1 | Energy Efficiency and Renewable Energy eere.energy.gov 

### [INSERT PICTURE(S) OF PRODUCT(S)]

[INSERT PICTURE(S) OF PRODUCT(S)]



# Energy Conservation Standards Notice of Proposed Rulemaking for Residential Furnace Fans

December 3, 2013 Ronald Majette

Department of Energy Building Technologies Program
EERE

– 2010

– BT

– STD

– 0011


### FurnFans

- 2010

- STD

0011@ee.doe.gov2 

# Welcome

• Introductions (around the room )

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record

– there will be a complete transcript of 

## this meeting.

– Be concise

– share the ‘air

- time’.

– Keep the focus here

– cell phones on silent; limit sidebar conversations.



## – Webinar participants turn phone on mute; “raise your hand” to be recognized to speak.



# • Housekeeping Items

• Agenda Review



# • Opening Remarks3 

# Agenda

9:00

– 9:15 am Welcome ; Introductions; and Agenda Review

Doug Brookman

9:15

– 9:45 am Purpose of Public Meeting; Opening Statements; Comment Submission

Instructions ; and Regulatory Authority and Rulemaking Overview Ronald Majette

9:45

– 10:15 am Market Assessment

Kevin Foley

10:15

– 10:30 am Break

10:30

– 11:15 am Engineering Analysis

Kevin Foley

11:15

– 12:00 pm Markups; Energy Use Characterization; and Lifecycle Cost and Payback Period

Analysis
Victor Franco

12:00

– 12:45 pm Lunch (on your own)4 

# Agenda (cont.)

12:45

– 1:15 pm LCC and Payback Period Analysis (cont.)

Victor Franco

1 :15

– 1:45 pm National Impact Analysis, Shipments, and Regulatory Impact Analysis

Alex Lekov

1:45

– 1:55 pm Break

1:55

– 2:30 pm Manufacturer Impact Analysis

Chris Lau

2:30

– 3:00 pm Environmental Impacts

Alex Lekov

3:00

– 3:30 pm Results and Proposed Standards

Alex Lekov

3:30

– 4:00 pm Closing Remarks from Interested Parties

Ronald Majette

4:00 pm Adjourn5 

# Participating Via the Webcast

• The Department is broadcasting this meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in, view the slides, and participate directly.

• All stakeholders are encouraged to submit written comments after the public meeting.6 

# Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate potential energy conservation standards for residential 

# furnace fans.

• Invite comment on the energy conservation standards notice 

# of proposed rulemaking (NOPR) and technical support document (TSD), including DOE’s proposed standard levels.

• Invite participants to provide summary comments or statements and raise additional issues for discussion.7 

# Issues for Discussion

The deadline for submitting comments is 12/24/2013. Issue Box: DOE welcomes comments, data, and information 

## concerning its proposed standards for residential furnace fans. Issues that correspond to those raised in DOE’s published material will be numbered in accordance with that material. Whether invited by an issue box or not, comments are 

## welcome on any part of DOE’s analysis.8 

# Opening Remarks

Meeting participants are invited to provide opening remarks or statements at this time.9 

# Public Meeting Agenda

1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Environmental Impacts

8 Results and Proposed Standards10 

# Regulatory Authority

The Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 94

- 163), as amended by the Energy Policy Act of 2005 

# (EPACT 2005)(Public Law 109

- 58) and the Energy Independence and Security Act of 2007 (EISA 2007)(Public Law 110

- 140), provides in relevant part:

• “...the Secretary shall consider and prescribe energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work.” (42 U.S.C. 6295(f)(4)(D))

• “[A]ny final rule establishing or revising [an energy conservation] standard for a covered product adopted after July 1, 2010, shall incorporate standby mode and off mode energy use into a single amended or new standard, pursuant to [42 U.S.C. 6295(o)], if 

## feasible. ” (42 U.S.C. 6295( gg )(3))11 

# Regulatory History DOE has no current energy conservation standard or test procedure for residential furnace fans.

• Test Procedure

– DOE is developing a test procedure in a parallel rulemaking.

– DOE published a test procedure NOPR on May 15, 2012 (77 FR 28674).

– DOE held the test procedure NOPR public meeting on June 15, 2012.

– DOE published a test procedure SNOPR on April 2, 2013 (78 FR 19606).

– DOE plans to publish a final test procedure by the end of 2013.



### • Energy Conservation Standard

– DOE published the Notice of Public Meeting and Availability of the Framework Document on June 3, 2010 (75 FR 31323).

– DOE held the energy conservation standards Framework Document public meeting on June 18, 2010.

– DOE published the Notice of Public Meeting and Availability of the Preliminary Technical Support Document on July 10, 2012 (77 FR 40530).

– DOE held the energy conservation standards Preliminary Analysis public meeting on July 27, 2012

.

• DOE conducted the energy conservation standards NOPR analysis on the basis of the test procedure proposed in the test procedure SNOPR. (78 FR 19606 (April 2, 2013))12 

# Criteria for Selecting Standard Levels

The Energy Policy and Conservation Act (EPCA) directs DOE to consider seven factors when setting energy conservation standards.

EPCA Factor DOE Analysis

1. Economic impact on consumers and manufacturers Life

- cycle cost analysis Manufacturer impact analysis

2. Lifetime operating cost savings Life

- cycle cost analysis

3. Total projected energy savings National impact analysis

4. Impact on utility or performance Screening analysis Engineering analysis

5. Impact of any lessening of competition Manufacturer impact analysis

6. Need for national energy conservation National impact analysis

7. Other factors the Secretary considers relevant Environmental assessment Utility impact analysis Employment impact analysis13 

# Energy Conservation Standards Rulemaking14 

# Public Meeting Agenda

1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Environmental Impacts

8 Results and Proposed Standards15 

# Market Assessment

DOE proposes to define a “furnace fan” as any electrically

- powered device used in residential heating, ventilation, and air

- conditioning (HVAC) products for the purpose of circulating air through duct work . DOE uses the term “furnace fan” as shorthand for any of these products.

• DOE recognizes that a significant number of products may be encompassed by its interpretation of the statutory language and its corresponding definition.

• The boxes outlined in red represent space

- conditioning products that include a furnace fan.



# Indoor Unit Outdoor Unit Condensing Unit

Coil

- Only Unit

Electric Furnace / Modular Blower NWG or Oil Furnace Hydronic Air

Handler Blower

- Coil Unit Hydronic Air Handler with Coil Packaged Unit (Weatherized Furnace) 

# Typical HVAC System Combinations16 

# Market Assessment

The proposed scope of coverage in the current NOPR includes 63% of estimated annual sales of space

- conditioning products that include furnace fans.

Key

Considered in this rulemaking.

Not considered in this rulemaking.17 

# Market Assessment

DOE is proposing to establish the following eight product classes that represent most of the energy use associated with furnace fans considered in the analysis.

Proposed Product Classes

Non

- Weatherized
, Non

- Condensing Gas Furnace Fan (NWG

- NC)

Non

- Weatherized , Condensing Gas Furnace Fan (NWG

- C)

Manufactured Home Non

- Weatherized
, Non

- Condensing Gas Furnace Fan (MH

- NWG

- NC)

Manufactured Home Non

- Weatherized , Condensing Gas Furnace Fan (MH

- NWG

- C) Manufactured Home Electric Furnace / Modular Blower Fan (MH

- EF/MB)

Non

- Weatherized, Non

- Condensing Oil Furnace Fan (NWO

- NC)

Weatherized Non

- Condensing Gas Furnace Fan (WG

- NC) Electric Furnace / Modular Blower Fan (EF/MB) 

## DOE differentiated between product classes based on internal structure and application

- specific design differences that impact furnace fan energy consumption.18 

# Market Assessment

Due to limited data for some product classes, DOE had to extrapolate data from similar product classes to generate FER values.

Directly Analyzed Extrapolated

Non

- Weatherized
, Non

- Condensing Gas Furnace Fan (NWG

- NC) Manufactured Home Non

- Weatherized, Non

Condensing Gas Furnace Fan (MH

- NWG

- NC) Non

- Weatherized , Condensing Gas Furnace Fan (NWG

- C) Manufactured Home Non

- Weatherized, Condensing Gas Furnace Fan (MH

- NWG

- C) Non

- Weatherized, Non

- Condensing Oil Furnace Fan (NWO

- NC) Manufactured Home Electric Furnace / Modular Blower Fan (MH

- EF/MB) Weatherized Non

- Condensing Gas Furnace Fan (WG

- NC) Electric Furnace / Modular Blower Fan (EF/MB)19 

# Market Assessment

DOE found two additional product classes with active models listed in the AHRI appliance directory: (1) manufactured home weatherized non

condensing gas furnace fans (MH

- WG

- NC) and (2) manufactured home non

weatherized non

- condensing oil furnace fans (MH

- NWO

- NC).

• Due to the limited number of basic models for MH

- WG

- NC and MH

- NWO

NC, DOE did not have data to directly analyze and consider establishing 

## standards for these additional product classes.

• DOE proposes to reserve standards for MH

- WG

- NC and MH

- NWO

- NC until sufficient data become available to consider establishing standards.20 

# Public Meeting Agenda

1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Environmental Impacts

8 Results and Proposed Standards21 

# Engineering Analysis

DOE considered six technology options in the Engineering Analysis.

