http://carljbushcompany.com/images/commercialwall-fan-6.jpg http://fileresource.sit epro.com/filemanage r/207/imagecollections/1939/8948FC2F6EC0-FE7A-A343- 2DE0EABA1FFD.jpg

http://media.netw orx.at/www.sche uch.ca/bilder/woo d_based_panel_industrie/Bild6.jpg http://old.greenheck. com/images/product s/vaneaxial/axials.jp g

Source: http://www.aikencolon.com/assets/images/Fantech

Source: http://img.directindustry.com/images_di/photo-g/crossflow-fan- 16672 - 2472755.jpg Source:http://carljbushcompany.com/images/commercial-wallfan-6.jpg Source: http://fileresource.sitepro.com/filemanager/207/imagecollections/1 939/8948FC2F-6EC0-FE7A-A343-2DE0EABA1FFD.jpg

Source: http://media.networx.at/www.scheuch.ca/bilder/wood_based_pa nel_industrie/Bild-6.jpg Source: http://old.greenheck.com/images/

Charles Llenza BUILDING TECHNOLOGIES PROGRAM

February 21, 2013 

# Energy Conservation Standards for Commercial & Industrial Fans and Blowers: Framework Public Meeting2 

# Welcome and Introduction

• Introductions
• Role of the Facilitator
• Ground Rules (Norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; state your 

### name for the record)

– Set cell phones to silent/vibrate 

## • Housekeeping Items
• Agenda Review
• Opening Remarks3 

# Morning Agenda
9:00 – 9:05 am Welcome 9:05 – 9:15 am Opening Remarks, Introductions, and Agenda Review 9:15 – 9:30 am Rulemaking Process Overview 9:30 – 10:30 am Authority, Definitions, and Regulatory Options 10:30 – 10:45 am Break 10:45 – 11:00 am Regulatory Regimes 11:00 – 11:15 am Test Procedure and Efficiency Metrics 11:15 – 12:00 pm Market &Technology Assessment, Screening

Analysis 12:00 – 1:00 pm Break for Lunch4 

# Afternoon Agenda
1:00 – 1:45 pm Engineering Analysis 1:45 – 2:15 pm Markups and Energy Use Determination 2:15 – 2:45 pm Life-Cycle Cost and Payback Period Analysis 2:45 – 3:00 pm Break 3:00 – 3:15 pm Shipments Analysis and National Impact Analysis 

### 3:15 – 3:30 pm Preliminary Manufacturer Impact Analysis 3:30 – 3:45 pm NOPR Analyses 

### 3:45 – 4:00 pm Next Steps and Closing Remarks5 

# Opening Remarks

Interested parties who contacted DOE to request an 

## opportunity to issue an opening statement should speak now.6 

### 5



### 3 2

Test Procedure & Efficiency Metrics Rulemaking Process Overview 

### Authority & Definitions 1 Introduction

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 

### 4 Regulatory Regimes7 

## Purpose of the Framework Document Public Meeting

• Present the analytical approaches to be used to 

### evaluate energy conservation standards for commercial and industrial fans and blowers

• Inform interested parties of and facilitate the 

### rulemaking process

• Provide a forum for public discussion of rulemaking issues



### • Encourage interested parties to submit data, information, and written comments 

# Introduction8 

# Introduction Request for Comment Item #- #: DOE solicits comment on a range of specific issues throughout the Framework Document.

• Throughout this presentation, these issues will be highlighted for discussion in comment boxes such as this.

• Item numbers correspond to those in the Framework Document.

• DOE welcomes comments concerning these specific issues and any other issues related to this rulemaking.9 

## Instructions for Submitting Comments

• In all correspondence, please refer to this Commercial and Industrial Fans and Blowers Rulemaking by:

– Docket # EERE- 2013 - BT -STD-0006, and/or RIN 1904-AC55
• Electronic: CIFB2013STD0006@EE.Doe.Gov or www.regulations.gov


### • Postal Mail: Ms . Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE - 2J

1000 Independence Avenue, SW. Washington, D.C. 20585 - 0121


### • Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

• Phone: (202) 586- 2945 

# Introduction

Comment period closes May 2, 201310 

### 5



### 3 2

Test Procedure & Efficiency Metrics Rulemaking Process Overview 

### Authority & Definitions 1 Introduction

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 

### 4 Regulatory Regimes11 

### Standards Development

• The Energy Policy and Conservation Act of 1975 (EPCA), as amended, 

### contains a list of 12 types of industrial equipment that are considered covered equipment for which the Secretary of Energy is authorized to 

### establish energy conservation standards.

• Fans and blowers are two of the specified types of industrial equipment that the Secretary has classified as covered industrial equipment. (42 USC 

### 6311 (2)(B)).

• EPCA directs DOE to develop new or amended standards designed to achieve the maximum improvement in energy efficiency that is 

### technologically feasible and economically justified for which DOE’s rulemaking process provides the schedule and analyses to do so. 

# Rulemaking Process Overview12 

### • EPCA directs DOE to consider seven factors for analysis when setting 

### technologically feasible and economically justifiable standards:

• : EPCA Requirement Corresponding DOE Analyses 1. Economic impact on consumers and manufacturers • Life-Cycle Cost Analysis • Manufacturer Impact Analysis 2. Lifetime operating cost savings compared to increased product cost • Life-Cycle Cost Analysis 3. Total projected energy savings • National Impact Analysis 4. Impact on utility or performance • Engineering Analysis • Screening Analysis 5. Impact of any lessening of competition • Manufacturer Impact Analysis 6. Need for national energy conservation • National Impact Analysis 7. Other factors the Secretary considers relevant • Emissions Analysis • Utility Impact Analysis • Employment Impact Analysis 

# Rulemaking Process Overview

Source: (42 U.S.C. § 6295(o)(2)(B)(i) and 42 U.S.C. § 6316(a))13 

# Rulemaking Process Overview

• TP and ECS rulemakings are separate processes but have integrated timelines.


