling) to enable hugger fans to be 

tested. DOE welcomes any information on how hugger fans currently are 

tested. .........................................................................................................................23 

Item 10 DOE requests comments on its proposal to test multi-mount fans in hugger 

fan configuration. .......................................................................................................23 

Item 11 DOE is considering investigating appropriate distances and measuring 

methodologies for ceiling fans having non-flat and unusually shaped 

blades to clarify how such fans should be measured. DOE requests 

feedback as to whether developing such methodologies is necessary and 

helpful. DOE seeks suggestions as to how best to clarify the test 

procedure to account for those types of configurations. ............................................23 

Item 12 DOE requests information on the effects of testing ceiling fans in 

cylinders having diameters other than 8 inches wider than the blade span 

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of the ceiling fan and seeks comments on the potential modifications to the 

test procedure described.............................................................................................23
 

Item 13 DOE requests comments on its proposed approach to testing ceiling fans 

with multiple fan heads..............................................................................................23
 

Item 14 DOE requests comments on its approach to testing ceiling fans where the 

airflow is not directed vertically. ...............................................................................23
 

Item 15 DOE is proposing to specify in its test procedure that heaters be switched 

off during testing. DOE requests comments on its proposed approach. ...................23
 

Item 16 DOE seeks comment on the possibility of testing at one, three, or all 

available fan speeds. Additionally, DOE seeks input on the amount of 

time spent at each fan speed setting...........................................................................23
 

Item 17 DOE seeks on how to define “high”, “medium”, and “low” speeds on fans 

with more than three speeds or variable speed controls. ...........................................23
 

Item 18 DOE seeks comments and any available data regarding its view that 

energy consumption in forward and reverse are likely to be highly 

correlated....................................................................................................................24
 

Item 19 DOE requests comments on the amount of energy ceiling fans consume in 

standby mode and/or off mode and how it compares to energy 

consumption in active mode. .....................................................................................27
 

Item 20 DOE requests feedback on its planned approach to use an integrated 

energy efficiency metric for ceiling fans. ..................................................................27
 

Item 21 DOE seeks information on the number of ceiling fans that are sold with 

remote controls or other devices that consume energy in standby mode 

and/or off mode..........................................................................................................27
 

Item 22 DOE seeks input on average ceiling fan usage, including the amount of 

time spent in each mode, and the feasibility of determining representative 

national average hours of operation...........................................................................27
 

Item 23 DOE requests comments on its proposal to use luminous efficacy as the 

efficiency metric for all ceiling fan light kits.............................................................30
 

Item 24 DOE requests comment on the proposal to base test procedures to 

determine ceiling fan light kit efficiency on the following IES lamp 

photometry test procedures: LM-9, LM-66, LM-45, and LM-79, 

depending on light source type. .................................................................................30
 

Item 25 DOE requests information on the existing and/or future market availability 

of ceiling fan light kits with inseparable LED lighting components. ........................30
 

Item 26 DOE requests comment on using guidance provided in the latest version 

of the upcoming ENERGY STAR Program Requirements for Luminaires 

for testing ceiling fan light kits with inseparable LED lighting 

components. ...............................................................................................................30
 

Item 27 DOE requests comment on the advantages or disadvantages of defining 

ceiling fan light kit efficacy as the total lamp lumens divided by the total 

input wattage..............................................................................................................30
 

Item 28 DOE requests input on whether ceiling fan light kits, or ceiling fan light 

kit controls, exist that have a standby mode and that operate independent 

of the ceiling fan. If such devices exist, DOE requests comment what 

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fraction of controllers that are of this type, the power draw in standby 

mode, and the fraction of time they spend in standby mode. ....................................31
 

Item 29 DOE requests feedback on its planned approach to attribute all standby 

power to the ceiling fan if ceiling fan standby is managed by a controller 

that is shared between the ceiling fan light kit and its ceiling fan. ............................31
 

Item 30 DOE requests information that would contribute to the market assessment 

for ceiling fans and ceiling fan light kits covered in this rulemaking (e.g., 

current product features and efficiencies, trends in product features and 

efficiency, and historical product shipments and prices). ..........................................35
 

Item 31 DOE welcomes input on estimates of market shares, products, features, 

and trends for the ceiling fans and ceiling fan light kits covered in this 

rulemaking. ................................................................................................................35
 

Item 32 DOE seeks input and data on ceiling fan life expectancy and, in particular, 

the relationship between ceiling fan usage and ceiling fan life expectancy. .............46
 

Item 33 DOE welcomes comments on whether it should establish a separate 

product class for hugger fans. ....................................................................................48
 

Item 34 DOE welcomes comments on whether it should establish a separate 

product class for “highly decorative fans for which air movement 

performance is a secondary feature.” DOE also seeks input on whether 

such ceiling fans should be subject to or exempted from energy 

conservation standards. ..............................................................................................49
 

