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 U.S. DEPARTMENT OF ENERGY

+ + + + +

PUBLIC MEETING ON ENERGY CONSERVATION

STANDARDS FRAMEWORK FOR CEILING FANS

AND CEILING FAN LIGHT KITS

+ + + + +

FRIDAY,

MARCH 22, 2013

+ + + + +

 The meeting convened in Room 8E-089 

of the Department of Energy, 1000 Independence 

Avenue, SW, Washington, DC, at 9:00 a.m., Doug 

Brookman, Facilitator, presiding.

PRESENT:

DOUG BROOKMAN, Public Solutions, Inc., 

Facilitator

ASHLEY ARMSTRONG, DOE

ABBEY BAKER, Baker Donelson

LAURA BARHYDT, DOE

MICHAEL BRANCATO, Navigant Consulting, Inc.

RACHEL CLUETT, American Council for an 

Energy-Efficient Economy

HAYDEN COOK, Navigant Consulting, Inc.

JOHN CYMBALSKY, DOE

LUCY DEBUTTS, DOE Project Manager

JULIA FARBER, Underwriters Laboratories*

NATHAN FRAMPTON, Fanimation

TOM FRAMPTON, Fanimation

KARINA GARBESI, Lawrence Berkeley National 

Laboratory

DAVE GATTO, Westinghouse Lighting

BRAD HEIMANN, Craftmade

AISHA HUSAIN, Navigant Consulting, Inc.

COLLEEN KANTNER, Lawrence Berkeley National 

Laboratory

ARIS MARANTAN, Navigant Consulting, Inc.
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JOANNA MAUER, Appliance Standards Awareness 

Project

TERRY MCGOWAN, American Lighting Association

SARAH MEDEPALLI, ICF International

ERIK PAGE, Erik Page & Associates

JOHN PARK, for Representative Todd Rokita

JEREMY TARR, Hunter Fan Co.

DAVID TURNER, Hunter Fan Co.

RICHARD UPTON, American Lighting Association

BILL WALKER, Hunter Fan Co.

*Participating via webinar
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TABLE OF CONTENTS

Welcome: Introductions, Agenda Review, and

Opening Remarks; Regulatory History

and Rulemaking Overview; Scope of

Coverage and Definitions .............. 4 

Test Procedures and Metrics ................ 41

Market and Technology Assessment, 

Screening Analysis ................... 95

Engineering Analysis ...................... 108

Markups and Energy Use Analysis: 

Life-Cycle Cost and Payback Period

Analysis and National Impacts

Analysis ............................ 123

Preliminary Manufacturer Impact 

Analysis ............................ 138

NOPR Analyses ............................. 147

Closing Remarks ........................... 158
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1 P-R-O-C-E-E-D-I-N-G-S 

2 9:14 a.m.

3 MR. BROOKMAN: Good morning, 

4 everyone. Welcome. This is the U.S. 

5 Department of Energy's Public Meeting on Energy 

6 Conservation Standards Framework Meeting for 

7 Ceiling Fans and Ceiling Fan Light Kits. Today 

8 is Tuesday, March 22nd, 2013 here in Washington 

9 D.C. My name is Doug Brookman from Public 

10 Solutions. Good to see you all here this 

11 morning.

12 We're going to start with welcoming 

13 remarks from John Cymbalsky. 

14 MR. CYMBALSKY: Thanks, Doug. This 

15 is John Cymbalsky, Program Manager for 

16 Appliance Standards and Building Codes here at 

17 the Department. Let me be the first to welcome 

18 all of you to our public meeting here. We 

19 have, I think, good representation from all 

20 sides of the industry and the advocates, so I 

21 hope we all realize this is a framework 

22 document and we're throwing a lot of ideas at 
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1 you. We know the framework document is 

2 comprehensive, and there's a lot of different 

3 aspects in here to comment on. So, hopefully, 

4 we've all had a chance to read it and comment 

5 here at the meeting, but remember there's 

6 another 30 days or so after this to comment in 

7 writing as we go through. And, again, thanks 

8 for coming. 

9 MR. BROOKMAN: Okay. So then we 

10 typically start with introductions. Let's do 

11 that. I'll start to my immediate left, and you 

12 can get used to turning these microphones on 

13 and off. Please say your name and 

14 organizational affiliation. 

15 MR. MCGOWAN: I'm Terry McGowan. 

16 I'm Director of Engineering for the American 

17 Lighting Association. 

18 MR. BROOKMAN: Thank you. 

19 MR. UPTON: Dick Upton, President 

20 and CEO of the American Lighting Association. 

21 MR. FRAMPTON: Nathan Frampton, 

22 President of Fanimation. 
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1 MS. MAUER: Joanna Mauer, Appliance 

2 Standards Awareness Project. 

3 MS. CLUETT: Rachel Cluett, the 

4 American Council for an Energy-Efficient 

5 Economy. 

6 MR. HEIMANN: Brad Heimann with 

7 Craftmade. 

8 MR. GATTO: Dave Gatto with 

9 Westinghouse Lighting. 

10 MR. WALKER: Bill Walker with Hunter 

11 Fan. 

12 MR. TURNER: David Turner with 

13 Hunter Fan. 

14 MR. TARR: Jeremy Tarr with Hunter 

15 Fan. 

16 MR. STAS: Eric Stas, DOE General 

17 Counsel Office.

18 MR. CYMBALSKY: John Cymbalsky, DOE.

19 MR. COOK: Hayden Cook with Navigant 

20 Consulting. 

21 DR. MARANTAN: Aris Marantan, 

22 Navigant Consulting. 
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1 DR. GARBESI: Karina Garbesi, 

2 Lawrence Berkeley National Lab.

3 DR. KANTNER: Colleen Kantner, 

4 Lawrence Berkeley National Lab. 

5 MR. BROOKMAN: We'll start with you. 

6 Please stand up and say your name. 

7 MR. PAGE: Erik Page, Lawrence 

8 Berkeley National Lab. 

9 MR. TOM FRAMPTON: Tom Frampton, CEO 

10 of Fanimation. 

11 MS. HUSAIN: Aisha Husain, Navigant.

12 MS. BAKER: Abbey Baker, Baker 

13 Donelson.

14 MS. MEDEPALLI: Sarah Medepalli with 

15 ICF.

16 MR. PARK: John Park for 

17 Representative Rokita.

18 MS. ARMSTRONG: Ashley Armstrong, 

19 DOE.

20 MS. BARHYDT: Laura Barhydt, DOE.

21 MR. BROOKMAN: Thanks to all of you. 

22 I'm going to do a very brief agenda review. I 
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1 think all of you received a packet of 

2 information as you came in the meeting room 

3 today. Immediately following this agenda 

4 review -- do you want to do a regulatory 

5 history then before we do opening remarks?

6 MS. DEBUTTS: Sure. 

7 MR. BROOKMAN: Yes. So we'll get to 

8 that in just a moment. Immediately following 

9 the agenda review, Lucy DeButts is going to 

10 provide a brief overview of the regulatory 

11 history and other rulemaking matters. 

12 Immediately following that there's an 

13 opportunity for anyone that wishes to do so to 

14 provide brief opening remarks, summary comments 

15 here at the outset, not lengthy, not reading an 

16 entire written report into the record here but 

17 brief summary remarks about issues that matter 

18 to you.

19 And then, from there, we'll dive 

20 into the detailed content that you found in 

21 this packet of information that you received, 

22 test procedures and metrics. We'll take a 
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1 break midmorning at about 10:40 or so. Market 

2 and technology assessment following that, 

3 screening analysis, and then immediately 

4 following that engineering analysis. 

5 We'll take a lunch break right about 

6 noon or so when we get there. And then 

7 following lunch, markups and energy use 

8 analysis, life-cycle costs and payback period 

9 analysis, shipments analysis, and national 

10 impacts analysis. And then, continuing on, 

11 preliminary manufacturer impact analysis, NOPR 

12 analyses. And at the end of the day today, 

13 which we anticipate will be sometime round 

14 about 1:30 to 2:00 or so, closing remarks and 

15 another opportunity to raise issues that 

16 haven't been covered sufficiently by anybody in 

17 the room.

18 So that's the plan for today. 

19 Questions and comments on the agenda? I see 

20 none. I'd ask for your consideration, if you 

21 would, please, what I think amounts really to 

22 common courtesy, please speak one at a time. 
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1 If you would say your name for the record each 

2 time you speak. You don't need to say your 

3 organizational affiliation; it's up to you. 

4 There will be a complete transcript of this 

5 meeting. 

6 I'm going to say it again. Please 

7 say your name for the record each time you 

8 speak. If you could keep the focus here and 

9 turn your cell phones on silent mode, limit 

10 your sidebar conversations. Please be concise. 

11 Share the air time. There's lots to be said 

12 in the amount of time that we have here today.

13 I'm going to be queuing individuals 

14 by name, as best I can, to speak. I'll also 

15 wish to encourage the follow-on, the back and 

16 forth between individuals here in the room. 

17 Sometimes, that's very useful for the 

18 Department to hear. 

19 For webinar participants, we welcome 

20 you. How many web participants do we have, 

21 Jack? Fifteen web participants. The 

22 Department of Energy is trying hard to make 
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1 these meetings accessible via the web. If you 

2 would keep your telephones on mute, and if you 

3 can raise your hand via the software if you 

4 wish to participate in the conversation or 

5 raise a question or comment.

6 So that's the preliminary stuff from 

7 me. Then to Lucy DeButts. 

8 MS. DEBUTTS: All right. So for 

9 those who haven't met me, I'm Lucy DeButts. 

10 I'm the team lead for this rulemaking for 

11 ceiling fans and ceiling fan light kits. I 

12 will be presenting some material here, 

13 including the scope of the rulemaking. The 

14 technical experts that are sitting at that 

15 table are going to be helping me through the 

16 presentation. We will introduce each presenter 

17 as we come up.

18 So I wanted to actually start maybe 

19 with the purpose of the public meeting. And 

20 the purpose today is to present the issues with 

21 the test procedure on ceiling fans and ceiling 

22 fan light kits. We're also going to be 
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1 presenting the analytical approaches for the 

2 evaluation of energy conservation standards for 

3 both products.

4 We are interested in your remarks. 

5 We would like to open this as a dialogue 

6 between the DOE and the industry to see how we 

7 can accommodate this rulemaking process. So 

8 this is the open forum and, again, we're asking 

9 for your comments, we're asking for your data 

10 that will help us to make the determination on 

11 which route we should take.

12 Sorry. I'm experiencing 

13 difficulties flipping through the slides. 

14 There we go. Okay. 

15 Throughout the presentation, you 

16 will see the comment boxes. So the framework 

17 document, which is on the web right now, has 

18 the issues numbered. Throughout the 

19 presentation, you will see the comment boxes. 

20 We're not discussing all the issues today. In 

21 order to save time, we're going to highlight 

22 the main issues. So please speak up. We are 
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1 seeking your comments. Give us written 

2 comments and data, any data that can help us.

3 Let's see. Next slide. The written 

4 comments can be submitted using these avenues. 

5 You can send it electronically. You can go on 

6 regulations.gov and use a docket number and the 

7 RIN number when you submit your written 

8 comments. For those who would like to send it 

9 via mail, that option also is available. But, 

10 so far, we've received a couple of comments 

11 from you, and it seems that the electronic way 

12 works best for everyone.

13 All right. So, actually, if we can 

14 do the opening remarks right now before we go 

15 into the regulatory history, that's probably 

16 going to flow better. 

17 MR. BROOKMAN: Okay. Sounds good. 

18 So as suggested in your packet and also the 

19 agenda, let's have summary comments. Dick?

20 MR. UPTON: Dick Upton, American 

21 Lighting Association. First, thanks for the 

22 opportunity to participate. We've had 
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1 interface with the staff for a long time here, 

2 and I like the way the document was laid out as 

3 far as the 75 questions. It's pretty clear.

4 But for those who don't know, the 

5 American Lighting Association is made up of 

6 designers, lamp manufacturers, the 

7 manufacturers of fixtures, ceiling fans, the 

8 manufacturers' representatives, and the 

9 independent lighting retailers in the United 

10 States, Canada, and the Caribbean. We have 18 

11 ceiling fan manufacturers, two of whom are 

12 Canadian firms. 

13 I was surprised by the scope of the 

14 document. That's up-front. If you're not a 

15 ceiling fan person or you're not an engineer, 

16 it was about a six-hour slog to get through it 

17 all, but it was easy to do, Lucy. And those 75 

18 question points point out where you need to be, 

19 so it was well laid out. 

20 We made this document available 

21 immediately to our members. We've had a 

22 telephone conversation to begin with on it a 
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1 week ago today, I believe, was the first, and 

2 we had a second conference call last Monday to 

3 see how we were going to organize ourselves to 

4 get going. And to DOE's credit and 

5 particularly John, thank you for giving us the 

6 extra days that allowed people to get some 

7 materials turned in.

8 Something I think you might find 

9 interesting about the scope of where you are, 

10 and I'm concerned about it, not from what we're 

11 going to review but just the work that's there, 

12 the economy impacted the ceiling fan industry 

13 like it did everybody else, simply because 

14 we're tied to the building industry. And a 

15 number of our companies have seen, in quotes, 

16 downsizing or rightsizing, depending on how you 

17 want to evaluate that. And engineers are part 

18 of that, and those are the people who are going 

19 to be doing the bulk of the work on these kinds 

20 of things. 

21 So our ability to, you know, nobody 

22 is sitting around waiting for someone to give 
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1 you something new to do. But we may need more 

2 time than we've been given. I don't think we 

3 know that yet. We've really just been there. 

4 I've not been able to work with these folks at 

5 all because I was pre-organized to be in 

6 Washington since Tuesday on other matters and, 

7 happily, Friday worked well for us. 

8 But one of the things that I have 

9 wondered about, and I think there's different 

10 opinion, even within the industry, but if it's 

11 as large a document and activity as it is, 

12 maybe some thought should be given to breaking 

13 it into two parts: one light kits and one 

14 ceiling -- the fans themselves. And we can 

15 then get into better depth, and I think the 

16 deeper we're all able to go on these things the 

17 better decisions everybody is going to make and 

18 better outcomes that we'll have. 

19 On the other hand of that argument 

20 is the light kit is part of what we're talking 

21 about, and maybe it's not separable and we 

22 don't know that yet. But I would ask you to 
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1 think about that, please. 

2 Other comments we would make, for 

3 openers, is we would ask everybody to remember 

4 that, of all the appliances, we think the 

5 ceiling fan was designed and built to be an 

6 energy-efficient product, and it is. And the 

7 more we can get ceiling fans used, the more 

8 energy we're going to save in the wintertime on 

9 heating with furnaces and air conditioning in 

10 the summer. And that's a reality. 

11 We would point out to you there are 

12 some state requirements that are there, 

13 especially in California. And the degree of 

14 any changes we make that can be tied to that, 

15 to the point we're not developing this party 

16 says do this with fans and that party says do 

17 that with fans, can we coordinate that kind of 

18 thing, which will be better for everybody and 

19 will keep costs lower. 

20 We would like to recommend that you 

21 use this rulemaking to eliminate power limiters 

22 from self-regulating products. We've been 
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1 beating at you for a couple of years about 

2 that, and this is an opportunity. So don't 

3 disappoint me.

4 And, lastly, cost-benefit analysis 

5 has really got to be there on this one. And 

6 we'll watch that like a hawk for you, but we 

7 think everybody needs to do that because what 

8 nobody wants to do is make the fan so expensive 

9 that the guy at the economic bottom end of the 

10 ladder can't afford them. And there's people 

11 who don't have air conditioners, so they're 

12 just going to suffer, period. But then you 

13 have another group of people who, if the fan 

14 starts to get so expensive, well, we'll just 

15 forget about that and we'll just run the air 

16 conditioner. 

17 So those are -- I've said that in 

18 greater depth in the writing, but, for the sake 

19 of everybody's comments and time, I think those 

20 are the points. Our industry is interested in 

21 working with you on this project, as we have 

22 everything else. And we'll be your good 
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1 partner. I'll make sure I listen to my people 

2 because I'm not smart enough on these issues to 

3 say things on my own. And when I get out of 

4 line, I'll look to Terry McGowan, who you all 

5 know as a strong player and an engineer of 

6 significant reputation who will be very helpful 

7 to us all. Thank you.

8 MR. BROOKMAN: Thank you. Nathan, 

9 did you want to go next? 

10 MR. FRAMPTON: Good morning. Nathan 

11 Frampton with Fanimation. I'll keep my 

12 comments brief. I think I can speak for all 

13 manufacturers in this room that our mission in 

14 life is to reduce worldwide energy consumption. 

15 Our products, by their very nature, reduce 

16 energy consumption. We are highly concerned 

17 that any regs will not only increase product 

18 costs, but they'll reduce the product's 

19 likeability. And those both, in turn, will 

20 decrease ceiling fan use. And reducing ceiling 

21 fan usage will increase energy consumption, in 

22 our opinion. 
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1 To tag on to what Dick said, not 

2 only are ceiling fans energy efficient, it's 

3 very important to understand that they're an 

4 energy-saving device. They're one of the only 

5 appliances that you can purchase that actually 

6 saves energy. 

7 I think the important question that 

8 we all have to ask ourselves is, is what we're 

9 doing here going to increase or decrease energy 

10 consumption? That's the important question. 

