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Charles Llenza 

BUILDING TECHNOLOGIES PROGRAM 

February 21, 2013

Energy Conservation Standards for Commercial & Industrial 

Fans and Blowers: Framework Public Meeting 
2 

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 Remarks 
3 

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 Lunch
4 

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 Remarks 
5 

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 Regimes 
7 

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 

Introduction 
8 

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, 2013
10

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 
11

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 Overview 
12

• 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 

Rule 
14

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 

Today
15

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 Rule 
17

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 Rule 
18

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 Schedule 
19

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 Metrics 
20

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 & Definitions 
21

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 & Definitions 
22

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 & Definitions 
23

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 & Definitions 
24

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 & Definitions 
25

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 Introduction 
27

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 Regime 
28

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 Regime 
29

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 Regime 
30

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 rulemaking 
31

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 Regime 
32

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 Introduction 
33

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 Metrics 
34

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 Metrics 
35

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 outlet
36

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 Metrics 
39

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 Metrics 
40

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 Metrics 

30

40

50

60

70

80

90

100

20

40

60

80

10000

20000

30000

40000

50000

60000

Total Efficiency (%)

Impeller Diameter (inch)

Specific Speed Ns

30 

40 

50 

60 

70 

80 

100 
42

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 90 100

Total Efficiency (%)

Impeller Diameter (inches)

10000

11833

13667

15500

17333

19167

21000

22833

24667

26500

28333

30167

32000

33833

35667

37500

39333

41167

43000

Specific Speed 
43

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 Metrics 
44

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 Metrics 
45

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 Table 
46

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 Regimes 
49

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 

Analysis 
50

• 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 Assessment 
51

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 Assessment 
53

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 

Analysis 
58

• 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 Analysis 
59

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 Analysis 
60

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 

Analysis 
61

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 Relationship

Manufacturer 

Selling Price (MSP) 

Efficiency Level 

Engineering Analysis – Purpose 
62

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 Analysis 
63

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 Analysis 
64

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 Analysis 
65

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 Analysis 
66

Reverse-Engineering Methodology 

Fabricated 

Parts 

Selection of 

Units 

Physical 

Teardown 

Bill of Materials 

Assembly 

Process 

Manufacturer 

Costs 

Purchased 

Parts 

Engineering Analysis 
67

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 Analysis 
68

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 Analysis 
69

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 fan 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 Analysis 
70

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 Analysis 
71

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 Analysis 
72

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 Analysis 
73

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 Analysis 
74

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 Analysis 
75

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 Analysis 
76

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 Analysis 
77

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 Analysis 
78

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 Analysis 
79

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 

Analysis 
80

• 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 Analysis 
81

Proposed Distribution Channels 

Markups Analysis 

Manufacturer  OEM  OEM Product Distributor  User (OEM Channel-A)

Manufacturer  Distributor  Contractor  User (Distributor Channel -B)

Manufacturer  Distributor  User (Distributor Channel-C) 

Manufacturer   User (Direct End-User Channel-D)

Manufacturer  Other  User (Channel-E)

Manufacturer 

Representatives

Figure 1. Commercial and Industrial Fan Distribution Channels
82

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 Analysis 
83

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 Analysis 
84

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 Analysis 
85

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 

Analysis 
86

• 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 Analysis 
87

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 

 

Where: 

AEC = annual energy consumption (kWh) 

Hfan = air horsepower at the operating point i 

Ni = operating hours at the operating point i 

ηOverall =ηF × ηT × ηM × ηC at the operating point i 

ηF = fan efficiency

ηT = transmission efficiency 

ηM = motor efficiency 

ηC = control system efficiency 

All operating po s

i

ii

Hfan overall N

HP

kW AEC

_ int_

1

746.0 )/(

 

Where: 

AEC = annual energy consumption (kWh) 

Hfan = air horsepower at the operating point i 

Ni = operating hours at the operating point i 

ηOverall =ηF × ηT × ηM × ηC at the operating point i 

ηF = fan efficiency

ηT = transmission efficiency 

ηM = motor efficiency 

ηC = control system efficiency 

All operating po s

i

ii

Hfan overall N

HP

kW AEC

_ int_

1

746.0 )/(

Hfan 
88

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 Analysis 
89

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 Analysis 
90

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 

Analysis 
91

• 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 Analysis 
92

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 Analysis 
93

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 Analysis 
94

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 Analysis 
95

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 Analysis 
96

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 Analysis 
97

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 

Analysis 
98

• 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 Analysis 
99

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 Analysis 
100

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 

Analysis 
101

• 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 Analysis 
102

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 

Analysis 
103

• 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 Analysis 
104

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 Burden 
105

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 Analysis 
106

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 Analyses 
107

• 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 Analysis 
108

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 Analyses 
110

• 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 Analysis 
111

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 Analyses 
113

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 Analysis 
114

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 Analyses 
116

• 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 (CO2) 

• Sulfur dioxide (SO2) 

– SO2 emissions from affected electric generating units are subject to nationwide and 

regional emissions cap and trading programs 

• Nitrogen oxides (NOx) 

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern States and 

DC

• Methane (CH4) 

• Nitrous Oxide (N2O)

• Mercury (Hg) 

Emissions Analysis 
117

• 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 CO2 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 NOx emissions 

resulting from the considered standard levels 

Monetization of Emission Reductions 
118

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 & Monetization 
119

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 Analyses 
120

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 Analyses 
121

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 
122

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