### • The TP rulemaking timeline duration is about 1.5 years from cradle to grave.
• The ECS rulemaking timeline duration is about 3 years from cradle to grave.
• For additional information on the rulemaking process go to: http :// www1.eere.energy.gov/buildings/appliance_standards/standards_dev_and_revision.html 

## Energy Conservation Standards (ECS) 

## Test Procedure (TP) NOPR Final Rule 

## Test Procedure and Standard Rulemakings Timelines
Framework Document Preliminary

Analysis NOPR Final Rule14 

## Framework Document

• Provides an overview of the rulemaking process and encourages early participation from interested parties


### • Invites comments on proposed approach and issues
• Accompanying Federal Register Notice of Public Meeting (NOPM) – 78 FR 7306, 

### February 1, 2013

– Gives notice of the public meeting and availability of the Framework 

### Document being discussed today

– Encourages interested parties to submit comments 

# Rulemaking Process Overview

Framework Document Preliminary

Analysis NOPR Final Rule Today15 

## Preliminary Analysis Document 

# Rulemaking Process Overview

Framework Document Preliminary

Analysis NOPR Final Rule  Planned Federal Register Notice and Public Meeting (NOPM) – Planned Q3 2014:  Gives notice of the public meeting and availability of the Technical Support Document (TSD ).  Encourages interested parties to submit comments.  Analysis:16 

## Notice of Proposed Rulemaking (NOPR) Document

• Discussion of comments received in response to Preliminary Analysis TSD

• Analysis of the impacts of potential standards on consumers, manufacturers, and the Nation and weighting of these impacts



### • Any proposed standard levels for public comment

• Accompanying Federal Register publication –

Planned Q2 2015

– Gives notice of the public meeting and availability of the revised TSD

– Encourages interested parties to submit comments 

# Rulemaking Process Overview

Framework Document Preliminary

Analysis NOPR Final Rule17 

## Final Rule Publication

• Discuss comments received in response to the NOPR

– DOE will consider all written & verbal input in preparing the final rule
• Revise analysis of the impacts of standards & weighting of these impacts of the final rule


### • Determine any standard levels DOE will adopt
• Establish the compliance date for any adopted standards


### • Accompanying Federal Register Final Rule – Planned Q1 2016 

# Rulemaking Process Overview

Framework Document Preliminary

Analysis NOPR Final Rule18 2013 Framework Document Public Meeting February 2013 Preliminary Analysis Public Meeting Planned –

Q3 2014 NOPR Public Meeting Planned –

Q2 2015 2015 2016 2019 Proposed Energy Conservation Standard Final Rule Effective Date Q1 2019

2014

TP NOPR Public Meeting Planned –

Q2 2014 

# Rulemaking Schedule19 

### 5



### 3 2


### Regulatory Regimes Rulemaking Process Overview 

### Authority & Definitions 1 Introduction

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 

### 4 Test Procedure & Efficiency Metrics20 

## Authority and Background

• Currently no energy conservation standards for commercial and 

### industrial fans
• Title III Part C of the Energy Policy and Conservation Act of 1975 (EPCA), 

### as amended, sets forth various provisions designed to improve energy efficiency of commercial and industrial equipment. (42 U.S.C. 6311 – 

### 6317)

– Section 6311 includes a list of industrial equipment which the Secretary may classify as covered equipment
• This list includes fans and blowers (42 U.S.C. 6311(2)(B)(ii) and (iii )) » Notice of Proposed Coverage Determination published June 28, 2011 ( 76 FR 37678 ) 

### • Manufacturers must use a DOE prescribed test procedure to establish 

### compliance with any standards set for commercial and industrial fans

– In addition to energy conservation standards, DOE will undertake a test 

### procedure rulemaking for commercial and industrial fans 

# Authority & Definitions21 

## Definitions

• Currently there are no statutory definitions for fans and blowers

– Framework Document discusses the considered definitions



### • DOE Proposed Definitions – • Commercial/Industrial Fan: A device used in commercial or industrial systems to provide a continuous flow of a gas, typically air, by an impeller fit to a shaft 

### and bearing(s). A fan may be manufactured with or without a housing component.
• Fan Manufacturer: An entity responsible for assembling a fan into a testable configuration such that the fan impeller is fit to a shaft, bearings, and in some cases installed within a housing component,


### • Axial Fan : A fan in which airflow enters and exits the impeller parallel to the shaft axis. The axial fan may or may not be equipped with a cylindrical 

### housing, orifice panel/ring, inlet or outlet guide vanes 

# Authority & Definitions22 

## Definitions (cont.)

• DOE Proposed Definitions (cont.) –

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

• Cross Flow Fan: A type of centrifugal fan in which the fluid path though the 

### impeller is in a direction that is substantially at right angles to its axis with air both entering and leaving radially at its periphery



### • Mixed Flow Fan: A fan in which the direction of airflow through the impeller takes on characteristics that are intermediate between centrifugal and axial fans 

### in that the air exits the fan in a direction which is neither parallel nor perpendicular to the shaft 

# Authority & Definitions23 

## Definitions (cont.)

• DOE Proposed Definitions (cont.) – • Blower: An axial or centrifugal fan with a specific ratio between 1.11 and 1.20 

### were the specific ratio is the total pressure at the fan outlet divided by the total pressure at the fan inlet, measured at peak fan total efficiency (European Union 2011 Non-domestic fans legislation ):

– The term “blower” is used in many contexts by the industry, however, generally used to describe high pressure fans. DOE considers specific ratio a way to quantify “high pressure”.

– AMCA 99 definition of blower emphasizes the application and not the specific technological features of the equipment


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

– Those designed to operate in potentially explosive atmospheres

– Those designed for emergency use only, short-time duty, fire safety requirements

– Those designed specifically to operate where gases temperature exceed 500oF

– Those designed in toxic, highly corrosive, or flammable environments. 

# Authority & Definitions24 

## Considered Fan Coverage

• Fan Types

– Inclusion of all fan types (axial, centrifugal, mixed flow, blowers)



### • Physical and Performance Criteria for Standards

– Impeller Diameter: inclusion of fans up to 98 inches



### – Transmission Type: all

– Rotational Speed: speeds up to 8,000 RPM 

# Authority & Definitions25 

# Authority & Definitions Request for Comment
Item 2- 1: DOE requests data on how fans are sold. Specifically DOE requests data on market share of fans 1) sold by themselves, 2) sold attached to or integrated with motors only, 3) sold attached to or integrated with both motors and VSDs, 4) sold physically separate from but priced together with a motor only, or 5) sold physically separate from but priced together with both a motor and VSD. DOE would appreciate these data by size, equipment category (see section 5.2.1), and application. Item 2- 2: DOE requests comment on the suggested definition for cross flow fan, specifically regarding whether this fan is a type of centrifugal fan. Item 2- 3: DOE requests comment on the suggested definition for blowers. Item 2- 4: DOE requests comment on the suggested definitions for safety fans. Specifically, are other safety features not included in the above definition that should be included. Item 2- 7: DOE requests comment on the consideration of standards for axial fans, centrifugal fans, mixed flow fans, safety fans, and blowers as defined in section 2.1.1 of the Framework document.26 

