## E nergy Conservation Standards Rulemaking Framework for

Commercial and Industrial Fans and Blowers

United States Department of Energy Office of Energy Efficiency and Renewable Energy

Building Technologies Program

January 28, 2013i TABLE OF CONTENTS

1. INTRODUCTION

................................ ................................ ................................ ............... 1

1.1 EPCA Coverage of Commercial and Industrial Fans

................................ ........... 1
1.2 Overview of the Rulemaking Process and Interested Parties Participation

........... 2
1.2.1 Preliminary Analysis

................................ ................................ .................... 3
1.2.2 Notice of Proposed Rulemaking

................................ ................................ .... 5
1.2.3 Final Rule

................................ ................................ ................................ ..... 5
1.2.4 Labeling

................................ ................................ ................................ ....... 6
2. OVERVIEW OF THE RULEMAKING SCOPE

................................ ................................ . 7

2.1 Current Coverage

................................ ................................ ............................... 7
2.1.1 Equipment Definitions

................................ ................................ .................. 7
2. 2 Preliminary Discussion of Fans For Which DOE is Considering Standards

....... 10
2.2.1 Fan Types

................................ ................................ ................................ ... 10
2.2.2 Motor Considerations

................................ ................................ ................. 13
2.2.3 Transmission Type Considerations

................................ ............................. 14
2.2.4 Variable

- Speed Drive Considerations

................................ ......................... 15
2.2.5 Consideration of Standards for Fans in Fume Hoods

................................ ... 15
3. TEST PROCEDURES

................................ ................................ ................................ ....... 16

3.1 Preliminary Discussion of Test Procedure Approaches for the Energy
Performance of Fans

................................ ................................ ................................ .............. 16
3.2 Discussion of Efficiency Metric Approaches for the Energy Performance of Fans
18
3.2.1 Data Sources for Efficiency Metric Development

................................ ....... 18
3.2.2 Efficiency Metric Approaches

- Bare Shaft Fans

................................ ......... 19
3.2.3 Efficiency Metric Approaches

- Fans defined as inclusive of motor/controls
20
3.2.4 Efficiency Metric Implications for Defining Fans Inclusive of
Motor/Controls

................................ ................................ ................................ .................. 21
4. OVERVIEW OF ANALYSES FOR RULEMAKING

................................ ....................... 25
5. MARKET AND TECHNOLOGY ASSESSMENT

................................ ........................... 28

5.1 Market Assessment

................................ ................................ ........................... 28
5.2 Equipment Classes

................................ ................................ ........................... 29
5.2.1 Fan Equipment Classes

................................ ................................ ............... 29
5.3 Technology Assessment

................................ ................................ ................... 33

6. SCREENING ANALYSIS

................................ ................................ ................................ 36

7. ENGINEERING ANALYSIS

................................ ................................ ............................ 37

7.1 Engineering Analysis Overview

................................ ................................ ....... 37
7.2 Engineering Analysis Methodology

................................ ................................ .. 39
7.2.1 Representative Unit Selection Methodology

................................ ............... 41
7.3 Baseline Models

................................ ................................ ............................... 42
7.4 Proprietary Designs

................................ ................................ .......................... 43
7.5 Efficiency Levels

................................ ................................ .............................. 44
7.6 Outside Regulatory Changes Affecting the Engineering Analysis

..................... 44
8. MARKUPS ANALYSIS

................................ ................................ ................................ ... 44ii 8.1 Market Participants and Distribution Channels

................................ ................. 45
8.1.1 OEM Market Segments (OEM Channel A)

................................ ................. 46
8.1.2 Distributor Channel

— Market Segments (Distributor Channels B and C)

.... 46
8.1.3 Distribution Channel Shares

................................ ................................ ....... 47
8.2 Estimating Markups

................................ ................................ ......................... 47
9. ENERGY USE AND END

- USE LOAD PROFILE CHARACTERIZATION

................... 4 8

9.1 Overview

................................ ................................ ................................ .......... 49
9.2 Analytical Approach

................................ ................................ ......................... 50
10. LIFE

- CYCLE COST AND PAYBACK PERIOD ANALYSIS

................................ .......... 51

10.1 Approach for Conducting the Life

- Cycle Cost and Payback Period Analysis 51
10.2 Installation Costs

................................ ................................ .......................... 52
10.3 Energy Prices

................................ ................................ ................................ 53
10.4 Maintenance and Repair Costs

................................ ................................ ...... 53
10.5 Equipment Lifetime

................................ ................................ ...................... 54
10.6 Discount Rates

................................ ................................ .............................. 54
10.7 Base Case Efficiency

................................ ................................ .................... 55
11. SHIPMENTS ANALYSIS

................................ ................................ ................................ 55

11.1 S tandards Impacts on Shipments

................................ ................................ ... 55
12. NATIONAL IMPACT ANALYSIS

................................ ................................ .................. 56

12.2 National Energy Savings

................................ ................................ ............... 56
12.3 Net Present Value of User Benefits

................................ ............................... 57
13. CUSTOMER SUBGROUP ANALYSIS

................................ ................................ ........... 57
14. MANUFACTURER IMPACT ANALYSIS

................................ ................................ ...... 58

14.1 Sources of Information for the Manufacturer Impact Analysis

...................... 58
14.2 Industry Cash Flow Analysis

................................ ................................ ........ 59
14.3 Manufacturer Subgroup Analysis

................................ ................................ .. 59
14.4 Competitive Impacts Assessment

................................ ................................ .. 60
14.5 Cumulative Regulatory Burden

................................ ................................ ..... 60
15. UTILITY IMPACT ANALYSIS

................................ ................................ ....................... 60
16. EMPLOYMENT IMPACT ANALYSIS

................................ ................................ ............ 61
17. EMISSIONS ANALYSIS

................................ ................................ ................................ . 62
18. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS

.......... 64
19. REGULATORY IMPACT ANALYSIS

................................ ................................ ............ 65
APPENDIX A

– LIST OF ITEMS FOR COMMENT

................................ ............................... 66 References

................................ ................................ ................................ ................................ . 73iii LIST OF FIGURES Figure 1. Flow Diagram of Analyses for the Fans and Standards Rulemaking Process

... 27 Figure 2. Commercial and Industrial Fan Distribution Channels

................................ .... 46

LIST OF TABLES

Table 1. Installation Category/ Test Configurations Descriptions

................................ ... 18 Table 2. Regulation Options and Efficiency Metric Alignment Options for Respective Equipment Class Sets

................................ ................................ ................................ ................ 25 Table 3. Considered Commercial and Industrial Fan Equipment Classes

........................ 30iv

LIST OF ABBREVIATIONS
AC alternating current
ACH air changes per hour
AEC annual energy consumption
AEO Annual Energy Outlook
AHAM Association of Home Appliance Manufacturers
AHRI Air

- Conditioning, Heating, and Refrigeration Institute
AIHA American Industrial Hygiene Association
AMCA Air Movement and Control Association International, Inc.
ANSI American National Standard Institute
ASHRAE American Society of Heating, Refrigerating, and Air Conditioning

Engineers

BT Building Technologies Program
CAV constant air volume
CFM cubic feet per minute
CFR Code of Federal Regulations
CSL candidate standard level
DC direct current
DOE U.S. Department of Energy
DOJ U.S. Department of Justice

EERE Office of Energy Efficiency and Renewable Energy
EIA Energy Information Administration
EISA Energy Independence and Security Act of 2007
EPA U.S. Environmental Protection Agency
EPACT Energy Policy Act of 1992
EPCA Energy Policy and Conservation Act

EU European Union

FPM feet per minute

FR Federal Register
GDP gross domestic product
GRIM government regulatory impact model
HVAC heating, ventilating, and air conditioning
LCC life

- cycle cost
NAICS North American Industry Classification System
NEMA National Electrical Manufacturers Association
NEMS National Energy Modeling System
NES national energy savings
NOPR notice of proposed rulemaking
NPV net present value
OMB U.S. Office of Management and Budget
R&D research and developmentv

RPM revolutions per minute
SBA Small Business Administration
TSD technical support document
TSL trial standard level
U.S.C. United States Code
VAV variable air volume
VSD variable speed drive
WSU Washington State University1

1. 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), establishes test procedures and energy conservation standards for certain cons umer appliances and commercial and industrial equipment. The process for consider ing whether to
establish standards involves analysis, public notice and comment, and consultation with interested parties. Interested parties include manufacturers, consumers, energy conservation and environmental advocates, State and Federal agencies, and any other groups or individuals with an interest in these standards and test procedures.

The purpose of this document is to describe the procedural and analytical approaches DOE anticipates using to evaluate potential new energy conservation standards or energy use
standards for fans and blowers

. DOE considers blowers to be a type of fan (discussed in section
2.1.1 ) ; therefore, blowers will hereinafter be referred to as "fans". This framework document is intended to inform interested parties of the process DOE will follow for this standards rulemaking and to encourage an d facilitate the input of interested parties during the rulemaking. This document is merely the starting point for evaluating energy conservation standards or energy use standards and is not a definitive statement on any issue to be determined in the
rulem aking.

Section 1 of this report includes an overview of DOE’s appliances and commercial and industrial equipment standards program, the statutory authority for this rulemaking, and the rulemaking process. Fan scope of coverage and test procedures are described in sections 2 and 3

, respectively . Sections 4 through 19 discuss the analyses DOE intends to conduct to fulfill the statutory requirements and guidance for this energy conservation standards rulemaking. DOE’s analysis will determine whether new energy conservation standards or energy use standards are technologically feasible, economically justified, and would result in significant energy savings. DOE will maintain information about this rulemaking on its website at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/65

.

While DOE invites comment on all aspects of the material presented in this document, several 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 anal yses required for the energy conservation standards rulemaking. Such requests for feedback are numbered sequentially throughout the document and are repeated in Appendix A.

1.1 EPCA Coverage of Commercial and Industrial Fans

Title III of the Energy Policy and Conservation Act of 1975 (EPCA), as amended (42 U.S.C. 6291 et seq.), sets forth various provisions designed to improve energy efficiency. Part C of Title III of EPCA (42 U.S.C. 6311

- 6317)(re

- designated as part A

- 1 upon codification in the U.S. Code), est ablishes the "Energy Conservation Program for Certain Industrial Equipment,"2

which covers certain commercial and industrial equipment (hereafter referred to as "covered equipment").

EPCA specifies a list of equipment that constitutes covered equipment. (4 2 U.S.C. 6311(1)(A)

- (L). The list includes 11 types of equipment and a catch

- all provision for certain other types of industrial equipment classified as covered by the Secretary of Energy (Secretary). EPCA also specifies the types of equipment that can be classified as covered in addition to the listed equipment, and the criteria that must be met. This equipment includes fans and blowers. (42 U.S.C. 6311(2)(A) and (B)). To be considered covered industrial equipment the equipment
must also be of a type that :

(1) Consume s , or is designed to consume, energy in operation;

(2) To any significant extent, is distributed in commerce for industrial or commercial use;

(3) Is n ot a covered product as defined in 42 U.S.C. 6291(a)(2) of EPCA, other than a

component of a covered pro duct with respect to which there is in effect a

determination under 42 U.S.C. 6312(c).

To classify equipment as covered commercial or industrial equipment, the Secretary must determine that classifying the equipment as covered equipment is necessary for th e purposes of
Part A

- 1 of EPCA. The purpose of Part A

- 1 is to improve the efficiency of electric motors, pumps and certain other industrial equipment to conserve the energy resources of the nation. (42 U.S.C. 6312(b)). N otice of DOE’s p roposed d eterminati on of c overage was published on June 28, 2011. ( 76 FR 37678 )

. DOE is not considering standards for fans that are a component in regulated comm ercial products in this rulemaking.

1.2 Overview of the Rulemaking Process and Interested Parties Participation

Under EPCA, any new or amended standards must achieve the maximum level of energy efficiency that is technologically feasible and economically justified. In setting any new or amended standards, DOE must consider: (1) the economic impact of the standard on the manufacturers and consumers of the affected products; (2) the savings in operating costs throughout the estimated average life of the product compared to any increases in the initial cost or maintenance expense; (3) the total projected amount of energ y savings likely to result directly from the imposition of the standard; (4) any lessening of the utility or the performance of the products likely to result from the imposition of the standard; (5) the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the imposition of the standard; (6) the need for national energy conservation; and (7) other factors the Secretary considers relevant. (42 U.S.C. § 6295(o)(2)(B)(i) and 42 U.S.C. § 6316(a))

As discussed in further detail below, the standards rulemaking process typically involves four steps for a given consumer product or commercial and/or industrial equipment type: (1) the publication of a framework document in which DOE describes the ove rall approach it is considering in developing potential energy conservation standards for a particular product or3

equipment; (2) the publication of a preliminary analysis that focuses on the analytical methodology DOE is considering in setting potential st andards; (3) the issuance of a notice of proposed rulemaking (NOPR); and (4) the issuance of a final rule. At each of the first three steps, DOE holds a public meeting and solicits comments from the public on a variety of relevant
issues under considerati on in developing potential standards.

A brief description of the next steps in DOE’s process follows:

Preliminary Analysis (section 1.2.1 ). The preliminary analysis presents a discussion of comments received on the framework document and is designed to publicly vet the models and tools that DOE intends to use in the rulemaking. Using these models and tools, DOE performs preliminary analyses to assess candidate standard levels (CSLs), which span the range of efficiencies from baseline equipment to the most efficient technology.

Notice of Proposed Rulemaking (NOPR) (section 1.2.2 ). The NOPR presents a discussion of comments received in response to the preliminary analysis, DOE’s analysis of the impacts of potential standards on consumers, manufacturers, and the nation, DOE’s weighting of these impacts, and any proposed standard levels for public comment.

Final Rule (section 1.2.3 ). The final rule presents a discussion of comments received in response to the NOPR, revised analysis, as appropriate, of the impacts of any standards, DOE’s weighting of those impacts, and the standard levels, if any, that DOE is adopting.
Th e final rule also establishes the date by which manufacturers must comply with any
standards.

DOE encourages interested parties to develop and submit joint recommendations and will carefully consider such recommendations in its decision making.

1.2.1 Prelimina ry Analysis

As part of its energy conservation standards rulemaking activity, DOE typically identifies equipment technology options and makes a preliminary determination as to whether to retain each option for detailed analysis or to eliminate it from furt her consideration. This process includes a market and technology assessment (section 5 ) and a screening analysis ( section 6 ). DOE applies four screening criteria in the screening analysis to determine which technology options to eliminate from further consideration: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on e quipment utility or availability; and (4) adverse impacts on health or safety. Technologies that pass through the screening analysis are evaluated, and referred t o as design options, in the engineering analysis (section 7 )

.

DOE consults with interested parties and researches industry literature to identify the design options or efficiency levels that DOE will consider in the rulemaking. DOE considers design options or efficiency levels for each equipment class. DOE uses these design options or efficiency levels to collect manufacturer cost data, historical s hipment data, shipment

- weighted average efficiency data, and preliminary manufacturer impact data ( e.g. , capital conversion expenditures, marketing costs, and research and development (R&D) costs). As part of the4

preliminary analysis, DOE also conducts oth er principal analyses, many of which are described in this document, including:

1. engineering analysis (section 7 );
2. markups analysis (section 8 );
3. energy use analysis (section 9 );
4. consumer life

- cycle cost (LCC) and payback period (PBP) analysis (section 10 );
5. shipments analysis(section 11 );

6. national impact analysis (NIA), which considers national energy savings (NES) and consumer net present value (NPV) (section 12 ); and

7. preliminary manufacturer impact analysis (MIA) (section 14 ).

DOE will present the results of these analyses in the preliminary analysis technical support document (TSD).

Based on the preliminary results of these analyses, DOE selects CSLs from the energy efficiency levels considered in the preliminary analysis. In addition to the efficiency level corresponding to the maximum technologically feasible ("max

- tech") efficiency level, DOE generally considers efficiency levels that span the full range of technologically achievable efficiencies. The range of efficiency levels DOE typically analyzes includes:

The baseline efficiency level, which typically represents equipment with the lowest energy efficiency on the market. For equipment where minimum energy conservation standards already exist, the baseline efficiency level is typically defined by the existing energy conservation standard.

The highest energy efficiency level or lowest energy consumption level that is technologically feasible ( i.e. , max

- tech)

.

Levels that incorporate noteworthy technologies or fill large gaps between other efficiency levels being considered.

DOE uses analytical models and tools to assess the different equipment classes at each efficiency or energy use level analyzed. Many of these analytical models and tools are in the form of spreadsheets, used to conduct the LCC and PBP analysis and to determine the NES and NPV of prospective standards. Discussion of various CSLs in the preliminary analysis helps interested parties review the spreadsheet models that underpin the analyses. DOE uses comments from interested parties to refine the models for the next stage of the rulemaking analyses.

DOE makes the spreadsheet tools and results of the preliminary analysis available on its
webs ite for review. 1 When it publishes the preliminary analysis, DOE also make s a preliminary TSD available, which contains the details of all the analyses performed to date. After publication

1 All materials associated with the test procedure and energy conservation standards rulemakings for this equipment are available on DOE’s website at: http:/ /www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/655

of the preliminary analysis, DOE provides a public comment period a nd holds a public meeting to discuss these analyses.

1.2.2 Notice of Proposed Rulemaking

In developing any NOPR, DOE considers the comments received during the comment period on the preliminary analysis. This process can result in revisions to the analyses cond ucted during the preliminary analysis stage; DOE conducts additional economic and environmental impact analyses for the NOPR. These analyses generally include:

1. customer subgroup analysis (section 13 );
2. complete MIA (section 14 );
3. utility impact analysis (section 15 );
4. employment impact analysis (section 16 );
5. emissions analysis (section 17 );

6. monetization of emissions (section 18 ); and

7. regulatory impact analysis (RIA) (section 19 ).

DOE describes the methodology used and makes the results of all the analyses available on its website for review. This analytical process results in the selection of proposed standard levels, if any, th at DOE presents in the NOPR. DOE selects the proposed standard levels from the trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking 2 . The NOPR is published in the Federal Register and describes 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. For each equipment class, DOE identifies the max

- tech efficiency level. If DOE proposes a lower level, DOE explains the reasons for eliminating higher levels, beginning with the highest level considered. DOE presents the analytical results in the NOPR and provides the details of the analysis in an accompanying TSD.

DOE con siders many factors in selecting proposed standards. These factors are prescribed by EPCA and take into consideration the benefits and costs of energy conservation
standards.

When DOE publishes the NOPR, it provides the U.S. Department of Justice (DOJ) w ith copies of the NOPR and TSD to solicit feedback on the impact of any proposed standard levels on competition in the market of the equipment that is the subject of the rulemaking. DOJ reviews standard levels to assess the impacts from any lessening of co mpetition likely to result from the imposition of such standards. (42 U.S.C. § 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the NOPR is followed by a public comment period that includes a public meeting.

1.2.3 Final Rule

After publication of any NOPR, DOE con siders public comments received on the proposal and accompanying analyses. DOE reviews the engineering and economic impact

2 TSLs are assembled from the candidate standard levels (CSLs) analyzed for the individual equipment classes based on a set of criteria from the analysis results.6

analyses and any proposed standards based on these comments and considers modifications where necessary. DOE also considers DOJ’s com ments on the NOPR relating to the impacts of any proposed standard levels on competition to determine whether changes to these standard levels are needed. DOE publishes the DOJ comments and DOE’s response as part of any final
rule.

In any final rule, DOE sets final standard levels and the compliance date and would also explain the basis for the selection of such standard levels. The final rule would be accompanied by a final TSD.

1.2.4 Labeling

Title III of the Energy Policy and Conservation Act of 1975 (EPCA), as amended (42 U.S.C. 6291 et seq.), includes provisions for labeling (42 U.S.C. 6315). If DOE prescribes a test procedure for fans, DOE must determine that the following criteria are met before prescribing a labeling rule: (1) labeling in accordance with this section is technologically and economically feasible with respect to such class; (2) significant energy savings will likely result from such labeling; and (3) labeling in accordance with this section is likely to assist consumers in making purchasing decisions (42 U.S.C. 6315(h)).

