83990 Federal Register / Vol. 89, No. 202 / Friday, October 18, 2024 / Rules and Regulations 

1All references to EPCA in this document refer 

to the statute as amended through the Energy Act 

of 2020, Public Law 116–260 (Dec. 27, 2020), which 

reflects the last statutory amendments that impact 

Parts A and A–1 of EPCA. 

2For editorial reasons, upon codification in the 

U.S. Code, Part B was redesignated Part A. 

DEPARTMENT OF ENERGY 

10 CFR Part 430 

[EERE–2021–BT–STD–0029] 

RIN 1904–AE64 

Energy Conservation Program: Energy 

Conservation Standards for Consumer 

Furnace Fans 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Final determination. 

SUMMARY: The Energy Policy and 

Conservation Act, as amended 

(‘‘EPCA’’), prescribes energy 

conservation standards for various 

consumer products and certain 

commercial and industrial equipment, 

including consumer furnace fans. EPCA 

also requires the U.S. Department of 

Energy (‘‘DOE’’) to periodically review 

its existing standards to determine 

whether more-stringent, amended 

standards would be technologically 

feasible and economically justified, and 

would result in significant energy 

savings. In this final determination, 

DOE has determined the energy 

conservation standards for consumer 

furnace fans do not need to be amended. 

DATES: The effective date of this final 

determination is November 18, 2024. 

ADDRESSES: The docket for this activity, 

which includes Federal Register 

notices, public meeting attendee lists 

and transcripts, comments, and other 

supporting documents/materials, is 

available for review at 

www.regulations.gov. All documents in 

the docket are listed in the 

www.regulations.gov index. However, 

not all documents listed in the index 

may be publicly available, such as 

information that is exempt from public 

disclosure. 

The docket web page can be found at 

www.regulations.gov/docket/EERE2021-BT-STD-0029. The docket web 

page contains instructions on how to 

access all documents, including public 

comments, in the docket. 

FOR FURTHER INFORMATION CONTACT: 

Ms. Julia Hegarty, U.S. Department of 

Energy, Office of Energy Efficiency and 

Renewable Energy, Building 

Technologies Office, EE–5B, 1000 

Independence Avenue SW, Washington, 

DC 20585–0121. Telephone: (240) 597– 

6737 Email: ApplianceStandards 

Questions@ee.doe.gov. 

Mr. Eric Stas, U.S. Department of 

Energy, Office of the General Counsel, 

GC–33, 1000 Independence Avenue SW, 

Washington, DC 20585–0121. 

Telephone: (202) 586–4798. Email: 

Eric.Stas@hq.doe.gov. 

For further information on how to 

review the docket, contact the 

Appliance and Equipment Standards 

Program staff at (202) 287–1445 or by 

email: ApplianceStandardsQuestions@

ee.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Synopsis of the Final Determination 

II. Introduction 

A. Authority 

B. Background 

1. Current Standards 

2. Current Rulemaking History 

III. General Discussion and Rationale 

A. General Comments 

B. Product Classes and Scope of Coverage 

C. Test Procedure 

D. Technological Feasibility 

1. General Considerations 

2. Maximum Technologically Feasible 

Levels 

E. Energy Savings 

1. Determination of Savings 

2. Significance of Savings 

F. Cost-Effectiveness 

G. Further Considerations 

1. Economic Impact on Manufacturers and 

Consumers 

2. Savings in Operating Costs Compared To 

Increase in Price 

3. Energy Savings 

4. Lessening of Utility or Performance of 

Products 

5. Impact of Any Lessening of Competition 

6. Need for National Energy Conservation 

7. Other Factors 

IV. Methodology and Discussion of Related 

Comments 

A. Market and Technology Assessment 

1. Product Classes and Scope of Coverage 

2. Technology Options 

3. Impact From Other Rulemakings 

4. Screening Analysis 

a. Screened-Out Technologies 

b. Remaining Technologies 

B. Engineering and Cost Analysis 

1. Efficiency Analysis 

a. Baseline Efficiency 

b. Intermediate Efficiency Levels 

c. Maximum Technology (‘‘Max-Tech’’) 

Efficiency Levels 

d. Summary of Efficiency Levels Analyzed 

2. Cost Analysis 

a. Teardown Analysis 

b. Cost Estimation Method 

3. Cost-Efficiency Results 

C. Markups Analysis 

D. Energy Use Analysis 

E. Life-Cycle Cost and Payback Period 

Analysis 

1. Product Cost 

2. Installation Cost 

3. Annual Energy Consumption 

4. Energy Prices 

5. Maintenance and Repair Costs 

6. Product Lifetime 

7. Discount Rates 

8. Energy-Efficiency Distribution in the NoNew-Standards Case 

9. Payback Period Analysis 

F. Shipments Analysis 

G. National Impact Analysis 

1. Product Efficiency Trends 

2. National Energy Savings 

3. Net Present Value Analysis 

H. Other Factors Related to BackwardInclined Impellers 

V. Analytical Results and Conclusions 

A. Economic Impacts on Individual 

Consumers 

B. National Impact Analysis 

1. National Energy Savings 

2. Net Present Value of Consumer Costs 

and Benefits 

C. Final Determination 

1. BPM Motor With Backward-Inclined 

Impellers 

2. BPM Motors With Forward-Inclined 

Impellers 

3. Summary 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Orders 12866, 

13563, and 14094 

B. Review Under the Regulatory Flexibility 

Act 

C. Review Under the Paperwork Reduction 

Act of 1995 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under the Information Quality 

Bulletin for Peer Review 

M. Congressional Notification 

VII. Approval of the Office of the Secretary 

I. Synopsis of the Final Determination 

The Energy Policy and Conservation 

Act, Public Law 94–163, as amended 

(‘‘EPCA’’),1 authorizes DOE to regulate 

the energy efficiency of a number of 

consumer products and certain 

industrial equipment. (42 U.S.C. 6291– 

6317, as codified) Title III, Part B2 of 

EPCA established the Energy 

Conservation Program for Consumer 

Products Other Than Automobiles. (42 

U.S.C. 6291–6309) These products 

include consumer furnace fans, the 

subject of this final determination. (42 

U.S.C. 6295(f)(4)(D)) 

Pursuant to EPCA, DOE is required to 

review its existing energy conservation 

standards for covered consumer 

products no later than six years after 

issuance of any final rule establishing or 

amending a standard. (42 U.S.C. 

6295(m)(1)) Pursuant to that statutory 

provision, DOE must publish either a 


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3As noted previously, for editorial reasons, upon 

codification in the U.S. Code, Part B was 

redesignated Part A. 

notification of determination that 

standards for the product do not need to 

be amended, or a notice of proposed 

rulemaking (‘‘NOPR’’) including new 

proposed energy conservation standards 

(proceeding to a final rule, as 

appropriate). (Id.) DOE has conducted 

this review of the energy conservation 

standards for consumer furnace fans 

under EPCA’s six-year-lookback 

authority described herein. 

For this final determination, DOE 

analyzed consumer furnace fans subject 

to energy conservation standards 

specified in the Code of Federal 

Regulations (‘‘CFR’’) at 10 CFR 

430.32(y). DOE first analyzed the 

technological feasibility of more energyefficient consumer furnace fans. For 

those consumer furnace fans for which 

DOE determined higher standards to be 

technologically feasible, DOE evaluated 

whether higher standards would be 

cost-effective for consumers by 

conducting life-cycle cost (‘‘LCC’’) and 

payback period (‘‘PBP’’) analyses. In 

addition, DOE estimated energy savings 

that would result from potential energy 

conservation standards by conducting a 

national impact analysis (‘‘NIA’’), in 

which it estimated the net present value 

(‘‘NPV’’) of the total costs and benefits 

experienced by consumers. 

Based on the results of the analyses, 

summarized in section V of this 

document, DOE has determined that the 

current standards for consumer furnace 

fans do not need to be amended and is 

issuing this final determination 

accordingly. 

II. Introduction 

The following sections briefly discuss 

the statutory authority underlying this 

final determination, as well as some of 

the historical background relevant to the 

establishment of energy conservation 

standards for consumer furnace fans. 

A. Authority 

Among other things, EPCA authorizes 

DOE to regulate the energy efficiency of 

a number of consumer products and 

certain industrial equipment. (42 U.S.C. 

6291–6317, as codified) Title III, Part B3

of EPCA established the Energy 

Conservation Program for Consumer 

Products Other Than Automobiles. 

These products include consumer 

furnace fans, the subject of this 

document. (42 U.S.C. 6295(f)(4)(D)) 

Specifically, EPCA authorized DOE to 

establish energy conservation standards 

for electricity used for the purpose of 

circulating air through ductwork. (Id.) 

The energy conservation program 

under EPCA consists essentially of four 

parts: (1) testing; (2) labeling; (3) the 

establishment of Federal energy 

conservation standards, and (4) 

certification and enforcement 

procedures. Relevant provisions of 

EPCA specifically include definitions 

(42 U.S.C. 6291), test procedures (42 

U.S.C. 6293), labeling provisions (42 

U.S.C. 6294), energy conservation 

standards (42 U.S.C. 6295), and the 

authority to require information and 

reports from manufacturers (42 U.S.C. 

6296). 

Federal energy efficiency 

requirements for covered products 

established under EPCA generally 

supersede State laws and regulations 

concerning energy conservation testing, 

labeling, and standards. (42 U.S.C. 

6297(a)–(c)) DOE may, however, grant 

waivers of Federal preemption in 

limited circumstances for particular 

State laws or regulations, in accordance 

with the procedures and other 

provisions set forth under EPCA. (42 

U.S.C. 6297(d)) 

Subject to certain criteria and 

conditions, DOE is required to develop 

test procedures to measure the energy 

efficiency, energy use, or estimated 

annual operating cost of each covered 

product. (42 U.S.C. 6295(o)(3)(A) and 42 

U.S.C. 6295(r)) Manufacturers of 

covered products must use the 

prescribed DOE test procedure as the 

basis for certifying to DOE that their 

product complies with the applicable 

energy conservation standards and as 

the basis for any representations 

regarding the energy use or energy 

efficiency of the product. (42 U.S.C. 

6293(c) and 42 U.S.C. 6295(s)) 

Similarly, DOE must use these test 

procedures to evaluate whether a basic 

model complies with the applicable 

energy conservation standard(s). (42 

U.S.C. 6295(s)) The DOE test procedures 

for consumer furnace fans appear at title 

10 CFR part 430, subpart B, appendix 

AA. 

As noted previously, not later than six 

years after the issuance of any final rule 

establishing or amending a standard, 

DOE must publish either a notice of 

proposed determination (‘‘NOPD’’) that 

standards for the product do not need to 

be amended, or a NOPR including new 

proposed energy conservation standards 

(proceeding to a final rule, as 

appropriate). (42 U.S.C. 6295(m)(1) and 

(3)) EPCA further provides that, not later 

than three years the issuance of a final 

determination not to amend standards, 

DOE must publish either a notification 

of determination that standards for the 

product do not need to be amended, or 

a NOPR including new proposed energy 

conservation standards (proceeding to a 

final rule, as appropriate). (42 U.S.C. 

6295(m)(3)(B)) DOE must make the 

analysis on which a NOPD or NOPR is 

based publicly available and provide an 

opportunity for written comment. (42 

U.S.C. 6295(m)(2)) 

A determination that amended 

standards are not needed must be based 

on consideration of whether amended 

standards will result in significant 

conservation of energy, are 

technologically feasible, and are costeffective. (42 U.S.C. 6295(m)(1)(A) and 

42 U.S.C. 6295(n)(2)) Additionally, any 

new or amended energy conservation 

standard prescribed by the Secretary for 

any type (or class) of covered product 

shall be designed to achieve the 

maximum improvement in energy 

efficiency which the Secretary 

determines is technologically feasible 

and economically justified. (42 U.S.C. 

6295(o)(2)(A)) Among the factors DOE 

considers in evaluating whether a 

proposed standard level is economically 

justified includes whether the proposed 

standard at that level is cost-effective, as 

defined under 42 U.S.C. 

6295(o)(2)(B)(i)(II). Under 42 U.S.C. 

6295(o)(2)(B)(i)(II), an evaluation of 

cost-effectiveness requires DOE to 

consider savings in operating costs 

throughout the estimated average life of 

the covered products in the type (or 

class) compared to any increase in the 

price, initial charges, or maintenance 

expenses for the covered products that 

are likely to result from the standard. 

(42 U.S.C. 6295(n)(2) and 42 U.S.C. 

6295(o)(2)(B)(i)(II)) 

Finally, pursuant to the amendments 

to EPCA contained in the Energy 

Independence and Security Act of 2007 

(‘‘EISA 2007’’), Public Law 110–140, 

any final rule for new or amended 

energy conservation standards 

promulgated after July 1, 2010, is 

required to address standby mode and 

off mode energy use. (42 U.S.C. 

6295(gg)(3)) Specifically, when DOE 

adopts a standard for a covered product 

after that date, it must, if justified by the 

criteria for adoption of standards under 

EPCA (42 U.S.C. 6295(o)), incorporate 

standby mode and off mode energy use 

into a single standard, or, if that is not 

feasible, adopt a separate standard for 

such energy use for that product. (42 

U.S.C. 6295(gg)(3)(A)–(B)) However, in a 

test procedure final rule for furnace fans 

published in the Federal Register on 

January 3, 2014, DOE has previously 

determined that there is no need to 

address standby mode and off mode 

energy use in the standards for 

consumer furnace fans, as the standby 


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mode and off mode energy use 

associated with furnace fans is 

accounted for by the standards and test 

procedures for the products in which 

furnace fans are used (i.e., consumer 

furnaces and consumer central air 

conditioners and heat pumps). 79 FR 

500, 504–505. DOE maintained the same 

approach in the most recent amended 

test procedure for consumer furnace 

fans, which was published in the 

Federal Register on April 12, 2024 

(‘‘April 2024 TP Final Rule’’; 89 FR 

25780, 25782) and continues to do so 

here for the reasons previously stated. 

DOE is publishing this final 

determination pursuant to the six-yearlookback review requirement in EPCA. 

B. Background 

1. Current Standards 

DOE most recently completed a 

review of the subject consumer furnace 

fans standards in a final rule published 

in the Federal Register on July 3, 2014 

(‘‘July 2014 Final Rule’’), through which 

DOE prescribed the current energy 

conservation standards for consumer 

furnace fans manufactured on and after 

July 3, 2019. 79 FR 38130. These 

standards are set forth in DOE’s 

regulations at 10 CFR 430.32(y) and are 

shown in Table II.1. 

TABLE II.1—FEDERAL ENERGY CONSERVATION STANDARDS FOR CONSUMER FURNACE FANS

Furnace fan product class * Fan energy rating ** 

(watts/1,000 cubic feet per minute (‘‘cfm’’)) 

Non-Weatherized, Non-Condensing Gas (‘‘NWG–NC’’) ................................................................. FER = 0.044 * Qmax + 182. 

Non-Weatherized, Condensing Gas (‘‘NWG–C’’) ........................................................................... FER = 0.044 * Qmax + 195. 

Weatherized, Non-Condensing Gas (‘‘WG–NC’’) ........................................................................... FER = 0.044 * Qmax + 199. 

Non-Weatherized, Non-Condensing Oil Furnace Fan (‘‘NWO–NC’’) ............................................. FER = 0.071 * Qmax + 382. 

Non-Weatherized Electric Furnace/Modular Blower Fan (‘‘NWEF/NWMB’’) .................................. FER = 0.044 * Qmax + 165. 

Mobile Home Non-Weatherized, Non-Condensing Gas Furnace Fan (‘‘MH–NWG–NC’’) ............. FER = 0.071 * Qmax + 222. 

Mobile Home Non-Weatherized, Condensing Gas Furnace Fan (‘‘MH–NWG–C’’) ....................... FER = 0.071 * Qmax + 240. 

Mobile Home Electric Furnace/Modular Blower Fan (‘‘MH–EF/MB’’) ............................................. FER = 0.044 * Qmax + 101. 

Mobile Home Non-Weatherized Oil Furnace Fan (‘‘MH–NWO’’) ................................................... Reserved. 

Mobile Home Weatherized Gas Furnace Fan (‘‘MH–WG’’) ............................................................ Reserved. 

* Furnace fans incorporated into hydronic air handlers, small-duct high-velocity (‘‘SDHV’’) modular blowers, SDHV electric furnaces, and central 

air conditioners/heat pump indoor units are not subject to the standards listed in this table. See section IV.A.1 of this document for further discussion. 

** Qmax is the airflow, in cfm, at the maximum airflow-control setting measured using the final DOE test procedure at 10 CFR part 430, subpart 

B, appendix AA. 

2. Current Rulemaking History 

DOE established energy conservation 

standards at 10 CFR 430.32(y) for 

furnace fans through the July 2014 Final 

Rule. 79 FR 38130. As discussed in 

section II.A of this document, EPCA 

authorized DOE to establish energy 

conservation standards for electricity 

used for the purpose of circulating air 

through ductwork. (42 U.S.C. 

6295(f)(4)(D)) While the statutory 

language allows for regulation of the 

electricity use of any electricallypowered device applied to residential 

central heating, ventilation, and air 

conditioning (‘‘HVAC’’) systems for the 

purpose of circulating air through 

ductwork, in the July 2014 Final Rule, 

DOE established standards only for 

certain furnace fans used in furnaces 

and modular blowers. 79 FR 38130, 

38146 (July 3, 2014). Compliance with 

the prescribed standards established for 

consumer furnace fans in the July 2014 

Final Rule was required as of July 3, 

2019. DOE’s energy conservation 

standards for furnace fans use the fan 

energy rating (‘‘FER’’) metric, which is 

the ratio of the electrical energy 

consumption to airflow, expressed as 

watts per 1,000 cubic feet per minute of 

airflow (‘‘W/1,000 cfm’’). 10 CFR 

430.32(y). In evaluating whether 

amended standards for furnace fans are 

warranted, DOE used the test procedure 

for determining FER which is 

established at 10 CFR part 430, subpart 

B, appendix AA, ‘‘Uniform Test Method 

for Measuring the Energy Consumption 

of Furnace Fans’’ (‘‘appendix AA’’). In 

parallel to this rulemaking, DOE 

conducted a test procedure rulemaking 

that considered whether amendments 

were warranted for the current test 

procedure for furnace fans. On May 13, 

2022, DOE published in the Federal 

Register a NOPR concerning the test 

procedure for furnace fans (‘‘May 2022 

TP NOPR’’). 87 FR 29576. Subsequently, 

DOE published the April 2024 TP Final 

Rule. 89 FR 25780. 

In support of the present review of the 

consumer furnace fans energy 

conservation standards, DOE published 

a request for information (‘‘RFI’’) in the 

Federal Register, which identified 

various issues on which DOE sought 

comment to inform its determination of 

whether the standards need to be 

amended, on November 23, 2021 

(‘‘November 2021 RFI’’). 86 FR 66465. 

The following year, on November 1, 

2022, DOE published a notice of 

availability of the preliminary technical 

support document (‘‘November 2022 

Preliminary Analysis’’) and the 

accompanying preliminary technical 

support document (‘‘November 2022 

Preliminary Analysis TSD’’) in the 

Federal Register. 87 FR 65687. In the 

November 2022 Preliminary Analysis, 

DOE assessed potential amended 

standard levels for consumer furnace 

fans. 

On September 20, 2022, a consent 

decree was issued for NRDC et al. v. 

DOE and New York et al. v. DOE that 

mandated that a final agency action 

pertaining to energy conservation 

standards (i.e., a final rule amending 

energy conservation standards or a final 

determination not to amend standards) 

must be issued by October 31, 2024. 

On October 6, 2023, DOE published a 

NOPD (‘‘October 2023 NOPD’’) in the 

Federal Register, which tentatively 

determined that the current standards 

for consumer furnace fans do not need 

to be amended. 88 FR 69826. 

DOE received comments in response 

to the October 2023 NOPD from the 

interested parties listed in Table II.2. 


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4The parenthetical reference provides a reference 

for information located in the docket. (Docket No. 

EERE–2021–BT–STD–0029, which is maintained at 

www.regulations.gov). The references are arranged 

as follows: (commenter name, comment docket ID 

number, page of that document). 

TABLE II.2—LIST OF COMMENTERS WITH WRITTEN SUBMISSIONS IN RESPONSE TO THE OCTOBER 2023 NOPD 

Commenter(s) Abbreviation Comment No. 

in the docket Commenter type 

Air-Conditioning, Heating, & Refrigeration Institute .............................. AHRI ..................... 32 Manufacturer Trade Association. 

Appliance Standards Awareness Project, American Council for an 

Energy-Efficient Economy, National Consumer Law Center, Natural 

Resources Defense Council, New York State Energy Research 

and Development Authority.

Joint Advocates .... 31 Efficiency Advocacy Organization. 

Lennox International ............................................................................. Lennox .................. 30 Manufacturer. 

Michael Ravnitzky ................................................................................. Ravnitzky .............. 29 Individual. 

A parenthetical reference at the end of 

a comment quotation or paraphrase 

provides the location of the item in the 

public record.4

III. General Discussion and Rationale 

DOE developed this final 

determination after a review of the 

market for the subject consumer furnace 

fans. DOE also considered comments, 

data, and information from interested 

parties that represent a variety of 

interests. This final determination 

addresses issues raised by these 

commenters. 

A. General Comments 

This section summarizes general 

comments received from interested 

parties regarding rulemaking timing and 

process, as well as general 

recommendations on the standard 

levels. 

In response to the October 2023 

NOPD, AHRI commented that it agrees 

with DOE’s proposed determination, 

stating that it is reasonable and 

appropriate and that the energy 

conservation standards for consumer 

furnace fans do not need to be amended 

at this time. (AHRI, No. 32 at p. 1) 

Lennox commented that the October 

2023 NOPD indicates that morestringent consumer furnace fan 

efficiency levels would cause most 

consumers to suffer net costs, and it 

supports DOE’s determination to not 

amend furnace fan standards at this 

time. (Lennox, No. 30 at pp. 1–3) 

Ravnitzky supported DOE’s proposed 

determination, stating that the ‘‘costbenefit analysis does not always 

demonstrate clear utility.’’ Ravnitzky 

stated that DOE’s analysis, which 

integrates durability and reliability 

design objectives, ensures that the 

standards developed are both functional 

and advantageous. (Ravnitzky, No. 29 at 

p. 1) Ravnitzky commented that furnace 

fans are used for air circulation both 

when the furnace or air conditioner is 

operating and during its inactive cycle, 

and that DOE’s acknowledgement of 

furnace fan operation in both cycles is 

important to establish feasible and 

relevant standards. (Id.) 

Conversely, the Joint Advocates 

commented that DOE should adopt 

standards that effectively require 

brushless permanent magnet (‘‘BPM’’) 

motors for all product classes (including 

oil and mobile home gas furnaces). 

(Joint Advocates, No. 31 at pp. 1–2) The 

Joint Advocates commented that, 

because DOE’s analysis shows about 90 

percent of mobile home gas furnaces 

achieve an efficiency level that assumes 

EL 1 (i.e., a BPM motor), the availability 

of those products would likely not be 

affected by an amended standard. (Joint 

Advocates, No. 31 at pp. 1–2) 

As part of the rulemaking process, 

DOE carefully considers the benefits 

and burdens of potential amended 

standards to determine whether the 

potential amended standards are the 

maximum standard levels that are 

technologically feasible and 

economically justified and would 

conserve a significant amount of energy, 

as required by EPCA (see 42 U.S.C. 

6295(o)(2)(A) and (3)(B)). Given the 

small role of NWO–NC, MH–NWG–NC, 

MH–NWG–C, and MH–NWO in the 

overall furnace market, the declining 

shipments for the affected product 

classes, and the number of products that 

incorporate a BPM motor today, DOE 

concludes that the energy savings 

potential from this design option is 

limited. Further, DOE has concerns 

about availability of products if 

standards are amended. If any products 

lines are required to be updated, that 

may lead to manufacturers to choose to 

leave the market, thereby potentially 

impacting consumers if the market 

becomes more concentrated. This topic 

is discussed further in section IV of this 

document, which outlines DOE’s 

approach to analyzing potential 

amended standard levels, and section V 

of this document, which includes a 

discussion of market considerations, as 

well as a detailed explanation of DOE’s 

weighing of the benefits and burdens 

and the rationale for proposing not to 

amend standards for consumer furnace 

fans. 

Ravnitzky recommended that DOE 

should mandate that manufacturers 

disclose the relative energy efficiency of 

the fans used in air handlers and air 

conditioners. The commenter stated that 

implementing an easily comparable 

metric/rating would allow consumers to 

make more energy-conscious decisions 

and encourage manufacturers to 

innovate their products. Ravnitzky 

further stated that, by mandating this 

information, DOE could create a market 

environment in which energy efficiency 

is a top consideration for product 

development and consumer purchasing. 

(Ravnitzky, No. 29 at p. 1) Further, 

Ravnitzky commented that DOE should 

establish a periodic review process to 

assess the standards’ real-world 

performance and impact, evaluating the 

longevity, consumer satisfaction, and 

environmental benefits of the 

established standards in order to 

guarantee that standards adapt to 

technological advancements and market 

trends. (Id. at pp. 1–2) Finally, 

Ravnitzky commented that DOE should 

develop partnerships with industry 

experts and consumer advocacy groups 

to create refined and impactful energy 

conservation measures. (Id. at p. 2) 

In response, DOE notes that the 

electrical energy consumption of fans 

used in HVAC products such as air 

handlers and air conditioners are 

accounted for by the seasonal energy 

efficiency ratio 2 (‘‘SEER2’’) and heating 

seasonal performance factor 2 

(‘‘HSPF2’’) metrics measured by the test 

procedure for central air conditioners 

(‘‘CACs’’) and heat pumps at 10 CFR 

part 430, subpart B, appendix M1 

(‘‘Appendix M1’’). These products are 

rated using a different metric than that 

used for furnace fans, as they have 

different functionalities and cannot not 

be directly compared. With regard to 

Ravnitzky’s suggestion that DOE 

establish a collaborative, periodic 

review process, DOE notes that, as 

outlined in section II.A of this 


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document, DOE is required to review its 

existing energy conservation standards 

for covered consumer products no later 

than six years after issuance of any final 

rule establishing or amending a 

standard (42 U.S.C. 6295(m)(1)) or three 

years after a determination that 

standards for the product do not need to 

be amended. (42 U.S.C. 6295(m)(3)(B)) 

In these reviews, DOE assesses factors 

including the economic impact of 

standards on consumers and national 

energy savings to capture the real-world 

impacts of amended standards. As a part 

of this process, DOE regularly engages 

with industry stakeholders through 

manufacturer interviews, public 

meetings/webinars, and written 

comments. 