### 5



### 3 2

Test Procedure & Efficiency Metrics Rulemaking Process Overview 

### Authority & Definitions 1 Introduction

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 

### 4 Regulatory Regimes 1 Introduction27 

## Combined Fan, Motor, & Control Equipment

• DOE is considering defining commercial and industrial fans as:

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



### • Addressing losses besides the bare shaft fan

– Example is in the EU Commission where they regulate non-domestic fans inclusive of motor & controls 

# Regulatory Regime28 

## Combined Fan Equipment (cont.)

• VSDs are control devices

– Enables the fan rotational speed to match process requirements
• Benefits variable load applications and depends on time spent at various operating conditions
• VSDs may not be appropriate for all applications and may degrade efficiency under constant load operation



### – Same fans can be used in constant and variable load applications
• DOE is not aware of any specific fan type that is always used in an application that would benefit from a VSD



### • Manufacturers cannot control if or how a VSD is used

– DOE will conduct analyses across the full spectrum of fan applications and baseline conditions to determine VSDs impact on the field energy use 

# Regulatory Regime29 

## Fans For Which DOE is Considering Standards

• Bare Shaft Fans: Fans without drives, attachments, or accessories

– Regulatory Regime #1: single set of equipment classes
• Bare shaft fan regulatory approach for all fan types regardless of how they are sold



### • Combined Fan Equipment: Fan+Motor or Fan+Motor+VSD

– Regulatory Regime #2: two sets of equipment classes
• Fans without VSD (sold with or without motor)
• Fans with VSD



### – Regulatory Regime #3 : two sets of equipment classes
• Fans without motor
• Fans with motor (sold with or without VSD), VSD is a design option to increase efficiency 

# Regulatory Regime30 

# Regulatory Regime Request for Comment
Item 2- 9: DOE requests comment on whether establishing standards for fans defined inclusive of the motor transmission, and controls could increase the beneficial use of VSDs in the field and whether interested parties believe the benefits of such a standard would outweigh any negatives, such as the potential use of VSDs in applications for which it is not suited.DOE seeks comment on the market share of fans (by type) that would be used in applications that would benefit from VSDs, as well as those where use of a VSD could result in increased energy use. In particular, whether there are specific fan types that are almost always used, or alternatively, very rarely used, in applications that would benefit from a VSD. Item 2- 10 : DOE requests data and comment on whether fans are more often combined with motors, VSDs, or both by the fan manufacturer or by distributors/contractors. Item 2- 11 : DOE requests information on how often and in what circumstances the intended application is known when the fan is sold. Item 2- 12: DOE requests comment on whether standards should be considered only for fans with an impeller diameter less than 98 or equal to inches and whether that impeller diameter distinction is appropriate for all fans equipment classes being considered in this rulemaking31 

## Request for Comment

Item 2- 14: DOE requests comment on considering standards for fans with power requirements between 125 W and 500 kW for this rulemaking. Item 2- 16: DOE requests comment on the percentage of fan motors estimated to be covered by the small and medium electric motor standards. Specifically, does the industrial plant motor study performed by WSU represent the commercial and industrial fan industry as a whole? Why or why not? Item 2- 17: DOE seeks comment on the market share (by fan type) and applications of fans that are driven by equipment other than electric motors. Item 2- 18: DOE requests comment on the transmission types to be considered in this rulemaking. Item 2- 19: DOE requests comment on the VSDs sold with fans and whether there is efficiency variability (and if so, to what extent) among VSDs. 

# Regulatory Regime32 

### 5

3 2

Test Procedure & Efficiency Metrics Rulemaking Process Overview Authority & Definitions

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 4 Regulatory Regimes 1 Introduction33 

## Test Procedures

• DOE is developing a test procedure for commercial and industrial fans.

• When establishing test procedures, DOE reviews existing industry test 

### procedures to measure the energy use or efficiency of the covered equipment as a starting point in the process.

• Manufacturers must use DOE test procedures to ensure compliance with 

### the standards and to make representations of the energy use of the covered equipment. 

# Test Procedure & Efficiency Metrics34 

## Current Industry Test Procedures

• ANSI/AMCA 210-07 / ANSI/ASHRAE 51- 07: “Laboratory Methods of 

### Testing Fans for Aerodynamic Performance Rating”
• Applicable to all fan types


### • Widely recognized and utilized in U.S.



### • AMCA Standard 220 “Laboratory Methods of Testing Air Curtain Units for Aerodynamic Performance Rating”
• Includes modifications for AMCA 210 for air curtain testing.



### • ISO 5801- 07 “Industrial fans - Performance testing using standardized airways”
• International standard developed based on standards: AMCA 210, BS 848 Part 1:1980 (U.K.) and DIN 24163-2: 1985 (Germany) 

# Test Procedure & Efficiency Metrics35 

## Potential Test Configurations Considered

• Defines the use and geometry of connections to a fan outlet and/or inlet.


### • There are four test configurations (also referred to as installation categories) specified in ISO 5801 and AMCA 210- 07:

• DOE is considering specifying a single test configuration per equipment 

### class for consistency of results since ducting impacts fan performance. 

# Test Procedure & Efficiency Metrics

Installation Category/ Test Configuration 

### Location of Ducting for Testing A Free inlet, free outlet 

### B Free inlet, ducted outlet C Ducted inlet, free outlet D Ducted inlet, ducted outlet36 

# Test Procedure & Efficiency Metrics Request for Comment Item 3-1: DOE requests comment on the use of the AMCA 210-07 test procedure 

### as a base for the development of a DOE test procedure Item 3-3: DOE requests comment on the applicability of AMCA Standard 210- 07 

### in coordination with AMCA Standard 220-05 for measuring performance of cross flow fans. Item 3-6: DOE requests comment on the ability of using a clean air only test procedure to determine the efficiency of fans designed for dust air or material handling applications that could be compared to fans not designed for handling such materials that are in the same equipment classes (see section 5.2 in 

### Framework Document for equipment class discussion)37 

# Test Procedure & Efficiency Metrics Request for Comment Item 3-7: DOE requests comment on which test configuration should be considered for each of the considered equipment classes (axial housed, axial un -housed, centrifugal clean air housed, centrifugal clean air unhoused , centrifugal dust air, centrifugal material handling, centrifugal cross flow, mixed flow, blowers, safety fans). Item 3-8: DOE requests comment on requiring an air straightener to reduce air 

### swirl at the outlet for axial fans tested in configuration B (free inlet, ducted outlet) or D (ducted inlet, ducted outlet).38 

## Currently Available Fan Efficiency Data & Definitions

• Sources

– Information from manufacturer websites and catalogs .