Technology Options Brief Description Improved permanent split capacitor (PSC) motors PSC motors with more than 3 airflow

- control settings.

Inverter technology (PSC motors) Motor controls used to extend the airflow range and flexibility of PSC motors.

Constant

- torque brushless permanent magnet (BPM) fan motors Constant

- torque, brushless permanent magnet motors, that are more efficient and have a wider airflow range than PSC motors.

Constant

- airflow BPM fan motors Constant

- airflow, brushless permanent magnet motors, that add to the efficiency and airflow

- range benefits of constant

- torque BPM motors.

Multi

- stage or modulating heating controls Multi

- stage furnaces are able to better match typical demand by operating at lower heat input rates to heat a residence and, in turn, a lower airflow

- control setting for extended periods of time compared to single

- stage furnaces.

Backward

- inclined impellers Impellers with backward facing inclined blades that can be more efficient than conventional forward

- curved impellers.22 

# Engineering Analysis

In the Engineering Analysis, DOE evaluated technologies that reduce furnace fan electrical consumption and characterized the relationship between manufacturer cost and energy consumption reduction.

Downstream Analyses

• Life

- Cycle Cost and Payback Period Analysis



### • National Impacts Analysis

• Shipments Analysis

• Manufacturer Impact Analysis Output: Cost

– Efficiency Relationship Incremental Manufacturing Cost

Energy Consumption23 

# Engineering Analysis
The proposed rating metric is Fan Energy Rating (FER), which is the estimated annual electrical energy consumption normalized by the airflow in the maximum airflow

- control setting and the estimated annual operating hours.

FER = ( Operating Hour s x 

### × Power Consumptio n x 

### ) x = modes 

### Operating Hour s x x = modes 

### × ( Maximum Airflow ) × 1000

FER = CH × E

max + HH × E heat + CCH × E circ ( CH + HH + CCH ) × Q max × 100024 

# Engineering Analysis
Variations to FER exist depending on the maximum heating setting and whether the unit has single

- stage or multi

- stage heating.

• Single

- stage heating, maximum airflow is not a heating setting:

FER = CH × E

max + HH × E heat + CCH × E circ ( CH + HH + CCH ) × Q max × 1000



### • Single

- stage heating, maximum airflow is a heating setting : E heat 

### = E max

FER = CH × E

max + HH × E

max + CCH × E circ ( CH + HH + CCH ) × Q max × 1000



### • Multi

- stage heating: HH = 830/ HCR in numerator

FER = CH × E

max + 830 H CR × E heat + CCH × E circ ( CH + HH + CCH ) × Q max × 100025 

# Engineering Analysis

DOE incorporated information from the following sources in the Engineering Analysis.

Product literature

Appliance Magazine, AHRI, GAMA

Manufacturer interviews

Product teardowns & manufacturing cost modeling

Product energy testing26 

# Engineering Analysis

DOE acquired data from specification sheets, testing, and teardowns to assist in developing FER values and cost models.

Specification Sheets • 163 units

• 6 manufacturers represented

• 800 to 2,000 CFM nominal airflow capacity

Teardown Units • 25 units

• 6 manufacturers represented

• 800 to 2,200 CFM nominal airflow capacity

Technology Variations • Motor Type: PSC, constant torque BPM, constant airflow BPM

• Airflow Capacity (800

- 2,200 CFM)

• Heat Exchanger Type (Clamshell, Tubular, Drum)

• Non

- condensing / Condensing

• Fan Housing Design (Standard, Proprietary)



### • Weatherized / Non

- weatherized

• Single

- Stage / Multi

- Stage Heating27 

# Engineering Analysis

The cost

- efficiency curve is developed in four steps.

• Define baseline specifications for each product class;

• Identify design options from the baseline to the maximum technologically feasible level (max

- tech) as a pathway for improving energy efficiency;

• Conduct teardown analysis for representative products spanning the range of efficiency levels considered; and

• Generate cost

- efficiency curves, which account for full production


### costs. Develop Baseline

Calculate Costs Develop Efficiency Pathway

Generate Cost

Efficiency Curves28 

# Engineering Analysis

DOE selected baseline models typical of the least

- efficient furnace fans used in commercially

- available residential HVAC models.

Across all product classes, a baseline furnace fan includes:



## • A PSC motor with 3 or fewer airflow

- control settings.

• A forward

- curved impeller.

• A standard, sheet

- metal fan housing

.



## • Single

- stage heating.29 

# Engineering Analysis

DOE reviewed all available FER values based on data from the preliminary analysis and new data, and concluded that FER can best be represented as a linear function of airflow capacity.



## • First, DOE determined the slope of the linear function by looking at multiple series of models of NWG

- NC and NWG

- C furnaces.

0 50 100 150 200 250 300 350 400 450

500 700 900 1100 1300 1500 1700 FER (W/1000 CFM)

Maximum Airflow Control Setting CFM Series 1

Series 2

Series 3 Slope = 5.7



### FER = slope x capacity + y

- intercept30 

# Engineering Analysis

Next, DOE performed a market

- and capacity

- weighted least

- squares regression analysis, keeping the slope constant, to determine the y

- intercept of the linear equation.

0 100 200 300 400 500 600

0 500 1000 1500 2000 2500 FER (W/1000 CFM)

CFM



### Baseline NWG

- NC Furnaces

error

Min ( market weight x capacity weight x ( error i ) 2 ) n i = 131 

# Engineering Analysis

DOE reviewed information from publicly

- available product literature and FER values calculated from test data to determine baseline FER ratings.

Key Product Class Baseline FER* (W/1000 cfm ) 1200 CFM 2000 CFM

NWG

- NC FER = 0.057 x Q Max + 362 430 476

NWG

- C FER = 0.057 x Q Max + 395 463 509

WG

- NC FER = 0.057 x Q Max + 271 339 385

NWO

- NC FER = 0.057 x Q Max + 336 404 450 EF/MB FER = 0.057 x Q Max + 331 399 445

MH

- NWG

- NC FER = 0.057 x Q Max + 271 339 385

MH

- NWG

- C FER = 0.057 x Q Max + 293 361 407

MH

- EF/MB FER = 0.057 x Q Max + 211 279 325

MH

- WG

- NC Reserved

----- -----
MH

- NWO

- NC Reserved

----- -----

* Q Max is the airflow, in cfm , at the maximum airflow

- control setting measured using the proposed DOE test procedure

.32 

# Engineering Analysis

Each efficiency level above the baseline is defined by the specific design option used to achieve it.

• DOE determined average percentage reductions in FER for each efficiency level and applied these reductions to all product classes.

– DOE found that manufacturers use similar components and design paths to improve efficiency across all product classes that DOE is examining.

– DOE does not expect the percentage reduction in FER associated with each design option, whether commercially available or prototype, to differ across product classes.



## • DOE based the reductions in FER associated with commercialized technologies on measurements or publicly

- available performance information.



## • DOE based the FER reductions associated with prototype technologies on research reports that included performance data.33 

# Engineering Analysis

DOE assigned percentage reductions in FER to each EL to obtain FER values for intermediate ELs.

Efficiency Level Design Option Percent Reduction in FER from Baseline

1 Improved PSC 10%

2 Inverter

- Driven PSC 25%

3 Constant

- Torque BPM Motor 42%

4 Constant

- Torque BPM Motor and

Multi

- Staging 50%

5 Constant

- Airflow BPM Motor and

Multi

- Staging 53%

6 Premium Constant

- Airflow BPM

Motor and Multi

- Staging + Backward

Inclined Impeller 57%*



## A premium constant

- airflow BPM motor is narrower and operates at higher RPM, which is characteristic of the motor paired with the backward

- inclined prototype. *DOE estimates that implementing a backward

- inclined impeller at EL 6 results in a 10% reduction in FER from EL 5. This is equivalent to a 4% percent reduction in FER from baseline.34 

# Engineering Analysis

DOE multiplied the slope and y

- intercept of the baseline FER equations by the percent reductions in FER at each efficiency level to generate intermediate FER equations.

Constant

- Torque BPM Motor and Multi

- Staging

Key Product Class Constant

- Torque BPM Motor and

Multi

- Stagin g FER* (W/1000 cfm ) 1200 CFM 2000 CFM

MH

- EF/MB FER = 0.029*Q Max +105 140 163

MH

- NWG

- NC FER = 0.029*Q Max +134 169 192

WG

- NC FER = 0.029*Q Max +135 170 193

MH

- NWG

- C FER = 0.029*Q Max +146 181 204 NWEF/ NWMB FER = 0.029*Q Max +165 200 223
NWO

- NC FER = 0.029*Q Max +167 202 225

NWG

- NC FER = 0.029*Q Max +180 215 238

NWG

- C FER = 0.029*Q Max +196 231 254

* Q Max is the airflow, in cfm , at the maximum airflow

- control setting measured using the proposed DOE test procedure

.35 

# Engineering Analysis

Non

- Weatherized, Non

- Condensing G as Furnace Fan

Efficiency Level Design Option NWG

- NC FER* (W/1000 cfm ) 1200 CFM 2000

CFM

1 Improved PSC FER = 0.051*QMax+323 384 425

2 Inverter

- Driven PSC FER = 0.043*QMax+271 323 357

3 Constant

- Torque BPM Motor FER = 0.033*QMax+212 252 278

4 Constant

- Torque BPM Motor and Multi

- Staging FER = 0.029*QMax+180 215 238

5 Constant

- Airflow BPM Motor and Multi

- Staging FER = 0.027*QMax+172 204 226

6 Premium Constant

Airflow BPM Motor and Multi

- Staging + Backward

- Curved Impeller FER = 0.025* QMax +155 185 205

* Q Max is the airflow, in cfm , at the maximum airflow

- control setting measured using the proposed DOE test procedure

.36 

# Engineering Analysis

Manufacturing cost models were developed by DOE as part of the efficiency

- level approach.