11 MR. BROOKMAN: Okay, thank you. 

12 Other comments here at the outset? Is it 

13 David? 

14 MR. TURNER: Yes. David Turner, 

15 Hunter Fan. Just to, you know, piggyback a lot 

16 on what Nathan said is, you know, we definitely 

17 want to work with and help the DOE, and we're 

18 on the same page as far as, you know, saving or 

19 using less energy. But if the goal of this is 

20 to potentially regulate and add cost to make 

21 fans more efficient when they are inherently 

22 already there and saving energy, we really need 
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1 to look at that and make sure we make the right 

2 decisions. 

3 And as Dick said, you know, 

4 economically feasible was mentioned a few times 

5 in the framework document, and that's got to be 

6 really, that's got to be on the forefront of 

7 this. And, you know, as far as the path of 

8 least energy-using devices in your homes, you 

9 know, fans fall at the low end of that. And 

10 they're able to, you know, when you're using a 

11 ceiling fan, you're able to turn those devices 

12 off that are using more energy. 

13 But, again, we're here to help, and 

14 Hunter, as all manufacturers are, dedicated to 

15 the continuous improvement of efficiency over 

16 the long run. So we're all trying to make fans 

17 more efficient, and we think, as an industry, 

18 we do that on our own. So we think the 

19 important thing here would be to further 

20 educate the end consumer on the energy savings 

21 benefits of fans. So, you know, when you're 

22 using your ceiling fan, you can set your AC to 
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1 a higher temperature so that it will shut off 

2 in warmer times. 

3 So I think, you know, our direction 

4 here would definitely be towards education 

5 versus more regulation.

6 MR. BROOKMAN: Okay, thank you. 

7 Additional comments? Nothing additional. 

8 Okay. Oh, Dick, one more thing. 

9 MR. UPTON: What's selling ceiling 

10 fans today is, first, cost; second is cost; and 

11 third is cost. And that's real, that's not 

12 made up. And if we get beyond that, then we 

13 start to have a cost-benefit challenge. Thank 

14 you. 

15 MR. BROOKMAN: Okay, thank you. Now 

16 we're going to move into the detailed content 

17 in your slide packet, and we're going to hear 

18 first from Lucy DeButts. 

19 MS. DEBUTTS: All right. To begin, 

20 I'd like to start with a little history 

21 regarding the DOE authority for ceiling fans 

22 and ceiling fan light kits. And as you can 
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1 see, in 2005, EPACT amended the EPCA and added 

2 ceiling fans and ceiling fan light kits to the 

3 list of DOE's covered product. 

4 On October 18th of 2005, DOE 

5 codified prescribed-by-Congress design 

6 standards for ceiling fans and energy 

7 efficiency standards for ceiling fans and 

8 ceiling fan light kits for medium screw-based 

9 sockets and the pin-based sockets. The 

10 following year, on December the 8th, DOE 

11 published a test procedure for ceiling fans and 

12 ceiling fan light kits as a part of the en 

13 masse rule. 

14 And, finally, on January 11th of 

15 2007, DOE published a technical amendment which 

16 codified energy efficiency standards for the 

17 third product class. That includes everything 

18 which is not included in the first two product 

19 classes for ceiling fan light kits.

20 So this brings me to our meeting 

21 today. We're initiating the energy 

22 conservation standards for the rulemaking 
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1 pursuant to the authority for ceiling fans and 

2 ceiling fan light kits. I also would like to 

3 mention that DOE is obligated to review the 

4 test procedure under EISA requirements. 

5 I also would like to go into the 

6 rulemaking schedule. And I understand that --

7 we hear you loud and clear, you know, your 

8 concern about the schedules. These are the 

9 projected dates which we're listing here. They 

10 will depend on the comments we receive from the 

11 industry. They will depend on the analysis 

12 that we do.

13 So what we are doing today is we're 

14 having a public meeting to discuss the 

15 framework document that was published. All the 

16 documents that we're publishing are available 

17 on the web on DOE’s website, so the framework 

18 is available, the presentation slides were 

19 posted a couple of days ago. We will put the 

20 transcript up on the web as soon as we can, 

21 hopefully in a couple of days, if not, you 

22 know, if not faster, but it all depends.
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1 So the proposed dates are that the 

2 test procedure and the Notice of Proposed 

3 Rulemaking are projected to come out in the 

4 fourth quarter of this year. We will wait for 

5 your remarks and comments, and we will publish 

6 these preliminary analyses hopefully in the 

7 first quarter of 2014. The test procedure 

8 final rule will follow in the second quarter of 

9 2014. The NOPR for standards will come out in 

10 the first quarter of 2012, and the standards 

11 final rule is projected to come out in the 

12 first quarter of 2016. Following that, three 

13 years later, the compliance date will be in 

14 place, which is the first quarter of 2019. 

15 Now, again -- yes? 

16 MR. UPTON: Lucy, are we talking 

17 about government quarters or calendar year 

18 quarters? 

19 MS. DEBUTTS: It's a calendar year 

20 quarter. I'm sorry. No, it's a fiscal year 

21 quarters. 

22 MR. UPTON: Okay. So when we say 
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1 first quarter of 2014, you're saying October 1 

2 of this year? 

3 MS. DEBUTTS: Right. Well, it 

4 starts, yes. Again, this all depends on the 

5 remarks we get from you. 

6 MR. BROOKMAN: Let's get used to 

7 using the microphone, but your comments are 

8 adequate to clarify the calendar, I think, so 

9 keep going. 

10 MS. DEBUTTS: Okay. All right. 

11 Let's see. I also would like to talk about the 

12 factors that we're using while we're doing the 

13 analyses. And, again, we hear you loud and 

14 clear. Economic times are tough right now. We 

15 understand that part. And we are going to do, 

16 we're going to evaluate all seven factors that 

17 are listed on the slide. Whatever we do with 

18 the rulemaking, we are committed to not 

19 lessening the utility of your product. So I 

20 just want to bring that up.

21 We will go into each factor later in 

22 the presentation. We will discuss what steps 
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1 are going to be done while we're doing the 

2 analyses. We will do the manufacturer 

3 interviews, in addition to the comments we 

4 receive from you. Any claims or ideas you 

5 have, if you have data to substantiate that, 

6 like ceiling fan is the energy-efficient 

7 product, if there are any data that will help 

8 us to determine what you're basing it on, that 

9 would be helpful. So please submit that data 

10 to us. 

11 So that brings me to the scope of 

12 coverage for ceiling fan and ceiling fans 

13 today. The framework document has more details 

14 on that, so feel free to take your time and 

15 review it. I know some of you may have time 

16 already, some haven't. But it's on the web.

17 What DOE is going to do is EPCA 

18 defined the ceiling fans as a non-portable 

19 device that is suspended from the ceiling for 

20 circulating air via rotational fan blades. We 

21 are considering interpreting the ceiling fan to 

22 incorporate hugger fans. Also, DOE is 
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1 considering establishing a separate product 

2 class for highly-decorative fans for which air 

3 movement performance is a secondary feature, 

4 which will help everyone to distinguish between 

5 the regular ceiling fans and the highly6 decorative ones. 

7 So we're also considering including 

8 in this rulemaking the fans that do not have 

9 external blades but produce air flow. And the 

10 last but not least, the statutorily-required 

11 prescribed standards will remain in place.

12 To continue the overview, so on this 

13 slide we have the ceiling fans. We grouped 

14 this -- these are not the product classes yet. 

15 What we did, we grouped the market information 

16 we found by the ceiling fan types and their 

17 functionality and, of course, the market 

18 description. This may or may not become 

19 product classes. We would like to get your 

20 input on that. That's why we're listing them 

21 in this order and making sure that the table is 

22 summarizing it correctly.
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1 And, again, as I stated, the 

2 definitions that we are proposing are on this 

3 slide. We want to include hugger fans, highly4 decorative fans, outdoor fans, revise their 

5 definitions. And, also, DOE will consider 

6 regulatory definitions of standard fans and 

7 multi-mount fans. More information is 

8 available in the framework.

9 So right now I'd like to -- the list 

10 of items that's listed here, we can go one by 

11 one and get your comments on each single item 

12 number, whoever would like to start first. 

13 MR. CYMBALSKY: John Cymbalsky, DOE. 

14 I just want to, I think, correct what you said 

15 about the schedule. It should be, it's 

16 calendar, not government fiscal year, if I 

17 interpret the framework in 2013 so it's 

18 calendar year, not fiscal.

19 MR. BROOKMAN: Thank you. Thanks 

20 for that. And, Terry, if you're going to be 

21 commenting, why don't you move up here to the 

22 table next to a microphone? Okay. We have now 
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1 the, you can see item number one. You want to 

2 queue that up for us? 

3 MS. DEBUTTS: Yes, sure. So DOE 

4 seeks comments on this proposed 

5 reinterpretation of the ceiling fan definition. 

6 

7 MR. BROOKMAN: Comments on the 

8 definition. Joanna? 

9 MS. MAUER: Joanna Mauer. We 

10 support the proposed reinterpretation to 

11 include hugger fans in the ceiling fan 

12 definition. 

13 MR. BROOKMAN: Thank you. Other 

14 comments? Dick? 

15 MR. UPTON: Yes, we question it. 

16 That's all we can do. 

17 MR. BROOKMAN: Okay. At this point.

18 MR. UPTON: Yes. We don't have 

19 enough time, but I've had some comments from 

20 our people that this is one where we could 

21 really see huge increase in costs to the point 

22 it's not a usable product. Thank you. 
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1 MR. BROOKMAN: Thank you. Final 

2 comments? We're going to keep moving 

3 expeditiously here, gentlemen, ladies. On to 

4 number two. 

5 MS. DEBUTTS: Okay. Item number 

6 two, DOE seeks comments on whether ceiling fans 

7 without external blades should be included in 

8 the rulemaking if they meet the definition of a 

9 ceiling fan. 

10 MR. BROOKMAN: No comments at this 

11 time. Okay. 

12 MS. DEBUTTS: Okay. Item number 

13 three, DOE seeks comments on its proposed 

14 approach in developing definitions for the four 

15 types of ceiling fans, the vertical distance 

16 that is used to characterize whether a fan can 

17 safely be used in a room with low ceiling 

18 heights, and any other typical characteristics 

19 used to determine the different types of 

20 ceiling fans currently on the market.

21 MR. BROOKMAN: So, David, do you 

22 want to go? David? 
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1 MR. TURNER: Our question on this or 

2 comment was the definition of using the 

3 distance from the ceiling, and it says average 

4 or the average distance. And we needed more 

5 clarification. Would huggers be allowed to be 

6 a max distance? Our comment would be that you 

7 would turn the phrase from average to maximum, 

8 as far as allowable distance for a hugger. 

9 MR. BROOKMAN: That's helpful. 

10 Okay. 

11 MR. TURNER: It was a little 

12 unclear, the definition.

13 MR. BROOKMAN: Okay. Additional 

14 comments? And especially the four types that 

15 are listed there on the preceding slide, 14, 

16 any additional thoughts on the differentiation 

17 or lack thereof that is there? Okay. 

18 MS. DEBUTTS: Last item on this 

19 slide, item number four. So we are seeking 

20 comments on our proposed definition of highly21 decorative ceiling fans. 

22 MR. FRAMPTON: Nathan Frampton with 
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1 Fanimation. It's our suggestion that we either 

2 raise the RPM higher or define a highly3 decorative ceiling fan as a blade ratio from 

4 blade width to blade length. 

5 MR. BROOKMAN: Oh, okay. So you'll 

6 put that in writing in detail, correct? 

7 MR. FRAMPTON: Yes. 

8 MR. BROOKMAN: Because there was 

9 more there than you just -- that was helpful, 

10 your comment. Dick? 

11 MR. UPTON: When it was not 

12 included, it was under the presumption or 

13 exempt, or whatever we wanted to say the first 

14 time, that it was a fan that didn't have any 

15 criteria for moving air because it was 

16 decorative. Do I recall that the document 

17 currently says considering 50 watts as a max, 

18 Lucy? 

19 MS. DEBUTTS: RPM. 

20 MR. UPTON: Most people's heart rate 

21 is faster than 50. And if you're going to have 

22 any ability to move the fan, decorative or not, 
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1 it's got to have the ability to move, and 50 is 

2 not going to get the job done. 

3 MR. BROOKMAN: Okay. So, of course, 

4 these comments and offering the specifics --

5 MR. UPTON: We've got to be much 

6 more broad and more detailed. We will 

7 understand. We're just not there yet. 

8 MR. BROOKMAN: Ashley? 

9 MS. ARMSTRONG: Yes. So I'm going 

10 to go back to a couple of these. I realize 

11 that you may not have comments, but maybe you 

12 can help us understand. How do you distinguish 

13 now? How do you determine what you're going to 

14 put on a box now? If you put hugger fan on a 

15 box, what does that mean to you now?

16 MR. TARR: This is Jeremy Tarr with 

17 Hunter Fan. Quite simply, a hugger fan today 

18 is a fixed, the blades are a fixed distance 

19 from the ceiling. They cannot be adjusted; 

20 that can vary. It is not adjustable by means 

21 of a down rod. It hugs the ceiling. 

22 MS. ARMSTRONG: So that's what we're 
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1 trying to get at, right? I think, from the 

2 Department's perspective, we pulled a bunch of 

3 literature off the websites and we were looking 

4 at different things. So we're going to have to 

5 have a way of uniformly defining across the 

6 board, and what we're understanding is that it 

7 may be done differently or may be implemented 

8 differently or slightly differently currently. 

9 So we're trying to understand what do you do 

10 today and how can we uniformly apply that in a 

11 regulatory scheme, if needed.

12 MR. BROOKMAN: Jeremy? 

13 MR. TARR: At the risk of sounding a 

14 little callous, I think we're over-thinking it. 

15 It is, quite simply, a fan that is at a fixed 

16 distance from the ceiling. It doesn't matter 

17 if you hang it on a 20-foot ceiling or an 8-

18 foot ceiling, the blades will be X distance 

19 from the ceiling. They cannot be adjusted. It 

20 is low profile to the ceiling.

21 MR. BROOKMAN: Dick?

22 MR. UPTON: Ashley, are you asking 
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1 us, can we help you with the definition?

2 MS. ARMSTRONG: Absolutely.

3 MR. UPTON: Yes.

4 MS. ARMSTRONG: Yes. I'm just 

5 trying to understand. I mean, I did a good 

6 deal of looking at it. And you're right, some 

7 of them are a fixed distance; but some of them 

8 are a fixed distance pretty far away, and they 

9 still have that label on it. So I think we're 

10 just trying to understand, you know, what is 

11 that, where is that threshold, is there a 

12 threshold? 

13 MR. BROOKMAN: Dick? 

14 MR. UPTON: One of the things I 

15 think we can give you some comfort level on is 

16 we're going to work on this as an industry. 

17 We've already agreed that we'll do that, and 

18 ALA will coordinate it. And we can help you on 

19 that side of it, Ashley, on the basis of what I 

20 hear, what I think I hear you saying is can we 

21 get together to give you a singular or close to 

22 a singular definition to the point you can get 
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1 your arms around one thing rather than a 

2 multiplicity of items. 

3 MS. ARMSTRONG: Yes. I mean, I will 

4 go a step further, and when you say a fixed, 

5 fixed is an adjective that means a lot of 

6 different things to a lot of different people, 

7 or can. So that's why I asked you, well, what 

8 is that distance? And while I can appreciate 

9 keeping it simple, at the same time if your 

10 definition of fixed is different than the 

11 Department's definition of fixed, when you get 

12 questions, we have an issue, right? And the 

13 last thing you want to do is think your 

14 definition of fixed may put you into a 

15 different bucket than we think you should be. 

16 So that's where it becomes important to have 

17 discrete defining characteristics, so we were 

18 just trying to understand, well, what is really 

19 done today, right? 

20 MR. BROOKMAN: Dick, go ahead.

21 MR. UPTON: Yes. I think if we 

22 continue as we are and working together, we'll 
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1 submit some things to you and you can finally 

2 say, no, that's enough yet, give me something 

3 more. And when we get there, then we'll have a 

4 closure, but we can help you with that a lot. 

5 MR. BROOKMAN: Thank you. Nathan? 

6 MR. FRAMPTON: Fanimation agrees 

7 with Hunter. Maybe a different way to say it 

8 is a hugger fan is a fan where you cannot 

9 change the distance of the blades to the 

10 ceiling. So instead of saying fixed, you can't 

11 change the distance -- 

12 MR. BROOKMAN: John Cymbalsky?

13 MR. CYMBALSKY: So the way I 

14 understand it then, you can change the 

15 configuration of your box from being horizontal 

16 to a big vertical box, and that's a fixed 

17 distance, but the distance is three feet from 

18 the ceiling and it's still fixed. So you would 

19 consider that a hugger fan under what you just 

20 said? 

21 MR. BROOKMAN: That gets to the 

22 issue, doesn't it? 
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1 MR. CYMBALSKY: Yes, I think that is 

2 the issue.

3 MR. BROOKMAN: Thanks for raising 

4 the issue, by the way. It's helpful. 

5 MR. CYMBALSKY: I'm just thinking, 

6 if you say fixed equals 12 inches, then we have 

7 a different definition than fixed equals the 

8 ability of not to move the distance. 

9 MR. BROOKMAN: I noticed that 

10 Christian Taber joining us via the web has a 

11 question or comment. Christian, speak loudly, 

12 please. You're not coming through yet. And, 

13 Christian, identify yourself when you do come 

14 through. You may still be on mute. Christian, 

15 we can't hear you. No, he's not coming 

16 through. Christian, we'll give you a moment. 

