Energy Conservation Program: Energy Conservation Standards for Ceiling Fans
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Abstract
The Energy Policy and Conservation Act, as amended ("EPCA"), prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including ceiling fans. EPCA also requires the U.S. Department of Energy ("DOE") to periodically determine whether more-stringent, standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking ("NOPR"), DOE proposes new and amended energy conservation standards for ceiling fans, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
Full Text
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<title>Federal Register, Volume 88 Issue 119 (Thursday, June 22, 2023)</title>
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[Federal Register Volume 88, Number 119 (Thursday, June 22, 2023)]
[Proposed Rules]
[Pages 40932-41013]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-12957]
[[Page 40931]]
Vol. 88
Thursday,
No. 119
June 22, 2023
Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for Ceiling
Fans; Proposed Rule
Federal Register / Vol. 88 , No. 119 / Thursday, June 22, 2023 /
Proposed Rules
[[Page 40932]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2021-BT-STD-0011]
RIN 1904-AE99
Energy Conservation Program: Energy Conservation Standards for
Ceiling Fans
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and announcement of public
meeting.
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SUMMARY: The Energy Policy and Conservation Act, as amended (``EPCA''),
prescribes energy conservation standards for various consumer products
and certain commercial and industrial equipment, including ceiling
fans. EPCA also requires the U.S. Department of Energy (``DOE'') to
periodically determine whether more-stringent, standards would be
technologically feasible and economically justified, and would result
in significant energy savings. In this notice of proposed rulemaking
(``NOPR''), DOE proposes new and amended energy conservation standards
for ceiling fans, and also announces a public meeting to receive
comment on these proposed standards and associated analyses and
results.
DATES: Comments: DOE will accept comments, data, and information
regarding this NOPR no later than August 21, 2023.
Meeting: DOE will hold a public meeting via webinar on Thursday,
July 27, 2023 from 1:00 p.m. to 4:00 p.m. See section IV, ``Public
Participation,'' for webinar registration information, participant
instructions and information about the capabilities available to
webinar participants.'' Comments regarding the likely competitive
impact of the proposed standard should be sent to the Department of
Justice contact listed in the ADDRESSES section on or before August 21,
2023.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at <a href="http://www.regulations.gov">www.regulations.gov</a> under docket
number EERE-2021-BT-STD-0011. Follow the instructions for submitting
comments. Alternatively, interested persons may submit comments,
identified by docket number EERE-2021-BT-STD-0011, by any of the
following methods:
Email: <a href="/cdn-cgi/l/email-protection#b2f1d7dbdedbdcd5f4d3dcc180828083e1e6f682828383f2d7d79cd6ddd79cd5ddc4"><span class="__cf_email__" data-cfemail="317254585d585f5677505f4203010300626575010100007154541f555e541f565e47">[email protected]</span></a>. Include the docket number
EERE-2021-BT-STD-0011 in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
Hand Delivery/Courier: Appliance and Equipment Standards Program,
U.S. Department of Energy, Building Technologies Office, 1000
Independence Ave. SW, Washington, DC 20585. Telephone: (202) 287-1445.
If possible, please submit all items on a CD, in which case it is not
necessary to include printed copies.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section VII of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting documents/materials,
is available for review at <a href="http://www.regulations.gov">www.regulations.gov</a>. All documents in the
docket are listed in the <a href="http://www.regulations.gov">www.regulations.gov</a> index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
The docket web page can be found at <a href="http://www.regulations.gov/docket/EERE-2021-BT-STD-0011">www.regulations.gov/docket/EERE-2021-BT-STD-0011</a>. The docket web page contains instructions on how
to access all documents, including public comments, in the docket. See
section VII of this document for information on how to submit comments
through <a href="http://www.regulations.gov">www.regulations.gov</a>.
EPCA requires the Attorney General to provide DOE a written
determination of whether the proposed standard is likely to lessen
competition. The U.S. Department of Justice Antitrust Division invites
input from market participants and other interested persons with views
on the likely competitive impact of the proposed standard. Interested
persons may contact the Division at <a href="/cdn-cgi/l/email-protection#4a2f242f382d3364393e2b242e2b382e390a3f392e2520642d253c"><span class="__cf_email__" data-cfemail="c3a6ada6b1a4baedb0b7a2ada7a2b1a7b083b6b0a7aca9eda4acb5">[email protected]</span></a> on or
before the date specified in the DATES section. Please indicate in the
``Subject'' line of your email the title and Docket Number of this
proposed rulemaking.
FOR FURTHER INFORMATION CONTACT: Mr. Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 506-9870. Email:
<a href="/cdn-cgi/l/email-protection#d796a7a7bbbeb6b9b4b284a3b6b9b3b6a5b3a486a2b2a4a3beb8b9a497b2b2f9b3b8b2f9b0b8a1"><span class="__cf_email__" data-cfemail="79380909151018171a1c2a0d18171d180b1d0a280c1c0a0d1016170a391c1c571d161c571e160f">[email protected]</span></a>.
Mr. Nolan Brickwood, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 586-4498. Email:
<a href="/cdn-cgi/l/email-protection#b7d9d8dbd6d999d5c5ded4dcc0d8d8d3f7dfc699d3d8d299d0d8c1"><span class="__cf_email__" data-cfemail="8de3e2e1ece3a3efffe4eee6fae2e2e9cde5fca3e9e2e8a3eae2fb">[email protected]</span></a>.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact the Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: <a href="/cdn-cgi/l/email-protection#0b4a7b7b67626a65686e587f6a656f6a796f785a7e6e787f626465784b6e6e256f646e256c647d"><span class="__cf_email__" data-cfemail="216051514d48404f42447255404f45405345527054445255484e4f526144440f454e440f464e57">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Ceiling Fans
C. Deviation From Appendix A
III. General Discussion
A. General Comments
B. Product Classes and Scope of Coverage
C. Test Procedure
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC
and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Product Classes
a. Very Small Diameter Ceiling Fans
b. High-Speed Belt-Driven Ceiling Fans
c. High- and Low-Airflow Large-Diameter Ceiling Fans
d. Very-Close Mount Hugger Ceiling Fans
2. Test Procedure and Certification
3. Technology Options
a. Standard and Hugger Ceiling Fans
b. Large-Diameter Ceiling Fans
c. High-Speed Belt-Driven Ceiling Fans
d. Summary of Technology Options
B. Screening Analysis
1. Screened-Out Technologies
a. Standard and Hugger Ceiling Fans
[[Page 40933]]
b. Large-Diameter Ceiling Fans
2. Remaining Technologies
C. Engineering Analysis
1. Representative Units
2. Efficiency Analysis
a. Baseline Efficiency
b. Higher Efficiency Levels
c. Large-Diameter Ceiling Fan Standby Power
3. Cost Analysis
a. Hugger and Standard Ceiling Fans
b. Large-Diameter Ceiling Fans
c. High-Speed Belt-Driven Ceiling Fans
d. Manufacturer Mark-Up
4. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
1. Inputs for Standard and Hugger Ceiling Fans
a. Sample of Purchasers
b. Operating Hours
c. Power Consumption at Each Speed and Standby
2. Inputs for Large-Diameter and High-Speed Belt-Driven Ceiling
Fans
a. Sample of Purchasers
b. Operating Hours
c. Power Consumption at Each Speed and Standby
3. Impact on Air-Conditioning or Heating Equipment Use
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Product Lifetime
7. Discount Rates
a. Residential
b. Commercial and Industrial
8. Energy Efficiency Distributions in the No-New-Standards Case
and Each Standard Case
9. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. National Energy Savings
2. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Product and Capital Conversion Costs
d. Markup Scenarios
3. Manufacturer Interviews
4. Discussion of MIA Comments
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous Oxide
2. Monetization of Other Emissions Impacts
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Ceiling Fan
Standards
2. Annualized Benefits and Costs of the Proposed Standards
D. Reporting, Certification, and Sampling Plan
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, Rule
3. Description on Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements Including
Differences in Cost, if Any, for Different Groups of Small Entities
5. Duplication, Overlap, and Conflict With Other Rules and
Regulations
6. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Webinar
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
The Energy Policy and Conservation Act, Public Law 94-163, as
amended (``EPCA''),\1\ authorizes DOE to regulate the energy efficiency
of a number of consumer products and certain industrial equipment. (42
U.S.C. 6291-6317) Title III, Part B of EPCA \2\ established the Energy
Conservation Program for Consumer Products Other Than Automobiles. (42
U.S.C. 6291-6309) These products include ceiling fans, the subject of
this proposed rulemaking.
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\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020), which reflect the last statutory amendments that impact
Parts A and A-1 of EPCA.
\2\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
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Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that DOE determines is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new
or amended standard must result in a significant conservation of
energy. (42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later
than 6 years after issuance of any final rule establishing or amending
a standard, DOE must publish either a notice of determination that
standards for the product do not need to be amended, or a notice of
proposed rulemaking (``NOPR'') including new proposed energy
conservation standards (proceeding to a final rule, as appropriate).
(42 U.S.C. 6295(m))
In accordance with these and other statutory provisions discussed
in this document, DOE proposes amended energy conservation standards
for ceiling fans. The proposed standards, which are expressed in cubic
feet per minute per watt (``CFM/W'') for standard and hugger ceiling
fans and ceiling fan energy index (``CFEI'') for large-diameter ceiling
fans (``LDCFs'') and high-speed belt-driven (``HSBD'') ceiling fans,
are shown in Table I.1. These proposed standards, if adopted, would
apply to all ceiling fans listed in Table I.1 manufactured in, or
imported into, the United States starting on the date 3 years after the
publication of the final rule for this proposed rulemaking.
[[Page 40934]]
Table I.1--Proposed Energy Conservation Standards for Ceiling Fans
------------------------------------------------------------------------
Equipment class CFM/W
------------------------------------------------------------------------
Standard Ceiling Fans *........... D <=53 in.: 0.69 D + 53.25.
D >53 in.: 1.31 D + 52.08.
Hugger Ceiling Fans *............. D <=53 in.: 0.56 D + 48.75.
D >53 in.: 1.37 D + 38.5.
------------------------------------------------------------------------
CFEI
-------------------------------------
Large-Diameter Ceiling Fans....... 1.22 at high speed.
1.31 at 40 percent speed or the
nearest speed that is not less than
40 percent speed.
High-Speed Belt-Driven Ceiling 1.89 at high speed.
Fans.
------------------------------------------------------------------------
* D is the representative value of blade span as determined in
accordance with the DOE test procedure at appendix U to subpart B of
10 CFR part 430 and applicable sampling plans.
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of ceiling fans, as measured by the
average life-cycle cost (``LCC'') savings and the simple payback period
(``PBP'').\3\ The average LCC savings are positive for all product
classes, and the PBP is less than the average lifetime of ceiling fans,
which is estimated to be 14.6 years (see section IV.F.6 of this
document).
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\3\ The average LCC savings refer to consumers that are affected
by a standard and are measured relative to the efficiency
distribution in the no-new-standards case, which depicts the market
in the compliance year in the absence of new or amended standards
(see section IV.F.8 of this document). The simple PBP, which is
designed to compare specific efficiency levels, is measured relative
to the baseline product (see section IV.C of this document).
Table I.2--Impacts of Proposed Energy Conservation Standards on
Consumers of Ceiling Fans
[TSL 3]
------------------------------------------------------------------------
Average LCC Simple payback
Ceiling fan class savings period
($2022) (years)
------------------------------------------------------------------------
Standard................................ 16.69 4.1
Hugger.................................. 5.14 6.6
HSBD.................................... 663.92 2.1
Large-Diameter.......................... 68.20 5.8
------------------------------------------------------------------------
DOE's analysis of the impacts of the proposed standards on
consumers is described in section IV.F of this document.
B. Impact on Manufacturers
The industry net present value (``INPV'') is the sum of the
discounted cash flows to the industry from the base year through the
end of the analysis period (2023-2057). Using a real discount rate of
7.4 percent, DOE estimates that the INPV for manufacturers of ceiling
fans in the case without new and amended standards is $2,329 million in
2022$. Under the proposed standards, the change in INPV is estimated to
range from -4.4 percent to -1.8 percent, which is approximately -$101
million to -$43 million. In order to bring products into compliance
with new and amended standards, it is estimated that the industry would
incur total conversion costs of $107.2 million.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this document. The
analytic results of the manufacturer impact analysis (``MIA'') are
presented in section V.B.2 of this document.
C. National Benefits and Costs <SUP>4</SUP>
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\4\ All monetary values in this document are expressed in 2022
dollars.
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DOE's analyses indicate that the proposed energy conservation
standards for ceiling fans would save a significant amount of energy.
Relative to the case without new and amended standards, the lifetime
energy savings for ceiling fans purchased in the 30-year period that
begins in the anticipated first full year of compliance with the new
and amended standards (2028-2057) amount to 0.92 quadrillion British
thermal units (``Btu''), or quads,\5\ of full-fuel-cycle energy
savings. This represents a savings of 9 percent relative to the energy
use of these products in the case without new and amended standards
(referred to as the ``no-new-standards case'').