B. Product Classes and Scope of 

Coverage 

When evaluating and establishing 

energy conservation standards, DOE 

divides covered products into product 

classes by the type of energy used or by 

capacity or other performance-related 

features that justify differing standards. 

In making a determination whether a 

performance-related feature justifies a 

different standard, DOE must consider 

factors such as the utility of the feature 

to the consumer and other factors DOE 

determines are appropriate. (42 U.S.C. 

6295(q)) The scope of coverage and 

product classes for this final 

determination are discussed in further 

detail in section IV.A.1 of this 

document. This final determination 

covers those consumer products that 

meet the definition of a ‘‘furnace fan’’ as 

codified at 10 CFR 430.2. That provision 

states that a ‘‘furnace fan’’ is defined as 

an electrically-powered device used in a 

consumer product for the purpose of 

circulating air through ductwork. Id. 

DOE did not receive any comments on 

product classes and scope of coverage in 

response to the October 2023 NOPD. 

Consequently, DOE is maintaining the 

same approach for the final 

determination. 

C. Test Procedure 

EPCA sets forth generally applicable 

criteria and procedures for DOE’s 

adoption and amendment of test 

procedures. (42 U.S.C. 6293) 

Manufacturers of covered products must 

use these test procedures to quantify the 

efficiency of their product and as the 

basis for certifying to DOE that their 

product complies with the applicable 

energy conservation standards and as 

the basis for any representations 

regarding the energy use or energy 

efficiency of the product. (42 U.S.C. 

6295(s) and 42 U.S.C. 6293(c)) 

Similarly, DOE must use these test 

procedures to evaluate whether a basic 

model complies with the applicable 

energy conservation standard(s) 

pursuant to EPCA. (42 U.S.C. 6295(s); 10 

CFR 429.110(e)) 

The current test procedure for 

consumer furnace fans is codified at 10 

CFR part 430, subpart B, appendix AA, 

Uniform Test Method for Measuring the 

Energy Consumption of Furnace Fans. 

Appendix AA includes provisions for 

determining the FER, the metric on 

which current standards are based (see 

10 CFR 430.32(y)). DOE most recently 

updated appendix AA on April 12, 

2024, when DOE published the April 

2024 TP Final Rule in the Federal 

Register. 89 FR 25780. The April 2024 

TP Final Rule adopted the following 

changes: 

(1) Specify testing instructions for 

furnace fans incapable of operating at 

the required external static pressure 

(‘‘ESP’’); 

(2) Incorporate by reference the most 

recent versions of industry standards, 

ASHRAE 103–2017 and ASHRAE 37– 

2009 (RA 2019), in 10 CFR 430.3; 

(3) Incorporate by reference chapter 1 

of the 2021 ASHRAE Handbook; 

(4) Define ‘‘dual-fuel furnace fans’’ 

and exclude them from the scope of 

appendix AA; 

(5) Change the term ‘‘default airflow 

control settings’’ to ‘‘specified airflow 

control settings’’; 

(6) Make clarifications to 

nomenclature, correct the value of the 

conversion factor from watts to British 

Thermal Units per hour (‘‘Btu/h’’), and 

correct the units of specific volume of 

dry air; 

(7) Revise the ambient temperature 

conditions allowed during testing to 

between 65 degrees Fahrenheit (‘‘°F’’) 

and 85 °F for all units (both condensing 

and non-condensing); 

(8) Assign an allowable range of 

relative humidity during testing to be 

between 20 percent and 80 percent; and 

(9) Require that the power 

measurements be determined as an 

average over the last 30 seconds of each 

steady-state period at intervals of no less 

than 1 per second, rather than taken as 

a single point measurement. 

Id. at 89 FR 25780, 25783 (April 12, 

2024). 

DOE did not receive any comments on 

the furnace fans test procedure in 

response to the October 2023 NOPD. 

D. Technological Feasibility 

1. General Considerations 

As discussed, a determination that 

amended energy conservation standards 

are not needed must be based on 

consideration of whether amended 

standards would result in significant 

conservation of energy, are 

technologically feasible, and are costeffective. (42 U.S.C. 6295(m)(1)(A) and 

42 U.S.C. 6295(n)(2)) 

To determine whether potential 

amended standards would be 

technologically feasible, DOE first 

develops a list of all known 

technologies and design options that 

could improve the efficiency of 

products that are the subject of the 

determination. DOE considers 

technologies incorporated in 

commercially-available products or in 

working prototypes to be 

‘‘technologically feasible.’’ 10 CFR part 

430, subpart C, appendix A, sections 

6(b)(3)(i) and 7(b)(1). Section IV.A.2 of 

this document discusses the technology 

options identified and considered by 

DOE for this analysis for consumer 

furnace fans. 

After DOE has determined which, if 

any, technologies and design options are 

technologically feasible, it further 

evaluates each technology and design 

option in light of the following 

additional screening criteria: (1) 

practicability to manufacture, install, 

and service; (2) adverse impacts on 

product utility or availability; (3) 

adverse impacts on health or safety; and 

(4) unique-pathway proprietary 

technologies. 10 CFR part 430, subpart 

C, appendix A, sections 6(b)(3)(ii)–(v) 

and 7(b)(2)–(5). Those technology 

options that are ‘‘screened out’’ based 

on these criteria are not considered 

further. Those technology and design 

options that are not screened out are 

considered as the basis for higher 

efficiency levels that DOE could 

consider for potential amended 

standards. Section IV.A.4 of this 

document discusses the results of the 

screening analysis conducted for this 

final determination. 

2. Maximum Technologically Feasible 

Levels 

EPCA requires that for any proposed 

rule that prescribes an amended or new 

energy conservation standard or 

prescribes no amendment or no new 

standard for a type (or class) of covered 

product, DOE must determine the 

maximum improvement in energy 

efficiency or maximum reduction in 

energy use that is technologically 

feasible for each type (or class) of 

covered products. (42 U.S.C. 6295(p)(1)) 

Accordingly, in the engineering 

analysis, DOE identifies the maximum 

technologically feasible efficiency level 

currently available on the market for 

consumer furnace fans. DOE also 

defines such ‘‘max-tech’’ efficiency 

level, representing the maximum 


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5 In applying these design options, DOE would 

only include those that are compatible with each 

other that when combined, would represent the 

theoretical maximum possible efficiency. 

6 DOE also presents a sensitivity analysis that 

considers impacts for products shipped in a nineyear period. 

7The FFC metric is discussed in DOE’s statement 

of policy and notice of policy amendment. 76 FR 

51281 (August 18, 2011), as amended at 77 FR 

49701 (August 17, 2012). 

8The numeric threshold for determining the 

significance of energy savings established in a final 

rule published in the Federal Register on February 

14, 2020 (85 FR 8626, 8670) was subsequently 

eliminated in a final rule published in the Federal 

Register on December 13, 2021 (86 FR 70892). 

theoretical efficiency that can be 

achieved through the application of all 

available technology options retained 

from the screening analysis.5 In many 

cases, the max-tech efficiency level is 

not commercially available because it is 

not currently economically feasible. The 

max-tech levels that DOE determined 

for this analysis are described in section 

IV.B.1.c of this final determination. 

E. Energy Savings 

1. Determination of Savings 

For each efficiency level (‘‘EL’’) 

evaluated, DOE projects anticipated 

energy savings from application of the 

EL to the consumer furnace fan products 

purchased during the 30-year period 

that begins in the assumed year of 

compliance with potential amended 

standards (2030–2059).6 The savings are 

measured over the entire lifetime of 

products purchased during the 30-year 

analysis period. DOE quantifies the 

energy savings attributable to each EL as 

the difference in energy consumption 

between each standards case and the nonew-standards case. The no-newstandards case represents a projection of 

energy consumption that reflects how 

the market for such products would 

likely evolve in the absence of amended 

energy conservation standards. 

DOE uses its NIA spreadsheet models 

to estimate national energy savings 

(‘‘NES’’) from potential amended 

standards for the products analyzed. 

The NIA spreadsheet model (described 

in section IV.G of this document) 

calculates energy savings in terms of site 

energy, which is the energy directly 

consumed by the products at the 

locations where they are used. For 

electricity, DOE reports NES in terms of 

primary energy savings, which is the 

savings in the energy that is used to 

generate and transmit the site 

electricity. For natural gas, the primary 

energy savings are considered to be 

equal to the site energy savings. DOE 

also calculates NES in terms of full-fuelcycle (‘‘FFC’’) energy savings. The FFC 

metric includes the energy consumed in 

extracting, processing, and transporting 

primary fuels (i.e., coal, natural gas, 

petroleum fuels), and, thus, presents a 

more complete picture of the impacts of 

energy conservation standards.7 DOE’s 

approach is based on the calculation of 

an FFC multiplier for each of the energy 

types used by covered products. Section 

IV.G.2 of this document provides more 

information on FFC energy savings. 

2. Significance of Savings 

As discussed, a determination that 

amended standards are not needed must 

be based on consideration of whether 

amended standards will result in 

significant conservation of energy, 

among other factors. (42 U.S.C. 

6295(m)(1)(A) and 42 U.S.C. 6295(n)(2)) 

The significance of energy savings 

offered by a new or amended energy 

conservation standard cannot be 

determined without knowledge of the 

specific circumstances surrounding a 

given rulemaking.8 For example, for 

some covered products, most of the 

energy consumption occurs during 

periods of peak energy demand. The 

impacts of these products on the energy 

infrastructure can be more pronounced 

than the impacts of products with 

relatively constant demand. 

Accordingly, DOE evaluates the 

significance of energy savings on a caseby-case basis. The significance of energy 

savings is further discussed in section 

V.B.1 of this final determination. 

F. Cost-Effectiveness 

As discussed, a determination that 

amended standards are not needed must 

be based on consideration of whether 

amended standards would be costeffective, among other factors. (42 U.S.C. 

6295(m)(1)(A) and 42 U.S.C. 6295(n)(2)) 

In evaluating cost-effectiveness, EPCA 

requires DOE to consider savings in 

operating costs throughout the 

estimated average life of the covered 

product in the type (or class) compared 

to any increase in the price, initial 

charges, or maintenance expenses for 

the covered product that are likely to 

result from the standard. (42 U.S.C. 

6295(n)(2)(c) and 42 U.S.C. 

6295(o)(2)(B)(i)(II)) Cost-effectiveness is 

also one of the factors that DOE 

considers under 42 U.S.C. 6295(o)(2)(B) 

in determining whether new or 

amended standards are economically 

justified. (42 U.S.C. 6295(o)(2)(B)(i)(II)) 

In determining cost-effectiveness of 

potential amended standards for 

covered products, DOE generally 

conducts LCC and PBP analyses that 

estimate the costs and benefits to users 

from potential standards. Section IV.E of 

this document provides more 

information on the LCC and PBP 

analyses conducted for this final 

determination. To further inform DOE’s 

consideration of the cost-effectiveness of 

potential amended standards, DOE 

considered the NPV of total costs and 

benefits estimated as part of the NIA. 

The inputs for determining the NPV of 

the total costs and benefits experienced 

by consumers are: (1) total annual 

installed cost, (2) total annual operating 

costs (energy costs and repair and 

maintenance costs), and (3) a discount 

factor to calculate the present value of 

costs and savings. The results of this 

analysis are discussed in section V.C.3 

of this document. 

G. Further Considerations 

In determining whether a potential, 

more-stringent standard is economically 

justified, DOE must determine whether 

the benefits of the standard exceed its 

burdens. (42 U.S.C. 6295(o)(2)(B)(i)) 

DOE must make this determination after 

receiving comments on the proposed 

standard, and by considering, to the 

greatest extent practicable, the following 

seven statutory factors: 

(1) The economic impact of the 

standard on manufacturers and 

consumers of the product subject to the 

standard; 

(2) The savings in operating costs 

throughout the estimated average life of 

the covered product in the type (or 

class) compared to any increase in the 

price, initial charges for, or maintenance 

expenses of the covered product that are 

likely to result from the standard; 

(3) The total projected amount of 

energy (or as applicable, water) savings 

likely to result directly from the 

standard; 

(4) Any lessening of the utility or the 

performance of the covered product 

likely to result from the standard; 

(5) The impact of any lessening of 

competition, as determined in writing 

by the Attorney General, that is likely to 

result from the standard; 

(6) The need for national energy and 

water conservation; and 

(7) Other factors the Secretary 

considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII)) 

The following sections discuss how 

DOE has addressed each of these seven 

factors in this final determination. 

1. Economic Impact on Manufacturers 

and Consumers 

In determining the impacts of a 

potential new or amended standard on 

manufacturers, DOE conducts a 

manufacturing impact analysis (‘‘MIA’’). 

DOE first uses an annual cash-flow 

approach to determine the quantitative 

impacts. This step includes both a shortVerDate Sep<11>2014 17:13 Oct 17, 2024 Jkt 265001 PO 00000 Frm 00007 Fmt 4701 Sfmt 4700 E:\FR\FM\18OCR3.SGM 18OCR3

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term assessment—based on the cost and 

capital requirements during the period 

between when a regulation is issued and 

when entities must comply with the 

regulation—and a long-term assessment 

over a 30-year period. The industrywide impacts analyzed include: (1) 

industry net present value, which 

values the industry on the basis of 

expected future cash flows; (2) cash 

flows by year; (3) changes in revenue 

and income; and (4) other measures of 

impact, as appropriate. Since DOE has 

determined not to amend the standards 

for consumer furnace fans, this final 

determination will have no cash-flow 

impacts on manufacturers. Accordingly, 

DOE did not conduct an MIA for this 

final determination. 

For individual consumers, measures 

of economic impact include the changes 

in LCC and PBP associated with new or 

amended standards. These measures are 

discussed further in the following 

section. For consumers in the aggregate, 

DOE also calculates the national NPV of 

the consumer costs and benefits 

expected to result from particular 

standards. DOE also evaluates the 

impacts of potential standards on 

identifiable subgroups of consumers 

that may be affected disproportionately 

by a standard. Since DOE has 

determined not to amend the standards 

for consumer furnace fans, this final 

determination will have no 

disproportionate impact on identifiable 

subgroups of consumers. Accordingly, 

DOE did not conduct a subgroup 

analysis for this final determination. 

2. Savings in Operating Costs Compared 

To Increase in Price 

EPCA requires DOE to consider the 

savings in operating costs throughout 

the estimated average life of the covered 

product in the type (or class) compared 

to any increase in the price of, or in the 

initial charges for, or maintenance 

expenses of, the covered products that 

are likely to result from a standard. (42 

U.S.C. 6295(m)(1); 42 U.S.C. 6295(n)(2), 

and 42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE 

conducts this comparison in its LCC and 

PBP analyses. 

For its LCC and PBP analyses, DOE 

assumes that consumers will purchase 

the covered product in the first year of 

compliance with new or amended 

standards. The LCC savings for the 

considered efficiency levels are 

calculated relative to the case that 

reflects projected market trends in the 

absence of new or amended standards. 

DOE’s LCC and PBP analyses is 

discussed in further detail in section 

IV.E of this document. 

3. Energy Savings 

EPCA requires DOE, in determining 

the economic justification of an 

amended standard, to consider the total 

projected energy savings that are 

expected to result directly from the 

standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) 

As discussed in section IV.G of this 

document, DOE uses the NIA 

spreadsheet models to project national 

energy savings that are expected to 

result directly from an amended 

standard. 

4. Lessening of Utility or Performance of 

Products 

In establishing product classes and in 

evaluating design options and the 

impact of potential standard levels, DOE 

evaluates potential standards that would 

not lessen the utility or performance of 

the considered product. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) Since DOE has 

determined not to amend the standards 

for consumer furnace fans, this final 

determination will not impact the utility 

of such products. 

5. Impact of Any Lessening of 

Competition 

EPCA directs DOE to consider the 

impact of any lessening of competition, 

as determined in writing by the 

Attorney General, that is likely to result 

from a standard. (42 U.S.C. 

6295(o)(2)(B)(i)(V)) Since DOE has 

determined not to amend the standards 

for consumer furnace fans, DOE did not 

transmit a copy of its determination to 

the Attorney General for anticompetitive review. 

6. Need for National Energy 

Conservation 

DOE also considers the need for 

national energy conservation in 

determining whether a new or amended 

standard is economically justified. (42 

U.S.C. 6295(o)(2)(B)(i)(VI)) The energy 

savings from the standards are likely to 

provide improvements to the security 

and reliability of the Nation’s energy 

system. Reductions in the demand for 

electricity also may result in reduced 

costs for maintaining the reliability of 

the Nation’s electricity system. DOE 

generally conducts a utility impact 

analysis to estimate how standards may 

affect the Nation’s needed power 

generation capacity. However, since 

DOE has determined not to amend the 

standards for consumer furnace fans, 

DOE did not conduct this analysis. 

DOE maintains that environmental 

and public health benefits associated 

with the more efficient use of energy are 

important to take into account when 

considering the need for national energy 

conservation. Amended standards are 

likely to result in environmental 

benefits in the form of reduced 

emissions of air pollutants and 

greenhouse gases associated with energy 

production and use. DOE generally 

conducts an emissions analysis to 

estimate how amended standards may 

affect these emissions. DOE also 

generally estimates the economic value 

of emissions reductions resulting from 

an amended standard. However, since 

DOE has determined not to amend the 

standards for consumer furnace fans, 

DOE did not conduct this analysis. 

7. Other Factors 

In determining whether an energy 

conservation standard is economically 

justified, DOE may consider any other 

factors that the Secretary deems to be 

relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) 

To the extent DOE identifies any 

relevant information regarding 

economic justification that does not fit 

into the other categories described 

previously, DOE could consider such 

information under ‘‘other factors.’’ 

IV. Methodology and Discussion of 

Related Comments 

The following sections of this 

document address each key component 

of the analyses DOE has performed for 

this final determination with respect to 

consumer furnace fans. Comments 

received from interested parties are 

addressed in each relevant section. 

A. Market and Technology Assessment 

DOE develops information in the 

market and technology assessment that 

provides an overall picture of the 

market for the products concerned, 

including the purpose of the products, 

the industry structure, manufacturers, 

market characteristics, and technologies 

used in the products. This activity 

includes both quantitative and 

qualitative assessments, based primarily 

on publicly-available information. The 

subjects addressed in the market and 

technology assessment for this final 

determination include: (1) identification 

of the scope and product classes, (2) 

manufacturers and industry structure, 

(3) existing efficiency programs, (4) 

shipments information, (5) market and 

industry trends, and (6) technologies or 

design options for improving efficiency 

of consumer furnace fans. The key 

findings of DOE’s market assessment are 

summarized in the following sections. 

1. Product Classes and Scope of 

Coverage 

In the October 2023 NOPD, DOE 

evaluated products within the same 

scope as those products for which DOE 

initially established energy conservation 


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standards in the July 2014 Final Rule. 

88 FR 69826, 69832 (Oct. 6, 2023). In 

this final determination, DOE is 

maintaining the scope of coverage as 

presented in the October 2023 NOPD. 

Products evaluated in this final 

determination include: 

• Furnace fans used in weatherized 

and non-weatherized gas furnaces, oil 

furnaces, and electric furnaces; and 

• Modular blowers 

Consistent with the approach taken in 

the July 2014 Final Rule, products not 

addressed in this rulemaking include: 

• Furnace fans used in other 

products, such as split-system CACs and 

heat pump indoor units, through-thewall indoor units, small-duct highvelocity indoor units, energy recovery 

ventilators, heat recovery ventilators, 

draft inducer fans, exhaust fans, and 

hydronic air handlers; and 

• Fans used in any non-ducted 

products, such as whole-house 

ventilation systems without ductwork, 

CAC condensing unit fans, room fans, 

and furnace draft inducer fans (because 

these products do not circulate air 

through ductwork). 

DOE has previously determined that 

the DOE test procedure for furnace fans 

is not currently equipped to address 

fans contained in CACs, heat pumps, or 

other products. 79 FR 38130, 38149 

(July 3, 2014). As mentioned in section 

III.A of this document, DOE has 

previously determined that SEER2 and 

HSPF2 capture a representative measure 

of CAC and heat pump performance, 

including fan energy consumption, 

during heating and cooling operations, 

and that the test method for determining 

these metrics is provided in appendix 

M1. (See, for example, discussion of 

appendix M1 amendments at 82 FR 

1426, 1446–1460 (Jan. 5, 2017)) 

Therefore, DOE has not established 

standards covering such products. (42 

U.S.C. 6295(o)(3)) Additionally, any 

products that are non-ducted or that do 

not move air through ductwork (e.g., 

draft inducer fans) would not meet the 

definition of a furnace fan and are, 

therefore, out of scope of the existing 

regulations. 

When evaluating and establishing or 

amending energy conservation 

standards, DOE may establish separate 

standards for a group of covered 

products (i.e., establish a separate 

product class) if DOE determines that 

separate standards are justified based on 

the type of energy used, or if DOE 

determines that the product has a 

capacity or other performance-related 

feature which other products within 

such type (or class) do not have and 

such feature justifies a different 

standard. (42 U.S.C. 6295(q)) In making 

a determination whether a performancerelated feature justifies a different 

standard, DOE considers such factors as 

the utility of the feature to the consumer 

and other factors DOE determines are 

appropriate. (Id.) 

In its regulations at 10 CFR 430.32(y), 

DOE currently categorizes furnace fans 

into 10 product classes, as presented in 

Table IV.1. In the proposed 

determination, DOE maintained these 

10 classes, with the exception of a 

change to the mobile home nonweatherized oil furnace fan (‘‘MH– 

NWO’’) class discussed later in this 

section. 88 FR 69826, 69833 (Oct. 6, 

2023). 

TABLE IV.1—CURRENT CONSUMER FURNACE FAN PRODUCT CLASSES

Product class 

Non-Weatherized, Non-Condensing Gas Furnace Fan (‘‘NWG–NC’’). 

Non-Weatherized, Condensing Gas Furnace Fan (‘‘NWG–C’’). 

Weatherized Non-Condensing Gas Furnace Fan (‘‘WG–NC’’). 

Non-Weatherized, Non-Condensing Oil Furnace Fan (‘‘NWO–NC’’). 

Non-Weatherized Electric Furnace/Modular Blower Fan (‘‘NWEF/NWMB’’). 

Mobile Home Non-Weatherized, Non-condensing Gas Furnace Fan (‘‘MH–NWG–NC’’). 

Mobile Home Non-Weatherized, Condensing Gas Furnace Fan (‘‘MH–NWG–C’’). 

Mobile Home Electric Furnace/Modular Blower Fan (‘‘MH–EF/MB’’). 

Mobile Home Non-Weatherized Oil Furnace Fan (‘‘MH–NWO’’).* 

Mobile Home Weatherized Gas Furnace Fan (‘‘MH–WG’’).* 

* DOE created the MH–NWO and MH–MG product classes in the July 2014 Final Rule, but these classes do not currently have energy conservation standards. 

As directed by EPCA and as 

previously noted, DOE must specify a 

different standard level for a type or 

class of products that has the same 

function or intended use if DOE 

determines that products within such 

group: (A) consume a different kind of 

energy from that consumed by other 

covered products within such type (or 

class), or (B) have a capacity or other 

performance-related feature that other 

products within such type (or class) do 

not have and such feature justifies a 

higher or lower standard. (42 U.S.C. 

6295(q)(1)) As shown in Table IV.1, 

there are four determinants of product 

class for consumer furnace fans: (1) 

whether the associated furnace is nonweatherized or weatherized; (2) whether 

the associated furnace uses condensing 

or non-condensing technology; (3) 

whether or not the associated furnace is 

designed for use in a mobile home, and 

(4) the type of fuel used by the 

associated furnace. DOE’s adoption of 

product classes for condensing and noncondensing furnace fans is discussed in 

the July 3, 2014 Furnace Fans ECS Final 

Rule and the December 18, 2023 

Furnaces ECS Final Rule published in 

the Federal Register at 79 FR 38130, 

38149–38150 and 88 FR 87502, 87537, 

respectively. 

In the July 2014 Final Rule, DOE 

created product classes for MH–NWO 

furnace fans and MH–WG furnace fans, 

but DOE did not analyze or prescribe 

standards for either product class 

because of the lack of available data for 

those product classes. 79 FR 38130, 

38150 (July 3, 2014). DOE is not aware 

of any products that would be 

considered MH–WG furnace fans at this 

time. However, DOE has become aware 

of a limited number of MH–NWO 

furnace fans that have been introduced 

to the market. The MH–NWO furnace 

fans that DOE identified are all used in 

non-condensing furnaces, so DOE 

analyzed a subset of the previously 

established but unanalyzed class— 

mobile home non-weatherized, oil, noncondensing (‘‘MH–NWO–NC’’) furnace 

fans. As DOE is not aware of any 

condensing MH–NWO products, DOE 

did not analyze them for this final 

determination analysis and instead 

focused on MH–NWO–NC furnace fans. 