Section 6315 of EPCA specifies certain aspects of equipment labeling that DOE must consider in any rulemaking establishing labeling requirements for covered equipment. At a minimum, such labels must include the energy effic iency of the equipment to which the rulemaking applies, as tested under the prescribed DOE test procedure. In addition, the labeling rulemaking may consider the addition of other specifications for equipment labels, including: directions for the display of the label; a requirement to display on the label additional information related to energy efficiency or energy consumption, which may include instructions for maintenance and repair of the covered equipment, as necessary to provide adequate
information to purchasers; and requirements that printed matter displayed or distributed with the equipment at the point of sale also include the information required by the labeling rule to be displayed on the label. 42 U.S.C. 6315(b) and 42 U.S.C. 6315(c). For more in formation, see DOE’s Request for Information on labeling for commercial and industrial equipment. 77 FR
75400 (December 20 , 2012).

DOE could consider the appropriateness of prescribing a labeling rule for commercial and industrial fans in conjunction with the analyses for standards described in the remainder of
this document.

Item 1

- 1 DOE seeks comment on whether a labeling rule would be technologically or economically feasible, result in a significant conservation of energy, or assist consumers in making purchasin g decisions.

Item 1

- 2 DOE seeks comment on information that it should consider requiring for display on any prospective label, as well as factors DOE should consider regarding the size, format, and placement of any such label.7

2. OVERVIEW OF THE RULEMAKING SCOPE

2.1 Current Coverage

Currently, there are no energy conservation standards for fans. DOE has published a proposed coverage determination for this equipment. 76 FR 37678 (June 28, 2011). DOE has developed this framework document in further consideration of t hat determination and any associated energy conservation standards for this equipment.

2.1.1 Equipment Definitions

Taking into consideration comments from interested parties during the Notice of Proposed Determination of Coverage comment period, DOE is consideri ng the following definition of fans to provide clarity for interested parties as it continues its analyses:

Commercial/Industrial Fan : A device used in commercial or industrial systems to provide a continuous flow of a gas, typically air, by an impeller f it to a shaft and bearing(s). A fan may be manufactured with or without a housing component.

Item 2

- 1 DOE requests data on how fans are sold. Specifically DOE requests data on market share of fans 1) sold by themselves, 2) sold attached to or integrated with

motor s only, 3) sold attached to or integrated with both motors and VSDs, 4) sold physically separate from but priced together with a motor only, or 5) sold physically separate from but priced together with both a motor and VSD. DOE would appreciate
these data by size, equipment category (see section 5.2.1 ), and application.

Fan Manufacturer : Entity responsible for assembling a fan into the first testable configuration such that the fan impeller is fit to a shaft, bearings, and , for housed fans, fit within a housing
component.

Impeller : The part of the fan that imparts energy into the gas flow, also known as the fan wheel for centrifugal fans.

Bare Shaft Fan : A term used to describe fans without drives, attachments, or accessories.

Drive: A device used to power the fan, including the motor, mechanical transmission, and motor/control system.

Driven Fan: A term used to describe a fan fitted to or connected to a motor, mechanical transmission, and a motor/control system.

Direct

- Driven Fan : A driven fan sold with a motor where the fan impeller is coupled directly to
the shaft of an electric motor.

Belt

- Driven Fan : A driven fan sold with a motor where the fan impeller is coupled to the electric motor through a set of belts and pulleys mounted on the motor shaft and fan shaft.8

Gear

- Driven Fan : A driven fan sold with a motor where the fan impeller is coupled to the electric motor through a gearbox.

Axial Fan : A fan in which airflow enters and exits the impeller parallel to the shaft axis. The axial fan may or may not be equipped with a cylind rical housing, inlet or outlet guide vanes, an orifice panel, or orifice ring.

Centrifugal Fan : A fan in which airflow enters the impeller parallel to the shaft axis but changes direction due to the impeller blades and exits perpendicular to the shaft in a radial direction at the impeller discharge. The impeller may have one or two inlets and may or may not have a housing
component.

Cross Flow Fan : A type of centrifugal fan in which the fluid path though the impeller is in a
direction that is substantiall y at right angles to its axis with air both entering and leaving radially at its periphery.

Item 2

- 2 DOE requests comment on the suggested definition for cross flow fan, specifically regarding whether this fan is a type of centrifugal fan.

Mixed Flow Fan : A fan in which the direction of airflow through the impeller takes on characteristics that are intermediate between centrifugal and axial fans in that the air exits the fan in a direction which is neither parallel nor perpendicular to the shaft.

Variable Speed Dr ive (VSD): A device that controls the speed of equipment.

Specific Ratio : Total pressure at the fan outlet divided by the total pressure at the fan inlet, measured at peak fan total efficiency [ 1 ]

.

Fan Total Pressure: The difference between the total pressure at the fan outlet and the total pressure at the fan inlet. Total pressure at a specific location is the sum of velocity pressure and static pressure a t that location.

Fan Velocity Pressure: The velocity pressure corresponding to the average velocity at the fan
outlet.

Fan Static Pressure: The difference between the fan total pressure and the fan velocity pressure;
the difference between static pressure at the fan outlet and total pressure at the fan inlet.

Fan Total Efficiency: The ratio of fan air power output to fan shaft power input.

Fan Static Efficiency: The fan total efficiency multiplied by the ratio of fan static pressure to fan
total pressure.9

Peak Fan Efficiency: The highest point on the efficiency curve; also referred to as the best efficiency point (BEP). Peak fan total efficiency is the highest point on the fan total efficiency curve, peak fan static efficiency is the highest point on the fan static efficiency curve.

Blower : An axial or centrifugal fan with a specific ratio between 1.11 and 1.20.

The terms "fan" and "blower" are used interchangeably by the industry. Some manufacturers refer to a centrifugal fan as a blower w hen designed for high pressure, low air volume applications [ 2 ]

. The American Society of Mechanical Engineers (ASME) uses a similar concept, specific ratio, to separate fans (specific ratio up to 1.11), blowers (specific ratio 1.11

- 1.20), and compressors (specific ratio above 1.20) [ 3 ]

. The European Union (EU) uses specific ratio in considering what operating range to exclude from the ecodesign requirements for non

- domestic
fans [ 1 ]

. I n response to the Coverage Determination document published by DOE on June 28, 2011, however, t he Air Movement and Control Association International (AMCA) commented
that proposing definitions of fans and blowers based on the ASME specific ratio approach is not consistent with the established fan industry definitions, and that it would be confusing to create a
second set of fan definitions. AMCA recommend ed that DOE adopt the ANSI/AMCA/ASHRAE standards. (AMCA, No.7 at p. 3) ANSI/AMCA 99 defines Blower as "a fan that operates against air system resistance downstream of the fan; a Forced Draft Fan". ANSI/AMCA 99 further defines Forced Draft Fan as "a high pressure/high volume fan used to supply primary and secondary combustion air to a furnace/boiler and its exhaust system." T he ANSI/AMCA 99 definition
appears to emphasize only one of the possible blower applications: the use of blowers in combustion processes.

Item 2

- 3 DOE requests co mment on the suggested definition for blowers.

Safety Fan: An axial or centrifugal fan designed for use in applications requiring extra safety measures, such as:

a) those designed to operate in potentially explosive atmospheres;

b) those designed for emergency use only, at short

- time duty, with regard to fire safety requirements;

c) those designed specifically to operate where the temperature of gases being moved exceed 500oF; and

d) those designed in toxic, highly corrosive, or flammable environments with
abrasive su bstances.

These safety fan applications were adopted from the European Union’s non

- domestic fan commission legislation [ 1 ]

.

Item 2

- 4 DOE requests comment on the suggested defi nitions for safety fans. Specifically, are other safety features not included in the above definition that should
be included.10

Item 2

- 5 DOE requests comment on the suggested definitions for fans and other terms
listed in section 2.1.1

.

2.2 Preliminary Discussion of Fans For Which DOE is Considering Standards

In response to the Coverage Determination document published by DOE on June 28, 2011, the Appliance Standards Awareness Project (ASAP), American Council for an Energy Efficient Economy (ACEEE), National Consumer Law Center (NCLC), and Natural Resources
Def ense Council (NRDC) submitted a joint comment (hereinafter referred to as the Joint
Commenters ) that the scope of coverage should not be finalized before initiating the rulemaking ( Joint Commenters , No. 04 at p. 1), and t he Pacific Gas and Electric Company (PG&E), Southern California Gas Company (SCGC), San Diego Gas and Electric (SDG&E), and Southern California Edison (SCE) submitted a joint comment (hereinafter referred to as CA IOUs) suggest that DOE follow either a market

- based or performance

- specificat ion based approach (CA IOUs, No. 06 at p. 4). DOE understood the performance

- specification based approach as assessing fan coverage based on fan performance characteristics rather than actual fan application. DOE plans to use this approach when determinin g the scope of th e standards rulemaking based on the information available in the manufacturers’ literature in which fans are catalogued according to their performance characteristics.

2.2.1 Fan Types

In the European Union, where most of the fans are sold with a motor, the commercial fans regulation [ 1 ] sets minimum efficiency requirements for fans sold as an integrated fan

- motor

transmission product only. This allows effic iency gains to be realized by improving the motor instead of only the fan itself. In the United States, the majority of fans are sold bare shaft

. [ 4 ] . Additionally,
DOE determined that the number of direct

- driven fan units shipped in the United States greatly
outnumbers belt

- driven fan units in the axial fan market [ 5 ] ; a trend DOE expects to be reflected in the
markets for most if not all of the other commerc ial and industrial fan types.

Item 2

- 6 DOE requests comment and information on the following trends: 1) increasing shipments of fan

- motor

- transmission packages and 2) increasing shipments of direct

driven fans in the U.S. market. Are there any other trends in the commercial and industrial fan s market that might influence the scope of this rulemaking that DOE should be aware of and are not listed here?

Item 2

- 7 DOE requests comment on the consideration of standards for axial fans

, centrifugal fans , mixed flow fans , safety fa ns , and blowers as defined in section 2.1.1

.

Item 2

- 8 DOE is aware of another type of fan, the contra

- rotating fan, popular in the European Union, and reque sts information on this fan type; specifically, are they sold
in the U.S. market and should be considered in the scope of coverage for the rulemaking?11

2.2.1.1 Fan System

There may be greater potential for energy savings if the energy conservation standards addressed all components of the fan system. Fan systems are subject to a variety of inefficiencies, and those inherent in the fan itself are often among the smallest. As a result, addressing other system
inefficiencies 3 in any DOE regulations could signifi cantly increase energy savings. DOE may consider defining "fan" as:

"a device used in commercial or industrial systems to provide a continuous flow of a gas, typically air, by an impeller for ventilation, circulation, or industrial process needs. A fan ma y be manufactured with a housing component, motor, drive, and/or a VSD".

The main goal of this approach is to capture the benefits of variable speed drives (VSDs). VSDs are control devices that can be used to improve equipment performance under variable l oads. The savings potential is highly dependent on (a) how much time the system requires operation at part

load; and (b) the means, if any, used to adjust fan system operation during these times. If DOE’s regulations were to require variable load fan syste ms to be installed with VSDs and appropriate control algorithms to take advantage of the device, the energy savings potential of the regulations could be significantly increased. It is important to note, however, that VSDs used under constant load operatio n conditions may degrade efficiency, because the electric losses in the VSD during full

- load operation may outweigh any savings achieved during part

- load operation for such systems.

DOE is considering the following 3 options for regulation depending on ho w fans are
defined and sold :

1. Defining and establishing standards for the fan exclusive of the motor and/or controls.

2. Defining and establishing standards for the fan inclusive of the motor and controls, if the fan is
sold with them. Most electric motors are already regulated by DOE, and preliminary data gathered by DOE show that the majority of fans (approximately 90%, see discussion in
section 2.2.2 ) are driven by motors covered by motor standards in EPCA . As a result, each fan equipment class (as discussed in section 5.2.1 for bare shaft fans) would be sub

divided into two categories: (1) without VSD (bare shaft fan sold with or without motor) and (2) with VSD (fan would only fall under this category if it is sold with motor).

3. De fining and establishing standards for fans inclusive of motors (if the fan is sold with a motor) and considering a VSD as a design option to improve efficiency for those fans sold with the motor. To accommodate this option, each fan equipment class (as pro posed in section
5.2.1 for bare shaft fans) would be sub

- divided into two categories: (1) without motor ( or VSD ) and (2) with motor (with or without VSD)

.

Based on DOE’s preliminary research, option 1 would be the simplest approach

. Option 2 has potential to capture additional energy savings because it directly addresses the use of more efficient VSD and motor pairs than might be sold in the absence of a standard. O ption 3 may increase the

3 These other inefficiencies include mismatch of fan to system requirements, use of dampers to control flow, running at constant load all the time when load is or could be variable, inefficient motors, and inefficient motor
drives.12

potential to capture savings associated with system inefficiencies as a n efficiency metric could be developed to demonstrate energy savings associated with reducing airflow using a VSD to adjust operation when full

- load is not required, rather than by less efficient means, such as using dampers to
reduce airflow. Because DOE regulates the manufacturer, options 2 and 3 would capture any additional energy savings only where the fan manufacturer also supplies the motor and VSD.

Given that fan manufacturers cannot control if or how a VSD is used in the field, a standard that requires or encourages the use of VSD could result in the presence of VSDs in applications for which t hey are not suited, such as constant loads with correctly sized fans. To determine whether selling more fans with VSDs (the possible result of option 3) or selling more efficient VSD/motor pairs (option 2) would actually save energy in the field, DOE would conduct analyses of fan and VSD usage across the spectrum of fan applications and baseline conditions (including using dampers and constant speed operation).

Item 2

- 9 DOE requests comment on whether establishing standard s for fans defined inclusive of the motor tr

ansmission, and controls could increase the beneficial use of VSDs in the field and whether interested parties believe the benefits of such a standard would outweigh any negatives, such as the potential use of VSDs in applications for
which it is not suite d. DOE seeks comment on the market share of fans (by type) that would be used in applications that would benefit from VSDs, as well as those where use of a VSD could result in increased energy use. In particular, whether there are specific fan types that ar e almost always used, or alternatively, very rarely used, in applications that would benefit from a VSD.

Item 2

- 10 DOE requests data and information on whether fans are more often combined with motors, VSDs, or both by the fan manufacturer or by distributors/contrac tors.

Item 2

- 11 DOE requests information on how often and in what circumstances the intended application is known when the fan is sold.

Fan Size (Impeller Diameter) Limit

Geometrically similar fans that differ by size (impeller diameter) are manufactured in
‘series ’. A review of fan manufacturer catalogues suggests that series produced fans have a maximum impeller diameter of 98 inches for all fans. It is expected that fans larger than 98 inches are typically custom

- built and DOE believes that these fans are already built to the highest efficiency possible because of the users’ demand to reduce the large amount of energy consumed by them.

Item 2

- 12 DOE requests comment on whether standards should be considered only for fans with an impeller diameter less than 98 or equal to in ches and whether that impeller diameter distinction is appropriate for all fans equipment classes being considered in this rulemaking

.13

Item 2

- 13 DOE requests comment on whether to similarly consider a minimum fan diameter in this rulemaking.

Fan Power Limit

In the European Union’s (EU) fan efficiency standard, coverage of fans is limited to those requiring 125 W to 500 kW power. A preparatory EU study showed that the majority of commercial and industrial fans are driven by motors in this power range [ 6 ]

. DOE is considering energy conservation standards for fans that require 125W to 500kW of power.

Item 2

- 14 DOE requests comment on considering standards for fans with power requirements between 125 W and 500 kW for this rulemaking.

Applicability of European Union Scope Fan Exclusions to U.S. Fan Standard

The EU excludes from its regulatory requirements fans used in applications that operate in a defined set of conditions, such as:

a) those with an optimum energy efficiency at 8,000 rotations per minute or more;

b) those in applications in which the ‘specific ratio’ is over 1.11 (this limitation excludes blowers from coverage as the blower is defined in this document); and

c) those used as conveying fans for the transport of non

- gaseous s ubstances in industrial process applications (this limitation excludes material handling fans as
described in section 5.2 )

.

Item 2

- 15 DOE requests commen t on these exclusions, specifically regarding whether they should be applied to this rulemaking. Why or why not? Are there any other fan characteristics that DOE should consider as criteria for exclusion?

2.2.2 Motor Considerations

In this rulemaking, DOE will consider the efficiency requirements already imposed by the small and medium electric motors rulemakings. DOE has found that commercial and industrial fans are primarily powered by the following types of electric motors:

Single

- phase AC motors: These motor types are used almost exclusively in commercial fan applications that require less than one horsepower [ 7 ] . Only the capacitor

- start motors are currently covered by the small motors regulation 4

.

Polyphase AC motors : Polyphase (three

- phase) AC motors are the most commonly used motors in fan applications requiring more than 1 HP [3]. These motors are usually NEMA Design B, and almost all of these types are already covered by the motors regulations.

4 75 FR 1703614 DC Motors : DC moto rs are not covered by the current motors regulations; however, they
are used in only a small fraction of fan applications.

To assess the use of these three motor types with fans, DOE reviewed a data set of motor nameplate and field measurements collected b y the Washington State University Extension Energy Program (WSU) 5 . This data set compiles data from 123 industrial plants and reports information for 3,900 motors (> 1HP) used to drive industrial fans. The survey showed that over 90% of fans are driven by motors currently subject to DOE energy conservation standards . The remaining 10 % are single

- phase motors, including: DC motors (~1%), specialized motors (multi

- speed) (~0.1%), totally

enclosed air

- over motors (~0.3%), medium voltage induction motors (2300 /4160V) (~1.8%), and synchronous motors (~6%).

Item 2

- 16 DOE requests comment on the percentage of fan motors estimated to be covered by the small and medium electric motor standards. Specifically, does the industrial plant motor study performed by WSU represent the commercial and industrial fan industry as a whole? Why or why not?

DOE notes that not all fans are driven by electric motors; some fans may be driven by natural gas or diesel engines or steam turbines. These fans may represent small percent of the fans pr oposed for coverage. Because some fans can be used with both motors and engines, DOE i s consider ing in this framework document covering fans without regard to how they are driven. Any fan sold with an engine or for use with an engine (as opposed to an elec tric motor) would likely be considered bare
shaft fans under regulatory options 2 and 3 as described in section 2.2.1.1

.

Item 2

- 17 DOE seeks comment on the market share (by fan type) and applications of fans that are driven by equipment other than electric motors.

2.2.3 Transmission Type Considerations

For fans, there are two principal types of drive systems: direct

- drive and belt

- drive. Gear
drives are also used but are less common . Direct

- drive and belt

- drive transmissions are defined and
described in section 2.1.1

. DOE is aware that gear

- drive systems are used when there is a need for very high or very low speeds that would otherwise result in excessive belt slip and belt losses, if a simple belt

- drive system were used.

In this rulemaking, DOE plans to consider fans with direct

- drive, belt

- drive, and gea r

- drive
transmission.

Item 2

- 18 DOE requests comment on the transmission types to be considered in this rulemaking.

5 WSU develo ped this database in conjunction with Applied Proactive Technologies (APT) under contract with the New York State Energy Research and Development Authority (NYSERDA). 2011.15

2.2.4 Variable

- Speed Drive Considerations

Variable

- speed drives (VSDs) are devices that control the rotational speed of a motor by varying the voltage to the motor. In variable

- load applications, varying the speed of the motor may save energy compared with other techniques for flow control, such as the use of dampers.

Under regulatory options 2 and 3 as described in section 2.2.1.1 , DOE would determine what types of VSDs are used in commercial and industrial fan applications and the efficiency range for those VSD devices.

Item 2

- 19 DOE requests comment on the types of VSDs sold with fans and whether there is efficiency variability (and if so, to what extent) among VSDs.

2.2.5 Consideration of Standards for Fans in Fume Hood s

DOE received comments regarding the coverage of fume hoods in response to the Coverage Determination document published on June 28, 2011. The Air

- Conditioning, Heating & Refrigeration Institute (AHRI) stated that after review of the proposed determination of coverage they believe that DOE should not include commercial and industrial fans, blowers, and fume hoods as covered equipment because subjecting them to regulation will not result in any energy savings (AHRI, No. 03 at p. 1). AHRI also stated that they believe that the DOE analysis is based on outdated data that does not reflect current design practices for commercial and industrial fans, blowers, and fume hoods. AHRI commented that all commercial building energy codes and commercial equipment energy co nservation standards currently used in the U.S. regulate the energy consumption of commercial and industrial fans, blowers, and fume hoods (AHRI, No. 03 at p. 3). The Joint Commenters stated that fans, blowers, and fume hoods represent a significant potent ial for energy savings and that they encourage DOE to initiate test procedure and standards rulemakings for this equipment ( Joint Commenters , No. 04 at p. 1). The CA IOUs stated that they support the Department’s efforts to examine the potential benefits o f energy efficiency standards for commercial and industrial fans, blowers, and fume hoods (CA IOUs, No. 06 at p. 1). The CA IOUs stated that for fume hoods there is a wide range of efficient designs, which suggests a significant savings opportunity (CA IOU s, No. 06 at p. 2). The CA IOUs also stated that there is economic growth in the chemical, biotech and pharmaceutical industries which may be an indicator of market growth for fume hoods (CA IOUs, No. 06 at p. 3).