17 We'll try you again later.

18 Additional comments on this? Eric?

19 MR. STAS: On the highly-decorative 

20 fans, I just wanted to ask a question or throw 

21 out whether, instead of it just being a blade 

22 to width ratio or the RPMs, maybe it could be 
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1 both. You could help us identify when it would 

2 be appropriate to be highly decorative under 

3 both of those characteristics. 

4 MR. BROOKMAN: Okay. Christian, do 

5 you want to try again? We're not getting any 

6 audio from you, so sorry about that. Okay. Do 

7 you know whether our system is working? His 

8 phone is not working we think. Okay. 

9 So then let's proceed. 

10 MS. DEBUTTS: Okay. So that brings 

11 us to -- it's not working. So that brings us 

12 to the scope of coverage for the ceiling fan 

13 light kits. And, basically, ceiling fan light 

14 kits are either built into or designed to be 

15 attached to the ceiling fan and they’re covered 

16 products. They're integral and attachable. So 

17 if you have any comments on this, please let us 

18 know.

19 MR. BROOKMAN: There's no comment 

20 box, but the Department is requesting comment, 

21 should there be any. None at this time. 

22 MS. DEBUTTS: Okay. Well, then that 
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1 concludes the scope, and Colleen Kantner will 

2 be presenting the test procedure and metrics 

3 part. 

4 MR. BROOKMAN: Okay. 

5 DR. KANTNER: Hi. I'm Colleen 

6 Kantner, and I'm with Lawrence Berkeley 

7 National Lab. As Lucy mentioned earlier, DOE 

8 will be conducting test procedure rulemakings 

9 for ceiling fans and ceiling fan light kits. 

10 And an important first step in the test 

11 procedure rulemaking is to first review any 

12 existing industry or governmental test 

13 procedures. And the purpose of the test 

14 procedure is to clarify for manufacturers how 

15 to certify compliance with applicable energy 

16 conservation standards and how to make 

17 representations of the energy efficiency.

18 So first let's look at test 

19 procedures for ceiling fans. The current DOE 

20 test procedure is version 1.1 of the ENERGY 

21 STAR test procedure with a few minor 

22 modifications for power measurement, sensors, 
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1 and sensor software. 

2 There are a couple of other relevant 

3 test procedures. There is the updated ENERGY 

4 STAR test procedure. This is version 1.2. And 

5 changes from the DOE test procedure include an 

6 increased allowable tolerance for the velocity 

7 sensor accuracy, also lowered room temperature 

8 and increased fan warm-up time. 

9 The Canadians also have a test 

10 procedure, and differences between the Canadian 

11 test procedure and DOE's test procedure include 

12 a test setup that allows for testing of hugger 

13 fans. The Canadians also have a sampling plan, 

14 as well as standby power measurement in their 

15 test procedure.

16 So now let's get into some key 

17 issues for the test procedure for ceiling fans. 

18 In order to assess the test procedure, DOE 

19 conducted some initial testing of a few 

20 conventional ceiling fans and observed that the 

21 average air velocity could vary significantly, 

22 depending on the sensor arm position. So for a 
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1 given sensor, if it rotated 90 degrees, you 

2 might see a difference in the average air 

3 velocity of a factor of two or three. And 

4 given the symmetry of the test setup, this 

5 suggested that there might be some potential 

6 issue with the accuracy of the velocity 

7 sensors.

8 DOE also observed that sometimes the 

9 measured RPM for a ceiling fan was not 

10 consistent with the RPM that might be listed in 

11 the owner's manual or online. And since the 

12 RPM just reflects the motor speed for ceiling 

13 fans, this suggested that perhaps there was 

14 some difference from one ceiling fan to another 

15 within a given model. And so DOE is seeking 

16 feedback on whether representations of RPM are 

17 based on test procedure values and whether DOE 

18 should consider a larger sample size to 

19 determine ceiling fan rating. 

20 So now we have a couple of comments. 

21 We're breaking down the key issues, instead of 

22 going all through them once and asking for 
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1 comment at the end. 

2 So the first item, item seven, is 

3 DOE requests comments on the accuracy tolerance 

4 of the velocity sensors for either the current 

5 DOE or current ENERGY STAR test procedures and 

6 potential sources of inaccuracy for low-speed 

7 airflow measurements. 

8 MR. BROOKMAN: We'll start with that 

9 one first. Comments on these, David? 

10 MR. TURNER: David Turner. When you 

11 say a factor of two, that there was 

12 variability, factor of two cubic feet per 

13 minute or, I mean, was it meaning it was double 

14 or --

15 DR. KANTNER: Yes, from double to 

16 triple the airflow. 

17 MR. WALKER: Bill Walker, Hunter 

18 Fan. Was that at low speed? 

19 DR. KANTNER: That was at low speed, 

20 yes.

21 MR. WALKER: Okay. 

22 DR. KANTNER: There was some 
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1 variability at higher speeds but not as much as 

2 at low speed. 

3 MR. BROOKMAN: Comments on seven 

4 about the accuracy tolerance of the velocity 

5 sensors and other potential sources of 

6 inaccuracy? Okay. On to the second one. 

7 DR. KANTNER: Okay. DOE also 

8 requests comment on the potential performance 

9 variability between ceiling fans for a specific 

10 fan model and the possibility of requiring a 

11 sample of ceiling fans to certify a model. 

12 MR. BROOKMAN: Nathan? 

13 MR. FRAMPTON: Just a general 

14 comment. Nathan Frampton with Fanimation. We 

15 think that the test procedure could be 

16 improved. However, we think we need, we need a 

17 lot of time, we need a lot more time to 

18 research what that procedure should actually 

19 be. 

20 MR. BROOKMAN: Has the industry 

21 association, has American Lighting Association 

22 or some group like that undertaken to do its 
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1 own test procedure stuff in the past? 

2 MR. FRAMPTON: Not to my knowledge. 

3 MR. BROOKMAN: Okay. 

4 MR. UPTON: American Lighting 

5 Association does not do any test procedures. 

6 We look to UL or CSA or ETL, but UL and CSA set 

7 standards for us. 

8 MR. BROOKMAN: Okay, thank you, 

9 Dick. Okay. Let's proceed. Ashley has got 

10 another question. 

11 MS. ARMSTRONG: Okay. So, Nathan, 

12 the test procedure you're currently using, are 

13 you using the DOE test procedure for ENERGY 

14 STAR, using the ENERGY STAR test procedure, or 

15 are you using the CSA test procedure? Are we 

16 using a combination of all three? Are there 

17 aspects of one that are better than the others? 

18 I mean, they're all basically the same but 

19 with slight differences here and there, at 

20 least from what we've found so far. And so 

21 these are questions that we've gotten from test 

22 labs that are either running tests for the 
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1 ENERGY STAR program. We've done testing of 

2 ceiling fans on the market at third-party labs, 

3 and these are issues we found when we went into 

4 lab at third-party labs.

5 We're open and we welcome your 

6 comments. You know, some type of discussion 

7 would be helpful at the outset, as well as 

8 long-term. 

9 MR. BROOKMAN: Nathan? 

10 MR. FRAMPTON: And I guess my 

11 response is we're open, as well. We just need, 

12 we need a lot more time because it's going to 

13 take time and resources for us to develop what 

14 we think would be an adequate test.

15 MR. BROOKMAN: I'm thinking that 

16 you've not done this in the past. And there's 

17 a capacity issue here, that is having that 

18 capacity built up. Dick? 

19 MR. UPTON: The American Lighting 

20 Association has worked very vigorously, to the 

21 point there's times I have to lower my voice to 

22 make sure they understand. But UL and CSA now 
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1 work very closely on harmonizing their lighting 

2 standards, and that's critical for us. We're 

3 not aware that anybody has beat us yet or beat 

4 us over the head to get a ceiling fan 

5 harmonized standard, but if that's what we 

6 need, why, we'll push to make that kind of 

7 thing happen and maybe a combination of us 

8 doing it. 

9 But to my knowledge, as you said, 

10 Ashley, the majority of those things are pretty 

11 close at this point. If we can get them a bit 

12 more finite, let us see what we can find out 

13 about that. That's critical for us, as you can 

14 imagine, with business going both ways across 

15 the border. With our Canadian members selling 

16 in the United States and U.S. people selling 

17 the other way around, we're not interested in 

18 double testing by any stretch of the 

19 imagination. So we should be able to get 

20 helpful definitions for you. 

21 MR. BROOKMAN: Ashley, go ahead.

22 MS. ARMSTRONG: I think what you're 
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1 hearing from the Department is that the statute 

2 requires us to look into it, and we will sit 

3 down and work with you guys on coming up with a 

4 method. These are the issues we've seen at the 

5 outset. I would have envisioned that you were 

6 seeing some of these, too, at least by the 

7 amount of questions I'm getting for testing 

8 that's being done to qualify your ceiling fans 

9 to ENERGY STAR right now. So DOE is in charge 

10 of the test procedures for ENERGY STAR, as 

11 well, so we work very closely with EPA, you 

12 know, on the program. So I'm hoping that we 

13 can work together and not, you know, shift this 

14 off to another -- we will work with them, as 

15 well, but all of us together. 

16 MR. BROOKMAN: So just to be 

17 obvious, no, explicit, as we try to be here --

18 just one moment. Ashley's earlier comment was, 

19 gee, what about this is working? What's good 

20 for you? What's not working for you? What are 

21 the details surrounding these different testing 

22 methods? And that would be the sweet spot, 
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1 that would be the descriptive stuff that you 

2 want to put in your comments and work with the 

3 Department and others, right? Just to be 

4 clear.

5 Julia Farber joining us online 

6 wishes to comment. Julia, go right ahead. 

7 MS. FARBER: Can you hear me? 

8 MR. BROOKMAN: Yes, we can.

9 MS. FARBER: Okay, perfect. Sorry. 

10 Julia Farber from Underwriters Laboratories. 

11 I've been listening to the conversation, and I 

12 just wanted to let you guys know that I'm with 

13 government affairs, and we'll do what we can to 

14 see if we can look into a little bit more 

15 details about the questions that were just 

16 raised. And we'd also be open to working with 

17 you guys on that with the knowledge that we 

18 have about the current test procedures, but the 

19 test procedures, I have a feeling, have more to 

20 do with safety right now. 

21 MR. BROOKMAN: Okay.

22 MS. FARBER: So I will, I guess 
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1 we'll look into that and get back to you. And 

2 if we have somewhere to add into comment, we 

3 will definitely do so. In the meantime, we're 

4 really looking to you guys to look to us as 

5 really your --

6 MR. BROOKMAN: Thank you. Okay, 

7 good. Bill? 

8 MR. WALKER: Bill Walker, Hunter 

9 Fan. Just to address the accuracy issues and a 

10 standardized test. Several years ago, there 

11 were only three test labs. It was ours and 

12 Intertek, and you all had one in Taiwan or 

13 overseas. At that time, what we did, we had a 

14 test fan that we would send around to each lab 

15 and make sure that each lab's results would 

16 correlate. I think that should happen again. 

17 We need to know that, from lab to lab, that, 

18 you know, if one lab measures 5,000 CFM, every 

19 lab should measure within some variation of 

20 that. And I think that takes out the problems 

21 associated with the tolerance and the velocity 

22 sensors, especially at low speeds. You know, 
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1 so if everybody is within five percent, ten 

2 percent, whatever that number is, then it 

3 should be okay. However, somebody has got to 

4 regulate that whole round robin testing 

5 procedure.

6 MR. BROOKMAN: Okay, great. Dick?

7 MR. UPTON: Ashley, I totally agree 

8 with you that we want to just all partner 

9 together on this thing because working with UL, 

10 and we've got them on the line, we should be 

11 able to make that happen. And we can put CSA 

12 in the room at the same time, and we'll just 

13 pull that together quickly. 

14 MR. BROOKMAN: Okay, great. Let's 

15 move on. 

16 DR. KANTNER: Okay. And here we 

17 have a few more issues for the test procedure. 

18 First of all, how should hugger fans be 

19 tested? And DOE is investigating potential 

20 methods of testing, including the use of an 

21 artificial ceiling. Another potential issue is 

22 how to test multi-mount fans. These are fans 
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1 that can be either mounted in the hugger 

2 configuration or in a standard configuration. 

3 And DOE is not currently aware of any data on 

4 how frequently they are in one configuration 

5 versus the other, so we're currently 

6 considering testing, looking at fans in the 

7 hugger fan configuration to provide a 

8 conservative estimate of airflow efficiency.

9 We're also aware that there are some 

10 ceiling fans that have non-flat or unusually11 shaped blades, and the current test procedure 

12 might be a bit ambiguous. It refers to the 

13 mid-point of the blade tip, and that might be a 

14 little bit ambiguous. And DOE is considering 

15 investigating appropriate configurations and 

16 methodologies, as well as clarifying the 

17 language in the test procedure.

18 Another change to the test procedure 

19 that DOE is considering is that, currently, 

20 ceiling fans must be tested in a test cylinder 

21 which is exactly eight inches larger in 

22 diameter than the blade span of the fan being 
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1 tested, and DOE is considering whether or not 

2 it can relax that restriction. A few 

3 possibilities to consider are, one, we could 

4 allow testing within a tolerance of the current 

5 eight-inch requirement, or we could also 

6 develop a correlation between blade span and 

7 cylinder size. Again, this is with the idea of 

8 relaxing that restriction and reducing the 

9 burden on manufacturers to buy new test 

10 cylinders when you test an unusual fan size.

11 And we have a couple of comments. 

12 Item number 9, DOE requests comments on its 

13 proposal to investigate methodologies, 

14 including the use of an artificial ceiling to 

15 enable hugger fans to be tested. 

16 MR. TURNER: David Turner with 

17 Hunter Fan. On the hugger comment, we 

18 recommend that you would adopt the Canadian 

19 method with a faux ceiling being used, the 

20 dimensions of which can be, you know, 

21 discussed, but I think right now it's a five22 by-five faux ceiling. 
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1 And then our comment on multi-mount 

2 fans being tested in the hugger configuration, 

3 we would argue against that because a large 

4 amount of the fans sold right now at retail are 

5 able to mount in a hugger configuration or a 

6 low-profile mount where you either remove the 

7 down rod or use a shorter down rod. And I 

8 think you would be falsely misleading because 

9 you're going to reduce the airflow by shrinking 

10 it up to the ceiling. So we would say you test 

11 at the down rod configuration that it's packed 

12 in with, and then, if necessary, on the CFM 

13 label on the box, you know, note that it was 

14 tested in a down rod configuration. I think 

15 that's it.

16 MR. BROOKMAN: That's it? Okay. 

17 Please look at the comment box, item 9, item 

18 10, and item 12. Additional comments on these? 

19 You didn't really set up -- 

20 DR. KANTNER: We didn't talk about 

21 item 12.

22 MR. BROOKMAN: Right. 
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1 DR. KANTNER: Item 12 is DOE 

2 requests information on the effects of testing 

3 ceiling fans in cylinders with diameters other 

4 than eight inches wider than the blade span and 

5 any comments on potential modification to the 

6 test procedure.

7 MR. BROOKMAN: Yes, Bill? 

8 MR. WALKER: Bill with Hunter Fan. 

9 We have our own test lab, so I just did a 

10 couple of tests before coming here with a 

11 cylinder, with a larger cylinder, and with no 

12 cylinder at all. And the variance from a 

13 ceiling fan, a 52-inch ceiling fan tested with 

14 a 60-inch cylinder, which is to spec, versus 

15 tested with no cylinder at all at high speed, 

16 that the CFM varied less than one percent. 

17 DR. KANTNER: Good to know.

18 MR. WALKER: Now, that's a very 

19 small sample size, and we should take it 

20 further to a larger sample size to see. But I 

21 think definitely you could relax the --

22 MR. BROOKMAN: The cylinder 
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1 requirement.

2 MR. WALKER: Yes.

3 MR. BROOKMAN: Okay.

4 MR. WALKER: But we need to test 

5 more --

6 MR. BROOKMAN: Okay.

7 MR. WALKER: -- to verify.

8 MR. BROOKMAN: Okay. And would you, 

9 that's your testing lab, correct?

10 MR. WALKER: That's correct.

11 MR. BROOKMAN: Would you speculate 

12 the other testing labs would come up with the 

13 same kind of experience? 

14 MR. WALKER: I don't see why not. I 

15 mean, our lab is to the DOE, I mean the ENERGY 

16 STAR that you see in the online ENERGY STAR 

17 manual, that's the lab. So each lab should be 

18 built to that same spec, so I don't see why 

19 they wouldn't get the same results.

20 MR. BROOKMAN: Okay. Joanna? 

21 MS. MAUER: Joanna Mauer. Just a 

22 question on how to test the multi-mount fans. 
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1 Has DOE looked into whether multi-mount fans 

2 that are kind of the more efficient models when 

3 tested in the kind of down-rod configuration 

4 also tend to be the more efficient models when 

5 tested in the hugger configuration? 

6 DR. KANTNER: DOE has not tested 

7 that yet.

8 MS. MAUER: Do any of the 

9 manufacturers have any input on -- 

10 MR. BROOKMAN: Okay. 

11 DR. KANTNER: And here are a few 

12 more potential issues for the test procedure. 

13 We've noticed that some ceiling fans have 

14 multiple fan heads, and then there's a question 

15 of how we should go about trying to test those 

16 fans. And right now DOE is considering trying 

17 to test only one fan head with the other fan 

18 head motors turned off and then treating that 

19 fan head like just a standard single ceiling 

20 fan. 