Raw Materials

Finished Materials Purchased Parts Physical Teardown Selection of Units

Fabrication Processes Bill of Materials

Assembly Processes

Manufacturing Cost 

### • Bills of material were generated during the product teardown analysis and entered into the cost model.

• Cost model generated manufacturing, material, labor, and overhead costs.

• Physical teardown analysis conducted with representative products.

• Manufacturer interviews conducted to further refine the analytical inputs and the results generated by the cost 

### model.37 

# Engineering Analysis

Structure/Classification of Manufacturing Costs

Full Manufacturer Selling Price (MSP)

Non

- Production Cost **

Selling General &

Admin. R & D Interest Full Manufacturing Production Cost (MPC)*

Direct Labor Direct

Material Overhead

Indirect labor

Indirect material

Maintenance

Depreciation

Taxes

Insurance related to assets Market research

Advertising

POS promotion
Sales person compensation & travel

Logistics

- Warehousing

- Delivery

- Record keeping Costs of service & staff units

General corporate costs

– comp., etc. Costs

associated with efforts to find

new or improved products or production processes Costs of

borrowing funds

* Tax Reform Act of 1986 essentially requires companies to measure cost of goods sold as the full production cost of the goods sold. ** In a company’s income statement, many of these costs are reported as a lump sum, under SG&A.38 

# Engineering Analysis

The costs used in the engineering analysis represent the cost of the furnace fan and not the cost of the entire HVAC product.

• The following components are included in the MPC estimates:

– Fan motor and integrated controls

– Primary control board

– Impeller

– Fan housing

– Components used to direct or guide airflow



### – Multi

- staging components and controls39 

# Engineering Analysis

DOE separated furnace fan product classes into high

- volume and low

- volume product classes to account for factors that impact manufacturers ’ production costs and purchasing power, such as:

• Some products are produced at volumes significantly larger than others.

• S ome manufacturers offer most types of the HVAC products, while others focus on niches

.

• High

- volume manufacturers operating in lower

- volume adjacent markets are expected to have purchased part price efficiencies consistent with their higher overall purchasing volume.

• Low

- volume operations were modeled as having lower production volumes and fewer shifts per day.


## High Volume

• Non

- Weatherized Gas Furnaces



### • Weatherized Gas Furnaces

• Electric Furnaces / Modular Blowers 

## Low Volume

• Oil Furnaces40 

# Engineering Analysis

DOE used a design option approach to estimate the cost of technologies not commercially available in furnace fan applications.

Design Option High Volume MPC Low Volume MPC Inverter Controls for Inverter

- Driven PSC $ 30.00 $ 42.29

Premium Constant

- Airflow BPM Motor $ 128.19 $ 175.85
Backward

- Inclined Impeller $ 18.00 $ 18.32

• DOE estimated these costs based on discussions with manufacturers and on cost estimates for inverter drives used in similar residential applications, such as clothes washers.

• DOE used a 10% markup on the estimated cost for a constant

- airflow BPM motor as the added cost for a premium constant

- airflow BPM motor.

• DOE used photographs and specifications found in research reports to determine cost model inputs to estimate the MPC of the backward

- inclined impeller.41 

# Engineering Analysis

$0 $50 $100 $150 $200 $250

0 100 200 300 400 500 MPC (2012$)

FER (Watts/1000 cfm)

Cost Efficiency Results for NWG

- NC at 1200 CFM

Premium Constant

- Airflow BPM Motor + Multi

- Stage + BI Impeller

Constant

- Airflow BPM Motor and Multi

- Staging

Constant

- Torque BPM Motor and Multi

- Staging

Constant

- Torque BPM Motor

PSC + Inverter

Improved PSC

Baseline PSC Proposed Standard Level42 

# Engineering Analysis

$0 $50 $100 $150 $200 $250

0 50 100 150 200 250 300 350 400 450 MPC (2012$)

FER (Watts/1000 cfm)



### Cost Efficiency Results for EF/MB at 1200 CFM

Premium Constant

- Airflow BPM Motor + Multi

- Stage + BI Impeller

Constant

- Airflow BPM Motor and Multi

- Staging

Constant

- Torque BPM Motor and Multi

- Staging

Constant

- Torque BPM Motor

PSC + Inverter

Improved PSC

Baseline PSC Proposed Standard Level43 

# Engineering Analysis

$0 $50 $100 $150 $200 $250 $300 $350

0 50 100 150 200 250 300 350 400 450 MPC (2012$)

FER (Watts/1000 cfm)



### Cost Efficiency Results for NWO

- NC at 1200 CFM

Premium Constant

- Airflow BPM Motor + Multi

- Stage + BI Impeller
Constant

- Airflow BPM Motor and Multi

- Staging

Constant

- Torque BPM Motor and Multi

- Staging

Constant

- Torque BPM Motor

PSC + Inverter Improved PSC

Baseline PSC Proposed Standard Level44 

# Engineering Analysis

Request for Comment

DOE invites additional FER value data that are generated using the DOE residential furnace fans test procedure proposed in the April 2, 2013 SNOPR (78 FR 19606 ), as well as the product class, measured airflow capacity in the maximum airflow control setting, and technology options of the model for which each FER value is calculated

.

DOE invites comments and recommendations from interested parties on DOE’s methodology for accounting for the relationship between FER and airflow capacity, and the resulting efficiency levels that are represented by equations for FER as a function of airflow capacity.45 

# Energy Use and Markups Analysis

1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Markups Analysis and Energy Use

5 Life

- Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Environmental Impacts

8 Results and Proposed Standards46 

# Markups Analysis

Markups relate consumer price to the manufacturer selling price, also referred as the “cost of goods sold.”


## Baseline and Incremental markups:

• Baseline markups relate direct business costs of products to baseline efficiency.

• Incremental markups relate the incremental change in consumer price to the incremental change in cost of goods sold due to potential energy efficiency improvements ( e.g. , fixed costs such as overhead and labor do not scale up ).



## Distribution Channels through which products move from manufacturers to producers: were developed for the following markets: ( 1) Replacement; (2) New Construction; (3) New Construction (Manufactured Home) 

## Markups were developed for the following market participants: M anufacturer, wholesaler, mechanical contractor, general contractor, manufactured home manufacturer, and manufactured home dealer.



## Sales Taxes and Wholesaler and Contractor markups were developed for each of the geographical areas in the analysis

.47 

# Markups Analysis
Distribution Channels for Residential Furnace Fans Equipment

Replacement



## New Construction

New Construction (Manufactured Homes Only) Manufacturer Wholesaler Mechanical Contractor Consumer

Manufacturer Wholesaler Mechanical Contractor General

Contractor Consumer

Manufacturer Manufactured Home Manufacturer Manufactured

Home Dealer Consumer48 Input Preliminary Analysis NOPR Changes
Distribution Channels See previous slide. Updated MH Contractor to MH Dealer.

Manufacturer Markup Determined in engineering analysis (Ch. 5), based on U.S. Security and Exchange Commission (SEC) 10

- K reports from publicly

owned residential HVAC companies. Updated values for every product class based on updated data from SEC 10

- K reports.

Wholesaler Markup Based on firm income statements from the HARDI 2011 Profit Report. No change.

Mechanical Contractor Markup Based on ACCA 2005 Financial Analysis report and Plumbing and HVAC Contractors sector from the 2007 Economic Census. No change.

General Contractor Markup Based on Residential Building Construction sector from the 2007 Economic Census. No change.

Manufactured Home Manufacturer Markup Based on M anufactured Home (Mobile Home) Manufacturing sector from the 2007 Economic Census. No change.

Manufactured Home Dealer Based on All Other Specialty Trade Contractors sector from the 2007 Economic Census. Determined manufactured home dealer based

on v arious sources (see Ch. 6).

Sales Tax Based on 2012 Sales Tax Clearinghouse Data. Updated to 2013 Sales Tax Clearinghouse Data. 

