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MEMORANDUM

To: John Cymbalsky

From: Lucy deButts and the Ceiling Fan and Ceiling Fan Light Kit Team

Date: April 11, 2013

Re: Teleconference with the American Lighting Association clarifying the Ceiling Fan and Ceiling Fan 

Light Kit Framework Document

On April 10, 2013, Lucy deButts of DOE, Colleen Kantner and Karina Garbesi of Lawrence Berkeley 

National Laboratory, and Aris Marantan, Andre Gondouin, Aisha Hussain, Maureen Kienle, Michael 

Brancato, and Caroline de Monasterio of Navigant Consulting participated in a teleconference with 

representatives of the American Lighting Association including Dick Upton (President), Terry McGowan 

(Director of Engineering), and members David Turner of Hunter Fans, and Dave Gatto of Westinghouse 

Lighting. This memo summarizes the discussion that took place at that meeting.

Questions on Specific Framework Items

Item 25: DOE requests information on the existing and/or future market availability of ceiling fan light 

kits with inseparable LED lighting components.

ALA (David Turner, Hunter Fans): What does DOE mean by inseparable LED lighting 

components? Is inseparable defined as per ENERGY STAR luminaires?

DOE: Yes. Inseparable means that the lamps are not consumer replaceable. It means that the lamp 

cannot be removed from the light kit by the consumer. These light kits are usually LEDs and are 

hard wired to the light kit. They don’t have an ANSI socket and replacing the lamp would mean 

replacing the entire light kit.

Item 38: DOE requests feedback the consumer utility of ceiling fan light kits that are packaged with 

dimming functionality.

ALA (David Turner, Hunter Fans): DOE indicated that there are currently light kits that have 

integrated dimmers or are packaged with dimmers. ALA would like information on those 

products.

DOE: DOE will post that information on the docket.

Item 49: DOE welcomes comments on the proposed method for isolating costs associated with 

decorative features from costs associated with functional features in ceiling fans and ceiling fan light kits.

ALA (Dave Gatto, Westinghouse Lighting): How do you plan to define decorative features and 

isolate costs for decorative and functional features?

DOE: Decorative components don’t affect performance in terms of either airflow or efficiency. 

DOE welcomes feedback on what should be included. Decorative features might include: 

hardware, motor housing, fan blade brackets, and finish.
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ALA (Dave Gatto, Westinghouse Lighting): Until we know what you are considering, it is hard 

for us to craft a response. There are fan parts that are decorative but can also affect performance, 

such as the motor housing and brackets. When will ALA be able to comment on what is being 

defined as decorative?

DOE: DOE welcomes additional feedback on which components should be considered when 

analyzing fan performance and costs. Beyond the Framework Document phase, there will also be 

two more opportunities to review and comment on the analysis – the Preliminary Analysis and 

the Notice of Proposed Rulemaking (NOPR). Each of these two phases will have their own 

public meeting and comment period.

ALA (Dick Upton): Can DOE provide a list of features it is considering including in the 

decorative categories within the next few days?

DOE: DOE will consider that. 

Item 51: DOE welcomes comments on regulatory burdens and changes that should be considered in the 

engineering analysis of ceiling fans and ceiling fan light kits.

and

Item 52: DOE welcomes comments on other engineering issues that could affect the engineering 

analysis. 

ALA (David Turner, Hunter Fans): Are these existing regulatory burdens or ones that would be 

incurred by the upcoming rulemaking?

DOE: Existing. In conducting the engineering analysis, DOE must consider the effects of 

regulatory changes outside DOE’s statutory energy conservation standards rulemaking process 

that can impact the manufacturers of the covered equipment. DOE is interested in assessing the 

cumulative regulatory burden to manufacturers. Stakeholders should make DOE aware of any 

other regulatory burdens placed on the industry. 

General Questions

Dick Upton, President of the ALA

ALA: Is this rulemaking for residential and commercial ceiling fans and light kits or only 

residential?

DOE: Only residential.

Terry McGowan, Director of Engineering, ALA

ALA: What is DOE planning to do regarding the GU-24 base? Is DOE aware of and will it be 

taking into account California’s experience with light kits?

DOE: DOE will consider the proposal to reclassify light kits with Gu-24 socket. Can ALA 

provide the information on California’s experience?
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ALA: We will provide that information.

(Note: DOE will post any information it receives to the docket.)

Terry McGowan, Director of Engineering, ALA. 

ALA: What are the assumptions on speed settings for the current analysis? What were the 

assumptions on speed settings that are the basis of the current standards?

DOE: DOE has not yet conducted this analysis for the current rulemaking. For the previous 

rulemaking, DOE did not do that analysis. There are currently only design standards and not 

efficiency performance standards for ceiling fans. The design standards were set legislatively and 

only codified by DOE. If ALA has documentation on analysis that was used as the basis for the 

legislative standards setting, it could potentially be useful for the current rulemaking.