21 Another potential issue is for fans 

22 where the airflow is not directed straight 
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1 downwards. Some fans are set at an angle. And 

2 for those fans, DOE is considering a couple of 

3 different approaches: one, adjusting the fan 

4 such that the airflow is vertical, if that's 

5 possible; two, using an adjustable mount to 

6 achieve a vertical orientation; and, three, 

7 testing without changing the orientation of the 

8 fan so some of the airflow then might miss the 

9 test cylinder, but this would provide a 

10 conservative estimate of airflow efficiency.

11 DOE is also aware that there are 

12 some ceiling fans sold with combined heaters, 

13 and DOE tentatively plans to test with the 

14 heater switched off. 

15 Another potential issue is whether 

16 or not we should be testing in the reverse 

17 direction. Most fans are currently required to 

18 be able to operate in reverse. Right now, DOE 

19 anticipates that fans are primarily used in the 

20 forward direction and that efficiency in 

21 forward and reverse are likely to be 

22 correlated, which may mean that it's not 
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1 necessary to test in reverse. But we would 

2 welcome any comments or feedback or data that 

3 gets at this idea of whether efficiency in 

4 forward and reverse are, in fact, correlated.

5 MR. GATTO: Dave Gatto with 

6 Westinghouse. I'm sorry, Dick. On this 

7 particular topic, I've only had a few days. I 

8 don't really have any empirical data either 

9 way. We agree that it's likely that in the 

10 reverse position, which we don't believe is a 

11 high percentage of the fan's actual use by 

12 consumers, we believe it's going to be a fairly 

13 consistent correlation, but we've done no 

14 testing at all to be able to back that up.

15 MR. BROOKMAN: That's helpful still. 

16 Thank you. Okay. So when are you going to 

17 have that data? 

18 MR. GATTO: That's a good question. 

19 We're looking into -- again, we're still 

20 reviewing the document. It's part of why I 

21 haven't had a lot of comments here. I've only 

22 had a few days with it. But at the same time, 
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1 we are looking at different things that we're 

2 going to need to do, along with ALA, to provide 

3 information back to the DOE. We know that 

4 there's a lot of information that you'll need. 

5 And as Dick had mentioned, we've kind of all 

6 agreed that we're going to work together to 

7 provide as much of it as possible.

8 MR. BROOKMAN: Okay. Yes, Dick?

9 MR. UPTON: A general comment I'm 

10 hearing from everybody is reverse testing is 

11 just not necessary. 

12 MR. BROOKMAN: Okay, okay. And also 

13 item 14, DOE requests comments on its approach 

14 to testing ceiling fans where the airflow is 

15 not directed vertically. Did we cover that? I 

16 don't think so. Nathan? 

17 MR. FRAMPTON: Again, our position 

18 is that we believe the test procedure could be 

19 improved. We just need a lot more time to come 

20 up with a recommendation. We also agree that 

21 testing in reverse is not necessary.

22 MR. BROOKMAN: So I believe that's 
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1 the third time you've said a lot more time. So 

2 how much is a lot more time? A lot. The 

3 industry comments a lot. Is it three months, 

4 six months?

5 MR. FRAMPTON: You know, I believe 

6 with the state of the economy and our industry, 

7 I think we need something, you know, like one 

8 to two years to test that. 

9 MR. BROOKMAN: Ashley? 

10 MS. ARMSTRONG: Okay. So I don't 

11 think -- I mean, that's fair, although the 

12 statute requires us to finish this by December 

13 2014. So with that being said, that's a final 

14 rule fully adopted, done. No amendments after 

15 that. So, obviously, proposals will have to be 

16 well before that, and I think our target, I 

17 can't remember what Lucy showed at the very 

18 beginning of the slide, but our target for a 

19 proposal is this year. So we hope that, while 

20 we agree that there's going to be a lot of 

21 things that need to be fleshed out over the 

22 next year and a lot of ideas generating and 
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1 some testing both done on the part of you guys 

2 and ourselves, we hope that we can do this, you 

3 know, start today and start to work through 

4 some of these issues, including feedback, 

5 realizing that the Department is moving forward 

6 and I'm hoping we can move forward with you 

7 guys. 

8 MR. BROOKMAN: Okay. Dick?

9 MR. UPTON: That deserves a 

10 response. A week ago Monday, we got a 100-page 

11 document for the first time. I personally am 

12 not sitting waiting for DOE or EPA or any other 

13 entity of federal government or state 

14 government to put a 100-page document on and 

15 tell me that I've got a week and everybody 

16 that's a member of ALA has a week to respond. 

17 Now, John, to his credit, gave us more time, 

18 and I thank you again formally. But we don't 

19 know how much time this is going to take. 

20 We've just gotten it. When you hear us say 

21 it's going to take more time or a lot more 

22 time, we've only had two conference calls that 
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1 we've been able to pull together quickly, and I 

2 think we're going to have to have some time to 

3 be able to tell you what our response time can 

4 be. You may not like it, and you may want to 

5 tell us speed it up, and then we can review to 

6 see what we can do to speed it up. But we just 

7 need some time to get through it to the point 

8 we can give you an honest and intelligent 

9 answer, and we just don't know that yet. But 

10 if you press us to say how much time, then a 

11 response that you got from Nathan Frampton is 

12 articulate. 

13 So let's just kind of cool the jets 

14 a little bit on what the time frame is going to 

15 be. We will do our due diligence of pulling it 

16 together as best we can and as rapidly as we 

17 can. The response I personally received from 

18 the industry in coming together on a two-day 

19 announcement for a conference call, we had 18 

20 companies involved out of 18 -- excuse me. We 

21 had one not there because the key party we 

22 needed was in China. And we've got a couple of 
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1 people who would have been and should be at 

2 this meeting, but one is in China and one has 

3 got a major industry issue for his company, he 

4 has to be where he is. 

5 But we will get back to you promptly 

6 and quickly. And I think the first thing we 

7 need to do is just tell you how long it's going 

8 to take us to get there, and I don't know that 

9 answer yet. 

10 MR. BROOKMAN: Okay.

11 MR. UPTON: Thank you.

12 MR. BROOKMAN: Colleen, as you look 

13 at these comment boxes, is there anything you 

14 wish to call out to see if you can get any 

15 additional information, or did we cover it? 

16 DR. KANTNER: I think we might have 

17 skipped item 13 on testing ceiling fans with 

18 multiple fan heads. 

19 MR. BROOKMAN: That's what I 

20 thought, too. So do we have comments on that? 

21 Joanna? 

22 MS. MAUER: Joanna Mauer. I guess 
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1 I'm just wondering could you have a situation 

2 where you had a ceiling fan with multiple fan 

3 heads where the individual fan heads had 

4 different efficiencies? Could you have fan 

5 heads with different motors? 

6 DR. KANTNER: Yes, that seems 

7 conceivable. 

8 MR. BROOKMAN: Nathan, you want to 

9 try that? 

10 MR. FRAMPTON: Yes, it's 

11 conceivable. Again, we would need time to 

12 figure out the best test, and we will do 

13 everything we can to figure it out as fast as 

14 we can. 

15 MR. BROOKMAN: Yes, good. In 

16 Ashley's defense, she just wanted to make sure 

17 you were really clear about the deadlines 

18 they're facing. I think everybody understands 

19 that now. Yes, okay. Okay. Then we're going 

20 to move on. 

21 DR. KANTNER: So, previously, there 

22 was only a design standard for ceiling fans and 
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1 no performance standard. Now that we are 

2 considering a possible -- 

3 MR. BROOKMAN: I believe we skipped 

4 one.

5 DR. KANTNER: Oh, sorry. Here we 

6 go. Sorry about that. So there's one last 

7 issue for active mode test procedure, and this 

8 is the question of how many fan speeds we 

9 should be testing at. So the current test 

10 procedure allows for testing at all available 

11 fan speeds, and ENERGY STAR requires 

12 certification at three fan speeds corresponding 

13 to low, medium, and high. So DOE could 

14 conceivably test at one, three, or multiple 

15 speeds, depending on how well those speeds 

16 represent the overall ceiling fan usage.

17 And so we have a couple of comments 

18 just on this. First, DOE seeks comment on the 

19 possibility of testing at one or multiple fan 

20 speeds, and DOE seeks input on the amount of 

21 time spent at each fan speed. 

22 MR. BROOKMAN: Nathan? 
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1 MR. FRAMPTON: Yes. In the short 

2 amount of time that we've had to prepare, we 

3 actually pulled via social media what fan speed 

4 consumers use. And by and large, most 

5 consumers run their fans on low and medium. 

6 Most consumers do not run their fans on high.

7 MR. BROOKMAN: Okay. That's 

8 helpful. Additional comments? Joanna, here. 

9 MS. MAUER: Joanna Mauer. I think 

10 we definitely consider, definitely encourage 

11 DOE to adopt a test procedure that tests at 

12 more than one fan speed, especially to capture 

13 variations in motor efficiencies at different 

14 speeds. 

15 MR. BROOKMAN: Dick? 

16 MR. UPTON: A question for you. I 

17 thought Nathan was creative in reaching out on 

18 social media to try to get a response on where 

19 is the fan operated. What's a reasonable way 

20 for industry to try to get a response on that? 

21 Because, for example, ALA has a hundred 

22 thousand people, consumers that we send a 
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1 particular newsletter to, and we know it's read 

2 by those hundred thousand. There's a hundred 

3 thousand going out that way. 

4 We also have members who have a 

5 significant internet presence, and we could go 

6 to their customers. You know, we're talking 

7 about millions in that circumstance. But is 

8 that an acceptable research package for us 

9 going to consumers and getting consumer 

10 feedback on how you're operating your fan? 

11 MR. CYMBALSKY: John Cymbalsky, DOE. 

12 I think it's great that we don't have to do it 

13 because that would be a PRA involvement with 

14 doing a survey. But, absolutely, you should 

15 get any information you can gather and enter it 

16 as a public comment and just describe how you 

17 collected the data and -- 

18 MR. UPTON: That seems reasonable?

19 MR. CYMBALSKY: Sure. It's as 

20 reasonable as any other approach.

21 MR. UPTON: Thank you. 

22 MR. BROOKMAN: I'm wanting to make 
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1 sure we've covered as much of this as we can, 

2 both 16 and 17.

3 DR. KANTNER: So 17 is on how to 

4 define high, medium, and low speeds for those 

5 fans that have more than three speeds or 

6 variable speed controls. 

7 MR. BROOKMAN: Is there any kind of 

8 standard definition? No? Nathan? No comment 

9 at this time. Okay, okay. 

10 DR. KANTNER: Okay. So, thus far, 

11 we've been talking about issues for active 

12 mode, but we must also, by law, address standby 

13 and off mode. So far, DOE's impression has 

14 been that only ceiling fans with a remote 

15 control appear to have standby mode energy 

16 consumption, and that no off-mode energy 

17 consumption is anticipated, though, of course, 

18 we welcome any comments you might have on that. 

19 

20 MR. TURNER: David Turner with 

21 Hunter. Are we asking what the standby power 

22 consumption is currently? I think that was 
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1 item 19, but I don't know if that was jumped 

2 over or --

3 DR. KANTNER: Yes, we'd welcome any. 

4 MR. TURNER: So we did some quick 

5 data study before we came, and it's about 1.4 

6 watts would be your standby mode with a remote7 controlled ceiling fan. In the off or if you 

8 turn the fan off, the standby power is 1.4 

9 watts. 

10 DR. KANTNER: Great, thank you. 

11 MR. TURNER: It's very minimal. 

12 MR. BROOKMAN: Thank you, David. 

13 Okay. 

14 DR. KANTNER: Okay. So, previously, 

15 there were only design standards for ceiling 

16 fans, and now that we're considering a 

17 performance standard for ceiling fans, the 

18 metric that we are considering regulating is 

19 airflow efficiency, which is in cubic feet per 

20 minute per watt. 

21 If technically feasible, DOE also 

22 plans to incorporate standby mode power, when 
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1 applicable, for ceiling fans into an integrated 

2 metric that addresses overall energy 

3 efficiency. So one possible approach would be 

4 to combine the energy consumed in standby and 

5 active mode according to the operating hours 

6 spent at each mode in an equation similar to 

7 the one listed here. And then DOE requests 

8 feedback on its planned approach to use an 

9 integrated energy-efficiency metric for ceiling 

10 fans. 

11 MR. BROOKMAN: David, do you have 

12 something? 

13 MR. TURNER: David Turner. Given 

14 how low the standby power is, we believe the 

15 metrics probably aren't necessary. If it has 

16 to be, if it has to come to fruition, as long 

17 as the standard is clearly defined on the 

18 front-end and everybody knows what the 

19 variables are and are the same for every 

20 region, every manufacturer, then everybody is 

21 on equal footing and it's fine. But because of 

22 how low the standby power is, we don't believe 
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1 the metric is necessary. 

2 MR. BROOKMAN: Okay, thank you. 

3 DR. KANTNER: Okay. Next, I'd like 

4 to introduce my colleague, Karina Garbesi, 

5 who's going to be talking about ceiling fan 

6 light kits. 

7 DR. GARBESI: Thanks, Colleen. 

8 Again, my name is Karina Garbesi, and I'm from 

9 Lawrence Berkeley Lab. I was going to start by 

10 talking about the current test procedures and 

11 metrics, which I'm sure most of you are 

12 familiar with, and the fact that they differ by 

13 product class. There are currently three 

14 product classes of ceiling fan light kit. 

15 Those with medium screw bases are required 

16 under the standard to be packaged with compact 

17 fluorescent lamps that meet the ENERGY STAR 

18 Version 3.0 specs or lamps that have equivalent 

19 efficacy. Therefore, the efficiency metric is 

20 lamp efficacy, in lumens per watt, and the test 

21 procedures reference the IES LM-66 for that.

22 For class two products, what we're 
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1 referring to as class two, those that have pin2 based sockets for externally ballasted 

3 fluorescent lamps, those light kits are 

4 required to meet the requirements of ENERGY 

5 STAR for residential light fixtures, Version 

6 4.0; and, specifically, all sockets are 

7 required to be packaged with lamps again.

8 Effectively, this is meaning, given 

9 the way that ENERGY STAR spec was structured, 

10 again, that the lamps have to meet a minimum 

11 efficacy requirement in lumens per watt and LM12 9 is referenced on that one. There's also, 

13 there's an exception for outdoor fixtures, 

14 hence outdoor light kits, which can comply by 

15 including automatic daylight shutoff and motion 

16 sensor controls.

17 Then what we're calling class three 

18 is all other ceiling fan light kits that don't 

19 belong to the class one and two. The standard 

20 requires that they shall not be capable of 

21 operating with lamps that total more than 190 

22 watts, and they're also required to be packaged 
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1 with all of the sockets filled.

2 Effectively, the metric on that then 

3 is wattage, but there are no test procedures 

4 specified. It's been interpreted as a design 

5 standard.

6 Now, I hope I have the magic here 

7 for changing the -- firmness is required, so I 

8 succeeded in my first hurdle. 

9 In terms of the changes that DOE is 

10 considering for test procedures and metrics for 

11 ceiling fan light kits, DOE has been 

12 considering adopting a single metric for all 

13 light kits to simplify the whole testing 

14 requirements, and that would simply be lamp 

15 efficacy. That would be applicable to lamps 

16 that are packaged with the devices when they're 

17 sold.

18 There's two approaches that are 

19 being considered to utilize that metric. The 

20 first approach is, essentially, what's 

21 happening now for those class one and class two 

22 devices, which is simply that the lamps that 
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1 are packaged have to meet a minimum efficacy 

2 requirement. The other approach is, 

3 essentially, to create a ceiling fan light kit 

4 efficacy which is the average of all the lamps 

5 that are packaged, the average efficacy, which 

6 is, essentially, total lumens out divided by 

7 total watts in. 

8 The virtue of the former is it is 

9 simpler. And the virtue of the latter is that 

10 it allows somewhat more flexibility in meeting 

11 the standard and also it gives the public an 

12 indication of the actual performance of the 

13 light kit, rather than just having met a 

14 minimum standard. So those that are more 

15 efficacious are clearly labeled as such or 

16 indicated as such.

17 The DOE test procedure in this case, 

18 in both cases, would reference the existing DOE 

19 test procedure for covered lamps. And if there 

20 wasn't a test procedure for lamps, they were 

21 not covered, then the DOE test procedure would 

22 reference the appropriate industry test 
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1 procedure, indicated at the bottom of the 

2 slide. 

3 In the current test procedures, 

4 there aren't requirements for LED lamps or 

5 integrated LED yet specified. For those with 

6 inseparable solid-state lighting, also known as 

7 integral LED lighting, DOE is considering two 

8 possible approaches. One of them is the 

9 current approach that's taken by ENERGY STAR 

10 Luminaires, which I should indicate is not the 

11 ENERGY STAR fixtures requirement. This is 

12 different, the current ENERGY STAR, from the 

13 one that's referenced in the DOE standards. 

14 That requires luminaire testing using LM-79 if 

15 you are a light kit that has directional 

16 lighting. 

17 An alternative approach would be to 

18 test the light engine using LM-79. The virtue 

19 of that approach is that it puts it on a level 

20 playing field with LED lamps that might be used 

21 for class one products. 

22 As Colleen already mentioned, we're 
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1 required to incorporate standby mode and off2 power mode and -- 

3 MR. BROOKMAN: Let's pause.

4 DR. GARBESI: Okay.

5 MR. BROOKMAN: Go back one.

6 DR. GARBESI: Go back one?

7 MR. BROOKMAN: Yes. Because there's 

8 quite a bit of content there. Terry? 