# Markups Analysis

NOPR Changes to Markups49 

# Markups Analysis

Average Markups by Product Class

Product Class Baseline Markup Incremental Markup

Non

- weatherized, Non

- condensing Gas Furnaces 3.18 2.00

Non

- weatherized, Condensing Gas Furnaces 3.11 1.96

Weatherized Gas Furnace 3.08 1.95 Oil Furnace 3.09 1.96 Electric Furnace / Modular Blower 2.84 1.80
Manufactured Home Non

- weatherized, Non

condensing Gas Furnaces 2.55 1.84

Manufactured Home Non

- weatherized, Condensing Gas Furnaces 2.54 1.83

Manufactured Home Electric Furnace /Modular Blower 2.32 1.6950 

# Markups Analysis

Request for Comment

DOE invites comments and recommendations from interested parties on any aspect relating to the Markups Analysis.51 

# Energy Use Characterization

Purpose: To develop energy consumption savings estimates for selected product efficiency levels. Annual energy consumption is the site energy use associated with 

### operating the product.



## Methodology: Furnace Fan (FF) annual energy use equals the sum of the energy used at each operating mode

– heating, cooling, and constant circulation:

• Furnace Fan Power : Power at air flow and pressure operating conditions that meet the pressure drop requirements for each household.

– Furnace fan performance depends on efficiency level, product class, and furnace fan sizing that meets the heating and cooling needs of the household.

– System curve distribution used depends on product class and availability of central air conditioning.

• Furnace Fan Operating Hours : Determined using RECS 2009 heating and cooling energy use data, furnace fan on

- time ratios, and adjustment factors.

• Impact on Furnace/AC Energy Use : (1) impact of more

- efficient furnace fans on overall energy use of household space conditioning equipment and (2) impact of standby energy use for more

- efficient furnace fans.52 Input Preliminary Analysis NOPR Changes

Furnace Fan Sizing Based on square footage, outdoor design

temperature, and shipments by capacity. Updated with EIA’s RECS 2009 data and new heating/cooling requirements methodology

Fan Performance Curves Based on manufacturer product literature and

test data. Updated with new test data, manufacturer

provided data, and product literature. Updated method for matching fan performance to FER.

System Curves Based on over 1300 field external static

pressure (ESP) measurements from 27 studies: 0.73 in w.c . (NWG, NWO, EF/MB w/ AC) 0.52 in w.c

. ( NWG, NWO,EF/MB w/o AC; WGF ) 0.37 in w.c

. (MH w/ AC); 0.17 in w.c

. (w/o AC) No change to values. For each household, the system curve is set by matching the resulting ESP (from a distribution of ESPs) to the cooling airflow at 400 CFM/tons. Max. ESP set to 1.2 in w.c

.

Heating/Cooling Operating Hours Using EIA’s RECS 2005 and adjusted for

building shell efficiency, average climate conditions, secondary heating equipment, and heat contribution from the motor. Updated to EIA’s RECS 2009 and updated adjustment factors with latest data (see Ch. 7 of TSD).

Continuous Operating Hours Based on Minnesota /Wisconsin survey data

and adjusted for rest of the country to match the provisions in the furnace fan test procedure. No change. Added sensitivities and reference to recent national survey (see Appendix 8

- H of TSD).

Impact on Furnace and AC Equipment Energy Use Calculated impact of more

- efficient furnace

fans on furnace gas and air conditioner electricity use. No change. 

# Energy Use Characterization NOPR Changes to Energy Use Characterization53 

# Energy Use Characterization

Energy Use Determination Methodology

Mfr. Product Lit. &Test Data

System Curves Field Studies Household Furnace Fan Energy Use

Constant Fan Operating Hours Fan Performance Curves

Impact on Furnace/AC Energy Use Power

Operating Hours FER Efficiency levels

RECS 2009 Data

Heating/Cooling Load Adjustments

Constant Fan Operation Field Data Heating & Cooling Fan Operating Hours Furnace Fan Sizing54 

# Energy Use Characterization

Fan Power Determination

NOTE: Vertical dashed lines indicate the airflows at different fan speed settings, while horizontal dashed lines indicate the power use at different fan speed settings.55 

# Energy Use Characterization

Fan Performance Curves Derivation

Deriving Adjustment Factors for Fan Performance Curves to match FER values at each efficiency level

Fan Performance Curves for all product classes and furnace

fan sizes Generate Average Fan Performance Curves (Source: mfr literature & test data)56 

# Energy Use Characterization Fan Curve Methodology

Operating Mode Airflow Criteria Reference Cooling Mode 400 CFM/AC Ton at 0.5 in w.c .* Typical manufacture r conditions.

Heating Mode (High or Low) Fraction of cooling mode airflow

OR Minimum static pressure set in the test procedure at the required CFM airflow rate** (whichever is higher). Typical default heating airflow settings from model data.

Continuous Fan Mode Fraction of cooling mode airflow. Typical default continuous fan mode airflow settings from model data.
* 0.3 in w.c . for manufactured home furnaces ** For example, for 60 kBu /h output capacity  60 kBtu /h/(1.08 * 50 deg temp. rise) = 1111 CFM at 0.20 in w.c

. 

### • Modeled furnace fan airflow performance curves meet the following criteria:

• Furnace fan is sized for each sampled household by taking into account both the heating and cooling requirements of the household based on house square footage, heating and cooling outdoor design temperature, and historical furnace and AC shipments by capacity.



### • Temperature rise of heating is checked to make sure it is met at the external static pressure of the sampled household (if not airflow is adjusted).

• Cooling airflow is adjusted so that it lies between 300 to 500 CFM/ton.57 

# Energy Use Characterization

Fan Performance (CFM vs. ESP)

- Heating Mode (High) Example: Non

- Weatherized (Non

- Condensing) Gas Furnace Fan, 3

- Ton58 

# Energy Use Characterization Operating Hours Furnace Fan Heating or Cooling Operating Mode Hours :

– Adjustment Factors ( AdjFactor ) :

• Adjusting heating/cooling load for building shell efficiency ( based on AEO 2012) and average climate conditions (based on 10

- year NOAA climate data)

• Adjusting RECS 2009 energy use estimates for non - Furnace Fan HVAC energy use

• Adjusting HVAC operating hours for heat produced by the motor (94% useful heat)



## Furnace Fan Constant

- Circulation Operating Mode Hours:

– Based on Wisconsin and Minnesota surveys and adjusted for rest of country resulting in nationally 11% of households using constant circulation.

– Conducted sensitivity analysis with scenarios assuming 9% and 5% of households use constant circulation (see Appendix 8

- H).



### – Referenced recent national survey ( Decision Analyst, American Comfort Survey, Sept. 2013 ) showing that nationally 19% of households frequently use constant circulation.59 

# Energy Use Characterization

Summary of Results
(Non

- Weatherized Gas Furnace Fan, Non

- Condensing & Condensing)

Efficiency Level Non

- Condensing Furnace Condensing Furnace
Annual Electricity Use (kWh) Electricity

Use Savings (kWh) Additional

Fuel Use ( MMBtu ) Annual

Electricity Use (kWh) Electricity

Use Savings (kWh) Additional

Fuel Use ( MMBtu )
Baseline PSC 1014

--- --- 1100

--- --- Improved PSC 894 119 0.13 980 120 0.16

Inverter

- Driven PSC 746 268 0.14 828 273 0.16

Constant

- Torque BPM Motor 572 442 0.45 634 467 0.55
Constant

- Torque BPM Motor and Multi

- Staging 475 539 0.54 541 560 0.64

Constant

- Airflow BPM Motor and Multi

- Staging 471 543 0.52 542 558 0.60

Premium Constant

- Airflow BPM Motor and Multi

- Staging + Backward

- Inclined Impeller 420 593 0.58 488 612 0.6860 

# Energy Use Characterization

Request for Comment

DOE invites comment and recommendations from interested parties on any aspect relating to the Energy Use Characterization.61 

# Life

- Cycle Cost and Payback Period Analysis

1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Environmental Impacts

8 Results and Proposed Standards62 

# Life

- Cycle Cost and Payback Period Analysis

Purpose: D evelop the consumer life

- cycle cost savings and payback period for 

### higher

- efficiency products.



## Methodology:

• LCC equals total installed cost plus the sum of operating expenses discounted to 

### a base year (2019).

• Economic evaluation performed from the consumer perspective.

• Analysis models the uncertainty and variability of inputs using Monte Carlo 

### approach and probability distributions using Excel ® 

### with Crystal Ball. ®63 

# Life

- Cycle Cost and Payback Period Analysis

LCC & Payback Period Analyses Flowchart

Engineering Analysis

Markups to Determine Product Price

Energy Use Characterization Baseline Manufacturer Cost

Std

- Level Manufacturer Cost

Manufacturer Markup

Distributer & Contractor Markups

Sales Tax

Energy Consumption

Marginal Energy Prices Consumer Price

Installation Cost Total Installed Cost

Annual Energy Cost

Repair Cost

Maintenance Cost Annual Operating Expense

Lifetime

Discount Rate

Energy Price Trend Lifetime Operating Expense Payback Period Life

- Cycle

Cost64 Input Purpose/Definition Methodology
Consumer Price Manufacturing cost multiplied by

markups and sales tax. Manufacturing cost: from Engineering Analysis. Markups and Sales Taxes: from Markups Analysis.
Installation Costs Labor and materials necessary to

install appliance. Assumed that a fraction of installations require additional labor at startup to check and adjust airflow.

Maintenance Routine cost to the consumer for

furnace fan maintenance. Assumes blower checking as part of regular equipment maintenance, and is based on maintenance frequency and labor hours and cost.