DOE has determined that it lacks authori ty to establish energy conservation standards for fume hoods because fume hoods are not listed as a type of industrial equipment for which DOE
could establish standards. DOE acknowledges , however, that the fan that provides ventilation
for the fume hood c onsumes the largest portion of energy within the fume hood system. As
discussed in section 2.2.1 , DOE plans to cover all commercial and industrial f an types , which
includes fans used to ventilate fume hoods.16

3. TEST PROCEDURES

DOE is considering development of a test procedure to determine the energy efficiency
of commercial and industrial fans . DOE intends for the test procedure to include an efficiency descriptor and the methods necessary to adequately measure the performance of the covered equipment for the purposes of determining compliance with energy conservation standards (this is referred to as the efficiency metric)

.

When establishing or amendin g test procedures, DOE reviews existing industry test procedures or testing methods to measure the energy use or energy efficiency of the covered equipment , such as ANSI/AMCA Standard 210

- 07

– ANSI/ASHRAE Standard 51 6

, a U.S.
commercial and industrial fan s test procedure (AMCA 210) [ 8 ]

. DOE discusses its preliminary review of test procedure approaches in section 3.1 , along with the issues for public comment.

3.1 Preliminary Discussion of Test Procedure Approaches for the Energy Performance
of Fans

In the test procedure rulemaking, DOE will consider methods for measuring the energy efficiency, energy use, or average annual operating cost of fans during a representative average

use cycle or period of use that is not unduly burdensome to conduct. (42 U.S.C. 6314(a)(2)) In prescribing new test procedures, DOE ta kes into account relevant information including technological developments relating to energy use or energy efficiency of fans. The test procedure will address the efficiency metrics discussed in section 3.2

.

The AMCA 210 test procedure defines uniform methods for conducting laboratory tests on fans to determine airflow rate, pressure, and power at a given speed of rotation. The test procedure appli es to a fan or other air

- moving device when air is used as the test gas with the following exceptions: air

- circulating fans (ceiling fans, desk fans), positive pressure ventilators, and compressors with inter

- stage cooling, positive displacement machines. Additional commercial and industrial fan test procedures include: GB/T 1236 Industrial fans

- Performance testing using standardized airways (China) and ISO 5801 Industrial fans

— Performance testing using standardized airways (European Union). DOE may con sider AMCA 210 as a basis for a potential DOE test procedure.

Item 3

- 1 DOE requests comment on the use of the AMCA 210

- 07 test procedure as a base for the development of a DOE test procedure.

Because the main application of a cross flow fan is air curtain applicati ons , DOE expects
that these fans could be tested for performance under AMCA 210 using the AMCA Standard 220 Laboratory Methods of Testing Air Curtain Units for Aerodynamic Performance Rating test set

ups

. R esearch into cross flow fan and air curtain performance , however, has resulted in very little publicly available data. DOE notes that in AMCA 220 motor power must be recorded and used in the calculation for air curtain unit efficiency

.

6 ANSI/AMCA Standard 210

- 07

– ANSI/ASHRAE Standard 51 Laboratory Methods of Testing Fans for Aerodynamic Performance Rating for fans.17

Item 3

- 2 DOE requests comment on for what other applications cross flow f ans are used and the breakdown of cross flow fan use across the fans market in those applications.

Item 3

- 3 DOE requests comment on the applicability of AMCA Standard 210

- 07 in
coordination with AMCA Standard 220

- 05 for measuring performance of cross flow fans.

Item 3

- 4 DOE requests comment on whether air curtains must be tested for performance in use with a motor, or whether fan performance as recorded through AMCA 210 test methods would provide accurate performance estimates.

Item 3

- 5 DOE requests performance data for cross flow fa ns.

DOE is also aware that performance (and thus efficiency) of industrial process fans is affected by the level of particulates found in the air stream and would like input as to whether testing these fans in clean air would allow for comparison of perfo rmance between fans within each equipment class. Initial research has shown that material handling fans are currently tested by AMCA 210 under clean air conditions. DOE is aware that, even if it is determined that the equipment classes allow for comparison of performance, material handling fans have characteristics (such as shorter lifetimes due to the wear on the impeller from the materials) that may impact DOE’s consideration of economic justification for efficiency standards.

Item 3

- 6 DOE requests comment on the ability of using a clean air only test procedure
to determine the efficiency of fans designed for dust air or material handling applications that could be compared to fans not designed for handling such materials
that are in the same equipment classes (see section 5.2 for equipment class discussion).

The AMCA 210 test procedure allows fans to be tested for air performance under a number of test config urations. The performance results may vary for a single fan tested at different installation categories due to the different fluid dynamic characteristics of each installation. The category distinguishes arrangement of ducting to the inlet and outlet of th e fan. Free inlet or outlet signifies that the air enters or leaves the fan directly from or into the unobstructed free atmosphere. Ducted inlet or outlet signifies that the air enters or leaves the fan through a duct directly connected to that fan inlet o r outlet, respectively. The test configurations can be categorized into one of four test installation categories; Category A, B, C, or D (see Table
1 ).18

Table 1 . Installation Category/ Test Configurations Descriptions

Installation Category/ Test Configurations Location of Ducting for Testing

A Free inlet, free outlet

B Free inlet, ducted outlet

C Ducted inlet, free outlet

D Ducted inlet, ducted outlet

ISO 5801 states that because “ the connection of a duct to a fan outlet and/or inlet modifies its performance, it has been agreed that four standard installation categories should be recognized. A fan adaptable to more than on e installation category will have more than one standardized performance characteristic. Users should select the installation category closest to their application." AMCA's Certified Ratings Program requires the manufacturer explicitly state
the installati on category for fans with a certified air performance label ; however if a fan is tested under more than one installation category

, AMCA allows the performance of the installation category that provides the highest efficiency be submitted for the FEG label.

DOE is considering a single test configuration per equipment class so that fan performance within each class can be compared . DOE notes that ISO 5801 test procedure is very
similar to AMCA 210 , except that in ISO 5801

, axial fans tested under installatio n category B or D (ducting on the outlet) where the outlet swirl is more than 15° are required to use a straightener to produce reproducible performance data. Within the development of a DOE fan test procedure
DOE w ould determine if fans with outlet swirl greater than 15° will require a straightener during testing to produce consistent performance data.

Item 3

- 7 DOE requests comment on which test configuration should be considered for each of the considered equipment classes.

Item 3

- 8 DOE requests comment on requiring an air straightener at the outlet for axial fans tested in configuration B or D.

3.2 Discussion of Efficiency Metric Approaches for the Energy Performance of Fans

To establish a fan efficiency metric for this rulemaking, DOE reviewed metrics and implementation meth ods used in local and international regulatory or voluntary programs.

3.2.1 Data Sources for Efficiency Metric Development

For the development of the efficiency metric, DOE intends to gather performance data using publicly available information from man ufacturer websites and catalog s. DOE's understanding is that fan performance available in catalogs are typically presented in data tables
which include pressure, airflow, rotational speed, and power values ; however

, the availability of
data is not consistent acros s manufacturers or fan types. T o calculate peak total efficiency in a consistent manner, DOE requests the following types of performance data:19 Operating conditions under total pressure, or other data that allow for the calculation of total pressure

.
Fan po wer (i.e., a fan's break horsepower (BHP) ) at all operating condition s , instead of a maximum BHP value.

T est data as measured instead of performance data that has been generated using
the fan laws.

Fan performance that does not include losses due to the mo tor, transmission, and/or accessories (i.e., filters)

.

Item 3

- 9 DOE requests comment on the use of publicly available performance data in lieu of original test data.

Item 3

- 10 DOE requests fan performance data generated from AMCA 210 tests.

3.2.2 Efficiency Metric Approaches

- B are Shaft Fans

1. In the U.S., AMCA has developed an efficiency metric that utilizes Fan Efficiency Grades (FEG)

, as described in AMCA Standard 205

- 10 (Rev. 2012) Energy Efficiency Classification for Fans

. The FEG is a numerical rating that reflects fan efficiency. It is established by expressing peak total efficiency as a function of a fan's impeller diameter. For fans without the shaft and bearings, the peak total efficiency
used for FEG is the impeller efficienc y . The fan efficiency grades are defined as the area between two adjacent efficiency limits shaped to follow the increasing efficiency of a single fan design as it increases in diameter [ 8 ]

. FEG represents a range of efficiency values and not a si ngle efficiency point. Efficiency limits were not
established separately for each fan category (e.g., centrifugal fans with airfoil blades, vaneaxial fans, plenum fans, etc.) but include all fan types

. [ 9 ] For fan sizes that are greater than or equal to 40 inches the FEG rating will be the same as for 40 inch
diameter fans.

On July 13, 2012, ASHRAE published a proposal (Addendum u) to append ASHRAE
90.1 Energy Standard for Buildings Except Low

- Rise Residential Buildings to include minimum FEG limits on fans. The addendum proposes that fans have a FEG of 67 or higher based on manufacturers’ certified data, as defined by AMCA 205 7 . The total efficiency of the fan at the de sign point of operation must be within 15 percentage points of the maximum total efficiency of the fan [ 11 ]

.

2. The Chinese standard GB 19761

- 2009 Minimum Allowable Values of Energy Efficiency and Energy Efficiency Grades for Fan describes the minimum efficiency

7 Although there are fan power limits in the existing ASHRAE 90.1, the limits only restrict the design of fan systems and the amount of fan energy used by the system, which does not reflect the efficiency o f the fan 10.
AS HRAE, Standard 90.1 Energy Standards for Buildings Except Low

- Rise Residential Buildings , 2010: Atlanta, GA. p. 36.

.20 requirements for axial and centrifugal fans for general use, and centrifugal fans for
air

- conditioning applications. While t he metric defines fan total efficiency requirements as a funct ion of impeller diameter, each fan type within the scope of coverage presents different efficiency requirements based on: 1) pressure coefficient, specific speed, and blade profile for centrifugal fans and 2) hub

- tip ratio 8 for axials.

For the preliminary analysis, DOE plans to evaluate different efficiency metric approaches for describing fans efficiency performance:

1. E valuating fan efficiency as a function of size similar to the method described in AMCA 205 using available data (from catalogs or other sources). To better represent differences in performance across fan types, DOE w ould derive FEG limits separately for each fan equipment class (see section 5.2 for equipment class discussion).

2. In addition to fan size, exploring other parameters that show a correlation to efficiency. DOE may consider expanding the FEG approach to incorporate operational conditions of a fan. The approach to expand FEG would include evaluating combinations 9 of size and operational parameters such as flow, pressure, flow coefficient, pressure coefficient, and specific speed 10 as well as any other suitable parameters

. Different combinations of parameters may be considered for each equipm ent class (i.e., hub

- tip ratio parameter for axial fans).

For each equipment class

, the available data would be plotted in a three

- dimensional space that includes efficiency and the other two considered parameters. A 3

- D plane
would be generated from the data to represent the fan average efficienc y over the range of operating conditions.

Item 3

- 11 DOE requests comment on the considered efficiency metric approaches.

3.2.3 Efficiency Metric Approaches

- Fans defined as inclusive of motor/controls

Under regulatory options 2 and 3 as defined in section 2.2.1 .1 , DOE is considering development of a n alternative efficiency metric. DOE has reviewed several existing efficiency metrics for fans, none of which take into consideration fan operation under variable loads.

In the EU clean water pumps regulation

, a variable load efficiency metric has been proposed which sets minimum efficiency requirements at three different points along the pump pressure/flow curve when operating at the pump’s rated speed: full

- load ( i.e., at Best Efficiency Point (BEP)), part

- load ( i.e., at 75 percent of flow at BEP), and over

- load ( i.e ., at 110 percent of flow at BEP). The EU standard would set a required efficiency for BEP, and the minimum pump efficiency at part

- load, a nd over

- load would be set at the required BEP efficiency multiplied by an appropriate factor. A failure at one or more points would mean the pump did not meet the standard. DOE is considering a similar approach for fans that would incorporate variable loa d

8 Hub

- tip ratio is the hub radius divided by the length from the center of the fan hub to the tip of the blade.

9 Combinations are limit ed to including only two parameters.

10 Flow coefficient, pressure coefficient, and specific speed are all based from the fan law relationships [7].21

profiles appropriate for fans and could have the potential to increase fan efficiency over a wider range of operating conditions.

Item 3

- 12 DOE requests data and/or sources of information for developing the representative load profiles for each fan equipment class (see section 5.2.1 for equipment class discussion).

Item 3

- 13 DOE specifically requests comment on the part

- load airflow test points that would represent a typical variable load for a fan as well as how many part

- load test points it should consid er

.

Item 3

- 14 DOE is interested in what test points, in addition to conditions at peak total efficiency, are appropriate for a variable load metric and how many test points sho uld be included to address the complete operating range of fans with or without VSDs.

3.2.4 Efficiency Metric Implications for Defining Fans Inclusive of Motor/Controls

3.2.4.1 Efficiency Calculation Approaches

Equipment efficiency under regulatory options 2 and 3 as described in section 2.2.1.1 may need to be based on motor input power because VSDs create two main energy

- related benefits compared to using dampers to change operating conditions. First, VSDs have the ability
to reduce power when operating at flows away from the peak efficiency operation point 11 . This phenomenon is described as the "cube law"; for example, fans running at a reduced speed of 25% require approximately 42% less power to operate, depending on a variety of pa rameters including the system in which the fan operates. Second, when reducing flow by shifting the fan performance curve using speed control, fan efficiency is maintained relative to the peak efficiency point instead of being subject to an efficiency decr ease due to higher pressure losses which occurs when reducing airflow by fan system dampers (which shift the system curve).

Because use of a VSD introduces losses to the fan system

, fans fit with a VSD will have lower efficiency at all duties than a fan without a VSD. Furthermore, while motor efficiency does not degrade significantly with speed reductions of 1

- 50%, the efficiency of a VSD may degrade significantly. DOE may need to determine if the benefit of a VSD at reduced airflows
that have higher effi ciency losses but reduced power requirements outweighs the higher power draw but potentially lower efficiency losses for a fan system that uses a damper . DOE has identified two methods for determining equipment efficiency if fans are defined to include the
motor and controls :

1. Overall peak efficiency: This approach would measure an overall set efficiency (also known as wire

- to

- air efficiency) similar to the calculation for bare shaft fan

11 This benefit may be realized in variable load systems when flows less than flow at maximum speed are

requ ired . It may also be realized in constant load systems with oversized fans, when a VSD is used to reduce speed and flow to the system requirements ; however it would use more power in constant load systems with correctly
sized fans

.22 peak total efficiency. The AMCA 210

- 07 test procedure provides a method in which overall set efficiency is calculated for the fan, motor, transmission, and controls (i.e., variable speed drives, etc.). A variable

- load metric using overall peak efficiency would capture some benefits of speed control using a VSD
becaus e e fficiency would be higher at part

- load conditions; however, this option would not necessarily capture the VSD

- related power savings described by the
"cube law".
2. Input power based efficiency: To capture the power savings of a VSD

, efficiency could be calculated as a function of input power to the motor per unit airflow, such as watts per airflow volume per minute (W/CFM).

DOE would consider a variety of metrics to capture the energy efficiency impacts of
VSDs for fans sold with m otors. T hese metrics may need to be based on motor/control input power, such as the input power requirement per unit flow or the ratio of input power at part

- load to input power at full

- load measured or calculated without VSD, rather than efficiency metric s for the fan, fan/motor, or fan/motor/VSD combination only. Such metrics show both the power

saving benefits of VSDs and the losses associated with the presence of a VSD. DOE is interested in suggestions for metrics that would achieve the stated goals for the alternate regulatory approach es described in section 2.2.1.1

.

One metric that could be used for fans defined inclusive of the motor and controls is
currentl y being used in the European Union (EU) for non

- domestic fans. This metric was developed because a large proportion of fans are supplied with integral and built

- in motors

. T his
metric is referred to as Fan

- Motor Efficiency Grades (FMEG). The standard 12 desc ribes minimum efficiency requirements that incorporate efficiency of both the fan and motor . The FMEG, referred to as the 'set' efficiency

, reflects the ability to convert electrical power to air power for a specific fan and drive combination [ 12 ] . The drive system includes not only the

motor

, but also any devices between the motor and the power supply so each fan and motor combination has a unique efficiency value. A fan belongs to a given FMEG grade (e.g. FMEG55) if its best efficiency at full speed is equal to or greater than the value calculated for the nominal efficiency grade level, e .g. FMEG55, and relevant input power. Although FEG is a function only of fan size and peak total efficiency, FMEG is a function of fan type, input power, and peak set efficiency. FMEG includes a com pensation factor, which has the effect of increasing the optimum efficiency of fans with variable speed drives.

Item 3

- 15 DOE requests comment on an appropriate efficiency calculation to capture the energy efficiency impacts of VSDs. Specifically, DOE requests comment on the use of an input power based efficiency versus an overall peak efficiency when comparing efficiencies.

Item 3

- 16 DOE requests comment on the FMEG efficiency metric.

12 Commission regulation (EU) No. 327/2011 of 30 March 2011, implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for fans driven by motors with an electric input power between 0.125 W and 500 kW, including those in tegrated in other energy

- related products23

If DOE defines and regulates fans inclusive of the motor and VSD if sold together (option 2 in section 2.2.1.1 ), DOE would follow the same metric approach discussed for regulation option 1 for equipment classes for fans sold without VSDs. For equipment classes with fans sold with VSDs, DOE would identify a metric that can be used to consider efficiency levels that require the use of more efficient VSDs; such a metric does not need to compare fans
with VSDs to fans w ithout VSDs, because fans without VSDs (with or without motors) would be in a separate set of equipment classes. For equipment including both motors and VSDs if sold together, DOE is considering a metric of overall efficiency (as discussed in section 3.2.4.1

, this approach to calculating efficiency can be thought of as the product of fan efficiency, motor efficiency, and VSD efficiency)

. The fan, motor, and VSD must be tested together because VSDs are not regulated separately (and thus there is no verified source of VSD efficiencies), motors are regulated only at full

- load, and VSDs and motors in combination do not necessarily operate with the efficiency that would be calculated by multiplying their individual tested efficiencies together.

Item 3

- 17 DOE requests comment on the use overall efficiency for fans sold with both
motors and VSDs.

If DOE define s and regulate s fans inclusive of the motor if sold together and include
VSD as a design option (option 3 in section 2.2.1.1 ), DOE would follow the same metric approach discussed for regulation option 1 for equipment classes for fans sold w ithout motors. For equipment classes sold with motors, DOE would identify a metric that can capture the impacts on energy efficiency associated with the use of a VSD in comparison to a fan with a motor but without a VSD. DOE could then consider efficiency levels that require VSDs and high

- efficiency VSDs.

Item 3

- 18 DOE requests comment on the use input power based efficiency for fans sold
with motors where VSDs are a design option to improve efficiency

.

3.2.4.2 Alignment of Efficiency Metrics Under Considered Approach es
If DOE pursues regulatory option 2 or 3 , the equipment classes discussed in section 5.2 may need to be expanded to accommodate the different (and u sually limited) operating
conditions these products can achieve. In addition to the equipment classes determined for bare shaft fans, DOE suggests a parallel set of equipment classes be developed for fans defined inclusive of
the motor and controls

. T he pa rallel sets of equipment classes may have different efficiency metrics

, which would allow DOE to capture energy savings from fan peak total efficiency gains for bareshaft fans while allowing for potentially greater energy savings to be realized from power reductions
associated with use of VSDs.

DOE is considering the following three options to align efficiency metrics between the potential two equipment class sets:

1. Separate metrics: DOE would use different metrics for the two equipment class sets. For example, bare shaft fans would utilize a fan peak total efficiency based metric that considers24

only fan losses while an overall set efficiency metric would be used for fans sold with mot ors and/or VSDs to capture the losses associated with motor and control inefficiencies . Although efficiencies would not be comparable across equipment class sets (i.e. fan efficiency would generally be higher than overall set efficiency because it only inc ludes fan losses), this would
allow an appropriate metric to be used to evaluate energy saving potential for the different equipment.