9 MR. MCGOWAN: Terry McGowan of 

10 American Lighting Association. The problem 

11 here that we see is a major one, and that is 

12 the difference between using the efficacy of 

13 the light sources and testing for the efficacy 

14 of the luminaire. That is a very dramatic 

15 increase in cost to do testing of the luminaire 

16 itself, and, particularly with the number of 

17 luminaire types and configurations that are 

18 used with fans, this would be a tremendous 

19 difference in the complexity, as well as the 

20 cost, of testing. So we would certainly 

21 recommend that the efficacy of the light 

22 sources be the metric here, rather than the 
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1 efficacy of the luminaire. 

2 MR. BROOKMAN: Thank you. Other 

3 comments on this? 

4 MR. GATTO: Dave Gatto with 

5 Westinghouse.

6 MR. BROOKMAN: Yes. 

7 MR. GATTO: We're questioning the 

8 need for efficacy testing where the products 

9 that are already -- so we have ENERGY STAR 3.0 

10 for included screw-based CFL. We have 4.0 for 

11 pin-base ENERGY STAR light kits, and then we 

12 have in EPAct max wattages for both candelabra 

13 and intermediate base. But we also have EISA 

14 which is impacting the candelabra base lamp. 

15 So the efficacy standards, if you're going to 

16 test the light kit, are on top of testing that 

17 we're already doing on the light bulb, which is 

18 in line with DOE and is continuing. We're not 

19 really done with rulemaking on incandescent and 

20 housing products. 

21 So we just want to propose that 

22 adding cost and test procedures to a product 
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1 where the only power use or primary power use 

2 is coming from a product that is already 

3 regulated may just be, just may be unnecessary. 

4 MR. BROOKMAN: Ashley? 

5 MS. ARMSTRONG: So on the previous 

6 slide -- sorry. On the previous slide, I think 

7 what we tried to distinguish at the bottom is 

8 that, for the ceiling fan light kit test 

9 procedure, what we're considering is that if 

10 it's already a DOE-covered lamp itself, you 

11 could rely on that test procedure in testing 

12 it. In other words, you wouldn't have to 

13 retest just because it's being packaged with a 

14 ceiling fan light kit. However, we recognize 

15 that there's a variety of types of other lamps 

16 that aren't regulated by the Department that 

17 may go in to ceiling fan light kits. Those are 

18 the ones we would pick up for testing 

19 separately. You could opt to do testing 

20 separately; I don't know why you would. But 

21 you could rely, just like you can now, on the 

22 lamp data already generated for either other 
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1 programs or federal purposes. 

2 MR. GATTO: Dave Gatto. Thank you. 

3 That clarification helps, at least in making 

4 us feel more comfortable that you're going to 

5 pick a standard that, if we're already 

6 compliant with it, we won't have to comply 

7 twice. Thank you. 

8 MR. BROOKMAN: Dick? 

9 MR. UPTON: Some background on EPA 

10 and when they got this program done. We helped 

11 host that meeting with NEMA and argued very 

12 strongly that, we said it was decorative and 

13 non-decorative. EPA came out with direct and 

14 non-direct on their light source and concurred 

15 with us on the photometric testing not being 

16 done. So if government is going to be unified, 

17 I would think you'd want to follow that point.

18 Then I'd like to raise a question. 

19 Why move away from a design standard to a 

20 performance standard? 

21 MR. BROOKMAN: Ashley? 

22 MS. ARMSTRONG: Okay. I'm guessing 
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1 it's for the wattage that you're asking about? 

2 MR. UPTON: No, I'm asking why move 

3 away from a design standard to a performance 

4 standard. 

5 MS. ARMSTRONG: The other two are 

6 already efficacy standards. Are we talking --

7 MR. UPTON: Anything.

8 MS. ARMSTRONG: Well, for light 

9 kits, we already have standards, so we're 

10 triggered to review those by the statute. For 

11 two of them, they're performance-based 

12 standards, for another one there's a wattage 

13 standard, depending on the socket type. For 

14 those, you know, that issue is out for comment. 

15 I mean, we're considering moving them all for 

16 ease to an efficacy-based standard, partially 

17 because it gets at your wattage limiter issue, 

18 which you've asked us to deal with. That is an 

19 easier way for us to migrate. So that is what 

20 you should think about when you're considering 

21 whether we should keep in that design standard 

22 which includes that wattage limiter or move to 
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1 a efficacy standard. 

2 MR. TURNER: David Turner. But as I 

3 understand what the framework document said is 

4 that the efficacy standard of the baseline 

5 would be the max efficiency of the first two 

6 classes. So it would be, it would basically 

7 have to be an efficacy greater than or equal to 

8 a CFL; is that correct? 

9 MS. ARMSTRONG: I don't think that's 

10 yet to be established yet. I think we are 

11 considering, the way we do our analysis is we 

12 can't backslide on those two classes, so, no, 

13 we couldn't adopt a less efficacious standard 

14 for medium screw-based and pin-based sockets. 

15 It's already established. It's a congressional 

16 standard. We can't change that one. 

17 Now, for the other ones, where we 

18 end up will largely depend on the cost-benefit 

19 analysis. And so we would look at the variety 

20 of types. It may end up something at 

21 fluorescents, it may end up somewhere 

22 different. 
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1 MR. TARR: Jeremy Tarr with Hunter 

2 Fan. Is there any concern that consumers will 

3 not have a choice of, depending on the outcome 

4 of the ruling, consumers would not have a 

5 choice of the bolt that would be going into 

6 their ceiling fan? If the efficacy standards 

7 are set at the CFL level, you're basically 

8 mandating that we include CFLs in ceiling fans; 

9 is that correct? 

10 MS. ARMSTRONG: Yes, yes, if we can 

11 cost justify that level. 

12 MR. GATTO: Dave Gatto with 

13 Westinghouse. A concern we'd have with that is 

14 utility for the consumer, particularly with 

15 dimming. The CFL dimming is not and probably 

16 never will be at a level the consumers are 

17 happy with it. So the concern, we'd kind of go 

18 back to the beginning that we're now going to 

19 create a standard that would drive consumers 

20 away from using an energy-efficient product and 

21 revert back to air conditioning and a standard 

22 luminaire. 
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1 MR. BROOKMAN: Yes. Okay. Nathan? 

2 MR. FRAMPTON: We have the same 

3 concern, and I think it's a dangerous path to -

4 - for example, if we're going to require ENERGY 

5 STAR products, I think that starts to dilute 

6 ENERGY STAR.

7 MR. BROOKMAN: Ashley? 

8 MS. ARMSTRONG: So this is Ashley. 

9 So I'm going to make a distinction here. The 

10 existing standards require ENERGY STAR products 

11 for medium screw-based and for pin-based. 

12 Currently, the only requirement for all other 

13 types of bases would be 190-watt requirement, 

14 right? Which we've interpreted as requiring 

15 some type of wattage-limiting device for you to 

16 meet shall not be capable of operating, right? 

17 So the Department would do a cost-benefit 

18 analysis to come out with an efficacy level. 

19 Now, that being said, we have certain 

20 restrictions like consumer utility that we have 

21 to take into account when we do that analysis. 

22 
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1 So it's not clear -- we wouldn't 

2 just say, you know, the standard is ENERGY STAR 

3 across the board going forward. We would come 

4 out with a variety of levels based on our 

5 analysis, based on product class, based on 

6 feedback from you guys, based on our interviews 

7 with manufacturers, based on feedback from 

8 interested parties across the board. And where 

9 that may end up, we don't know at this point. 

10 It's now a matter of should we do that analysis 

11 as an efficacy, or should we continue the 

12 wattage?

13 MR. BROOKMAN: Dick? 

14 MR. UPTON: If I understand the 

15 directive in EPAct 5, every seven years DOE 

16 will review, which is where you are. But 

17 there's nothing here that I see that says it's 

18 your responsibility to design the ceiling fan 

19 to the point there probably should only be one 

20 company involved. 

21 The marketplace, don't forget, and 

22 these people are going to work together, but 
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1 they're going to put together different 

2 products in different ways that they think is 

3 going to be more appealing to the consumer, 

4 whether that's a less expensive product or a 

5 product that has better quality services or 

6 systems or whatever. That's why my question is 

7 why are we moving away from a design standard, 

8 and you're talking about real costs, and I 

9 think we've now hit on a space where the 

10 industry will really be working pretty hard and 

11 I would hope you'd keep an open mind to that 

12 degree that, because you need to review it, 

13 thank you for reviewing, but it doesn't mean 

14 that what you've done today is wrong.

15 MS. ARMSTRONG: So I guess my 

16 question to you guys, just to follow-up and to 

17 answer this, is are you in favor of retaining a 

18 wattage requirement and reviewing that, rather 

19 than moving to efficacy? 

20 MR. TURNER: It all depends on what 

21 that efficacy is. Well, no, we're with you. 

22 We don't know the answer to that question 
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1 either until the previous question is answer. 

2 If the efficacy is CFL or above, then that 

3 limits functionality, it limits consumer 

4 choice, so then, at that point, maybe wattage5 limiter looks more enticing. But, you know, we 

6 don't like packing in the wattage-limiters, but 

7 it is what it is. So if there's another 

8 option, you know, we'll certainly look at it.

9 MR. BROOKMAN: So that was David, 

10 and now to Terry. 

11 MR. MCGOWAN: Yes. Terry McGowan. 

12 Yes, we like the design standard because it is 

13 simple and it's so easy to implement. The 

14 problem is the power limiter was the wrong 

15 design standard, and so what we would prefer to 

16 see is a socket and number standard so we would 

17 limit the wattage by the number of sockets 

18 using regulated lamps. That's a very simple 

19 alternative and can be done by inspection.

20 MR. BROOKMAN: Ashley? 

21 MS. ARMSTRONG: Thank you. 

22 MR. BROOKMAN: Nothing additional at 
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1 this time? Okay. Well, thank you, Terry. 

2 That was helpful. Bill, do you want in here? 

3 Jeremy.

4 MR. TARR: This is Jeremy Tarr with 

5 Hunter. I appreciate the consideration, but I 

6 think, from our side of the table, we want to 

7 make sure that that really is considered. 

8 Wattage limiters are a piece of cost, but they 

9 are a less expensive alternative to CFL bulbs. 

10 They provide more options for consumers in 

11 terms of lower product cost, in terms of 

12 quality of the light, something they're 

13 familiar with, features such as dimmability. 

14 You know, with the current bulb regulations 

15 that are in place, we think a standard of three 

16 sockets or less shouldn't require a limiter. 

17 You know, and if it's a four-socket fan, I 

18 don't think anyone has any major objections to 

19 continuing with some sort of limit. You know, 

20 I think we're willing to work there, but we 

21 have the interest of consumers at heart. We 

22 really want to keep that functionality for the 
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1 consumers, and we really want to improve their 

2 product experience. 

3 Limiters are an electronic device, 

4 and they will fail. That's a matter of 

5 concern. So, you know, anything we can do to 

6 improve the use of ceiling fans will save 

7 energy. If we can push the use of ceiling 

8 fans, the adoption of ceiling fans, that will 

9 save energy. Thanks. 

10 MR. BROOKMAN: I think we've covered 

11 this one. Let's move on, and we'll get a 

12 chance when we get to the comment boxes to see 

13 if we've covered it sufficiently. Karina? 

14 DR. GARBESI: All right. As Colleen 

15 has already mentioned, we're required to 

16 address standby mode and off-power mode in the 

17 test procedures. DOE, again, assumes that 

18 there is no power consumption, no standby power 

19 consumption, in off-mode, and that only light 

20 kits with remote controllers would have standby 

21 mode energy consumption.

22 DOE is tentatively considering that 
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1 if the fan and the light kit share a remote 

2 then the power consumption would be attributed 

3 to the fan and not the light kit. And at this 

4 point, DOE isn't aware of any ceiling fan light 

5 kits that do have, you know, standby and remote 

6 where that is not shared. 

7 So turning to the items for comment, 

8 item 23, DOE is requesting comments on its 

9 proposal to use luminous efficacy as an 

10 efficiency metric. I think maybe we discussed 

11 that one adequately. Everyone seems to be 

12 smiling and nodding. Moving on then.

13 Item 25, DOE requests information on 

14 the existing and/or future availability of 

15 light kits with inseparable LED lighting 

16 components. 

17 MR. BROOKMAN: Can you comment on 

18 that one? They're everywhere else. 

19 MR. TURNER: David Turner with 

20 Hunter. Item 27 has total lamp lumens divided 

21 by total input wattage. Should it be just 

22 total lamp input wattage included in the 
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1 definition? All right. 

2 DR. GARBESI: We're okay on that one 

3 then? Okay. Going on.

4 MR. BROOKMAN: Hang on a second. 

5 Did we get a comment on LEDs in item 25? No? 

6 Nothing there. What about 29? Did we cover 

7 that one? 

8 DR. GARBESI: Not yet. So DOE is 

9 also requesting feedback on the approach to 

10 attribute all of the standby power to fans if 

11 the remote is shared between the fan and the 

12 light kit. It looks like agreement on that 

13 one. Okay. So I'm going to --

14 MR. BROOKMAN: Dave? No, okay.

15 DR. GARBESI: All right. Then I'm 

16 going to turn it back over to Colleen Kantner.

17 MR. BROOKMAN: Yes, let's take a 

18 break. We've made good progress. It's now 

19 almost 10:45. Let's take a 15-minute break, 

20 which means we'll resume at 11. For those of 

21 you who are not familiar with the building, you 

22 must wear a visitor's badge or some form of 
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1 identification that the Department likes while 

2 you're in the building. There are restrooms at 

3 both ends of the hall. There's a coffee shop 

4 on the ground floor. Take the elevator down to 

5 the ground floor and go in that direction. 

6 It's just below us on the other side of the 

7 hallway.

8 Please, if you're going to go get 

9 coffee, do that quickly. Sometimes, it takes a 

10 while. And we'll resume at 11. We've covered 

11 a lot of good ground already. We'll continue 

12 doing that when we resume at 11 right here. 

13 (Whereupon, the foregoing matter 

14 went off the record at 10:43 a.m. and went back 

15 on the record at 11:00 a.m.)

16 MR. BROOKMAN: So as a housekeeping 

17 matter, welcome back, everyone. I guess we 

18 uncovered what was causing our internet feed to 

19 go in and out, so we've corrected that we 

20 think. So thanks for those of you who are 

21 hanging with us on the internet.

22 The Department has provided a 
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1 photocopy of the business cards of everyone 

2 here present. So, yes, that's a convenient 

3 thing to have done.

4 We're going to proceed. We're going 

5 to be talking about the preliminary analyses 

6 segment, market and technology and back to 

7 Colleen.

8 DR. KANTNER: I'm Colleen Kantner. 

9 So whenever DOE goes through the standards 

10 rulemaking process, we go through several 

11 analyses that Lucy introduced briefly earlier. 

12 And the first one we undertake as part of the 

13 preliminary analysis is the market and 

14 technology assessment. 

15 The purpose of the market and 

16 technology assessment is to determine product 

17 classes and identify technology options to 

18 improve ceiling fan and CFLK efficiency. To do 

19 this, DOE will characterize ceiling fan and 

20 CFLK markets and look into manufacturers, 

21 shipments, and trends, and identify 

22 technologies that could improve efficiency.
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1 So one of the main results of the 

2 market and technology assessment is the 

3 establishment of product classes, each of which 

4 is subject to its own standard. Currently, 

5 there is only a single product class for 

6 ceiling fans. 

7 As directed by EPCA, DOE establishes 

8 product classes based on three criteria: one, 

9 the type of energy used; two, the capacity of 

10 the product; and, three, any other performance11 related features that require different 

12 standard levels, such as features affecting 

13 consumer utility. 

14 So in the case of ceiling fans, we 

15 believe that all ceiling fans use electricity, 

16 so the same type of energy. And we plan to, 

17 we're considering handling capacity, as will be 

18 described in the engineering analysis in a 

19 little bit. So it seems that, in developing 

20 product classes, this last criteria on features 

21 affecting functionality seems to be the most 

22 important.
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1 So based on that, DOE is considering 

2 the following ceiling fan classes: indoor 

3 ceiling fans which, right now, would represent 

4 the bulk of the market; hugger ceiling fans 

5 which would be suitable for use in rooms that 

6 have low ceilings; highly-decorative ceiling 

7 fans for which air movement performance is a 

8 secondary feature; and outdoor ceiling fans 

9 which would be suitable for wet or damp 

10 conditions.

11 Moving on, next is the technology 

12 assessment in which DOE identifies technology 

13 options that can be used to improve efficiency 

14 for ceiling fans. And here is a list of 

15 preliminary technology options. We've grouped 

16 them into three categories. First, more 

17 efficient motors. You could have more 

18 efficient versions of the motors that are in 

19 most ceiling fans right now, direct-drive 

20 single-phase induction motors. You could have 

21 geared single-phase induction motors. You 

22 could have brushless DC motors. You could also 
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1 have three-phase induction motors. And for all 

2 of these, we welcome any additions that should 

3 be added to this list.

4 The second category is more 

5 efficient blades. You could have ceiling fans 

6 with fewer blades. You could have ceiling fans 

7 with twisted fan blades. You could have fan 

8 blades that were in the shape of an airfoil. 

9 You could have fan blades that had an 

10 attachment to them that increased airflow for a 

11 given a blade movement. And you could also 

12 have alternative blade materials.

13 The last category is ceiling fan 

14 controls, which would be something like an 

15 occupancy sensor. And this would reduce 

16 overall energy use, although DOE is not 

17 currently aware of any ceiling fans on the 

18 market that have occupancy sensors.

19 So now we have a few comments on the 

20 market and tech assessment for ceiling fans. 