In this final determination, DOE 

maintained the product classes 

considered in the October 2023 NOPD, 

including consideration of only noncondensing MH–NWO products. DOE 

did not consider condensing MH–NWO 

or MH–WG products because, as noted 

in the previous paragraph, DOE has not 


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found any such products available on 

the market. Further, as discussed in the 

October 2023 NOPD, DOE concluded 

that it would be premature to analyze 

energy conservation standards for 

NWO–C and WG–C furnace fans at this 

time as DOE is only aware of a very 

small number of products on the 

market. 88 FR 69826, 69833. (Oct. 6, 

2023) Therefore, DOE did not analyze 

the NWO–C and WG–C product classes 

for this final determination. DOE 

considered the product classes shown in 

the following list in its analysis: 

(1) NWG–NC 

(2) NWG–C 

(3) MH–NWG–NC 

(4) MH–NWG–C 

(5) MH–EF/MB 

(6) NWO–NC 

(7) WG–NC 

(8) NWEF/NWMB 

(9) MH–NWO–NC 

In the case where a covered product 

has numerous product classes, DOE 

identifies and selects certain product 

classes as most representative and 

concentrates its analytical effort on 

those classes. 

2. Technology Options 

DOE develops information in the 

technology assessment that 

characterizes the technologies and 

design options that manufacturers may 

use to attain higher-efficiency 

performance. 

In the October 2023 NOPD, DOE 

identified several technology options 

that would be expected to improve the 

efficiency of consumer furnace fans, in 

terms of FER as measured by the DOE 

test procedure. 88 FR 69826, 69833 (Oct. 

6, 2023). To develop a list of technology 

options, DOE identified possible 

technology options for improving 

furnace fan efficiency and examined the 

most common efficiency-improving 

technologies used in consumer furnace 

fans today. These technology options 

provide insight into the technological 

improvements typically used to increase 

the energy efficiency of consumer 

furnace fans. 

For this final determination, DOE has 

reviewed the consumer furnace fans 

market and confirmed that the 

technology options identified in the 

October 2023 NOPD continue to reflect 

the market. The identified technology 

options are shown in Table IV.2. 

TABLE IV.2—LIST OF TECHNOLOGY OPTIONS CONSIDERED FOR THIS FINAL DETERMINATION

Technology option Description 

Housing design modifications .................... Optimizing the shape and orientation of the housing of a furnace fan can improve fan efficiency. 

This can be accomplished by: (1) optimizing the shape of the inlet cone, (2) optimizing the fan 

housing shape, (3) optimizing the motor mount and the motor location, (4) minimizing the gaps 

between the impeller and the inlet cone, and (5) optimizing cut-off location and the manufacturing 

tolerances. 

Multi-stage heating components and controls.Multi-stage or modulating heating allows furnaces to meet heating load requirements more precisely 

and can run at a low output when less heat is required. Due to the cubic relationship between fan 

input power and airflow, operating at the reduced airflow-control setting may reduce overall fan 

electrical energy consumption for heating despite the extended hours. 

Airflow path design .................................... Modifications to the design and configuration of elements in the airflow path, such as the heat exchanger, could reduce internal static pressure. Reduced internal static pressure levels result in 

lower expected energy consumption levels. 

Constant-torque BPM (‘‘CT–BPM’’) and 

constant-airflow BPM (‘‘CA–BPM’’) motors.

Furnace fan manufacturers typically use either a permanent split capacitor (‘‘PSC’’) motor or a more 

efficient BPM motor. PSC motors are a type of induction motor where the stator is an electromagnet that consists of electrical wire windings, and BPM motors are three-phase permanent 

magnet motors. 

Inverter controls for PSC motors ............... Using an inverter, the incoming alternating current (‘‘AC’’) is converted to DC current by a rectifier 

and then back to AC current at a specific frequency. The output AC current is used to drive the 

motor, the operating speed of which depends on the frequency of the AC current. This allows 

PSC motors with inverter controls to better match demand. 

Higher-efficiency fan blades ...................... Furnace fans typically use an impeller to move air through ductwork. Energy savings may be possible by using backward-inclined impellers. These impellers incorporate backward-facing inclined 

blades that are generally wider in the airflow direction across the blade as compared with forwardcurved impellers. 

In response to the October 2023 

NOPD, the Joint Advocates stated that 

more-efficient BPM motors are a 

technology option that can be used to 

improve FER but were not considered as 

an efficiency level in DOE’s analysis. 

(Joint Advocates, No. 31 at p. 3) Lennox 

commented that the feasible 

technologies available for furnace fans 

considered by the NOPD have not 

changed since the last furnace fan 

standards rulemaking in 2014, which 

adopted the current standards that took 

effect in 2019. (Lennox, No. 30 at pp. 1– 

3) 

In response, DOE notes that BPM 

motor manufacturers do not currently 

disclose the efficiency of their motors. 

Further, as discussed in the October 

2023 NOPD, DOE is not aware of any 

data showing the relationship between 

improved BPM motor efficiency and 

FER ratings. In the October 2023 NOPD, 

DOE requested data regarding this 

relationship and stated that it may 

include efficiency levels corresponding 

to the use of more-efficient BPM motors 

in a future analysis, but DOE did not 

include this additional efficiency level 

in the October 2023 analysis, due to the 

lack of data. 88 FR 69826, 69840 (Oct. 

6, 2023). For this final determination, 

although DOE did continue to analyze 

use of BPM motors, DOE similarly did 

not include an analysis of more-efficient 

BPM motors as a technology option, due 

to lack of data about BPM motors that 

are more efficient than those analyzed 

by DOE. DOE’s analysis of BPM motors 

as a technology for improving FER 

ratings is discussed further in section 

IV.B.1 of this document. 

3. Impact From Other Rulemakings 

In response to the October 2023 

NOPD, Lennox commented that the 

significant cumulative regulatory 

burden on furnace manufacturers 

furthers the case that adopting a ‘‘nonew-standard’’ for furnace fans is 

warranted. The commenter added that 

there are a variety of Federal and State 

regulations being implemented that 

impact furnace manufacturers, 

including the EPA Technology 

Transition Final Rule to lower global 

warming potential (‘‘GWP’’) refrigerants, 


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9At the time of AHRI’s comment, DOE had issued 

a pre-publication copy of the final rule amending 

the standards for consumer non-weatherized gas 

furnaces and mobile home gas furnaces. That final 

rule was ultimately published in the Federal 

Register on December 18, 2023. 88 FR 87502. 

EPA Refrigerant Management NOPR, 

DOE energy conservation standards 

(‘‘ECS’’) Furnace Standards rulemaking, 

National and Regional Cold Climate 

Heat Pump Specifications, DOE ECS for 

Three-Phase Central Air Conditioners 

and Heat Pumps below 65,000 Btu/h, 

DOE Test Procedure for Variable 

Refrigerant Flow (‘‘VRF’’) Systems, DOE 

Walk-in Cooler and Freezer Test 

Procedure, and DOE Walk-in Cooler and 

Freezer ECS NOPR. (Lennox, No. 30 at 

p. 3) Lennox emphasized that Federal 

and State refrigerant regulations are 

consuming nearly all of manufacturers’ 

testing, laboratory, and product 

development resources. (Id.) AHRI 

commented that the furnace industry 

will be significantly impacted by the 

amended energy conservation standards 

for non-weatherized gas-fired furnaces, 

and DOE should consider this burden 

when assessing the manufacturer impact 

on this rule.9 (AHRI, No. 32 at pp. 1– 

2) The commenter further stated that the 

U.S. Consumer Product Safety 

Commission (‘‘CPSC’’) published a 

NOPR in the Federal Register on 

October 25, 2023, in which it proposed 

to require that all consumer gas-fired 

furnaces and boilers must continuously 

monitor the production of carbon 

monoxide (‘‘CO’’) during the 

combustion process and modulate or 

shut down the furnace at certain carbon 

monoxide levels (see 88 FR 73272). 

AHRI commented that CPSC’s proposal 

would have a significant impact on the 

furnace industry, and DOE should 

consider CPSC’s proposal when 

assessing manufacturer impacts of this 

current rulemaking. (Id. at p. 2) 

In response, DOE notes that the 

Department is not amending the energy 

conservation standards for consumer 

furnace fans, and, therefore, it does not 

expect this rulemaking to contribute to 

the cumulative regulatory burden of 

manufacturers. 

4. Screening Analysis 

As discussed, DOE conducts a 

screening analysis to evaluate whether 

to further consider each identified 

technology and design option. DOE uses 

the following five screening criteria to 

determine which technology options are 

suitable for further consideration in an 

energy conservation standards 

rulemaking: 

(1) Technological feasibility. 

Technologies that are not incorporated 

in commercially-available products or 

in commercially-viable, existing 

prototypes will not be considered 

further. 

(2) Practicability to manufacture, 

install, and service. If it is determined 

that mass production of a technology in 

commercially-available products and 

reliable installation and servicing of the 

technology could not be achieved on the 

scale necessary to serve the relevant 

market at the time of the projected 

compliance date of the standard, then 

that technology will not be considered 

further. 

(3) Impacts on product utility. If a 

technology is determined to have a 

significant adverse impact on the utility 

of the product to subgroups of 

consumers or results in the 

unavailability of any covered product 

type with performance characteristics 

(including reliability), features, sizes, 

capacities, and volumes that are 

substantially the same as products 

generally available in the United States 

at the time, it will not be considered 

further. 

(4) Safety of technologies. If it is 

determined that a technology would 

have significant adverse impacts on 

health or safety, it will not be 

considered further. 

(5) Unique-pathway proprietary 

technologies. If a technology has 

proprietary protection and represents a 

unique pathway to achieving a given 

efficiency level, it will not be considered 

further, due to the potential for 

monopolistic concerns. 

See 10 CFR part 430, subpart C, 

appendix A, sections 6(a)(3)(iii) and 

7(b). 

If DOE determines that a technology 

fails to meet one or more of these listed 

criteria, it is excluded from further 

consideration in the engineering 

analysis. The following sections include 

comments from interested parties 

pertinent to the screening analysis and 

DOE’s evaluation of each technology 

option against the screening analysis 

criteria. 

a. Screened-Out Technologies 

In the October 2023 NOPD, DOE 

tentatively screened out housing design 

modifications and changes to airflow 

path designs from its analysis. 88 FR 

69826, 69835–69836 (Oct. 6, 2023). As 

discussed in section IV.A.2 of this 

document, airflow path and fan housing 

improvements can improve furnace fan 

efficiencies. However, as initially 

discussed in chapter 4 of the November 

2022 Preliminary Analysis TSD, DOE 

does not have data to quantify the 

impact of housing design modifications 

or airflow path design on FER. 

Additionally, DOE has found that the 

housing design modifications and 

airflow path design can impact the 

performance of the furnace efficiency as 

measured in AFUE. Although housing 

design modifications and changes to the 

airflow path design have the potential to 

reduce FER, DOE currently lacks the 

data necessary to conclude that these 

options will not reduce utility to 

consumers (e.g., by reducing the AFUE), 

and, therefore, the Department has 

continued to screen out these 

technologies for this analysis. DOE did 

not receive any comments on the 

screening of these technologies in 

response to the October 2023 NOPD. 

Based on DOE’s research, DOE 

screened out the technology options on 

the basis of each of the screening criteria 

shown in Table IV.3 from further 

consideration as options to improve the 

FER (as measured by the DOE test 

procedure) of consumer furnace fans. 

The reasons for exclusion associated 

with each technology are marked in the 

table with an ‘‘X.’’ 

TABLE IV.3—TECHNOLOGY OPTIONS SCREENED OUT

Technology option 

Screening criteria 

(X = basis for screening out) 

Technological 

feasibility 

Practicability to 

install, manufacture, 

and service 

Impacts on 

product utility 

or product 

availability 

Adverse impacts 

on health 

or safety 

Unique-pathway 

proprietary 

technologies 

Housing Design Modifications ................... ........................ .................................... X .............................. ............................

Airflow Path Design ................................... ........................ .................................... X .............................. ............................


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b. Remaining Technologies 

After a thorough review of each 

technology, DOE concludes that all of 

the remaining identified technologies 

not ‘‘screened out’’ meet all of the 

screening criteria. In summary, DOE 

retained (i.e., did not screen out) the 

technology options listed below: 

• Multi-stage heating components 

and controls; 

• High-efficiency fan motors; 

• Inverter controls for PSC motors, 

and 

• Higher-efficiency fan blades. 

DOE determined that these 

technology options are technologically 

feasible because they are being used or 

have previously been used in 

commercially-available products or 

working prototypes. DOE also finds that 

all of the remaining technology options 

meet the other screening criteria (i.e., 

practicable to manufacture/install/ 

service; do not result in adverse impacts 

on product utility, product availability, 

health, or safety; and do not utilize 

unique-pathway proprietary 

technologies). DOE considers these 

remaining technology options as the 

basis for higher efficiency levels that 

DOE could consider for potential 

amended standards. 

In response to the October 2023 

NOPD, Lennox commented that 

backward-inclined impellers do not 

guarantee efficiency improvements for 

furnace fans. The commenter stated that 

there is a limited number of backwardinclined impellers on the market and 

expressed concern about the feasibility 

of implementing this technology option 

across all input capacities and cabinet 

sizes, which could lead to the 

unavailability of certain furnace product 

sizes. Consequently, Lennox 

recommended that this technology 

should not form the basis for morestringent furnace fan standards. 

(Lennox, No. 30 at p. 2) 

As discussed in the October 2023 

NOPD, even if there are only a limited 

number of commercially-available 

product designs that incorporate 

backward-inclined impellers, they are 

sufficient to demonstrate technological 

feasibility, as required by EPCA and 

clarified in DOE’s regulations at 10 CFR 

part 430, subpart C, appendix A, section 

7(b)(1). 88 FR 69826, 69836 (Oct. 6, 

2023). Further, DOE is aware of 

backward-inclined impellers that have 

been safely and reliably implemented in 

consumer furnace fan models currently 

available on the market and that reduce 

the FER of those units. Thus, DOE finds 

that backward-inclined impellers pass 

the screening analysis and consequently 

are suitable for further consideration. 

However, DOE acknowledges that there 

may be additional challenges associated 

with backward-inclined impellers, and 

these issues are discussed further in 

section IV.H of this document. 

B. Engineering and Cost Analysis 

The purpose of the engineering 

analysis is to establish the relationship 

between the efficiency and 

manufacturer production cost (‘‘MPC’’) 

of the subject product (i.e., consumer 

furnace fans). There are two elements to 

consider in the engineering analysis: (1) 

the selection of efficiency levels to 

analyze (i.e., the ‘‘efficiency analysis’’), 

and (2) the determination of product 

cost at each efficiency level (i.e., the 

‘‘cost analysis’’). In determining the 

performance of higher-efficiency 

products, DOE considers those 

technologies and design option 

combinations not eliminated by the 

screening analysis. For each product 

class, DOE estimates the baseline cost, 

as well as the incremental cost for the 

product at efficiency levels above the 

baseline. The output of the engineering 

analysis is a set of cost-efficiency 

‘‘curves’’ that are used in downstream 

analyses (i.e., the LCC and PBP analyses 

and the NIA). 

DOE recently conducted an 

engineering analysis to determine the 

cost-efficiency relationship for furnace 

fans for the October 2023 NOPD. 88 FR 

69826, 69837–69849 (Oct. 6, 2023). For 

this final determination, DOE reviewed 

market data collected as part of the 

market and technology assessment (see 

section IV.A of this document) and has 

determined that consumer furnace fan 

efficiencies have not changed 

substantially since the October 2023 

NOPD analysis. Thus, as discussed in 

section IV.B.1 of this document, DOE 

maintained the efficiency levels from 

the October 2023 NOPD in the final 

determination analysis. Additionally, 

DOE examined its most recent inputs to 

its manufacturing cost analysis (e.g., raw 

material prices, component prices, labor 

rates) and found that, while underlying 

manufacturing costs inputs have 

increased, the resulting manufacturing 

cost increases would be nearly 

proportional at each efficiency level. In 

other words, the incremental increase in 

cost to achieve each efficiency level 

would be approximately the same as 

was presented in the October 2023 

NOPD analysis. Because incremental 

cost increases at efficiency levels above 

the baseline would not change 

significantly, DOE concludes that an 

updated cost analysis would not impact 

the results of this final determination. 

Therefore, as discussed in sections 

IV.B.2 and IV.B.3 of this document, DOE 

used the same cost analysis 

methodology as the October 2023 

NOPD, and the resulting cost-efficiency 

relationships used for this final 

determination are the same as the 

October 2023 NOPD. Further 

information on this analytical 

methodology is presented in the 

following subsections. 

1. Efficiency Analysis 

DOE typically uses one of two 

approaches to develop energy efficiency 

levels for the engineering analysis: (1) 

relying on observed efficiency levels in 

the market (i.e., the efficiency-level 

approach), or (2) determining the 

incremental efficiency improvements 

associated with incorporating specific 

design options to a baseline model (i.e., 

the design-option approach). Using the 

efficiency-level approach, the efficiency 

levels established for the analysis are 

determined based on the market 

distribution of existing products (in 

other words, based on the range of 

efficiencies and efficiency-level 

‘‘clusters’’ that already exist on the 

market). Using the design-option 

approach, the efficiency levels 

established for the analysis are 

determined through detailed 

engineering calculations and/or 

computer simulations of the efficiency 

improvements from implementing 

specific design options that have been 

identified in the technology assessment. 

DOE may also rely on a combination of 

these two approaches. For example, the 

efficiency-level approach (based on 

actual products on the market) may be 

extended using the design-option 

approach to interpolate to define ‘‘gap 

fill’’ levels (to bridge large gaps between 

other identified efficiency levels) and/or 

to extrapolate to the ‘‘max-tech’’ level 

(particularly in cases where the ‘‘maxtech’’ level exceeds the maximum 

efficiency level currently available on 

the market). 

Although FER data exist in DOE’s 

Compliance Certification Database 

(‘‘CCD’’) for furnace fans currently 

subject to efficiency standards, DOE has 

determined through testing that for 

many furnace fan models, the rated FER 

values may not be representative of the 

model’s actual performance. During 

confidential manufacturer interviews, 

several manufacturers confirmed that 

they rate the FER of their furnace fan 

products conservatively. Therefore, an 

efficiency-level approach was not 

possible because the FER ratings of 

products currently available are largely 

not representative of their actual 

performance. Thus, DOE chose a designoption approach to identify efficiency 


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10Chapter 5 of the TSD accompanying the July 

2014 Final Rule includes additional details about 

how this conversion factor was calculated. See 

docket no. EERE–2010–BT–STD–0011. 

levels for the analysis in this final 

determination. 

a. Baseline Efficiency 

For each product class, DOE generally 

selects a baseline model as a reference 

point for each class, and measures 

anticipated changes to the product 

resulting from potential energy 

conservation standards against the 

baseline model. The baseline model in 

each product class represents the 

characteristics of products typical of 

that class (e.g., capacity, physical size). 

Generally, a baseline model is one that 

just meets current energy conservation 

standards, or, if no standards are in 

place, the baseline is typically the mostcommon or least-efficient unit on the 

market. For consumer furnace fans, the 

energy conservation standard sets a 

maximum energy usage requirement, 

and, therefore, a baseline furnace fan’s 

rated FER is just below or at the 

maximum FER threshold. 

DOE used baseline units for 

comparison in several analyses, 

including the engineering analysis, LCC 

analysis, PBP analysis, and NIA. To 

determine energy savings that will 

result from an amended energy 

conservation standard, DOE compared 

energy use at each of the higher 

efficiency levels to the energy 

consumption of the baseline unit. 

Similarly, to determine the changes in 

price to the consumer that will result 

from an amended energy conservation 

standard, DOE compared the prices of 

baseline units to the prices of units at 

each higher efficiency level. 

The identification of baseline units 

requires establishing the baseline 

efficiency level. In cases where there is 

an existing standard, DOE defines 

‘‘baseline units’’ as units with 

efficiencies equal to the current Federal 

energy conservation standards. For the 

MH–NWO–NC furnace fan product 

class, which does not currently have 

energy conservation standards, DOE 

developed the baseline equation by 

modifying the current energy 

conservation standards for the NWO– 

NC product class to account for the 

lower ESP experienced by mobile home 

units compared to other units. 

Specifically, DOE multiplied the yintercept (382) by 0.75, which was the 

conversion factor determined in the 

analysis for the July 2014 Final Rule 

that was previously used to calculate 

the MH–NWG–NC baseline based on the 

NWG–NC baseline.10

In the October 2023 NOPD, DOE used 

the current energy conservation 

standards for consumer furnace fans and 

the developed equation for MH–NWO– 

NC furnace fans, presented in Table 

IV.4, as the baseline FER efficiency level 

for each consumer furnace fan product 

class, along with the typical 

characteristics of a baseline unit. 

TABLE IV.4—BASELINE EFFICIENCY LEVELS AND ASSOCIATED DESIGN OPTIONS FOR EACH PRODUCT CLASS

Product class Maximum FER Design option 

Non-weatherized, non-condensing gas furnace fan ............................. 0.044 * QMax + 182 ........ BPM motor w/forward-inclined impeller. 

Non-weatherized, condensing gas furnace fan .................................... 0.044 * QMax + 195 ........ BPM motor w/forward-inclined impeller. 

Weatherized, non-condensing gas furnace fan .................................... 0.044 * QMax + 199 ........ BPM motor w/forward-inclined impeller. 

Non-weatherized, non-condensing oil furnace fan ............................... 0.071 * QMax + 382 ........ Improved PSC motor w/forward-inclined impeller. 

Non-weatherized electric furnace fan/modular blower fan ................... 0.044 * QMax + 165 ........ BPM motor w/forward-inclined impeller. 

Manufactured home, non-weatherized, non-condensing gas furnace 

fan.

0.071 * QMax + 222 ........ Improved PSC motor w/forward-inclined impeller. 

Manufactured home, non-weatherized, condensing gas furnace fan .. 0.071 * QMax + 240 ........ Improved PSC motor w/forward-inclined impeller. 

Manufactured home, non-weatherized electric furnace fan/modular 

blower fan.

0.044 * QMax + 101 ........ BPM motor w/forward-inclined impeller. 

Manufactured home, non-weatherized, non-condensing oil furnace 

fan.

0.071 * QMax + 287 ........ Improved PSC motor w/forward-inclined impeller. 

Products in the NWG–NC, NWG–C, 

WG–NC, NWEF/NWMB, and MH–EF/ 

MB product classes are currently subject 

to the standards set in the July 2014 

Final Rule, in which the efficiency 

levels adopted were understood at that 

time to reflect models with CT–BPM 

motors and multi-stage operation. 

Products in the NWO–NC and MH– 

NWG–NC product classes are currently 

subject to standards set in the July 2014 

Final Rule, in which the efficiency 

levels adopted were understood to 

correspond to the performance 

associated with models including 

improved PSC motors and single-stage 

operation. Baseline products in the MH– 

NWO–NC product class were also found 

to correspond to performance associated 

with models including improved PSC 

motors and single-stage operation, based 

on DOE’s market findings for mobile 

home oil-fired units certified in DOE’s 

CCD for consumer furnaces. 

Many furnaces include multi-stage or 

modulating heating controls. However, 

based on current furnace fan market 

data, as well as feedback received 

during manufacturer interviews, it is 

unclear if these features impact furnace 

fan efficiency as measured by FER (see 

section IV.A.2 of this document). 

Therefore, DOE did not include the 

costs of multi-stage or modulating 

heating controls in the baseline design 

(i.e., DOE’s MPC estimates reflect singlestage units). However, DOE did develop 

separate cost values for multi-stage or 

modulating heating controls that can be 

applied to the above costs to represent 

the addition of multi-stage or 

modulating heating controls (see section 

IV.B.2.b of this document). These 

additional cost values are used in DOE’s 

LCC and PBP analyses in order to 

represent typical furnace fan cost 

distributions. 

In addition, the baseline motor 

technology is either BPM or PSC, 

depending on the product class. 

Manufacturers may choose a CA–BPM 

motor instead of a CT–BPM, despite its 

relatively higher cost, to add comfortrelated benefits to their product. This 

additional comfort may be marketed as 

a premium feature. Therefore, DOE 

included the cost of a CT–BPM motor in 

the MPCs for furnace fans with BPM 

motors. DOE also developed cost values 

to represent the cost increase for CA– 

BPM motors relative to CT–BPM motors 

(see section IV.B.2.b of this document). 

These values were applied in the LCC 


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analysis to represent the distribution of 

BPM blower motor technologies 

expected on the market because, 

although DOE is not differentiating 

between CA–BPM motors and CT–BPM 

motors in terms of furnace fan 

efficiency, manufacturers and 

consumers may consider CA–BPM 

motors to be a premium feature that may 

offer comfort-related consumer benefits. 

In developing the cost-efficiency 

relationship, teardowns of baseline 

units were used as a reference point for 

determining the cost-efficiency 

relationship of units with lower (more 

efficient) FERs. DOE compared the 

design features incorporated into 

products at the baseline efficiency to the 

features of units with higher energy 

efficiencies in order to determine the 

changes in manufacturing, installation, 

and operating costs that occur as FER 

decreases. 

DOE did not receive comments in 

response to the baseline efficiency 

levels used in the October 2023 NOPD. 