2. Same metrics: DOE would use the same efficiency metric for all equipment classes. For bare shaft fans, the test procedure would specify the motor and VSD characteristics to be used in the performance test. Because the motor and VSD would be standardized, the test procedure would effectively measure only fan peak total efficiency for bare shaft fans. This option could
enable the test results for all fans to be directly comparable regardless of how they are sold. However, the motor or VSD used in the field may have different efficiency characteristics than those selected for testing.

3. Multiple metrics for equipment sold with a VSD (or with the motor where a VSD is technology option to improve efficiency ). DOE is also analyzing whether t he equipment class set that
addresses VSDs c ould have two metrics. Alternatively, DOE is analyzing whe ther a fan peak total efficiency metric could be used for all equipment class sets but the equipment classes that address VSDs would also be subject to a labeling requirement using an overall set efficiency or motor input power based efficiency metric. Thi s approach would allow comparison across all fans, no matter how the fan is sold, and allow for a comparison between the equipment
class sets

.

DOE notes that the options for metric alignment may impact manufacturer burden. For
fans sold both with and wit hout motors or with and without VSDs, the same fan may be included in two different equipment classes, one for the fan alone and one for the fan with the motor or motor and VSD. Each of these equipment classes would be subject to a different standard. In such cases some metrics may require additional measurements or calculations.

Item 3

- 19 DOE requests comment on the metrics discussed above, including whether a weighted average metric should be developed under the third metric option

.

Item 3

- 20 DOE recognizes that the same f an may in some cases be sold bare shaft or in conjunction with a motor or motor/control package. DOE seeks comment on any issues that may result from having different metrics for fans sold alone and fans sold
with motors or VSDs.

Table 2 shows a summary of each regulatory option and respective metric alignment options for the proposed equipment class sets.25

Table 2 . Regulation Options and Efficiency Metric Alignment Options for Respective Equipment
Class Sets

Regulatory Option Equipment Class Set Metric Alignment Options*

Separate Same Multiple

1 Bare Shaft fans Only one set of

equipment classes will be developed N/A N/A N/A

2 Fans inclusive
of the motor
and VSD Fans Without VSD

(with or without motor) Fan Peak Total Efficiency Overall Efficiency

(standardized motor and VSD) Fan Peak

Total Efficiency

Fans With VSD Overall Efficiency Overall Efficiency Fan Peak
Total Efficiency and
Overall Efficiency

3 Fans inclusive of motor, with VSD a design option for all
fans sold with

motors Bare Shaft Fans Fan Peak Total Efficiency Motor/VSD Input

Power Based (standardized motor) Fan Peak

Total Efficiency

Fans With Motor (with

or without VSD) Motor/VSD Input Power
Based Motor/VSD Input

Power Based Fan Peak

Total Efficiency and
Motor/VSD Input Power
Based Metric *Note that "fan peak total efficiency" here reflects bare shaft fan efficiency measured using total pressure values (see section 2.1.1 for this and other "efficiency" definitions, see section 3.2.1 for description of "fan peak total efficiency" metrics considered.)

4. OVERVIEW OF ANALYSES FOR RULE MAKING

The purpose of the analyses is to support DOE’s determination on whether to establish energy conservation standards for fans. The analyses ensure that if standards are established, DOE selects 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 the factors set forth in EPCA (see section 1.1 of this framework document), which encompass the economic impacts on domestic manufacturers and users and such national benefits as environmental impacts, issues of consumer utility, and impacts from any lessening of competition.26

Figure 1 summarizes the analytical components of the DOE standards

- setting process.
The analyses are presented in the center column. Each analysis has a set of ke y inputs, which are data and information required for the analysis. "Approaches" are the methods that DOE will use to obtain key inputs. The results of each analysis are key outputs, which feed directly into the rulemaking. Arrows indicate the flow of info rmation between 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.27

Figure 1

. Flow Diagram of Anal yses for the Fans and Standards Rulemaking Process28

5. MARKET AND TECHNOLOG Y ASSESSMENT

The market and technology assessment provides information about the commercial and
industrial fan industry and the performance attributes of this equipment. DOE uses this assessment to determine equipment classes and identify potential design options or efficiency levels for each equipment class.

5.1 Market Assessment

DOE’s market assessment identifies and characterizes the manufacturers of fans, estimates market shares and trends, and addresses regulatory and non

- regulatory initiatives intended to improve the energy efficiency or reduce the energy consumption of fans c overed by this rulemaking.

The market assessment phase allows DOE to gather data that can help identify important issues ( e.g. , potential small business impacts, competitive disruptions, and other factors that may arise from enacting standards). For exam ple, market structure data can be used to assess competitive impacts as part of the manufacturer impact analysis.

DOE is consider s manufacturers, industry organizations, and other interested parties as potential sources of such information. In addition, DOE is considering examining national market reports or data collected in national energy use surveys, or extrapolating historical fan sales data from the U.S. Census Bureau. The Census Bureau publishes limited information on the quantity and dollar

- value of equipment shipments. The Census Bureau data does not, however, disaggregate fans according to design or the equipment classes DOE is considering for this rulemaking.

DOE encourages interested parties to submit data on national shipments, manufacturing costs, channels of distribution, and manufacturer market shares of fans that will improve DOE’s understanding of the fan market.

Item 5

- 1 DOE requests information that would contribute to the market assessment for fans that would be covered in this rulemaking, es pecially for those equipment classes designated in section 5.2

. Examples of information sought include current equipment features and efficiencies, equipment feature and efficiency trends, and historical equipment shipments and prices.

AMCA represents many fan manufacturers based in the United States and other
countries [ 13 ] . There are approximately 140 establishments in the commercial and industrial fan industry [ 14 ] . As defined by the Small Business Administration (SBA) 13 , the North American Industry Classification System (NAICS) lists 123 businesses in Industrial and Commercial Fan and Blower Manufacturing (NAICS: 333412) as small [ 15 ]

.

13 The SBA defines small businesses as manufacturing enterprises having 500 employees or fewer

.29

Item 5

- 2 DOE requests comment on the estimates of the number of U.S. fan manufacturers and the number of small businesses in the industry.

5.2 Equipment Classe s

DOE may divide covered equipment into equipment classes by: (a) the type of energy used; (b) the capacity of the equipment; and/or (c) any other performance

- related feature that justifies different standard levels. In determining whether such feature jus tifies a different standard level, DOE considers the utility of the feature to the consumer and other factors DOE considers appropriate. (42 U.S.C. 6295(q)) DOE uses the market assessment to determine the appropriate equipment classes and their respective operating ranges. DOE will conduct its analysis to establish separate standard levels for each equipment class.

In this framework document, DOE is not differentiating equipment classes for fans based on the type of energy used because the majority of fan s are powered by electric motors. For fans driven by engines, DOE is considering an efficiency metric based only on fan efficiency. In addition, DOE does not plan to use fan capacity as a factor in defining equipment classes as the capacity will be account ed for in the efficiency metric as applicable for each equipment class.

DOE is considering establishing equipment classes using the following design
characteristics , which DOE considers to be performance

- related features:

the aerodynamic characteristic of the fan

a fan manufa ctured with or without housing a fan’s ability to operate in certain environments (clean versus dust versus material

- filled
air or under high temperatures, etc. ) a fan sold with or without motor and transmission (if DOE include s the motor and
transmission in the definitio n of a fan) a fan sold with or without a VSD (if DOE include s the V SD in the definition of a fan) safety features that impact performance

Item 5

- 3 DOE welcomes comments on wh ether there are other design characteristics
th at should be considered when establishing equipment classes.

Further explanation of how DOE intends to use these performance

- related features to define equipment classes for fans is provided in the following sections.

5.2.1 Fan Equipment Classes

The considered e quipment classes for bare shaft fans are shown in Table 3

. The equipment classes were developed using the industry’s practice of distinguishing fan types by their aerodynamic characteristics. Further distinctions were made based on: 1) sold by manufacturer with a housing component (housed, unhoused fans), 2) performance capabilities (clean air only vs. material handling), and 3) inclusion of additional features spe cific to safety applications that would require those fans be subject to different efficiency standards or exclusion (safety fans).30

DOE understands that fans are sold as standalone units (bareshaft) or as combined packages that include the motor (and tran smission) and in some cases a VSD. The proposed equipment classes for bareshaft fans are shown in Table 3 . As discussed in section 2 .2.1 , DOE may develop two parallel sets of equipment classes to accommodate potential differences in performance characteristics of fans sold with VSD and fans sold bare shaft

. DOE expects that this series of equipment classes would be duplicated, one set of standards (in these categories)
for bareshaft fans and another set of standards for fans sold with motors and VSDs

.

Table 3 . Considered Commercial and In dustrial Fan Equipment Classes

Fan Type Equipment Class

Axial Housed

Unhoused Safety Fans

Centrifugal Clean A ir Housed

Clean Air Unhoused

Dust Air Housed Material Handling Housed

Cross Flow Housed Safety Fans

Mixed Flow All

Blowers Axial

Centrifugal

The following sections describe the further breakdown of the equipment classes for axial

, centrifugal , and mixed flow fans

.

Item 5

- 4 DOE requests comment on whether the development of separate equipment classes, and thus separate efficiency standards, is necessary to accommodate different performance characteristics of fans sold bare shaft versus fans sold with the motor, transmission, and/or controls.

5.2.1.1 Axial Fans

DOE is considering separate equipment classes for axial fans. DOE understands th at the presence and design of a housing component plays a significant role in dictating the performance of the axial fan and thus fan application. Therefore, DOE is considering splitting the axial fan types into equipment classes according to whether the f ans are manufactured with or without a housing component, distinguished by the terms "housed" or "unhoused".31

Housed axial fans are those in which an impeller is fitted within a cylindrical housing; example fan types that fall into the housed axial fan equipment class includes tube axial and vane axial
fans

. Unhoused axial fans are those manufactured with the impeller mounted in a panel or ring instead of in a housing component; an example of unhoused axial fans are traditional propeller fans. A third

eq uipment class

– safety fans

– includes axial fan designs that have special characteristics that are required for use in safety applications, as defined in section 2.1.1

.
The European Union’s non

- domestic fan legislation 327/2011 14 sets efficiency requirements for the fan and motor combination, and it does not create separate equipment classes for axial fans. However, DOE feels that the housed/unhoused design feature plays a significant role in dictating the performance of the axial fan and thus necessitates separate standards , and that safety features may also necessitate separate standards

.

Item 5

- 5 DOE requests comment on splitting axial fan types into housed and unhoused equipment classes or whether a single equipment class would suffici ently represent axial fan applications.

Item 5

- 6 DOE requests comment on what types of axial fan designs or characteristics are unique to axial

- type safety fans.

5.2.1.2 Centrifugal Fans

The presence and design of a housing component plays a significant role in dictating the operating conditions (flow and pressure) a centrifugal fan is capable of achieving. The design of the impeller (blades and hub) plays a significant role in dictating in what kind of environmental conditions (particulate level in the air) a centrifugal fan is capable of performing. DOE is considering centrifugal fan equipment classes split according to whether the fan is equipped with a housing component, and then to further refine the equipment classes based on the environmental capability of the fan as dictated by the geometry of the impeller. Typical centrifugal fans applications are f used or ventilation and industrial processes. However, some fans are used in specialized applications, such as air curtains.

Item 5

- 7 DOE requests comment on whether there are any other commercial or industrial applications (beyond clean air, dust air and material handling) that should be considered while defining equipment classes for centrifugal fans.

DOE developed housed centrifugal fan type equipment classes based on the degree to which the impeller blades can self

- clean as based on an evaluation of the geometry of the impeller (the impeller design) where:

"Clean Air" describes environments where the fan blades have curvature or the blade meets the impeller at a large angle of incidence such that dust materials build

- up on the blade surface during operation; examples of impeller designs that fall within this

14 http://eur

- lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:090:0008:0021:en:PDF32 category are airfoil, backward

- curved, backward

- inclined, and forward

- curved bladed impellers.

"Dust Air" describes environments where the blade meets the hub at a small or at no angle of incidence; examples of fans types that fall within this category in clude radial

tipped bladed impellers, shrouded radial bladed impellers, and open paddle fans.

"Material Handling" describes environments where the fan has the ability to move stringy materials such as wool, wood chips, paper shavings, etc.; these are centr ifugal fans with a radial impeller design fit with a backplate so that the materials in the air
stream will not interfere with the rotation of the fan shaft.

Item 5

- 8 DOE requests comment on the considered groupings of housed centrifugal fans. Specifically, DOE req uests comment on the use of air quality (Clean Air, Dust Air, Material Handling) and geometrical design descriptors for classification

purposes.

There are two Clean Air equipment classes for centrifugal fans, housed and unhoused. These fans typically opera

te in ventilation applications (both commercial and industrial buildings) in which there is a zero (or near

- zero) tolerance for dust

- laden air. The impeller design of Clean Air fans are subject to significant damage, increased maintenance, and premature re placement if used in applications that handle dust

- laden air.

The Dust Air and Material Handling equipment classes include fans that are typically used in
i ndustrial process applications and are designed to handle a range of dust levels and materials in t he
airstream. Fan manufacturer literature has thus far shown that these fans are sold fit in a housing.
S eparate standards for these fans from those used in clean air applications may be warranted because they have a special utility achievable only by the specific geometry of the impellers.

DOE has also included two additional equipment classes to reflect fans for special applications: cross flow fans and safety fans.

Cross flow fans are a housed centrifugal fan design used in air curtain applications. Cro ss flow
fans are forward

- curve bladed centrifugal fans that have a small wheel diameter but have elongated
blades. Because t hese fans perform a specific utility for which other fan types are not suited, DOE is placing this fan design into its own equipment class.

Item 5

- 9 DOE requests comment on whether the Dust Air, Material Handling, and Cross Flow fan equipment classes should be split into housed and unhoused categories.

Item 5

- 10 DOE requests comment on setting cross flow fans as a separate equipment
class within the cen trifugal fans category.33

Item 5

- 11 DOE requests information about the specific design characteristics of cross flow fans.

As with axial fans, some centrifugal fan designs have special characteristics that have been implemented so that they can be used in safety appli cations (see definition of "safety fan" in section 2.1.1). Since these additional features may decrease efficiency of the fan, a separate equipment class has been designated for them.

Item 5

- 12 DOE requests comment on what types of centrifugal fan designs or characteristics are unique to centrifugal

- type safety fans.

5.2.1.3 Blowers

Blowers are a type of fan, either centrifugal or axial in design, modified to perform over a high pressure range. A "high pressure" fan is determined through the fan's specific ratio as calculated based on operating conditions at peak efficiency. Specific ratios of 1.11

- 1.20 are considered blowers where as specific ratios above 1.20 are considered compressors

, which are not a subject of this document.

Item 5

- 13 DOE requests comment on setting a sep arate equipment class for blowers.

Item 5

- 14 DOE requests comment on whether there is a need of more than one blower equipment class to account for the differences between centrifugal and axial blowers.

5.2.1.4 Mixed Flow Fans

Mixed flow fans combine characteristics of cen trifugal and axial fans and are designed to perform under operating conditions in which axial fans are not capable of achieving the required pressure and centrifugal fans would perform very inefficiently. Mixed flow fans fulfill this particular
market nich e. DOE determined that these defining characteristics warrant a separate equipment class.

Item 5

- 15 DOE requests comment on setting a separate equipment class for mixed flow fans.

Item 5

- 16 DOE requests comment on whether there are differences among mixed flow fans that might warrant more than one equipment class for this fan type.

5.3 Technology Assessment

The technology assessment focuses on understanding how energy is used by fans and what potential technology changes to the design and construction of these fans would improve

t heir energy efficiency . Measures that improve the energy efficiency of the equipment are called "technology options." These measures are based on commercially available technologies, as well34

as working prototypes. In consultation with interested parties, D OE will develop a list of technology options to consider in this rulemaking. Initially, this list will include all those options that may improve energy efficiency, including a max

- tech design. Then, DOE will consider each of these technology options again st four screening criteria, discussed in section 6

. Technology options that pass all the screening criteria are called "design options," and analyze d in the engineering analysis (section 7 ).

To develop a list of technology options that could improve the efficiency of fans covered in this rulemaking, DOE is reviewing manufacturer catalogs, recent trade publications, and technical journals. DOE also intends to consult with interested parties to gather information on fan designs and applications.

Fan efficiency can be increased by improving the technology used in the design and manufacturing process. Based on its preliminary review, DOE identified the following technology options as having pote ntial to improve the efficiency of fans:

1. improving aerodynamic design
2. blade shape
3. material selection
4. guide vanes
5. optimization of housing design

6. variable speed drives

7. variable pitch blades

Fan efficiency can be increased by improving the technology used in the design of a fan and its components. The aerodynamic characteristics of the individual components used in the manufacture of a fan play an important role in the performance and efficien cy of the fan. If DOE
defines fans inclusive of the motor and controls , DOE would consider technology options for reduction of standby and off mode power for those fans sold with motors and VSDs

.

Blade Shape The shape of the blades used in the manufacture of a fan plays a significant role in how the air moves through the fan. Most fans are manufactured with single

- thickness steel blades. Airfoil blades are an alternative to the single

- thickness blade. An airfoil blade is a hollow steel blade shaped like th at of an airplane wing. The airfoil shape reduces the pressure losses from the impeller [ 16 ] . For single

- thickness blades, efficiency improvements can be achieved by changing
the amount of curvature, as well as the direction of curvature in the blade.

Material Selection This technology option may serve to improve efficiency of a fan. DOE anticipates that the impact of the material selection may be different depending on the fan type and app lication. DOE is aware of fan impellers being constructed with aluminum, steel, fiberglass, and plastics.

Item 5

- 17 DOE requests comment and/or information on the effect of different materials on efficiency.35

Item 5

- 18 DOE requests comment on whether there are other fan blade materials that
should be included in the list above.

Guide Vanes Guide vanes direct and straighten the airflow, resulting in less pressure loss through the impeller. The fan housing serves to gather airflow and direct it in the desired direction. Some
axia l and centrifugal fans are used in air handling units without housing or are manufactured without housing but are installed within a wall or other equipment that takes on the characteristics of a housing. For axial fans manufactured with a housing, guide v anes can be added upstream, downstream, or both. For centrifugal fans, guide vanes may be used at the inlet (upstream) of the housing.

Optimization of Housing Design Centrifugal fan housing serves to gather airflow and direct it in the desired direction. The housing is shaped so that the flow area increases in the direction of rotation from the cutoff to the
outlet. Matching the width of the housing to the width of the impeller could improve efficiency

, as a housing that is too wide allows recirculation, and housing that is too narrow may interfere
with the inlet.

For axial fans, the radial clearance between the blade tip and the housing can impact fan performance and efficiency. Optimization of the axial fan housing means ensuring that the region
of hou sing enclosing the impeller is kept round so that the tip clearance will be small and uniform around the circumference. Axial fan capacity is a function of the tip clearance and the
thickness of the blade.

Variable Speed Drives Variable speed drives (VS Ds) are control devices that can be used as a means to improve efficiency for fans sold with the motor that operate under variable loads. VSDs used under

constant

- load operation conditions may degrade in efficiency compared to optimally designed
systems.

Item 5

- 19 D OE requests comment on whether there are compatibility issues with certain fans and VSDs DOE should be aware of when considering a VSD as a means to improve fan efficiency.

Variable Pitch Blades (Axial Fans only) The angle at which the fan blade is fit to the impeller hub affects the way the air flows through the impeller. A variable pitch for axial fans allows for changes in operating conditions by changing the blade angle instead of using a throttling device [ 17 ] . The pressure losses from the
im peller are believed to be much less than the losses from a throttling device; thus, the energy requirements to power the fan are lessened. Variable

- pitch blades can be adjusted manually or through an automatic variable

- pitch control.36

Item 5

- 20 DOE welcomes comments on the preliminary technology options identified in this section 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 user utility.

6. SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technology options that DOE will not consider in its potential energy conservation standard rulemaking for commercial and
industrial fans. At the outset, DOE develops a list of technology options for consideration through its own research and in consultation with interested parties. Development of the list is based on the technologies described in section 5.3 . The identified candidate technology options encompass all those technologies that may improve energy efficiency.

DOE then reviews each technology option considering the f ollowing four criteria, as provided in sections 4(a)(4) and 5(b) of Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products (see 10 CFR Part 430, Subpart C, Appendix A):

1. Technologic al feasibility. DOE does not further consider technologies that are not incorporated in commercially available equipment or in working prototypes.

2. Practicability to manufacture, install, and service. If DOE determines that mass production of a technology in commercial equipment 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 effective date of the sta ndard, then it does 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 equipment to significant subgroups of consumers, or result in the unavailability of any covered equipment type with performance characteristics (including reliability), features, size, capacities, and volumes that are substantially the same as equipment generally available in the United Sta tes at the time, it does 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 does not consider that technology
further.