### • Efficiency Definitions

– Peak Total Efficiency (AMCA 99)
• Ratio of fan air power output to fan shaft power input for the operating condition for which this value is highest.



### – Overall Efficiency (ISO 12759)
• Fan peak total efficiency multiplied by drive components efficiency (includes efficiency of motor and any components between the motor and the power supply and any mechanical devices between motor and fan ).
• Each fan and motor combination has a unique efficiency value. 

# Test Procedure & Efficiency Metrics39 

## Potential Efficiency Metric Considered for Bare Shaft Fans

• Fan Efficiency Grades (FEG) 

### per AMCA 205-10 (Rev. 2012)

– Numerical rating that represents fan efficiency

– Each FEG represents a relationship of peak total efficiency as a function of a fan's impeller diameter

– DOE plans to evaluate an FEG metric by developing fan efficiency grades unique to each equipment class 

# Test Procedure & Efficiency Metrics40 

## Potential Efficiency Metric Considered for Bare Shaft Fans (cont .) 

# Test Procedure & Efficiency Metrics

• DOE is interested in expanding the FEG approach to incorporate operational 

### conditions of a fan

– DOE would evaluate efficiency against combinations of size and operational parameters, for example, diameter and specific speed * *Specific speed is a function of a fan’s airflow, rotational speed, and pressure .41 

## Expanded FEG - Example 

# Test Procedure & Efficiency Metrics42 

## Expanded FEG Efficiency Metric - Example 

# Test Procedure & Efficiency Metrics

30% 40% 50% 60% 70% 80% 90%

0 10 20 30 40 50 60 70 80 90 100Total Efficiency (%)

Impeller Diameter (inches) 10000 11833 13667 15500 17333 19167 21000 22833 24667 26500 28333 30167 32000 33833 35667 37500 39333 41167 43000 Specific Speed43 

## Efficiency Metric for Fans Inclusive of Motor & Controls

• Efficiency may need to include motor power to reflect energy-efficiency 

### changes for fan-motor systems.

• DOE would consider a metric that can be used to account for the use of more efficient VSDs.

• DOE would consider a metric that can capture the energy impacts from 

### using a VSD in comparison to a fan with a motor but without a VSD.

• Example: European Union’s Fan -Motor Efficiency Grade (FMEG)

– Uses overall efficiency with a VSD compensation factor. 

# Test Procedure & Efficiency Metrics44 

## Efficiency Metric for Fans Inclusive of Motor & Controls (cont.)

• If DOE pursues an regulatory regime for fans inclusive of the motor & 

### controls, then two sets of equipment classes will be developed - may require different efficiency metrics for each set


### • Separate metrics:

– DOE would use different metrics for the two equipment class sets



### – Would not allow direct comparison of fan efficiency when comparing bare shaft fans vs. fans with additional components


### • Same metrics:

– DOE would use the same efficiency metric for both equipment class sets



### – Would allow direct comparison of fan efficiency across the equipment class sets 

# Test Procedure & Efficiency Metrics45 

# Test Procedure & Efficiency Metrics

Regulatory Regime Equipment Class Set Metric Alignment Options Separate Same Multiple 1 Bare Shaft fans Only one set of equipment classes N/A N/A N/A

2 Fans inclusive of the motor and VSD Fans Without VSD (with or without motor) Fan Peak Total Efficiency Overall Efficiency

(standardized motor and VSD) N/A
Fans With VSD Overall Efficiency Overall Efficiency Fan Peak Total Efficiency and Overall Efficiency

3 Fans inclusive of motor Bare Shaft Fans Fan Peak Total Efficiency Motor Input Power

Based (standardized motor) N/A
Fans With Motor (with or without VSD) Electric Input Power Based Electric Input

Power Based Fan Peak Total

Efficiency and Electric Input Power Based Metric 

### Regulatory Regimes and Efficiency Metric Options for Equipment Class Sets Summary Table46 

# Test Procedure & Efficiency Metrics Request for Comment Item 3-9: DOE requests comment on the use of publicly available performance 

### data in lieu of original test data. Item 3-10: DOE requests original fan performance data generated from AMCA 

### 210 tests Item 3-11: DOE requests comment on the considered efficiency metric approaches Item 3- 16: DOE requests comment on the FMEG efficiency metric.47 

# Test Procedure & Efficiency Metrics Request for Comment Item 3-17: DOE requests comment on the use of overall efficiency for fans sold 

### with both motors and VSDs Item 3-18: DOE requests comment on the use input power based efficiency for 

### fans sold with motors where VSDs are a design option to improve efficiency Item 3-19: DOE requests comment on the metrics discussed above, including whether a weighted average metric should be developed under the third metric option. Item 3-20: DOE recognizes that the same fan may in some cases be sold bare 

### shaft or in conjunction with a motor or motor/control package. DOE seeks comment on any issues that may result from having different metrics for fans 

### sold alone and fans sold with motors or VSDs.48 

### 5



### 3 2

Test Procedure & Efficiency Metrics Rulemaking Process Overview 

### Authority & Definitions 1 Introduction

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 

### 4 Regulatory Regimes49 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis50 

### • Purpose:

– Characterize the commercial and industrial fan markets and the measures to improve efficiency.



### • Method:

– Identify and characterize manufacturers of commercial and industrial fans



### – Estimate shipments and trends in the market

– Identify technologies that could improve efficiency



### – Identify regulatory and non-regulatory initiatives intended to improve the efficiency of the equipment covered under this rulemaking 

# Market and Technology Assessment51 

## Considered Commercial and Industrial Fan Equipment Classes, 

## Bare Shaft* 

# Market and Technology Assessment

Fan Type Equipment Class Axial Housed Unhoused Safety Fans
Centrifugal Clean Air Housed Clean Air Unhoused Dust Air Housed Material Handling Housed Cross Flow Housed Safety Fans Mixed Flow All Blowers Axial Centrifugal *Note: If DOE uses regulatory option #2 or #3, a second set of equipment classes could be developed that mirror the set shown for bare shaft fans.52 

## Technology Options to Improve Efficiency Bare Shaft Fans
• Improving aerodynamic design
• Blade shape


### • Material selection
• Guide vanes


### • Optimization of housing design 

### Fans Sold with Motors/VSD
• Improved motor efficiency


### • Variable speed drive
• Improved variable speed design 

# Market and Technology Assessment53 

# Market and Technology Assessment Request for Comment Item 5- 1: DOE requests information that would contribute to the market assessment for fans that would be covered in this rulemaking, especially for 

### those equipment classes designated in section 5.2 of the Framework Document. Examples of information sought include current equipment features and efficiencies, equipment feature and efficiency trends, and 