Repair Cost of replacing or repairing

failed components in the fan. Repair cost is based on failure year, warranty period, labor hours and cost, and material cost. Marginal Energy Prices D evelop average marginal

monthly prices. Multiply most current average annual energy prices by monthly price factors and marginal price factors by geographical area

. Energy Price Trends Project future energy prices. Multiply marginal energy prices by the projected annual energy price trends for the corresponding Census Division.

Discount Rates Determine the present value of

lifetime operating expenses. Derived from estimates of the “finance cost”, which can be interpreted

as: (1) t he financial cost of any debt incurred, or (2) t he opportunity cost of any equity used.

Lifetime Age when the equipment is

retired from service. A ssumed furnace fan lifetime equals furnace equipment lifetime. Furnace lifetime based on shipments, equipment stock, and survey data.

Base

- Case Efficiencies Project market share of products

at each efficiency level in the absence of standards. Projected efficiency market share for each product class based on historical market share data and models information. 

# Life

- Cycle Cost and Payback Period Analysis

LCC Methodology65 Input Data Sources

Maintenance • Maintenance Frequency : based on Decision Analysts, 2008 American Home Comfort Study

• Labor Hours/Cost : based on 2012 RS Means Facility Repair and Maintenance Data

.

Repair • Failure Year : based on fan motor lifetime operating hours from small motors final rule (avg. 30,000);

capacitor lifetime operating hours based on Electrical Industries Alliance EIA

- 456 standard (avg. 60,000); control failure on 12 year average failure from 1992 GTI furnace study and assumed failure rate of 7.5% for simple controls, 15% for moderate complex controls, and 30% for complex controls

• Labor Hours/Cost : based on 2012 RS Means Facility Repair and Maintenance Data

.

• Material Cost : based on Engineering Analysis and Markups Analysis.

• Warranty Period : based on manufacturer product literature and 2008 American Home Comfort Study.

Energy Prices • 1990

- 2011 Form 826 monthly data.

• 1989

- 2011 Natural Gas Navigator monthly data.

• 2009 Short Term Energy Outlook 1995

- 2009 historical data.

• 2011 State Energy Data System (SEDS). Energy Price Trends • 2018

- 2035 trends based on EIA’s AEO 2012 by Census Division.

• After 2035 trends based on Federal Energy Management Program (FEMP) guidelines.

Discount Rates Federal Reserve Board’s Survey of Consumer Finances 1989

- 2010.
Lifetime Shipments data, RECS data on furnace ages, and historical AHS data on the total installed furnace stock.

Base

- Case Efficiencies • PSC Market Shares : Based on testing results and manufacturer provided data.

• BPM Market Shares: Total market share based on stakeholder data. Disaggregated BPM technology based on AHRI’s 2013 furnace model directory and product literature. 

# Life

- Cycle Cost and Payback Period Analysis

Data Sources for LCC Inputs66 Input Preliminary Analysis NOPR Changes Compliance Year 2018 2019
Dollar Year 2011$ 2012$ Building Sample EIA’s RECS 2005 EIA’s RECS 2009
Labor Costs 2011 RS Means 2012 RS Means

Installation Costs Up to one hour of additional labor. Updated methodology; up to two hours of additional labor (see Appendix 8

- D)
Maintenance/Repair Cost annualized; repair cost of motor replacement only Cost added to year of maintenance/repair; added repair cost for controls and capacitor Energy Prices 2010 EIA data 2011 EIA data Energy Price Trends EIA’s AEO 2012 Early Release EIA’s AEO 2012 Full Version

Discount Rates Based on 1989

- 2007 SCF data and historical interest rate data up to 2011 Updated with 2010 SCF data and 2012 interest rate data

Lifetime Different lifetime distribution product classes Same lifetime distribution for all product classes based on stakeholder input and available data

Base

- Case Efficiencies • PSC Market Shares : 50 % for EL 0 and EL 1

• BPM Market Shares: 45% of market in 2018 • PSC Market Shares : 40 % for EL 0 ; 60% for EL 1

• BPM Market Shares: 35% of market in 2019 

# Life

- Cycle Cost and Payback Period Analysis

NOPR Changes to LCC Inputs67 

# Life

- Cycle Cost and Payback Period Analysis

Average Equipment Lifetimes: DOE defines “lifetime” as the age at which residential furnace fan equipment is retired from service. DOE modeled furnace fan lifetime based on the distribution of furnace 

## lifetimes developed for the recent energy conservation standards rulemaking for residential furnaces. DOE welcomes further input on the average equipment lifetimes for the LCC analysis and NIA.

Base

- Case Efficiency Distribution: DOE seeks input on its estimate of the base

- case efficiency distribution of residential furnace fans in 2019. 

## Request for Comment68 

# Life

- Cycle Cost and Payback Period Analysis

LCC and PBP Analysis Results Example: Non

- Weatherized, Condensing Gas Furnace Fan

Efficiency Level Life

- Cycle Cost

2012$ Life

- Cycle Cost Savings Median Payback Period years Installed Cost Discounted

Operating Cost LCC Average

Savings 2012$ % of Consumers that Experience

Net Cost No Impact Net

Benefit

Baseline $339 $2,259 $2,598

--- 0% 100% 0%

---

1 $351 $2,066 $2,417 $49 1% 75% 24% 1.4

2 $398 $1,775 $2,173 $203 21% 41% 38% 4.1

3 $408 $1,506 $1,914 $361 10% 41% 49% 2.7

4 $490 $1,414 $1,904 $371 24% 34% 42% 5.4

5 $658 $1,488 $2,146 $199 45% 29% 27% 11.7

6 $692 $1,415 $2,107 $238 57% 0% 43% 11.069 

# Life

- Cycle Cost and Payback Period Analysis

LCC Consumer Subgroup Analysis
Purpose: E valuate impacts on groups or customers who may be disproportionately affected by a proposed national energy conservation standard.

– DOE evaluated LCC and Payback Period impacts on low

- income households and households occupied by senior citizens (senior

- only households). Example: Non

- Weatherized, Condensing Gas Furnace Fan, Comparison

Efficiency Level Average LCC Savings 2012$ Median Payback Period Years
Low

Income Senior All Low

Income Senior All

1 $32 $41 $49 2.2 1.6 1.4 2 $129 $173 $203 6.6 5.1 4.1 3 $245 $313 $361 4.0 3.2 2.7 4 $212 $301 $371 8.5 6.6 5.4 5 $35 $121 $199 18.3 14.5 11.7 6 $52 $151 $238 16.4 12.2 11.070 

# Life

- Cycle Cost and Payback Period Analysis

Request for Comment

DOE invites comments and recommendations from interested parties on any aspect relating to Life

- Cycle Cost and Payback Period Analysis.71 

# Shipments, NIA, RIA, and MIA Analysis

1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Environmental Impacts

8 Results and Proposed Standards72 

## Purpose: Forecast the furnace fans that would be expected to be shipped between 2019 and 2048, both with and without energy conservation standards. 

## Methodology:

• Shipment Projections : Estimate the number of furnace fans in each product class shipped annually in the absence of new standards (base case) and for the standard cases between 2019 and 2048 regionally and by market segment:

‒ Replacements : Product retirement calculation methodology applied to product stock, which is generated using historical shipments; accounts for the units demolished and early replacements.

‒ New construction : New housing construction projections multiplied by historical market shares.

‒ New Owners : Existing homes that acquire a furnace fan for the first time, including consumers switching between furnace fan product classes.



## • Efficiency Projections : Projects the percent of shipments in each product class at each efficiency level in the base case and for the standard cases.

• Accounted for impact of standards on shipments using price elasticities

. 

# Shipments Analysis73 

# Shipments Analysis

New Installations
Historical Market New Construction Saturations Projected New Housing Starts

Replacement Shipments Historical Annual Shipments

Retirement Function (based on lifetime data) Total Shipments New Owners Historical New Owner Shipments

Switching*

Early Replacements Demolitions** * Switching to other furnace fan product classes (such as non

condensing to condensing) based on historical shipments by efficiency. ** Based on year

- to

- year changes to projected housing stock.74 Input Sources
Historical Annual Shipments • AHRI historical shipments, 1972

- 2012, disaggregated into (1) NWGF and MHGF and (2) OF

• AHRI historical shipments, 2004

- 2009 data for WGF and estimated for other years based on 1972

- 2009 packaged AC unit shipments from DOE’s 2011 CAC standards final rule.

• AHRI 1972

- 2009 historical shipments by efficiency was used to separate condensing vs. non

condensing NWGF shipments.

• Census MHGF new construction data, MHGF lifetime, American Housing Survey (AHS) saturation data used to disaggregate NWGF and MHGF historical shipments.

• For EF, DOE’s 2011 furnace standards final rule historical shipments.

Retirement Function Based on lifetime distribution (see Ch.8).
Historical New Construction Market Saturations • Saturations from Characteristics of New Housing data, U.S. Census Bureau.

• U.S. Census historical housing starts data.

• RECS 2009 saturation data. Projected New Construction Starts EIA’s AEO 2012 projections.

Relative Price Elasticities Based on appliance shipments and household economic data during the period (1980

- 2002).