DOE will full y document the reasons for eliminating any technology options during the screening analysis and solicit interested parties’ comment. The remaining options, called design options, are considered further in the engineering analysis (section 7 .)37

Item 6

- 1 Are there any technologies, including those listed in section 5.3 , that DOE should not consider because of any of the four screening criteria? If so, which screening criteria apply to the cited technology or technologies?

7. ENGINEERING ANALYSIS

After conducting the screening analysis, DOE performs an engin eering analysis b ased on the remaining design options that would improve fan efficiency. This section provides an overview of the engineering analysis, and discusses baseline models, DOE’s proposed approach for determining the cost

- efficiency relationship, efficiency levels, proprietary designs, and cumulative regulatory burdens that might affect the engineering analysis.

7.1 Engineering Analysis Overview

The purpose of the engineering analysis is to determine the relationship between manufacturer selling pric e (MSP) and fan efficiency. In determining the cost

- efficiency relationship, DOE estimates the increase in MSP (includes manufacturing cost and manufacturer markups) associated with design changes that increase fan efficiency relative to the baseline
model s.

As a preliminary step in this analysis, DOE may determine an appropriate subset of representative equipment classes to analyze. DOE would extrapolate the results of this analysis to the remaining equipment classes. Typically, each representative equip ment class would represent the majority of the shipments in its category. The number of representative equipment
classes w ould depend on the availability of data that would allow for developing appropriate relationships between the engineering analysis results of the representative equipment class and the other equipment classes not directly analyzed.

For each representative equipment class, DOE may analyze a subset of representative units. The representative units w ould be selected based on fan size (impeller diameter) and potentially a second parameter such as specific speed. Multiple representative units may be
chosen for e ach equipment class, or, a single fan size w ould be selected and scaling factors derived to extrapolate the results from the selected size(s) to other sizes not directly analyzed.
DOE may develop scaling relationships for fans by creating a model that desc ribes efficiency as a function of certain parameters such as a fan’s impeller diameter and specific speed at peak efficiency.38

Item 7

- 1 Once DOE establishes any representative equipment classes and representative units, it selects a baseline model as a reference p oint for each representative unit from which to measure changes resulting from the design options. DOE develop s separate engineering analyses for each baseline model analyzed. DOE intends to use fan teardowns and fan efficiency (determined from fan perform ance tests) to develop cost

- efficiency relationships for the fans analyzed. DOE intends to develop the necessary test procedures through a test procedure rulemaking, as
discussed in section 3

. DOE welcomes inputs from interested parties on a methodology that would be appropriate for determining the max

- tech models for each fan analyzed.

Item 7

- 2 DOE seeks input on the methods and approaches used by manufacture rs to improve the efficiency of fans.

Item 7

- 3 DOE welcomes comment from interested parties on the best methodology for scaling the representative units to other fan sized within the equipment class.

For the engineering analysis, DOE examine s incremental increases in the manufacturer selling price associated with increases in fan efficiency. For the preliminary analysis phase of the rulemaking, DOE intends to utilize publicly available data from manufacturer websites and catalogs for fans in the market to categorize relationships between efficiency and technological options. DOE encourages interested parties to submit test data that will improve DOE’s understanding of fan performance. DOE also use s this information to select representative units in each equipment cla ss. DOE focus es its analyses on these representative units.

Item 7

- 4 DOE seeks fan test data to improve DOE’s understanding of fan performance to select appropriate representative units for the respective equipment classes.

DOE has two options for conducting the engineering analysis:

Option 1: Design

- option approach. Report the incremental costs of adding design options or combinations of design options to a baseline model 15 . This cost includes but is not limited to incremental cost of changes in material, labor, shipping, and overhead from the baseline Option 2: Efficiency level approach. Report relative costs of achieving improvements in energy efficiency at incremental efficiency levels over baseline including those efficiency levels that include the maximum ef ficiency improvements that are technologically feasible ("max

- tech"). All models of varying efficiency for a given representative unit should be as similar as possible to be comparable and ideally differ only in efficiency.

15 Typically represents equipment with the lowest efficiency on the market

.39

For each representative unit, DOE identif ies and evaluate s commercially available fans that incorporate design options that improve efficiency. The engineering analysis will also identify the highest efficiency that is technologically feasible ( i.e., the max

- tech model). DOE may determ ine the max

- tech model by investigating the existence of any working fan prototypes with higher efficiency than those commercially available.

7.2 Engineering Analysis Methodology

DOE plans to purchase, test, and reverse engineer the representative units withi n each representative equipment class. DOE would conduct testing according to the appropriate DOE test procedure which is concurrently being developed (see section 3 )

. The reverse engineering will include a physical teardown of the representative unit in which DOE will: disassemble and inventory the fan, identify the design options and technology changes used in each fan, and construct a bill of materials (BOM) and labor cost estimate for each fan.

DOE may supplement the findings from its tests and teardowns through: (1) a review of data collected from manufacturers about prices, efficiencies, and other features of various fan models, and (2) interviews with manufa cturers about the techniques and associated costs used to improve efficiency. In addition, DOE will use the cost data generated by the engineering analysis in the manufacturer impact analysis (see section 14 ). If possible, DOE will then aggregate the cost numbers by weighing individual data points by company

- level sales volumes for each equipment class.

A cost model will be developed as part of the engineering analysis. The cost model will use the BOM generated from either a design

- option or an efficiency level approach to estimate the equipment costs (i.e. MSP) for each representative unit at each effici ency level considered. The cost model would also assess the conversion costs (e.g., tooling, research and development, machinery) that a manufacturer would need to invest for producing a more efficient product.

DOE typically only considers equipment cos ts in the engineering analysis and all conversion costs are accounted for in the manufacturer impact analysis (see section 14 ). However, DOE unders tands that many efficiency improvements are the result of re

- design to improve a fan’s aerodynamic characteristics and therefore may not be apparent in a BOM and reflected in the equipment costs. Therefore, DOE may consider adding some of the conversion

co sts to the equipment costs when developing cost efficiency curves in the engineering analysis.

The structure/classification of the manufacturing cost/price follows the traditional manufacturing process and includes:

1) Equipment Costs (i.e. MSP): Recurring costs associated with manufacturing.

a. Full production cost (i.e. MPC), i.e., direct labor, direct material, overhead (Indirect labor, indirect material, maintenance, depreciation, taxes, insurance related to assets).
b. Non

- production cost (used to generate MS P), i.e., selling (market research, advertizing, point

- of

- sale (POS) promotion, sales person compensation and travel, logistics such as warehousing, delivery, record keeping), general and administration (costs for service and staff units, general corporate costs such as40 compensation, etc.), research and development (R&D) (costs associated with efforts to find new or improved products or production processes) and interest (costs of borrowing funds). DOE typically uses manufacturer markups calculated from pub licly available financial information ( e.g. , Securities and Exchange
Commission 10

- K reports) to account for non

- production costs. 2) Conversion Costs: I nvestments used to bring production facilities and equipment designs in compliance with the new regulation

.

a. Equipment conversion costs, i.e., investments in research, development, testing, and marketing focused on making equipment designs comply with the new
standard.
b. Capital conversion costs, i.e., investments in property, plant, and equipment to adapt or cha nge existing production facilities so that the new equipment designs
can be fabricated and assembled.

c. Stranded assets, i.e., equipment or tooling that become obsolete as a result of new regulation.

DOE intends to consider three production scenarios when de veloping manufacturing production cost estimates: (1) an average volume to represent the average sized manufacturer with levels of production that are average for the industry; (2) a high volume to represent those manufacturers with high levels of producti on, resulting in large purchasing power and lower MPC; and (3) a low volume to represent those manufacturers with low levels of production, resulting in limited purchasing power and higher MPC. For the analysis, DOE plans to utilize
these scenarios to deve lop a single "weighted average scenario" which would be representative of the typical volume of sales.

Manufacturer cost information should reflect the variability in baseline models, design strategies, and cost structures that exist among manufacturers. I f necessary, DOE will qualify any aggregated cost

- efficiency data using information obtained through follow

- ups with manufacturers. These interviews will provide a deeper understanding of the various combinations of technologies used to increase fan effici ency, as well as their associated manufacturing costs.

DOE will estimate the contribution of the depreciation of conversion capital expenditures to the incremental overhead. During the interviews with manufacturers, DOE will gather
information about the ca pital expenditures needed to increase the efficiency of baseline models to various efficiency levels ( i.e. , conversion expenditures by efficiency). DOE will also gather information about the depreciation method(s) used to expense the conversion expenditure s.

The proposed approach will enable DOE to characterize the cost

- efficiency relationship for fans across the entire efficiency range for all equipment classes. DOE will maintain the confidentiality of proprietary data while allowing the public to examine the cost and design assumptions that underlie the cost

- efficiency estimates.41

Item 7

- 5 For each equipment class, DOE welcomes comment on methods and approaches that DOE intends to employ to determine potential fan efficiency improvements. Detailed information on fan performance and the incremental manufacturing costs (e.g., material costs, 16 labor costs, 17 overhead costs 18 , building conversion capital expenditures, tooling/equipment conversion capital expenditures associated with more efficient designs, research and development (R&D) expenses, and marketing expenses) would be useful.

Item 7

- 6 DOE welcomes comment on the markup approach proposed for developing estimates of manufacturer selling prices.

Item 7

- 7 DOE welcomes comment on the proposed approach to determine the relationship between manufacturer selling prices and fan efficiency.

Item 7

- 8 DOE welcomes comment on the conversion costs required to improve the efficiency of the fans to various levels, as well as what portion of these costs would be passed on to the consumer.

7.2.1 Representativ e Unit Selection Methodology

The proposed fan equipment classes cover a range of fan designs and allow for a wide range of fan sizes. To evaluate the efficiency and design of a variety of fans within an equipment class, specific speed at a single fan size, or over a small range of sizes, would be used in the selection process. The specific speed parameter would be used to confirm that the selected fans are of a similar design.

A fan’s peak efficiency has a non

- linear relationship with fan size [ 9

, 18 ] . This pheno menon is due to the Reynolds number effect. Reynolds number is a value used to describe different flow regimes (low Reynolds numbers represent a laminar (smooth) flow , large Reynolds numbers represent turbulent flow). Small fans have greater losses due to the Reynolds number effect causing them to be less efficient than geometrically identical, larger diameter,
fans.

16 Direct material costs are the c osts of raw materials such as steel, and also includ e scrap metal that can be

trace d to final or end equipment . Direct material costs do not include indirect material costs

, which are attributed to supplies that may be used in the production process

, but are not assigned to final pieces of equipment ( e.g. , lubricating oil for production machinery).

17 Labor costs are t he earnings of workers who assemble parts into a finished good or operate machines in the production process. Direct labor costs include the fringe benefits of direct laborers such as group health care, as well as overtime pay. Direct labor costs do not include indirect labor, which is defined as the earnings of employees who do not work directly in assembling a piece of equipment

— such as supervisors, janitors, stockroom personnel, inspectors, and forklift operators.

18 Factory overhead exclud es depreciation , but includes indirect labor, downtime, set

- up costs, indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG& A)

, R&D

, interest

, or profit (which DOE accounts for separately).42

D ata gathered from manufacturer literature indicates that above a certain fan size (approximately 30 inches), peak total efficiency is genera lly constant. Therefore, Reynolds number is no longer a sensitive efficiency parameter. DOE plans to narrow representative unit selections for each equipment class by identifying the fan size (or size range) with the greatest frequency of fan models. 19 DOE will then evaluate the range of specific speeds within the data set and select fans near the same specific speed. Additionally, for several equipment classes, DOE is considering testing fans from one of the selected fan series at both larger and smaller
si zes to develop a size

- efficiency scaling relationship.

Item 7

- 9 DOE requests comment on limiting representative unit selection to fan size(s)
that include the most available units.

Item 7

- 10 DOE requests comment on the selection of additional fans at both larger and
smaller sizes to determine a fan size

- efficiency scaling relationship. DOE requests comment on the number of additional fans to test to develop the size

- efficiency scaling relationship.

After a size (or size range) is established, the entire set of fan models will be assessed to
determine bottom

- of

- market, average

- of

- market, and top

- of

- market efficiency levels. Since there are no current efficiency standards for commercial and industrial fans, DOE plans to determine
the bottom

- of

- market efficiency level by selectin g the lowest efficiency model in the data set. A similar process would be performed to select the top

- of

- market efficiency level. An average

- of

market efficiency level may be determined by averaging the efficiencies for the sample set and choosing a unit o f that efficiency.

Item 7

- 11 DOE requests comment on the method of using fan unit efficiencies as the basis for determining efficiency levels.

7.3 Baseline Models

Once DOE establishes the representative units for the equipment classes, it selects a baseline model as a reference point from which to measure changes resulting from the design options. The baseline efficiency level may be higher than the bottom

- of

- market efficiency as it is representative of the lowest efficiency level at which the majority of fans are being purchased in
the market.

To analyze technology options for energy efficiency improvements, DOE will define a representative baseline model for each representative unit. The baseline model should re present the characteristics of fans in a given equipment class used in common commercial or industrial applications. Typically, the baseline model would be a model that just meets current energy

19 Data source for fan information used in representative model selection and efficiency level determination(s) is publicly available performance data from manufacturer catalogs and fan selec tion software.43

conservation standards; however, energy conservation standard s for fans do not exist. As a result,
DOE will evaluate selection of the baseline model at the bottom

- of

- market efficiency level or [can we describe what this is rat her than just saying “higher”? ] . Selection of the baseline model for each representative un it will encompass consideration of fan features and performance characteristics, such as a fan’s impeller type. Should DOE determine that additional representative units are warranted, DOE would develop baseline efficiency levels for these representative units.

Item 7

- 12 DOE seeks comment on the selection, appropriate features, and performance characteristics of baseline models for each equipment class. Specifically, DOE requests comment on choosing the least efficient fan design as the baseline model for the equipm ent class. DOE will define the characteristics of the proposed baseline models based on comments from interested parties in addition to DOE's analysis.

7.4 Proprietary Designs

DOE will consider in its engineering and economic analyses all design options that a re commercially available or present in a working prototype, including proprietary designs and technologies. However, DOE will consider a proprietary design in the subsequent analyses only if the achieved efficiency level can also be reached using other no n

- proprietary design options. If the proprietary design is the only approach available to achieve a given efficiency level, then DOE will reject that efficiency level, as the analytical results would appear to favor one
manufacturer over others.

DOE is s ensitive to manufacturer concerns regarding proprietary designs and will make provisions to maintain the confidentiality of proprietary data submitted by manufacturers or discussed during manufacturer interviews. Materials provided to Lawrence Berkeley Nat ional Laboratory (LBNL) or Navigant Consulting, Inc. (NCI), DOE contractors for this rulemaking, are generally subject to the terms of the applicable agreement under which those materials are submitted. In the case of materials provided to LBNL or NCI in the context of a DOE rulemaking and subject to a non

- disclosure agreement, those materials are generally not shared with DOE, apart from aggregated data that do not identify particular submitters. These materials may also be subject to a variety of laws a nd regulations governing the disclosure of Federal agency information. Information submitted to DOE will be protected in accordance with all applicable federal laws, rules, or regulations, including but not limited to the Trade Secrets Act, 18 U.S.C. §190 5, and the Freedom of Information Act (FOIA), 5 U.S.C. §552, and DOE's implementing regulations at 10 CFR 1004.

Item 7

- 13 DOE welcomes comment on whether there are proprietary designs it should consider for any of the fan designs under consideration in this rulemaki ng and, if so, how DOE should acquire the cost data necessary for evaluating these designs.44

7.5 Efficiency Levels

For each of the representative units, DOE will undertake analyses to determine potential efficiency levels and seek to develop incremental cost data at each of these levels.

To establish the efficiency levels DOE intends to consider, DOE will analyze the design changes and costs associated with improving fan efficiency from the baseline through the max

tech model. This will include considering the design options identified in the screening analysis. DOE also intends to collect fan efficiency data from various manufacturer catalogs 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 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 commerciall y available and, therefore, would not be found in today’s available maximum efficiency equipment. DOE seek s input from interested parties to determine appropriate max

- tech efficiency levels. (42 U.S.C. § 6295(p)(2))

Item 7

- 14 DOE seeks input from interested partie s regarding the range of efficiency levels that should be examined as part of its analysis.

Item 7

- 15 DOE requests comment on whether manufacturers generally do not offer fans of varying efficiencies that meet the same duty requirement.

7.6 Outside Regulatory Changes Af fecting the Engineering Analysis

In conducting an engineering analysis, DOE takes into consideration the effects of other DOE energy conservation standards and regulatory changes outside DOE’s statutory energy conservation standards rulemaking process that can impact the manufacturers of the covered equipment. Some regulatory changes can also affect the efficiency or energy consumption of the fans covered in this rulemaking. DOE will attempt to identify all such outside engineering issues that could impact the engineering analysis. The con sideration of these issues is closely related to the cumulative regulatory burden assessment that DOE will carry out as part of the manufacturer impact analysis (see section 14 )

.

Item 7

- 16 DOE welcomes comment on whether there are outside regulatory changes that DOE should consider in its engineering analysis of fans.

8. MARKUPS ANALYSIS

DOE uses manufacturer

- to

- user markups to convert the manufacturer selling pri ce estimates from the engineering analysis to user prices, which are then used in the LCC and PBP.
End

- user prices are needed for the baseline efficiency level and all other efficiency levels under45

consideration to estimate user costs and benefits as a res ult of energy conservation standards.
DOE will obtain these end

- user prices by applying manufacturer

- to

- user markups (consisting of distribution channel markups and sales tax) to the manufacturer selling price estimates.

To develop markups, DOE must iden tify distribution channels ( i.e. , how the equipment is distributed from the manufacturer to the user). Once it establishes proper distribution channels for each of the equipment classes, DOE will rely primarily on economic census data from the
U.S. Census Bureau and input from the industry to estimate how equipment is marked up in the distribution chain from the manufacturer to the user. DOE may also consider examining whether
end

- user price data can be used to characterize overall manufacturer

- to

- user mark ups.

The following subsections summarize DOE’s approach for developing markups for the preliminary analysis of commercial and industrial fans

.

8.1 Market Participants and Distribution Channels

DOE’s review of information for commercial and industrial fan distribution channels indicates that fan manufacturers sell most fans through: OEMs and specialized distributors or dealers representing the manufacturer. It is likely that fan manufacturers als o sell directly to large
end

- users and, possibly to a lesser degree, to large mechanical contractors. However, DOE
believes that shares of direct end

- user sales through the National Accounts and large mechanical contractor channels are low compared to the OEM and distributor channel shares.

Figure 2 shows the likely distribution channels for commercial and industrial fans. In the OEM channel (labele d A in the figure), fans purchased by OEMs from the manufacturer may be
included in air

- handling unit 20 or shipped within the scope of project supplies for industrial projects. In the Distributor channels (labeled B and C), equipment inventory for sale is either maintained at the distributor’s premises or the ordered items are procured by the distributor on user orders. The distributors may sell equipment through a mechanical contractor (distributor
channel

- B), or directly to the user (distributor channel

- C). For the direct end

- user (labeled
channel

- D), the distributing companies are identified as manufacturer representatives in manufacturer websites. If these companies do not actually sell equipment, but provide only user support and technical assistance, then they earn commissions paid by the manufacturers, and there may not be any markup from the manufacturer representatives. In Figure 2 , any distribu tion channel that is different from the channels described above (channels A through D) is labeled as
channel E.

20 DOE is only considering fans that are not a component of other equipment for which DOE has already
established standards.46

Item 8

- 1 DOE requests information regarding the functioning of the manufacturer representatives/distributors for different equipment classes and market segments.

8.1.1 OEM Market Segments (OEM Channel A)

Based on the comments received from interested parties during the Notice of Proposed Determination of Coverage and preliminary market asse ssment, DOE has identified the following OEM m arket segments where commercial and industrial fans are components integrated in the systems manufactured by OEM manufacturers:

commercial air

- handler units
cooling tower manufacturers
pneumatic conveying equipment manufacturers (coal, grain, pharmaceuticals, cement, insulation and others)

industrial boiler manufacturers

The above is a preliminary list of identified OEM m arket segments where the fans are first sold to the OEMs, who add their mark

- ups, an d then sell either directly to the user or through distributor channels.

Item 8

- 2 DOE requests information on other OEM market segments, and the downstream distributor channel, if any.