Item 35 DOE seeks input on whether the differences between the construction of
 

outdoor and indoor ceiling fans warrants establishing a separate product 

class for outdoor ceiling fans. ....................................................................................49
 

Item 36 DOE seeks feedback from interested parties on its general approach to 

developing product classes. .......................................................................................49
 

Item 37 DOE requests feedback on the possibility of combining or restructuring 

product classes for ceiling fan light kits specifically on: (i) significant 

consumer utility differences among ceiling fan light kits; (ii) which 

products should be combined; and (iii) what issues should be considered. ...............50
 

Item 38 DOE requests feedback the consumer utility of ceiling fan light kits that
 

are packaged with dimming functionality..................................................................50
 

Item 39 DOE welcomes comments on the preliminary technology options 

identified in this section (i.e., high-efficiency motors and high-efficiency 

fan blades for ceiling fans) and whether there are other technology options 

it should consider. In commenting on technology options, please discuss 

their impacts (if any) on safety, performance, and consumer utility. ........................56
 

Item 40 DOE requests input on whether it should include occupancy sensors as an 

energy efficiency option for ceiling fans and on how these could be taken 

into consideration in its rulemaking. ..........................................................................56
 

Item 41 DOE welcomes input on the potential technology options for ceiling fan 

light kits and on other technology options that should be considered. ......................57
 

Item 42 DOE welcomes comments on any technologies listed in section 6.2 (or 

others not identified) that it should not consider based on any of the four 

screening criteria. If so, which screening criteria apply to the cited 

technology or technologies? DOE also welcomes comments on how the 

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above four screening criteria might apply to any additional technology 

option(s) that an interested party recommends to DOE. ............................................58 

Item 43 DOE seeks stakeholder comment on these and other potential approaches 

to determining the cost-efficiency relationship for ceiling fans and ceiling 

fan light kits. ..............................................................................................................60 

Item 44 DOE welcomes comments on its proposed approach and on the selection 

and appropriate features and performance characteristics of baseline 

models for each representative product group for ceiling fans..................................61 

Item 45 DOE seeks input from stakeholders regarding the range of efficiency 

levels that should be examined as part of its analysis for ceiling fans and 

ceiling fan light kits. ..................................................................................................61 

Item 46 DOE seeks input from interested parties on a methodology that would be 

appropriate for determining the max-tech models for each ceiling fan and 

ceiling fan light kit analyzed. .....................................................................................61 

Item 47 DOE seeks comments on its proposed methods for determining costs 

associated with incremental efficiency improvements in both ceiling fans 

and ceiling fan light kits. ............................................................................................63 

Item 48 DOE welcomes comments on how ceiling fan efficiency varies with 

airflow capacity, motor type, motor rated horsepower, blade span, number 

and design of blades, or any other ceiling fan parameter. DOE also seeks 

comments on how ceiling fan light kit efficiency varies with bulb type, 

number of bulbs, or any other ceiling fan light kit parameter. ..................................63 

Item 49 DOE welcomes comments on the proposed method for isolating costs 

associated with decorative features from costs associated with functional 

features in ceiling fans and ceiling fan light kits .......................................................63 

Item 50 DOE seeks information on proprietary designs of which it should be aware 

for both the ceiling fans and ceiling fan light kits under consideration in 

this rulemaking. If such proprietary designs exist, DOE would like to 

acquire the cost data necessary for evaluating those designs. ...................................64 

Item 51 DOE welcomes comments on regulatory burdens and changes that should 

be considered in the engineering analysis of ceiling fans and ceiling fan 

light kits. ....................................................................................................................64 

Item 52 DOE welcomes comments on other engineering issues that could affect 

the engineering analysis. ............................................................................................64 

Item 53 DOE welcomes suggestions and comments concerning its proposed 

approach for estimating end-user prices for ceiling fans and ceiling fan 

light kits. ....................................................................................................................66 

Item 54 DOE welcomes suggestions and comments concerning its assumed 

distribution channels for ceiling fans and ceiling fan light kits, and data 

and/or estimates regarding relative sales volumes through each channel. .................66 

Item 55 DOE welcomes comments on typical manufacturer, retailer, wholesaler, 

and contractor markups associated with ceiling fans and ceiling fan light 

kits. .............................................................................................................................66 

Item 56 DOE welcomes comments on its proposed methodology to determine 

annual operating hours and energy use for covered ceiling fans and ceiling 

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fan light kits, and how operating hours may vary (e.g., by product type and 

application, geographical location, season). ..............................................................68
 

Item 57 DOE welcomes comments from interested parties as to whether a moreefficient ceiling fan or ceiling fan light kit would be expected to be used 

more and whether such a rebound effect should be considered separately 

for this product...........................................................................................................70
 

Item 58 DOE seeks stakeholder input on the planned approach for estimating 

current and forecasted energy prices..........................................................................70
 

Item 59 DOE welcomes input on the planned approaches for estimating discount 

rates for consumers of ceiling fans and ceiling fan light kits. ...................................71
 