### historical equipment shipments and prices Item 5- 2: DOE requests comment on the estimates of the number of U.S. fan manufacturers that could be considered small businesses.54 

# Market and Technology Assessment Request for Comment
Item 5- 3: DOE welcomes comments on performance-related features DOE should consider when defining fan equipment classes. Item 5- 5: DOE requests comment on splitting axial fan types into housed and unhoused equipment classes or whether a single equipment class would sufficiently represent axial fan applications Item 5- 6: DOE requests comment on what types of axial fan designs or characteristics are unique to axial-type safety fans.. Item 5- 7: DOE requests comment on whether there are any other commercial or industrial applications (beyond clean air, dust air and material handling) that should be considered while defining equipment classes for centrifugal fans Item 5- 8: DOE requests comment on the considered groupings of housed centrifugal fans. Specifically, DOE requests comment on the use of air quality (Clean Air, Dust Air, Material Handling) and geometrical design descriptors for classification purposes Item 5- 9: DOE requests comment on whether the Dust Air, Material Handling, and Cross Flow fan equipment classes should be split into housed and unhoused categories.55 

# Market and Technology Assessment Request for Comment
Item 5- 10: DOE requests comment on setting cross flow fans as a separate equipment class within the centrifugal fans category Item 5- 11: DOE requests information about the specific design characteristics of cross flow fans. Item 5- 13: DOE requests comment on setting a separate equipment class for blowers. Item 5- 14: DOE requests comment on whether there is a need of more than one blower equipment class to account for the differences between centrifugal and axial blowers. Item 5- 15: DOE requests comment on setting a separate equipment class for mixed flow fans. Item 5- 16: DOE requests comment on whether there are differences among mixed flow fans that might warrant more than one equipment class for this fan type Item 5- 17: DOE requests comment and/or information on the effect of different materials on efficiency.56 

# Market and Technology Assessment Request for Comment Item 5- 18: DOE requests comment on whether there are other fan blade materials that should be included in the list above. Item 5- 19: DOE requests comment on whether there are compatibility issues with certain fans and VSDs that DOE should be aware of when considering a VSD as a means to improve fan efficiency. Item 5- 20: DOE welcomes comments on the preliminary technology options identified in the Framework and whether there are other technology options it should consider.57 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis58 

### • Purpose:

– Screen out technology options that DOE will not consider in the engineering analysis for commercial and industrial fans



### • Method:

– DOE will evaluate each technology option based on the following criteria:
• Technological feasibility
• Practicability to manufacture, install and service

– Note: practicability is on a commercial scale at the compliance date of any final standards
• Impacts on product utility or available to consumers
• Impact on health and safety 

# Screening Analysis59 

## Request for Comment Item 6- 1: Are there any technologies that DOE should not consider because of any of the four screening criteria? If so, which screening criteria apply to the cited technology or technologies? 

# Screening Analysis60 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis61 

# Engineering Analysis

• Develop the cost-efficiency curve, which characterizes the relationship between manufacturer selling price (MSP) and energy efficiency. 

### • The cost-efficiency curves for the examined equipment classes are key inputs for the downstream rulemaking analyses. Rulemaking Analyses



### • Life-Cycle Cost and Payback 

### Period Analysis
• Manufacturer Impact Analysis


### • Employment Impact Analysis Manufacturer Selling Price – 

### Efficiency RelationshipManufacturerSelling Price (MSP)

Efficiency Level 

## Engineering Analysis –

Purpose62 

## Representative Equipment Classes and Representative 

## Units

• The equipment classes identified by DOE cover a range of fan designs and allow for a wide range of fan sizes.

• DOE may focus its analysis on a subset of representative equipment 

### classes and a representative group of units within these classes. 

# Engineering Analysis63 

## Requests for Comment

Item 7-1 Once DOE establishes any representative equipment classes and representative units, it selects a baseline model as a reference point for each representative unit from which to measure changes resulting from the design options. DOE develops separate engineering analyses for each baseline model analyzed. DOE intends to use fan teardowns and fan efficiency (determined from fan performance tests) to develop cost-efficiency relationships for the fans analyzed. DOE intends to develop the necessary test procedures through a test procedure rulemaking, as discussed in section 3.DOE welcomes inputs from interested parties on a methodology that would be appropriate for determining the max-tech models for each fan analyzed. Item 7-2 DOE seeks input on the methods and approaches used by manufacturers to improve the efficiency of fans. Item 7-3 DOE welcomes comment from interested parties on the best methodology for scaling the representative units to other fan sized within the equipment class. 

# Engineering Analysis64 

## Data Sources

• DOE may use publicly available data from manufacturer websites and 

### catalogs, but such information may be limited.



## Request for Comment Item 7-4 DOE seeks fan test data to improve DOE’s understanding of fan performance to select appropriate representative units for the respective equipment classes. 

# Engineering Analysis65 

## Engineering Analysis Methodology

• Determine characteristics of common or typical models which will serve as reference points to assess changes due to energy conservation standards. 

## Define Baseline 

## Models

• Conduct tests to verify efficiency ratings. • Perform equipment disassembly to identify design options and provide input to manufacturing cost models to determine designs and costs associated with each efficiency level. 

## Reverse-Engineering

• Collect manufacturer cost data on efficient fan designs. • Conduct interviews with manufacturers to enhance understanding of efficiency improvements and associated costs. 

## Data Collection, & 

## Interviews

• Develop cost-efficiency curves based on reverse-engineering and cost data from available sources including manufacturer interviews. 

## Develop Engineering Analysis Curves 

# Engineering Analysis66 

## Reverse-Engineering Methodology

Fabricated Parts Selection of

Units Physical Teardown Bill of Materials

Assembly Process Manufacturer Costs Purchased

Parts 

# Engineering Analysis67 

## Requests for Comment Item 7-5 For each equipment class, DOE welcomes stakeholder comments on methods and approaches that DOE intends to employ to determine potential fan efficiency improvements. Detailed information on fan performance and the incremental manufacturing costs (e.g., material costs, labor costs, overhead costs , building conversion capital expenditures, tooling/equipment 

### conversion capital expenditures associated with more efficient designs, research and development (R&D) expenses, and marketing expenses) would 

### be useful. 

# Engineering Analysis68 

## Manufacturing Selling Price (MSP)

• MSP includes manufacturer production costs (MPC) as well as nonproduction costs, such as maintenance, depreciation, and taxes.

• Markups will be used to represent non-production costs and convert the 

### MPC to the MSP.

• DOE intends to estimate manufacturer markups based on publicly available financial information and manufacturer interviews.