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\5\ The quantity refers to full-fuel-cycle (``FFC'') energy
savings. FFC energy savings includes the energy consumed in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and, thus, presents a more complete
picture of the impacts of energy efficiency standards. For more
information on the FFC metric, see section IV.H.1 of this document.
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The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for ceiling fans ranges from 1.84
billion USD (at a 7-percent discount rate) to 4.96 billion USD (at a 3-
percent discount rate). This NPV expresses the estimated total value of
future operating-cost savings minus the estimated increased product
costs for ceiling fans purchased in 2028-2057.
In addition, the proposed standards for ceiling fans are projected
to yield significant environmental benefits. DOE estimates that the
proposed standards would result in cumulative emission reductions (over
the same period as for energy savings) of 18.3 million metric tons
(``Mt'') \6\ of carbon dioxide (``CO<INF>2</INF>''), 4.5 thousand tons
of sulfur dioxide (``SO<INF>2</INF>''), 31.3 thousand tons of nitrogen
oxides (``NO<INF>X</INF>''), 141 thousand tons of methane
(``CH<INF>4</INF>''), 0.15 thousand tons of nitrous oxide
(``N<INF>2</INF>O''), and 0.03 tons of mercury (``Hg'').\7\
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\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO<INF>2</INF> are presented in short tons.
\7\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2023 (``AEO 2023''). AEO 2023 represents current Federal and
state legislation and final implementation of regulations as of the
time of its preparation. See section IV.K of this document for
further discussion of AEO 2023 assumptions that effect air pollutant
emissions.
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DOE estimates the value of climate benefits from a reduction in
greenhouse gases (GHG) using four different estimates of the social
cost of CO<INF>2</INF> (``SC-CO<INF>2</INF>''), the social cost of
methane (``SC-CH<INF>4</INF>''), and the social cost of nitrous oxide
(``SC-N<INF>2</INF>O''). Together these represent the social cost of
GHG (SC-GHG). DOE used interim SC-GHG values developed by an
Interagency Working Group on the Social Cost of Greenhouse Gases
(IWG).\8\ The
[[Page 40935]]
derivation of these values is discussed in section IV.L of this
document. For presentational purposes, the climate benefits associated
with the average SC-GHG at a 3-percent discount rate are estimated to
be $0.95 billion. DOE does not have a single central SC-GHG point
estimate and it emphasizes the importance and value of considering the
benefits calculated using all four sets of SC-GHG estimates.
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\8\ To monetize the benefits of reducing GHG emissions this
analysis uses the interim estimates presented in the Technical
Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990 published in February
2021 by the IWG. (``February 2021 SC-GHG TSD''). <a href="http://www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf">www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf</a>.
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DOE estimated the monetary health benefits of SO<INF>2</INF> and
NO<INF>X</INF> emissions reductions using benefit per ton estimates
from the scientific literature, as discussed in section IV.L of this
document. DOE estimated the present value of the health benefits would
be $0.6 billion using a 7-percent discount rate, and $1.7 billion using
a 3-percent discount rate.\9\ DOE is currently only monetizing (for
SO<INF>2</INF> and NO<INF>X</INF>) PM<INF>2.5</INF> precursor health
benefits and (for NO<INF>X</INF>) ozone precursor health benefits, but
will continue to assess the ability to monetize other effects such as
health benefits from reductions in direct PM<INF>2.5</INF> emissions.
---------------------------------------------------------------------------
\9\ DOE estimates the economic value of these emissions
reductions resulting from the considered TSLs for the purpose of
complying with the requirements of Executive Order 12866.
---------------------------------------------------------------------------
Table I.3 summarizes the monetized benefits and costs expected to
result from the proposed standards for ceiling fans. There are other
important unquantified effects, including certain unquantified climate
benefits, unquantified public health benefits from the reduction of
toxic air pollutants and other emissions, unquantified energy security
benefits, and distributional effects, among others.
Table I.3--Summary of Monetized Benefits and Costs of Proposed Energy
Conservation Standards for Ceiling Fans
[TSL 3]
------------------------------------------------------------------------
Billion 2022$
------------------------------------------------------------------------
3% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings......................... 6.43
Climate Benefits *...................................... 0.95
Health Benefits **...................................... 1.70
---------------
Total Benefits [dagger]............................... 9.08
Consumer Incremental Product Costs...................... 1.47
---------------
Net Benefits.......................................... 7.61
------------------------------------------------------------------------
7% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings......................... 2.66
Climate Benefits * (3% discount rate)................... 0.95
Health Benefits **...................................... 0.64
---------------
Total Benefits [dagger]............................... 4.25
Consumer Incremental Product Costs...................... 0.82
---------------
Net Benefits.......................................... 3.43
------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with ceiling
fans shipped in 2028-2057. These results include benefits to consumers
which accrue after 2028 from the products shipped in 2028-2057.
* Climate benefits are calculated using four different estimates of the
social cost of carbon (SC-CO2), methane (SC-CH4), and nitrous oxide
(SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent
discount rates; 95th percentile at 3 percent discount rate) (see
section IV.L of this document). Together these represent the global SC-
GHG. For presentational purposes of this table, the climate benefits
associated with the average SC-GHG at a 3 percent discount rate are
shown; however, DOE emphasizes the importance and value of considering
the benefits calculated using all four sets of SC-GHG estimates. To
monetize the benefits of reducing GHG emissions, this analysis uses
the interim estimates presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published in February 2021 by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX
and SO2. DOE is currently only monetizing (for SO2 and NOX) PM2.5
precursor health benefits and (for NOX) ozone precursor health
benefits, but will continue to assess the ability to monetize other
effects such as health benefits from reductions in direct PM2.5
emissions. See section IV.L of this document for more details.
[dagger] Total and net benefits include those consumer, climate, and
health benefits that can be quantified and monetized. For presentation
purposes, total and net benefits for both the 3-percent and 7-percent
cases are presented using the average SC-GHG with 3-percent discount
rate.
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The monetary values for the
total annualized net benefits are (1) the reduced consumer operating
costs, minus (2) the increase in product purchase prices and
installation costs, plus (3) the monetized value of climate and health
benefits of emission reductions, all annualized.\10\
---------------------------------------------------------------------------
\10\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2023, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur, and
then discounted the present value from each year to 2023. Using the
present value, DOE then calculated the fixed annual payment over a
30-year period, starting in the compliance year, that yields the
same present value.
---------------------------------------------------------------------------
The national operating cost savings are domestic private U.S.
consumer monetary savings that occur as a result of purchasing the
covered products and are measured for the lifetime of ceiling fans
shipped in 2028-2057. The benefits associated with reduced emissions
achieved as a result of the proposed standards are also calculated
based on the lifetime of ceiling fans shipped in 2028-2057. Total
benefits for both the 3-percent and 7-percent cases are presented using
the average GHG social costs with 3-percent discount rate. Estimates of
SC-GHG values are presented for all four discount rates in section
IV.L.1 of this document.
Table I.4 presents the total estimated monetized benefits and costs
associated with the proposed standard, expressed in terms of annualized
values. The results under the primary estimate are as follows.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced NO<INF>X</INF> and SO<INF>2</INF>
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated monetized cost of the
standards proposed in this rule is $86.6 million per year in increased
equipment costs, while the estimated annual benefits are $281.1 million
in reduced equipment operating costs, $54.7 million in monetized
climate benefits, and $67.5 million in monetized health benefits. In
this case the net monetized benefit would amount to $316.7 million per
year.
Using a 3-percent discount rate for all benefits and costs, the
estimated monetized cost of the proposed standards is $84.6 million per
year in increased equipment costs, while the estimated annual benefits
are $369.3 million in reduced operating costs, $54.7 million in
monetized climate benefits, and $97.5 million in monetized health
benefits. In this case, the net monetized benefit would amount to
$436.9 million per year.
[[Page 40936]]
Table I.4--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Ceiling Fans
[TSL 3]
----------------------------------------------------------------------------------------------------------------
Million 2022$/year
-----------------------------------------------
Low-net- High-net-
Primary benefits benefits
estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
3% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 369.3 343.9 387.6
Climate Benefits *.............................................. 54.7 52.4 55.5
Health Benefits **.............................................. 97.5 93.6 98.9
-----------------------------------------------
Total Monetized Benefits [dagger]............................... 521.4 489.9 542.1
Consumer Incremental Product Costs.............................. 84.6 85.8 81.3
-----------------------------------------------
Net Benefits.................................................... 436.9 404.1 460.7
----------------------------------------------------------------------------------------------------------------
7% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 281.1 263.2 294.3
Climate Benefits * (3% discount rate)........................... 54.7 52.4 55.5
Health Benefits **.............................................. 67.5 65.1 68.5
-----------------------------------------------
Total Monetized Benefits [dagger]............................... 403.3 380.7 418.3
Consumer Incremental Product Costs.............................. 86.6 87.7 83.6
-----------------------------------------------
Net Monetized Benefits.......................................... 316.7 293.0 334.7
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with ceiling fans shipped in 2028-2057. These
results include benefits to consumers which accrue after 2057 from the products shipped in 2028-2057. The
Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the AEO
2023 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. The methods used
to derive projected price trends are explained in sections IV.F.1 and IV.H.2 of this document. Note that the
Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this
notice). For presentational purposes of this table, the climate benefits associated with the average SC-GHG at
a 3 percent discount rate are shown; however, DOE emphasizes the importance and value of considering the
benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG
emissions, this analysis uses the interim estimates presented in the Technical Support Document: Social Cost
of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 published in February 2021
by the IWG.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for SO2 and NOX) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. See section IV.L of this document for more details.
[dagger] Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-
percent discount rate.
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this document.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. Specifically, with regards to
technological feasibility products achieving these standard levels are
already commercially available for all product classes covered by this
proposal. As for economic justification, DOE's analysis shows that the
benefits of the proposed standard exceed, to a great extent, the
burdens of the proposed standards.
Using a 7-percent discount rate for consumer benefits and costs and
NO<INF>X</INF> and SO<INF>2</INF> reduction benefits, and a 3-percent
discount rate case for GHG social costs, the estimated monetized cost
of the proposed standards for ceiling fans is $86.6 million per year in
increased ceiling fan costs, while the estimated annual monetized
benefits are $281.1 million in reduced ceiling fan operating costs,
$54.7 million in monetized climate benefits and $67.5 million in
monetized health benefits. The net monetized benefit amounts to $316.7
million per year.
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\11\ For
example, some covered products and equipment have substantial energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
products with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis.
---------------------------------------------------------------------------
\11\ Procedures, Interpretations, and Policies for Consideration
in New or Revised Energy Conservation Standards and Test Procedures
for Consumer Products and Commercial/Industrial Equipment, 86 FR
70892, 70901 (Dec. 13, 2021).
---------------------------------------------------------------------------
As previously mentioned, the standards are projected to result in
estimated national energy savings of 0.92 quad FFC for ceiling fans
shipped between 2028 and 2057, the equivalent of the primary annual
energy use of almost 10 million homes. In addition, they are projected
to reduce CO<INF>2</INF> emissions by 18.3 million metric tons for
ceiling fans shipped from 2028 to 2057.\12\ Based on these findings,
DOE has initially determined the energy savings from the proposed
standard levels are ``significant'' within the meaning of 42 U.S.C.
6295(o)(3)(B). A more detailed discussion of the basis for these
tentative conclusions is contained in the remainder of this document
and the accompanying technical support document.
---------------------------------------------------------------------------
\12\ These results include benefits to consumers which accrue
after 2057 from the products shipped in 2028-2057.
---------------------------------------------------------------------------
DOE also considered more-stringent energy efficiency levels as
potential
[[Page 40937]]
standards, and is still considering them in this rulemaking. However,
DOE has tentatively concluded that the potential burdens of the more-
stringent energy efficiency levels would outweigh the projected
benefits.
Based on consideration of the public comments DOE receives in
response to this document and related information collected and
analyzed during the course of this rulemaking effort, DOE may adopt
energy efficiency levels presented in this document that are either
higher or lower than the proposed standards, or some combination of
level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed rule, as well as some of the relevant
historical background related to the establishment of standards for
ceiling fans.
A. Authority
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. Title III, Part
B of EPCA established the Energy Conservation Program for Consumer
Products Other Than Automobiles. These products include ceiling fans,
the subject of this document. (42 U.S.C. 6292(a)(20)) This NOPR covers
those consumer products that meet the definition of ``ceiling fans''
codified at 10 CFR 430.2 as nonportable devices suspended from a
ceiling for circulating air via the rotation of fan blades. EPCA, as
amended, prescribed energy conservation standards for these products
and authorized DOE to consider energy efficiency or energy use
standards for the electricity used by ceiling fan to circulate air in a
room.\13\ (42 U.S.C. 6295(ff)(6))
---------------------------------------------------------------------------
\13\ While ceiling fans are often sold with light kits, this
notice only considers the electricity used by ceiling fans to
circulate air in a room. DOE evaluates energy efficiency standards
associated with ceiling fan light kits in a separate rulemaking
(Docket No. EERE-2019-BT-STD-0040).