21 So first is item 33, DOE welcomes comments on 

22 whether it should establish a separate product 
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1 class for hugger fans. 

2 MR. BROOKMAN: Let's do them one at 

3 a time. Comments on separate product class? 

4 What do you think? No comment here. Okay. 

5 DR. KANTNER: Item 34, DOE welcomes 

6 comments on whether it should establish a 

7 separate product class for highly-decorative 

8 fans for which air movement performance is a 

9 secondary feature. 

10 MR. BROOKMAN: I guess not yet.

11 DR. KANTNER: Okay. And item 35, 

12 DOE seeks input on whether the differences 

13 between the construction of outdoor and indoor 

14 ceiling fans warrant establishing a separate 

15 product class for outdoor ceiling fans. 

16 MR. BROOKMAN: Okay. Nothing.

17 DR. KANTNER: Okay. Up next is 

18 Karina Garbesi to talk about ceiling fan light 

19 kits. I'm sorry.

20 MR. TURNER: Will the definition of 

21 the damp and wet fall back to the UL definition 

22 or the -- 
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1 DR. KANTNER: Right, the safety 

2 rating. 

3 MR. TURNER: Okay. 

4 MR. BROOKMAN: And just, David, 

5 state that again. The safety rating for what? 

6 Bill?

7 MR. WALKER: This is Bill with 

8 Hunter Fan. Yes, it's UL 507 is the standard, 

9 and it defines damp and wet.

10 MR. BROOKMAN: Okay. 

11 MS. MAUER: This is Joanna. Sorry. 

12 Just one quick question. Is DOE considering 

13 any technology options for reducing standby 

14 power consumption in those ceiling fans that 

15 have standby? 

16 DR. KANTNER: We haven't been to 

17 this point, although we welcome any 

18 suggestions.

19 MS. MAUER: Okay. I don't have any 

20 specific suggestions.

21 MR. BROOKMAN: Terry? 

22 MR. MCGOWAN: Terry McGowan. Maybe 
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1 there should be a note added here that three2 phase is not normally available for the bulk of 

3 the ceiling fan market because it is 

4 residential, so three-phase is not normally 

5 encountered in residential facilities.

6 MR. BROOKMAN: Okay, thank you. 

7 DR. KANTNER: I think the 

8 understanding is that there's been improvements 

9 in the electronics that might allow for three10 phase motors in the future. 

11 MR. UPTON: Say that again. 

12 DR. KANTNER: There's been 

13 improvements in electronics that might make it 

14 financially feasible to have three-phase motors 

15 in the residential sector in the future.

16 MR. MCGOWAN: That would require 

17 homes being wired for three-phase power, which 

18 that isn't done at the present time except in 

19 multi-family buildings possibly.

20 DR. KANTNER: I think the idea is 

21 you would still be a single-phase coming out of 

22 the wall, but then you would have some sort of 
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1 electronics near the fan that would convert it 

2 to three-phase. 

3 MR. MCGOWAN: Oh, a phantom three4 phase --

5 DR. KANTNER: Exactly. 

6 MR. MCGOWAN: -- arrangement of some 

7 kind.

8 MR. BROOKMAN: Okay. Bill? Bill, 

9 do you wish to comment? 

10 MR. WALKER: Bill with Hunter Fan. 

11 For DC motors and for three-phase motors, you 

12 would have to have a control that converts it, 

13 and that's, you're talking reliability issues 

14 and cost and everything. 

15 MR. BROOKMAN: Okay. 

16 DR. KANTNER: That's right.

17 MR. BROOKMAN: But thanks for the 

18 clarification. Now we're moving on. Dick?

19 MR. UPTON: A quick question, if I 

20 may. I thought I heard you talking about 

21 motion detectors for ceiling fans. But I don't 

22 see the -- 
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1 DR. KANTNER: We said a possible 

2 technology option could be an occupancy sensor. 

3 MR. UPTON: Occupancy sensor maybe 

4 that's heat related, but certainly not a motion 

5 detector. I use my ceiling fan at night, and I 

6 don't want to have to wake up every 20 minutes 

7 to move my arm through the air to keep it 

8 going. 

9 MR. BROOKMAN: Okay. 

10 DR. KANTNER: So up next is Karina 

11 Garbesi. 

12 DR. GARBESI: Again, Karina Garbesi 

13 from Lawrence Berkeley Lab. So currently, as 

14 you already know, there are three product 

15 classes for ceiling fan light kits: those with 

16 medium screw-based sockets, those with pin17 based fluorescents that are externally 

18 ballasted, and all others. 

19 We can break up the ceiling fan 

20 market into light kits of the following types 

21 if we're concerned with energy efficiency22 related issues. We can break it up by light 
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1 source type: incandescent and halogens, compact 

2 fluorescent and LEDs. We can break it up by 

3 socket type. There's an enormous variety of 

4 socket types in existing light kits. There's a 

5 number of screw-based, a number of pin-based 

6 that are for externally ballasted lamps, there 

7 are bayonet-type connectors for internally 

8 ballasted lamps, and then there's non-socket 

9 types just coming on to the market, 

10 particularly those integral LED light kits.

11 We can also consider whether dimming 

12 controls are either packaged with or integrated 

13 into or left out of the light kit. There's 

14 very few on the market right now that actually 

15 do have them either packaged with or integrated 

16 into. 

17 Colleen already mentioned what the 

18 DOE's criteria are for establishing product 

19 classes, so I'll skip this piece. But DOE is 

20 considering combining or restructuring ceiling 

21 fan light kit product classes into some smaller 

22 number or some different arrangement of product 
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1 classes. 

2 In terms of the technology options 

3 for energy efficiency that DOE is considering, 

4 it's basically light source type. And that, of 

5 course, will depend on the product class, how 

6 much they can actually differ.

7 DOE does plan to take into account 

8 the fact that certain socket types can restrict 

9 the light source type that is used. For 

10 example, the GU-24 sockets, which there's been 

11 a lot of discussion over. 

12 So only one question here. We're 

13 requesting feedback on the possibility of 

14 combining or restructuring the product classes 

15 for light kits, especially on the possibility 

16 of consumer utility differences, and whether 

17 there are any other issues that we should 

18 consider and how many product classes should be 

19 created. So it's an open question. 

20 MR. GATTO: Dave Gatto with 

21 Westinghouse. We kind of covered this pretty 

22 in-depth earlier, and we kind of had said at 
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1 that point that we're open to, as long as 

2 utility for the consumer is considered, we're 

3 open to finding a way to go possibly from three 

4 to two classes. But we would strongly caution 

5 against going to a single class that would 

6 eliminate other technologies beyond currently 

7 CFL.

8 MR. BROOKMAN: Okay. Thank you, 

9 Dave. Thank you. Other comments here? 

10 Nothing additional. We're ready to move on.

11 DR. GARBESI: So back to Colleen 

12 Kantner.

13 DR. KANTNER: So the next analysis 

14 is the screening analysis. And in the 

15 screening analysis, DOE will screen out 

16 technology options based on four criteria. DOE 

17 will look at technological feasibility, and 

18 that is whether the technology is commercially 

19 available or in a working prototype. DOE will 

20 also look at practicability to manufacture, 

21 install, and service, meaning it should be 

22 possible to achieve mass production, as well as 
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1 reliable installation and servicing. And DOE 

2 will also look at adverse impacts on product 

3 utility or availability to consumers, as well 

4 as adverse impacts on health and safety. 

5 Up next, we have Aris Marantan to 

6 discuss the engineering analysis.

7 DR. MARANTAN: Thanks, Colleen. 

8 Good morning. I'm Aris Marantan. I'm with 

9 Navigant Consulting. After DOE conducts the 

10 screening analysis, all the technology options 

11 that remain are included in the engineering 

12 analysis for consideration. These become the 

13 design options that are used in the evaluation 

14 of the engineering analysis.

15 The purpose of the engineering 

16 analysis is to determine the relationship 

17 between cost and efficiency. Typically, what 

18 we see in the rulemaking is that, as efficiency 

19 improves, the cost of producing the product is 

20 increasing. And the engineering analysis 

21 really just describes the relationship between 

22 the cost and the efficiency. The engineering 
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1 analysis is also used as the basis for all the 

2 economic analyses downstream of engineering. 

3 DOE may determine an appropriate 

4 subset of classes to analyze, which we call the 

5 representative product classes. DOE may 

6 extrapolate results of the analyses for these 

7 representative classes to other product 

8 classes. For each representative class, DOE 

9 may analyze a subset of representative units: 

10 for example, different fan sizes or blade 

11 spans.

12 Once DOE has identified the cost 

13 efficiency relationships of these selected 

14 sizes, it's considering whether the results can 

15 cover the full range of blade spans for other 

16 sizes. This could result in a standard which 

17 is in the form of an equation that's based on, 

18 that is a function of size.

19 Okay. This slide gives a little bit 

20 more detail on the steps needed to conduct the 

21 engineering analysis. One of the first steps 

22 is to choose the representative product class 
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1 and size to be analyzed. Second, the baseline 

2 efficiency level is selected based on common 

3 features and bottom of market efficiencies.

4 Next, for each representative class 

5 and size, DOE identifies the efficiency and 

6 cost of more efficient units based on a 

7 combination of design option modeling, product 

8 testing, and teardowns. DOE then identifies 

9 the maximum technologically-feasible level or 

10 what we call the max-tech for each 

11 representative class and size. That provides 

12 the upper bound of the efficiency. 

13 Next, we develop the efficiency 

14 levels that range from the baseline all the way 

15 up to max-tech for each of these classes and 

16 sizes. And the end result of the engineering 

17 analysis is a set of price-efficiency curves 

18 for each class and fan size analyzed, and this 

19 takes the form of manufacturer selling prices 

20 versus efficiency.

21 For ceiling fans, the design option 

22 technologies look similar to the technologies 
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1 that we saw earlier in the market and tech 

2 assessment. You can see here that DOE is 

3 tentatively considering including, considering 

4 more efficient alternating AC motors, brushless 

5 DC motors, different fan blade shapes and 

6 materials, and different number of blades.

7 The manufacturer's selling price is 

8 based on the cost of the motor, the fan blades, 

9 and other hardware times the industry 

10 manufacturer markup. The component costs will 

11 be determined using a reverse engineering 

12 approach or product teardowns that we'll 

13 conduct. And the results of this cost 

14 assessment will be discussed with manufacturers 

15 during the engineering analysis interview 

16 process, so we welcome and encourage 

17 manufacturer feedback.

18 This is actually the next step in 

19 the rulemaking for us. After this public 

20 meeting comment period, we're going to be 

21 reaching out to manufacturers to conduct 

22 confidential manufacturer interviews, so this 
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1 is an important step because of all the talk 

2 we've heard about the cost-benefit analysis. 

3 This is your chance to give us your input on 

4 the costs involved with these design options, 

5 so we'd like to learn as much as we can and we 

6 welcome interaction with you during these 

7 interviews. 

8 Last, the industry-wide manufacturer 

9 markup will first be determined based on 

10 publically-available sources. This can include 

11 things such as the SEC 10-Ks and other 

12 publically-available data. 

13 What we then do is we take our 

14 publically-available information sources, 

15 aggregate that for the entire industry, and 

16 then discuss it with you during the 

17 manufacturer interview process. So we'll get 

18 your feedback on this industry aggregate 

19 number.

20 For ceiling fan light kits, DOE 

21 plans to consider more efficient lighting 

22 technologies when identifying higher-efficiency 
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1 levels: for example, incandescent, CFLs, LEDs. 

2 DOE is considering the following to develop 

3 the cost-efficiency relationship. The cost of 

4 the ceiling fan light kit includes the cost of 

5 the lamp, as well as the cost of any other 

6 components of the light kit. DOE does not 

7 believe that changing the lamp type will add to 

8 the cost of the remaining light kit components. 

9 And, finally, therefore, to isolate 

10 efficiency-related costs, DOE is considering 

11 only including the cost of the lamp and any 

12 lamp-specific parts, as necessary, in the 

13 analysis.

14 So with that, we have two items for 

15 discussion. The first one, item 47, DOE seeks 

16 comment on its proposed methods for determining 

17 costs associated with incremental efficiency 

18 improvements in both ceiling fans and ceiling 

19 fan light kits. 

20 MR. BROOKMAN: Comments here? 

21 MR. UPTON: Dick Upton. You're 

22 saying manufacturers' cost is based on the cost 
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1 of motor and blades and other hardware times 

2 the manufacturers' markup. There's certainly 

3 far more than those items built in that are 

4 costs for the manufacturer. He's got labor 

5 costs. He's got facility costs. He's got 

6 shipping costs. And then, you know, how are 

7 you going to make a differentiation between the 

8 manufacturer that is operating efficiently in 

9 his business and those that are not? Do you 

10 understand that? Are you going to take that 

11 into account, or do you just think you've only 

12 got those three items? 

13 DR. MARANTAN: We're going to take 

14 that into account. The direct production costs 

15 incorporate a lot of those labor costs that you 

16 discussed. We'll be presenting that to the 

17 manufacturers that we interview and discuss all 

18 the components that build up to the final 

19 component cost. 

20 MR. UPTON: The cost-benefit ratio 

21 is going to be very critical. Everybody, I 

22 think, would understand that. And there's 
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1 going to be more than these issues involved. 

2 Just so you're aware, we'll be working toward 

3 that end, and it's going to be a question we'll 

4 give to you for you to respond to us. Thank 

5 you. 

6 MR. BROOKMAN: Thank you. Are there 

7 still comments? David? 

8 MR. TURNER: David Turner. Can you 

9 describe a little more the manufacturing 

10 interviews and how they'll work and just a 

11 little more detail as to how you'll, what 

12 information you'll pass to us that you would 

13 need in return? 

14 DR. MARANTAN: Yes. The engineering 

15 analysis interviews start with a communication 

16 between manufacturers and DOE's consultants. 

17 What we try to do is schedule these interviews 

18 right after the comment period of the framework 

19 document, so after April 29th we can start 

20 scheduling or even before April 29th we can 

21 start scheduling interviews to happen after 

22 April 29th. So if you're interested, please 
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1 come see me during one of the breaks, and we 

2 can start that process.

3 Basically, what we try to do is 

4 develop an interview guide, a manufacturer 

5 interview guide prior to the interview itself. 

6 And we'll share that with you so you'll know 

7 the questions that we're interested in 

8 discussing prior to that day. 

9 We tend to typically come out to 

10 production facilities because we also are 

11 interested in seeing the manufacturer site. I 

12 recognize that that may be difficult in this 

13 case since production is overseas, but we do 

14 still try to visit in-person, at least, to 

15 conduct the interview. It's typically a whole 

16 day. It doesn't have to be, but it typically 

17 is when we have a plant tour, for example. And 

18 it's an exchange of information. You know, we 

19 try to give you as much information as we can 

20 on what we've already learned about the 

21 industry and manufacturing and components and 

22 technologies, and it's a way for us to get 
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1 information from you on what you're doing, as 

2 well.

3 We sign non-disclosure agreements, 

4 as well, since we're a contractor to the 

5 Department. So all of your information is held 

6 with us in confidence, and we try to aggregate 

7 data after all the interviews and make 

8 aggregate data available publically. 

9 MS. DEBUTTS: I just would like to 

10 add that, if you can't find Aris outside, you 

11 can always email me, you know, at the 

12 Department and say you're interested in those 

13 interviews, and I'll pass along the 

14 information. 

15 MR. BROOKMAN: Thank you, Lucy. 

16 Dick?

17 MR. UPTON: Dick Upton. To our 

18 people here, will we have industry members who 

19 will be reticent to participate in those 

20 discussions with DOE? To that end, make sure 

21 you let us know who the people are, the company 

22 names, to the point that ALA can help you by 
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1 alerting our members what's going to take place 

2 and they're legitimate people -- 

3 MS. DEBUTTS: Certainly. 

4 Absolutely, yes. 

5 MR. UPTON: I could see some, I can 

6 think of about four companies right now that 

7 would tell you to put it in your ear and 

8 they're not going to talk to you at all. And 

9 if you need that information, we could help you 

10 get that legitimized. 

11 MS. DEBUTTS: Great, wonderful. As 

12 Aris said, there's going to be confidentiality 

13 agreements, so the information should not be 

14 shared. And we would definitely welcome your 

15 help. 

16 MR. BROOKMAN: Okay. 

17 DR. MARANTAN: Okay. The second 

18 item is item 48, DOE welcomes comments on how 

19 ceiling fan efficiency varies with airflow 

20 capacity, motor type, blade span, number and 

21 design of blades, or any other parameter. 

22 MR. BROOKMAN: Can we comment on 
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1 this at this time? 

2 MR. TURNER: David Turner. For fan 

3 efficiency, the relationship among the 

4 variables listed is extremely complex, and 

5 they're all interdependent on each other. So 

6 there's not really a way to say it because you 

7 can make your blades longer but your efficiency 

8 might go down because you're putting more drag 

9 on the motor. So it's hard to comment on that. 

10 DR. MARANTAN: Okay. The last 

11 portion, DOE also seeks comments on how ceiling 

12 fan light kit efficiency varies with bulb type, 

13 number of bulbs, or any other parameter. 

14 MR. GATTO: Dave Gatto with 

15 Westinghouse. And, again, we kind of spent 

16 some time on light kits over there, so I won't 

17 belabor the point. The efficacy of the light 

18 kit typically is based on the lamp efficacy, so 

19 there isn't a whole lot more, you know, from a 

20 standards standpoint, I think, that we need to 

21 do. 