## Requests for Comment Item 7-6 DOE welcomes comment on the markup approach proposed for developing estimates of manufacturer selling prices. Item 7-7 DOE welcomes comment on the proposed approach to determine the relationship between manufacturer selling prices and fan efficiency. 

# Engineering Analysis69 

## Conversion Costs

• Includes the difference in investments required to build production facilities required for higher-efficiency designs as compared with investments for production facilities used for current designs.

• DOE typically does not include conversion costs in the engineering analysis.



### • One option to improve fa n efficiency is re -design. The non-recurring R&D costs required to develop such new designs also would not be part of the MSP 

### calculated in the engineering analysis. It will be addressed in the Manufacturer Impact Analysis. 

## Requests for Comment Item 7-8 DOE welcomes comment on the conversion costs required to 

### improve the efficiency of the fans to various levels, as well as what portion of these costs would be passed on to the consumer. 

# Engineering Analysis70 

## Selecting Representative Units and Scaling Results

• Within each representative equipment class, DOE would select 

### representative unit fans in size ranges and of specific speed values that represent a large number of models.



### • DOE would also plan to evaluate fans of small and large sizes for at least one fan series to characterize a size-efficiency relationship.



### • DOE would use this relationship to scale results for representative units to smaller and larger units. 

# Engineering Analysis71 

## Request for Comment Item 7- 9: DOE requests comment on limiting representative unit selection to fan size(s) that include the most available units. 

### Item 7- 10: DOE requests comment on the selection of additional fans at both larger and smaller sizes to determine a fan size-efficiency scaling relationship. 

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

# Engineering Analysis72 

## Baseline Models

• DOE typically selects models that just meet current energy conservation 

### standards to represent the baseline.

• Energy conservation standards for fans do not currently exist. Hence, for 

### this rulemaking, DOE will select baseline models at the bottom- of -market efficiency representing substantial shipments. 

# Engineering Analysis73 

## Request for Comment Item 7- 12: DOE seeks comment on the selection, appropriate features, and performance characteristics of baseline models for each equipment class. Specifically, DOE requests comment on choosing the least efficient fan design 

### as the baseline model for the equipment class. DOE will define the characteristics of the proposed baseline models based on comments from 

### interested parties in addition to DOE's analysis. 

# Engineering Analysis74 

## Efficiency Levels

• Within a given size selected for analysis, the fan models for which performance data is available will be assessed to determine efficiency levels for analysis.



## Requests for Comment Item 7- 11 DOE requests comment on the method of using fan unit efficiencies as the basis for determining efficiency levels. 

# Engineering Analysis75 

## Efficiency Levels (cont.)

• Once DOE establishes a baseline for each representative unit, it establishes efficiency levels based on measured improvements in efficiency resulting from implementation of technology options. DOE will 

### develop separate engineering analyses for each baseline model analyzed.

• DOE intends to determine fan efficiency from fan performance tests 

### performed using the proposed DOE test procedure. 

# Engineering Analysis76 

## Request for Comment
Item 7- 14: DOE seeks input from interested parties regarding the range of efficiency levels that should be examined as part of its analysis. Item 7- 15: DOE requests comment on whether manufacturers generally do not 

### offer fans of varying efficiencies that meet the same duty requirement. 

# Engineering Analysis77 

## Max Tech

• DOE is required to analyze maximum technologically feasible (“max tech”) 

### efficiency levels.

• DOE will seek interested party input on the appropriate max tech levels.



## Requests for Comment Item 7-A DOE welcomes inputs from interested parties on a methodology that would be appropriate for determining the max-tech models for each fan analyzed. 

# Engineering Analysis78 

## Outside Regulatory Changes

• DOE will consider the effects of other DOE energy conservation standards and 

### regulatory changes outside DOE’s rulemaking process that can impact manufacturers of covered equipment.



### • Some regulatory changes can also affect the efficiency or energy consumption of the fans covered under this rulemaking.

• DOE will attempt to identify any outside engineering issues that could impact the 

### engineering analysis. 

## Request for Comment Item 7- 16: DOE welcomes comment on whether there are outside regulatory changes that DOE should consider in its engineering analysis of fans. 

# Engineering Analysis79 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis80 

### • Purpose:

– Estimate actual user prices from manufacturer selling prices of baseline and higher efficiency designs of equipment



### • Method:

– Identify distribution channels and estimate share of each channel in the aggregate sales volume

– Estimate how equipment is marked up along each level of the distribution 

### chain 

# Markups Analysis81 

## Proposed Distribution Channels 

# Markups Analysis82 

## Types of Markups in Distribution Chain

• Baseline Markups:

- Markups relate end-user price to manufacturers selling price (MSP) averaged over all distribution channels.

- Baseline markups relate price to MSP for all currently sold equipment.

- Baseline markups indicate a consumer price that covers all of a distributor’s or contractor’s current expenses plus profit.


### • Incremental Markups:

- Incremental markups relate the incremental change in end-user price to the incremental change in MSP due to higher efficiency designs.

- Some of the distributor’s costs, such as direct labor costs (salaries, payroll, rental and occupancy), do not vary with efficiency induced changes and are excluded from the calculation of incremental markups.



### - Incremental markups cover only expenses that are expected to vary with higher cost of equipment sold e.g., business promotion, interest and 

### insurance etc. 

# Markups Analysis83 

# Mark-Ups Analysis Request for Comment Item 8- 1: DOE requests information regarding the functioning of the manufacturer 

### representatives/distributors for different equipment classes and market segments. Item 8- 2: DOE requests information on OEM market segments, and the downstream distributor channels, if any. 

### Item 8- 3: DOE requests comments on the applications and market segments identified by interested parties and information on other market segments, 

### including their corresponding distributor channel(s) and the trade association(s) representing the distributors. 

# Markups Analysis84 

## Request for Comment Item 8- 4: DOE requests information on the proposed distribution channels and 

### the share of industry shipments expected for each distribution channel for the commercial and industrial fans in terms of either each specific equipment class 

### or the broader equipment categories described above. Item 8- 5: DOE seeks comment on other sources of relevant data that could be used to characterize markups for commercial and industrial fans. 

### Item 8- 6: DOE requests feedback on its proposal to use incremental distribution channel markups for the LCC analysis. 