Therefore, for this final determination, 

DOE used the baseline efficiency levels 

as presented in the October 2023 NOPD. 

b. Intermediate Efficiency Levels 

As noted, EPCA requires that any new 

or amended energy conservation 

standard be designed to achieve the 

maximum improvement in energy 

efficiency that is technologically 

feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A)) 

In the October 2023 NOPD, DOE 

analyzed intermediate efficiency levels 

for NWO–NC, MH–NWG–NC, MH– 

NWG–C, and MH–NWO–NC classes of 

consumer furnace fans. 88 FR 69826, 

69840 (Oct. 6, 2023). As discussed in 

section IV.B.1.c of this document, DOE 

did not identify any efficiency levels 

between baseline and max-tech for the 

NWG–NC, NWG–C, WG–NC, NWEF/ 

NWMB, and MH–EF/MB classes. The 

intermediate efficiency levels identified 

are representative of efficiency levels 

where major technological changes 

occur (i.e., replacing PSC motors with 

BPM motors). As discussed in section 

IV.B.1.a of this document, DOE has 

found that CT–BPM motors and CA– 

BPM motors have comparable impacts 

on FER ratings, and DOE has, therefore, 

only analyzed a single efficiency level 

reflecting the implementation of BPM 

motors. In the 2014 Final Rule (79 FR 

38130, 38159), DOE used the 

assumption of a 12-percent reduction in 

FER for improved PSC motors and a 46- 

percent reduction in FER for models 

with a CT–BPM and multi-staging from 

the baseline to calculate a 39-percent 

reduction in FER from improved PSC 

(the current baseline) to CT–BPM with 

multi-staging. The 39-percent reduction 

in FER is implemented into the current 

analysis to represent the reduction in 

FER from improved PSC to a model 

with a CT–BPM (regardless of staging) 

because DOE decided not to include 

staging as a technology option that 

improves FER. 

In commenting on the October 2023 

NOPD, the Joint Advocates 

recommended that DOE gather 

additional information about BPM 

motor efficiency and analyze an 

efficiency level with improved (i.e., 

higher-efficiency) BPM motors. The 

Joint Advocates commented that, based 

on conversations with motor 

manufacturers, more-efficient BPM 

motors exist in the furnace fan market 

and would improve furnace fan 

efficiency. (Joint Advocates, No. 31 at p. 

3) 

In response, as discussed in section 

IV.A.2 of this document, DOE does not 

currently have the data necessary to 

determine the relationship between 

improved BPM motor efficiency and 

furnace fan efficiency. Therefore, 

although DOE continued to analyze 

BPM motors as a technology that 

improves FER, the Department did not 

analyze an efficiency level based on 

improved BPM motor efficiency 

(relative to the BPM motor efficiency 

identified in the October 2023 NOPD) 

for this final determination. 

c. Maximum Technology (‘‘Max-Tech’’) 

Efficiency Levels 

As part of its analysis, DOE identifies 

the ‘‘maximum available’’ efficiency 

level, representing the highest-efficiency 

unit currently available on the market. 

DOE also defines a ‘‘max-tech’’ 

efficiency level, representing the 

maximum theoretical efficiency that can 

be achieved through the application of 

all available technology options retained 

from the screening analysis. In many 

cases, the max-tech efficiency level is 

not commercially available because it is 

not currently economically feasible. 

In the October 2023 NOPD, DOE 

identified the max-tech design for all 

consumer furnace fan product types as 

incorporating a BPM motor and a 

backward-inclined impeller. 88 FR 

69826, 69840 (Oct. 6, 2023). BPM 

motors are described in sections IV.B.1.a 

and IV.B.1.b of this document. For 

furnace fan models that use PSC motors, 

BPM motors can offer an improvement 

in efficiency and reduce FER. 

Backward-inclined impellers, in 

comparison to forward-inclined 

impellers (which are used in the 

majority of furnace fans on the market), 

have been found to have a higher 

efficiency under certain operating 

conditions. DOE has used the same 

assumptions about the percent 

reduction in FER associated with 

implementing backward-inclined 

impellers as in the July 2014 Final Rule 

(i.e., a 10-percent reduction in FER 

compared to models that include 

forward-inclined impellers). 79 FR 

38130, 38159 (July 3, 2014). 

In response to the October 2023 

NOPD, the Joint Advocates encouraged 

DOE to investigate the most efficient 

furnace fans currently available on the 

market that exceed DOE’s max-tech 

level. The commenters argued that there 

are many furnace fan models across a 

range of airflows in the major product 

classes that are more efficient than EL 

1. The Joint Advocates added that there 

are many NWG–C furnace fans in the 

CCD that exceed the max-tech level by 

more than 10 percent and do not appear 

to use backward-inclined impeller 

technology. The Joint Advocates further 

stated it is unlikely that the CCD 

overstates the efficiencies of these fans, 

as they are often rated conservatively. 

(Joint Advocates, No. 31 at p. 2) 

In response, DOE assessed the furnace 

fan entries in the CCD that are rated at 

a lower FER than would be required by 

the max-tech efficiency level and found 

that these fans used a variety of motor 

technologies, staging technologies, and 

controls. DOE was unable to identify a 

design option that captured the 

technologies used in these units to 

develop an additional efficiency level. 

DOE notes that technologies such as 

housing design modifications and 

airflow design paths could allow the 

identified furnace fans to achieve FER 

ratings below those prescribed by the 

max-tech efficiency levels. However, as 

discussed in section IV.A.4 of this 

document, these technology options 

were screened out due to adverse 

impacts on product utility. Therefore, 

for this final determination, DOE 

concludes that the max-tech efficiency 

levels, as presented in the October 2023 

NOPD, accurately reflect the maximum 

possible efficiency levels using the 

technology options remaining after the 

screening analysis. 

d. Summary of Efficiency Levels 

Analyzed 

The FER efficiency levels and 

associated technologies expected to be 

used to increase energy efficiency above 

the baseline levels for each class of 

consumer furnace fans are presented in 

Table IV.5 through Table IV.13, 

respectively. 


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TABLE IV.5—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR NWG–NC FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.044 * QMax + 182 ...................... BPM motor w/forward-curved impeller ................... N/A 

1—Max-tech ................................. 0.04 * QMax + 164 ........................ BPM motor w/backward-inclined impeller ............... 10 

TABLE IV.6—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR NWG–C FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.044 * QMax + 195 ...................... BPM motor w/forward-curved impeller ................... N/A 

1—Max-tech ................................. 0.04 * QMax + 176 ........................ BPM motor w/backward-inclined impeller ............... 10 

TABLE IV.7—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR WG–NC FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.044 * QMax + 199 ...................... BPM motor w/forward-curved impeller ................... N/A 

1—Max-tech ................................. 0.04 * QMax + 179 ........................ BPM motor w/backward-inclined impeller ............... 10 

TABLE IV.8—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR NWEF/NWMB FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.044 * QMax + 165 ...................... BPM motor w/forward-curved impeller ................... N/A 

1—Max-tech ................................. 0.04 * QMax + 149 ........................ BPM motor w/backward-inclined impeller ............... 10 

TABLE IV.9—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR MH–EF/MB FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.044 * QMax + 101 ...................... BPM motor w/forward-curved impeller ................... N/A 

1—Max-tech ................................. 0.04 * QMax + 91 .......................... BPM motor w/backward-inclined impeller ............... 10 

TABLE IV.10—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR MH–NWG–NC FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.071 * QMax + 222 ...................... Improved PSC motor .............................................. N/A 

1 ................................................... 0.044 * QMax + 137 ...................... BPM motor w/forward-curved impeller ................... 39 

2—Max-tech ................................. 0.04 * QMax + 123 ........................ BPM motor w/backward-inclined impeller ............... 45 

TABLE IV.11—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR MH–NWG–C FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.071 * QMax + 240 ...................... Improved PSC motor .............................................. N/A 

1 ................................................... 0.044 * QMax + 148 ...................... BPM motor w/forward-curved impeller ................... 39 

2—Max-tech ................................. 0.04 * QMax + 133 ........................ BPM motor w/backward-inclined impeller ............... 45 


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TABLE IV.12—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL FOR NWO–NC FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.071 * QMax + 382 ...................... Improved PSC motor .............................................. N/A 

1 ................................................... 0.044 * QMax + 236 ...................... BPM motor w/forward-curved impeller ................... 39 

2—Max-tech ................................. 0.04 * QMax + 212 ........................ BPM motor w/backward-inclined impeller ............... 45 

TABLE IV.13—EFFICIENCY LEVELS AND TECHNOLOGIES USED AT EACH EFFICIENCY LEVEL MH–NWO–NC FANS

EL FER equation Description of technologies typically incorporated 

Percentage 

reduction in FER 

from baseline 

0—Baseline .................................. 0.071 * QMax + 287 ...................... Improved PSC motor .............................................. N/A 

1 ................................................... 0.044 * QMax + 176 ...................... BPM motor w/forward-curved impeller ................... 39 

2—Max-tech ................................. 0.04 * QMax + 158 ........................ BPM motor w/backward-inclined impeller ............... 45 

2. Cost Analysis 

The cost analysis portion of the 

engineering analysis is conducted using 

one or a combination of cost 

approaches. The selection of cost 

approach depends on a suite of factors, 

including the availability and reliability 

of public information, characteristics of 

the regulated product, and the 

availability and timeliness of 

purchasing the product on the market. 

The cost approaches generally used by 

DOE are summarized as follows: 

b Physical teardowns: Under this 

approach, DOE physically dismantles 

commercially-available products, 

component-by-component, to develop a 

detailed bill of materials for the 

products. 

b Catalog teardowns: In lieu of 

physically deconstructing products, 

DOE identifies each component using 

parts diagrams (available from 

manufacturer websites or appliance 

repair websites, for example) to develop 

the bill of materials for the product. 

b Price surveys: If neither a physical 

nor catalog teardown is feasible (e.g., for 

tightly integrated products such as 

fluorescent lamps, which are infeasible 

to disassemble and for which parts 

diagrams are unavailable), costprohibitive, or otherwise impractical 

(e.g., large commercial boilers), DOE 

conducts price surveys using publiclyavailable pricing data published on 

major online retailer websites and/or by 

soliciting prices from distributors and 

other commercial channels. 

In the October 2023 NOPD, DOE 

conducted the cost analysis using a 

combination of physical and catalog 

teardowns to assess how manufacturing 

costs change with increased product 

efficiency. 88 FR 69826, 69844 (Oct. 6, 

2023). DOE estimated the MPC 

associated with each efficiency level to 

characterize the cost-efficiency 

relationship of improving consumer 

furnace fan performance. The MPC 

estimates are not for the entire HVAC 

product. Because consumer furnace fans 

are a component of the HVAC product 

into which they are integrated, the MPC 

estimates include costs only for the 

components of the HVAC product that 

impact FER. Id. 

Products were selected for physical 

teardown analysis that have 

characteristics of typical products on 

the market near a representative input 

capacity of 80,000 Btu/h for the NWG– 

NC, NWG–C, WG–NC, NWEF/NWMB, 

MH–NWG–NC, MH–NWG–C, MH–EF/ 

MB, and MH–WG product classes and 

105,000 Btu/h for the NWO–NC and 

MH–NWO–NC product classes 

(determined based on market data and 

discussions with manufacturers). 

Selections spanned a range of FER 

efficiency levels and designs and 

included most manufacturers. The 

resulting bill of materials provides the 

basis for the MPC estimates for products 

at various efficiency levels spanning the 

full range of efficiencies from the 

baseline to max-tech. 

To account for manufacturers’ nonproduction costs and profit margin, DOE 

applies a non-production cost multiplier 

(the manufacturer markup) to the MPC. 

The resulting manufacturer selling price 

(‘‘MSP’’) is the price at which the 

manufacturer distributes a unit into 

commerce. DOE developed an average 

manufacturer markup by examining the 

annual Securities and Exchange 

Commission (‘‘SEC’’) 10–K reports filed 

by publicly-traded manufacturers 

primarily engaged in HVAC 

manufacturing and whose combined 

product range includes consumer 

furnace fans. DOE refined its 

understanding of manufacturer markups 

by using information obtained during 

manufacturer interviews. The 

manufacturer markups were used to 

convert the MPCs into MSPs. Further 

information on this analytical 

methodology is presented in the 

following subsections. 

a. Teardown Analysis 

For the October 2023 NOPD, to 

assemble bills of materials (‘‘BOMs’’) 

and to calculate manufacturing costs for 

the different components in consumer 

furnace fans, multiple units were 

disassembled into their base 

components, and DOE estimated the 

materials, processes, and labor required 

to manufacture each individual 

component, a process referred to as a 

‘‘physical teardown.’’ Using the data 

gathered from the physical teardowns, 

each component was characterized 

according to its weight, dimensions, 

material, quantity, and the 

manufacturing processes used to 

fabricate and assemble it. 

For supplementary catalog teardowns, 

product data were gathered, such as 

dimensions, weight, and design features 

from publicly-available information 

such as manufacturer catalogs. Such 

‘‘virtual teardowns’’ allowed DOE to 

estimate the major physical differences 

between a product that was physically 

disassembled and a similar product that 

was not. For this final determination, 

data from a total of 61 physical and 

virtual teardowns of consumer furnace 

fans were used to calculate industry 

MPCs in the engineering analysis. 

The models selected for teardown in 

each product class represented 

manufacturers with large market shares 

in the product classes for which their 

teardown units are categorized. 

Whenever possible, DOE examined 

multiple models from a given 

manufacturer that capture different 

design options and used them as direct 

points of comparison. DOE examined 


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11For more information on MEPS International, 

please visit www.mepsinternational.com/gb/en (last 

accessed March 25, 2024). 12For more information on PolymerUpdate, 

please visit www.polymerupdate.com (last accessed 

March 25, 2024). 

13For more information on USGS metal price 

statistics, please visit www.usgs.gov/centers/ 

national-minerals-information-center/commoditystatistics-and-information (last accessed March 25, 

2024). 

14For more information on the BLS producer 

price indices, please visit www.bls.gov/ppi/ (last 

accessed March 25, 2024). 

products with PSC, CT–BPM, and CA– 

BPM indoor blower motors, as well as 

products using single-stage, two-stage, 

and modulating combustion systems. As 

further discussed in section IV.B.2.b of 

this document, cost values were 

developed for some of these 

technologies to estimate the 

manufacturing cost of changing designs 

from one technology to another (i.e., 

using a CA–BPM instead of a CT–BPM, 

or two-stage combustion instead of 

single-stage combustion). 

As described in Chapter 5 of the 

November 2022 Preliminary Analysis 

TSD, DOE found that MPC did not differ 

significantly across product classes at a 

given efficiency level and given 

production volume because 

manufacturers use similar components. 

Therefore, in this analysis, DOE used 

teardowns of non-weatherized gas and 

mobile home gas furnaces to represent 

all high-volume product classes, 

including NWG–NC, NWG–C, WG–NC, 

NWEF/NWMB, and MH–EF/MB, while 

teardowns of non-weatherized oil units 

were used for the analysis of the NWO– 

NC and MH–NWO–NC product classes. 

b. Cost Estimation Method 

For the October 2023 NOPD, the costs 

of individual models were estimated 

using the content of the BOMs (i.e., 

relating to materials, fabrication, labor, 

and all other aspects that make up a 

production facility) to generate MPCs. 

The resulting MPCs include costs such 

as overhead and depreciation, in 

addition to materials and labor costs. 

DOE collected information on labor 

rates, tooling costs, raw material prices, 

and other factors to use as inputs into 

the cost estimates. For purchased parts, 

DOE estimates the purchase price based 

on volume-variable price quotations and 

detailed discussions with manufacturers 

and component suppliers. Furnace fans 

are a component of HVAC products that 

include other products not associated 

with the cost and/or efficiency of the 

furnace fan. Therefore, DOE focused its 

engineering analysis on the components 

that compose the furnace fan assembly, 

including: 

• Fan motor and integrated controls 

(as applicable); 

• HVAC product control boards; 

• Impellers; 

• Single-staging or multi-staging 

components and controls; 

• Fan housing, and 

• Components used to direct or guide 

airflow. 

For purchased parts, DOE estimated 

the purchase prices paid to the original 

equipment manufacturers (‘‘OEMs’’) of 

these parts based on discussions with 

manufacturers during confidential 

interviews. Whenever possible, DOE 

obtained price quotes directly from the 

component suppliers used by furnace 

fan manufacturers whose products were 

examined in the engineering analysis. 

DOE determined that the components in 

Table IV.14 are generally purchased 

from outside suppliers. 

TABLE IV.14—PURCHASED FURNACE FAN COMPONENTS

Assembly Purchased sub-assemblies or components 

Fan assembly ..................................................... Fan motor. 

Motor capacitor (when applicable). 

Impeller. 

Controls ............................................................... Primary control board (‘‘PCB’’). 

Multi-staging components (when applicable). 

For parts fabricated in-house, the 

costs of underlying ‘‘raw’’ materials are 

determined based on manufacturer 

interviews, quotes from suppliers, and 

secondary research. Past results are 

updated periodically and/or inflated to 

present-day prices using indices from 

resources such as MEPS International,11

PolymerUpdate,12 the U.S. Geological 

Survey (‘‘USGS’’),13 and the U.S. Bureau 

of Labor Statistics (‘‘BLS’’).14 The prices 

of the underlying raw metals (e.g., tube, 

sheet metal) are estimated on the basis 

of five-year averages spanning from 

2018 through 2022 to smooth out spikes 

in demand. For non-metal raw material 

prices (e.g., plastic resins, insulation 

materials), DOE used prices based on 

current market data, rather than a fiveyear average, because non-metal raw 

materials typically do not experience 

the same level of price volatility as 

metal raw materials. 

Certain factory parameters—such as 

fabrication rates, labor rates, and 

wages—also affect the cost of each unit 

produced. DOE factory parameter 

assumptions were based on internal 

expertise and manufacturer feedback. 

Table IV.15 lists the factory parameter 

assumptions used for both high-volume 

and low-volume manufacturers. For the 

engineering analysis, these factory 

parameters, including production 

volume, are the same at every efficiency 

level. The production volume used at 

each efficiency level corresponds with 

the average production volume per 

manufacturer, if 100 percent of all units 

manufactured were at that efficiency 

level. These assumptions are 

generalized to represent typical 

production and are not intended to 

model a specific factory. For the NWG– 

NC, NWG–C, WG–NC, NWEF/NWMB, 

MH–NWG–NC, MH–NWG–C, and MH– 

EF/MB product classes, high production 

volume parameters were assumed due 

to these classes having generally high 

production volumes or using enough of 

the same major components as other 

high production volume classes. For 

NWO–NC and MH–NWO product 

classes, low production parameters were 

assumed. 

TABLE IV.15—FACTORY PARAMETER ASSUMPTIONS

Parameter High-volume furnace 

fan estimate 

Low-volume furnace fan 

estimate 

Actual Annual Production Volume (units/year) ....................................................................... 1,500,000 ....................... 5,000. 


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TABLE IV.15—FACTORY PARAMETER ASSUMPTIONS—Continued 

Parameter High-volume furnace 

fan estimate 

Low-volume furnace fan 

estimate 

Purchased Parts Volume ........................................................................................................ 500,000 units/year ......... 5,000 units/year. 

Workdays Per Year (days) ..................................................................................................... 250 ................................. 250. 

Assembly Shifts Per Day (shifts) ............................................................................................ 2 ..................................... 1. 

Fabrication Shifts Per Day (shifts) .......................................................................................... 2 ..................................... 2. 

Fabrication Labor Wages ($/h) ............................................................................................... 16 ................................... 16. 

Assembly Labor Wages ($/h) ................................................................................................. 16 ................................... 16. 

Length of Shift (hr) .................................................................................................................. 8 ..................................... 8. 

Average Equipment Installation Cost (% of purchase price) ................................................. 10% ................................ 10%. 

Fringe Benefits Ratio .............................................................................................................. 50% ................................ 50%. 

Indirect to Direct Labor Ratio ................................................................................................. 33% ................................ 33%. 

Average Scrap Recovery Value ............................................................................................. 30% ................................ 30%. 

Worker Downtime ................................................................................................................... 10% ................................ 10%. 

Building Life (in years) ............................................................................................................ 25 ................................... 25. 

Burdened Assembly Labor Wage ($/h) .................................................................................. 24 ................................... 24. 

Burdened Fabrication Labor Wage ($/h) ................................................................................ 24 ................................... 24. 

Supervisor Span (workers/supervisor) ................................................................................... 25 ................................... 25. 

Supervisor Wage Premium (over fabrication and assembly wage) ....................................... 30% ................................ 30%. 

Constant-Airflow BPM Blower Motor 

Cost Value 

As discussed in section IV.B.1.a of 

this document, for the NWG–NC, NWG– 

C, WG–NC, NWEF/NWMB, and MH– 

WF/MB product classes, the current 

baseline motor technology is a BPM 

motor, and specifically a CT–BPM 

motor. DOE’s research suggests that the 

predominant BPM indoor blower motors 

sold on the market today are either a 

constant-torque or a constant-airflow 

design. Both types of motors rely on 

electronic variable-speed motor systems 

that are typically mounted in an 

external chassis to the back of the 

motor. CA–BPM motors utilize feedback 

control to adjust torque based on ESP in 

order to maintain a desired airflow. This 

differentiates them from CT–BPM 

motors that will maintain torque and 

likely decrease airflow output in 

environments with high ESPs. 

Additionally, CA–BPM motors use 

feedback control to vary their output to 

maintain pre-programmed airflows. 

DOE has found that there are no 

significant differences in measured FER 

performance between furnace fans using 

CA–BPM and CT–BPM motors; 

however, CA–BPM motors are 

sometimes chosen for other benefits, 

such as increased consumer comfort. 

CA–BPM fan motors typically cost more 

than CT–BPM motors while not 

improving FER. Therefore, as discussed 

in section IV.B.1.a of this document, 

DOE considered the baseline design to 

include CT–BPM motors for the NWG– 

NC, NWG–C, WG–NC, NWEF/NWMB, 

and MH–EF/MB classes. However, to 

better represent costs to consumers, 

DOE has developed cost values for CA– 

BPMs that are applied in the LCC 

analysis to a portion of furnace fan 

installations. Table IV.16 shows the cost 

difference between CT–BPM and CA– 

BPM motors for high-volume and lowvolume product classes. 

TABLE IV.16—INCREMENTAL COST DIFFERENCE FOR BPM MOTORS

Product class 

Incremental cost increase 

for CT–BPM to CA–BPM 

(2022$) 

NWG–C, NWG–NC, WG–NC, NWEF/NWMB, MH–NWG–NC, MH–NWG–C, and MH–EF/MB .............................. $28.07 

NWO–NC, MH–NWO–NC ......................................................................................................................................... 83.67 

Multi-Stage Furnace 

As discussed in section IV.A.2 of this 

document, DOE has identified a number 

of furnace fans in two-stage and 

modulating furnaces that are rated at the 

same relative FER as single-stage 

furnaces. DOE has determined that 

consumers choose to purchase multistage products for the additional 

thermal comfort offered by furnaces 

with multiple stages of heating output. 

During teardowns, DOE examined 

multi-stage furnace designs to analyze 

the production cost differential for 

manufacturers to switch from singlestage to two-stage or modulating 

combustion. DOE determined a marketshare weighted-average marginal cost 

increase of $21.07 for the NWG–C, 

NWG–NC, WG–NC, NWEF/NWMB, 

MH–NWG–NC, MH–NWG–C, and MH– 

EF/MB classes to change a furnace from 

a single-stage to a two-stage design. DOE 

determined that oil units with multistaging were rare and, thus, not 

representative of the market, so DOE did 

not analyze the cost increase of multistage burners for the NWO–NC and 

MH–NWO–NC product classes. Where 

applicable, the additional cost to change 

to a two-stage furnace includes the 

added cost of a two-stage gas valve, a 

two-speed inducer assembly, an 

additional pressure switch, and 

additional controls and wiring. As with 

the blower motor costs discussed 

previously, the additional cost of a 

multi-stage burner is accounted for in 

the LCC analysis based on the market 

penetration of such designs for furnaces. 

Scaling to Alternative Input Capacities 

For the October 2023 NOPD, DOE also 

developed equations to scale the MPC 

results at the representative capacity to 

the full range of input capacities 

available on the market for each motor 

type. DOE performed regression 

analyses on the discrete MPCs for each 

teardown and their respective input 

capacities—which spanned a range of 

capacities and airflows and 

encompassed a range of motor sizes—to 

generate an equation for each motor 

technology that reflects the relationship 

between these parameters. These 


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parameters were derived separately for 

high-volume (NWG–C, NWG–NC, MH– 

NWG–NC, MH–NWG–C, and WG–NC) 

and low-volume (NWO–NC and MH– 

NWO–NC) product classes. These 

equations, which are presented in Table 

IV.17, are used in the LCC analysis (see 

section IV.E of this document) to 

analyze the impacts on furnace fans 

over the full range of input capacities. 

To estimate the MPC at a given input, 

first the appropriate adder is calculated 

using the equation and then the result 

added to or subtracted from (as 

applicable) the MPC at the 

representative input capacity. 

TABLE IV.17—EQUATIONS FOR SCALING MPCS TO ADDITIONAL INPUT CAPACITIES

Input Capacity MPC Scaling Equation: MPC Change = Slope * (Input Capacity (kBtu/h)¥Representative Capacity (kBtu/h)) 

NWGF–C, NWGF–NC, 

MH–NWGF–NC, 

MH–NWGF–C, WGF–NC 

NWOF–NC and 

MH–NWOF–NC 

Motor technology ....................................................................................................................... Slope Slope 

PSC ............................................................................................................................................ 0.0650 0.7031 

Constant-torque BPM ................................................................................................................ 0.1395 0.6272 

Constant-airflow BPM ................................................................................................................ 0.1603 1.0069 

Backward-Inclined Impellers 

For the max-tech efficiency levels, in 

the October 2023 NOPD, DOE estimated 

the cost to manufacture a backwardinclined impeller by using manufacturer 

feedback along with photographs and 

specifications found in research reports 

to determine cost model inputs to 

estimate the MPCs of the backwardinclined impeller. 88 FR 69826, 69847 

(Oct. 6, 2023). These costs were scaled 

to different capacities by evaluating the 

impact of the backward-inclined 

impeller on the overall furnace system, 

depending on the average cabinet width 

at that capacity. DOE estimated the 

manufacturing cost of implementing a 

backward-inclined impeller and 

compared it to the average cost of using 

the forward-inclined impellers that are 

ubiquitous in furnace fans currently on 

the market to determine the incremental 

increase in MPC associated with 

implementing backward-inclined 

impellers as compared to forwardinclined impellers. The cost increases 

for backward-inclined impellers at each 

capacity were applied at the max-tech 

level to estimate the MPCs and are 

outlined in Table IV.18. 