See Appendix 9

- A. 

# Shipments Analysis

Sources for the Shipment Model75 Input Preliminary Analysis NOPR Changes
Historical Annual Shipments See previous slide for data up to 2010. Updated to 2011 and 2012 AHRI national shipments of gas furnaces and oil

- fired furnaces

Retirement Function Different function for each product class. Single distribution for all product classes.

Early Replacements None Applied to fraction of shipments during the period 1998

- 2010 for NWGF (see Ch. 9).
Historical New Construction Market Saturations See previous slide. Updated with 2011

- 2012 U.S. Census data.

Projected New Construction Starts EIA’s AEO 2011 projections. EIA’s AEO 2012 projections.

Shipments to New Owners Projected new owner shipments, for both

non

- furnace to furnace product and for switching between furnace fan product classes. Updated new owner projected fraction of shipments and updated fraction switching between furnace fan product classes based on stakeholder input and updated data

. Forecasting Condensing Market Shares North : assumed 100% for NWGF and MHGF South : increase from 28% in 2018 to 41% in 2047. North : increase from 75% in 2019 to 97% in 2048. South : increase from 32% in 2019 to 46% in 2048. (Based on updated shipments data.)

Price Elasticities See previous slide. No change. 

# Shipments Analysis

NOPR Changes to Shipments Model76 

# Shipments Analysis

Shipments and Demand Elasticity: To estimate the impact on shipments of the price increase for the considered efficiency levels, DOE used the relative price elasticity approach that was applied in the 

## 2011 energy conservation standards rulemaking for residential furnaces. DOE welcomes stakeholder input and estimates on the effect of amended standards on future furnace fan equipment shipments. DOE also welcomes input and data on the demand elasticity estimates 

## used in the analysis. 

## Request for Comment77 0.0

1.0 2.0 3.0 4.0 5.0

1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 Shipments (millions) MHEF MHGFc MHGFnc EF OF WGF NWGFc NWGFnc Historical Projected 

# Shipments Analysis

Historical and Projected Shipments for Furnace Fans

MH

- EF/MB

MH

- NWG

- C
MH

- NWG

- NC EF/MB
NOW

- NC
WG

- NC
NWG

- C
NWG

- NC78 

# National Impact Analysis

Purpose: Estimate the national impacts of energy conservation standards for furnace fans shipped between 2019 and 2048.

• National Energy Savings (NES): Primary energy savings.

• Net Present Value (NPV) : D ifference between the present value of annual energy expenditures and the present value of annual equipment expenditures.



## Methodology

• For each product class in each standards case : 1. Calculate per

- unit cost increase and per

- unit energy savings due to a standard.



### 2. Calculate number of units (stock) in use and energy savings each year from
2019 to 2048.
3. Combine the above to determine NES and NPV.79 Input Definition/Methodology

National Energy Savings Difference in annual energy savings ( UEC multiplied by equipment stock) between base case and each standards case and summed over the analysis period

. Unit Energy Consumption (UEC) A function of product efficiency for each product class from LCC analysis results. Shipments Projected shipments for each product class under the base case and all standards cases. Equipment Stock Determined yearly stock using annual shipments and lifetimes for each product class.

Rebound Effect Applied to annual UEC and derived using a 2009 Wisconsin field study to estimate the rebound effect for standard cases requiring higher

- efficiency furnace fans.

Base

- Case Efficiencies Developed a distribution of efficiencies in the base case for 2019 (see Ch. 8). In each standards case, “roll

- up” scenario is used to establish the efficiency distribution. Future trends are based on historical data and stakeholder input.

Site

- to

- Power Plant and Full

Fuel

- Cycle (FFC) Energy Factors Converts site energy into primary (power plant) energy consumption. In addition, FFC factors account for the energy used for resource extraction and distribution losses.

National Present Value Difference in installed costs and operating c osts between base case and each standards case discounted to the present and summed over the analysis period Total Installed Cost per Unit Derived as a function of product efficiency for each product class based on LCC analysis.

Total Operating Cost per Unit Includes costs for energy, maintenance , and repair derived as a function of product efficiency for each product class based on LCC analysis.

Discount Factor Used to determine present value of future monetary values based on discount rate

. 

# National Impact Analysis

National Impact Analysis (NIA) Inputs80 Input Preliminary Analysis NOPR Changes Compliance Year 2018 2019
Dollar Year 2011$ 2012$

Discount Factor 3% and 7% in accordance with the Office of

Management and Budget’s guidance. No change

LCC Output Results
to NIA Disaggregated by North and South regions

and by Replacement and New Construction. No change in disaggregation. Values updated based on changes to LCC analysis (see Ch. 8) Energy Price Trends EIA’s AEO 2012 Early Release. EIA’s AEO 2012 Full Version.

Rebound Effect Calculated a separate for the North and

South regions based on the expected increase of constant

- circulation fan use for all BPM designs (20% in the North and 10% in the South). Calculated separately for each product class and efficiency level based on the additional household energy use from the expected increase of
constant

- circulation fan use for higher efficiency furnace fans. (see Ch. 10)

Base

- Case Efficiencies BPM Market Share: increases from 45% in

2018 to 75% in 2047. BPM Market Share: increases from 35% in 2019 t o 45% in 2048.
Site

- to

- Power Plant and Full

- Fuel

- Cycle (FFC) Energy Use Factors DOE derived annual average site

- to

- power

plant and FFC factors based on National Energy Modeling System (NEMS) corresponding to EIA’s AEO 2011. Updated with NEMS data corresponding to EIA’s AEO 2012. 

# National Impact Analysis

NOPR Changes to NIA81 Efficiency

Level Market Share for Non

- weatherized, Condensing Gas Furnace Fans

2019 Base Case 2019 Standards Case 2048 Base Case 1 2 3 4 5 6
Baseline 25% 19%
1 34% 59% 28%
2 0% 0% 59% 0%
3 7% 7% 7% 66% 9 %
4 6% 6% 6% 6% 72% 8 %
5 28% 28% 28% 28% 28% 100% 36%
6 0% 0% 0% 0% 0% 0% 100% 0% 

### • Products below standard will “roll

- up” to comply with standards. Products at or above the standard will not be affected.

• Overall BPM market share trend (35% in 2019 to 45% in 2048) is used to adjust the annual base

- case efficiency for each product class. 

# Base

- Case Efficiencies 

# National Impact Analysis82 

# National Impact Analysis

Rebound Effect: DOE seeks comment on the values that DOE used to characterize the rebound effect with higher

efficiency residential furnace fans.



## Request for Comment

Market Penetration of Higher

- Efficiency Furnace Fans: DOE seeks comment on the long

- term market penetration of 

## higher

- efficiency residential furnace fans.83 

# National Impact Analysis

TSL Selection Criteria for each product class:

• TSL 6: Max

- Tech efficiency levels

• TSL 5 : Yields maximum NPV at 7% discount rate

• TSL 4: Yields maximum NPV at 7% discount rate and for which the percentage of LCC winners is higher than the percentage of LCC losers

• TSL 3: One level lower than TSL 4 , except in the case of OF

• TSL 2: One level lower than TSL3 for MH

- NWG

- NC, MH

- NWG

- C and MH

- EF/MB

• TSL 1: Same as EL1 Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
Non

- Weatherized, Non

- Condensing Gas Furnace Fan 1 3 3 4 4 6
Non

- Weatherized , Condensing Gas Furnace Fan 1 3 3 4 4 6 Weatherized Gas Furnace Fan 1 3 3 4 4 6
Non

- Weatherized Oil Non

- Condensing Furnace Fan 1 1 3 1 3 6
Non

- Weatherized Electric Furnace/Modular Blower Fan 1 3 3 4 4 6 Manufactured Home Non

- Weatherized Gas, Non

- Condensing Furnace Fan 1 1 3 1 3 6 Manufactured Home Non

- Weatherized Gas, Condensing Furnace Fan 1 1 3 1 3 6 Manufactured Home Electric Furnace/Modular Blower Fan 1 1 3 4 4 6



# Trial Standard Levels (TSLs) TSL4 is Proposed TSL

Note: The numbers in the TSL columns represent the applicable efficiency level described in the Engineering Analysis.84 Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
Non

- Weatherized, Non

- Condensing Gas Furnace Fan 0.25 1.02 1.02 1.86 1.86 2.40

Non

- Weatherized , Condensing Gas Furnace Fan 0.28 0.88 0.88 2.00 2.00 2.79

Weatherized Gas Furnace Fan 0.03 0.14 0.14 0.26 0.26 0.34
Non

- Weatherized Oil Non

- Condensing Furnace Fan 0.01 0.01 0.03 0.01 0.03 0.05

Non

- Weatherized Electric Furnace/Modular Blower Fan 0.04 0.20 0.20 0.36 0.36 0.45

Manufactured Home Non

- Weatherized Gas, Non

- Condensing Furnace Fan 0.01 0.01 0.04 0.01 0.04 0.09

Manufactured Home Non

- Weatherized Gas, Condensing Furnace Fan 0.00 0.00 0.01 0.00 0.01 0.02

Manufactured Home Electric Furnace/Modular Blower Fan 0.01 0.01 0.03 0.06 0.06 0.07

