### 1 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 de veloping regulations for fan efficiency standards; and to inform DOE on how commercial and industrial fan markets work.

Representin g the U.S. Department of Energy:

• John Cymbalsky, Supervisor, Appliance Standards, Building Technologies Program

• Charles Llen za, 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. f an m arket AMCA summarized its history and membership , emphasizing its mission to promote the health, growth, and int egrity 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 wou ld take approximately

### 2 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 first

time 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 f an m arket p erspective AMCA described that there are many different types of fans because ther e are so many different appl ications based on duty and size (Exhibits 2 and 3) Different types of fans have different efficiencies, bu t even lower

- efficiency fans can be better selections for specific duties, such as material handling, emergency smoke

evac uation, 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 commerci al fans are sized and selected, with smaller fans having lower efficiencies, but l ower 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 f an m arket p erspective AMCA described how a large fraction of the industrial fan market is design/bu ild, 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 lar ge 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 f an e fficiency s tandards and performance certificat ion 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

e fficiency 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 Exhi bit 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).

### 3 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’ inf ormation 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 Moveme nt; 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 standa rds, 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.

### 4 Navy during World War I. AMCA currently maintains 20 differe nt 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 pr imary 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 12 759 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 Inter national 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 provid es FSAT training for the DOE.

• ISO began development of Standard 12759 in 200 9 , 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 soo n 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 rev iew, 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 Gui de 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.

### 5 Exhibit 2

Photos of Different Fan Types

Centri l ulI"llnline • FEG 61

Mixed-flow Inline • F E G 80 

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### 6 Exhibit 3

Ph otos of Different Fan Types

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Cemrilugal SWSI • FEG 85 Mixed_How I lIline • F E G 80

Axial Fall • FEG 60 Energy Recove<y 

### VemiLator • FEG 50

### 7 Exhibit 4

Fan Selection Example

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### 8 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 p ower, 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 f ollows:

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