TABLE IV.18—BACKWARD-INCLINED IMPELLER MPC INCREASES

Input capacity 

(kBtu/h) 

High volume 

(2022$) 

Low volume 

(2022$) 

40 28.60 34.15 

60 34.93 41.71 

80 37.21 44.43 

100 55.18 65.89 

120 59.09 70.56 

3. Cost-Efficiency Results 

The results of the October 2023 NOPD 

engineering analysis are the MPCs for 

each furnace fan product class analyzed 

at each FER efficiency level (and 

associated design option), resulting in a 

cost-efficiency relationship. The costefficiency results are shown in tabular 

form in Table IV.19 through Table IV.21 

in the form of efficiency versus MPC. 

(QMax is the airflow, in cfm, at the 

maximum airflow-control setting 

measured using the DOE test 

procedure.) As described in section 

IV.B.2.b of this document, the MPC 

presented is not for the entire HVAC 

product, because furnace fans are a 

component of the HVAC product in 

which they are integrated. 

As discussed in section IV.B.2.b of 

this document, separate cost values 

were developed for constant-airflow 

BPM motors and multi-staging because 

these premium design elements could 

add comfort or provide other benefits 

but were not incorporated as design 

options into efficiency levels for furnace 

fans used in this analysis. 

DOE used the cost-efficiency curves 

from the engineering analysis as an 

input to the LCC analysis to determine 

the added price of the more-efficient 

furnace fan components in HVAC 

equipment sold to the customer (see 

section IV.E of this document). 

TABLE IV.19—COST-EFFICIENCY RESULTS BY PRODUCT CLASS—NWG–NC, NWG–C, WGF–NC, NWEF/NWMB, AND

MH–EF/MB 

Efficiency level 

Design option 

Baseline EL 1 

BPM motor BPM motor + backward-inclined impeller 

MPC ................................................................... $108.06 ............................................................ $136.13. 

Product class ..................................................... Maximum allowable FER equation 


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TABLE IV.19—COST-EFFICIENCY RESULTS BY PRODUCT CLASS—NWG–NC, NWG–C, WGF–NC, NWEF/NWMB, AND

MH–EF/MB—Continued 

Efficiency level 

Design option 

Baseline EL 1 

BPM motor BPM motor + backward-inclined impeller 

NWG–NC ........................................................... 0.044 * QMax + 182 .......................................... 0.04 * QMax + 164. 

NWG–C .............................................................. 0.044 * QMax + 195 .......................................... 0.04 * QMax + 176. 

WG–NC .............................................................. 0.044 * QMax + 199 .......................................... 0.04 * QMax + 179. 

NWEF/NWMB .................................................... 0.044 * QMax + 165 .......................................... 0.04 * QMax + 149. 

MH–EF/MB ......................................................... 0.044 * QMax + 101 .......................................... 0.04 * QMax + 91. 

TABLE IV.20—COST-EFFICIENCY RESULTS BY PRODUCT CLASS—MH–NWG–NC AND MH–NWG–C 

Efficiency level 

Design option 

Baseline EL 1 EL 2 

Improved PSC BPM motor 

BPM motor + backward-inclined 

impeller 

MPC ............................................... $82.39 ........................................... $108.06 ......................................... $136.13. 

Product class ................................. Maximum allowable FER equation 

MH–NWG–NC ............................... 0.071 * QMax + 222 ...................... 0.044 * QMax + 137 ...................... 0.04 * QMax + 123. 

MH–NWG–C .................................. 0.071 * QMax + 240 ...................... 0.044 * QMax + 148 ...................... 0.04 * QMax + 133. 

TABLE IV.21—COST-EFFICIENCY RESULTS BY PRODUCT CLASS—NWO–NC AND MH–NWO–NC 

Efficiency level 

Design option 

Baseline EL 1 EL 2 

Improved PSC BPM motor 

BPM motor + backward-inclined 

impeller 

MPC ............................................... $195.61 ......................................... $216.95 ......................................... $300.62. 

Product Class ................................ Maximum allowable FER equation 

NWO–NC ....................................... 0.071 * QMax + 382 ...................... 0.044 * QMax + 236 ...................... 0.04 * QMax + 212. 

MH–NWO–NC ............................... 0.071 * QMax + 287 ...................... 0.044 * QMax + 176 ...................... 0.04 * QMax + 158. 

In commenting on the October 2023 

NOPD, Lennox stated that equipment 

costs have increased since the most 

recent furnace fans standards went into 

effect in 2019. (Lennox, No. 30 at pp. 1– 

3) The commenter argued that 

consumers are struggling to afford new 

furnace equipment due to inflation and 

supply-chain issues. Lennox stated that 

this makes increasing furnace fan costs 

through standards particularly illadvised, and Lennox supported the 

NOPD’s conclusion that amended 

standards are not appropriate. (Id.) 

In response, DOE notes that changes 

in equipment costs have been taken into 

account in the engineering analysis for 

this final determination. As discussed in 

section IV.B.2.b of this document, DOE 

gathered price quotations for purchased 

parts from major suppliers at different 

production volumes during 

manufacturer interviews that were 

conducted after the standards went into 

effect in 2019. For parts produced inhouse, metal raw material prices are 

estimated on the basis of five-year 

averages, spanning from 2018 through 

2022, which includes changes since the 

2019 standards went into effect. These 

material costs are captured in the costefficiency results and, in turn, are 

reflected in the LCC and PBP analyses, 

which are outlined in section IV.E of 

this document. 

In this final determination DOE 

maintained the same cost analysis as 

that used for the October 2023 NOPD. 

As a result, the cost-efficiency 

relationships used for this final 

determination are the same as those 

presented in the October 2023 NOPD. 

C. Markups Analysis 

The markups analysis develops 

appropriate markups (e.g., distributor 

markups, retailer markups, contractor 

markups) in the distribution chain and 

sales taxes to convert the MSP estimates 

derived in the engineering analysis to 

consumer prices, which are then used in 

the LCC and PBP analyses. At each step 

in the distribution channel, companies 

mark up the price of the product to 

cover business costs and profit margin. 

As part of the analysis, DOE identifies 

key market participants and distribution 


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15Because the projected price of standardscompliant products is typically higher than the 

price of baseline products, using the same markup 

for the incremental cost and the baseline cost would 

result in higher per-unit operating profit. While 

such an outcome is possible, DOE maintains that in 

markets that are reasonably competitive it is 

unlikely that standards would lead to a sustainable 

increase in profitability in the long run. 

16Sales Tax Clearinghouse, Inc., State Sales Tax 

Rates Along With Combined Average City and 

County Rates (Jan. 4, 2023) (Available at: 

www.thestc.com/STrates.stm) (last accessed June 

28, 2024). 

17Energy Information Administration (EIA), 2020 

Residential Energy Consumption Survey (RECS) 

(Available at: www.eia.gov/consumption/ 

residential/data/2020/index.php/) (last accessed 

June 11, 2024). 

channels. As in the October 2023 NOPD, 

DOE used the same distribution 

channels for furnace fans as it used for 

furnaces in the recent energy 

conservation standards rulemaking for 

those products. DOE believes that this is 

an appropriate approach because the 

vast majority of the furnace fans covered 

in this rulemaking are a component of 

a furnace. DOE has concluded that there 

is insufficient evidence of a replacement 

market for furnace fans to establish a 

separate distribution channel on that 

basis. 

DOE developed baseline and 

incremental markups for each actor in 

the distribution chain. Baseline 

markups are applied to the price of 

products with baseline efficiency, while 

incremental markups are applied to the 

difference in price between baseline and 

higher-efficiency models (the 

incremental cost increase). The 

incremental markup is typically less 

than the baseline markup and is 

designed to maintain similar per-unit 

operating profit before and after new or 

amended standards.15

To estimate average baseline and 

incremental markups, DOE relied on 

several sources, including: (1) the 

HARDI 2013 Profit Report (i.e., for 

wholesalers), and (2) U.S. Census 

Bureau 2017 Economic Census data on 

the residential and commercial building 

construction industry (i.e., for general 

contractors, mechanical contractors, and 

mobile home manufacturers). In 

addition, DOE used the 2005 Air 

Conditioning Contractors of America’s 

(‘‘ACCA’s’’) financial analysis on the 

heating, ventilation, air-conditioning, 

and refrigeration contracting industry to 

disaggregate the mechanical contractor 

markups into replacement and new 

construction markets. DOE also used 

various sources for the derivation of the 

mobile home dealer markups (see 

chapter 6 of the November 2022 

Preliminary Analysis TSD). 

DOE derived State and local taxes 

from data provided by the Sales Tax 

Clearinghouse.16 These data represent 

weighted averages that include county 

and city rates. DOE applied the State 

sales taxes to match the State-level 

markups for wholesalers and 

mechanical and general contractors. 

DOE did not receive comments 

regarding markups in response to the 

October 2023 NOPD. Chapter 6 of the 

November 2022 Preliminary Analysis 

TSD provides details on DOE’s 

development of markups for consumer 

furnace fans. 

D. Energy Use Analysis 

The purpose of the energy use 

analysis is to determine the annual 

energy consumption of consumer 

furnace fans at different efficiencies in 

representative U.S. homes and 

commercial buildings, and to assess the 

energy savings potential of increased 

consumer furnace fan efficiency. The 

energy use analysis estimates the range 

of energy use of the subject products in 

the field (i.e., as the products are 

actually used by consumers). The 

energy use analysis provides the basis 

for other analyses DOE performed, 

particularly assessments of the potential 

energy savings and the savings in 

consumer operating costs that could 

result from adoption of amended or new 

standards. 

For the October 2023 NOPD, DOE 

primarily used data from the U.S. 

Energy Information Administration’s 

(‘‘EIA’s’’) 2015 Residential Energy 

Consumption Survey (‘‘RECS 2015’’) to 

establish a reasonable range of energy 

consumption for consumer furnace fans. 

RECS 2015 is a national sample survey 

of housing units that collects statistical 

information on the consumption of and 

expenditures for energy in housing 

units, along with data on energy-related 

characteristics of the housing units and 

occupants. RECS 2015 has a sample size 

of 5,686 housing units and was 

constructed by EIA to be a national 

representation of the household 

population in the United States. DOE 

also considered the use of consumer 

furnace fans in commercial 

applications, based on characteristics 

from EIA’s most recent 2012 

Commercial Building Energy 

Consumption Survey (‘‘CBECS 2012’’) 

for a subset of building types that use 

consumer furnace fans covered by a 

potential standard. DOE utilized 

additional data sources to refine the 

development of a representative 

population of buildings for each furnace 

fan product class, as detailed in chapter 

7 of the November 2022 Preliminary 

Analysis TSD. 

EIA recently published the microdata 

for the 2020 edition of RECS.17 To 

assess the impact of using RECS 2020, 

DOE compared the LCC consumer 

sample in the July 2022 Furnace NOPR, 

which used RECS 2015, to the consumer 

sample used in the December 2023 

Furnace Final Rule consumer sample, 

which used RECS 2020. DOE assumed 

that changes in annual energy heating 

use between the two RECS editions 

serves as a reasonable proxy for the 

relative change in consumer furnace 

fans energy use. As can be seen by 

comparing Table 7.4.1 of the TSD for the 

July 2022 Furnace NOPR and Table 

7.4.1 of the TSD for the December 2023 

Furnace final rule, the estimated average 

annual energy consumption by region 

and efficiency level is similar between 

the two versions of RECS for households 

with furnaces, with RECS 2020 showing 

slightly lower energy consumption. 

Given the correlation in usage between 

furnaces and furnace fans and given that 

the estimated furnace energy use 

declines when updating to RECS 2020, 

updating the consumer sample to RECS 

2020 would not alter the conclusions of 

this final determination. Therefore, DOE 

continued to use RECS 2015 as the basis 

for its consumer sample, as was done in 

the October 2023 NOPD. 

DOE notes that commercial 

installations of consumer furnace fans 

account for approximately five percent 

or less of total installations, as shown in 

Table 6.2.1 of the November 2022 

Preliminary Analysis TSD. Given the 

relatively small number of installations 

in the commercial sector relative to the 

residential sector, changes between 

CBECS 2012 and 2018 would not 

significantly impact overall analytical 

conclusions. Therefore, for this final 

determination, DOE continued to use 

CBECS 2012 as the basis of its consumer 

sample, as was done in October 2023 

NOPD. 

In calculating the energy consumption 

of furnace fans, DOE adjusted the energy 

use from RECS 2015 and CBECS 2012 to 

normalize for year-to-year variation in 

weather. This was accomplished by 

adjusting the RECS 2015 household and 

CBECS 2012 building energy 

consumption values based on 10-year 

average heating degree day (‘‘HDD’’) and 

average cooling degree day (‘‘CDD’’) 

data for each geographical region. DOE 

also accounted for the change in 

building shell characteristics by 

applying the building shell efficiency 

index and projected trend in the HDD 

and CDD in EIA’s Annual Energy 

Outlook 2023 (‘‘AEO 2023’’). 

As in the October 2023 NOPD, DOE’s 

analysis takes into account ACCA 


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18Crystal BallTM is a commercially-available 

software tool to facilitate the creation of these types 

of models by generating probability distributions 

and summarizing results within Excel (Available at: 

www.oracle.com/technetwork/middleware/ 

crystalball/overview/index.html) (last accessed June 

11, 2024). 

Manuals J, S, and D methods to size 

every household and building in the 

sample. DOE first uses Manual J to 

estimate the house or building design 

heating load in order to determine the 

blower requirements for the assigned 

heating and cooling equipment. DOE’s 

analysis considers that typically the 

furnace fan is sized based on the 

maximum cooling capacity required. 

The heating and cooling furnace fan 

speed setting is then varied to match the 

recommended/required airflow 

performance and takes into account 

differences in the ductwork system 

curve in the field. 

DOE did not receive comments 

regarding energy use in response to the 

October 2023 NOPD. Chapter 7 of the 

November 2022 Preliminary Analysis 

TSD provides details on DOE’s energy 

use analysis for consumer furnace fans. 

E. Life-Cycle Cost and Payback Period 

Analysis 

DOE conducts LCC and PBP analyses 

to evaluate the economic impacts on 

individual consumers of potential 

amended energy conservation standards 

for consumer furnace fans. The effect of 

new or amended energy conservation 

standards on individual consumers 

usually involves a reduction in 

operating cost and an increase in 

purchase cost. DOE typically uses the 

following two metrics to measure 

consumer impacts: 

b Life-Cycle Cost (‘‘LCC’’) is the total 

consumer expense of operating the 

product over the lifetime of that 

product, consisting of total installed 

cost (which includes manufacturer 

selling price, distribution chain 

markups, sales tax, and installation 

costs) plus operating costs (e.g., 

expenses for energy use, maintenance, 

and repair). To compute the operating 

costs, DOE discounts future operating 

costs to the time of purchase and sums 

them over the lifetime of the product. 

b Payback Period (‘‘PBP’’) is the 

estimated amount of time (in years) it 

takes consumers to recover the 

increased purchase cost (including 

installation) of a more-efficient product 

through lower operating costs. DOE 

calculates the PBP by dividing the 

change in purchase cost at higher 

efficiency levels by the change in 

annual operating cost for the year that 

amended or new standards are assumed 

to take effect. 

For any given efficiency level, DOE 

measures the change in LCC relative to 

the LCC in the no-new-standards case, 

which reflects the estimated efficiency 

distribution of the product in the 

absence of new or amended energy 

conservation standards. In contrast, the 

PBP for a given efficiency level is 

measured relative to the baseline 

product. 

For each considered efficiency level 

in each product class, DOE calculated 

the LCC and PBP for a nationally 

representative set of housing units and, 

where appropriate, commercial 

buildings. As stated previously, DOE 

developed household and commercial 

building samples from RECS 2015 and 

CBECS 2012, respectively. For each 

sample household or commercial 

building, DOE determined the energy 

consumption for the consumer furnace 

fans and the appropriate energy price. 

By developing a representative sample 

of households and commercial 

buildings, the analysis captured the 

variability in energy consumption and 

energy prices associated with the use of 

consumer furnace fans. 

Inputs to the LCC calculation include 

the installed cost to the consumer, 

operating expenses, the lifetime of the 

product, and a discount rate. Inputs to 

the calculation of total installed cost 

include the cost of the product—which 

includes MPCs, manufacturer markups, 

retailer and distributor markups, and 

sales taxes (where applicable)—and 

installation costs. Inputs to the 

calculation of operating expenses 

include annual energy consumption, 

energy prices and price projections, 

repair and maintenance costs, product 

lifetimes, and discount rates. Inputs to 

the PBP calculation include the 

installed cost to the consumer and firstyear operating expenses. DOE created 

distributions of values for installation 

cost, repair and maintenance, product 

lifetime, discount rates, and sales taxes, 

with probabilities attached to each 

value, to account for their uncertainty 

and variability. 

The computer model DOE uses to 

calculate the LCC relies on a Monte 

Carlo simulation to incorporate 

uncertainty and variability into the 

analysis. The Monte Carlo simulations 

randomly sample input values from the 

probability distributions and product 

user samples. For this proceeding, the 

Monte Carlo approach is implemented 

in Microsoft Excel together with the 

Crystal BallTM add-on.18 The model 

calculated the LCC for products at each 

efficiency level for 10,000 consumers 

per simulation run. The analytical 

results include a distribution of 10,000 

data points showing the range of LCC 

savings for a given efficiency level 

relative to the no-new-standards case 

efficiency distribution. In performing an 

iteration of the Monte Carlo simulation 

for a given consumer, product efficiency 

is chosen based on its probability. If the 

chosen product efficiency is greater than 

or equal to the efficiency of the standard 

level under consideration, the LCC 

calculation reveals that a consumer is 

not impacted by the standard level. By 

accounting for consumers who are 

already projected to purchase moreefficient products than the baseline in a 

given case, DOE avoids overstating the 

potential benefits from increasing 

product efficiency. 

DOE calculated the LCC and PBP for 

consumers of consumer furnace fans as 

if each were to purchase a new product 

in the expected first year of required 

compliance with new or amended 

standards. For purposes of this final 

determination, DOE used 2030 as the 

first year of compliance with any 

amended standards. 

Table IV.22 summarizes the approach 

and data DOE used to derive inputs to 

the LCC and PBP analysis. The 

subsections that follow provide further 

discussion. Details of the spreadsheet 

model, and how all inputs to the LCC 

and PBP analyses are applied, are 

contained in chapter 8 of the November 

2022 Preliminary Analysis TSD and its 

appendices. 

TABLE IV.22—SUMMARY OF INPUTS AND METHODS FOR THE LCC AND PBP ANALYSES * 

Inputs Source/method 

Product Cost .............................................. Derived from the manufacturer production cost (‘‘MPC’’) for furnace fans at different heating input 

capacities for each efficiency level (from the engineering analysis). The MPCs are then multiplied 

by the various market participant markups (e.g., manufacturer, wholesaler, and plumbing contractor) for each distribution channel and sales taxes derived for each State and the District of Columbia. 


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19EIA, Form EIA–861M (formerly EIA–826) 

detailed data (2022) (Available at: www.eia.gov/ 

electricity/data/eia861m/) (last accessed June 28, 

2024). 

20EIA, Natural Gas Navigator (2022) (Available at: 

www.eia.gov/naturalgas/data.php) (last accessed 

June 11, 2024). 

21EIA, 2021 State Energy Data System (SEDS) 

(2021) (Available at: www.eia.gov/state/seds/) (last 

accessed June 11, 2024). 

TABLE IV.22—SUMMARY OF INPUTS AND METHODS FOR THE LCC AND PBP ANALYSES *—Continued 

Inputs Source/method 

Installation Costs ....................................... Varies by efficiency level and individual house/building characteristic. Material and labor costs are 

derived for each State and the District of Columbia mainly using RSMeans Residential Cost Data 

2023. Overhead and profits are included in the RSMeans data. Probability distributions are derived for various installation cost input parameters. 

Annual Energy Use .................................... Derived mainly by using the heating energy use data for each housing unit and building from the 

Energy Information Administration’s (‘‘EIA’s’’) 2015 Residential Energy Consumption Survey 

(‘‘RECS 2015’’) and EIA’s 2012 Commercial Buildings Energy Consumption Survey (‘‘CBECS 

2012’’), together with consumer furnace fans test procedure calculation methodologies used to 

determine the annual energy consumption associated with the considered standard levels. Probability distributions are derived for various input parameters. 

Energy Prices ............................................ Calculated monthly marginal average electricity, natural gas or liquefied petroleum gas (‘‘LPG’’), and 

fuel oil prices in each of the 50 U.S. States and District of Columbia, using EIA historical data and 

billing data for each RECS 2015 housing unit and CBECS 2012 building. 

Energy Price Trends .................................. Residential and commercial prices were escalated by using EIA’s Annual Energy Outlook 2023 

(AEO 2023) forecasts to estimate future energy prices. Escalation was performed at the Census 

Division level. 

Repair and Maintenance Costs ................. Estimated the costs associated with preventive maintenance (e.g., checking furnace fan) and repair 

(e.g., replacing motor) based on data from a variety of published sources, including RSMeans 

2023 Facilities Maintenance and Repair Data. It is assumed that maintenance and repair costs 

vary by efficiency level, and probability distributions are derived for various input parameters. 

Product Lifetime ......................................... Used Weibull probability distribution of lifetimes developed for consumer furnace fans based on various survey and shipments data. 

Discount Rates .......................................... Probability distributions by income bins are derived for residential discount rates based on the Federal Reserve Board’s Survey of Consumer Finances from 1995 to 2019 and various interest rate 

sources. Probability distributions for commercial discount rates for various building activities (e.g., 

office) are derived using multiple interest rate sources. See section IV.E.7 of this document. 

Compliance Date ....................................... 2030 (five years after expected publication of the final rule). 

* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the November 2022 

Preliminary Analysis TSD. Energy price trends, product lifetimes, and discount rates are not used for the PBP calculation. 

1. Product Cost 

To calculate consumer product costs, 

DOE multiplied the MPCs developed in 

the engineering analysis by the markups 

described previously (along with sales 

taxes). DOE used different markups for 

baseline products and higher-efficiency 

products, because DOE applies an 

incremental markup to the increase in 

MSP associated with higher-efficiency 

products. 

For the October 2023 NOPD, DOE 

assumed no price trend for consumer 

furnace fans due to uncertainty in future 

commodity prices. DOE did not receive 

comment on this assumption and 

maintains the same approach for this 

final determination. 

See chapter 8 of the November 2022 

Preliminary Analysis TSD for details. 

2. Installation Cost 

Installation cost includes labor, 

overhead, and any miscellaneous 

materials and parts needed to install the 

product. Because consumer furnace fans 

are installed in furnaces in the factory, 

there is generally no additional 

installation cost in the home. However, 

consumer furnace fans that employ a 

constant-airflow BPM design may 

require additional installation costs. 

DOE assumed that all constant-airflow 

BPM furnace fan installations will 

require extra labor at startup to check 

and adjust airflow. 

As in the October 2023 NOPD, DOE 

estimated the installation costs at each 

considered efficiency level using a 

variety of sources, including RSMeans 

data, manufacturer literature, and 

information from an expert consultant 

report. DOE’s analysis of installation 

costs accounted for regional differences 

in labor costs. For a detailed discussion 

of the development of installation costs, 

see appendix 8C of the November 2022 

Preliminary Analysis TSD. 

3. Annual Energy Consumption 

For each sampled household or 

commercial building, DOE determined 

the energy consumption for a consumer 

furnace fan at different efficiency levels 

using the approach described previously 

in section IV.D of this document. 

4. Energy Prices 

Energy bills to consumers typically 

include fixed costs (i.e., costs that do 

not depend on consumption) and costs 

that depend on the level of 

consumption. To estimate the impact of 

standards on consumer operating costs, 

DOE calculated average energy prices, 

which represent the typical cost for a 

consumer to use energy, including fixed 

costs, and marginal energy prices, 

which represent the energy price 

consumers would pay for reduced 

consumption. In other words, a 

marginal energy price reflects the cost or 

benefit of adding or subtracting one 

additional unit of energy consumption. 

Because marginal price more accurately 

captures the incremental savings 

associated with a change in energy use 

from higher efficiency, it provides a 

better representation of incremental 

change in consumer costs than average 

electricity prices. DOE applied average 

natural gas and electricity prices for the 

energy use of the product purchased in 

the no-new-standards case, and 

marginal prices for the incremental 

change in energy use associated with 

the other efficiency levels considered. 

For the October 2023 NOPD, DOE 

derived average monthly marginal 

residential and commercial electricity, 

natural gas, LPG, and fuel oil prices for 

each State using data from EIA.19 20 21

DOE calculated marginal monthly 

regional energy prices by: (1) first 

estimating an average annual price for 

each region; (2) multiplying by monthly 

energy price factors; and (3) multiplying 

by seasonal marginal price factors for 

electricity, natural gas, and LPG. The 


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22The Gas Technology Institute provided a 

reference located in the docket of DOE’s 2016 

rulemaking to develop energy conservation 

standards for residential boilers. (Docket No. EERE– 

2012–BT–STD–0047–0068) (Available at: 

www.regulations.gov/document/EERE-2012-BTSTD-0047-0068) (last accessed June 28, 2024). 

23EIA, Annual Energy Outlook 2023 with 

Projections to 2050, Washington, DC (Available at: 

www.eia.gov/forecasts/aeo/) (last accessed June 11, 

2024). 

24RSMeans Company Inc., RS Means Facilities 

Maintenance & Repair Cost Data (2021) (Available 

at: www.rsmeans.com/) (last accessed June 1, 2024). 