22 I did have a question on the prior 
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1 slide. DOE does not believe the changing of 

2 the lamp type will add to the cost, but then 

3 the next statement is cost of lamp and any 

4 lamp-specific parts, as necessary. So as long 

5 as it's clear that the changing of the lamp 

6 might add cost because you have, you know, 

7 power supply or other things, if it's an 

8 integrated LED, then we're in agreement with 

9 that. We just want to make sure it's clear 

10 that that first statement we wouldn't really 

11 necessarily agree with because if you just take 

12 a medium-based socket and put a CFL in, it 

13 works. But if you start to change socket 

14 types, then the cost can change. 

15 MR. BROOKMAN: Okay, thank you. 

16 Yes, Terry? 

17 MR. MCGOWAN: Terry McGowan. Let me 

18 point out that this last one here, when you're 

19 talking about light kit efficiency, many fans 

20 are chosen, sold, and designed not for lumen 

21 output but for appearance. So you're using a 

22 metric that nobody uses to evaluate in their 
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1 comparison shopping or their decision to buy 

2 it. So you're measuring something that isn't 

3 used as a metric in many types of light kits. 

4 MR. BROOKMAN: And that goes beyond 

5 the decorative category. 

6 MR. MCGOWAN: Well, if it's a 

7 decorative light kit and ceiling fan, the lumen 

8 output may be irrelevant to the way that 

9 product is designed or used or chosen by the 

10 consumer. 

11 MR. BROOKMAN: Okay. Thank you.

12 MR. MCGOWAN: In other words, I'm 

13 saying it's not a metric that should be used to 

14 evaluate that light kit.

15 MR. BROOKMAN: Okay. Thank you. 

16 MR. TARR: This is Jeremy Tarr with 

17 Hunter. To kind of follow up on what Terry is 

18 saying, as far as the fan design goes, there 

19 are certainly, and I know you'll find through 

20 your engineering analysis, there are certainly 

21 very efficient fan designs. Typically, you 

22 find those fans in warehouses. Those are not 
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1 residential designs. Those are not the fans 

2 that are sold every day to consumers that help 

3 offset their energy. 

4 So I understand we will find more 

5 efficient ways of doing things. But I'd just 

6 caution that just because it's the most 

7 efficient answer doesn't mean that it's the 

8 correct one. 

9 MR. BROOKMAN: Moving on. 

10 DR. MARANTAN: Thank you. Okay. 

11 Next will be Colleen Kantner on the markups and 

12 energy use analysis. 

13 DR. KANTNER: So as Aris said, up 

14 next is markups analysis. The purpose of the 

15 markups analysis is to relate manufacturer 

16 selling prices to end-user prices of products. 

17 And the first step is to identify distribution 

18 channels and estimate share of each channel in 

19 the aggregate sales volume.

20 So here you see two distribution 

21 channels that DOE has identified. First, the 

22 home improvement retailer distribution channel 
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1 where a product would move from manufacturers 

2 to home improvement retailer to the consumer. 

3 And there's also the electrical wholesaler 

4 distribution channel where a product would move 

5 from manufacturer to electrical wholesaler to 

6 contractor to consumer. And the idea is that 

7 we will estimate markups for each step along 

8 the distribution chain. 

9 MR. BROOKMAN: Dick?

10 MR. UPTON: Dick Upton. You 

11 eliminated the lighting retail store. And 

12 industry might be able to tell me better than 

13 I, but I'm under the impression they sell to 

14 more than electrical distributors. Am I nuts? 

15 

16 MR. TARR: There's not a great 

17 amount of market data available for that, but I 

18 think if we can make the distinction that 

19 potentially lighting showrooms and electrical 

20 distributors could be grouped as one class 

21 separate from home improvement retailers, I 

22 think that might be a cleaner definition and 
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1 still limit it to two channels. 

2 MR. UPTON: We just don't want to 

3 forget that. 

4 MR. TARR: Certainly not. Certainly 

5 not. 

6 MR. BROOKMAN: Okay. Thanks, 

7 Jeremy. 

8 MR. UPTON: One other quick comment. 

9 We've been in communications with Lowe's and 

10 Home Depot, and they're very critically 

11 interested in this issue. 

12 MR. BROOKMAN: Okay. Excellent. 

13 Thank you, Dick. 

14 DR. KANTNER: Okay. So next is the 

15 energy use analysis. The purpose of the energy 

16 use analysis is to identify how ceiling fans 

17 and CFLKs are operated by users and determine 

18 the energy-savings potential of more efficient 

19 designs. And this analysis will be used as an 

20 input to both the life cycle costs and payback 

21 period analysis, as well as the national impact 

22 analysis. 
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1 DOE plans to obtain data to develop 

2 a distribution of operating hours for ceiling 

3 fans and CFLKs by region: for example, census 

4 division. And data sources could include, for 

5 example, for ceiling fans, usage studies, 

6 regional residential utility monitoring 

7 studies, EIA's RECS. And for CFLKs, it could 

8 include, among other sources, DOE's 2013 

9 Residential Lighting End Use Consumption Survey 

10 and DOE's 2010 U.S. Lighting Market 

11 Characterization, as well as EIA's RECS.

12 We use the input power rating 

13 developed in the engineering analysis, and then 

14 we multiply that by the annual operating hours 

15 to determine the energy use. 

16 MR. BROOKMAN: Terry?

17 MR. MCGOWAN: I just wanted to ask 

18 is the DOE aware of any studies on ceiling fans 

19 that would give this kind of information so 

20 far? 

21 DR. KANTNER: In a very not precise 

22 way. This is asked in the RECS surveys where 
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1 they ask something like if you use it a lot or 

2 a little, things like that. We will also keep 

3 an eye out for any studies that might go into 

4 this in more detail, or, if anyone has more 

5 detail, we'd be very interested in hearing 

6 about that. 

7 MR. TARR: This is Jeremy Tarr with 

8 Hunter. I think one of the things that should 

9 be considered is what speed the fans are 

10 operating on. Simply because they're on 

11 doesn't mean that they're running at high speed 

12 which -- 

13 DR. KANTNER: Agreed. 

14 MR. TARR: -- just needs to be part 

15 of it somehow. 

16 MR. BROOKMAN: Okay, thank you. 

17 Questions, comments? 

18 DR. KANTNER: Okay. So next is the 

19 life cycle cost and payback period analysis. 

20 The LCC determines the impact of energy 

21 conservation standards on consumers under 

22 different efficiency levels. It is from the 
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1 consumer's perspective, and it reflects the 

2 total cost of an appliance over its lifetime. 

3 The LCC is equal to the consumer 

4 price, plus the sum of annual operating costs. 

5 As part of this analysis, we also calculate 

6 the payback period, which is the amount of time 

7 required for energy cost savings to pay back 

8 any increased cost of a higher efficiency 

9 product. 

10 The LCC analysis takes a look at the 

11 selection process for ceiling fans and CFLKs. 

12 It is based on the distribution of product 

13 efficiencies expected for the compliance year. 

14 So some customers may not be affected by this 

15 standard, and the LCC accounts for that. 

16 It aggregates the annual energy 

17 consumption over the product's lifetime, and it 

18 uses probability distributions to characterize 

19 operating costs, as well as other parameters. 

20 Then this is all run using a computational 

21 simulation to determine the percent of 

22 customers benefitting from, being burdened by, 
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1 or not being affected by the standard.

2 So we use the energy use analysis we 

3 just discussed a moment ago to get the annual 

4 energy consumption and then combine that with 

5 other parameters, including lifetime, discount 

6 rate, energy price, installation cost, among 

7 others, to arrive at the final life cycle cost. 

8 So I'm just going to briefly discuss a few of 

9 these points.

10 First up is installation costs. For 

11 ceiling fans and CFLKs, DOE expects that 

12 installation costs will be independent of 

13 efficiency improvements, although, of course, 

14 we welcome if anybody else has data on that. 

15 As far as energy prices, DOE plans to use the 

16 latest version of EIA's Annual Energy Outlook

17 to estimate future energy prices. And DOE will 

18 consider maintenance and repair costs and plans 

19 to determine whether such costs change with 

20 increased efficiency.

21 Another important component is the 

22 product lifetime. And DOE will estimate the 
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1 product lifetime of ceiling fans using data 

2 from various sources, including Appliance 

3 Magazine, expert opinions, and any other 

4 relevant sources. 

5 DOE anticipates that ceiling fan 

6 lifetime could vary significantly, depending on 

7 usage. And DOE plans to correlate CFLK 

8 lifetime with ceiling fan lifetime. So in 

9 other words, assume that those lifetimes are 

10 equal. But the energy savings would depend on 

11 the lifetime of a packaged lamp and any 

12 substitutable lamps. For calculating energy 

13 savings, the relevant lifetime will be the 

14 lesser of the ceiling fan light kit lifetime 

15 and the ceiling fan lifetime. 

16 And then we have a comment on this 

17 slide. DOE welcomes comments on appropriate 

18 lifetimes for both ceiling fans and CFLKs 

19 covered in this rulemaking. DOE is 

20 particularly interested in regional lifetime 

21 data and data on the relationship between 

22 ceiling fan usage and ceiling fan life 
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1 expectancy. 

2 MR. BROOKMAN: Brian? 

3 MR. HEIMANN: Brad Heimann with 

4 Craftmade. A couple of comments. First, I 

5 think you're going to find that the lifetime is 

6 going to vary significantly, depending on what 

7 motor technology you use. So that may come 

8 later. But back on the installation costs, I 

9 think, depending on the channel, you're going 

10 to find that installation costs are not 

11 independent of the fan cost within the showroom 

12 channel because, in the DIY channel, that may 

13 be the homeowner that's putting that in. But, 

14 typically, in the other channel, you do have 

15 installers that are doing that, and then that's 

16 going to get compounded with the lifetime of 

17 the fan because they have to go back and 

18 reinstall and replace if they don't last as 

19 long as what's currently on the market. 

20 MR. BROOKMAN: Thank you. Yes, 

21 please, Aris. 

22 DR. MARANTAN: Hello. Aris 
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1 Marantan, Navigant. I wonder if you could 

2 elaborate on your -- do you have any estimates 

3 on lifetime for various motor types? 

4 MR. HEIMANN: We don't have, we 

5 don't have enough data, but we can tell you, 

6 from our company's experience, that, in 

7 particular DC motors, the componentry that's 

8 required to drive those do not last nearly as 

9 long as the current motors that are out there. 

10 You know, we've discontinued introducing those 

11 motors simply because we can't warranty them 

12 like we can with a conventional motor. So I 

13 could give you, you know, that's just a three14 to four-year time frame that we've been 

15 introducing those, and we're already finding 

16 some significant backlash on our buyers of 

17 those products. 

18 MR. BROOKMAN: Jeremy?

19 MR. TARR: I'd agree. With more 

20 time, we could potentially come up with more 

21 data, as far as product life. I would really 

22 like to see the data behind the Appliance 
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1 Magazine survey.

2 MR. BROOKMAN: You don't trust it?

3 MR. TARR: It's from a long time ago 

4 and, for all we know, that gentleman is writing 

5 articles for Guns and Ammo today. I don't know 

6 that he was an expert in the industry or an 

7 expert on ceiling fans. Appliance Magazine

8 doesn't track ceiling fans anymore, as far as 

9 I'm aware. So, you know, I'm not saying that 

10 it's -- I would just like to see the data 

11 behind it, and then, you know, supplement that 

12 with our own industry data. We'll certainly 

13 participate, I'd just like to see some more 

14 details on it. 

15 DR. KANTNER: Sure. And we would 

16 certainly welcome any more current data on 

17 lifetime. 

18 MR. TARR: Sure. One other 

19 question. Is there a payback period that has 

20 been deemed appropriate? 

21 DR. KANTNER: That payback period is 

22 something that will be analyzed as we go 
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1 through the process. It's not something that 

2 is necessarily set in stone. The idea is that 

3 the standard is evaluated based on the 30-year 

4 national impact. 

5 MR. TARR: Is there a target? Is 

6 there a tipping point where -- I guess my 

7 question is, is there a tipping point where 

8 these are good ideas and should move forward or 

9 these are not worth it? 

10 MR. BROOKMAN: Lucy? 

11 MS. DEBUTTS: We're going to have to 

12 come back to that one. 

13 MR. BROOKMAN: Okay.

14 MS. DEBUTTS: Not at this point.

15 MR. BROOKMAN: Okay. Yes, Dick?

16 MR. UPTON: I'm not sure, but EPA, 

17 if you're an ENERGY STAR qualified product, you 

18 have to guarantee 30 years on that.

19 DR. KANTNER: On the motor.

20 MR. UPTON: Maybe that becomes the 

21 standard. 

22 MR. BROOKMAN: Thank you. Okay. 
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1 DR. KANTNER: Okay. DOE will also 

2 determine a discount rate to calculate the 

3 present value of any cash flows over the 

4 analysis period. DOE will derive a discount 

5 rate for residential users, which will be an 

6 estimate of the financial cost to the consumer. 

7 And this could include the cost of any debt 

8 incurred to purchase a product, as well as the 

9 opportunity cost of any equity used to purchase 

10 a product.

11 We also develop base case 

12 efficiency, which is just used to characterize 

13 the ceiling fan and CFLK market in the 

14 compliance year in the absence of DOE energy 

15 conservation standards. 

16 MR. GATTO: Dave Gatto with 

17 Westinghouse. This is kind of similar to 

18 Jeremy's question. In the life cycle cost, is 

19 there a tipping point in the energy savings 

20 versus lifetime costs? So we're talking about 

21 lifetime of the product, but is there a tipping 

22 point on we're going to save one watt over 60 
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1 years but it's going to cost four times as 

2 much? Is there a formula that DOE uses for 

3 that, you know, to determine whether to set 

4 rulemaking or not, or is that -- 

5 MS. DEBUTTS: We don't have a 

6 formula, but we'll definitely look into and 

7 take it into consideration. I know that, from 

8 prior experiences, that some of the savings 

9 were not there, so DOE hasn't moved forward 

10 with certain rulemakings. It's not necessarily 

11 lighting products, but, you know, it's being 

12 considered every time. 

13 MR. GATTO: Okay, thank you. 

14 DR. KANTNER: Okay. All right. So 

15 moving on to the shipments analysis. The 

16 purpose of the shipments analysis is to 

17 estimate shipments of ceiling fan and CFLKs, as 

18 well as the product mix of the stock over the 

19 analysis period in the base case and standards 

20 cases. The national impact analysis uses the 

21 shipment and stock estimates to determine 

22 national energy savings and net present value 
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1 at various standard levels.

2 The analysis period will be over 30 

3 years, beginning with the expected compliance 

4 date of the standard. And DOE will estimate 

5 the stock and shipments of ceiling fans and 

6 CFLKs based on existing data, including but not 

7 limited to EIA's RECS, as well as ENERGY STAR 

8 data. And DOE plans to use an economic model 

9 to project shipments in the standards case, as 

10 compared to the base case. And this will be 

11 based on observed and projected technology 

12 price trends. And modeled CFLK shipments will 

13 depend on ceiling fan shipments.

14 Okay. So moving on to the national 

15 impact analysis. The purpose of the national 

16 impact analysis is to determine the projected 

17 national energy savings, or NES, and the 

18 consumer national net present value, or NPV, 

19 associated with potential energy conservation 

20 standards.

21 The national energy savings is the 

22 difference in the annual operating consumption 
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1 between the base case and standards case. The 

2 net present value is the operating costs 

3 savings minus the increased total installed 

4 cost at present value. 

5 And the method that we will use is 

6 to develop an annual series of national energy 

7 and economic impacts and then use the shipments 

8 model to estimate stock in each year. We use 

9 the LCC to develop input about total installed 

10 cost and energy use per unit in any year, and 

11 then we aggregate the cost and energy use for 

12 all years in the analysis period. DOE will 

13 report the NES in terms of both primary and 

14 full fuel cycle savings. And DOE will also 

15 report change in national NPV in constant year 

16 dollars. And we also account for the time 

17 value of money through defined discount rates. 

18 

19 Okay. So up next is the preliminary 

20 manufacturer impact analysis. And Hayden Cook 

21 from Navigant will be discussing that. 

22 MR. COOK: Hi. My name is Hayden 
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1 Cook. I'm with Navigant Consulting, and I'll 

2 be briefly speaking about the manufacturer 

3 impact analysis, or MIA. DOE is conducting the 

4 MIA to better understand how standards could 

5 affect manufacturers of ceiling fans and 

6 ceiling fan light kits. 

7 There are three main purposes of the 

8 MIA. The first is to quantitatively assess the 

9 financial impact of energy conservation 

10 standards on manufacturers of ceiling fans and 

11 ceiling fan light kits. The second is to 

12 identify any potential manufacturer subgroups 

13 whose cost structure could differ significantly 

14 from an industry average. One such common 

15 subgroup is small business manufacturers. The 

16 third is to quantitatively and qualitatively 

17 examine other non-direct financial impacts of 

18 energy conservation standards on manufacturers. 

19 These could include things like direct 

20 employment, manufacturing capacity, or 

21 cumulative regulatory burden on these 

22 manufacturers.
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1 The methodology for the MIA is 

2 typically performed in three phases, which will 

3 be shown in the next slide. However, the key 

4 output of the MIA is the change in industry net 

5 present value, or INPV, that results from an 

6 energy conservation standard.

7 Here you can see the three phases 

8 that the MIA is conducted in. In the first 

9 phase, DOE creates an industry profile building 

10 on the market and technology assessment. This 

11 takes place during the preliminary analysis. 

12 During this time, DOE also identifies the key 

13 issues that concern manufacturers relating to 

14 an energy conservation standard. 