Item 60 DOE welcomes comments on appropriate maintenance and repair costs for 

ceiling fans and ceiling fan light kits. ........................................................................71
 

Item 61 DOE welcomes comments on appropriate lifetimes for both ceiling fans 

and ceiling fan light kits covered in this rulemaking. DOE is particularly 

interested in regional lifetime data and data on the relationship between 

ceiling fan usage and ceiling fan life expectancy. .....................................................72
 

Item 62 DOE seeks comments on the appropriate distribution of energy 

efficiencies for both ceiling fans and ceiling fan light kits in the absence of 

amended energy conservation standards. ...................................................................73
 

Item 63 DOE welcomes comments on the approach described to forecast 

shipments of ceiling fans and ceiling fan light kits. ...................................................73
 

Item 64 DOE seeks input on historical shipments and stock data for ceiling fans 

and ceiling fan light kits, including the distribution of shipments by 

efficiency....................................................................................................................74
 

Item 65 DOE welcomes comments on whether energy conservation standards 

might affect shipments of ceiling fans and ceiling fan light kits, as well as 

the anticipated extent of such impacts, if any. ...........................................................74
 

Item 66 DOE seeks comments on the appropriate assumptions to use regarding 

long-run changes in ceiling fan and ceiling fan light kit energy efficiency 

independent of amended energy conservation standards. ..........................................75
 

Item 67 DOE seeks comments on the use of the “roll-up” and “shift” efficiency 

scenarios to characterize the impact that potential standards would have on 

the product efficiency distributions. ..........................................................................75
 

Item 68 DOE welcomes input from interested parties regarding which, if any, 

consumer subgroups should be considered when developing potential 

energy conservation standards for ceiling fans and ceiling fan light kits. .................77
 

Item 69 DOE seeks comment on the appropriate manufacturer subgroups, if any, 

for ceiling fans and ceiling fan light kits that DOE should consider in a 

manufacturer subgroup analysis. ...............................................................................80
 

Item 70 DOE welcomes comments on what other existing regulations or pending 

regulations it should consider in its examination of cumulative regulatory 

burden. .......................................................................................................................81
 

Item 71 DOE seeks input on its approach to conduct the emissions analysis for the 

products covered by this rulemaking. ........................................................................83
 

Item 72 DOE requests comments on the approach it plans to use for estimating 

monetary values associated with emissions reductions. ............................................84
 

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Item 73 DOE welcomes input from stakeholders on its proposed approach to 

conduct the utility impact analysis. ............................................................................84 

Item 74 DOE welcomes feedback on its proposed approach to assessing national 

employment impacts. .................................................................................................85 

Item 75	 DOE requests any available data or reports that would contribute to the 

Regulatory Impact Analysis for ceiling fans and ceiling fan light kits 

covered in this rulemaking. In particular, DOE seeks information on the 

effectiveness of existing or past programs for these products that are 

similar to the policies noted above.............................................................................86 

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APPENDIX B – DRAFT PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

QUESTIONAIRE 

1 Issues 

1.1	 What are the key issues for your company regarding a possible future product rulemaking? 

2 Shipment Projections 

2.1	 What is your company’s approximate market share? 

2.2	 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels? 

2.3	 How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

2.4	 Looking at price/cost effects only, how would you expect shipments to change for a 5 

percent, 10 percent, 25 percent, or 50 percent manufacturer price/cost increase? 

3 Conversion Costs 

3.1	 What level of capital expenditure and product conversion costs would you anticipate to 

make at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes. 

3.2	 How would the adoption of amended energy conservation standards affect capacity 

utilization and manufacturing assets at your domestic production facilities? Would an 

amended standard result in stranded capital assets? Would any facilities be closed or 

downsized? Added or upgraded? 

3.3	 How might an amended standard impact product innovation? 

4 Product Mix and Profitability 

4.1	 How would your company’s product mix and marketing strategy change with changes in 

the efficiency standard? 

4.2	 What distribution channels are used from the manufacturer to the retail outlet? What is the 

share of product going through each distribution channel? 

4.3	 Generally, how would new product standards affect your customer mix, distribution 

channels, and corresponding profit margins? 

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4.4	 How might a new standard affect the ENERGY STAR program, and consequently your 

firm? 

5 Market Shares and Industry Consolidation 

5.1	 In the absence of amended standards, do you expect any industry consolidation? 

5.2	 How would amended standards affect your ability to compete? 

5.3	 Could amended standards disproportionately advance or harm the competitive positions of 

some firms? 

5.4	 Are there concerns over intellectual property? 

5.5	 Could amended standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups? 

5.6	 Beyond price and energy efficiency, could amended standards result in products that will 

be more or less desirable to consumers due to changes in product functionality, utility, or 

other features? 

6 Cumulative Regulatory Burden 

6.1	 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry? 

6.2	 If so, what is the total expected impact of those other regulations? 

94