# Mark-Ups Analysis 

# Markups Analysis85 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis86 

### • Purpose:

– Identify how fans are actually operated by users and to determine the energy savings potential of more efficient designs in the field

– Estimate annual energy consumption (AEC) for baseline and higher-efficiency 

### designs


### • Issues:

– End-use load profiles are expected to be highly variable across equipment classes and applications



### – In practice many, if not all, fans typically operate at points other than their peak efficiency



### – Useful work done by any fan will vary widely across a range of possible applications 

# Energy Use Analysis87 

## Approach

• Estimate annual energy consumption (AEC) for baseline and higherefficiency designs using use the load profiles developed for each application:

• Develop statistical models describing the expected range of duty profiles for fans in different applications 

# Energy Use Analysis

H fan88 

## Request for Comment

Item 9- 1: DOE requests input and recommendations for identifying high sales volume and large installed base market segments corresponding to specific industries and specific applications for which the fan equipment may have similar load profiles. Item 9- 2: DOE welcomes recommendations on sources of data or analysis methods that would provide end-use load profiles for each of the commercial and industrial fans in the different market segments. Item 9- 3: DOE requests input on ways to characterize fan sizing and selection practices for different equipment classes and applications and to help define the design or peak fan load for the purpose of generating normalized load profiles. For example, one question is whether load profiles should reflect normalization to the delivered air horsepower at the peak efficiency of the fan (at a given fan size and speed) Item 9- 4: DOE welcomes comment on methods for determining generic (non-market segment specific) load profiles for fan equipment classes considered in this rulemaking. 

# Energy Use Analysis89 

## Request for Comment

Item 9- 5: DOE welcomes comment on the current penetration level of variable-speed drives in the installed base of products or applications for each of the equipment classes considered in this rulemaking. Item 9- 7: DOE requests comment and recommendations on the range of and number of fan rotation speeds over which the analysis should be carried out for different equipment classes. Item 9- 8: DOE requests information on current industry practices and recommendations on the selection of representative operating points for a given rotational speed. DOE welcomes comment on whether the analysis should be extended to a range of operating points away from the peak efficiency. Item 9- 9: DOE requests comment and estimates to establish the mean value and the ranges of likely values for motor, transmission, and motor control efficiencies. 

# Energy Use Analysis90 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis91 

### • Purpose:

– Assess life-cycle cost (LCC) impacts of different efficiency levels on the consumer



### • Method:

– LCC equals consumer price plus the sum of annual operating costs (including 

### repair and maintenance costs) discounted to a particular base year

– Economic evaluation from the consumer perspective



### – Results are expressed as LCC difference (base case minus higher efficiency level)



### – Payback Period (PBP) is also calculated and reported in this analysis 

# Life-Cycle Cost and Payback Period Analysis92 

## Approach

• For each of the representative units in each equipment class:

– Develop fan selection process to reflect product choices by customers

– Develop distribution of equipment efficiencies expected for the compliance 

### year

– Aggregate the annual energy consumption over a fan’s lifetime

– Model uncertainty and variability in the inputs using a Monte Carlo simulation method and probability distributions

– Perform an analysis to determine whether the three-year rebuttable presumption of economic justification applies 

# Life-Cycle Cost and Payback Period Analysis93 

## Approach

• Installation Costs

– Consists of labor and any miscellaneous materials and parts.



### • Energy Prices

– DOE will collect information about commercial and industrial electricity tariffs 

### as a means of establishing marginal electricity prices.

– DOE will use EIA’s Annual Energy Outlook to estimate future energy prices.



### • Maintenance & Repair Costs

– DOE plans to consider maintenance and repair costs and plans to determine whether it changes with increased efficiency. 

# Life-Cycle Cost and Payback Period Analysis94 

## Approach

• Equipment Lifetime

– The operational lifetime of a fan can be determined from the number of revolutions until failure.

– Revolutions until failure are usually limited by the fan’s bearing.

– Basic bearing lifetime for medium-sized light duty fans is approximately 40,000 hours; for heavy duty fans is approximately 100,000 hours*.
• A fan operating full-time is estimated to run 4,000 hours per year, translating into a fan lifetime of 10-25 years.
• The RSMeans method uses an average fan lifetime of 15 years. 

### *Source: Cory, W.T.W., Fans and Ventilation: A practical guide . 

# Life-Cycle Cost and Payback Period Analysis95 

## Approach

• Discount Rates

– DOE will derive the discount rates for the commercial and industrial users by estimating the capital costs for companies that purchase fans



### • Base Case Efficiency

– Used to characterize the commercial and industrial fan market in the compliance year in the absence of DOE standards

– If market share efficiency data are not available, DOE may develop efficiency distributions based on available models and information from fan manufacturers and experts 

# Life-Cycle Cost and Payback Period Analysis96 

## Request for Comment

Item 10- 1: DOE welcomes comment on the factors that impact the installation costs for fans and on whether installation cost increases with higher-efficiency equipment. Item 10- 2: DOE welcomes input on the proposed methodology for estimating current and future electricity prices for the fans covered under this rulemaking. Item 10- 3: DOE invites comment on how repair costs may change for more efficient fans. DOE also invites comment on repair practices, and how usage patterns may impact equipment repair and maintenance. Item 10- 4: DOE welcomes information that will assist in determining an appropriate distribution of fan lifetimes for the equipment classes covered in this rulemaking. Item 10- 5: DOE welcomes input on the proposed approaches for estimating discount rates for fan users. Item 10- 6: DOE requests data on the efficiency distribution and welcomes comment on the likelihood and degree of improvement in efficiency of commercial and industrial fans in the next 5 to 10 years as a result of market forces or industry trends. 

# Life-Cycle Cost and Payback Period Analysis97 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis98 

### • Purpose:

– Project future shipments by equipment class



### • Approach:

– DOE typically projects shipments for a 30-year period beginning in the expected compliance date of the standard



### – Characterize the production of fans by using
• Gross Domestic Product (GDP) as an indicator of the performance of industrial and commercial sectors where fans are used
• Private fixed investment data for equipment incorporating fans from the U.S. Department of Commerce’s Bureau of Economic Analysis



### – DOE may use different shipments projection in the standards case as compared to the base case 

# Shipments Analysis99 

# Shipments Analysis Request for Comment Item 11- 1: DOE welcomes comment on the shipments projection methodology. DOE invites comments regarding the selection of appropriate 

### economic drivers and sources of data for historical shipments and shipment breakdowns by equipment class. Item 11- 2: DOE requests historical shipments data for each of the considered equipment classes. Item 11- 3: DOE welcomes comment on how an energy conservation standard 

### for fans might impact shipments of the equipment covered in this rulemaking. 

# Shipments Analysis100 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis101 

### • Purpose:

– Determine the projected national energy savings (NES) and consumer national net present value (NPV)