Total

– All Classes 0.63 2.27 2.34 4.56 4.62 6.22 

# National Impact Analysis

Primary National Energy Savings (quads)
TSL4 is Proposed TSL85 Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
Non

- Weatherized, Non

- Condensing Gas Furnace Fan 0.26 1.02 1.02 1.87 1.87 2.42

Non

- Weatherized, Condensing Gas Furnace Fan 0.28 0.87 0.87 2.00 2.00 2.80

Weatherized Gas Furnace Fan 0.03 0.14 0.14 0.27 0.27 0.34
Non

- Weatherized Oil Non

- Condensing Furnace Fan 0.00 0.00 0.02 0.00 0.02 0.05

Non

- Weatherized Electric Furnace/Modular Blower Fan 0.04 0.20 0.20 0.36 0.36 0.45

Manufactured Home Non

- Weatherized Gas, Non

- Condensing Furnace Fan 0.01 0.01 0.04 0.01 0.04 0.09

Manufactured Home Non

- Weatherized Gas, Condensing Furnace Fan 0.00 0.00 0.01 0.00 0.01 0.02

Manufactured Home Electric Furnace/Modular Blower Fan 0.01 0.01 0.03 0.06 0.06 0.07

Total

– All Classes 0.63 2.25 2.33 4.58 4.63 6.25 

# National Impact Analysis
Full

- Fuel

- Cycle National Energy Savings (quads)

TSL4 is Proposed TSL86 Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
Non

- Weatherized, Non

- Condensing Gas Furnace Fan 1.46 9.86 9.86 11.09 11.09 8.28

Non

- Weatherized , Condensing Gas Furnace Fan 1.49 11.16 11.16 12.23 12.23 9.20

Weatherized Gas Furnace Fan 0.17 1.12 1.12 1.30 1.30 0.49
Non

- Weatherized Oil Non

- Condensing Furnace Fan 0.02 0.02 0.19 0.02 0.19 0.10

Non

- Weatherized Electric Furnace/Modular Blower Fan 0.15 1.05 1.05 1.29 1.29 0.12

Manufactured Home Non

- Weatherized Gas, Non

- Condensing Furnace Fan 0.04 0.04 0.25 0.04 0.25

- 0.06

Manufactured Home Non

- Weatherized Gas, Condensing Furnace Fan 0.01 0.01 0.05 0.01 0.05

- 0.02

Manufactured Home Electric Furnace/Modular Blower Fan 0.03 0.03 0.13 0.17 0.17

- 0.17

Total

– All Classes 3.37 23.30 23.81 26.16 26.57 17.95 

# National Impact Analysis Net Present Value of Consumer Benefit, Discounted at 3% (billion 2012$)
TSL4 is Proposed TSL87 Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6
Non

- Weatherized, Non

- Condensing Gas Furnace Fan 0.53 3.52 3.52 3.71 3.71 1.98

Non

- Weatherized , Condensing Gas Furnace Fan 0.51 3.78 3.78 3.91 3.91 2.11

Weatherized Gas Furnace Fan 0.06 0.39 0.39 0.41 0.41

- 0.01
Non

- Weatherized Oil Non

- Condensing Furnace Fan 0.01 0.01 0.07 0.01 0.07 0.01

Non

- Weatherized Electric Furnace/Modular Blower Fan 0.05 0.33 0.33 0.40 0.40

- 0.20

Manufactured Home Non

- Weatherized Gas, Non

- Condensing Furnace Fan 0.02 0.02 0.08 0.02 0.08

- 0.09

Manufactured Home Non

- Weatherized Gas, Condensing Furnace Fan 0.00 0.00 0.02 0.00 0.02

- 0.02

Manufactured Home Electric Furnace/Modular Blower Fan 0.01 0.01 0.04 0.05 0.05

- 0.13

Total

– All Classes 1.19 8.07 8.23 8.51 8.64 3.65 

# National Impact Analysis
Net Present Value of Consumer Benefit, Discounted at 7% (billion 2012$)
TSL4 is Proposed TSL88 

## Directed by Executive Order 12866.

Methodology: DOE used modified NIA spreadsheet to evaluate non

- regulatory alternatives to proposed standards:

• Consumer Rebates

• Consumer Tax Credits

• Manufacturer Tax Credits

• Voluntary Energy Efficiency Targets

• Early Replacement

• Bulk Government Purchases



## Results: N o alternative was found to be as beneficial as the proposed energy conservation standards. (See Chapter 17 of the TSD for methodology and results.) 

# Regulatory Impact Analysis

Evaluation of Policy Alternatives89 

# Purpose:

• Assess the impacts of potential energy conservation standards on 

## manufacturers.

• Identify and estimate impacts on manufacturer subgroups that may be more severely affected than the industry as a whole.

• Examine the direct employment, product competition, manufacturing 

## capacity, and cumulative regulatory impacts on the industry.



# Methodology:

• Analyze industry cash flow and industry net present value (INPV) through use of the Government Regulatory Impact Model ( GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop subgroup analyses, and address qualitative issues. 

# Manufacturer Impact Analysis90 

# • Phase 1

– DOE creates an industry profile to characterize the market and identify 

## important issues that require further investigation.



# • Phase 2

– DOE prepares an industry cash flow model and an interview questionnaire to guide subsequent discussions with manufacturers.



# • Phase 3

– DOE interviews manufacturers and assesses the impacts of standards both quantitatively (using the GRIM) and qualitatively (impacts on employment, competition, manufacturing capacity, and regulatory 

## burden). 

# Manufacturer Impact Analysis91 

# Industry Cash Flow Model

• Upstream Inputs

– Market and Technology Assessment (MTA) Industry Profile

– Engineering MPCs

– Shipments



# • MIA Inputs

– Markup Scenarios



## – Conversion Costs 

# Manufacturer Impact Analysis92 

# Markup Scenarios

– Preservation of Gross Margin Percentage



## – Preservation of Operating Profit 

# Manufacturer Impact Analysis

High

- Volume Product Classes Pres. Of Gross Margin Scenario (TSL 4) Pres. Of Operating

Profit Scenario (TSL 4)

Non

- Weatherized, Non

- Condensing Gas Furnaces 1.30 1.25

Non

- Weatherized , Condensing Gas Furnaces 1.31 1.26
Weatherized Non

- Condensing Gas Furnaces 1.27 1.24

Non

- Weatherized Electric Furnace/Modular Blowers 1.19 1.1893 

# Industry Conversion Costs at TSL 4 in 2012 $M 

# Manufacturer Impact Analysis

Product Class Capital Conv Costs Product Conv Costs

Non

- Weatherized, Non

- Condensing Gas Furnace Fan 0 1.20

Non

- Weatherized, Condensing Gas Furnace Fan 0 1.23
Weatherized Non

- Condensing Gas Furnace Fan 0 0.23

Non

- Weatherized Oil Non

- Condensing Furnace Fan 0 0.02
Non

- Weatherized Electric Furnace/Modular Blower Fan 0 0.30

Manufactured Home Non

- Weatherized Gas, Non

Condensing Furnace Fan 0 0.02

Manufactured Home Non

- Weatherized Gas, Condensing Furnace Fan 0 0.01 Manufactured Home Electric Furnace/Modular Blower Fan 0 0.0894 

# Manufacturer Impact Analysis

Base Case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6

INPV (2012 $M) 252.2 249.2 To 252.9 225.5

To 265.7 223.6

To 265.1 197.8

To 286.0 196.7

To 286.5 82.1

To 310.4 Change in INPV (2012 $M) - (3.0 ) To 0.7 (26.7)

to 13.5 (28.6)

to 12.9 (54.4)

to 33.8 (55.5)

to 34.2 (170.1)

to 58.2
Change in INPV (%) - (1.2) To 0.3 (10.6)

To 5.3 (11.3)

To 5.1 (21.6)

To 13.4 (22.0)

To 13.6 (67.5)

To 23.1
Conversion Costs ( 2012 $M) - 1.1 2.8 2.9 3.1 3.2 164.3 

# INPV Results*

* 

### Parentheses indicate negative values.95 

# Small Business Impacts

• 14 small manufacturers were identified.



### • Small manufacturers could have differential impacts relative to larger competitors due to the following:

– Product conversion and certification costs tend to be fixed and do not scale with sales volume.



### – Small manufacturers have fewer engineering and testing resources.

– Small manufacturers lack purchasing power for critical components.

• Comparison of Product Conversion Costs 

# Manufacturer Impact Analysis

TSL 4 Large Manufacturer Small Manufacturer

Product Conversion Cost as a % of Annual Revenue 1% 5%

Product Conversion Cost as a % of Annual R&D Expense 41% 267%96 

# Small Business Impact Comments

Small Business Impacts: DOE seeks comment on the number of small manufacturers; on the potential impacts of new energy conservation standard on those small manufacturers; and on the severity of those impacts.

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD 

## Request for Comment97 

### 1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis
Shipments, NIA, RIA, and MIA Analysis 6

7 Environmental Impacts, Indirect Employment

8 Results and Proposed Standards 

# Public Meeting Agenda98 

# Emissions Analysis

Purpose: Report environmental impacts resulting from potential energy conservation standards due to changes in power plant emissions, as well as site emissions from the use of gas and oil furnaces. 