8.1.2 Distributor Channel

— Market Segments (Distributor Channels B and C)

During th e Notice of Proposed Determination of Coverage, the Joint Commenters pointed out the following major application segments for fans:

Fans for HVAC systems in commercial buildings: These include the main fans of the air

handling units, return air fans, and exhaust fans. The distribution channel for this market Manufacturer  OEM  OEM Product Distributo r  User (OEM Channel

- A )

Manufacturer  D istributor  Contractor  User (Distributor Channel

- B )

Manufacturer  D istributor  User (Distributor Channel

- C )

Manufacturer   User (Direct End

- User Channel

- D )

Manufacturer  Other  User (Channel

- E ) Manufacturer Representatives

Figure 2

. Commercial and Industrial Fan Distribution Channels47

segment is through the air

- conditioning and refrigeration equipment distributors who are usually members of Heating, Air

- conditioning and Refrigeration Distributors International (HARDI).

Fans for vent ilation and evaporative cooling in the poultry and livestock industry: These are distributed by poultry and livestock equipment dealers. Commercial kitchen exhaust fan hoods: These are distributed by food service equipment

dealers. DOE has identified the Food Equipment Dealers Association (FEDA) and the National Association of Food Equipment Dealers (NAFED) as the representative trade associations representing their interests.

In a related comment, the CA IOUs also identified the above as "commodity" p roducts. The above is a preliminary list of identified market segments where the equipment is sold through different distributor channels. DOE is independently attempting to identify the high

volume market segments for fans and the associated distribution channels. DOE is also seeking to confirm the segments already identified by interested parties.

Item 8

- 3 DOE requests comments on the applications and market segments identified by interested parties and information on other market segments, including their

corre sponding distributor channel(s) and the trade association(s) representing the
distributors.

8.1.3 Distribution Channel Shares

DOE requests comments and additional information on the appropriate way to establish distribution channel percentages across equipment classes and application (market) segments for the current rulemaking.

In particular, DOE seeks information on the percentage, by equipment category (i.e.,
axial housed fans, axial unhoused fans, centrifugal clean air unhoused fans, centrifugal clean air
housed fans, centrifugal dust air housed fans, centrifugal material handling housed fans, housed cross flow fans, blowers, safety fans, and mixed flow fans) and application segment (i.e., ventilation, agriculture, exhaust, and any other applicat ions), of OEM sales, distributor sales, direct sales, and other sales. DOE seeks this information over the total market.

Item 8

- 4 DOE requests information on the proposed distribution channels and the share of industry shipments expected for each distribution channel for the commercial and industrial fans covered under this rulemaking in terms of either each specific equipment class in 5.2 o r the broader equipment categories described above.

8.2 Estimating Markups

DOE intends to develop baseline and incremental markups for commercial and industrial fans. Baseline markups are cost multipliers applied to the manufacturer sales price (MSP) of48

baseli ne equipment, while the incremental markups are cost multipliers applied to the incremental cost change in the MSP of the higher

- efficiency equipment. Through the markup analysis, DOE will generate end

- user prices for each equipment efficiency level that D OE considers. DOE’s approach for estimating the mark

- up multipliers will depend on the specific distribution channel traced by the equipment (from the manufacturer to the end

- user).

For the distribution channels, DOE will use such data sources as the U.S . Census Bureau Economic Census reports, and, if available, member aggregate profit analysis reports from the respective trade associations to estimate the markup percentages. For estimating general contractor markups, DOE proposes to use the U.S. Census Bureau data for Commercial and Institutional Building Construction.

For the OEM channel, DOE will first estimate the OEM’s markup using either public domain data from a representative sample of manufacturers or economic census data from the
U.S. Census Bu reau for specific industry groups. In determining the final end

- user price, the
distributors’ mark

- ups (as multipliers or factors) for the OEM equipment incorporating the fans will be estimated using the approach described previously.

For the direct end

- user channels, DOE will estimate the markup percentage based on information provided by the manufacturers on differences in the end

- user price and the
d istributor prices.

For the appropriate sales tax markup, population

- weighted average tax data will be based on the Sales Tax Clearinghouse and U.S. Census Bureau. DOE may consider adding shipping costs to the markups or have them included in the manufacturer’s selling price, as appropriate.

Item 8

- 5 DOE seeks comment on other sources of relevant data that cou ld be used to characterize markups for commercial and industrial fans.

Item 8

- 6 DOE requests feedback on its proposal to use incremental distribution channel markups for the LCC analysis.

Item 8

- 7 DOE seeks comment on appropriate transportation and shipping costs to
include in the analysis and whether those costs are likely to vary for higher

- efficiency equipment.

9. ENERGY USE AND END

- USE LOAD PROFILE CHA RACTERIZATION

The purpose of the energy

- use and end

- use load profile characterization is to identify
how fans are actually o perated by users and to determine the energy savings potential of more efficient designs in the field. The results of this analysis are used as inputs to the LCC, PBP, NIA, and other downstream analyses.49

9.1 Overview

DOE will estimate annual energy consumption (AEC) for baseline and higher

- efficiency designs using use the load profiles developed for each application. Energy savings will then be calculated in the life cycle cost and payback period analysis discussed in section 10.

In the context of this document, DOE uses the term ‘load profile’ to represent the temporal variation of the useful output from the fan at the point of fan exit

— that is, the variation in delivered air horsepower over the usage cycle, relat ive to a predetermined fixed output, which may be the "design", "peak", or other well

- defined useful output point for the fan. Thus, the load profile represents the time variability in the ratio of the actual air horsepower output to a predetermined fixed output.

For most fans, the end

- use load profiles are expected to be highly variable across equipment classes and applications. If there is little variation in the fan total pressure and the delivery airflow volume of the fan over the period of usage, on ly the number of annual operating hours needs to be determined to estimate the AEC. For example, DOE expects this situation to be typical of most commercial kitchen exhaust fan applications

— a high

- volume market segment. On the other hand, an air

- handler fa n in a commercial building HVAC application would have constantly changing airflow rates and total pressure variation throughout the year. The annual energy consumption in this case would be based on a summation of the number of hours run in specific flow rate and total pressure bins and the corresponding hourly energy consumption in each bin. A related issue is how a fan is sized to an application. From an energy efficiency standpoint, optimally sized fans would all be selected to provide their peak effici ency for each application. In practice, however, DOE recognizes that the use of discrete fan designs and sizes, as well as practical application constraints, results in many, if not most, fans typically operating at points other than their peak efficiency

.

The useful work done by any fan will vary widely across a range of possible applications. The energy used by the fan in producing useful work equals the flow energy transferred to the media plus all energy losses associated with the fan system (includ ing the fan, the motor, and the transmission system). DOE intends this analysis to capture and estimate energy consumption in the field for a variety of applications. For applications not specifically considered, DOE would apply a generic load profile for the equipment class.

DOE will consider develop ing statistical models describing the expected range of duty profiles for fans in different applications. DOE will also consider whether the model parameters should vary with the fan equipment class or capacity. DOE intends to use manufacturer performance data and fan similarity laws to determine the energy use of a fan under the expected deviation from peak efficiency. This approa ch w ould provide a statistical distribution of AEC values for each fan type and application for use in the LCC and payback period analysis (section
10 ).

Item 9

- 1 DOE requests input and recommendations for identifying high sales volume and large installed base market segments corresponding to specific industries and specific applications for which the fan equipment may have similar load profiles.50

Item 9

- 2 DOE welcomes recommendations on sources of data or analysis methods that would provide end

- use load profiles for each of the commercial and industrial fans in the different market segments.

Item 9

- 3 DOE requests input on ways to characterize fan sizing and selection practices f or different equipment classes and applications and to help define the design or peak fan load for the purpose of generating normalized load profiles. For example, one question is whether load profiles should reflect normalization to the delivered air
hor sepower at the peak efficiency of the fan (at a given fan size and speed).

Item 9

- 4 DOE welcomes comment on methods for determining generic (non

- market segment specific) load profiles for fan equipment classes considered in this rulemaking.

Item 9

- 5 DOE welcomes comment on the current penetration level of variable

- speed drives in the installed base of products or applications for each of the equipment classes considered in this rulemaking.

9.2 Analytical Approach

Because series

- produced fans cover a wide range of fan diameters, DOE will estimate the energy savings for an equipment class based on the calculated energy saving potential for improved efficiency designs for each representative unit. For each analyzed representative unit, the starting point for the annual energy consum ption calculation will be the fan performance and power curves developed in the engineering analysis for a range of operating points at the maximum speed. DOE will estimate the average annual energy consumption for each representative unit in a given appli cation by using the following formula :

Equation 1

Where: AEC = annual energy consumption (kWh)

= air horsepower at the operating point i

N i = operating hours at the operating point i

η Overall =η F × η T × η M × η C at the operating point i

η F = fan efficiency

η T = transmission efficiency

η M = motor efficiency

η C = control system efficiency

The air horsepower (H Fan ) is based on the actual operating point of the fan on the fan performance curve. For a given application in an equipment class, and for each equipment class51

overall, DOE requests information and data sources useful for determining each of the factors
descri bed above.

Item 9

- 6 DOE requests comment and recommendations on the number of analyzed sizes to be selected for each equipment class.

Item 9

- 7 DOE requests comment and recommendations on the range of and number of fan rotation speeds over which the analysis should be carried out for different equipment classes.

Item 9

- 8 DOE requests information on current industry practices and recommendations on the selection of representative operating points for a given rotational speed. DOE welcomes comment on whether the analysis should be extended to a range of operating points away from the peak efficiency.

Item 9

- 9 DOE requests comment and estimates to establish the mean value and the ranges of likely values for motor, transmission, and motor control efficiencies.

10. LIFE

- CYCLE COST AND PAYBA CK PERI OD ANALYSIS

The effects of energy conservation standards on users include a change in operating expense (usually decreased) and a change in purchase price (usually increased). DOE analyzes the net effect on users by calculating the LCC and PBP using the en gineering performance data, equipment prices, and the energy

- use and end

- use load characterization data. Inputs to the LCC calculation include the cost to the user of the installed equipment (purchase price plus installation cost), operating expenses (ener gy expenses and, if applicable, repair costs and maintenance costs), the lifetime of the equipment, and a discount rate.

10.1 Approach for Conducting the Life

- Cycle Cost and Payback Period Analysis

DOE plans to conduct an LCC and PBP analysis for each of the r epresentative units within each representative equipment class. DOE conducts the LCC and PBP analysis by modeling both the uncertainty and variability in the inputs using a Monte Carlo simulation method and probability distributions to characterize the inp uts. The Monte Carlo approach identifies the percentage of consumers benefiting from and being burdened by a potential
standard.

DOE develops an LCC and PBP model that incorporates both Monte Carlo simulation and probability distributions by using Micros oft Excel spreadsheets combined with Crystal Ball (a commercially available add

- in program). Each Monte Carlo simulation would typically consist of 10,000 21 LCC and PBP calculations. The model would perform each calculation using input values sampled from p robability distributions or characterized with single point values. The

21 DOE typically chooses 10,000 iterations to ensure consistency of the LCC results.52

analysis results would be 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.

DOE expects to use pr obability distributions to characterize some of the operating cost inputs to the LCC and PBP analysis, including equipment lifetime and consumer discount rates. Depending on the available data, DOE expects to use point values to characterize the other LC C inputs, such as the manufacturer markup.

To estimate the percentage of users that would be affected by a particular standard level, DOE takes into account the distribution of equipment efficiencies expected for the compliance year. In other words, rather than analyzing the impacts of a particular standard level assuming that all users are currently purchasing equipment at the baseline level, DOE conducts the analysis by taking into account the full range of equipment efficiencies that users purchase under the base case ( i.e., the case without new energy efficiency standards). By accounting for users who already purchase more

- efficient equipment, DOE avoids overstating the potential benefits from standards. DOE determines the LCC and PBP for a particu lar standard level relative to the base case distribution of equipment efficiencies. For example, in performing an iteration of the Monte Carlo simulation for a given user, equipment efficiency will be chosen based on its probability. If the chosen equipme nt efficiency is greater than or equal to the efficiency of the standard level under consideration, the LCC and PBP calculation would reveal that a user is not impacted by
the standard level.

DOE is also required to perform an analysis to determine wheth er the three

- year rebuttable presumption of economic justification applies (i.e., whether the additional cost of purchasing a product that meets the standard level would be less than three times the value of the energy savings in the first year.). (42 U.S. C. § 6295(o)(2)(B)(iii)) To determine the rebuttable

presumption PBP, DOE would determine the value of the first year’s energy savings by calculating the quantity of those savings in accordance with DOE’s test procedure. DOE
determine s whether selected CSL s are economically justified through a n 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 following sections discuss how DOE plans to develop key inputs to the LCC and PBP analysis, including (1) installation costs; (2) energy prices; (3) maintenance and repair costs; (3) equipment lifetime; and (4) discount rates. The other inputs to the LCC and PBP analysis

— namely, manufacturer costs, annual energy consumption, and mar kups for the determination of retail prices

— have been discussed previously. The final section discusses the base case efficiency distribution, which accounts for expected market behavior in the absence of new
standards.

10.2 Installation Costs

The installation cost consists of labor (including overhead) and any miscellaneous materials and parts.

For fans, installation costs typically amount to from 50% to more than 100% of the purchase price of the fan [ 6 ]

. The installation cost is deter mined largely by the transmission type53

and, less directly, by fan size. For either direct

- driven or belt

- driven fans, the simplest installation takes place when the motor is mounted by the fan manufacturer (sold as a driven fan). When the fan is sold as a bare shaft fan the installer aligns the fan and motor, which involves more time. Installation cost is not strongly related to fan capacity (rated CFM). For example, in general, axial fans are more compact for a given fan capacity, so installation costs

ten d to be lower than for centrifugal fans of similar capacity.

DOE recognizes that larger, as well as more efficient, fans may be more difficult and expensive to install in constrained spaces or configurations.

Item 10

- 1 DOE welcomes comment on the factors that impact the installation costs for fans and on whether installation cost increases with higher

- efficiency equipment.

10.3 Energy Prices

For fan users, DOE will survey commercial and industrial energy tariffs 22 as a means of establishing marginal electricity prices.

DOE will also use data from the Commercial Building Energy Consumption Survey 23 conducted by the Energy Information Administration (EIA) to estimate building electricity use characteristics that impa ct electricity prices. If the tariff survey and EIA data demonstrate a large variability in electricity prices, DOE will conduct a sensitivity analysis to determine how high and low electricity price estimates might impact the economic feasibility of any e nergy conservation standard. DOE will use projections of national average energy prices for
commercial and industrial users

— principally from EIA’s Annual Energy Outlook ( AEO ) from the most recent year available

— to estimate future energy prices in its LCC a nalysis. To account for the expenses due to reactive power demand, DOE also intends to survey reactive power prices, principally using data from the EIA.

Item 10

- 2 DOE welcomes input on the proposed methodology for estimating current and future electricity prices for the fans covered under this rulemaking.

10.4 Maintenance and Repair Costs

DOE will take into consideration any maintenance and repair costs for the equipment covered in this rulemaking. Often, small incremental changes in equipment efficiency would

22 "Energy tariffs" are the rules for calculating energy bills. DOE maintains a database of hundreds of tariffs that can be used to calculate incremental energy bill impacts from energy savings. See: K. Coughlin, R. White, C. Bolduc, D. Fisher, & G. Rosenquist, The Tariff Analysis Proje ct: A database and analysis platform for electricity tariffs, Lawrence Berkeley National Laboratory, Berkeley, CA, LBNL

- 55680 (2006) (available at http://ees.ead.lbl. gov/bibliography/the_tariff_analysis_proje ); and K. Coughlin, C. Bolduc, R. Van Buskirk, G. Rosenquist & J. E. McMahon, Tariff

- based Analysis of Commercial Building Electricity Prices, Lawrence Berkeley National Laboratory: Berkeley, CA, LBNL

- 55551 (2008) (available at: http://escholarship.org/uc/item/9dv1m729.pdf).

23 Available at: http://www.eia.doe.gov/emeu/cbecs/

.54

incur li ttle or no change in repair and maintenance costs over baseline equipment. For equipment with significant energy efficiency improvements over the baseline, there may be increased repair and maintenance costs, because such equipment is more likely to incorp orate technologies that are not widely available.

Item 10

- 3 DOE invites comment on how repair costs may change for more efficient fans. DOE also invites comment on repair practices, how they may change for more efficient fans, and how energy use patterns may impact equipment repair and

maintenance.

10.5 Equipment Lifetime

The expected lifetime of commercial and industrial fans is highly dependent on the application. The operational lifetime of a fan rotating at a constant speed can be determined by the following formula :

Equation 2

Revolutions until fatigue are usually limited by the fan’s bearing. It is reported [ 19 ] that

t he basic bearing lifetime for medium

- sized light duty fans is approximately 40,000 hours,
whereas lifetime for heavy duty fans is approximately 100,000 hours. A fan operating full

- time is estimated to run 4,000 hours per year, translating into a fan lifetime of 10

- 25 years. The RSMeans method uses an average fan lifetime of 15 years [ 20 ]

.

DOE will use information from catalogs and other various literature sources, as wells as input from the interested parties, to establish fan lifetime(s) for use in the LCC and subsequent analyses. DOE intends to develop a distribution of fan li fetimes that reflect equipment operation in different applications.

Item 10

- 4 DOE welcomes information that will assist in determining an appropriate distribution of fan lifetimes for the equipment classes covered in this rulemaking.

10.6 Discount Rates

The calculation o f LCC requires the use of an appropriate discount rate for those commercial or industrial companies that purchase fans. DOE will derive the discount rates for these commercial and industrial users by estimating the capital costs for companies that purchase fans. The cost of capital is commonly used to estimate the present value of cash flows to be derived from a typical company project or investment. Most companies use both debt and equity capital to fund investments, so the cost of capital is the weighted

- average cost of equity and debt financing, which is referred to as the weighted

- average cost of capital.

Item 10

- 5 DOE welcomes input on the proposed approaches for estimating discount rates for fan users.55

10.7 Base Case Efficiency

In the market assessment, DOE attempts to characterize the distribution of equipment efficiencies currently being sold in the marketplace. If market share efficiency data are not available, DOE may develop efficiency distributions based on available models and information
from fan manufacturer s and other interested parties

. In the LCC and PBP analysis, DOE will evaluate whether the current distribution provides a reasonable approximation of the likely commercial and industrial fan market in the compliance year in the absence of DOE standards, o r whether there is reason to expect improvement in efficiency as a result of market forces.

Item 10

- 6 DOE requests data on the efficiency distribution and welcomes comment on the likelihood and degree of improvement in efficiency of commercial and industrial fans in the next 5 to 10 years as a result of market forces or industry trends.

11. SHIPMENTS ANALYSIS

DOE ’s shipment analysis requires shipment projection s by equipment class to calculate the national impacts of standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to develop shipments projection s based on an analysis of key market drivers (i.e., commercial building constructions trends, growth in industries that use fans, etc.) for the
fans covered in this rulemaking.

DOE’s approach considers that shipments of fans are driven by the economic growth of commercial and industrial sectors that use this equipment and, for a fraction of the market, by the production growth of equipment incorporating fans. Hi storical data will be used to establish the relationship between shipments of fans and the appropriate growth index for the sector.

DOE intends to use Gross Domestic Product (GDP) as an indicator of the performance
of industrial and commercial sectors w here fans are used and private fixed investment data for equipment incorporating fans from the U.S. Department of Commerce’s Bureau of Economic Analysis to characterize the production of this equipment.

Item 11

- 1 DOE welcomes comment on the shipments projection met hodology. DOE invites comments regarding the selection of appropriate economic drivers and sources of data for historical shipments and shipment breakdowns by equipment class.

Item 11

- 2 DOE requests historical shipments data for each of the considered equipment
clas ses.

11.1 Standards Impacts on Shipments

DOE plans to derive standards case projection s using the same data used in the development of the base

- case projection s. However, because the standards case projection s take into account the usual increase in purchase pr ice and the usual decrease in operating costs caused56

by standards, project ed shipments typically deviate from the base case. The magnitude of the
difference between the standards case and base

- case shipment projection s depends on the estimated purchase pri ce increase, as well as the operating

- cost savings from the standard. DOE plans to assess whether the purchase price or the operating cost will have a greater impact on equipment purchase decisions; therefore, standards case projection s may show a change in shipments relative to the base case.

DOE typically projects shipments for a 30

- year period beginning in the expected compliance date of any standards.