15 In phase two which spans the NOPR 

16 and final rule phases of analyses, DOE builds a 

17 strawman industry cash flow model called the 

18 Government Regulatory Impact Model, or GRIM, to 

19 forecast free industry cash flows in the 

20 industry. This is used in the base case, in 

21 the standards case, and calculates the INPV for 

22 each case. 
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1 Also in phase two, DOE develops an 

2 interview guide that will help to lead 

3 subsequent discussions with manufacturers 

4 during the MIA interviews, which takes place in 

5 phase three. And it's just a note that these 

6 manufacturer interviews are separate from the 

7 engineering manufacturers that Aris talked 

8 about that will be conducted after this stage. 

9 Usually, those will be conducted after the 

10 preliminary analysis stage is published. The 

11 manufacturer interviews, that is.

12 In phase three, DOE interviews a 

13 variety of different manufacturers to receive 

14 feedback on the items that are listed in the 

15 interview guide that will be submitted. These 

16 interviews are conducted under non-disclosure 

17 agreements, just like the engineering 

18 interviews, so no proprietary information will 

19 be disclosed publically. Following these 

20 interviews, DOE refines the GRIM and evaluates 

21 other qualitative issues, such as direct 

22 employment, manufacturing capacity, and 
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1 cumulative regulatory burden on manufacturers. 

2 Oh, and then, at this time, DOE is 

3 requesting any comment on any existing or 

4 pending regulations that DOE should examine in 

5 the cumulative regulatory burden. 

6 MR. BROOKMAN: David? 

7 MR. GATTO: David Gatto with 

8 Westinghouse Lighting. We've already talked 

9 about it. It's the lamp legislation that's 

10 covered under EISA and EPAct, as well as 

11 proposed rulemakings on additional lamp 

12 categories like HID and the next round for IRL 

13 and fluorescent. 

14 MR. BROOKMAN: Okay. Nothing 

15 additional. Okay. 

16 MR. UPTON: Lucy, is there any way 

17 that these two interviews can be done at the 

18 same time? 

19 MS. DEBUTTS: They're happening in 

20 different stages of the rulemaking process, so 

21 the answer, unfortunately, is no. 

22 MR. UPTON: We've got one day for 
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1 one person, and we've got another day being 

2 shot up. There's a lot of work going in to 

3 trying to come up with all the answers you 

4 need, and I'll just caution that we want to 

5 give as good of answers as we can but you're 

6 going to run into roadblocks at some point 

7 where people say enough is enough. 

8 MR. COOK: Sure. We understand 

9 that, and these two interview cycles would 

10 probably be held, you know, months apart, maybe 

11 even a full year apart. So one would be 

12 conducted between the framework stage and the 

13 preliminary analysis, and the second one would 

14 be conducted between the preliminary analysis 

15 publication and the publication of the NOPR. 

16 So we're talking potentially a full year apart, 

17 but we do understand. And it gives us another 

18 chance to refine some of the variables that are 

19 published in the preliminary analysis and, 

20 basically, we can't interact with manufacturers 

21 about that data until we publish that 

22 preliminary analysis data. 
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1 MS. DEBUTTS: And I'm looking at the 

2 proposed schedule right now. He's absolutely 

3 correct. It's going to be a year between the 

4 two. 

5 MR. BROOKMAN: Brian? 

6 MR. HEIMANN: Brad Heimann with 

7 Craftmade. I'm curious specifically about the 

8 derivation of a discount rate. It occurs to me 

9 that, by the very nature of everything you're 

10 talking about, be it the consumer tradeoff, NPV 

11 analysis, the discount rate can significantly 

12 impact how those analyses turn out. And I'd 

13 like to know exactly how we're going to derive 

14 that because, with regard to consumer impact, I 

15 would propose that these days a consumer 

16 discounts future savings much more heavily than 

17 you're probably anticipating as far as when 

18 they're going to let go of a current-day dollar 

19 for a future benefit. So I think we should 

20 look very heavily at how we derive those 

21 discount rates.

22 MR. BROOKMAN: Okay, thank you. 
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1 MR. COOK: There's also, it's not 

2 listed as a comment, but if there's any 

3 manufacturer subgroups that people would like 

4 to raise, other than the small business 

5 manufacturers, DOE is also looking for comment 

6 for that, but I don't know if there is any. 

7 MR. TARR: Jeremy Tarr with Hunter. 

8 I would suggest we look at the impact on the 

9 lighting showroom channel. We have a lot of 

10 small business retailers that would, could be 

11 significantly impacted by a substantial 

12 increase in product costs and retails. It 

13 would also, to that end, I mean, it would also 

14 affect the home center business. We're talking 

15 about significantly altering the cost structure 

16 of ceiling fans potentially. I'm not saying 

17 that's where we're going to end up, but that's 

18 what we're here discussing. So it's a 

19 significant impact across the board for the 

20 retail environment.

21 MR. BROOKMAN: Okay, thank you. 

22 Dick? 
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1 MR. UPTON: The Remodelers 

2 Association, we partner with them a lot. And 

3 we see a price tag go up where they've looked 

4 in the past at having a ceiling fan with a 

5 light kit on it to take care of the primary 

6 light requirement in the room and/or the 

7 builders, they'll forget about a ceiling fan 

8 and put in a light and put in the air 

9 conditioner and let people run their air 

10 conditioner. 

11 MR. TARR: And to that end, you 

12 know, there is no regulation on a light that 

13 can be put in the place of that ceiling fan. 

14 That might be a 12-light chandelier with 40-

15 watt bulbs in every socket. So, again, when we 

16 talk cumulative regulatory burden, ceiling fans 

17 are energy-savings devices. We're trying to 

18 squeeze blood out of a turnip in terms of 

19 efficiency. So I just ask that we keep that in 

20 mind as we move through the proceedings. 

21 MR. BROOKMAN: Thank you. Okay. 

22 MR. COOK: Okay. Now Colleen will 
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1 continue with the NOPR analyses.

2 MS. HUSAIN: Excuse me. Sorry. Can 

3 I just ask one question? 

4 MR. BROOKMAN: Just say your name 

5 again. 

6 MS. HUSAIN: Aisha.

7 MR. BROOKMAN: Yes.

8 MS. HUSAIN: Can I ask a quick 

9 question before we move into NOPR analyses, and 

10 this is on an earlier section so sorry about 

11 that. For light kits product classes, consumer 

12 utility was mentioned as a consideration. 

13 Would the manufacturers have any key things 

14 that they think are really important to 

15 consumers that come to mind? 

16 MR. FRAMPTON: Light output. I 

17 mean, the 190-watt limiter is driving customers 

18 away from the product. 

19 MR. BROOKMAN: So that was Nathan. 

20 Brian, you want to keep going here? 

21 MR. HEIMANN: I would agree with 

22 that. First is, you know, people are looking 
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1 for light output, but there's an attractiveness 

2 component. You know, it's not mentioned very 

3 much in appliance standards, but we do have a 

4 unique product in that people don't just buy it 

5 for its utility, they buy it because they want 

6 it to look nice while it's accomplishing 

7 lighting up the room. So it has to satisfy 

8 that demand pretty heavily, as well. 

9 MS. HUSAIN: This is Aisha again. 

10 Is there a certain range of light output that's 

11 used as a rule of thumb? 

12 MR. BROOKMAN: Terry? 

13 MR. MCGOWAN: Yes, but the light 

14 output varies widely, depending upon the size 

15 of the room and the reflectance of the surfaces 

16 in that room. So it is not manufacturer 

17 controllable in the sense that they can 

18 influence those external factors. 

19 MR. BROOKMAN: Dave? 

20 MR. GATTO: I wanted to wait until 

21 you finished writing. Dave Gatto. From a 

22 functionality standpoint, a lot of the consumer 
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1 feedback we get is, particularly in CFL, warm2 up period, even in current, which is much 

3 further along than it was even five years ago. 

4 There's a warmup period for the lamps. They 

5 don't come on at full brightness. And then the 

6 functionality, being able to dim or control the 

7 light levels in the room. 

8 MR. MCGOWAN: I can also add that 

9 the appearance of the bulbs matters. Some 

10 people don't like the swirly look of a compact 

11 fluorescent, for example. They prefer the 

12 roundness and shape of a standard a-line bulb.

13 MR. BROOKMAN: So now we're moving 

14 on. 

15 MR. TURNER: Well, and color 

16 temperature. Just the cooler or the warmer of 

17 a light, at 2700 Kelvin to 3500 or higher.

18 MR. BROOKMAN: Okay. Terry? 

19 MR. MCGOWAN: Yes. And we have to 

20 include color rendering because that's what 

21 makes people look natural and normal. So 

22 chromaticity and color rendering with respect 
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1 to performance, color performance of the light 

2 source are both important. 

3 MR. BROOKMAN: On to consumer 

4 subgroups. 

5 DR. KANTNER: Okay. And this slide 

6 describes the analyses that will be revised at 

7 the preliminary -- excuse me. For the NOPR 

8 analyses, these are the ones that will be 

9 revised that were previously done in the 

10 preliminary analysis stage, and that includes 

11 the engineering analysis, the LCC and payback 

12 period analysis, the NIA and the MIA, and then 

13 there's a number of new analyses which are done 

14 at the NOPR stage for the first time.

15 So the first of these is the 

16 consumer subgroup analysis, which is basically 

17 just the LCC analysis for certain 

18 disproportionately-impacted subgroups. And DOE 

19 welcomes input from interested parties 

20 regarding which, if any, consumer subgroups 

21 should be considered when developing potential 

22 energy conservation standards for ceiling fans 
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1 and CFLKs. 

2 Okay. The next analysis is the 

3 emissions analysis. We do an emissions 

4 analysis to estimate environmental impacts from 

5 potential standards, including changes in full 

6 fuel cycle emissions, for several of these 

7 emissions, including carbon dioxide, sulfur 

8 dioxide, nitrogen oxides, methane, nitrous 

9 oxide, and mercury. And DOE seeks input on its 

10 approach to conduct the emissions analysis for 

11 the products covered by this rulemaking. 

12 MR. GATTO: Dave Gatto with 

13 Westinghouse. It's more of a question. Will 

14 the DOE be taking into consideration the 

15 potential emission increases caused by HVAC and 

16 air conditioning use if ceiling fans are not in 

17 the room? So kind of from our -- it's in our 

18 public comment that the concern we have here is 

19 that the regulation is actually going to be run 

20 counterproductive to the DOE's mandate because 

21 it will drive consumers away from an energy22 saving product and result in higher energy 
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1 usage for cooling and heating purposes. 

2 MS. DEBUTTS: And you have data to 

3 substantiate that? 

4 MR. GATTO: It's tough. In the few 

5 days that we've had this, the one thing that we 

6 did look at -- Nathan may want to chime in, we 

7 talked about it last night. Go ahead.

8 MR. BROOKMAN: Nathan, go ahead.

9 MR. FRAMPTON: Well, I mean, we do 

10 have data. We know that an air conditioner 

11 consumes three, four, five thousand watts. We 

12 know an electric furnace consumes, I think it's 

13 27,000 watts or some absurd number. So we do 

14 have that data. 

15 MR. BROOKMAN: Please use the 

16 microphone. 

17 DR. GARBESI: I'm sorry. We can and 

18 will incorporate those kinds of analyses that 

19 affect total energy use if we have the data. 

20 MR. BROOKMAN: So that data, that 

21 objective data just comparing those two usages, 

22 those usage rates may not do it for DOE. You 
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1 know what I'm saying? It's going to have to be 

2 the tradeoff. That's what you're going to need 

3 to show, right? 

4 DR. KANTNER: It will be helpful to 

5 know how it actually affects consumer behavior 

6 and not just the wattages of each. 

7 MR. BROOKMAN: Yes, that's a better 

8 way of putting it. Thank you. 

9 MR. TARR: This is Jeremy Tarr with 

10 Hunter. I believe that DOE has calculated some 

11 potential savings based on using an ENERGY STAR 

12 ceiling fan. I believe that could be adapted 

13 for this purpose.

14 MR. BROOKMAN: Lucy? 

15 DR. GARBESI: But the potential 

16 savings doesn't necessarily reflect what 

17 happens in the field. Those are the data that 

18 would be the most persuasive. I think there 

19 were comments submitted about the need for 

20 education that reflect on that, as well.

21 MR. BROOKMAN: Yes. So I saw Brian 

22 first.
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1 MR. HEIMANN: I was just going to 

2 mention that I think on the EPA's website they 

3 actually do tell consumers that they can save 

4 up to 14 percent on their air conditioning 

5 costs over a season if they use a ceiling fan 

6 and raise their thermostat. So I know that 

7 data exists, and there is a correlation. I 

8 understand that we have to, you know, match up 

9 the data to what happens in the field, but, 

10 again, you can, by the same note, you can drive 

11 efficiency in a ceiling fan, as well, but if 

12 they don't get purchased it doesn't manifest 

13 itself unless it gets put in the home either. 

14 So you're still talking about having to match 

15 up the reality. We have to make some 

16 assumptions, and I think it's a pretty safe 

17 assumption to make that, if people are going to 

18 make a tradeoff to be comfortable there, if 

19 they don't use a fan, they are going to manage 

20 their climate in some other way. 

21 MR. BROOKMAN: So it sounds like 

22 you've got a good start on making this case, 
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1 and the better you can do it the easier it is 

2 for DOE. 

3 MS. DEBUTTS: Correct, yes. 

4 MR. BROOKMAN: Okay, good. Joanna?

5 MS. MAUER: Joanna Mauer. I think 

6 there's no question that ceiling fans certainly 

7 have the potential to save a lot of energy if 

8 consumers do, in fact, raise the thermostat in 

9 the summer or use ceiling fans in place of air 

10 conditioning. I'm not aware of any field 

11 studies that have actually confirmed that, you 

12 know, consumers are changing their behavior. 

13 The only field study I came across conducted by 

14 the Florida Solar Energy Center, conducted a 

15 number of years ago, but I think they found 

16 that there was no noticeable difference in 

17 energy consumption in homes with ceiling fans 

18 compared to homes without ceiling fans, that 

19 they didn't find that consumers were actually 

20 changing thermostats when they had ceiling fans 

21 running. But I'd be interested if there's 

22 other data available.
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1 MR. BROOKMAN: Okay. Dick?

2 MR. UPTON: Most of these analyses 

3 will be done, hopefully, from what's real, as 

4 opposed to this is where we want to head so 

5 let's go find some numbers that prove our 

6 point. And I'm concerned about that.

7 MR. BROOKMAN: Okay. 

8 DR. KANTNER: Okay. Next is the 

9 monetization of emissions reductions. We 

10 currently monetize some of the emissions we 

11 just discussed, specifically carbon dioxide and 

12 nitrogen oxides. And for CO2, DOE intends to 

13 use the most recent social cost of carbon 

14 values developed by interagency reviews. 

15 And DOE requests comments on the 

16 approach it plans to use for estimating 

17 monetary values associated with emissions 

18 reductions. 

19 MR. BROOKMAN: Any comments here? 

20 No comments here. 

21 DR. KANTNER: Okay. Next is the 

22 utility impact analysis, and we do a utility 
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1 impact analysis to look at, among other things, 

2 avoided capacity. So DOE welcomes input from 

3 stakeholders on its proposed approach to 

4 conduct the utility impact analysis. 

5 Next comes the employment impact 

6 analysis. Whereas the MIA looked at direct 

7 employment impacts, the employment impact 

8 analysis looks at indirect employment impacts 

9 resulting from shifting consumer expenditures. 

10 And DOE welcomes feedback on its proposed 

11 approach to assessing national employment 

12 impacts.

13 MR. BROOKMAN: Both direct and 

14 indirect. Comments? I see none. Okay. 

15 DR. KANTNER: And then, finally, we 

16 do a regulatory impact analysis that looks at 

17 the potential for other non-regulatory 

18 alternatives to affect the energy efficiency of 

19 ceiling fans and ceiling fan light kits. DOE 

20 requests any available data or reports that 

21 would contribute to the regulatory impact 

22 analysis for ceiling fans and CFLKs covered in 
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1 this rulemaking. In particular, DOE seeks 

2 information on the effectiveness of existing or 

3 past programs for these products that are 

4 similar to the policies noted above.

5 MR. BROOKMAN: No comments here? 

6 Okay. So do you want to advance to the final 

7 slide?

8 DR. KANTNER: Sure. 

9 MR. BROOKMAN: As we promised at the 

10 outset, now is another opportunity for anyone 

11 that wants to make a final comment, to cover 

12 issues that haven't been covered sufficiently 

13 at this point. Now is your chance. I see 

14 none. So let me encourage you, your packet has 

15 an evaluation form. This is the last page in 

16 your packet. If you'd take the time to take a 

17 look at that and fill it out, and I'm going to 

18 turn it back to Lucy deButts for closing 

19 remarks. 

20 MS. DEBUTTS: Well, I just want to 

21 thank everyone for coming and talking to us 

22 about this rulemaking. We will, we're looking 
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1 forward to working with the industry and every 

2 single participant on developing the test 

3 procedures and the standards for these product 

4 classes, for these products.

5 Again, I just wanted to comment that 

6 the comment period closes on April 29th. I 

7 hear the concern about the time frames, so if 

8 you decide that you need a little more time you 

9 can submit the request to us and we'll consider 

10 it. Again, these are the means by which you 

11 can communicate with us. And with that, I can 

12 move to close. 

13 MR. BROOKMAN: Thanks to all of you 

14 and safe travels.

15 (Whereupon, the foregoing matter was 

16 concluded at 12:03 p.m.)

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