25 Jakob, F.E., et al., Assessment of Technology for 

Improving the Efficiency of Residential Gas 

Furnaces and Boilers, Volume I and II—Appendices 

(September 1994), Gas Research Institute, Report 

No. GRI–94/0175 (Available at: www.gti.energy/ 

software-and-reports/) (last accessed Feb. 15, 2022). 

analysis used 2022 data for residential 

and commercial natural gas and 

electricity prices and 2021 data for LPG 

and fuel oil prices. Further details may 

be found in chapter 8 of the Preliminary 

Analysis TSD. 

For the October 2023 NOPD, DOE 

compared marginal price factors 

developed by DOE from the EIA data to 

develop seasonal marginal price factors 

for 23 gas tariffs provided by the Gas 

Technology Institute for the 2016 

residential boilers energy conservation 

standards rulemaking.22 DOE found that 

the winter price factors used by DOE are 

generally comparable to those computed 

from the tariff data, indicating that 

DOE’s marginal price estimates are 

reasonable at average usage levels. The 

summer price factors are also generally 

comparable. Of the 23 tariffs analyzed, 

eight have multiple tiers, and of these 

eight, six have ascending rates and two 

have descending rates. The tariff-based 

marginal factors use an average of the 

two tiers as the commodity price. A full 

tariff-based analysis would require 

information about the household’s total 

baseline gas usage (to establish which 

tier the consumer is in), and a weight 

factor for each tariff that determines 

how many customers are served by that 

utility on that tariff. These data are 

generally not available in the public 

domain. DOE’s use of EIA State-level 

data effectively averages overall 

consumer sales in each State, and so 

incorporates information from all 

utilities. DOE’s approach is, therefore, 

more representative of a large group of 

consumers with diverse baseline gas 

usage levels than an approach that uses 

only tariffs. 

DOE notes that within a State, there 

could be significant variation in the 

marginal price factors, including 

differences between rural and urban 

rates. To take this into account, DOE 

developed marginal price factors for 

each individual household using RECS 

2015 billing data. These data are then 

normalized to match the average State 

marginal price factors, which are 

equivalent to a consumption-weighted 

average marginal price across all 

households in the State. For more 

details on the comparative analysis and 

updated marginal price analysis, see 

appendix 8D of the November 2022 

Preliminary Analysis TSD. 

To estimate energy prices in future 

years, DOE multiplied the 2022 energy 

prices by the projection of annual 

average price changes for each of the 

nine Census Divisions from the 

Reference case in AEO 2023, which has 

an end year of 2050.23 To estimate price 

trends after 2050, DOE used the average 

annual rate of change in prices from 

2046 through 2050. 

To assess the impact of updated 

energy price estimates, DOE compared 

the energy price estimates in 2030 from 

the October 2023 NOPD to the projected 

estimates using updated EIA energy 

price data from 2023. The results of this 

comparison are presented in Table 

IV.23. 

TABLE IV.23—SUMMARY OF ENERGY

PRICE COMPARISON OF 2023 EIA 

DATA RELATIVE TO NOVEMBER 2023 

NOPD 

Energy type 

Percentage 

change in 2030 

energy price 

Electricity .......................... ¥20 

Natural Gas ...................... 1 

LPG ................................... 1 

Fuel Oil ............................. ¥16 

Based upon this review, DOE has 

determined that energy prices have 

either not changed significantly, as in 

the case of natural gas and LPG, or have 

decreased, as in the case of electricity 

and fuel oil, relative to the energy prices 

used in the October 2023 NOPD. 

Consequently, updating energy prices 

would either have no impact on 

analytical results or decrease operating 

cost savings, thereby further justifying 

DOE’s decision to not amend the 

existing energy conservation standards 

for consumer furnace fans. DOE did not 

receive comments regarding energy 

prices in response to the October 2023 

NOPD. As a result, DOE has continued 

to use the energy prices from the 

October 2023 NOPD in this 

determination. 

5. Maintenance and Repair Costs 

The maintenance cost is the routine 

cost to the consumer of maintaining 

product operation. The regular furnace 

maintenance generally includes 

checking the furnace fan. As in the 

October 2023 NOPD, DOE assumes for 

this analysis that this maintenance cost 

is the same at all efficiency levels. 

The repair cost is the cost to the 

consumer for replacing or repairing 

components in the consumer furnace 

fan that have failed. For the October 

2023 NOPR, DOE included motor 

replacement as a repair cost for a 

fraction of furnace fans. To estimate 

rates of motor failure, DOE developed a 

distribution of fan motor lifetime 

(expressed in operating hours) by motor 

size using data from DOE’s analysis for 

the March 9, 2010 Small Electric Motors 

Final Rule and manufacturer literature. 

(75 FR 10874) DOE then paired these 

data with the calculated number of 

annual operating hours for each sample 

furnace fan. Motor costs were based on 

costs developed in the engineering 

analysis and the replacement markups 

developed in the markup analysis. DOE 

assumed that the motor cost does not 

apply if motor failure occurs during the 

furnace warranty period (assumed to be 

at least one year, and five or more years 

for a fraction of installations). 

For the October 2023 NOPD, the 

repair costs (including labor hours, 

component costs, and frequency) at each 

considered efficiency level were derived 

based on RSMeans data,24 manufacturer 

literature, and a report from the Gas 

Research Institute.25 DOE accounted for 

regional differences in labor costs. DOE 

did not receive comments related to its 

repair cost assumptions, and 

accordingly, the Department has 

maintained the same costs as used in 

the October 2023 NOPD for this final 

determination. 

For a detailed discussion of the 

development of maintenance and repair 

costs, see appendix 8E of the November 

2022 Preliminary Analysis TSD. 

6. Product Lifetime 

Product lifetime is the age at which an 

appliance is retired from service. 

Furnace fan lifetimes are considered 

equivalent to furnace lifetimes, so DOE 

modeled furnace fan lifetime based on 

estimated furnace lifetimes. Because 

product lifetime varies, DOE uses a 

lifetime distribution to characterize the 

probability that a product will be retired 

from service at a given age. DOE 

conducted an extensive literature 

review and took into account published 

studies. Because the basis for the 

estimates in the literature was 

uncertain, DOE developed a method 

using national survey data, along with 

shipment data, to estimate the 

distribution of consumer furnace 

lifetimes in the field. 


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26U.S. Census Bureau: Housing and Household 

Economic Statistics Division, American Housing 

Survey, Multiple Years (1974, 1975, 1976, 1977, 

1978, 1979, 1980, 1981, 1983, 1985, 1987, 1989, 

1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 

2007, 2009, 2011, 2013, 2015, 2017, 2019, and 2021) 

(Available at: www.census.gov/programs-surveys/ 

ahs.html) (last accessed June 28, 2024). 

27U.S. Department of Energy: Energy Information 

Administration, Residential Energy Consumption 

Survey (‘‘RECS’’), Multiple Years (1990, 1993, 1997, 

2001, 2005, 2009, and 2015) (Available at: 

www.eia.gov/consumption/residential/) (last 

accessed June 28, 2024). 

28 Decision Analysts, 2022 American Home 

Comfort Study (2022) Arlington, Texas (Available 

at: www.decisionanalyst.com/syndicated/ 

homecomfort/) (last accessed August 26, 2024). 

29The implicit discount rate is inferred from a 

consumer purchase decision between two otherwise 

identical goods with different first cost and 

operating cost. It is the interest rate that equates the 

increment of first cost to the difference in net 

present value of lifetime operating cost, 

incorporating the influence of several factors: 

transaction costs, risk premiums and response to 

uncertainty, time preferences, and interest rates at 

which a consumer is able to borrow or lend. The 

implicit discount rate is not appropriate for the LCC 

analysis because it reflects a range of factors that 

influence consumer purchase decisions, rather than 

the opportunity cost of the funds that are used in 

purchases. 

30U.S. Board of Governors of the Federal Reserve 

System, Survey of Consumer Finances, 1995, 1998, 

2001, 2004, 2007, 2010, 2013, 2016, and 2019 

(Available at: www.federalreserve.gov/econresdata/ 

scf/scfindex.htm) (last accessed April 26, 2024). 

31 Damodaran, A. Data Page: Historical Returns on 

Stocks, Bonds and Bills-United States (2023) 

(Available at: pages.stern.nyu.edu/∼adamodar/) 

(Last accessed June 1, 2024). 

DOE assumed that the probability 

function for the annual survival of 

consumer furnaces would take the form 

of a Weibull distribution. For the 

October 2023 NOPD, DOE derived the 

Weibull distribution parameters by 

using stock and age data on consumer 

furnaces from the U.S. Census’s biennial 

American Housing Survey (‘‘AHS’’) 

from 1974–2019 26 and EIA’s RECS 

1990, 1993, 2001, 2005, 2009, and 

2015.27 DOE used the results from the 

2022 American Home Comfort Survey 

(‘‘AHCS’’) to estimate the national 

average lifetime of 21.4 years.28 DOE 

also determined the average lifetime for 

different regions: 22.5 years for the 

North region and 20.2 years for rest of 

the country. These results were used to 

scale the average lifetime for these 

regions. 

DOE did not receive any comments on 

the lifetime distributions used in the 

October 2023 NOPD. As consumer 

furnace fans, and the furnaces in which 

they reside, have not changed 

significantly since the October 2023 

NOPD, DOE has maintained the same 

lifetime distribution in this final 

determination. 

7. Discount Rates 

In the calculation of LCC, DOE 

applies discount rates appropriate to 

estimate the present value of future 

expenditures and savings. DOE 

estimated a distribution of discount 

rates for consumer furnace fans based 

on the opportunity cost of funds. DOE 

estimates discount rates separately for 

residential and commercial end users. 

For residential end users, DOE applies 

weighted-average discount rates 

calculated from consumer debt and 

asset data, rather than marginal or 

implicit discount rates.29 The LCC 

analysis estimates net present value 

over the lifetime of the product, so the 

appropriate discount rate will reflect the 

general opportunity cost of household 

funds, taking this time scale into 

account. Given the long time horizon 

modeled in the LCC analysis, the 

application of a marginal interest rate 

associated with an initial source of 

funds is inaccurate. Regardless of the 

method of purchase, consumers are 

expected to continue to rebalance their 

debt and asset holdings over the LCC 

analysis period, based on the 

restrictions consumers face in their debt 

payment requirements and the relative 

size of the interest rates available on 

debts and assets. 

To establish residential discount rates 

for the LCC analysis, DOE identified all 

relevant household debt or asset classes 

in order to approximate a consumer’s 

opportunity cost of funds related to 

appliance energy cost savings. It 

estimated the average percentage shares 

of the various types of debt and equity 

by household income group using data 

from the Federal Reserve Board’s 

triennial Survey of Consumer 

Finances 30 (‘‘SCF’’). Using the SCF and 

other sources, DOE developed a 

distribution of rates for each type of 

debt and asset by income group to 

represent the rates that may apply in the 

year in which amended standards 

would take effect. DOE assigned each 

sample household a specific discount 

rate drawn from one of the distributions. 

The average rate across all types of 

household debt and equity and income 

groups, weighted by the shares of each 

type, is 4.1 percent. 

To establish commercial discount 

rates for commercial end users in the 

small fraction of consumer furnace fans 

in commercial buildings, DOE estimated 

the weighted-average cost of capital 

using data from Damodaran Online.31

The weighted-average cost of capital is 

commonly used to estimate the present 

value of cash flows to be derived from 

a typical company project or 

investment. Most companies use both 

debt and equity capital to fund 

investments, so their cost of capital is 

the weighted average of the cost to the 

firm of equity and debt financing. DOE 

estimated the cost of equity using the 

capital asset pricing model, which 

assumes that the cost of equity for a 

particular company is proportional to 

the systematic risk faced by that 

company. The average rate for consumer 

furnace fans used in commercial 

applications in this analysis, across all 

business activity, is 7.2 percent. DOE 

did not receive comments regarding 

discount rates in response to the 

October 2023 NOPD. 

See chapter 8 of the November 2022 

Preliminary Analysis TSD for further 

details on the development of consumer 

and commercial discount rates. 

8. Energy-Efficiency Distribution in the 

No-New-Standards Case 

To accurately estimate the share of 

consumers that would be affected by a 

potential energy conservation standard 

at a particular efficiency level, DOE’s 

LCC analysis considered the projected 

distribution (i.e., market shares) of 

product efficiencies under the no-newstandards case (i.e., the case without 

amended or new energy conservation 

standards) in the compliance year 

(2030). This approach reflects the fact 

that some consumers may purchase 

products with efficiencies greater than 

the baseline levels, even in the absence 

of new or amended standards. 

For consumer furnace fans, DOE does 

not have any shipments data by 

efficiency after the 2019 furnace fan 

standards became effective. Due to the 

lack of available shipments data, DOE 

used DOE’s CCD for furnace fans and 

furnaces as a proxy to develop an 

efficiency distribution based on 

available models. 

DOE did not receive additional data 

or comments on estimated market 

shares in the no-new-standard case in 

response to the October 2023 NOPD. 

Accordingly, DOE continued to use 

estimates from the October 2023 NOPD 

for this final determination. 

Table IV.24 shows the resulting 

market shares by efficiency level. For a 

detailed discussion of the development 

of no-new-standards case distributions 

based on models, see appendix 7F of the 

November 2022 Preliminary Analysis 

TSD. 


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32 DOE uses data on manufacturer shipments as 

a proxy for national sales, as aggregate data on sales 

are lacking. In general, one would expect a close 

correspondence between shipments and sales. 

33Appliance Magazine, Appliance Historical 

Statistical Review: 1954–2012 (2014). 

34Air-Conditioning, Heating, & Refrigeration 

Institute (‘‘AHRI’’), Furnace Historical Shipments 

Data (1996–2022) (Available at: www.ahrinet.org/ 

analytics/statistics/historical-data/furnaceshistorical-data) (last accessed June 28, 2024). 

35Heating, Air-conditioning and Refrigeration 

Distributors International (‘‘HARDI’’), Gas Furnace 

Shipments Data from 2013–2022 (Provided to 

Lawrence Berkeley National Laboratory). 

36BRG Building Solutions, The North American 

Heating & Cooling Product Markets (Available at: 

www.brgbuildingsolutions.com/solutions/marketreports/) (last accessed June 28, 2024). 

37AHRI (formerly Gas Appliance Manufacturers 

Association (‘‘GAMA’’)), Updated Shipments Data 

for Residential Furnaces and Boilers (April 25, 

2005) (Available at: www.regulations.gov/ 

document/EERE-2006-STD-0102-0138) (last 

accessed June 28, 2024). 

TABLE IV.24—NO-NEW-STANDARDS CASE ENERGY EFFICIENCY DISTRIBUTIONS IN 2030 FOR CONSUMER FURNACE FANS

Product class EL 

No-newstandards 

case 

(%) 

Efficiency level 

(%) 

1 2 

Non-Weatherized, Non-Condensing Gas Furnace Fan ................................................................ 0 

1 

100 

..................

................

100 

................

................

NonWeatherized, Condensing Gas Furnace Fan ......................................................................... 0 

1 

100 

..................

................

100 

................

................

Weatherized NonCondensing Gas Furnace Fan .......................................................................... 0 

1 

100 

..................

................

100 

................

................

NonWeatherized, NonCondensing Oil Furnace Fan ..................................................................... 0 46 ................ ................

1 54 100 ................

2 .................. ................ 100 

NonWeatherized Electric Furnace/Modular Blower Fan ............................................................... 0 

1 

100 

..................

................

100 

................

................

Mobile Home NonWeatherized, NonCondensing Gas Furnace Fan ............................................ 0 11 ................ ................

1 89 100 ................

2 .................. ................ 100 

Mobile Home NonWeatherized, Condensing Gas Furnace Fan ................................................... 0 8 ................ ................

1 92 100 ................

2 .................. ................ 100 

Mobile Home NonWeatherized Oil Furnace Fan .......................................................................... 0 90 ................ ................

1 10 100 ................

2 .................. ................ 100 

Mobile Home Electric Furnace/Modular Blower Fan ..................................................................... 0 

1 

100 

..................

................

100 

................

................

The LCC Monte Carlo simulations 

draw from the efficiency distributions 

and assign an efficiency to the consumer 

furnace fans purchased by each sample 

household or commercial business in 

the no-new-standards case. The 

resulting percentage shares within the 

sample match the market shares in the 

efficiency distributions. 

9. Payback Period Analysis 

The payback period is the amount of 

time (expressed in years) it takes the 

consumer to recover the additional 

installed cost of more-efficient products, 

compared to baseline products, through 

energy cost savings. Payback periods 

that exceed the life of the product mean 

that the increased total installed cost is 

not recovered in reduced operating 

expenses. 

The inputs to the PBP calculation for 

each efficiency level are the change in 

total installed cost of the product and 

the change in the first-year annual 

operating expenditures relative to the 

baseline. DOE refers to this as a ‘‘simple 

PBP’’ because it does not consider 

changes over time in operating cost 

savings. The PBP calculation uses the 

same inputs as the LCC analysis when 

deriving first-year operating costs, 

except that discount rates are not 

needed. DOE did not receive comments 

regarding the payback period 

methodology in response to the October 

2023 NOPD. 

F. Shipments Analysis 

DOE uses projections of annual 

product shipments to calculate the 

national impacts of potential amended 

or new energy conservation standards 

on energy use, NPV, and future 

manufacturer cash flows.32 The 

shipments model takes an accounting 

approach, tracking market shares of 

each product class and the vintage of 

units in the stock. Stock accounting uses 

product shipments as inputs to estimate 

the age distribution of in-service 

product stocks for all years. The age 

distribution of in-service product stocks 

is a key input to calculations of both the 

NES and NPV, because operating costs 

for any year depend on the age 

distribution of the stock. 

DOE developed shipment projections 

based on historical data and an analysis 

of key market drivers for each product. 

The vast majority of furnace fans are 

shipped installed in furnaces, so DOE 

estimated furnace fan shipments by 

projecting furnace shipments in three 

market segments: (1) replacements, (2) 

new housing, and (3) new owners in 

buildings that did not previously have 

a central furnace. 

To project furnace replacement 

shipments, DOE developed retirement 

functions for furnaces from the lifetime 

estimates and applied them to the 

existing products in the housing stock. 

The existing stock of products is tracked 

by vintage and developed from 

historical shipments data. The 

shipments analysis uses a distribution 

of furnace lifetimes to estimate furnace 

replacement shipments. In addition, 

DOE adjusted replacement shipments by 

taking into account demolitions, using 

the estimated changes to the housing 

stock from AEO 2023. 

DOE assembled historical shipments 

data for consumer furnaces from 

Appliance Magazine from 1954–2012,33

AHRI from 1996–2022,34 HARDI from 

2013–2022,35 and BRG from 2007– 

2022.36 DOE also used the 1992 and 

1994–2003 shipments data by State 

provided by AHRI 37 and 2004–2009 

and 2010–2015 shipments data by the 

North region and the rest of country 


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38AHRI, Non-Condensing and Condensing 

Regional Gas Furnace Shipments for 2004–2009 and 

2010–2015 Data Provided to DOE contractors (July 

20, 2010 and November 26, 2016). 

39U.S. Census Bureau, Manufactured Homes 

Survey: Annual Shipments to States from 1994– 

2022 (Available at: www.census.gov/data/tables/ 

time-series/econ/mhs/latest-data.html) (last 

accessed June 28, 2024). 

40U.S. Census Bureau, Manufactured Homes 

Survey: Historical Annual Placements by State from 

1980–2013 (Available at: www.census.gov/data/ 

tables/time-series/econ/mhs/historical-annualplacements.html) (last accessed June 28, 2024). 

41U.S. Census Bureau—Housing and Household 

Economic Statistics Division, American Housing 

Survey, multiple years from 1973–2021 (Available 

at: www.census.gov/programs-surveys/ahs/ 

data.html) (last accessed June 28, 2024). 

42EIA, Residential Energy Consumption Survey 

(RECS), multiple years from 1979–2015 (Available 

at: www.eia.gov/consumption/residential/) (last 

accessed June 28, 2024). 43Mortex estimated that the total number of 

MHGFs manufactured in 2014 was about 54,000, 

and about two-thirds were sold to the replacement 

market. Mortex also stated that MHGF sales have 

not been growing. (Mortex, No. 157 at p. 3) 

(Available at: www.regulations.gov/document/ 

EERE-2014-BT-STD-0031-0157) (last accessed June 

28, 2024). 44U.S. Census, Characteristics of New Housing 

from 1999–2022 (Available at: www.census.gov/ 

construction/chars/) (last accessed June 1, 2023). 45U.S. Census, Characteristics of New Housing 

(Multi-Family Units) from 1973–2022 (Available at: 

www.census.gov/construction/chars/mfu.html) (last 

accessed June 1, 2023). 46Home Innovation Research Labs (independent 

subsidiary of the National Association of Home 

Builders (NAHB), Annual Builder Practices Survey 

(2015–2019) (Available at: 

www.homeinnovation.com/trends_and_reports/ 

data/new_construction) (last accessed June 28, 

2024). 

47U.S. Census Bureau, Characteristics of New 

Housing (Available at: www.census.gov/ 

construction/chars/) (last accessed June 28, 2024). 

48 Decision Analyst, 2002, 2004, 2006, 2008, 

2010, 2013, 2016, 2019, and 2022 American Home 

Comfort Study (Available at: 

www.decisionanalyst.com/syndicated/ 

homecomfort/) (last accessed June 28, 2024). 

49BRG data (Available at: 

www.brgbuildingsolutions.com/) (last accessed June 

28, 2024). 

50AHRI (formerly GAMA), Furnace and Boiler 

Shipments data provided to DOE for Furnace and 

Boiler ANOPR (Jan. 23, 2002). 

51The NIA accounts for impacts in the United 

States and U.S. territories. 

52For the NIA, DOE adjusts the installed cost data 

from the LCC analysis to exclude sales tax, which 

is a transfer. 

provided by AHRI,38 as well as HARDI 

shipments data that is disaggregated by 

region and most States to disaggregate 

shipments by region. DOE also used 

CBECS 2012 data and BRG shipments 

data to estimate the commercial fraction 

of shipments. Disaggregated shipments 

for mobile home gas furnaces 

(‘‘MHGFs’’) are not available, so DOE 

disaggregated MHGF shipments from 

the total by using a combination of data 

from the U.S. Census,39 40 AHS,41

RECS,42 and a 2014 MHGF shipments 

estimate by Mortex.43

To project shipments to the new 

housing market, DOE utilized a 

projection of new housing construction 

and historic saturation rates of various 

furnaces in new housing. DOE used the 

AEO 2023 housing starts and 

commercial building floor space 

projections and data from the U.S. 

Census Bureau’s Characteristics of New 

Housing,44 45 Home Innovation Research 

Labs Annual Builder Practices Survey,46

RECS 2015, AHS 2021, and CBECS 2012 

to estimate new construction 

saturations. DOE also estimated future 

furnace saturation rates in new singlefamily housing based on a weighted 

average of values from the U.S. Census 

Bureau’s Characteristics of New 

Housing from 1999 through 2022, and 

for multi-family buildings using data 

from the Census Bureau’s 

Characteristics of New Housing (MultiFamily Units) from 1973 through 

2022.47

To project shipments to the newowner market, DOE estimated the new 

owners based on the residual shipments 

from the calculated replacement and 

new construction shipments compared 

to historical shipments over five years 

(2018–2022). DOE compared this with 

data from Decision Analyst’s 2002 to 

2022 AHCS,48 2023 BRG data,49 and 

AHRI’s estimated shipments in 2000,50

which showed similar historical 

fractions of new owners. DOE assumed 

that the new-owner fraction would be 

the 10-year average (2013–2022) in 2030 

and then decrease to zero by the end of 

the analysis period (2059). 

DOE did not receive comments on the 

shipments methodology in response to 

the October 2023 NOPD. DOE notes that 

although there may be additional 

historical data available for 2023, 

including an additional year of 

historical data would have a minimal 

impact to projected shipments over the 

shipments analysis period (2030–2059). 

Additionally, the October 2023 NOPD 

relied on AEO 2023, which remains the 

most recent available edition for AEO 

for many key inputs for future product 

demand. For these reasons, DOE 

continued to use shipments from the 

October 2023 NOPD for this final 

determination. 

G. National Impact Analysis 

The NIA assesses the NES and the 

NPV from a national perspective of total 

consumer costs and savings that would 

be expected to result from new or 

amended energy conservation standards 

at specific efficiency levels.51

(‘‘Consumer’’ in this context refers to 

consumers of the product being 

regulated.) DOE calculates the NES and 

NPV for the potential standard levels 

considered based on projections of 

annual product shipments, along with 

the annual energy consumption and 

total installed cost data from the energy 

use and LCC analyses.52 For the present 

analysis, DOE projected the energy 

savings, operating cost savings, product 

costs, and NPV of consumer benefits 

over the lifetime of consumer furnace 

fans sold from 2030 through 2059. 

DOE evaluates the impacts of new or 

amended standards by comparing a case 

without such standards with standardscase projections. The no-new-standards 

case characterizes energy use and 

consumer costs for each product class in 

the absence of new or amended energy 

conservation standards. For this 

projection, DOE considers historical 

trends in efficiency and various forces 

that are likely to affect the mix of 

efficiencies over time. DOE compares 

the no-new-standards case with 

projections characterizing the market for 

each product class if DOE adopted new 

or amended standards at specific energy 

efficiency levels (i.e., the candidate 

standards levels (‘‘CSLs’’) or standards 

cases) for that class. For the standards 

cases, DOE considers how a given 

standard would likely affect the market 

shares of products with efficiencies 

greater than the standard. 

DOE uses a spreadsheet model to 

calculate the energy savings and the 

national consumer costs and savings 

from each CSL. Interested parties can 

review DOE’s analyses by changing 

various input quantities within the 

spreadsheet. The NIA spreadsheet 

model uses typical values (as opposed 

to probability distributions) as inputs. 