---------------------------------------------------------------------------
EPCA further provides that, not later than 6 years after the
issuance of any final rule establishing or amending a standard, DOE
must publish either a notice of determination that standards for the
product do not need to be amended, or a NOPR including new proposed
energy conservation standards (proceeding to a final rule, as
appropriate). (42 U.S.C. 6295(m)(1))
The energy conservation program under EPCA consists essentially of
four parts: (1) testing, (2) labeling, (3) the establishment of Federal
energy conservation standards, and (4) certification and enforcement
procedures. Relevant provisions of EPCA specifically include
definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293),
labeling provisions (42 U.S.C. 6294), energy conservation standards (42
U.S.C. 6295), and the authority to require information and reports from
manufacturers (42 U.S.C. 6296).
Federal energy efficiency requirements for covered products
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of Federal
preemption for particular State laws or regulations, in accordance with
the procedures and other provisions set forth under EPCA. (See 42
U.S.C. 6297(d))
Subject to certain criteria and conditions, DOE is required to
develop test procedures to measure the energy efficiency, energy use,
or estimated annual operating cost of each covered product. (42 U.S.C.
6295(o)(3)(A) and 42 U.S.C. 6295(r)) Manufacturers of covered products
must use the prescribed DOE test procedure as the basis for certifying
to DOE that their products comply with the applicable energy
conservation standards adopted under EPCA and when making
representations to the public regarding the energy use or efficiency of
those products. (42 U.S.C. 6293(c) and 42 U.S.C. 6295(s)) Similarly,
DOE must use these test procedures to determine whether the products
comply with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) The
DOE test procedures for ceiling fans appear at title 10 of the Code of
Federal Regulations (``CFR'') part 430, subpart B, appendix U.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products, including ceiling fans. Any new
or amended standard for a covered product must be designed to achieve
the maximum improvement in energy efficiency that the Secretary of
Energy determines is technologically feasible and economically
justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(3)(B))
Furthermore, DOE may not adopt any standard that would not result in
the significant conservation of energy. (42 U.S.C. 6295(o)(3))
Moreover, DOE may not prescribe a standard: (1) for certain
products, including ceiling fans, if no test procedure has been
established for the product, or (2) if DOE determines by rule that the
standard is not technologically feasible or economically justified. (42
U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is
economically justified, DOE must determine whether the benefits of the
standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make
this determination after receiving comments on the proposed standard,
and by considering, to the greatest extent practicable, the following
seven statutory factors:
(1) The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result from the standard;
(3) The total projected amount of energy (or as applicable, water)
savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered
products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (``Secretary'') considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA establishes a rebuttable presumption that a standard
is economically justified if the Secretary finds that the additional
cost to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an ``anti-backsliding''
provision, which prevents the Secretary from prescribing any amended
standard that either increases the maximum allowable energy use or
decreases the minimum required energy efficiency of a covered product.
(42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended
or new standard if interested persons have established by a
preponderance of the evidence that the standard is likely to result in
the unavailability in the United States in any covered product type (or
class) of performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as those
[[Page 40938]]
generally available in the United States. (42 U.S.C. 6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for a covered product that has two or more
subcategories. DOE must specify a different standard level for a type
or class of product that has the same function or intended use, if DOE
determines that products within such group: (A) consume a different
kind of energy from that consumed by other covered products within such
type (or class); or (B) have a capacity or other performance-related
feature which other products within such type (or class) do not have
and such feature justifies a higher or lower standard. (42 U.S.C.
6295(q)(1)) In determining whether a performance-related feature
justifies a different standard for a group of products, DOE must
consider such factors as the utility to the consumer of the feature and
other factors DOE deems appropriate. Id. Any rule prescribing such a
standard must include an explanation of the basis on which such higher
or lower level was established. (42 U.S.C. 6295(q)(2))
Finally, pursuant to the amendments contained in the Energy
Independence and Security Act of 2007 (``EISA 2007''), Pub. L. 110-140,
any final rule for new or amended energy conservation standards
promulgated after July 1, 2010, is required to address standby mode and
off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE
adopts a standard for a covered product after that date, it must, if
justified by the criteria for adoption of standards under EPCA (42
U.S.C. 6295(o)), incorporate standby mode and off mode energy use into
a single standard, or, if that is not feasible, adopt a separate
standard for such energy use for that product. (42 U.S.C.
6295(gg)(3)(A)-(B)) DOE's current test procedures for ceiling fans does
address measuring standby mode and off mode energy use. In this
rulemaking, for small-diameter ceiling fans \14\ DOE intends to
incorporate such energy use into any amended energy conservation
standards that it may adopt. For LDCFs \15\ and HSBD ceiling fans, DOE
has determined that incorporating this energy use into a single
standard and establishing a separate standard is not justified under 42
U.S.C. 6295(o).
---------------------------------------------------------------------------
\14\ A small-diameter ceiling fan is a ceiling fan that is less
than or equal to seven feet in diameter. 10 CFR part 430 subpart B
appendix U section 1.18.
\15\ A large-diameter ceiling fan is a ceiling fan that is
greater than seven feet in diameter. 10 CFR part 430 subpart B
appendix U section 1.12.
---------------------------------------------------------------------------
B. Background
1. Current Standards
In a final rule published on October 18, 2005, DOE codified the
design standards prescribed by EPCA for ceiling fans. 70 FR 60407,
60413. These standards are set forth in DOE's regulations at 10 CFR
430.32(s)(1) and require all ceiling fans manufactured on or after
January 1, 2007, to have: (1) fan speed controls separate from any
lighting controls; (2) adjustable speed controls (either more than one
speed or variable speed); and (3) the capability for reverse action
(other than fans sold for industrial or outdoor application or where
safety would be an issue). (42 U.S.C. 6295(ff)(1)(A))
In a final rule published on January 19, 2017, (``January 2017 ECS
Final Rule''), DOE prescribed the current energy conservation standards
for ceiling fans manufactured in, or imported into, the United States
on and after January 21, 2020. 82 FR 6826, 6827.
On December 27, 2020, the Energy Act of 2020 (Pub. L. 116-260) was
signed into law. The Energy Act of 2020 amended performance standards
for LDCFs. (42 U.S.C. 6295(ff)(6)(C)(i), as codified) Pursuant to the
Energy Act of 2020, LDCFs are subject to standards in terms of the CFEI
metric, with one standard based on operation of the fan at high speed
and a second standard based on operation of the fan at 40 percent speed
or the nearest speed that is not less than 40 percent speed. (42 U.S.C.
6295(ff)(6)(C)(i), as codified)
On May 27, 2021, DOE published a final rule to amend the current
regulations for LDCFs (``May 2021 Technical Amendment''). 86 FR 28469.
The May 2021 Technical Amendment was published to codify provisions
enacted by Congress through the Energy Act of 2020. Specifically,
section 1008 of the Energy Act of 2020 amended section 325(ff)(6) of
EPCA to specify that LDCFs manufactured on or after January 21, 2020,
are not required to meet minimum ceiling fan efficiency requirements in
terms of the ratio of the total airflow to the total power consumption,
as established in the January 2017 ECS Final Rule, and instead are
required to meet specified minimum efficiency requirements based on the
CFEI metric. 86 FR 28469, 28469-28470. On November 28, 2022, DOE also
published a final rule to implement the full scope of standards for
LDCFs as set forth in the Energy Act of 2020. 86 FR 72863.
The current standards are set forth in DOE's regulations at 10 CFR
430.32(s) and are summarized in Table II.1.
Table II.1--Current Federal Energy Conservation Standards for Ceiling
Fans
------------------------------------------------------------------------
Product class as defined in appendix U [of Minimum efficiency (CFM/W)
10 CFR 430.32(s)] \1\
------------------------------------------------------------------------
Very small diameter (VSD)................. D <=12 in.: 21.
D >12 in.: 3.16D-17.04.
Standard.................................. 0.65D + 38.03.
Hugger.................................... 0.29D + 34.46.
High-speed small diameter (HSSD).......... 4.16D + 0.02.
------------------------------------------------------------------------
Minimum Efficiency (CFEI)
-----------------------------
Large-diameter ceiling fans (LDCFs)....... 1.00 at high speed.
1.31 at 40 percent speed or
the nearest speed that is
not less than 40 percent
speed.
------------------------------------------------------------------------
\1\ D is the ceiling fan's blade span, in inches, as determined in
Appendix U of [10 CFR 430.32(s)].
2. History of Standards Rulemaking for Ceiling Fans
On May 7, 2021, DOE published a notice that it was initiating an
early assessment review to determine whether any new or amended
standards would satisfy the relevant requirements of EPCA for a new or
amended energy conservation standard for ceiling fans and a request for
information (``RFI''). 86 FR 24538 (``May 2021 RFI'').
On February 10, 2022, DOE published a notice of public webinar and
availability of preliminary technical support document (``TSD''). 87 FR
7758 (``February 2022 Preliminary Analysis''). The purpose of the
February 2022 Preliminary Analysis was to make publicly available the
initial technical and economic analyses conducted for ceiling fans and
present initial results of those analyses. DOE held the public webinar
on March 16, 2022, to present its preliminary analysis and to seek
comments from interested parties.
DOE received comments in response to the February 2022 Preliminary
Analysis from the interested parties listed in Table II.2.
[[Page 40939]]
Table II.2--February 2022 Preliminary Analysis Written Comments
----------------------------------------------------------------------------------------------------------------
Comment number
Commenter(s) Abbreviation in the docket Commenter type
----------------------------------------------------------------------------------------------------------------
American Lighting Association........... ALA....................... 26 Trade Association.
Air Movement and Control Association.... AMCA...................... 23 Trade Association.
Pacific Gas and Electric Company, CA IOUs................... 22 Utilities.
Southern California Edison, San Diego
Gas & Electric Company.
Appliance Standards Awareness Project, Efficiency Advocates...... 25 Efficiency Organizations.
American Council for an Energy-
Efficient Economy, Natural Resources
Defense Council, New York State Energy
Research and Development Authority.
Lutron Electronics Co................... Lutron.................... 24 Controller Manufacturer.
Northwest Energy Efficiency Alliance.... NEEA...................... 27 Efficiency Organization.
----------------------------------------------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\16\
To the extent that interested parties have provided written comments
that are substantively consistent with any oral comments provided
during the March 2022 public meeting, DOE cites the written comments
throughout this document. Any oral comments provided during the webinar
that are not substantively addressed by written comments are summarized
and cited separately throughout this document.
---------------------------------------------------------------------------
\16\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for ceiling fans. (Docket No. EERE-
2021-BT-STD-0011, which is maintained at <a href="http://www.regulations.gov">www.regulations.gov</a>). The
references are arranged as follows: (commenter name, comment docket
ID number, page of that document).
---------------------------------------------------------------------------
C. Deviation From Appendix A
In accordance with section 3(a) of 10 CFR part 430, subpart C,
appendix A (``appendix A''), DOE notes that it is deviating from the
provision in appendix A regarding the NOPR stage for an energy
conservation standard rulemaking. Section 6(f)(2) of appendix A
specifies that the length of the public comment period for a NOPR will
vary depending upon the circumstances of the particular rulemaking, but
will not be less than 75 calendar days. DOE is opting to deviate from
this step by providing a 60-day comment period. As previously
discussed, DOE requested comment on its analytical approach in section
ES.3 of the February 2022 Preliminary Analysis TSD and provided
stakeholders with a 60-day comment period. Given that this NOPR relies
largely on the same analytical approach taken in the February 2022
Preliminary Analysis, DOE believes a 60-day comment period is
appropriate and will provide interested parties with a meaningful
opportunity to comment on the proposed rule.
III. General Discussion
DOE developed this proposal after considering oral and written
comments, data, and information from interested parties that represent
a variety of interests. The following discussion addresses issues
raised by these commenters.
A. General Comments
This section summarizes general comments received from interested
parties regarding rulemaking timing and process.
NEEA commented generally that they support DOE's continued
development of energy conservation standards and use of transparent and
comparable efficiency metrics to encourage market adoption of efficient
products. (NEEA, No. 27 at p. 1)
B. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered products into product classes by the type of energy
used or by capacity or other performance-related features that justify
differing standards. In determining whether a performance-related
feature justifies a different standard, DOE must consider such factors
as the utility of the feature to the consumer and other factors DOE
determines are appropriate. (42 U.S.C. 6295(q)) This NOPR covers those
consumer products that meet the definition of ``ceiling fans,'' as
codified at 10 CFR 430.2. See section IV.A.1 of this document for
discussion of the scope of coverage and product classes analyzed in
this NOPR.
C. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product. DOE's
current energy conservation standards for ceiling fans are expressed in
terms of CFM/W and CFEI. (See 10 CFR 430.32(s)(2).)
D. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the products or equipment that are the subject of the
rulemaking. As the first step in such an analysis, DOE develops a list
of technology options for consideration in consultation with
manufacturers, design engineers, and other interested parties. DOE then
determines which of those means for improving efficiency are
technologically feasible. DOE considers technologies incorporated in
commercially-available products or in working prototypes to be
technologically feasible. Sections 6(b)(3)(i) and 7(b)(1) of appendix A
to 10 CFR part 430 subpart C (``Process Rule'').
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; (3) adverse impacts on
health or safety, and (4) unique-pathway proprietary technologies.
Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of the Process Rule. Section
IV.B of this document discusses the results of the screening analysis
for ceiling fans,
[[Page 40940]]
particularly the designs DOE considered, those it screened out, and
those that are the basis for the standards considered in this proposed
rulemaking. For further details on the screening analysis for this
rulemaking, see chapter 4 of the NOPR technical support document
(``TSD'').
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max-tech'') improvements in energy efficiency for ceiling
fans, using the design parameters for the most efficient products
available on the market or in working prototypes. The max-tech levels
that DOE determined for this rulemaking are described in section IV.C
of this proposed rule and in chapter 5 of the NOPR TSD.
E. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to ceiling fans purchased in the
30-year period that begins in the first full year of compliance with
the proposed standards (2028-2057).\17\ The savings are measured over
the entire lifetime of ceiling fans purchased in the previous 30-year
period. DOE quantified the energy savings attributable to each TSL as
the difference in energy consumption between each standards case and
the no-new-standards case. The no-new-standards case represents a
projection of energy consumption that reflects how the market for a
product would likely evolve in the absence of amended energy
conservation standards.
---------------------------------------------------------------------------
\17\ Each TSL is composed of specific efficiency levels for each
product class. The TSLs considered for this NOPR are described in
section V.A of this document. DOE conducted a sensitivity analysis
that considers impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (``NIA'') python programming
language model to estimate national energy savings (``NES'') from
potential amended or new standards for ceiling fans. The NIA python
programming language model (described in section IV.H of this document)
calculates energy savings in terms of site energy, which is the energy
directly consumed by products at the locations where they are used. For
electricity, DOE reports national energy savings in terms of primary
energy savings, which is the savings in the energy that is used to
generate and transmit the site electricity. DOE also calculates NES in
terms of FFC energy savings. The FFC metric includes the energy
consumed in extracting, processing, and transporting primary fuels
(i.e., coal, natural gas, petroleum fuels), and thus presents a more
complete picture of the impacts of energy conservation standards.\18\
DOE's approach is based on the calculation of an FFC multiplier for
each of the energy types used by covered products or equipment. For
more information on FFC energy savings, see section IV.H.1 of this
document.
---------------------------------------------------------------------------
\18\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as
amended at 77 FR 49701 (Aug. 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE
must determine that such action would result in significant energy
savings. (42 U.S.C. 6295(o)(3)(B))
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\19\ For
example, some covered products and equipment have most of their energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
products with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis, taking into
account the significance of cumulative FFC national energy savings, the
cumulative FFC emissions reductions, and the need to confront the
global climate crisis, among other factors. DOE has initially
determined the energy savings from the proposed standard levels are
``significant'' within the meaning of 42 U.S.C. 6295(o)(3)(B).
---------------------------------------------------------------------------
\19\ The numeric threshold for determining the significance of
energy savings established in a final rule published on February 14,
2020 (85 FR 8626, 8670), was subsequently eliminated in a final rule
published on December 13, 2021 (86 FR 70892).
---------------------------------------------------------------------------
F. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides seven factors to be evaluated in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) The
following sections discuss how DOE has addressed each of those seven
factors in this proposed rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on
manufacturers, DOE conducts an MIA, as discussed in section IV.J of
this document. DOE first uses an annual cash-flow approach to determine
the quantitative impacts. This step includes both a short-term
assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period. The industry-wide impacts analyzed include (1) INPV, which
values the industry on the basis of expected future cash flows, (2)
cash flows by year, (3) changes in revenue and income, and (4) other
measures of impact, as appropriate. Second, DOE analyzes and reports
the impacts on different types of manufacturers, including impacts on
small manufacturers. Third, DOE considers the impact of standards on
domestic manufacturer employment and manufacturing capacity, as well as
the potential for standards to result in plant closures and loss of
capital investment. Finally, DOE takes into account cumulative impacts
of various DOE regulations and other regulatory requirements on
manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and PBP associated with new or amended standards. These
measures are discussed further in the following section. For consumers
in the aggregate, DOE also calculates the national net present value of
the consumer costs and benefits expected to result from particular
standards. DOE also evaluates the impacts of potential standards on
identifiable subgroups of consumers that may be affected
disproportionately by a standard.
b. Savings in Operating Costs Compared To Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a standard. (42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP
analysis.
The LCC is the sum of the purchase price of a product (including
its
[[Page 40941]]
installation) and the operating expense (including energy, maintenance,
and repair expenditures) discounted over the lifetime of the product.
The LCC analysis requires a variety of inputs, such as product prices,
product energy consumption, energy prices, maintenance and repair
costs, product lifetime, and discount rates appropriate for consumers.
To account for uncertainty and variability in specific inputs, such as
product lifetime and discount rate, DOE uses a distribution of values,
with probabilities attached to each value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of a more-efficient product through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered products in the first full year of compliance with
new or amended standards. The LCC savings for the considered efficiency
levels are calculated relative to the case that reflects projected
market trends in the absence of new or amended standards. DOE's LCC and
PBP analysis is discussed in further detail in section IV.F of this
document.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section III.D of this document, DOE uses the NIA python
programming language model to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data
available to DOE, the standards proposed in this document would not
reduce the utility or performance of the products under consideration
in this proposed rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from a proposed standard. (42 U.S.C.
6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine
the impact, if any, of any lessening of competition likely to result
from a proposed standard and to transmit such determination to the
Secretary within 60 days of the publication of a proposed rule,
together with an analysis of the nature and extent of the impact. (42
U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed
rule to the Attorney General with a request that the Department of
Justice (``DOJ'') provide its determination on this issue. DOE will
publish and respond to the Attorney General's determination in the
final rule. DOE invites comment from the public regarding the
competitive impacts that are likely to result from this proposed rule.
In addition, stakeholders may also provide comments separately to DOJ
regarding these potential impacts. See the ADDRESSES section for
information to send comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water
conservation in determining whether a new or amended standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy
savings from the proposed standards are likely to provide improvements
to the security and reliability of the Nation's energy system.
Reductions in the demand for electricity also may result in reduced
costs for maintaining the reliability of the Nation's electricity
system. DOE conducts a utility impact analysis to estimate how
standards may affect the Nation's needed power generation capacity, as
discussed in section IV.M of this document.
DOE maintains that environmental and public health benefits
associated with the more efficient use of energy are important to take
into account when considering the need for national energy
conservation. The proposed standards are likely to result in
environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases (``GHGs'') associated with energy
production and use. DOE conducts an emissions analysis to estimate how
potential standards may affect these emissions, as discussed in section
IV.K of this document; the estimated emissions impacts are reported in
section V.B.6 of this document. DOE also estimates the economic value
of emissions reductions resulting from the considered TSLs, as
discussed in section IV.L of this document.
g. Other Factors
In determining whether an energy conservation standard is
economically justified, DOE may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To
the extent DOE identifies any relevant information regarding economic
justification that does not fit into the other categories described
previously, DOE could consider such information under ``other
factors.''
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effects that proposed
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the 3-year
payback period contemplated under the rebuttable-presumption test. In
addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the Nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable presumption payback calculation
is discussed in section V.B.1.c of this proposed rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
rulemaking with regard to ceiling fans. Separate subsections address
each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential
[[Page 40942]]
amended or new energy conservation standards. The national impacts
analysis uses a second spreadsheet set that provides shipments
projections and calculates national energy savings and net present
value of total consumer costs and savings expected to result from
potential energy conservation standards. DOE uses the third spreadsheet
tool, the Government Regulatory Impact Model (``GRIM''), to assess
manufacturer impacts of potential standards. These three spreadsheet
tools are available on the DOE website for this rulemaking:
<a href="http://www.regulations.gov/docket/EERE-2021-BT-STD-0011">www.regulations.gov/docket/EERE-2021-BT-STD-0011</a>. Additionally, DOE
used output from the latest version of the Energy Information
Administration's (``EIA's'') Annual Energy Outlook (``AEO''), a widely
known energy projection for the United States, for the emissions and
utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the products
concerned, including the purpose of the products, the industry
structure, manufacturers, market characteristics, and technologies used
in the products. This activity includes both quantitative and
qualitative assessments, based primarily on publicly-available
information. The subjects addressed in the market and technology
assessment for this rulemaking include (1) a determination of the scope
of the rulemaking and product classes, (2) manufacturers and industry
structure, (3) existing efficiency programs, (4) shipments information,
(5) market and industry trends; and (6) technologies or design options
that could improve the energy efficiency of ceiling fans. The key
findings of DOE's market assessment are summarized in the following
sections. See chapter 3 of the NOPR TSD for further discussion of the
market and technology assessment.
1. Product Classes
When evaluating and establishing energy conservation standards, DOE
may establish separate standards for a group of covered products (i.e.,
establish a separate product class) if DOE determines that separate
standards are justified based on the type of energy used, or if DOE
determines that a product's capacity or other performance-related
feature justifies a different standard. (42 U.S.C. 6295(q)) In making a
determination whether a performance-related feature justifies a
different standard, DOE must consider such factors as the utility of
the feature to the consumer and other factors DOE determines are
appropriate. (Id.)
DOE currently defines separate energy conservation standards for
the following ceiling fan product classes: hugger, standard, very small
diameter (``VSD''), high-speed small diameter (``HSSD''), and LDCF. 10
CFR 430.32(s)(2).
In section 2.2 of the February 2022 Preliminary Analysis TSD, DOE
requested comment on VSD ceiling fans, HSBD ceiling fans, high- and
low-airflow LDCFs, and very-close mount hugger ceiling fans. These
comments are discussed in detail as follows:
a. Very Small Diameter Ceiling Fans
A VSD ceiling fan is defined as a small-diameter ceiling fan less
than or equal to 18 inches. Appendix U to subpart B of part 430
(``appendix U''). On August 16, 2022, DOE published a test procedure
final rule for ceiling fans (``August 2022 TP Final Rule''). 87 FR
50396. The August 2022 TP Final Rule amended the definition of ceiling
fan to clarify that a ceiling fan must provide circulating air, and
clarified that ``a ceiling fan that has a ratio of fan blade span (in
inches) to maximum rotation rate (in revolutions per minute) greater
than 0.06 provides circulating air.'' Id. at 87 FR 50402.
DOE included VSD fans in the February 2022 Preliminary Analysis,
but in section 2.2.1 of the preliminary analysis TSD stated that all
VSD fans DOE was aware of had a diameter-to-maximum operating speed
ratio of less than or equal to 0.06 inches to revolutions per minute
(``in/RPM''). Therefore, with the amended definition of ``circulating
air'', DOE expected that there would no longer be any ceiling fans on
the market that would meet the definition of a VSD ceiling fan. In the
February 2022 Preliminary Analysis, DOE requested comment on its
observation that all VSD ceiling fans would have a diameter-to-maximum
operating speed ratio of less than or equal to 0.06 in/RPM.
In response, ALA supported delineating air circulating fan heads
from ceiling fans using the 0.06 ratio, and provided data that shows a
distinct difference in the ratio for air circulating fan heads and
ceiling fans. (ALA, No. 26 at p. 7) The Efficiency Advocates encouraged
DOE to cover VSD ceiling fans in the fans and blowers rulemaking.
(Efficiency Advocates, No. 25 at p. 3)
DOE notes that comments related to scope and definitions for fans
and blowers are available at Docket No. EERE-2021-BT-TP-0021. DOE did
not receive any comments identifying VSD fans that exceed the 0.06
ratio. Further, DOE notes that the maximum diameter for a VSD fan is 18
inches. Based on the 0.06 ratio, a VSD fan would have to operate at a
maximum of 300 rpm to meet the definition of circulating air and
therefore meet the definition of a ceiling fan. Most fans with blade
spans 18 inches or less on the market advertise blade speeds greater
than 1,000 rpm.
In theory, a ceiling fan could exist that meets the definition of
both circulating air and VSD ceiling fan. In that case, the DOE test
procedure at appendix U to subpart B of part 430 would be applicable,
and the current energy conservation standards for VSD ceiling fans at
10 CFR 430.32(s)(2) would apply. However, DOE does not expect fans to
enter the market that meet the definition of both ceiling fan and VSD
ceiling fan because a fan with a blade span of 18 inches or less
spinning at fewer than 300 rpm would provide limiting cooling utility
for consumers. As such, for this NOPR, DOE has assumed that VSD ceiling
fan shipments are zero, and has not evaluated amended energy
conservation standards for VSD ceiling fans.
DOE requests comment on its assumption that there are zero products
on the market that meet the definition of both ceiling fan and VSD
ceiling fan, and its decision not to evaluate amended energy
conservation standards for VSD ceiling fans on that basis.
b. High-Speed Belt-Driven Ceiling Fans
Belt-driven ceiling fans are defined as ``a ceiling fan with a
series of one or more fan heads, each driven by a belt connected to one
or more motors that are located outside of the fan head.'' Appendix U
to subpart B of part 430. On July 25, 2016, DOE published a test
procedure final rule (``July 2016 TP Final Rule''), in which it stated
it would not propose standards for belt-driven ceiling fans due to the
limited number of basic models and lack of available data. 81 FR 48619,
48622. In the January 2017 ECS Final Rule, DOE noted that belt-driven
ceiling fans were generally highly customizable, and that customers can
decide on the number of fan heads, distance from the motor to the fan
head, and type of belt. (See chapter 3 of the January 2017 ECS Final
Rule TSD). While DOE did establish a definition and product class,
belt-driven ceiling fans were exempt from the test procedure, and
energy conservation standards were therefore not established. 81 FR
48619, 48622, 48624.