Item 11

- 3 DOE welcomes comment on how an energy conservation standard for fans might impact shipments of the e quipment covered in this rulemaking.

12. NATIONAL IMPACT ANAL YSIS

The National Impact Analysis (NIA) assesses the aggregate impacts of potential efficiency standards at the national level. Impacts that DOE will report include the national energy savings (NES) from potential fan standards ( i.e. , the cumulative incremental energy savings from fans efficiency standards) and the net present value (NPV) of the total user benefits.

A key component of DOE’s estimates of NES and NPV are the equipment energy
efficienc ies project ed over time, for the base case (without new standards) and for each of the
standards case s

. To develop the various standards cases, DOE plans to develop market

- share efficiency data ( i.e. , data on the distribution of equipment shipments by efficiency) for the fan equipment classes DOE is considering. To estimate the impact that standards may have in the year compliance becomes required; DOE has used "roll

- up" and/or "shift" scenarios in it s standards rulemakings. Under the "roll

- up" scenario, DOE assumes (1) equipment 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) equipment shipments at efficienci es 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. . After DOE establishes the average efficiency for the assumed effective date of a standard, it can estimate future efficiency by using the same rate of project ed efficiency growth as for the base

- case efficiency trend.

Item 12

- 1 DOE requests comment on whether it s hould pursue a roll

- up or shift approach for the national impact analysis.

12.2 National Energy Savings

DOE intends to calculate national fan energy consumption for each year beginning with the expected compliance date of any standards. It will calculate natio nal fan energy consumption for the base cases and each standard level analyzed, and the energy savings will be calculated as the difference in energy consumption between the base case and the standards cases. DOE plans57

to perform this calculation through t he use of a spreadsheet model that effectively accounts for the stock of equipment affected by standards. 24 The energy savings are measured over the entire lifetime of products purchased in the 30

- year projection period. 25

DOE has historically presented NES in terms of primary energy savings. On August 18, 2011, DOE announced 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 51282) 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 the National Energy Modeling System ( NEMS ) . After evaluating both models and the approaches discussed in the August 18, 2011 notice, DOE has determined NEMS is a more appropriate tool f or this analysis

. 77 FR 49701 (August 17, 2012). Therefore, DOE intends to use NEMS to conduct FFC analyses.

12.3 Net Present Value of User Benefits

To develop the national NPV of user benefits from potential standards, DOE must calculate annual energy expenditures and annual equipment expenditures for the base case and
the standards cases. DOE calculates annual energy expenditures based on annual energy consumption by incorporating project ed energy prices, using the projection s of shipments and

average energy efficiency described in section 11

. DOE calculates annual equipment expenditures by multiplying the price per unit by the number of projecte d shipments. The difference each year between energy bill savings and increased equipment expenditures is the net savings (if positive) or net costs (if negative). DOE discounts those annual values to the present
time and sums them to obtain a NPV. Accordi ng to U.S. Office of Management and Budget (OMB) guidelines, DOE will calculate NPV using real discount rates of three percent and seven percent (OMB, Circular A

- 4: Regulatory Analysis (2003).

13. CUSTOMER SUBGROUP AN ALYSIS

The LCC analysis described in section 10 analyzes the impacts of energy conservation
standards on all consumers of commercial and industrial fans. F or the subgroup analysis, DOE divides consumers into subgroups, which comprise a subset of the population that is likely, for one reason or another, to be affected disproportionately by new or revised energy conservation standards ( e.g. , small businesses o r firms that use fans in particular applications where energy savings are likely to be small 26 ) . The purpose of a subgroup analysis is to determine the extent of

24 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/

.

25 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 wi th the approach used for its national economic analysis.

26 These firms differ from any fan manufacturers who may qualify as a small business under the size standards established by the Small Business Administration. DOE analyzes impacts to these small bus inesses,58

this disproportional impact. DOE will work with interested parties to identify any subgroups fo r this consideration and will conduct a subgroup analysis for any NOPR developed for this rulemaking.

Item 13

- 1 DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fans.

14. MANUFACTURER IMPACT ANALYSIS

T he MIA provide s an assessment of the potential impacts of energy conservation
standards on manufacturers of fans . A wide range of quantitative and qualitative effects may occur following the adoption of a standard that may require changes to manufacturing practices.
DOE will identify these potential effects through interviews with manufacturers and other interested parties.

For any NOPR, DOE will conduct an industry

- wide cash

- flow analysis using the Government Regulatory Impact Model (GRIM), identify and analyze subgroup s of manufacturers whose businesses vary significantly from the industry as a whole, perform a competitive impacts assessment, and review the cumulative regulatory burden for the industry. This analysis will include an examination of direct employment impa cts.

14.1 Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described earlier provide information that DOE will use as inputs for the MIA. Such information includes financial parameters developed in the market assessment ( s ection 5 ), cost data developed in the engineering analysis ( s ection 7 ), and shipments projection s ( s ection 11 ). DOE will supplement this information with information gathered during
manufacture r interviews, as discussed below.

During any preliminary analysis phase, DOE will conduct interviews with manufacturers to gain insight into the range of possible impacts from potential energy conservation standards. These interviews will coincide with pr eliminary technical interviews for the engineering analysis.

During any NOPR phase, DOE will conduct more detailed MIA interviews with manufacturers. The interview process plays a key role in the MIA, because it provides an opportunity for directly affect ed parties to express their views on important issues. During the interviews, DOE will solicit information on the possible impacts of potential standards on manufacturing costs, product prices, sales, direct employment (meaning employment for the
manufactu rer only), capital assets, and industry competitiveness. Both qualitative and quantitative information are valuable in this analysis. DOE prefers an interactive interview

which would be directly impacted by any final standards DOE might establish, as required by the Regulatory Flexibility Act (see section 14.3 ).59

process because it helps to clarify manufacturer input and provides the opportunity t o identify
additional issues.

DOE ask s interview participants to identify confidential information and protect s the confidentiality of the information provided as explained in section 7.4 . DOE also ask s participants to identify any information they wish to have included in the public record, but do not want to have associated with their interview (thereby identifying that part icular manufacturer). DOE incorporate s this information into the public record without attribution.

DOE collate s the interview results and prepare a summary of the major issues and outcomes. This summary become s part of the technical support document for this rulemaking.

14.2 Industry Cash Flow Analysis

The industry cash

- flow analysis will rely primarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of new or amended energy conservation standards on the industry that produces the products cove red by the standard.

The GRIM uses a number of factors

— annual expected revenues; manufacturer costs such as costs of goods sold; selling, general, and administrative (SG&A) costs; research and development costs; product conversion costs; taxes; capital ex penditures (both ordinary capital expenditures and those related to standards); and working capital requirements

— to determine annual cash flows associated with a new standard, beginning with the announcement of the standard and continuing for several years after its implementation. DOE compares the results against base

- case projections that involve no new standards. The financial impact of new standards is the difference between the two sets of discounted annual cash flows, or the
differences between the ba se

- case and standards

- case industry net present values (INPV). Other performance metrics, such as return on invested capital, are also available from the GRIM.

DOE gather s the inputs needed for the GRIM from two primary sources: (1) the analyses conducted to this point; and (2) interviews with manufacturers and other interested parties. As discussed above, information gathered from previous analyses will include financial p arameters, manufacturing costs, price projection s, and shipment projection s. Interviews with manufacturers and other interested parties will supplement this information.

14.3 Manufacturer Subgroup Analysis

Average industry cost values may not reveal differentia l impacts among fan manufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a cost structure that differs significantly from the industry average may be affected differently by standards. Ideally, DOE would consider the i mpact 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 appropria te. For commercial and industrial fans, DOE is interested in feedback about potential subgroups, including small businesses. DOE conduct s a Regulatory Flexibility Act analysis to determine the impacts of any standards on small businesses consistent with th e Regulatory60

Flexibility Act. The detailed manufacturer subgroup impact analysis will calculate cash flows separately for each class of manufacturer.

Item 14

- 1 DOE seeks comments on the subgroups of the fan equipment manufacturers that it should consider in a manuf acturer subgroup analysis.

14.4 Competitive Impacts Assessment

EPCA directs DOE to consider any lessening of competition likely to result from the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General
to determine in w riting the impacts, if any, of any lessening of competition likely to result from standards. (42 U.S.C. 6295(o)(2)(B)(ii))

DOE gather s firm

- specific financial information and impacts and report the aggregated impact of the amended standard on manufacturer s. The competitive impacts analysis will focus on assessing the impacts on smaller manufacturers. DOE base s the assessment on manufacturing
cost data and information collected from interviews with manufacturers. The manufacturer interviews focus on gatheri ng information that would 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 provide s the Attorney General with a copy of any NOPR for consideration in his evaluation of the impact of standards on the lessening of competition. DOE publish the Attorney General’s letter and address any related comments in any final rule.

14.5 Cumulative Regulatory Burden

Other regulations (Federal, State, local, or international) may apply to manufacturers of fans covered under this rulemaking and to other equipment made by these manufacturers. Multiple regulations may result in a significant, cumulative regulatory burden on these
manufacturers. DOE consider s the impact on these manufacturers of multiple, product

- specific regulatory actions.

Item 14

- 2 DOE welcomes comments on other existing regulations or pending regulations
it should consider in examining cumulative regulat ory burden.

15. UTILITY IMPACT ANALY SIS

In the utility im

pact 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
EIA’s NEMS 27

, which 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 projection for the United

27 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(2003), (March 2003).61

States, the Annual Energy Outlook (AEO) . DOE uses a variant of this model, referred to as NEMS

- BT, 28 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 commercial and industrial fans, DOE will
use the version of NEMS used for the most recent AEO.

Item 15

- 1 DOE welcomes input from interested parties on its proposed approach to
conduct the utility impact analysis.

16. EMPLOYMENT IMPACT AN ALYSIS

The e mployment impacts analysis examines indirect employment impacts from standards, which 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

- cons umers on energy; (2) reduced spending on new energy supply by the utility industry; (3) increased spending on new equipment to which the new standards apply; and (4) the effects of those three factors throughout the economy. D irect employment impacts are a ny changes in the number of employees of manufacturers of the equipment subject to standards , their suppliers, and related
service firms. ( The MIA will address the direct employment impacts, i.e., the impacts on the number of employees working for the manu facturers.)

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 publis hes its estimates of the number of jobs per million dollars of economic activity in different sectors of the economy, as well as the jobs created elsewhere in the economy by this same economic activity. Data from BLS indicate that expenditures in the utili ty sector generally create fewer jobs (both directly and indirectly) than expenditures in other sectors of the economy. 29 There are many reasons for these differences, including wage differences and the fact that the utility sector is more capital

intensive and less labor

- intensive than other sectors. Energy conservation standards have the

e ffect of reducing user utility bills. Because reduced user expenditures for energy likely lead to increased expenditures in other sectors of the economy, the general effe ct 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 any NOPR developed for this rulemaking , DOE plans to estimate indirect national employment impacts using an input/output model of the U.S. economy called Impact of Sector

28 DOE/EIA approves use of the name NE MS 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 NEMS

BT. (BT is DOE’s Building Technologies Program, under whose aegis this work has been performed.)

29 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input

Output Modeling System (RIMS II)

. Washington, DC. U.S. Department of Commerce, 1992.62

Energy Technologies version 3.1.1 (ImSET). 30 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 late r 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 employ ment impacts.

Item 16

- 1 DOE welcomes comments on its proposed approach to assessing national employment impacts.

17. EMISSIONS ANALYSIS

In the emissions analysis, conducted in the NOPR phase, DOE will estimate the reduction in power sector emissions of carbon dioxide (CO 2 ), nitrogen oxides (NO X ), sulfur dioxide (SO 2 ), and mercury (Hg) from potential energy conservation standards for fans and blowers. In addition, DOE will estimate emissions impacts in production activities (extracting, processing, and transporting fue ls) that provide the energy inputs to power plants. These are referred to as “upstream” emissions. Together, these emissions account for the FFC. In accordance with DOE’s FFC Statement of Policy (76 FR 51281 (Aug. 18, 2011)), the FFC analysis also inclu des impacts on emissions of methane (CH 4 )and nitrous oxide (NO 2 ), both of which are recognized as greenhouse gases.

DOE will conduct the emissions analysis using emissions factors derived from data in
EIA’s most recent Annual Energy Outlook ( AEO ), suppl emented by data from other sources. DOE developed separate emissions factors for power sector emissions and upstream emissions.
The method that DOE used to derive emissions factors will be described in the NOPR TSD.

EIA prepares the AEO using NEMS. Eac h annual version of NEMS incorporates the projected impacts of existing air quality regulations on emissions.

SO 2 emissions from affected electric generating units (EGUs) are subject to nationwide and regional emissions cap

- and

- trade programs. Title IV o f the Clean Air Act sets an annual emissions cap on SO 2 for affected EGUs in the 48 contiguous States and the District of Columbia (D.C.). SO 2 emissions from 28 eastern States and D.C. were also limited under the Clean Air Interstate Rule (CAIR, 70 FR 2516 2 (May 12, 2005)), which created an allowance

- based 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

30 J. M. Roop, M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies

, PNNL

1 8412, Pacific Northwest National Laboratory

, 200 9 . Available at: www.pnl.gov/main/publications/external/technical_reports/PNNL

- 18412.pdf63

Columbia Circuit , but it remained in effect. See North Carolina v. EPA , 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA , 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2011, EPA issued a replacement for CAIR, the Cross

- State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8,
20 11). The AEO 2012 emissions factors assume the implementation of the CSAPR. 31

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 SO 2 emissions allowances resulting from the lower electricity demand caused by the adoption of an efficiency standard could be used to permit offsetting increases in SO 2 emissions by any regulated EGU. In past rulemakings, DOE recognized that t here was uncertainty about the effects of efficiency standards on SO 2 emissions covered by the existing cap

- and

- trade system, but it concluded that negligible reductions in power sector SO 2 emissions would occur as
a result of standards.

Beginning in 2015 , however, SO 2 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). In the final MATS rule, EPA established a standard for hydrochlori c acid (HCl) as a surrogate for acid gas hazardous air pollutants (HAP), and also
established a standard for SO 2 (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 ac id gas; thus, SO 2 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 SO 2 emissions. Under the MATS, NEMS shows a reduction in SO 2 emissions when electricity demand decrease s ( 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 SO 2 emissions allowances resulting from the lower electricity demand would be needed or used to perm it offsetting increases in SO 2 emissions by any regulated EGU. Therefore, DOE believes that efficiency standards will reduce SO 2 emissions in 2015 and beyond.

CSAPR established a cap on NO X emissions in the 28 eastern States and the District of Colombia. Energy conservation standards are expected to have little or no effect on NO X emissions in those States covered by CSAPR because excess NO
x emissions allowances resulting
from the lower ele ctricity demand could be used to permit offsetting increases in NO
x emissions. However, standards would be expected to reduce NO
x emissions in the States not affected by CSAPR, so DOE estimates NO X emissions reductions from potential standards for these St ates.

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.

31 On December 30, 2011, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and
told EPA to continu e 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 o n emissions impacts of energy efficiency standards.64

Power plants may emit particulates from the smoke stack, which are known as dir ect 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. T he 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 SO 2 and NO
x . The monetary benefits that DOE estimates for
reductions in SO 2 and NO
x emissions resulting from standards are in fact primarily related to the
health benefits of reduced ambient PM.

Item 17

- 1 DOE welcomes comments on its proposed approach to analyzing emissions impacts on potential standards for commercial and industrial fans.

18. MONETIZING CARBON DI OXIDE AND OTHER EMIS SIONS REDUCTIONS

DOE plans to consider the estimated monetary benefits likely to result from the reduced
emissions of CO 2 and NO X that are expected to result from each of the standard levels
considered.

To estimate the monetary value of benefits resulting from reduced emissions of CO 2 , DOE plans to use the most current social cost of carbon (SCC) values developed and/or agreed to by an int eragency 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. Nevertheless, with full regard for the limits of both quantification an d 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 CO 2 emissions in 201 0, expressed in 2010$, were $4.9, $22.3, $36.5, and $67.6 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 pe rcent 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 CO 2 emissions. To calculate a present value of the stream of monetary values, D OE will discount the values in each of the four cases using the discount rates 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 CO 2 and other GHG emissi ons to changes in the future global climate and the potential resulting damages to the world economy. Thus, these values are subject to change.65

DOE also intends to estimate the potential monetary benefit of reduced NO X emissions resulting from the standa rd levels it considers. For NO
x emissions, available estimates suggest a very wide range of monetary values for NO
x emissions, ranging from $450 to $4,623 per ton in 2010$. 32 In accordance with U.S. Office of Management and Budget (OMB) guidance, DOE will

c onduct two calculations of the monetary benefits derived using each of the economic values
used for NO
x , using real discount rates of 3 percent and 7 percent. 33

19. REGULATORY IMPACT AN ALYSIS

In the NOPR stage of this rulemaking, DOE will prepare a regulatory i mpact analysis that will address the potential for non

- regulatory approaches to supplant or augment energy conservation standards to improve the efficiency of fans on the market. DOE recognizes that voluntary or other non

- regulatory efforts by manufacturer s, utilities, and other interested parties can result in substantial efficiency improvements. DOE intends to analyze the likely effects of

non

- regulatory initiatives and compare those effects with those projected to result from 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.

If DOE proposes energy conservation standards for fans 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 (October 4 , 1993).

32 F or additional information , refer to U.S. Office of Management and Budget , Office of Information and Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal Entities , Washington, DC

.

33 OMB, Circular A

- 4: Regulatory Analysis ( Sept. 17, 2003).66

APPENDIX A

– LIST OF ITEMS FOR CO MMENT

Item 1

- 1 DOE seeks comment on whether a labeling rule would be technologically or economically feasible, result in a significant conservation of energy, or assist consumers in making purchasing decisions.

................................ ................................ ............................. 6
Item 1

- 2 DOE seeks comment on information that it should consider requiring for display on any prospective label, as well as factors DOE should consider regarding the size, format, and placement of any such label.

................................ ................................ ........................ 6
Item 2

- 1 DOE requests data on how fans are sold. Specifically DOE requests data on market share of fans 1) sold by themselves, 2) sold attached to or integrated with motors only, 3) sold attached to or integrated with both motors and VS Ds, 4) sold physically separate from but priced together with a motor only, or 5) sold physically separate from but priced together with both a motor and VSD. DOE would appreciate these data by size, equipment category (see section 5.2.1), and application.

................................ ................................ ...... 7
Item 2

- 2 DOE requests comment on the suggested definition for cross flow fan, specifically regarding whether this fan is a type of centrifugal fan.

................................ ........................ 8
Item 2

- 3 DOE requests comment on the suggested definition for blowers.

............................... 9
Item 2

- 4 DOE requests comment on the suggested definitions for safety fans. Specifically, are other safety features not included in the above definition that should be included.

.............. 9
Item 2

- 5 DOE requests comment on the suggested definitions for fans and other terms listed in
section 2.1.1.

................................ ................................ ................................ .................... 10
Item 2

- 6 DOE requests comment and information on the following trends: 1) increasing shipments of fan

- motor

- transmission packa ges and 2) increasing shipments of direct

- driven fans in the U.S. market. Are there any other trends in the commercial and industrial fans market that might influence the scope of this rulemaking that DOE should be aware of and
are not listed here?

................................ ................................ ................................ ............ 10
Item 2

- 7 DOE requests comment on the consideration of standards for axial fans, centrifugal fans, mixed flow fans, safety fans, and bl owers as defined in section 2.1.1.

...................... 10
Item 2

- 8 DOE is aware of another type of fan, the contra

- rotating fan, popular in the Europe an Union, and requests information on this fan type; specifically, are they sold in the U.S. market and should be considered in the scope of coverage for the rulemaking?

................. 10
Item 2

- 9 DOE requests comment on whether establishing standards for fans defined inclusive of the motor transmission, and controls could increase the beneficial use of VSDs in the
field and whether interested parties believe the benefits of such a standard would outweigh any negatives, such as the potential use of VSDs in applications for which it is not suited.DOE seeks comment on the market share of fans (by type) that would be used in applications that would benefit from VSDs, as well as those where use of a VSD could result in increased energy use. In particular, whether there are specific fan types that are almost always used, or alternatively, very rarely used, in applications that would benefit
from a VSD

. ................................ ................................ ................................ ..................... 12
Item 2

- 10 DOE requests data and information on whether fans are more often combined with motors, VSDs, or both by the fan ma nufacturer or by distributors/contractors.

.................. 12
Item 2

- 11 DOE requests information on how often and in what circumstances the intend ed application is known when the fan is sold.