Table IV.25 summarizes the inputs 

and methods DOE used for the NIA for 

the final determination. Discussion of 

these inputs and methods follows the 

table. See chapter 10 of the November 

2022 Preliminary Analysis TSD for 

details. 

TABLE IV.25—SUMMARY OF INPUTS AND METHODS FOR THE NATIONAL IMPACT ANALYSIS

Input Method 

Shipments ........................................................... Annual shipments from shipments model. 


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53 DOE reviewed an evaluation report from 

Wisconsin that indicates that a considerable 

number of homeowners who purchase constantairflow BPM furnaces significantly increase the 

frequency with which they operate their furnace fan 

subsequent to the installation of the constantairflow BPM furnace. This report indicates that, on 

average, there is a doubling in the amount of 

continuous fan circulation use. DOE assumed that 

this doubling was the same for all types of furnace 

fans that had a significant decrease in energy use 

in the continuous fan circulation mode. (Evaluation 

report available at: www.focusonenergy.com/sites/ 

default/files/emcfurnaceimpactassessment_

evaluationreport.pdf) (last accessed August 26, 

2024). 

54 DOE, Energy Conservation Program for Certain 

Industrial Equipment: Energy Conservation 

Standards for Small, Large, and Very Large AirCooled Commercial Package Air Conditioning and 

Heating Equipment and Commercial Warm Air 

Furnaces; Direct Final Rule. 81 FR 2419 (Jan. 15, 

2016) (Available at: www.regulations.gov/ 

document/EERE-2013-BT-STD-0021-0055) (last 

accessed June 28, 2024). 

55 DOE, Energy Conservation Program: Energy 

Conservation Standards for Residential Boilers; 

Final Rule. 81 FR 2319 (Jan. 15, 2016) (Available 

at: www.regulations.gov/document/EERE-2012-BTSTD-0047-0078) (last accessed June 11, 2024). 

56 DOE, Energy Conservation Program: Energy 

Conservation Standards for Commercial Packaged 

Boilers; Final Rule. 85 FR 1592 (Jan. 10, 2020) 

(Available at: www.regulations.gov/document/ 

EERE-2013-BT-STD-0030-0099) (last accessed June 

11, 2024). 

TABLE IV.25—SUMMARY OF INPUTS AND METHODS FOR THE NATIONAL IMPACT ANALYSIS—Continued 

Input Method 

Compliance Date of Standard ............................ 2030. 

Efficiency Trends ................................................ No-new-standards case based on historical shipment data and on current consumer furnace 

fans model availability by efficiency level (see chapter 8 of the November 2022 Preliminary 

Analysis TSD). 

Roll-up in the compliance year for standards cases. 

Annual Energy Consumption per Unit ................ Annual weighted-average values are a function of shipments-weighted unit energy use consumption. 

Total Installed Cost per Unit ............................... Annual weighted-average values as a function of the efficiency distribution (see chapter 8 of 

the November 2022 Preliminary Analysis TSD). 

Annual Energy Cost per Unit .............................. Annual weighted-average values as a function of the annual energy consumption per unit and 

energy prices. 

Repair and Maintenance Cost per Unit .............. Annual values as a function of efficiency level (see chapter 8 of the November 2022 Preliminary Analysis TSD). 

Energy Price Trends ........................................... AEO 2023 projections to 2050 and extrapolation thereafter. 

Energy Site-to-Primary and FFC Conversion ..... A time-series conversion factor based on AEO 2023. 

Discount Rate ..................................................... 3 percent and 7 percent. 

Present Year ....................................................... 2023. 

1. Product Efficiency Trends 

A key component of the NIA is the 

trend in energy efficiency projected for 

the no-new-standards case and each of 

the standards cases. Section IV.E.8 of 

this document describes how DOE 

developed an energy efficiency 

distribution for the no-new-standards 

case (which yields a shipment-weighted 

average efficiency) for each of the 

considered product classes for the year 

of anticipated compliance with an 

amended or new standard (2030). To 

project efficiencies for the no-newstandards case, DOE used historical 

shipment data and current consumer 

furnace fan model availability by 

efficiency level (see chapter 8 of the 

November 2022 Preliminary Analysis 

TSD). 

To develop standards-case efficiency 

trends, DOE used a ‘‘roll-up’’ scenario to 

establish the shipment-weighted 

efficiency for the year that standards are 

assumed to become effective (2030). In 

this scenario, the market shares of 

products in the no-new-standards case 

that do not meet the standard under 

consideration would ‘‘roll up’’ to meet 

the new standard level, and the market 

share of products above the standard 

would remain unchanged. 

2. National Energy Savings 

The NES analysis involves a 

comparison of national energy 

consumption of the considered products 

between each potential standards case 

(i.e., CSL) and the case with no new or 

amended energy conservation 

standards. DOE calculated the national 

energy consumption by multiplying the 

number of units (i.e., stock) of each 

product (by vintage or age) by the unit 

energy consumption (also by vintage). 

DOE calculated annual NES based on 

the difference in national energy 

consumption for the no-new-standards 

case and for each higher-efficiency 

standards case. DOE estimated energy 

consumption and savings based on site 

energy and converted the electricity 

consumption and savings to primary 

energy (i.e., the energy consumed by 

power plants to generate site electricity) 

using annual conversion factors derived 

from AEO 2023. For natural gas and 

LPG, primary energy consumption is the 

same as site energy consumption. 

Cumulative energy savings are the sum 

of the NES for each year over the 

timeframe of the analysis. 

Use of higher-efficiency products is 

sometimes associated with a direct 

rebound effect, which refers to an 

increase in utilization of the product 

due to the increase in efficiency and 

reduction in operating cost. A rebound 

effect reduces the energy savings 

attributable to a standard. Where 

appropriate, DOE accounts for the direct 

rebound effect when estimating the NES 

from potential standards. In the October 

2023 NOPD, DOE applied a rebound 

effect in the residential sector for those 

standards cases that require a BPM 

motor furnace fan for product classes 

that currently have an improved PSC 

motor standard. A rebound effect factor 

of 16 percent was determined by 

calculating the additional electricity use 

that is required from a doubling of the 

use of continuous fan circulation 

compared to the average use assumed in 

the energy use analysis.53 Although a 

lower value might be warranted, DOE 

preferred to be conservative and not risk 

understating the rebound effect. For 

commercial applications, DOE applied 

no rebound effect, a decision consistent 

with other recent energy conservation 

standards rulemakings.54 55 56

DOE did not receive comments on 

rebound in response to the October 2023 

NOPD. Consequently, DOE maintained 

the same approach for this final 

determination. 

In 2011, in response to the 

recommendations of a committee on 

‘‘Point-of-Use and Full-Fuel-Cycle 

Measurement Approaches to Energy 

Efficiency Standards’’ appointed by the 

National Academy of Sciences, DOE 

announced its intention to use FFC 

measures of energy use and greenhouse 

gas and other emissions in the NIAs and 

emissions analyses included in future 

energy conservation standards 

rulemakings. 76 FR 51281 (August 18, 

2011). After evaluating the approaches 


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57For more information on NEMS, refer to The 

National Energy Modeling System: An Overview 

May 2023, DOE/EIA (May 2023) (Available at: 

www.eia.gov/outlooks/archive/0581(2023).pdf) (last 

accessed June 11, 2024). 

58United States Office of Management and 

Budget, Circular A–4: Regulatory Analysis (Sept. 17, 

2003) Section E. (Available at: 

www.whitehouse.gov/omb/information-foragencies/circulars) (last accessed June 28, 2024). 

DOE used the prior version of Circular A–4 

(September 17, 2003) in accordance with the 

effective date of the November 9, 2023 version 

(Available at: www.whitehouse.gov/wp-content/ 

uploads/legacy_drupal_files/omb/circulars/A4/a4.pdf) (last accessed June 28, 2024). 

discussed in the August 18, 2011 notice, 

DOE published a statement of amended 

policy in which DOE explained its 

determination that EIA’s National 

Energy Modeling System (‘‘NEMS’’) is 

the most appropriate tool for its FFC 

analysis and its intention to use NEMS 

for that purpose. 77 FR 49701 (August 

17, 2012). NEMS is a public domain, 

multi-sector, partial equilibrium model 

of the U.S. energy sector 57 that EIA uses 

to prepare its Annual Energy Outlook. 

The FFC factors incorporate losses in 

production and delivery in the case of 

natural gas (including fugitive 

emissions) and additional energy used 

to produce and deliver the various fuels 

used by power plants. The approach 

used for deriving FFC measures of 

energy use and emissions is described 

in appendix 10B of the November 2022 

Preliminary Analysis TSD. 

3. Net Present Value Analysis

The inputs for determining the NPV

of the total costs and benefits 

experienced by consumers are: (1) total 

annual installed cost, (2) total annual 

operating costs (which include energy 

costs and repair and maintenance costs), 

and (3) a discount factor to calculate the 

present value of costs and savings. DOE 

calculates net savings each year as the 

difference between the no-newstandards case and each standards case 

in terms of total savings in operating 

costs versus total increases in installed 

costs. DOE calculates operating cost 

savings over the lifetime of each product 

shipped during the projection period. 

The operating cost savings are energy 

cost savings, which are calculated using 

the estimated energy savings in each 

year and the projected price of the 

appropriate form of energy. To estimate 

energy prices in future years, DOE 

multiplied the average regional energy 

prices by the projection of annual 

national-average residential energy price 

changes in the AEO 2023 Reference 

case, which has an end year of 2050. To 

estimate price trends after 2050, DOE 

used the average annual rate of change 

in prices from 2020 through 2050. 

In calculating the NPV, DOE 

multiplies the net savings in future 

years by a discount factor to determine 

their present value. For this final 

determination, DOE estimated the NPV 

of consumer benefits using both a 3- 

percent and a 7-percent real discount 

rate. DOE uses these discount rates in 

accordance with guidance provided by 

the Office of Management and Budget 

(‘‘OMB’’) to Federal agencies on the 

development of regulatory analysis.58

The discount rates for the determination 

of NPV are in contrast to the discount 

rates used in the LCC analysis, which 

are designed to reflect a consumer’s 

perspective. The 7-percent real value is 

an estimate of the average before-tax rate 

of return to private capital in the U.S. 

economy. The 3-percent real value 

represents the ‘‘social rate of time 

preference,’’ which is the rate at which 

society discounts future consumption 

flows to their present value. DOE did 

not receive comments regarding the NIA 

methodology in response to the October 

2023 NOPD. 

H. Other Factors Related to BackwardInclined Impellers

In this analysis, although DOE did not 

screen out backward-inclined impellers 

from further considerations in this 

analysis (for the reasons discussed in 

section IV.A.4.b of this document), DOE 

is aware of several points of uncertainty 

related to the impacts of a potential 

standard that would require the use of 

this technology. First, DOE understands 

that there may be uncertainty related to 

whether this technology can be 

implemented across all input capacities 

and cabinet sizes. Second, as discussed 

in the October 2023 NOPD, 

manufacturers raised concerns about the 

potential negative impacts on consumer 

features because of increased noise in 

certain sizes of furnaces (although DOE 

is not aware of data on this subject). 88 

FR 69826, 69836, 69861 (Oct. 6, 2023). 

Additionally, the incorporation of 

backward-inclined impellers could 

require system changes to the furnace 

system that expand beyond the scope of 

the furnace fan. Manufacturers noted 

that adoption of backward-inclined 

impellers could necessitate system 

considerations to ensure reliability of 

heat exchanger performance, acceptable 

sound performance, and ease of 

installation. Manufacturers also raised 

concerns that constraints of backwardinclined impeller designs could impede 

the flexibility of installation 

configurations, as discussed in the 

October 2023 NOPD. Id. For a fraction 

of the market, complete furnace 

redesign would be required to 

accommodate the backward-inclined 

impellers design option. 

Finally, as discussed in section 

IV.B.1.c of this document, DOE

understands that there is uncertainty

associated with the estimated 10-

percent reduction in FER for fans using

a backward-inclined impeller as

compared to models that include

forward-inclined impellers. Uncertainty

related to the results of the energy use

analysis contributes uncertainty to all

the conclusions of DOE’s subsequent

analyses, including the LCC and PBP

analyses and the NIA.

In commenting on the October 2023 

NOPD, Ravnitzky supported DOE’s 

consideration of unintended 

consequences such as limiting small 

cabinet-size options and increased noise 

associated with specific design options, 

including backward-inclined impellers, 

so as to ensure that standards did not 

limit the performance of consumer 

furnace fans or place excessive burden 

on manufacturers and consumers. 

(Ravnitzky, No. 29 at p. 1) Lennox 

commented that it agrees with DOE’s 

conclusions that the limited number of 

backward-inclined impellers on the 

market, concerns about feasibility of 

implementing the technology across all 

input capacities and cabinet sizes, 

unavailability of certain furnace product 

sizes, and uncertainty of estimates of 

energy reduction associated with 

backward-inclined impellers suggest 

that amended standards may not be 

appropriate. (Lennox, No. 30 at pp. 2– 

3) 

In response, as discussed in section 

V.C of this document, DOE has

considered these uncertainties in its

decision of whether to amend the

energy conservation standards for

consumer furnace fans.

V. Analytical Results and Conclusions

The following section addresses the

results from DOE’s analyses with 

respect to the considered energy 

conservation standards for consumer 

furnace fans. It addresses the CSLs 

examined by DOE (see section IV.B.1 of 

this document) and the projected 

impacts of each of these levels if 

adopted as energy conservation 

standards for the subject consumer 

furnace fans. To estimate the impacts of 

amended standards for consumer 

furnace fans, DOE compared the nonew-standards case to scenarios in 

which specific CSLs are implemented. 

CSL 1 analyzes a scenario in which 

standards corresponding to EL 1 are 

adopted for the NWO–NC, MH–NWG– 

NC, MH–NWG–C, and MH–NWO 

product classes and standards are not 

amended for the NWG–NC, NWG–C, 


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WG–NC, NWEF/NWMB, and MH–EF/ 

MB product classes. CSL 2 analyzes a 

scenario in which standards are adopted 

corresponding to EL 1 for the NWG–NC, 

NWG–C, WG–NC, NWEF/NWMB, and 

MH–EF/MB product classes and as EL 2 

for the NWO–NC, MH–NWG–NC, MH– 

NWG–C, and MH–NWO product 

classes. In other words, CSL 1 analyzes 

a scenario with standards set at a level 

at which BPM motors are effectively 

required for all product classes, and CSL 

2 analyzes a scenario with standards set 

at a level at which BPM motors with 

backward-inclined impellers are 

effectively required for all product 

classes, corresponding to the max-tech 

efficiency level for all product classes. 

Additional details regarding DOE’s 

analyses are contained in the November 

2022 Preliminary Analysis TSD 

supporting this document. 

A. Economic Impacts on Individual 

Consumers 

DOE analyzed the economic impacts 

on furnace fan consumers by looking at 

the effects that potential amended 

energy conservation standards at each 

EL would have on the LCC and PBP. 

This approach allowed DOE to assess 

the potential standards’ costeffectiveness (i.e., the savings in 

operating costs throughout the 

estimated average life of consumer 

furnace fans compared to any increase 

in the price of, or in the initial charges 

for, or maintenance expenses of, the 

consumer furnace fans that are likely to 

result from the imposition of a 

standard). These analyses are discussed 

in the following sections. 

In general, higher-efficiency products 

typically affect consumers in two ways: 

(1) purchase price increases, and (2) 

annual operating costs decrease. Inputs 

used for calculating the LCC and PBP 

include total installed costs (i.e., 

product price plus installation costs), 

and operating costs (i.e., annual energy 

use, energy prices, energy price trends, 

repair costs, and maintenance costs). 

The LCC calculation also uses product 

lifetime and a discount rate. Section 

IV.E of this final determination and 

chapter 8 of the November 2022 

Preliminary Analysis TSD provide 

detailed information on the LCC and 

PBP analyses. 

Table V.1 through Table V.18 show 

the average LCC and PBP results for the 

ELs considered for each product class of 

consumer furnace fans. In the first of 

each pair of tables, the simple payback 

is measured relative to the baseline 

level. In the second table, the impacts 

are measured relative to the efficiency 

distribution in the no-new-standards 

case in the compliance year. The LCC 

and PBP results for consumer furnace 

fans include both residential and 

commercial users. Because some 

consumers purchase products with 

higher efficiency in the no-newstandards case, the average savings are 

less than the difference between the 

average LCC of the baseline product and 

the average LCC at each EL. The savings 

refer only to consumers who are affected 

by a standard at a given EL. Those who 

already purchase products with 

efficiency at or above a given EL are not 

affected. Consumers for whom the LCC 

increases at a given EL experience a net 

cost. 

TABLE V.1—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR NON-WEATHERIZED, NON-CONDENSING GAS

FURNACE FANS (NWG–NC) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 403 67 1,160 1,563 .............................. 20.9 

1 ........................... 495 60 1,069 1,565 12.9 20.9 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.2—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR NON-WEATHERIZED, 

NON-CONDENSING GAS FURNACE FANS (NWG–NC) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 68.4 (1) 

* The savings represent the average LCC for affected consumers. Parentheses indicate negative (¥) values. 

TABLE V.3—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR NON-WEATHERIZED, CONDENSING GAS

FURNACE FANS (NWG–C) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 420 61 1,106 1,525 .............................. 21.9 

1 ........................... 501 55 1,024 1,526 13.3 21.9 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 


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TABLE V.4—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR NON-WEATHERIZED, 

CONDENSING GAS FURNACE FANS (NWG–C) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 70.7 (0) 

* The savings represent the average LCC for affected consumers. Parentheses indicate negative (¥) values. 

TABLE V.5—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR MOBILE HOME NON-WEATHERIZED, NONCONDENSING GAS FURNACE FANS (MH–NWG–NC) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 212 54 884 1,096 .............................. 20.7 

1 ........................... 258 35 589 847 2.3 20.7 

2 ........................... 332 30 530 863 5.0 20.7 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.6—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR MOBILE HOME NONWEATHERIZED, NON-CONDENSING GAS FURNACE FANS (MH–NWG–NC) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 3.8 231 

2 ....................................................................................................................................................... 76.1 9 

* The savings represent the average LCC for affected consumers. 

TABLE V.7—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR MOBILE HOME NON-WEATHERIZED, 

CONDENSING GAS FURNACE FANS (MH–NWG–C) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 238 62 1,039 1,277 .............................. 21.5 

1 ........................... 300 37 666 966 2.5 21.5 

2 ........................... 364 34 631 995 4.6 21.5 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.8—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR MOBILE HOME NONWEATHERIZED, CONDENSING GAS FURNACE FANS (MH–NWG–C) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 1.5 292 

2 ....................................................................................................................................................... 82.1 (7) 

* The savings represent the average LCC for affected consumers. Parentheses indicate negative (¥) values. 

TABLE V.9—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR MOBILE HOME ELECTRIC FURNACE/MODULAR

BLOWER FANS (MH–EF/MB) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 255 36 629 885 .............................. 20.7 


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TABLE V.9—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR MOBILE HOME ELECTRIC FURNACE/MODULAR

BLOWER FANS (MH–EF/MB)—Continued 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

1 ........................... 315 32 578 893 14.7 20.7 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.10—LCC AVERAGE SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR MOBILE HOME

ELECTRIC FURNACE/MODULAR BLOWER FANS (MH–EF/MB) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 71.5 (8) 

* The savings represent the average LCC for affected consumers. Parentheses indicate negative (¥) values. 

TABLE V.11—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR NON-WEATHERIZED, NON-CONDENSING OIL

FURNACE FANS (NWO–NC) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 568 151 2,601 3,169 .............................. 22.2 

1 ........................... 654 110 1,940 2,594 2.1 22.2 

2 ........................... 765 103 1,840 2,605 4.1 22.2 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.12—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR NON-WEATHERIZED, 

NON-CONDENSING OIL FURNACE FANS (NWO–NC) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 4.4 618 

2 ....................................................................................................................................................... 52.2 274 

* The savings represent the average LCC for affected consumers. 

TABLE V.13—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR WEATHERIZED, NON-CONDENSING GAS

FURNACE FANS (WG–NC) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 385 81 1,322 1,706 .............................. 20.6 

1 ........................... 478 71 1,188 1,666 9.1 20.6 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 


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TABLE V.14—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR WEATHERIZED, NONCONDENSING GAS FURNACE FANS (WG–NC) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 54.9 40 

* The savings represent the average LCC for affected consumers. 

TABLE V.15—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR ELECTRIC FURNACE/MODULAR BLOWERS

(NWEF/NWMB) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 305 43 726 1,031 .............................. 20.7 

1 ........................... 371 39 673 1,045 16.0 20.7 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.16—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR ELECTRIC FURNACE/ 

MODULAR BLOWERS (NWEF/NWMB) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 77.5 (14) 

* The savings represent the average LCC for affected consumers. Parentheses indicate negative (¥) values. 

TABLE V.17—AVERAGE LCC AND PBP RESULTS BY EFFICIENCY LEVEL FOR MOBILE HOME NON-WEATHERIZED, NONCONDENSING OIL FURNACE FANS (MH–NWO–NC) 

Efficiency level 

Average costs 

(2022$) Simple 

payback period 

(years) 

Average 

lifetime 

(years) Installed cost First year’s 

operating cost 

Lifetime 

operating cost LCC 

0 ........................... 491 88 1,539 2,030 .............................. 22.5 

1 ........................... 541 66 1,187 1,728 2.3 22.5 

2 ........................... 624 61 1,105 1,729 5.0 22.5 

Note: The results for each EL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative 

to the baseline product. 

TABLE V.18—AVERAGE LCC SAVINGS RELATIVE TO THE BASE CASE EFFICIENCY DISTRIBUTION FOR MOBILE HOME NONWEATHERIZED, NON-CONDENSING OIL FURNACE FAN (MH–NWO–NC) 

Efficiency level 

Percentage of 

consumers with 

net cost 

Average savings— 

impacted consumers 

(2022$) * 

1 ....................................................................................................................................................... 21.0 308 

2 ....................................................................................................................................................... 54.7 276 

* The savings represent the average LCC for affected consumers. 

B. National Impact Analysis 

This section presents DOE’s estimates 

of the NES and the NPV of consumer 

benefits that would result from each of 

the CSLs considered as potential 

amended standards. 

1. National Energy Savings 

To estimate the energy savings 

attributable to potential amended energy 

conservation standards for consumer 

furnace fans, DOE compared their 

energy consumption under the no-newstandards case to their anticipated 

energy consumption under each CSL. 

The savings are measured over the 

entire lifetime of products purchased 

during the 30-year period that begins in 

the year of anticipated compliance with 

amended standards (2030–2059). 

Table V.19 presents DOE’s projections 

of the national energy savings for each 

CSL considered for the analysis. The 

savings were calculated using the 


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59U.S. Office of Management and Budget, 

Circular A–4: Regulatory Analysis (Available at: 

www.whitehouse.gov/omb/information-foragencies/circulars) (last accessed Sept. 9, 2021). 

DOE used the prior version of Circular A–4 (Sept. 

17, 2003) in accordance with the effective date of 

the November 9, 2023 version (Available at: 

www.whitehouse.gov/wp-content/uploads/legacy_

drupal_files/omb/circulars/A4/a-4.pdf) (last 

accessed June 11, 2024). 

60EPCA requires DOE to review its standards at 

least once every six years, and requires, for certain 

products, a three-year period after any new 

standard is promulgated before compliance is 

required, except that in no case may any new 

standards be required within six years of the 

compliance date of the previous standards. (42 

U.S.C. 6295(m)) If DOE makes a determination that 

amended standards are not needed, it must conduct 

a subsequent review within three years following 

such a determination. As DOE is evaluating the 

need to amend the standards, the sensitivity 

analysis is based on the review timeframe 

associated with amended standards. While adding 

a six-year review to the three-year compliance 

period adds up to nine years, DOE notes that it may 

undertake reviews at any time within the six-year 

period and that the three-year compliance date may 

yield to the six-year backstop. A nine-year analysis 

period may not be appropriate given the variability 

that occurs in the timing of standards reviews and 

the fact that for some products, the compliance 

period is five years rather than three years. 

approach described in section IV.G.2 of 

this document. 

TABLE V.19—CUMULATIVE NATIONAL

ENERGY SAVINGS FOR CONSUMER

FURNACE FANS; 30 YEARS OF SHIPMENTS

[2030–2059] 

Candidate standards 

level 

1 2 

(quads) 

Primary energy ......... 0.013 1.355 

FFC energy ............... 0.013 1.374 

OMB Circular A–4 59 requires 

agencies to present analytical results, 

including separate schedules of the 

monetized benefits and costs that show 

the type and timing of benefits and 

costs. Circular A–4 also directs agencies 

to consider the variability of key 

elements underlying the estimates of 

benefits and costs. For this final 

determination, DOE undertook a 

sensitivity analysis using nine years, 

rather than 30 years, of product 

shipments. The choice of a nine-year 

period is a proxy for the timeline in 

EPCA for the review of certain energy 

conservation standards and potential 

revision of and compliance with such 

revised standards.60 The review 

timeframe established in EPCA is 

generally not synchronized with the 

product lifetime, product manufacturing 

cycles, or other factors specific to 

consumer furnace fans. Thus, such 

results are presented for informational 

purposes only and are not indicative of 

any change in DOE’s analytical 

methodology. The NES sensitivity 

analysis results based on a nine-year 

analytical period are presented in Table 

V.20. The impacts are counted over the 

lifetime of consumer furnace fans 

purchased during the period 2030–2038. 

TABLE V.20—CUMULATIVE NATIONAL

ENERGY SAVINGS FOR CONSUMER

FURNACE FANS; 9 YEARS OF SHIPMENTS

[2030–2038] 

Candidate standards 

level 

1 2 

(quads) 

Primary energy ......... 0.005 0.376 

FFC energy ............... 0.005 0.381 

2. Net Present Value of Consumer Costs 

and Benefits 

DOE estimated the cumulative NPV of 

the total costs and savings for 

consumers that would result from the 

CSLs considered for consumer furnace 

fans. In accordance with OMB Circular 

A–4, DOE calculated NPV using both a 

7-percent and a 3-percent real discount 

rate. Table V.21 shows the consumer 

NPV results with impacts counted over 

the lifetime of products purchased 

during the period 2030–2059. 