In response to the May 2021 RFI, BAF \20\ and AMCA commented that a
new type of belt-driven ceiling fan that
[[Page 40943]]
uses a larger motor and higher tip speeds has recently entered the
market. (BAF, No. 14 at p. 2; AMCA, No. 9 at p. 4) BAF and AMCA
recommended that DOE create a high-speed product class and a low-speed
product class for these belt-driven ceiling fans. Id. BAF and AMCA
additionally suggested that the HSBD ceiling fans be subject to testing
according to the American National Standards Institute (``ANSI'')/AMCA
Standard 230-15 ``Laboratory Methods of Testing Air Circulating Fans
for Rating and Certification'' (``AMCA 230-15''). Id. BAF also
recommended that HSBD ceiling fans be subject to energy conservation
standards, but that low-speed belt-driven ceiling fans should be
exempted. (BAF, No. 14 at p. 2) The CA IOUs identified one of these
HSBD ceiling fans (drum-type circulating ceiling fan) and asked DOE to
clarify whether industrial belt-driven fans are covered as ceiling fans
or as fans and blowers. (CA IOUs, No. 12 at p. 4-5)
---------------------------------------------------------------------------
\20\ This notice uses BAF to refer to comments from Big Ass
Fans, a manufacturer of ceiling fans.
---------------------------------------------------------------------------
In its August 2022 TP Final Rule, DOE defined HSBD ceiling fan,
stated that these fans shall be tested according to AMCA 230-15, and
stated that HSBD ceiling fans will use the CFEI metric. 87 FR 50396.
DOE did not establish separate definitions for small- and large-
diameter HSBD fans, but rather included all HSBD ceiling fans into one
definition. Id. at 87 FR 50404. DOE notes that belt-driven ceiling fans
that do not meet the definition of HSBD remain exempt from the DOE test
procedure. See appendix U.
DOE notes that a ceiling fan must be ``distributed in commerce with
components that enable it to be suspended from a ceiling.'' 87 FR
50396, 50402. Belt-driven fans are often distributed in commerce
without components that enable the fan to be suspended from a ceiling.
For example, some belt-driven fans are sold connected to wheels or to a
pedestal base. In this case, such a fan would not meet the definition
of a ceiling fan because it has not been manufactured to be suspended
from the ceiling, and therefore would not be subject to the HSBD test
procedure or any potential energy conservation standards even though a
consumer could independently purchase their own straps or chains and
elect to hang this fan from the ceiling.
HSBD fans in contrast, are distributed in commerce with specific
straps, chains, or other similar components that are designed and
tested by the manufacturer to safely support the weight of the ceiling
fan in an overhead configuration. Further, they circulate air, since
they meet the 0.06 blade span to maximum rpm ratio.
Many belt-driven fans are housed (meaning the fan blades are
contained within a cylindrical enclosure, often with solid metal sides
and a cage on the front and back); however, the presence of a housing
is not relevant in determining whether a product meets the definition
of ceiling fan. While a housing is generally included to better direct
air, a housing could be added to a ceiling fan, including those that
are clearly intended to circulate air. As such, DOE emphasizes that the
definition of a ceiling fan requires that fan to be ``suspended from a
ceiling'' and to ``circulate air'', rather than the presence or absence
of a fan housing.
In this NOPR, DOE has evaluated potential energy conservation
standards for HSBD ceiling fans.
c. High- and Low-Airflow Large-Diameter Ceiling Fans
BAF and AMCA previously commented that two product classes,
separated based on airflow, may be justified for LDCFs to reflect
unique characteristics for products intended for commercial versus
industrial applications. (BAF, No. 14 at p. 2; AMCA, No. 9 at p. 7). In
response to these comments, DOE considered whether to establish
separate high-airflow and low-airflow product classes for LDCFs in
section 2.4.1.1 of its February 2022 Preliminary Analysis TSD.
In response, the CA IOUs, AMCA, and NEEA all commented that DOE
should not divide the LDCF product class into separate high- and low-
airflow classes because doing so would not provide any benefit or be
warranted by differences in features or technology. (AMCA, No. 23 at
pp. 2-4; NEEA, No. 27 at p. 2; CA IOUs, No. 22 at pp. 2-4) The CA IOUs
provided results from a study they conducted that analyzed the
performance data of 90 AMCA-certified LDCFs. (CA IOUs, No. 22 at pp. 2-
4) The results showed that 66 percent of fans were included in the low-
airflow class and that many were near the airflow cutoff between the
two classes that DOE defined in the February 2022 Preliminary Analysis.
Id. They noted that slight changes in fan speed could therefore cause a
fan to move from one class into another. Id. The CA IOUs suggested that
the similarity in the airflow data therefore indicated that it is
unnecessary to separate low- and higher-airflow fans, and that if
different energy conservation standards were used for the two classes
it could result in market distortion. Id. Additionally, the results
also showed that commercial LDCFs generally had a higher CFEI than
industrial LDCFs, which the CA IOUs attributed to commercial LDCFs
often using more efficient motors. They stated that these results also
indicate that airflow is not a driver of efficiency for LDCFs. Id.
To establish a separate product class, DOE must determine that a
product has a capacity or other performance-related feature which other
covered products do not have, and that such feature justifies a
different standard through the feature's utility to the consumer and
other factors. (42 U.S.C. 6295(q)) DOE reviewed the data provided by
the CA IOUs and manufacturer literature and found that while some fans
are marketed for lower airflow and commercial applications, and that
others are marketed for higher-airflow, DOE agrees with commenters that
there is not a clear performance-related distinction between the two.
Therefore, DOE did not evaluate low- and high-airflow LDCFs as separate
product classes in this analysis.
d. Very-Close Mount Hugger Ceiling Fans
Hugger ceiling fans offer consumer utility since they have less
distance between the ceiling fan blades and the ceiling. This allows
them to be installed in applications with lower ceilings, where a
standard ceiling fan with a down rod could be a safety issue or would
not be desirable to consumers.
In section 2.4.1.1 of the February 2022 Preliminary Analysis TSD,
DOE discussed that moving a hugger fan further from the ceiling could
increase airflow without an associated increase in power consumption,
although this would be at the expense of consumer preferences for a
very-close mounted fan. DOE requested comment on whether consumers
consider all hugger ceiling fans equal, or if there is additional
consumer utility associated with hugger fans that are closer to the
ceiling.
ALA commented that there is no additional utility associated with
hugger fans that are closer to the ceiling and encouraged DOE to
maintain only one product class for hugger ceiling fans as doing so
would avoid the need for additional testing. (ALA, No. 26 at p. 9) DOE
did not receive any comment suggesting that very-close mount hugger
fans warranted a separate equipment class.
In this NOPR, DOE did not further evaluate a separate product class
for ceiling fans that are closer to the ceiling. However, DOE did
modify its engineering analysis for hugger ceiling fans to reflect that
moving a hugger fan further from the ceiling (although still less than
or equal to 10 inches from the
[[Page 40944]]
ceiling) represents a possible path toward meeting higher efficiency
standards. This is discussed in greater detail in section IV.C of this
document.
2. Test Procedure and Certification
DOE's test procedure for measuring the energy efficiency of ceiling
fans is available at appendix U and requirements for certification in
DOE's compliance certification database (``CCD'') specific to ceiling
fans are provided at 10 CFR 429.32. In section 2.3 of the February 2022
Preliminary Analysis TSD, DOE stated that proposed rules had been
issued to amend both the ceiling fan test procedure and ceiling fan
certification requirements. Since the February 2022 Preliminary
Analysis, the August 2022 TP Final Rule (87 FR 50396) and a
certification Final Rule (``July 2022 Certification Final Rule'') (87
FR 43952) have published, and updates were included in their respective
sections of the CFR.
In response to the February 2022 Preliminary Analysis, stakeholders
commented on test procedure and certification issues. These comments
are summarized and addressed as follows.
Regarding the test procedure for LDCFs, NEEA commented that they
generally support use of the CFEI metric for LDCFs. (NEEA, No. 27 at
pp. 1-2) AMCA recommended that DOE define a minimum testable
configuration for LDCFs that specifies which components and accessories
should and should not be included for testing. (AMCA, No. 23 at p. 9)
Additionally, AMCA recommended that, for a minimum LDCF testable
configuration, the fan should be tested as a complete fan with a
single-fan controller and that any optional features that do not relate
to air movement should not be energized during testing. (AMCA, No. 23
at p. 9)
Regarding AMCA's suggestion to test ceiling fans without including
additional accessories and in a minimum testable configuration, DOE
notes that appendix U requires that additional accessories not related
to ceiling fan airflow be turned off during testing and that testing
shall be completed with the default or minimally functional controller.
Specifically, section 3.3.1 of appendix U lists specifications for
testing with additional accessories for standard and hugger fans and
section 3.5.1 of appendix U lists specifications for testing with
additional accessories for LDCFs and HSBD fans.
AMCA also commented that additional parameters, like blade span,
CFEI100, CFEI40, airflow at high speed, and airflow at 40 percent
speed, should be included in the reporting requirements for the CCD so
that the data can be used in the next rulemaking to adjust CFEI ratings
and standby power requirements. AMCA added that standby power should
also be reported for compliance filing. AMCA further stated that adding
these reporting requirements would not create an additional burden on
manufacturers because the additional data being reported would come
directly from the test report that is already produced for DOE
compliance testing. (AMCA, No. 23 at pp. 3, 7)
Regarding compliance with existing energy conservation standards,
AMCA commented that, based on an internet market survey they conducted,
they believe many LDCFs on the market are not currently registered in
DOE's CCD. AMCA estimated that less than half of the LDCF models
available for sale in the United States were certified to DOE and that
only 7 of the 23 LDCF manufacturers/importers they identified had
registered products in the CCD. (AMCA, No. 23 at pp. 7, 14-15)
Additionally, AMCA commented that some of the published performance
data for fan models identified in their internet market survey may be
physically impossible. (AMCA, No. 23 at pp. 14-15; Ivanovich, Public
Meeting Transcript, No. 21 at p. 10)
AMCA expressed concern that increased standards would have a
disproportionate impact on manufacturers that are certifying their fans
and working to meet the energy conservation standards, and they
encouraged DOE to enforce its standards across the ceiling fan
industry. (AMCA, No. 23 at pp. 14-15; Ivanovich, Public Meeting
Transcript, No. 21 at p. 10)
AMCA estimated that the performance of many products identified
through their internet market survey but not registered in the CCD may
be below the current energy conservation standards. Id. AMCA further
stated that these unregistered products could muddy DOE's analysis by
suggesting that the current energy conservation standards are being
easily met. (AMCA, No. 23 at pp. 1-2,7) AMCA commented that current
energy conservation standards were met through investment by
manufacturers, and enacting higher efficiency standards today would
penalize manufacturers that have invested to comply with current energy
conservation standards while rewarding bad actors who never invested.
(AMCA, No. 23 at p. 1,2)
Regarding ceiling fan certification requirements, DOE notes that
the July 2022 Certification Final Rule amended 10 CFR 429.32 to require
additional data submission at the time of certification for LDCFS,
including blade span, CFEI40, and CFEI100, amongst other data. 87 FR
43952, 43964-66. Further, DOE notes that 10 CFR 429.12(a) specifies
that ``[e]ach manufacturer, before distributing in commerce any basic
model of a covered product or covered equipment subject to an
applicable energy conservation standard set forth in parts 430 or 431,
and annually thereafter on or before the dates provided in paragraph
(d) of this section, shall submit a certification report to DOE
certifying that each basic model meets the applicable energy
conservation standard(s).'' 10 CFR 429.12(a). DOE's current energy
conservation standards are listed at 10 CFR 430.32(s)(2) and are
relevant to all ceiling fans manufactured on or after January 21, 2020.
Consistent with 10 CFR parts 429 and 430, manufacturers are required to
submit a certification report to DOE that their basic models meet the
relevant energy conservation standards at10 CFR 430.32(s)(2) along with
the additional information as required in 10 CFR 429.32.
Regarding the sampling requirements when testing LDCFs, AMCA stated
that the data they provided to DOE were based on single-sample tests,
rather than the two-sample tests required by 10 CFR 429.32. AMCA also
commented that the current Federal energy conservation standards are
based on single-sample test data as well. AMCA provided calculations
showing the impact of using the confidence limits in 10 CFR 429.32 to
determine the represented CFEI values from two samples.
AMCA further commented that after the Energy Act of 2020 was
published, which prescribed the current energy conservation standards
at CFEI100 and CFEI40, a technical errata to AMCA 230-15 was published
on May 15, 2021 to account for air density differences between test
labs. (AMCA, No. 23 at pp. 12-13) AMCA commented that because DOE has
incorporated the technical errata to AMCA 230-15 into DOE's test
procedure, (see appendix U and 87 FR 50396, 50405), the manufacturer
data on which DOE's analysis is based overestimates performance by an
average of 3 percent.
