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30 West University Drive • Arlington Heights, IL 60004 • 847-394-0150 • www.amca.org

TO: expartecommunications@hq.doe.gov (sent via email)

FROM: Wade Smith, Executive Director, AMCA International

DATE: December 23, 2011

RE: Memorandum Memorializing Ex Parte Communication, December 19, 2011 for 

DOE impending determination of coverage for commercial and industrial fans, blowers, 

and fume hoods, Docket!No!EERE,2011,BT,DET,0045.

Meeting Purpose: The meeting was requested by AMCA International to introduce the 

association’s leadership, standards, and experience in developing fan standards to DOE; 

to learn more about the DOE process for developing regulations for fan efficiency 

standards; and to inform DOE on how commercial and industrial fan markets work.

Representing the U.S. Department of Energy:

• John Cymbalsky, Supervisor, Appliance Standards, Building Technologies 

Program

• Charles Llenza, Project Manager, Appliance Standards, Building Technologies 

Program

Representing AMCA International:

• Michael Barry, Chairman of the Board, AMCA and President, Twin City Fan

• Vic Colwell, President, AMCA and VP Sales and Marketing, Loren Cook

• Wade Smith, Executive Director, AMCA

• Michael Ivanovich, Director of Strategic Energy Initiatives, AMCA

Notes:

• Introductions

• About AMCA and the U.S. fan market

AMCA summarized its history and membership, emphasizing its mission to 

promote the health, growth, and integrity of the air movement and control 

industry in the interest of the public. (Exhibit 1).

• About DOE and DOE's efficiency standards program 

DOE summarized how efficiency standards are developed, and stated that DOE 

had not yet made a final ruling on its proposed determination of coverage. DOE 

also stated that setting fan efficiency regulations was discretionary, not 

mandatory, so there was no certainty that regulations would be developed. If DOE 

were to decide to set efficiency standards, the process would take approximately 
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two years (and possibly three) and compliance would be required three years later 

(but which could possibly be extended to five years because this would be a firsttime ruling). DOE also suggested that AMCA consider taking proactive measures 

by working with industry stakeholders, such as efficiency groups, utilities, etc. to 

develop a joint proposal for fan efficiency regulation.

• Commercial fan market perspective

AMCA described that there are many different types of fans because there are so 

many different applications based on duty and size (Exhibits 2 and 3) Different 

types of fans have different efficiencies, but even lower-efficiency fans can be

better selections for specific duties, such as material handling, emergency smoke 

evacuation, and low-pressure high volume air movement. The variety of fans and 

applications will make fan regulation difficult. AMCA also provided an example 

of how some commercial fans are sized and selected, with smaller fans having 

lower efficiencies, but lower first costs, are often purchased instead of larger fans 

that cost more but can have energy-cost paybacks of less than 1 year (Exhibit 4).

• Industrial fan market perspective

AMCA described how a large fraction of the industrial fan market is design/build, 

whereby specific fans are custom designed and built for the one application they 

will be used, such as for a utility plant or a manufacturing process. AMCA also 

discussed how industrial fan owners are very aware of energy efficiency because 

of the large amount of energy they use – and there are often penalties to fan 

manufacturers (liquidated damages) if fans installed in the field do not yield the 

promised operating efficiencies when tested. 

• AMCA’s leadership on fan efficiency standards and performance certification 

AMCA discussed it’s proactive fan efficiency leadership in the development of 

standards and having its standards adopted into national codes and standards, and 

the testing program it runs to verify manufacturer certification of ratings and 

efficiency performance (Exhibit 1 and 5).

Exhibit 1: AMCA Fact Sheet on Fan Efficiency Leadership

Exhibit 2: Photos of different fan types

Exhibit 3: Photos of different fan types

Exhibit 4: Example of a commercial fan sizing/selection software output

Exhibit 5: Final language on minimum fan efficiency proposed by AMCA and adopted 

by 2012 International Green Construction Code (prescriptive path for buildings 25,000 sq 

ft and less).
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About AMCA International and Fan Efficiency

Prepared Dec. 16, 2011 by 

AMCA International

30 W. University Drive, Arlington Heights, IL 60004

www.amca.org

Overview of AMCA International

The Air Movement and Control Association International (AMCA) is a not-for-profit 

trade association. Member firms manufacture commercial and industrial fans, 

blowers, dampers, louvers, air-monitoring stations, acoustical products, and more. 

AMCA’s mission to promote the health, growth, and integrity of the air movement 

and control industry in the public interest of the public. 

AMCA has its roots going back to 1917, when 11 companies met for the first time as 

the National Credit Association of Fan Manufacturers. In 1919, the organization 

changed its name to the National Association of Fan Manufacturers (NAFM). In 1955, 

NAFM consolidated with the Power Fan Manufacturers Association to become the Air 

Moving and Conditioning Association (AMCA). This is considered the formal start of 

“AMCA” as we know it. In 1977, AMCA changed its name to Air Movement and 

Control Association International to reflect its broader product and regional scope.

AMCA International currently has 291 members with three core regions having the 

majority of members, as shown in Table 1. Table 1 also reflects how our 

international scope extends to serving our members’ information needs through our 

Website, www.amca.org.

Table 1: AMCA International Membership Regions

Region Member 

Companies

Website Traffic 

(%)

North America 161 72

Pacific Region 89 19

Europe 22 7

Other 19 3

AMCA has four divisions: Air Movement; Air Control; Acoustic Attenuation, and Air

Flow Measurement Monitoring Stations. Members can be represented in more than 

one region. The Air Movement Division is by far the largest, with 213 members. 