## Methodology:

• DOE assessed the environmental impacts using NEMS

- BT to derive emissions factors. 

## Results: Energy savings from the proposed standards would be expected to reduce cumulative emissions by:

• 429.78 million metric tons (Mt) of carbon dioxide (CO 2 ),

• 230,900 tons of nitrogen oxides (NO X ),

• 313,460 tons of sulfur dioxide (SO 2 ), and

• 1.77 tons of mercury (Hg).99 

# Monetization of Emission Reductions

Purpose: Estimate the potential monetary benefit of reduced power plant emissions resulting from the considered energy conservation standard levels.



## Methodology:

• DOE used the most current Social Cost of Carbon (SCC) values developed through interagency reviews.

– SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including but not limited to agricultural productivity loss, human health effects, property damage from rising sea level, and changes in the ecosystem.



### • Interagency estimates of the potential global benefits resulting from reduced CO 2 

### emissions in 2015 are $12.9, $40.8, $62.2, and $117.0 per metric ton (2012 $).

• For emission reductions that occur in later years, these values grow in real terms over time.100 

# Monetization of Emission Reductions
Results

TSL SCC Case * ( million 2012$ ) 5% discount rate, average 3% discount rate,

average 2.5% discount rate,

average 3% discount rate,

95 th percentile

Power Sector and Site Emissions** 1 298 1531 2499 4725

2 1121 5747 9378 17733
3 1161 5951 9711 18363
4 2177 11165 18221 34452
5 2205 11309 18455 34894
6 2944 15103 24652 46603

Upstream Emissions 1 10 51 82 156

2 31 160 262 495
3 32 164 268 506
4 70 359 585 1106
5 70 360 588 1111
6 97 497 810 1531

Total Emissions 1 308 1582 2581 4880

2 1152 5907 9639 18228
3 1193 6115 9978 18869
4 2247 11524 18807 35558
5 2275 11669 19043 36005
6 3041 15600 25462 48134

* For each of the four cases, the corresponding SCC value for emissions in 2015 are $ 12.9, $40.8, $62.2, and $117.0 per metric ton (2012$). ** Includes site emissions associated with additional use of natural gas by more

- efficient furnace fans

.101 

# Utility Impact Analysis

Purpose : A ssess impacts on energy supply, specifically the changes in electric installed capacity and generation, that would result from the adoption of potential energy conservation standards

. 

## Methodology:

• DOE modeled the energy savings impacts from the considered standard levels using the National Energy Modeling System (NEMS)

- Building Technologies (BT) (a variant 

### of the NEMS used by EIA for their AEO report) to generate forecasts that deviate from the AEO reference case.

• Outputs of the utility impact analysis include forecasts of electricity generation and avoided capacity increases resulting from the considered standard levels.



## Results: See Chapter 17 of the TSD.102 

# Employment Impact Analysis

Purpose:

• Assess the overall impact on indirect* national employment from the proposed energy conservation standard that results from shifting consumer expenditures among goods and services and changing equipment and energy costs

. 

## Methodology:

• DOE used the Impact of Sector Energy Technologies (ImSET) model for the evaluation of indirect employment impacts.



## Results:

• DOE anticipates that net labor market impacts will be small over time due to the small magnitude of the short

- term effects . (See Chapter 16 of the TSD.)

* Direct national employment impacts are discussed in the Manufacturer Impact Analysis (MIA).103 

### 1 Overview

2 Market Assessment

3 Engineering Analysis



### 4 Energy Use; Markups Analysis

5 Life

- Cycle Cost and Payback Period Analysis
Shipments, NIA, RIA, and MIA Analysis 6

7 Environmental Impacts, Indirect Employment

8 Results and Proposed Standards 

# Public Meeting Agenda104 Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 Consumer Average LCC Savings (2012$) Non

- weatherized, Non

- condensing Gas Furnace Fan (34% of total shipments) $64 $442 $442 $474 $474 $313

Non

- weatherized, Condensing Gas Furnace Fan (39% of total shipments) $49 $361 $361 $371 $371 $238

Non

- weatherized Electric Furnace/Modular Blower Fan (11% of total shipments) $21 $160 $160 $185 $185 $17

Consumer Median PBP (years ) Non

- weatherized, Non

- condensing Gas Furnace Fan 1.3 2.7 2.7 5.4 5.4 11.2

Non

- weatherized, Condensing Gas Furnace Fan 1.4 2.7 2.7 5.4 5.4 11.0

Non

- weatherized Electric Furnace/Modular Blower Fan 2.4 3.2 3.2 3.6 3.6 13.4 

# Results
Consumer Average LCC Savings and Median PBP
TSL4 is Proposed TSL105 TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 Non

- Weatherized, Non

- Condensing Gas Furnace Fan Net Cost (%) 2 18 18 33 33 58 No Impact (%) 68 25 25 14 14 0 Net Benefit (%) 30 57 57 53 53 42

Non

- weatherized, Condensing Gas Furnace Fan Net Cost (%) 1 10 10 24 24 57 No Impact (%) 75 41 41 34 34 0 Net Benefit (%) 24 49 49 42 42 43

Non

- weatherized Electric Furnace/Modular Blower Fan Net Cost (%) 5 20 20 27 27 68 No Impact (%) 73 37 37 25 25 0 Net Benefit (%) 21 42 42 48 48 32 

# Results
Consumer LCC Impacts by Product Class

TSL4 is Proposed TSL106 TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 National Energy Savings (quads) 0.64 2.25 2.33 4.58 4.63 6.25

NPV of Consumer Benefits (2012$ billion, 30 years of shipments) 3% discount rate 3.37 23.30 23.81 26.16 26.57 17.95 7% discount rate 1.19 8.07 8.23 8.51 8.64 3.65

NPV of Consumer Benefits (2012$ billion, 9 years of shipments ) 3% discount rate 1.35 9.36 9.59 10.53 10.72 7.55 7% discount rate 0.63 4.26 4.35 4.50 4.58 2.09 Manufacturer Impacts
Industry NPV (2012$ million) (3.0) to 0.7 (26.7) to

13.5 (28.6) to

12.9 (54.4) to

33.8 (55.5) to

34.2 (170.1) to

58.2 Industry NPV (% change) (1.2) to 0.3 (10.6) to

5.3 (11.3) to

5.1 (21.6) to

13.4 (22.0) to

13.6 (67.5) to

23.1 

# Results NES, NPV, MIA, and Employment Impacts

TSL4 is Proposed TSL107 

# Results

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 Cumulative Emissions Reduction CO 2 (million metric tons) 59.0 220.2 227.9 429.8 435.2 582.3 NO X (thousand tons) 31.2 124.4 128.4 230.9 233.6 308.7 SO 2 (thousand tons) 43.4 155.3 160.4 313.5 316.9 427.4 Hg (tons) 0.2 1.0 1.0 1.8 1.8 2.4 N 2 O (thousand tons) 0.7 2.7 2.8 5.1 5.2 6.9 CH 4 (thousand tons) 132.6 371.0 384.6 913.7 922.3 1295.3 Value of Emissions Reduction

CO 2 (2012$ b illion )* 0.308 to 4.880 1.152 to

18.228 1.193 to

18.869 2.247 to

35.558 2.275 to

36.005 3.041 to

48.134 NO X – 3% discount rate (2012$ billion ) 0.043 0.155 0.161 0.314 0.318 0.428 NO X – 7% discount rate (2012$ b illion ) 0.015 0.054 0.056 0.109 0.111 0.149

* Range of the economic value of CO 2 reductions is based on 2013 draft interagency estimates of the global benefit of reduced CO 2 emissions. 

## Total Emission Impacts

TSL4 is Proposed TSL108 

# Proposed Standards

Product Class FER* (Watts/1000 cfm )

Non

- Weatherized, Non

- Condensing Gas Furnace Fan (NWG

– NC) FER = 0.029 × Q Max + 180

Non

- Weatherized, Condensing Gas Furnace Fan (NWG

– C) FER = 0.029 × Q Max + 196
Weatherized Non

- Condensing Gas Furnace Fan (WG

– NC) FER = 0.029 × Q Max + 135

Non

- Weatherized, Non

- Condensing Oil Furnace Fan (NWO

– NC) FER = 0.051 × Q Max + 301

Non

- Weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB) FER = 0.029 × Q Max + 165 Manufactured Home Non

- Weatherized, Non

- Condensing Gas Furnace Fan (MH

– NWGNC) FER = 0.051 × Q Max + 242

Manufactured Home Non

- Weatherized, Condensing Gas Furnace Fan (MH

– NWG

– C) FER = 0.051 × Q Max + 262
Manufactured Home Electric Furnace/Modular Blower Fan (MH

– EF/MB) FER = 0.029 × Q Max + 105
Manufactured Home Weatherized Non

- Condensing Gas Furnace Fan (MH

– WG

– NC) Reserved

Manufactured Home Non

- Weatherized Non

- Condensing Oil Furnace Fan (MH

– NWO

– NC) Reserved

* Q Max is the airflow, in cfm , at the maximum airflow

- control setting measured using the proposed DOE test procedure

.