AMCA estimated that correcting for the test lab air density, as
required in the AMCA 230 technical errata, and two-sample requirements
in 10 CFR 429.32 increase CFEI 100 and CFEI 40 by an average of 12
percent and 17 percent, respectively. (AMCA, No. 23 at pp. 2-3) AMCA
encouraged DOE to both account for the impact of the technical errata
and ensure that its analysis is based on two-sample data. (AMCA, No. 23
at pp. 13-14) Given the impact of the
[[Page 40945]]
technical errata and the requirement to use two-sample test data, AMCA
commented that the current energy conservation standards are stricter
than congress intended and therefore AMCA recommended that DOE maintain
the current CFEI requirements of CFEI100 = 1.00 and CFEI40 = 1.31 in
this proposed rulemaking. (AMCA, No. 23 at p. 3)
DOE disagrees with AMCA's comment that the statistical requirements
in 10 CFR 429.32 result in a more stringent standard when conducting a
two-sample test. 10 CFR 429.32(a)(2)(i) states that reported airflow
should use the lower of ``the mean of the sample'' or ``the lower 90
percent confidence limit (LCL) of the true mean divided by 0.9.''
Similarly, 10 CFR 429.32(a)(2)(ii) states that reported power
consumption should use the higher of ``the mean of the sample'' or
``the upper 95 percent confidence limit (UCL) of the true mean divided
by 1.1.'' In the example data AMCA included in their comments (AMCA No.
23 at p. 14), the values listed as ``Represented Value'' are the 90
percent lower confidence limit (``LCL'') of the true mean of the
airflow and the 95 percent upper confidence limit (``UCL'') of the true
mean of the power consumption. These values do not include the
``divided by 0.9'' in 10 CFR 429.32(a)(2)(i)(B) and the ``divided by
1.1'' in 10 CFR 429.32(a)(2)(ii)(B). If the statistical calculations
were applied as written in 10 CFR 429.32(a)(2), the mean of the sample
is lower than the 90 percent LCL of the true mean divided by 0.9 and
therefore the mean of the sample should be used to represent the
airflow. Similarly, the mean of the power consumption is greater than
the mean of the 95 percent UCL of the true mean divided by 1.1 and
therefore the mean of the sample should be used to represent power
consumption.
DOE notes that the only time the mean of the two-sample test is not
used is when there is a large deviation between the measured results of
the two tests. Even in a scenario where the two-sample test requirement
results in large deviation, manufacturers have the option to conduct
additional tests to increase the confidence of the sample mean.
Therefore, DOE has not modified its analysis to reflect any difference
between reported single-sample results and two-sample results in this
NOPR.
Regarding using the AMCA 230-15 technical errata, DOE agrees that
if manufacturer data did not correct for air density, it may overstate
a CFEI values for a given LDCF. DOE notes that current energy
conservation standards must be met using appendix U, which includes the
AMCA 230-15 technical errata. However, DOE has modified its analysis of
higher efficiency levels in this NOPR to reflect the possibility that
some manufacturer data on which DOE's analysis is based may not include
air density corrections. This modification is discussed in more detail
in section IV.C.2.b of this document.
3. Technology Options
In the preliminary market analysis and technology assessment, DOE
identified several technology options that would be expected to improve
the efficiency of ceiling fans, as measured by the DOE test procedure.
As previously discussed, standard and hugger ceiling fan efficiency is
based on a weighted average CFM/W metric, whereas LDCF and HSBD ceiling
fan efficiency is evaluated using CFEI. Standard and hugger ceiling
fans are also typically installed in residential applications whereas
LDCF and HSBD ceiling fans are typically installed in commercial and/or
industrial applications. The differences in metric, market, and utility
mean that the technology options for improving the efficiency as
measured by the DOE test procedure are unique for each product class.
In section 2.4.3 of the February 2022 Preliminary Analysis TSD, DOE
identified technologies for improving the efficiency of each ceiling
fan product class. The following sections discuss the technology
options identified in the February 2022 Preliminary Analysis,
stakeholder comment, and DOE's technology options included in this NOPR
analysis.
a. Standard and Hugger Ceiling Fans
Generally, at both low and high speeds an increase in standard and
hugger ceiling fan efficiency can be achieved by increasing airflow and
decreasing power consumption. In section 2.4.3 of the February 2022
Preliminary Analysis TSD, DOE identified three primary categories for
increasing standard and hugger fan efficiency: (1) more efficient
motors, including larger direct-drive single-phase induction motors and
brushless direct current (``BLDC'') motors; (2) more efficient ceiling
fan blades using common blade materials, twisted blades, and beveled
blades; and (3) advanced ceiling fan controls, including occupancy
sensors, wind sensors, and temperature sensors.
As discussed previously, moving a hugger fan further from the
ceiling is one way of increasing the CFM/W for these fans because it
increases airflow without reducing power consumption. Hugger ceiling
fans with fan blades very close to the ceiling can create a vacuum
between the fan blades and the ceiling that prevents air from returning
to the input side of the fan (i.e., the air choking effect). However,
certain consumers may prefer closely mount ceiling fans, despite the
reduced airflow, because they do not protrude as far into the ceiling.
DOE requested data regarding the impact that the distance between the
ceiling fan blades and the ceiling had on airflow.
In response, ALA conducted testing in which they measured high
speed CFM for multiple fan models while increasing the distance between
the fan blades and the ceiling. (ALA, No. 26 at pp. 9-11) ALA's said
that their test data showed that for most models the benefit of having
a fan closer to the ceiling than 10 inches decreases significantly for
each additional inch closer to the ceiling, and that hugger fan airflow
approximately doubled when the distance between the fan blades and the
ceiling increased from 6 inches to 10 inches. Id.
DOE interprets the ``benefit of having a fan closer to the ceiling
than 10 inches decreases significantly'' stated in ALA's comment to
mean that the airflow of a hugger fan decreases below 10 inches. DOE
does not interpret this text to mean that there is no reason for
consumers to want a fan that is mounted closer than 10 inches from the
ceiling. DOE has previously determined that ceiling fans mounted closer
to ceiling (i.e., hugger fans) warrant a separate energy conservation
standard. 86 FR 6826, 6841. The fact that fans exist on market that are
fewer than 10-inches from the ceiling indicate that there are some
consumer preferences for these fans, even if the airflow is somewhat
reduced. Specifically, the ability for that fan to be installed in
areas with low ceilings where additional clearance between the ceiling
fan and the floor are desired.
In this NOPR, DOE included increasing the distance from the ceiling
as a possible technology option for hugger ceiling fans but has
retained flexibility in its maximum technology options for fans to be
fewer than 10 inches from the ceiling.
b. Large-Diameter Ceiling Fans
An increase in LDCF efficiency is associated with a reduction in
power consumption while maintaining airflow. In section 2.4.3 of the
February 2022 Preliminary Analysis TSD, DOE identified three primary
technology options: (1) more efficient motors, including three-phase
geared induction motors, three-phase geared premium induction motors,
and permanent magnet direct-drive motors; (2) more
[[Page 40946]]
efficient ceiling fan blades, including twisted blades and blade
attachments; and (3) advanced ceiling fan controls, including occupancy
sensors, wind sensors, and temperature sensors.
AMCA commented that changing from a lower-efficiency geared motor
to an IE3 \21\ motor would improve the efficiency of a LDCF. (AMCA, No.
23 at p. 2) However, AMCA stated that all its members that manufacture
gear-driven ceiling fan already use IE3 motors. Id.
---------------------------------------------------------------------------
\21\ ``IE3'' is the International Electrotechnical Commission
(``IEC'') designation for premium efficiency motors. IE3, National
Electrical Manufacturers Association (``NEMA'') premium, and EISA
2007 standards for electric motors are often considered equivalent
efficiency requirements, although the actual values differ depending
on pole, horsepower and enclosure.
---------------------------------------------------------------------------
AMCA is correct that IE3 motors, or similarly efficient motors (for
those below 1 horsepower (``HP'') where IE3 levels do not exist) are
typical in the industry. Therefore, DOE is no longer considering three-
phase geared induction motors that are not premium efficiency as a
technology option in this NOPR. DOE did not receive any other comments
regarding other technology options and therefore has retained them in
this analysis.
In addition to the technology options identified in the February
2022 Preliminary Analysis, DOE has identified LDCF optimization as an
additional technology option evaluated in this NOPR for improving the
efficiency of LDCFs.
Section 1008 of the Energy Act of 2020, as codified in appendix U,
specifies that LDCF CFEI be calculated using AMCA 208-18 \22\ with
modifications. Broadly, the CFEI metric is the evaluation of the real-
world performance of a given fan relative to the performance of a
theoretical reference fan. In determining the power required for a
reference fan, the CFEI calculation assumes the power input that would
be required to produce the tested airflow, given the ceiling fan blade
span. AMCA 208-18 assumes four efficiency metrics for the reference
fan: (1) airfoil efficiency; (2) transmission efficiency; (3) motor
efficiency; and (4) controller efficiency.
---------------------------------------------------------------------------
\22\ ANSI/AMCA Standard 208-18 (``AMCA 208-18''), Calculation of
the Fan Energy Index, ANSI approved January 24, 2018.
---------------------------------------------------------------------------
The reference fan calculation in AMCA 208-18 assumes that airfoil
blades are 42 percent efficient and that controllers are 100 percent
efficient. Further, the reference fan calculation assumes the
transmission efficiency is consistent with a perfectly sized V-belt
drive. DOE notes that LDCF manufacturers typically use a two-stage
helical gearbox rather than a V-belt drive; however, in interviews,
manufacturers stated that the reference fan V-belt drive efficiency is
a reasonable approximation of a two-stage helical gearbox. The
reference fan calculation also assumes the motor efficiency is
consistent with a perfectly sized (relative to the required input
power) IE3 motor. DOE notes that IE3 motor specifications exist at
distinct motor sizes and not as a smooth curve across all possible
motor horsepower sizes. Therefore, the motor efficiency formula in AMCA
208-18 is only an approximation. Further, motors are typically sold at
distinct horsepower sizes, and therefore the motor size used will not
exactly align with the assumed reference fan horsepower and the
efficiency may vary.
To meet higher CFEI, some manufacturers may increase fan motor
efficiency, others may increase airfoil efficiency, and others may
increase transmission efficiency. Further, these various efficiencies
can compound with one another. A higher airfoil efficiency means that a
smaller gearbox and a smaller motor, with less energy loss, can be used
since more power input to the fan blades is converted to airflow.
For example, a 24-foot LDCF with a high-speed airflow of 230,000
CFM has a reference fan power consumption of 1,683 W. A fan with the
same efficiency characteristics of the reference fan would have a
CFEI100 equal to 1.00 and use 1,683 W at 100 percent speed. If a
manufacturer were to improve the airfoil efficiency by one percent
(from the reference value of 42 percent to 43 percent), that fan would
consume 1,647 W, corresponding to a CFEI equal to 1.022.
LDCFs are commonly offered as a fan ``family'' with one brand name
spanning a variety of blade spans. Typically, a single fan family will
be offered in 8-, 10-, 12-, 14-, 16-, 18-, 20-, and 24-foot diameters.
To reduce the number of custom parts, it is common for manufacturers to
use the same motor/transmission part across several LDCF blade spans.
While this practice reduces the burden on manufacturers, it means that
the motor size and blade angle is better optimized for certain blade
spans and less well optimized for others. This practice also results in
a range of CFEI values on the market even within a single fan family,
despite the fact that the motor size, transmission, and airflow may be
similar. Therefore, in addition to the technology options evaluated in
the February 2022 Preliminary Analysis, DOE included LDCF optimization
as a technology option in this NOPR for improving the efficiency of
LDCFs.
c. High-Speed Belt-Driven Ceiling Fans
Similar to LDCF efficiency, HSBD ceiling fan efficiency is achieved
by reducing power consumption while maintaining airflow. In the
February 2022 Preliminary Analysis, DOE stated that it did not have
sufficient data to analyze a baseline efficiency level or evaluate
higher efficiency levels for HSBD ceiling fans. DOE requested comment
on technology options for improving HSBD ceiling fan efficiency. DOE
received no comments regarding specific technology options for
improving the efficiency of HSBD ceiling fans.
Given the similarities between large, housed, air-circulating fan
heads and HSBD ceiling fans, DOE expects that technologies which
improve air-circulating fan head efficiency would also improve HSBD
ceiling fan efficiency. As such, the technology options evaluated for
HSBD ceiling fans in this NOPR align with the technology options
analyzed in the Fans and Blowers Notice of Data Availability regarding
air circulating fans published October 13, 2022 (``Air Circulating Fans
NODA''). The technology options analyzed in the Air Circulating Fans
NODA included: split-phase motors, permanent split-capacitor (``PSC'')
motors, high-efficiency PSC motors, electronically commutated motors
(``ECMs''), and aerodynamic redesign. 87 FR 62038, 62042.
d. Summary of Technology Options
For this NOPR, DOE has tentatively selected the technology options
listed in Table IV.1 for its NOPR analysis.