................................ ................................ ........ 1267

Item 2

- 12 DOE requests comment on whether standards should be considered only for fans with an impeller diameter less than 98 or equal to inches and whether that impeller diameter distinction is appropriate for all fans equipment classes being considered in this rulemaking.

................................ ................................ ................................ ...................... 12
Item 2

- 13 DOE requests comment on whether to similarly consider a minimum fan diameter in this rulemaking.

................................ ................................ ................................ ............ 13
Item 2

- 14 DOE requests comment on considering standards for fans with power requirements between 125 W and 500 kW for this rulemaking.

................................ ............................. 13
Item 2

- 15 DOE requests comment on these exclusions, specifically regarding whether they should be applied to this rulemaking. Why or why not? Are there any other fan
characteristics that DOE should consider as criteria for exclusion?

................................ ... 13
Item 2

- 16 DOE requests comment on the percentage of fan motors estimated to be covered by the small and medium electric motor standards. Specifically, does the industrial plant motor study performed by WSU represent the commercial and industrial fan industry as a whole? Why or why not?

................................ ................................ ................................ .............. 14
Item 2

- 17 DOE seeks comment on the market share (by fan type) and applications of fans that are driven by equipment other than electric motors.

................................ .......................... 14
Item 2

- 18 DOE requests comment on the transmission types to be considered in this rulemaking.

................................ ................................ ................................ ...................... 14
Item 2

- 19 DOE requests comment on the types of VSDs sold with fans and whether there is efficiency variability (and if so, to what extent) among VSDs.

................................ .......... 15
Item 3

- 1 DOE requests comment on the use of the AMCA 210

- 07 test procedure as a base for the development of a DOE test procedure.

................................ ................................ ........ 16
Item 3

- 2 DOE requests comment on for what other applications cross flow fans are used and
the breakdown of cross flow fan use across the fans market in th ose applications.

............ 17
Item 3

- 3 DOE requests comment on the applicability of AMCA Standard 210

- 07 in
coordination with AMCA Standar d 220

- 05 for measuring performance of cross flow fans.
17
Item 3

- 4 DOE requests comment on whether air curtains must be tested for performance in use with a motor, or whether fan performance as recorded through AMCA 210 test methods would provide accurate performance estimates.

................................ ................................ 17
Item 3

- 5 DOE requests performance data for cross flow fans.

................................ ................ 17
Item 3

- 6 DOE requests comment on the ability of using a clean air only test procedure to determine the efficiency of fans designed for dust air or material handling applications that could be compared to fans not designed for handling such materials that are in the same equipment classes (se e section 5.2 for equipment class discussion).

................................ .. 17
Item 3

- 7 DOE requests comment on which test configuration should be considered for each of the considered equipment classes.

................................ ................................ ..................... 18
Item 3

- 8 DOE requests comment on requiring an air straightener at the outlet for axial fans tested in configuration B or D.

................................ ................................ .......................... 18
Item 3

- 9 DOE requests comment on the use of publicly available performance data in lieu of original test data.

................................ ................................ ................................ .............. 19
Item 3

- 10 DOE requests fan performance data generated from AMCA 210 tests.

................. 19
Item 3

- 11 DOE requests comment on the considered efficiency metric approaches.

............. 2068

Item 3

- 12 DOE requests data and/or sources of information for developing the representative load profiles for each fan equipment class (see section 5.2.1 for equipment class discussion).

................................ ................................ ................................ ....................... 21
Item 3

- 13 DOE specifically requests comment on the part

- load airflow test points that would

repres ent a typical variable load for a fan as well as how many part

- load test points it
should consider.

................................ ................................ ................................ ................ 21
Item 3

- 14 DOE is interested in what test points, in addition to conditions at peak total efficiency, are appropriate for a variable load metric and how many test points should be included to address the complete operating range of fans with or without VSDs.

.............. 21
Item 3

- 15 DOE requests comment on an appropriate efficiency calculation to capture the energy efficiency impacts of VSDs. Specifically, DOE re quests comment on the use of an input power based efficiency versus an overall peak efficiency when comparing
efficiencies.

................................ ................................ ................................ ...................... 22
It em 3

- 16 DOE requests comment on the FMEG efficiency metric.

................................ ..... 22
Item 3

- 17 DOE requests comment on the use overall efficiency for f ans sold with both motors
and VSDs.

................................ ................................ ................................ ........................ 23
Item 3

- 18 DOE requests comment on the use input power based efficiency for fans sold with motors where VSDs are a design option to improve efficiency.

................................ ........ 23
Item 3

- 19 DOE requests comment on the metrics discussed above, inc luding whether a weighted average metric should be developed under the third metric option.

.................... 24
Item 3

- 20 DOE recognizes that the same fan may in some cases be sold bare shaft or in conjunction with a motor or motor/control package. DOE seeks comment on any issues that may result from having different metrics for fans sold alone and fans sold with motors or
VSDs. 24
Item 5

- 1 DOE requests information that would contribute to the market assessment for fans that would be covered in this rulemaking, especially for those equipment classes designated in section 5.2. Examples of information sought include current equipment features and efficiencies, equipment feature and efficiency trends, and historical equipment shipments and prices.

................................ ................................ ................................ ........................ 28
Item 5

- 2 DOE requests comment on the estimates of the number of U.S. fan manufacturers and the number of small businesses in the industry.

................................ ................................ . 29
Item 5

- 3 DOE welcomes comments on whether there are other design characteristics that should be considered when establishing equipment classes.

................................ .............. 29
Item 5

- 4 DOE requests comment on whether the development of separate equipment classes, and thus separate efficiency standards, is necessary to accommodate different performance characteristics of fans sold bare shaft versus fans sold with the motor, transmission, and/or
controls.

................................ ................................ ................................ ........................... 30
Item 5

- 5 DOE requests comment on splitting axial fan types into housed and unhoused equipment classes or whether a single equipment class would sufficiently represent axial fan applications.

................................ ................................ ................................ ............... 31
Item 5

- 6 DOE requests comment on what types of axial fan designs or characteristics are unique to axial

- type safety fans.

................................ ................................ ........................ 31
Item 5

- 7 DOE requests comment on whether there are any other commercial or industrial applications (beyond clean air, dust air and material handling) that should be considered while defining equipment classes for centrifugal fans.

................................ ...................... 3169

Item 5

- 8 DOE requests comment on the considered groupings of housed centrifugal fans. Specifically, DOE requests comment on the use of air quality (Clean Air, Dust Air, Material Handling) and geometrical design descriptors for classification purposes.

.......... 32
Item 5

- 9 DOE requests comment on whether the Dust Air, Material Handling, and Cross Flow fan equipment classes should be split into housed and unhoused categories.

..................... 32
Item 5

- 10 DOE requests comment on setting cross flow fans as a separate equipment class within the centrifugal fans category.

................................ ................................ ................. 32
Item 5

- 11 DOE requests information about the specific design characteristics of cross flow
fans. 33
Item 5

- 12 DOE requests comment on what types of centrifugal fan designs or characteristics are unique to centrifugal

- type safety fans.

................................ ................................ ......... 33
Item 5

- 13 DOE requests comment on setting a separate equipment class for blowers.

.......... 33
Item 5

- 14 DOE requests comment on whether there is a need of more than one blower equipment class to account for the differences between centrifugal and axial blowers.

...... 33
Item 5

- 15 DOE requests comment on setting a separate equipment class for mixed flow fans.

33
Item 5

- 16 DOE requests comment on whether there are differences among mixed flow fans that might warrant more than one equipment class for this fan type

. ................................ . 33
Item 5

- 17 DOE requests comment and/or information on the effect of different materials on efficiency.

................................ ................................ ................................ ........................ 34
Item 5

- 18 DOE requests comment on whether there are other fan blade materials that should
be included in the list above.

................................ ................................ ............................. 35
Item 5

- 19 DOE requests comment on whether there are compatibility issues with certain fans and VSDs DOE should be aware of when considering a VSD as a means to improve fan efficiency.

................................ ................................ ................................ ........................ 35
Item 5

- 20 DOE welcomes comments on the preliminary technology options identified in this
secti on 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 user utility.

................................ ................................ ................................ ....................... 36
Item 6

- 1 Are there any technologies, including those listed in section 5.3, that DOE should not consider because of any of the four screening criteria? If so, which screening criteria apply
to the cited technology or technologies?

................................ ................................ ........... 37
Item 7

- 1 Once DOE establishes any representative equipment classes and representative units, it selects a baseline model as a reference point for each representative unit from which to measure changes resulting from the design options. DOE develops separate engineering analyses for each baseline model analyzed. DOE intends to use fan teardowns an d fan efficiency (determined from fan performance tests) to develop cost

- efficiency relationships for the fans analyzed. DOE intends to develop the necessary test procedures through a test procedure rulemaking, as discussed in section 3.DOE welcomes inputs from interested parties on a methodology that would be appropriate for determining the max

- tech models for each fan analyzed.

................................ ................................ ................................ ....... 38
Item 7

- 2 DOE seeks input on the methods and approaches used by manufacturers to improve the efficiency of fans.

................................ ................................ ................................ ....... 38
Item 7

- 3 DOE w elcomes comment from interested parties on the best methodology for scaling the representative units to other fan sized within the equipment class.

............................... 3870

Item 7

- 4 DOE seeks fan test data to improve DOE’s understanding of fan performance to select appropriate representative units for the respective equipment classes.

..................... 38
Item 7

- 5 For each equipment class, DOE welcomes comment on methods and approaches that DOE intends to employ to determine potential fan efficiency improvements. Detailed
information on fan performance and the incremental manufacturing costs (e.g., material costs, labor costs, overhead costs, building conversion capital expenditures, tooling/equipment conversion capital expenditures associated with more efficient designs, research and develop ment (R&D) expenses, and marketing expenses) would be useful.

... 41
Item 7

- 6 DOE welcomes comment on the markup approach proposed fo r developing estimates of manufacturer selling prices.

................................ ................................ .......................... 41
Item 7

- 7 DOE welcomes comment on the proposed approach to determine the relationship between manufacturer selling prices and fan efficiency.

................................ ................... 41
Item 7

- 8 DOE welcomes comment on the conversion costs required to improve the efficiency of the fans to various levels, as well as what portion of these costs would be passed on to
the consumer.

................................ ................................ ................................ ................... 41
Item 7

- 9 DOE requests comment on limiting representative unit selection to fan size(s) that
include the most available units.

................................ ................................ ....................... 42
Item 7

- 10 DOE requests comment on the selection of additional fans at both larger and
smaller sizes to determine a fan size

- efficiency scaling relationship. DOE requests comment on the number of additional fans to test to develop the size

- eff iciency scaling relationship.

................................ ................................ ................................ ...................... 42
Item 7

- 11 DOE requests comment on the method of using fan unit efficiencies as the basis for
det ermining efficiency levels.

................................ ................................ ........................... 42
Item 7

- 12 DOE seeks comment on the selection, appropriate features, and performance characteristics of baseline models for each equipment class. Specifically, DOE requests comment on choosing the least efficient fan design as the baseline model for the equipment class. DOE will define the characteristics of the proposed baseline models ba sed on comments from interested parties in addition to DOE's analysis.

................................ ....... 43
Item 7

- 13 DOE welcomes comment on whether there are prop rietary designs it should consider for any of the fan designs under consideration in this rulemaking and, if so, how DOE should acquire the cost data necessary for evaluating these designs.

......................... 43
Item 7

- 14 DOE seeks input from interested parties regarding the range of efficiency levels that should be examined as part of its analysis.

................................ ................................ . 44
Item 7

- 15 DOE requests comment on whether manufacturers generally do not offer fans of varying efficiencies that meet the same duty requirement.

................................ ................ 44
Item 7

- 16 DOE welcomes comment on whether there are outside regulatory changes that DOE should consider in its engineering analysis of fans.

................................ .................. 44
Item 8

- 1 DOE requests information regarding the functioning of the manufacturer representatives/distributors for different equipment classes and market segments.

............ 46
Item 8

- 2 DOE requests information on other OEM market segments, and the downstream distributor channel, if any.

................................ ................................ ................................ 46
Item 8

- 3 DOE requests comments on the applications and market segments identified by interested parties and information on other market segments, including their corresponding distributor channel(s) and the trade association(s) representing the distributors.

................ 47
Item 8

- 4 DOE requests information on the proposed distribution channels and the share of industry shipments expected for each distribution channel for the commercial and industrial71

fans covered under this rulemaking in terms of either each specific equipment clas in 5.2 or the broader equipment categories described above.

................................ ........................... 47
Item 8

- 5 DOE seeks comment o n other sources of relevant data that could be used to characterize markups for commercial and industrial fans.

................................ ................. 48
Item 8

- 6 DOE requests feedback on its proposal to use incremental distribution channel markups for the LCC analysis.

................................ ................................ .......................... 48
Item 8

- 7 DOE seeks com ment on appropriate transportation and shipping costs to include in the analysis and whether those costs are likely to vary for higher

- efficiency equipment.

... 48
Item 9

- 1 DOE requests input and recommendations for identifying high sales volume and large installed base market segments corresponding to specific industries and specific applications for which the fan equipment may have sim ilar load profiles.

......................... 49
Item 9

- 2 DOE welcomes recommendations on sources of data or analysis methods that would provide end

- use lo ad profiles for each of the commercial and industrial fans in the different market segments.

................................ ................................ ................................ .............. 50
Item 9

- 3 DOE requests input on ways to characterize fan sizing and selection practices for different equipment classes and applications and to help define the design or peak fan load for the purpose of generating normalized load profiles. For example, one question is whether load profi les should reflect normalization to the delivered air horsepower at the peak efficiency of the fan (at a given fan size and speed).

................................ ................. 50
Item 9

- 4 DOE welcomes comment on methods for determining generic (non

- market segment specific) load profiles for fan equipment classes considered in this rulemaking.

................ 50
Item 9

- 5 DOE welcomes comment on the current penetration level of variable

- speed drives in the installed base of products or applications for each of the equipment classes considered in this rulemaking.

................................ ................................ ................................ ............ 50
Item 9

- 6 DOE requests comment and recommendations on the number of analyzed sizes to be selected for each equipment class.

................................ ................................ .................... 51
Item 9

- 7 DOE requests comment and recommendations on the range of and number of fan rotation speeds over which the analysis sh ould be carried out for different equipment
classes.

................................ ................................ ................................ ............................. 51
Item 9

- 8 DOE requests information on current industry practices and recomm endations on the selection of representative operating points for a given rotational speed. DOE welcomes comment on whether the analysis should be extended to a range of operating points away from the peak efficiency.

................................ ................................ ................................ .. 51
Item 9

- 9 DOE requests comment and estimates to establish the mean value and the ranges of likely values for motor, transmission, and motor control efficiencies.

............................... 51
Item 10

- 1 DOE welcomes comment on the factors that impact the installation costs for fans
and on whether installation cost increases with higher

- efficiency equipment.

................... 53
Item 10

- 2 DOE welcomes input on the proposed methodology for estimating current an d future electricity prices for the fans covered under this rulemaking.

................................ .. 53
Item 10

- 3 DOE invites comment on how repair costs may change for more efficient fans. DOE also invites comment on repair practices, how they may change for more efficient fans, and how energy use patterns may impact equipment repair and maintenance.

........... 54
Item 10

- 4 DOE welcomes information that will assist in determining an appropriate distribution of fan lifetimes for the equipment classes covered in this rulemaking.

............ 54
Item 10

- 5 DOE welcomes input on the proposed approaches for estimating discount rates for
fan users.

................................ ................................ ................................ .......................... 5472

Item 10

- 6 DOE requests data on the efficiency distribution and welcomes comment on the likelihood and degree of improvement in efficiency of commercial and industrial fans in the next 5 to 10 years as a result of market forces or industry trends.

................................ 55
Item 11

- 1 DOE welcomes comment o n the shipments projection methodology. DOE invites comments regarding the selection of appropriate economic drivers and sources of data for historical shipments and shipment breakdowns by equipment class.

................................ . 55
Item 11

- 2 DOE requests historical shipments data for each of the considered equipment
classes. 55
Item 11

- 3 DOE welcomes comment on how an energy conservation standard for fans might impact shipments of the equipment covered in this rulemaking.

................................ ........ 56
Item 12

- 1 DOE requests comment on whether it should pursue a roll

- up or shift approach for the national impact analysis.

................................ ................................ ............................. 56
Item 13

- 1 DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fans.

................................ ................................ .......................... 58
Item 14

- 1 DOE seeks comments on the subgroups of the fan equipment manufacturers that it should consider in a manufacturer subgroup analysis.

................................ ....................... 60
Item 14

- 2 DOE welcomes comments on other existing regulations or pending regulations it should consider in examining cumulative regulato ry burden.

................................ ............ 60
Item 15

- 1 DOE welcomes input from interested parties on its proposed approach to conduct the utility impact analysis

. ................................ ................................ ................................ 61
Item 16

- 1 DOE welcomes comments on its proposed approach to assessing national employment impacts.

................................ ................................ ................................ ........ 62
Item 17

- 1 DOE welcomes comments on its proposed approach to analyzing emissions impacts on potential standards for commercial and industrial fans.

................................ ... 6473

REFERENCES

1. Implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to Ecodesign Requirements for Fans Driven by Motors with an Electric Input Power between 125 W and 500 kW (text with EEA relevance) , 2011, Official Journal of th e European Union. p. 21.
2. Cincinnati Fan and Ventilator Company, I. Centrifugal Blowers & Fans . March 20, 2012]; Available from: http://www.cincinnatifan.com/centrifugal

- fans

- blowers.htm

. 3. Verma, V.S. Energy Efficiency in Electrical Utilities: Fans and Blowers . 2005; Available
from: http://www.emt

- india.com/BEE

- Exam/GuideBooks_QB.htm

. 4. Duggan, M., New Fan Standard for Energy Efficiency , in Development and

Initiatives 2009, ISO Focus. p. 2.
5. Ventilation Equipment: A United States Market Overview , 2011, Industry Experts. p. 126.

6. Radgen, P. and J. Oberschmidt, EuP Lot 11: Fans for Ventialtion in Non Residential Buildings , 2008. p. 202.

7. Jorgensen, R., Fan Engineering; An Engineer's Handbook on Fans and Their Applications . 9th ed, ed. R. Jorgensen1999, Buffalo, NY: Howden Buffalo, Inc.
8. AMCA, Standard 210

- 07: Laboratory Methods of Testing Fans for Certified Aerodynamic Performance Rating , 2007: Arlington Heights, IL. p. 67.
9. AMCA, Fan Industry

- Facing up to the Energy Challenges , 2009. p. 1

- 9.
10. ASHRAE, S tandard 90.1 Energy Standards for Buildings Except Low

- Rise Residential Buildings , 2010: Atlanta, GA. p. 36.
11. ASHRAE. Proposed Addendum u to Standard 90.1

- 2012, Energy Standard for Buildings Except Low

- Rise Residential Buildings . 2012 07/13/2012]; Avai lable from: https://osr.ashrae.org/sitepages/showdoc2.aspx/ListName/Public%20Review%20Draft%2 0Standards/ItemID/737/IsAttachment/N/90.1u+1stPPRDraft.pdf.
12. International Standard Organization, ISO 12759: Fans

-- Efficiency Classification for

Fans , 2010. p. 42.
13. AMCA Comments: Docket No EERE

- 2011

- BT

- DET

- 0045 2011; Available from: http://www.regulations.gov/#!documentDetail;D=EERE

- 2011

- BT

- DET

- 0045

- 0007

. 14. Industrial and Commercial Fan and Blower Manufacturing Industry in the U.S. and its International Trade [2011 Q3 Edition] , 2011: Irvine, CA. p. 163.
15. U.S. Census Bureau. Annual Data: U.S., 6

- digit NAICS, detailed employment sizes . 2008;
Available from: http://www.census.gov/econ/susb/data/download_susb2008.html

. 16. Keith Blackman Centrfugal Fan Guide . 2 ed1980: London Typographical Designers
Limited.
17. Monroe, R.C., Consider V ariable Pitch Fans , Hudson Products Company. p. 13.
18. AMCA, Standard 205

- 10: Energy Efficiency Classification for Fans , 2010, Air Movement and Control Association International, Inc.: Arlington Heights, IL. p. 14.
19. Cory, W.T.W., Fans and Ventilation: A practical guide . 1 ed2005: Elsevier Science. 424.
20. RSMeans Engineering Dept. and M.J. Mossman, RSMeans Facilities Construction Cost
Data 2011 2010: RSMeans Co.