AMCA has a long history of developing test standards, such as AMCA 210 Laboratory 

Methods of Testing Fans for Certified Aerodynamic Performance Rating, which was 

first published in 1923 in response to fan-rating problems encountered by the U.S. 
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Navy during World War I. AMCA currently maintains 20 different testing standards, 

15 of which are ANSI-certified. Thirteen AMCA standards focus on fans, nine of which 

are ANSI-certified.

AMCA International has been certifying fan performance for over 60 years. 

Participating in the Certified Ratings Program is a primary reason why a large 

number of member firms join AMCA. Currently, 193 (66%) of AMCA members certify 

at least one product. The directory of certified products that AMCA maintains for 

public use is the most heavily trafficked section of our Website after the Home page.

AMCA Energy Efficiency Leadership

AMCA International has been on the forefront of the development of U.S. and 

international standards for fan efficiency. We participated in the International 

Standards Organization’s development of ISO 12759 Efficiency Classification for 

Fans, and published a U.S. standard, AMCA 205 Energy Efficiency Classification for 

Fans shortly afterward. AMCA 205 was developed slightly behind ISO 12759 so the 

two standards could be harmonized.

AMCA began certifying fan efficiency performance in 2011, while also working with 

ASHRAE and the International Code Council to adopt fan-efficiency standards that 

reference AMCA 205. The following is a timeline of AMCA fan-efficiency leadership for 

codes, standards, regulations, and guidelines.

• In 2005, AMCA partnered with the U.S. Dept. of Energy to launch the Fan 

System Assessment Tool (FSAT), which calculates the amount of energy used 

by an industrial fan and examines fan-system performance characteristics. 

AMCA still provides FSAT training for the DOE.

• ISO began development of Standard 12759 in 2009, with U.S. and AMCA 

participation and AMCA 205 development started later the same year.

• AMCA 205 was published in 2010, slightly after ISO 12759-10.

• AMCA 205 was revised in 2011 and will soon be publicly available; ANSI 

approval is expected in the first quarter of 2012.

• In 2011, AMCA drafted a Continuous Maintenance Proposal for 

ANSI/ASHRAE/IES 90.1, 2011, which eventually became “Addendum u.” 

Following an advisory public peer review, AMCA led the development of the 

first draft of revised language for Addendum u, which is now in the hands of 

the SSPC 90.1 Mechanical Subcommittee, for consideration toward the 

January 2012 ASHRAE Winter Meeting. 

• AMCA developed a code change proposal for the 2012 International Green 

Construction Code, which was adopted despite opposition from AHRI.

• AMCA responded affirmatively to a U.S. Dept. of Energy proposed 

determination for defining commercial fans, blowers, and fume hoods as 

“covered equipment” under the Energy Policy and Conservation ACT. AMCA is 

seeking to collaborate with the DOE in the development of fan efficiency 

standards.

• Reference to AMCA 205 and Fan Efficiency Grades are in the current working 

draft of the 50% Advanced Energy Design Guide Big Box Retail Stores.

• Pending!developments!with!Addendum!u!for!90.1,2010,!in!2012,!AMCA!plans!

to!assist!with!the!harmonization!of!ASHRAE!189.1!and!the!IECC!with!90.1,!

and!the!IGCC!with!189.1.
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Exhibit 2 

Photos of Different Fan Types 

Centril ulI"llnline • FEG 61 

Mixed-flow Inline • FEG 80 

nq 

, -'I 

t·. ~ -

Computational Fluid Dynamic. (C FD) 

MlHlel 01 Mixed-flow Impeller 
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Exhibit 3 

Photos of Different Fan Types 

CerllJifugaI Restaurant Exhaust· FEG 61 Axial"""! • FEG 53 

Cemrilugal SWSI • FEG 85 Mixed_How IlIline • FEG 80 

Axial Fall • FEG 60 Energy Recove<y VemiLator • FEG 50 
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Exhibit 4 

Fan Selection Example 

" " 1m ., " ~ " 

101 ,. '" " "Ul1 " 

I ll)" lO' 1)} '" OJ '" " IE 

I 1(11 '" '" 

. " 

'""""'M ... __ "'-'<""', ... ""' ... OO,_ .. "'.· ... ~ ... ..",,_ ...... ..,_._ ,_ _ _ (Ul'_~ ~ .... ,.". "'''''_D •. L''' ....... _,''' ~ .... __ _ """' __ ri .... -... 

Cetltriit>glll F ..... FEG 85 

Double WKlth I Dooble Inle{ 

""" ..., ~ 

"'~-~ ~"""" 

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Exhibit 5

Language adopted into the 2012 International Green Construction Code

CHAPTER 6

607.2.2.3 Minimum fan efficiency. Stand alone supply, return and exhaust fans designed 

for operating with motors over 750 watts (1hp) shall have an energy efficiency classification 

of not less than FEG71 as defined in AMCA 205-10. The total efficiency of the fan at the 

design point of operation shall be within 10 percentage points of either the maximum total 

efficiency of the fan or the static efficiency of the fan.

Add new definition as follows:

SECTION 202 

DEFINITIONS 

FAN EFFICIENCY GRADE (FEG). A numerical rating identifier that specifies the fan’s 

aerodynamic ability to convert shaft power, or impeller power in the case of a direct driven 

fan, to air power. FEGs are based on fan peak (optimum) energy efficiency that indicates 

the quality of the fan energy usage and the potential for minimizing the fan energy usage.

Add new standard as follows:

CHAPTER 12 

REFERENCED STANDARDS 

AMCA Air Movement and Control Association International

30 West University Dr.

Arlington Heights IL 60004-1806

205-10 Energy Efficiency Classification for Fans