[[Page 40947]]
Table IV.1--Technology Options and Descriptions
------------------------------------------------------------------------
Technology option Description
------------------------------------------------------------------------
Small-diameter ceiling fans:
Larger direct-drive Direct-drive, single-phase, PSC motors
motors. with an external rotor are the most
common type of motor used in ceiling
fans. These motors typically have a
flat, pancake-style construction. Larger
direct-drive motors have increased mass
and/or use steel with better energy
efficiency characteristics for the
stator and rotor stack. These motors
also typically have improved lamination
design which increases the cross section
and/or length of the copper wiring
inside the motor.
BLDC motors.............. BLDC motors are electronically
commutated, synchronous motors with
permanent magnets embedded in or on
their rotors. BLDC motors are driven by
a converter plus inverter combination
control system, which converts the AC
power supplied by a building into DC
power and controls the power flow into
the motor to create continuously
switching currents in the motor phases.
BLDC motors can be much more efficient
than induction motors.
Blade materials.......... Use of alternative materials could enable
more complex and efficient blade shapes
(plywood vs. MDF vs. injection-molded
resin, for example). Further, some
ceiling fans use a natural material that
is somewhat porous (i.e., allows air to
pass through the blades without
contributing to airflow). Replacing this
natural material with more common
materials can increase ceiling fan
efficiency.
Occupancy, wind, and Occupancy sensors use technologies that
temperature sensors and detect the presence of people through
ceiling fan controls. movement or body heat. Wind sensors
measure airflow speed and can be used in
conjunction with a ceiling fan to
determine whether the fan is providing
the ideal amount of airflow in a room.
Temperature sensors measure the
temperature of a room. Ceiling fans can
be paired with these sensors and a
control system to automatically adjust
and optimize their power consumption.
Control systems can be mounted into the
wall to allow consumers to conveniently
turn ceiling fans off or slow their
speed as they leave a room or building,
reducing unnecessary power consumption.
Distance from the ceiling Ceiling fans mounted such that their
(hugger ceiling fans blades are closer to the ceiling are
only). unable to produce as much airflow as if
their blades were further from the
ceiling. Therefore, hugger ceiling fans
mounted close to the ceiling have a
reduced energy efficiency potential
compared to those with a greater
distance between the ceiling and the
blades. Increasing this distance
improves airflow and efficiency.
Large-diameter ceiling fans:
Permanent magnet direct- Permanent magnet motors are able to offer
drive motors. high-torque even at low-speeds and as
such are able to be used without a gear-
box. The rotor spins in a synchronous
manner (i.e., the motor rotates at the
same speed as the revolving magnetic
field), which is why these motors are
sometimes referred to as ``permanent
magnet synchronous motors.'' Permanent
magnet motors can be significantly more
efficient than induction motors. Several
types of permanent magnet direct-drive
motors are currently used in the large-
diameter ceiling fans industry,
including BLDC, permanent magnet AC, and
transverse flux.
Fan Optimization......... LDCFs are typically not optimized for
every blade span for which they are
offered. To minimize parts,
manufacturers often use the same motor/
transmission assembly across numerous
blade spans, rather than having an
optimized design for each blade span.
Optimizing the fan for each blade span
represents an opportunity to increase
efficiency.
Airfoil blades........... Airfoil blades increase ceiling fan
efficiency by reducing drag and
therefore reducing power consumption.
Airfoil blades use curved surfaces to
improve aerodynamics. The thickness is
not uniform, and the top and bottom
surfaces do not follow the same path
from leading edge to trailing edge.
Beveled blades........... Beveled fan blades are typically beveled
at the blade edges from the motor casing
to the blade tip. Beveled fan blades are
more aerodynamic than traditional fan
blades, which reduce drag and increase
airflow efficiency.
Curved blades............ Curved blades increase ceiling fan
efficiency by reducing drag and
therefore reducing power consumption.
Curved blades are blades for which the
centerline of the blade cross section is
cambered. Curved blades generally have
uniform thickness and no significant
internal volume.
HSBD ceiling fans: .........................................
Improved Motor Efficiency The efficiency of an HSBD fan can be
increased by improving the efficiency of
the HSBD motor. Several different motor
technologies exist, ranging from split-
phase motors, PSC motors, higher-
efficiency PSC motors, and ECMs.
Improved aerodynamic The efficiency of a fan can be increased
design. by improving the aerodynamic design of
its components. This includes optimizing
the blade shape to reduce drag and
optimizing the housing or guard design
to increase airflow.
------------------------------------------------------------------------
B. Screening Analysis
DOE uses the following five screening criteria to determine which
technology options are suitable for further consideration in an energy
conservation standards rulemaking:
(1) Technological feasibility. Technologies that are not
incorporated in commercial products or in commercially viable, existing
prototypes will not be considered further.
(2) Practicability to manufacture, install, and service. If it is
determined that mass production of a technology in commercial products
and reliable installation and servicing of the technology could not be
achieved on the scale necessary to serve the relevant market at the
time of the projected compliance date of the standard, then that
technology will not be considered further.
(3) Impacts on product utility. If a technology is determined to
have a significant adverse impact on the utility of the product to
subgroups of consumers, or result in the unavailability of any covered
product type with performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as products generally available in the United States at the time,
it will not be considered further.
(4) Safety of technologies. If it is determined that a technology
would have significant adverse impacts on health or safety, it will not
be considered further.
(5) Unique-pathway proprietary technologies. If a technology has
proprietary protection and represents a unique pathway to achieving a
given efficiency level, it will not be considered further, due to the
potential for monopolistic concerns.
10 CFR 431.4; 10 CFR part 430, subpart C, appendix A, sections 6(c)(3)
and 7(b).
[[Page 40948]]
In summary, if DOE determines that a technology, or a combination
of technologies, fails to meet one or more of the listed five criteria,
it will be excluded from further consideration in the engineering
analysis. The reasons for eliminating any technology are discussed in
the following sections.
The subsequent sections include comments from interested parties
pertinent to the screening criteria, DOE's evaluation of each
technology option against the screening analysis criteria, and whether
DOE determined that a technology option should be excluded (``screened
out'') based on the screening criteria.
1. Screened-Out Technologies
a. Standard and Hugger Ceiling Fans
In section 2.5 of the February 2022 Preliminary Analysis TSD, DOE
screened out the following technology option for small-diameter ceiling
fans: three-phase induction motors, blade shape, blade attachments,
occupancy sensors, wind sensors, temperature sensors, and brushed DC
motors. ALA commented that they agreed with the technologies DOE
screened out in the February 2022 Preliminary Analysis. (ALA, No. 26 at
p. 6)
In this NOPR, DOE has continued to screen these technology options.
Each of these technology options is discussed further in Section 4 of
the TSD.
In response to the May 2021 RFI, numerous stakeholders commented
that the DOE CFM/W metric for small-diameter ceiling fans penalizes
smart technologies that use standby power but does not credit any
reduction in active mode power consumption that results from
implementing advanced controls and smart technology. (AMCA, No. 9 at p.
9, 13; ALA No. 8 at p. 2) ALA and Center for the Built Environment
(``CBE'') recommended DOE credit products with smart technologies to
account for active mode energy reduction and system wide energy
reductions. (ALA, No. 8 at p. 2; CBE, No. 7 at pp. 2-4)) In section
2.4.3.3 of the February 2022 Preliminary Analysis TSD, DOE acknowledged
that smart technologies have the potential to reduce ceiling fan CFM/W,
on account of using additional power while in standby operation which
is accounted for in an operating hour-based weighted average power
consumption used in the denominator of the CFM/W metric, despite the
fact that smart technologies may reduce operating hours. In response to
stakeholder's suggestion that DOE's test procedure ``credit'' potential
operating hour reductions in the CFM/W metric to better convey to
consumers on the fan's label which products use less power, DOE noted
that smart technologies are currently incorporated into high-efficiency
products that easily exceed energy conservation standards, and
therefore a smart technology credit was not needed.
Regarding ceiling fan smart technology's ability to reduce building
wide energy usage, DOE noted in section 2.4.3.3 of the February 2022
Preliminary Analysis TSD that, while studies show there are potential
system-wide energy savings associated with incorporation of automated
controls, these studies reported connectivity challenges that led to
DOE questioning whether any potential savings of automated controls
would be fully realized by consumers. Therefore, DOE did not account
for any potential operating hour savings in the February 2022
Preliminary Analysis.
In response, Lutron stated that, while smart technologies are
typically used for high-efficiency fans, they can also be integrated
into lower-efficiency fans to save energy. (Lutron, No. 24 at pp. 3-4)
Lutron added that DOE's decision not to include operating hour savings
associated with smart technologies is based on a single field study of
a single fan model and that the issues described in this field study
are uncommon with smart technologies. (Lutron, No. 24 at p. 3)
DOE agrees that smart technologies can be incorporated into lower-
efficiency ceiling fans. In Table IV.2, DOE has provided example
numbers to demonstrate why a credit is not needed for theoretical
operating hour savings associated with smart technology.
Table IV.2--Example Smart Tech Power Consumption
----------------------------------------------------------------------------------------------------------------
Fan 1 AC Fan 2 AC Fan 3 BLDC Fan 4 BLDC
motor-- no motor--with motor--no motor--with
smart tech smart tech smart tech smart tech
----------------------------------------------------------------------------------------------------------------
Airflow High (CFM).............................. 4,500 4,500 4,500 4,500
Airflow Low (CFM)............................... 1,200 1,200 1,200 1,200
Power High (W).................................. 58.7 55.0 28.3 27.0
Power Low (W)................................... 12.0 11.0 3.9 3.5
Standby Power (W)............................... 0.0 1.4 0.7 1.4
CFM/W........................................... 80 77 157 149
----------------------------------------------------------------------------------------------------------------
In the CFM/W efficiency metric, the denominator is a weighted
average of high-speed power consumption, low-speed power consumption
and standby power consumption. In high-efficiency fans, such as fans
with BLDC motors, standby power energy consumption can make up a much
larger percentage of the denominator, because high-speed and low-speed
power are relatively low. Therefore, more efficient active mode fans
run the risk of appearing on consumer labels to be less efficient by
having lower CFM/W. In Table IV.2, Fan 3 has a higher certified CFM/W
than Fan 4, despite the fact that Fan 4 uses less power in active mode.
However, as stated both fans are very efficient and there is little
difference in power consumption. Therefore, there is no need to
``credit'' potential operating hour savings of Fan 4 such that it
appears equally or more efficient than Fan 3.
Regarding lower-efficiency ceiling fans, and specifically fans with
AC motors, DOE notes that high-speed and low-speed power consumption is
considerably more than fans with BLDC motors and therefore the standby
power usage contributes less to the denominator of the CFM/W metric and
the difference in certified CFM/W values is going to be relatively
small between fans with smart tech and fans without smart tech. In
Table IV.2, Fan 1 has a higher certified CFM/W than Fan 2, despite the
fact that Fan 2 uses less power in active mode. Because standby power
is a small component of total power consumption, there is only a 3 CFM/
W difference between Fan 1 and Fan 2 and there is little risk to
consumers in purchasing Fan 1, thinking it is more efficient than Fan
2. Therefore, there is no need to ``credit'' potential operating hour
savings of Fan
[[Page 40949]]
2 such that it appears equally or more efficient than Fan 1.
DOE therefore maintains its position that a CFM/W ``credit'' is not
needed for ceiling fans incorporating sensors or other smart
technologies for the purpose of communicating to consumers which
products are more efficient.
Regarding potential building-wide energy savings, DOE notes that
regardless of whether smart technologies/automated controls are
included in minimally compliant products or high-efficiency products,
the operating hours impact would be the same. DOE does not expect that
amended efficiency standards would impact the prevalence of smart
technologies in ceiling fans and has therefore screened out smart
technologies in this NOPR.
b. Large-Diameter Ceiling Fans
DOE screened out and did not receive comment on the following
technology options for LDCFs in the February 2022 Preliminary Analysis:
alternative blade materials; twisted blades; blade attachments;
occupancy, wind, and temperature sensors; and brushed DC motors. DOE
therefore continues to screen out these technology options in this
NOPR. These technology options are discussed further in Chapter 4 of
the TSD.
2. Remaining Technologies
Regarding DOE's decision to screen-in BLDC motors in the February
2022 Preliminary Analysis, several stakeholders suggested BLDC motors
may not satisfy DOE's screening criteria. ALA commented that a standard
level that eliminates ceiling fans with AC motors is not in the public
interest and recommended non-mandatory measures, such as consumer
education programs, a properly designed and promoted ENERGY STAR
specification, utility rebates or other manufacturer incentives
combined with a less stringent standard level can yield substantial
energy savings by accommodating consumer design and utility
preferences. (ALA, No. 26 at pp. 1-2) ALA added that when the ENERGY
STAR program moved to a level that could be met only by BLDC motor
ceiling fans, the result was a 70-percent reduction in ceiling fan
ENERGY STAR units sold, and HSSD fans were almost eliminated when DOE's
efficiency standard moved to requiring a DC motor. (ALA, No. 26 at p.
2) ALA commented that BLDC motor ceiling fans have a delayed start-up
where they may change rotational direction (from clockwise to
counterclockwise) which can be confusing and annoying to consumers.