TABLE V.21—CUMULATIVE NET

PRESENT VALUE OF CONSUMER

BENEFITS FOR CONSUMER FURNACE

FANS; 30 YEARS OF SHIPMENTS

[2030–2059] 

Discount rate 

Candidate standards 

level 

1 2 

(billion 2022$) 

3 percent ................... 0.112 1.821 

7 percent ................... 0.042 (0.150) 

Note: Parentheses indicate negative (¥) 

values. 

The NPV results based on the 

aforementioned nine-year analytical 

period are presented in Table V.22. The 

impacts are counted over the lifetime of 

consumer furnace fan products 

purchased during the period 2030–2038. 

As mentioned previously, such results 

are presented for informational 

purposes only and are not indicative of 

any change in DOE’s analytical 

methodology or decision criteria. 

TABLE V.22—CUMULATIVE NET

PRESENT VALUE OF CONSUMER

BENEFITS FOR CONSUMER FURNACE

FANS; 9 YEARS OF SHIPMENTS

[2030–2038] 

Discount rate 

Candidate standards 

level 

1 2 

(billion 2022$) 

3 percent ................... 0.056 0.716 

7 percent ................... 0.026 (0.071) 

Note: Parentheses indicate negative (¥) 

values. 

C. Final Determination 

As discussed previously, in order to 

make a final determination that the 

energy conservation standards for 

consumer furnace fans do not need to be 

amended, EPCA requires that DOE 

analyze whether amended standards 

would result in significant conservation 

of energy, be technologically feasible, 

and be cost-effective. (42 U.S.C. 

6295(m)(1)(A) and 42 U.S.C. 6295(n)(2)) 

DOE has determined that technology 

options are available that can improve 

the efficacy of consumer furnace fans. 

These technology options are being used 

in commercially-available consumer 

furnace fans and, therefore, are 

technologically feasible. (See section 

IV.A.4 of this document for further 

information.) Hence, DOE has 

determined that amended energy 

conservation standards for consumer 

furnace fans would be technologically 

feasible. 

Under 42 U.S.C. 6295(o)(2)(B)(i)(II), 

an evaluation of cost-effectiveness 

requires DOE to consider savings in 

operating costs throughout the 

estimated average life of the covered 

product in the type (or class) compared 

to any increase in the price, initial 

charges, or maintenance expenses for 

the covered product that are likely to 

result from the standard. (42 U.S.C. 

6295(n)(2)(C) and 42 U.S.C. 

6295(o)(2)(B)(i)(II)) DOE conducted an 

LCC analysis to estimate the net costs/ 

benefits to users from increased 

efficiency in the considered consumer 

furnace fan product classes, the results 

of which are shown in Table V.1 

through Table V.18. DOE then 

aggregated the results from the LCC 

analysis to estimate the NPV of the total 

costs and benefits experienced by the 

Nation. (See results in Table V.21.) As 

noted, the inputs for determining the 

NPV are: (1) total annual installed cost, 

(2) total annual operating costs (energy 

costs and repair and maintenance costs), 


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and (3) a discount factor to calculate the 

present value of costs and savings. 

EPCA also requires that DOE consider 

whether amended energy conservation 

standards for the subject consumer 

furnace fans would result in significant 

conservation of energy. (42 U.S.C. 

6295(m)(1)(A) and 42 U.S.C. 

6295(n)(2)(A)) To estimate the energy 

savings attributable to potential 

amended standards for consumer 

furnace fans, DOE compared their 

energy consumption under the no-newstandards case to their anticipated 

energy consumption under each 

potential standard level. The savings are 

measured over the entire lifetime of 

products purchased in the 30-year 

period that begins in the year of 

anticipated compliance with amended 

standards (2030–2059). The results of 

this analysis are shown in Table V.19. 

Because an analysis of potential costeffectiveness and energy savings first 

requires an evaluation of the relevant 

technology, DOE typically first 

discusses the technological feasibility of 

amended standards. DOE then typically 

addresses the cost-effectiveness and 

energy savings associated with potential 

amended standards. For this final 

determination, DOE reviewed the 

impacts of amended standards 

corresponding to the implementation of 

the two design options analyzed in this 

proceeding separately (i.e., BPM motor 

with forward-curved impellers and BPM 

motor with backward-inclined 

impellers, as discussed in section IV.B.1 

of this document). For each design 

option, DOE considered the 

technological feasibility, costeffectiveness, and significance of energy 

savings. 

1. BPM Motor With Backward-Inclined 

Impellers 

BPM motors with backward-inclined 

impellers are included in the current 

analysis as the max-tech design option 

for all furnace fan product classes. In 

other words, they are analyzed as EL 1 

for the NWG–NC, NWG–C, WG–NC, 

NWEF/NWMB, and MH–EF/MB 

product classes and as EL 2 for the 

NWO–NC, MH–NWG–NC, MH–NWG– 

C, and MH–NWO product classes. As 

discussed in section IV.A.4 of this 

document, DOE is aware of BPM motors 

with backward-inclined impellers being 

used in commercially-available 

consumer furnace fans, and, therefore, 

this technology is technologically 

feasible. 

As seen in Table V.19, DOE estimates 

that amended standards for consumer 

furnace fans would result in FFC energy 

savings of 1.374 quads at max-tech 

levels over a 30-year analysis period 

(2030–2059). However, as seen in Table 

V.1 through Table V.18 and Table V.21, 

these efficiency levels result in net LCC 

costs for the majority of consumers and 

negative net present value at a 7-percent 

discount rate. Therefore, DOE finds that 

the max-tech ELs (which would require 

the use of backward-inclined impellers) 

are not cost-effective. 

Additionally, as discussed in section 

IV.H of this document, there is a 

significant amount of uncertainty 

associated with the inputs and results of 

this analysis. At this time, DOE has 

concerns about the feasibility of 

implementing backward-inclined 

impellers across all input capacities and 

cabinet sizes and the unavailability of 

certain furnace product sizes, concerns 

about potential negative impacts on 

consumer features, and uncertainty 

related to its assumptions about the 

energy reduction associated with 

backward-inclined impellers as opposed 

to forward-curved impellers. 

2. BPM Motors With Forward-Inclined 

Impellers 

BPM motors with forward-curved 

impellers (which is the type of impeller 

used in the vast majority of consumer 

furnace fans on the market today) are 

included in the current analysis as the 

design option analyzed in CSL 1. For 

these product classes, the current 

standards can be met using less-efficient 

PSC motors, so replacing the motor with 

a BPM motor can improve the efficiency 

of the furnace fan. BPM motors are 

widely used in commercially-available 

consumer furnace fans and, therefore, 

are technologically feasible. 

As seen in Table V.21, CSL 1 results 

in positive NPV at the 3-percent and 7- 

percent discount rates. And, as seen in 

Table V.19, DOE estimates that 

amended standards for consumer 

furnace fans would result in energy 

savings of 0.013 quads at CSL 1 over a 

30-year analysis period (2030–2059). 

However, as discussed in section IV.F of 

this document, shipments in the 

affected product classes have declined 

over the past 20 years and could decline 

faster than current shipment 

projections, which may lead to 

reductions in energy savings from 

amended standards. Given the small 

role of NWO–NC, MH–NWG–NC, MH– 

NWG–C, and MH–NWO in the overall 

furnace market and the low sales 

relative to the consumer boiler and 

consumer water heater markets, 

manufacturers may deprioritize furnace 

fan updates for these product classes. 

Depending on how companies prioritize 

resources, there could be reduced 

availability of NWO–NC, MH–NWG– 

NC, and MH–NWO products in the 

marketplace after 2030. Additionally, 

there is a potential risk that some 

manufacturers would choose to exit 

these markets rather than redesign 

affected products, given the low 

shipment volumes, lack of anticipated 

growth, limited potential for cost 

recovery, and need to prioritize 

technical resources. In particular, the 

loss of a few manufacturers in the 

NWO–NC market could lead to changes 

in competition and shifts toward the 

market becoming highly concentrated. 

Based on the declining shipments of the 

affected product classes and uncertainty 

over whether manufacturers will choose 

to remain in a shrinking market, DOE 

has determined that it is unable to 

conclude that amended standards for 

consumer furnace fans would be 

economically justified. 

3. Summary 

As discussed previously, a 

determination that amended standards 

are not needed must be based on 

consideration of whether amended 

standards will result in significant 

conservation of energy, are 

technologically feasible, and are costeffective. (42 U.S.C. 6295(m)(1)(A) and 

42 U.S.C. 6295(n)(2)) Additionally, DOE 

can only propose an amended standards 

if it is, among other things, 

economically justified. (42 U.S.C. 

6295(m)(1)(B); 42 U.S.C. 6295(o)(2)(A)) 

However, for the reasons discussed in 

the preceding sections, DOE is unable to 

conclude that amended standards for 

furnace fans at any of the CSLs analyzed 

would result in significant conservation 

of energy, be technologically feasible, 

and also be cost-effective. Therefore, 

DOE has determined that energy 

conservation standards for consumer 

furnace fans do not need to be amended 

at this time. 

VI. Procedural Issues and Regulatory 

Review 

A. Review Under Executive Orders 

12866, 13563, and 14094 

Executive Order (‘‘E.O.’’) 12866, 

‘‘Regulatory Planning and Review,’’ 58 

FR 51735 (Oct. 4, 1993), as 

supplemented and reaffirmed by E.O. 

13563, ‘‘Improving Regulation and 

Regulatory Review,’’ 76 FR 3821 (Jan. 

21, 2011) and amended by E.O. 14094, 

‘‘Modernizing Regulatory Review,’’ 88 

FR 21879 (April 11, 2023), requires 

agencies, to the extent permitted by law, 

to: (1) propose or adopt a regulation 

only upon a reasoned determination 

that its benefits justify its costs 

(recognizing that some benefits and 

costs are difficult to quantify); (2) tailor 

regulations to impose the least burden 


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on society, consistent with obtaining 

regulatory objectives, taking into 

account, among other things, and to the 

extent practicable, the costs of 

cumulative regulations; (3) select, in 

choosing among alternative regulatory 

approaches, those approaches that 

maximize net benefits (including 

potential economic, environmental, 

public health and safety, and other 

advantages; distributive impacts; and 

equity); (4) to the extent feasible, specify 

performance objectives, rather than 

specifying the behavior or manner of 

compliance that regulated entities must 

adopt; and (5) identify and assess 

available alternatives to direct 

regulation, including providing 

economic incentives to encourage the 

desired behavior, such as user fees or 

marketable permits, or providing 

information upon which choices can be 

made by the public. DOE emphasizes as 

well that E.O. 13563 requires agencies to 

use the best available techniques to 

quantify anticipated present and future 

benefits and costs as accurately as 

possible. In its guidance, the Office of 

Information and Regulatory Affairs 

(‘‘OIRA’’) in the OMB has emphasized 

that such techniques may include 

identifying changing future compliance 

costs that might result from 

technological innovation or anticipated 

behavioral changes. For the reasons 

stated in this preamble, this final 

regulatory action is consistent with 

these principles. 

Section 6(a) of E.O. 12866 also 

requires agencies to submit ‘‘significant 

regulatory actions’’ to OIRA for review. 

OIRA has determined that this final 

regulatory action does not constitute a 

‘‘significant regulatory action’’ under 

section 3(f) of E.O. 12866, as amended 

by E.O. 14094. Accordingly, this action 

was not submitted to OIRA for review 

under E.O. 12866. 

B. Review Under the Regulatory 

Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility 

analysis (‘‘IRFA’’) and a final regulatory 

flexibility analysis (‘‘FRFA’’) for any 

rule that by law must be proposed for 

public comment, unless the agency 

certifies that the rule, if promulgated, 

will not have a significant economic 

impact on a substantial number of small 

entities. As required by E.O. 13272, 

‘‘Proper Consideration of Small Entities 

in Agency Rulemaking,’’ 67 FR 53461 

(August 16, 2002), DOE published 

procedures and policies in the Federal 

Register on February 19, 2003, to ensure 

that the potential impacts of its rules on 

small entities are properly considered 

during the rulemaking process. 68 FR 

7990. DOE has made its procedures and 

policies available on the Office of the 

General Counsel’s website 

(www.energy.gov/gc/office-generalcounsel). 

DOE reviewed this final 

determination under the provisions of 

the Regulatory Flexibility Act and the 

policies and procedures published on 

February 19, 2003. Because DOE is not 

amending standards for consumer 

furnace fans, the determination will not 

amend any energy conservation 

standards. On the basis of the foregoing, 

DOE certifies that the final 

determination will have no significant 

economic impact on a substantial 

number of small entities. Accordingly, 

DOE has not prepared an FRFA for this 

final determination. DOE has 

transmitted this certification and 

supporting statement of factual basis to 

the Chief Counsel for Advocacy of the 

Small Business Administration for 

review under 5 U.S.C. 605(b). 

C. Review Under the Paperwork 

Reduction Act of 1995 

This final determination, which 

concludes that no amended energy 

conservation standards for consumer 

furnace fans are needed, imposes no 

new informational or recordkeeping 

requirements. Accordingly, OMB 

clearance is not required under the 

Paperwork Reduction Act. (44 U.S.C. 

3501 et seq.) 

D. Review Under the National 

Environmental Policy Act of 1969 

DOE has analyzed this final action in 

accordance with the National 

Environmental Policy Act of 1969 

(‘‘NEPA’’) and DOE’s NEPA 

implementing regulations (10 CFR part 

1021). DOE’s regulations include a 

categorical exclusion for actions which 

are interpretations or rulings with 

respect to existing regulations. 10 CFR 

part 1021, subpart D, appendix A4. DOE 

has determined that this rule qualifies 

for categorical exclusion A4 because it 

is an interpretation or ruling in regard 

to an existing regulation and otherwise 

meets the requirements for application 

of a categorical exclusion. See 10 CFR 

1021.410. Accordingly, neither an 

environmental assessment nor an 

environmental impact statement is 

required. 

E. Review Under Executive Order 13132 

E.O. 13132, ‘‘Federalism,’’ 64 FR 

43255 (August 10, 1999), imposes 

certain requirements on Federal 

agencies formulating and implementing 

policies or regulations that preempt 

State law or that have federalism 

implications. The Executive order 

requires agencies to examine the 

constitutional and statutory authority 

supporting any action that would limit 

the policymaking discretion of the 

States and to carefully assess the 

necessity for such actions. The 

Executive order also requires agencies to 

have an accountable process to ensure 

meaningful and timely input by State 

and local officials in the development of 

regulatory policies that have federalism 

implications. On March 14, 2000, DOE 

published a statement of policy 

describing the intergovernmental 

consultation process it will follow in the 

development of such regulations. 65 FR 

13735. DOE has examined this final 

determination and has determined that 

it would not have a substantial direct 

effect on the States, on the relationship 

between the national government and 

the States, or on the distribution of 

power and responsibilities among the 

various levels of government. EPCA 

governs and prescribes Federal 

preemption of State regulations as to 

energy conservation for the products 

that are the subject of this final 

determination. States can petition DOE 

for exemption from such preemption to 

the extent, and based on criteria, set 

forth in EPCA. (42 U.S.C. 6297) 

Therefore, no further action is required 

by E.O. 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of E.O. 

12988, ‘‘Civil Justice Reform,’’ 61 FR 

4729 (Feb. 7, 1996), imposes on Federal 

agencies the general duty to adhere to 

the following requirements: (1) 

eliminate drafting errors and ambiguity; 

(2) write regulations to minimize 

litigation; (3) provide a clear legal 

standard for affected conduct rather 

than a general standard, and (4) promote 

simplification and burden reduction. 

Regarding the review required by 

section 3(a), section 3(b) of E.O. 12988 

specifically requires that Executive 

agencies make every reasonable effort to 

ensure that the regulation: (1) clearly 

specifies the preemptive effect, if any; 

(2) clearly specifies any effect on 

existing Federal law or regulation; (3) 

provides a clear legal standard for 

affected conduct while promoting 

simplification and burden reduction; (4) 

specifies the retroactive effect, if any; (5) 

adequately defines key terms, and (6) 

addresses other important issues 

affecting clarity and general 

draftsmanship under any guidelines 

issued by the Attorney General. Section 

3(c) of E.O. 12988 requires Executive 

agencies to review regulations in light of 


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applicable standards in section 3(a) and 

section 3(b) to determine whether they 

are met or it is unreasonable to meet one 

or more of them. DOE has completed the 

required review and determined that, to 

the extent permitted by law, this final 

determination meets the relevant 

standards of E.O. 12988. 

G. Review Under the Unfunded 

Mandates Reform Act of 1995 

Title II of the Unfunded Mandates 

Reform Act of 1995 (‘‘UMRA’’) requires 

each Federal agency to assess the effects 

of Federal regulatory actions on State, 

local, and Tribal governments and the 

private sector. Public Law 104–4, sec. 

201 (codified at 2 U.S.C. 1531). For a 

regulatory action likely to result in a 

rule that may cause the expenditure by 

State, local, and Tribal governments, in 

the aggregate, or by the private sector of 

$100 million or more in any one year 

(adjusted annually for inflation), section 

202 of UMRA requires a Federal agency 

to publish a written statement that 

estimates the resulting costs, benefits, 

and other effects on the national 

economy. (2 U.S.C. 1532(a), (b)) UMRA 

also requires a Federal agency to 

develop an effective process to permit 

timely input by elected officers of State, 

local, and Tribal governments on a 

proposed ‘‘significant intergovernmental 

mandate,’’ and requires an agency plan 

for giving notice and opportunity for 

timely input to potentially affected 

small governments before establishing 

any requirements that might 

significantly or uniquely affect them. On 

March 18, 1997, DOE published a 

statement of policy on its process for 

intergovernmental consultation under 

UMRA. 62 FR 12820. DOE’s policy 

statement is also available at 

www.energy.gov/sites/prod/files/gcprod/ 

documents/umra_97.pdf. 

DOE examined this final 

determination according to UMRA and 

its statement of policy and determined 

that the final determination does not 

contain a Federal intergovernmental 

mandate, nor is it expected to require 

expenditures of $100 million or more in 

any one year by State, local, and Tribal 

governments, in the aggregate, or by the 

private sector. As a result, the analytical 

requirements of UMRA do not apply. 

H. Review Under the Treasury and 

General Government Appropriations 

Act, 1999 

Section 654 of the Treasury and 

General Government Appropriations 

Act, 1999 (Pub. L. 105–277) requires 

Federal agencies to issue a Family 

Policymaking Assessment for any 

proposed rule or policy that may affect 

family well-being. When developing a 

Family Policymaking Assessment, 

agencies must assess whether: (1) the 

action strengthens or erodes the stability 

or safety of the family and, particularly, 

the marital commitment; (2) the action 

strengthens or erodes the authority and 

rights of parents in the education, 

nurture, and supervision of their 

children; (3) the action helps the family 

perform its functions, or substitutes 

governmental activity for the function; 

(4) the action increases or decreases 

disposable income or poverty of families 

and children; (5) the proposed benefits 

of the action justify the financial impact 

on the family; (6) the action may be 

carried out by State or local government 

or by the family, and whether (7) the 

action establishes an implicit or explicit 

policy concerning the relationship 

between the behavior and personal 

responsibility of youth, and the norms 

of society. In evaluating the above 

factors, DOE has concluded that it is not 

necessary to prepare a Family 

Policymaking Assessment as none of the 

above factors are implicated. Further, 

this final determination would not have 

any financial impact on families nor any 

impact on the autonomy or integrity of 

the family as an institution. 

I. Review Under Executive Order 12630 

Pursuant to E.O. 12630, 

‘‘Governmental Actions and Interference 

with Constitutionally Protected Property 

Rights,’’ 53 FR 8859 (March 18, 1988), 

DOE has determined that this final 

determination would not result in any 

takings that might require compensation 

under the Fifth Amendment to the U.S. 

Constitution. 

J. Review Under the Treasury and 

General Government Appropriations 

Act, 2001 

Section 515 of the Treasury and 

General Government Appropriations 

Act, 2001 (44 U.S.C. 3516 note) provides 

for Federal agencies to review most 

disseminations of information to the 

public under information quality 

guidelines established by each agency 

pursuant to general guidelines issued by 

OMB. OMB’s guidelines were published 

at 67 FR 8452 (Feb. 22, 2002), and 

DOE’s guidelines were published at 67 

FR 62446 (Oct. 7, 2002). Pursuant to 

OMB Memorandum M–19–15, 

‘‘Improving Implementation of the 

Information Quality Act’’ (April 24, 

2019), DOE published updated 

guidelines, which are available at 

www.energy.gov/sites/prod/files/2019/ 

12/f70/DOE%20Final%

20Updated%20IQA%20Guidelines%

20Dec%202019.pdf. DOE has reviewed 

this final determination under the OMB 

and DOE guidelines and has concluded 

that it is consistent with applicable 

policies in those guidelines. 

K. Review Under Executive Order 13211 

E.O. 13211, ‘‘Actions Concerning 

Regulations That Significantly Affect 

Energy Supply, Distribution, or Use,’’ 66 

FR 28355 (May 22, 2001), requires 

Federal agencies to prepare and submit 

to OIRA at OMB a Statement of Energy 

Effects for any proposed significant 

energy action. A ‘‘significant energy 

action’’ is defined as any action by an 

agency that promulgates or is expected 

to lead to promulgation of a final rule, 

and that: (1) is a significant regulatory 

action under Executive Order 12866, or 

any successor order, and is likely to 

have a significant adverse effect on the 

supply, distribution, or use of energy; or 

(2) is designated by the Administrator of 

OIRA as a significant energy action. For 

any significant energy action, the agency 

must give a detailed statement of any 

adverse effects on energy supply, 

distribution, or use should the proposal 

be implemented, and of reasonable 

alternatives to the action and their 

expected benefits on energy supply, 

distribution, and use. 

This final determination, which does 

not amend energy conservation 

standards for consumer furnace fans, is 

not a significant regulatory action under 

E.O. 12866. Moreover, it would not have 

a significant adverse effect on the 

supply, distribution, or use of energy, 

nor has it been designated as such by 

the Administrator at OIRA. Therefore, it 

is not a significant energy action, and 

accordingly, DOE has not prepared a 

Statement of Energy Effects. 

L. Review Under the Information 

Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in 

consultation with the Office of Science 

and Technology Policy (‘‘OSTP’’), 

issued its Final Information Quality 

Bulletin for Peer Review (‘‘the 

Bulletin’’). 70 FR 2664 (Jan. 14, 2005). 

The Bulletin establishes that certain 

scientific information shall be peer 

reviewed by qualified specialists before 

it is disseminated by the Federal 

Government, including influential 

scientific information related to agency 

regulatory actions. The purpose of the 

bulletin is to enhance the quality and 

credibility of the Government’s 

scientific information. Under the 

Bulletin, the energy conservation 

standards rulemaking analyses are 

‘‘influential scientific information,’’ 

which the Bulletin defines as ‘‘scientific 

information the agency reasonably can 

determine will have, or does have, a 

clear and substantial impact on 


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61 ‘‘Energy Conservation Standards Rulemaking 

Peer Review Report’’ (2007) (Available at: 

www.energy.gov/eere/buildings/downloads/energyconservation-standards-rulemaking-peer-reviewreport-0) (last accessed June 28, 2024). 

62The December 2021 NAS report is available at 

www.nationalacademies.org/our-work/review-ofmethods-for-setting-building-and-equipmentperformance-standards (Last accessed August 28, 

2024). 

important public policies or private 

sector decisions.’’ Id. at 70 FR 2667. 

In response to OMB’s Bulletin, DOE 

conducted formal peer reviews of the 

energy conservation standards 

development process and the analyses 

that are typically used and has prepared 

a peer review report pertaining to the 

energy conservation standards 

rulemaking analyses.61 Generation of 

this report involved a rigorous, formal, 

and documented evaluation using 

objective criteria and qualified and 

independent reviewers to make a 

judgment as to the technical/scientific/ 

business merit, the actual or anticipated 

results, and the productivity and 

management effectiveness of programs 

and/or projects. Because available data, 

models, and technological 

understanding have changed since 2007, 

DOE has engaged with the National 

Academy of Sciences (‘‘NAS’’) to review 

DOE’s analytical methodologies to 

ascertain whether modifications are 

needed to improve DOE’s analyses. DOE 

is in the process of evaluating the 

resulting December 2021 report.62

M. Congressional Notification 

As required by 5 U.S.C. 801, DOE will 

report to Congress on the promulgation 

of this final determination prior to its 

effective date. The Office of Information 

and Regulatory Affairs has determined 

that this rule does not meet the criteria 

set forth in 5 U.S.C. 804(2). 

VII. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of this final determination. 

Signing Authority 

This document of the Department of 

Energy was signed on October 10, 2024, 

by Jeffrey Marootian, Principal Deputy 

Assistant Secretary for Energy Efficiency 

and Renewable Energy, pursuant to 

delegated authority from the Secretary 

of Energy. That document with the 

original signature and date is 

maintained by DOE. For administrative 

purposes only, and in compliance with 

requirements of the Office of the Federal 

Register, the undersigned DOE Federal 

Register Liaison Officer has been 

authorized to sign and submit the 

document in electronic format for 

publication, as an official document of 

the Department of Energy. This 

administrative process in no way alters 

the legal effect of this document upon 

publication in the Federal Register. 

Signed in Washington, DC, on October 10, 

2024. 

Treena V. Garrett, 

Federal Register Liaison Officer, U.S. 

Department of Energy. 

[FR Doc. 2024–23907 Filed 10–17–24; 8:45 am] 

BILLING CODE 6450–01–P 


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