### • Method:

– Develop annual series of national energy and economic impacts



### – Utilize the shipments model to estimate stock each year

– Utilize the LCC to develop input about total installed cost and energy use per 

### unit (UEC) in any year

– Aggregate the costs and energy use for all years in the analysis period



### – Report NES in primary and full fuel cycle (FFC) savings

– Report change in national customer NPV (in constant year dollars)



### – Account for the time-value of money though defined discount rates 

# National Impact Analysis102 

# Preliminary Analysis
Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis
Energy Use

Analysis Shipments Analysis National Impact Analysis Markups for Product Price Determination Life-Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis103 

### • Purpose:

– Assessment of the potential impacts of energy conservation standards on manufacturers of fans



### • Method:

– Conduct interviews with manufacturers



### – Collate the interview results and prepare a summary of the major issues and outcomes



### – Industry cash-flow analysis 

# Preliminary Manufacturer Impact Analysis104 

## Manufacturer Subgroups

• DOE will identify any subgroups that may be disproportionately affected 

### by efficiency standards
• DOE will identify small businesses and conduct a Regulatory Flexibility Act 

### analysis to determine the impacts of any standards these manufactures

• DOE will identify and consider the impact of multiple product-specific 

### regulations on the manufacturers 

# Preliminary Manufacturer Impact Analysis

Cumulative Regulatory Burden105 

## Request for Comment Item 14- 1: DOE seeks comments on the subgroups of the fan equipment manufacturers that it should consider in a manufacturer subgroup analysis. Item 14 - 2: DOE seeks comments on what other existing regulations or pending 

### regulations it should consider in its examination of cumulative regulatory burden. Item 14 - A: DOE seeks comment on small businesses that could be impacted by potential energy conservation standards for commercial and industrial fans, as 

### well what these impacts might be. 

# Preliminary Manufacturer Impact Analysis106 Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

# NOPR Analyses107 

### • Purpose:

– Analyze the economic impacts of standards on consumers, including subgroups who may be disproportionately impacted compared with the general user population
• A subgroup comprises a subset of the population likely to be disaffected disproportionately by new or revised energy conservation standards



### • Method:

– Extend the LCC analysis to examine the impacts for defined subgroups

– DOE will use inputs specific to each of the considered consumer subgroups 

# Customer Subgroup Analysis108 

# Customer Subgroup Analysis Request for Comment Item 13 - 1: DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fans.109 Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

# NOPR Analyses110 

### • Purpose:

– Assess the overall impacts on domestic energy supplies that would result from the imposition of standards


### • Method:

– DOE proposes to use NEMS-BT, a variant of the NEMS (National Energy Modeling System) developed and used by DOE/EIA for their Annual Energy 

### Outlook (AEO) report, as the basis of the Utility Impact Analysis

– Outputs of the utility impact analysis include projections of electricity sales, 

### price, and avoided capacity resulting from a comparison of base and standards cases

– DOE will model the energy savings impacts from amended energy conservation standards using NEMS-BT to generate projections that deviate from the AEO reference case 

# Utility Impact Analysis111 

# Utility Impact Analysis Request for Comment Item 15 - 1: DOE welcomes input from interested parties on its proposed approach to conduct the utility impact analysis.112 Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

# NOPR Analyses113 

## Employment Impact Analysis

• Purpose:

– Assess the overall impact on national employment from the imposition of efficiency standards at differing levels

– Include both direct and indirect employment impacts
• Direct employment impacts are estimated in the manufacturer impact analysis
• Indirect employment impacts result from shifting consumer expenditures among goods and services ( “substitution effect”) and changing equipment and energy costs (“income effect ”) 

### • Method:

– DOE intends to use the ImSET (Impact of Sector Energy Technologies) model 

### for the evaluation of indirect employment impacts 

# Employment Impact Analysis114 

# Employment Impact Analysis Request for Comment Item 16 - 1: DOE welcomes comments on its proposed approach to assessing national employment impacts.115 Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

# NOPR Analyses116 

### • Purpose:

– Estimate environmental impacts from potential energy conservation standards for fans including changes in Full Fuel Cycle (FFC) emissions


### • Method:

– DOE will base the emission factors for FFC on EIA’s Annual Energy Outlook, supplemented by data from other sources. The following emissions are assessed:
• Carbon dioxide (CO 2 )
• Sulfur dioxide (SO 2 )

– SO 2 emissions from affected electric generating units are subject to nationwide and regional emissions cap and trading programs
• Nitrogen oxides (NO x )

– Clean Air Interstate Rule (CAIR) permanently caps NO x emissions in 28 eastern States and DC
• Methane (CH 4 )
• Nitrous Oxide (N 2 O)
• Mercury (Hg) 

# Emissions Analysis117 

### • DOE intends to use the most current Social Cost of Carbon (SCC) values developed by interagency reviews

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

### • At present, the most recent interagency estimates of the potential global benefits 

### resulting from reduced CO 2 

### emissions in 2015, expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton avoided

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

### • DOE will also estimate the potential monetary benefit of reduced NO x 

### emissions resulting from the considered standard levels 

# Monetization of Emission Reductions118 

## Request for Comment Item 17 - 1: DOE welcomes comments on its proposed approach to analyzing 

### emissions impacts on potential standards for commercial and industrial fans. 

# Emissions Analysis & Monetization119 Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Customer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis and Monetization Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

# NOPR Analyses120 

## Regulatory Impact Analysis

• Purpose:

– Explore the potential for non-regulatory alternatives to new energy efficiency standards



### • Method:

– Base the assessment on the actual impacts of any such initiatives to date, but consider information presented regarding the impacts that any existing initiative might have in the future 

# NOPR Analyses121 

### 5



### 3 2

Test Procedure & Efficiency Metrics Rulemaking Process Overview 

### Authority & Definitions 1 Introduction

6 Rulemaking Analyses 

# Public Meeting Agenda

7 Closing Remarks 

### 4 Regulatory Regimes122 

### How to Submit Written Comments 

### In all correspondence, please refer to the Commercial and Industrial Fans and Blowers rulemaking by : – Framework Document for Commercial and Industrial Fans and Blowers – Docket Number: EERE- 2013 - BT -STD- 0006 – Regulatory Identification Number (RIN): 1904-AC55 

### Electronic: CIFB2013STD0006@EE.Doe.Gov or www.regulations.gov Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy Building Technologies Program, Mailstop EE- 2J 1000 Independence Avenue, SW Washington, DC 20585- 0121 

### Courier: Ms. Brenda Edwards

U.S. Department of Energy Building Technologies Program Sixth Floor, 950 L’Enfant Plaza, SW Washington, DC 20024 Telephone: (202) 586- 2945 

### Comment period closes: May 2, 2013 

# Closing Remarks