(ALA, No. 26 at p. 5)
ALA further commented that DC motor manufacturing relies on ferrite
magnet materials and rare earth magnet materials sourced from China.
They added that a standard that requires BLDC motors would further U.S.
ceiling fan manufacturer reliance on Chinese imports. (ALA, No. 26 at
p. 14) In section 2.6.3.3 of the February 2022 Preliminary Analysis
TSD, DOE noted small-diameter ceiling fan manufacturers already rely on
China for the vast majority of their production and it does not expect
that a transition to BLDC motors would change this reliance. ALA
provided no comment suggesting that BLDC motor ceiling fans are
manufactured in a different location than AC motor ceiling fans.
Regarding ALA's comments that the ENERGY STAR level requiring BLDC
motors resulted in a significant reduction in shipments, DOE notes that
ENERGY STAR is a voluntary standard and ENERGY STAR products are
typically offered at a price premium. BLDC motor ceiling fans sold
today are not sold as the lowest price point products but as premium
products with marketing for their sleek designs, additional speed
controls, and quiet operation. In the case of amended efficiency
standards, consumers choose between purchasing a ceiling fan and not
purchasing a ceiling fan, not between purchasing an ENERGY STAR
certified fan and a non-ENERGY STAR certified fan. Products that do not
meet amended efficiency standards would no longer be an option for
consumers to choose. In this analysis, DOE has accounted for purchase
price elasticity between efficiency levels requiring BLDC motors and
the no-new standards case (as discussed in section IV.G of this
document), but DOE does not expect a 70-percent reduction in shipments
or a similar dynamic as stakeholders suggested.
In section 2.4.3.3 of the February 2022 Preliminary Analysis TSD,
DOE acknowledged that the control mechanism is different for AC motor
ceiling fans and BLDC motor ceiling fans but did not determine that
these differences represented a significant loss in consumer utility.
DOE noted that while some AC motor ceiling fans are controlled with a
remote control, the vast majority are controlled with electromechanical
controllers, e.g., a pull chain or a wired wall-control. BLDC motors,
by contrast, require an electronic controller to operate with either a
remote control or an electronic receiver.
In response, Lutron commented that setting an energy efficiency
level where AC powered fans are removed from the market would not be in
the public interest. (Lutron, No. 24 at p. 2) Lutron stated that the
near-universal compatibility of wall-mounted fan speed controls with AC
motors has allowed consumers to purchase fan speed controls for
reliability, aesthetics, potential energy savings, and integration
features. (Lutron, No. 24 at p. 2) Lutron commented that high-tech,
integrated lighting and fan control systems do not control only ceiling
fans, but can save significant energy in a home, and that a ceiling fan
efficiency standard that requires BLDC motors would result in the
elimination of this energy savings potential and consumer utility.
(Lutron, No. 24 at pp. 2, 3) Lutron provided an example of an ``All
Off'' button on an integrated control system that turns off all lights
and fans in a home as a consumer is exiting the home and stated that
without this feature, it's more likely for fans and lights to be left
on for an extended period while nobody is home. Id.
Lutron and ALA commented that the adoption of an efficiency
standard that requires BLDC motors would remove ceiling fans
controllable by wall-mounted fan speed controls from the market, since
quiet fan speed controls and variable speed controls cannot be
integrated with BLDC motors. (Lutron, No. 24 at p. 2; ALA, No. 26 at p.
7) Lutron commented that they do not believe that DOE has the authority
to set an efficiency standard that essentially requires BLDC motors
since such a standard could remove wall-mounted control features from
the market. (Lutron, No. 24 at p. 2) Lutron cited three specific
examples where consumer utility is lost if consumers cannot use wired-
wall mounted speed controls: (1) wall-mounted controls that incorporate
both light and fan speed controls in the same device; (2) fan speed
controls that coordinate with other switches and dimmers; and (3)
conveniently located wall-mounted controls that interrupt power to the
ceiling fan and its light kit. (Lutron, No. 24 at p. 2)
DOE agrees that existing wired wall controllers would not be
compatible with BLDC motors, and that BLDC motors instead rely on
wireless controls. However, DOE disagrees that this incompatibility
results in the loss of consumer utility. DOE disagrees that wall
mounted controls that incorporate both light and fan speed controls
would no longer be available if BLDC motors were required for ceiling
fans. Many BLDC fans on the market today are sold with wall controllers
that provide both
[[Page 40950]]
light and fan speed controls. Although wall controls for BLDC motors
are more similar to a remote control, the interface with consumers
offers the same functionality as a wired wall control.
In terms of style and design coordination with other switches and
dimmers in the house, DOE notes that the external design for BLDC motor
ceiling fan wall-controls are in many cases similar or identical to AC
motor ceiling fan wall-control designs. DOE agrees that consumers may
have to purchase a different brand wall-control from their light-
switch; however, the style could still match other switches.
Regarding Lutron's comment that conveniently located wall-mounted
controls that interrupt power to the ceiling fan and its light kit
would not exist with BLDC motors, DOE reiterates that these controls do
exist. BLDC control switches interrupt power to the fan in the same way
that any other switch would. While this feature is not universal for
BLDC wall controls, it is available for consumers who want this
feature.
DOE acknowledges that BLDC wall controls are incompatible with
existing AC motor wall controls. However, the consumer features
provided by BLDC motors are identical to the features provided by AC
motor wall controls--namely, a convenient, wall mounted system for
controlling ceiling fan speed and lights. Therefore, DOE has evaluated
BLDC motors as a design option for standard and hugger ceiling fans in
this NOPR. DOE accounts for differences in BLDC motor production costs
and manufacturer impacts in the downstream analyses.
Through a review of each technology, DOE tentatively concludes that
all of the other identified technologies listed in section IV.A.3 of
this document met all five screening criteria to be examined further as
design options in DOE's NOPR analysis.
DOE has initially determined that these technology options are
technologically feasible because they are being used or have previously
been used in commercially available products or working prototypes. DOE
also finds that all of the remaining technology options meet the other
screening criteria (i.e., practicable to manufacture, install, and
service and do not result in adverse impacts on consumer utility,
product availability, health, or safety, unique-pathway proprietary
technologies). For additional details, see chapter 4 of the NOPR TSD.
C. Engineering Analysis
The purpose of the engineering analysis is to establish the
relationship between the efficiency and cost of ceiling fans. There are
two elements to consider in the engineering analysis: the selection of
efficiency levels to analyze (i.e., the ``efficiency analysis''); and
the determination of product cost at each efficiency level (i.e., the
``cost analysis''). In determining the performance of higher-efficiency
products, DOE considers technologies and design option combinations not
eliminated by the screening analysis. For each product class, DOE
estimates the baseline cost, as well as the incremental cost for the
product at efficiency levels above the baseline. The output of the
engineering analysis is a set of cost-efficiency ``curves'' that are
used in downstream analyses (i.e., the LCC and PBP analyses and the
NIA).
1. Representative Units
Ceiling fans are sold with a range of diameters or blade spans.
Rather than model every possible set of characteristics a ceiling fan
could have, DOE models certain representative units as the basis of its
analysis. In section 2.6.1 of the February 2022 Preliminary Analysis
TSD, DOE modeled three representative units for standard ceiling fans,
a 44-inch standard fan, a 52-inch standard fan, and a 60-inch standard
fan. For hugger ceiling fans, DOE modeled two representative units, a
44-inch ceiling fan and a 52-inch ceiling fan. These representative
units were consistent with the blade spans used in the January 2017 ECS
Final Rule, 82 FR 6826, 6852, and in section 2.6.1 of the February 2022
Preliminary Analysis TSD DOE stated that the units were still
representative of the current market. In section 2.6.1 of the February
2022 Preliminary Analysis TSD, DOE requested comment and data regarding
this assumption. In response, ALA commented that the blade spans used
in the preliminary analysis are representative. (ALA No. 26 at p. 9).
DOE did not receive any comment recommending alternative representative
units be used. Therefore, DOE has included in this analysis the
standard and hugger representative units and blades spans from the
February 2022 Preliminary Analysis.
In section 2.6.4 of the February 2022 Preliminary Analysis TSD, DOE
observed that the incremental costs to achieve higher efficiencies was
lower for larger blade spans. In order to better evaluate the larger
blade spans in the hugger ceiling fan product class, DOE has included
an additional 60-inch hugger ceiling fan representative unit in this
analysis in addition to the representative units and blade spans
analyzed in the February 2022 Preliminary Analysis.
For LDCFs, DOE modeled three representative blades spans in the
February 2022 Preliminary Analysis, an 8-foot fan, a 12-foot fan, and a
20-foot fan. In section 2.6.1 of the February 2022 Preliminary Analysis
TSD, DOE evaluated a high-airflow product and a low-airflow product at
each blade span. DOE requested comment on its consideration of a high-
and low-airflow product class and representative units. DOE also
requested data addressing why a 20-foot ceiling fan cost-efficiency
curve would not be representative of a 24-foot ceiling fan cost
efficiency curve.
As discussed in section IV.A.1.c of this document, DOE concluded
that evaluation of a high-airflow and low-airflow product classes was
not necessary. Manufacturers may market some LDCFs for the commercial
market and other LDCFs for the industrial market; however there is
overlap between these applications and one fan can typically be
substituted for another. In accordance with this determination, DOE has
removed the high- and low-airflow distinction in its representative
units and has modeled one LDCF fan at each blade span, with the power
usage modified to reflect typical values for the whole market.
Regarding differences between a 20-foot and 24-foot ceiling fan,
AMCA commented that within a given product line, the general
construction of the two products is similar but there may be cost
differences due to longer blades, a larger shipping container, and a
longer recommended extension-tube to provide additional clearance from
the ceiling to avoid restriction of intake air. (AMCA, No. 23 at p. 5)
DOE notes that all of the difference identified by AMCA are associated
with minor cost-differences between a 20-foot and 24-foot fan, not with
differences in the incremental costs associated with meeting amended
efficiency standards. While a 24-foot ceiling fan may be slightly more
expensive overall, the technologies (i.e., permanent magnet direct
drive motors, fan optimization, etc.) and incremental costs associated
with improving the efficiency of a 24-foot ceiling fan are going to be
similar to a 20-foot ceiling fan. Therefore, DOE has tentatively
determined that a 20-foot fan is sufficient to represent the cost-
efficiency relationship of 24-foot fans.
AMCA requested that DOE consider a ``very low power'' LDCF product
class, stating data from their survey of LDCF manufacturers shows that
lower-power LDCFs have high enough CFEI ratings and low enough standby
powers to warrant a separate product class from
[[Page 40951]]
high-volume LDCFs. (AMCA, No. 23 at pp. 2, 4) AMCA stated that these
lower-power LDCFs have lower maximum airflows, smaller motors, and
simpler controls than typical high-volume LDCFs. AMCA added that the
constants used in the CFEI metric were derived using high-volume low-
speed (``HVLS'') fans, so a different metric may be more appropriate
for ``very low power'' LDCFs. Id.
Regarding AMCA's comment that a different metric or different CFEI
constants may be needed for ``low-power'' LDCFs, DOE notes that the
CFEI metric and constants were prescribed at 42 U.S.C. 6295(ff)(6)(C)
for ``large-diameter ceiling fans'' without regard to the power usage
of those fans.
In DOE's review of the market, the number of ``low-power'' LDCFs
has increased since the January 2017 ECS final rule. These units are
often produced by manufacturers that predominately manufacture small-
diameter ceiling fans. In many cases, these ``low-power'' LDCFs
leverage an existing small-diameter ceiling fan design, but with a
diameter greater than 7 feet, and are therefore subject to LDCF
regulations. These ``low-power'' LDCFs tend to have much smaller
motors, blade spans between 7 and 10 feet, and are significantly less
expensive both to manufacture and to sell. Since these fans require
high torque to spin such large blades, they only use BLDC motors.
Although DOE is not considering a different product class for ``low-
power'' LDCFs in this analysis, DOE has evaluated an additional
representative unit for ``low-power'' LDCFs because of the unique power
consumption and selling price of these products. DOE notes that low-
power LDCFs are subject to the same test procedure and energy
conservation standards as all other LDCFs; however, the MIA analysis
considers the industry cash flow for these units to be in line with the
modeled costs for these units and not in line with the more expensive
manufacturer selling prices (``MSPs'') for all other LDCFs.
For HSBD ceiling fans, DOE stated in section 2.6.2.4 of the
February 2022 Preliminary Analysis TSD that it did not have sufficient
data to evaluate higher efficiency standards and therefore did not
model a representative HSBD unit. As discussed in section IV.A.1.b of
this document, DOE recently revised the definition of ceiling fan such
that a fan is only considered a ceiling fan if it has a blade span to
rpm ratio greater than 0.06. DOE notes that a belt-driven, housed air-
circulating fan shares many of the same performance characteristic with
HSBD fans. In general, most housed air circulating fans have smaller
diameters and higher maximum rpms than ceiling fans, however as the
diameter increases, the rpm of the fans tend to decrease such that
beyond a certain diameter, certain housed air circulating fans exceed
the 0.06 ratio. In that case, the primary distinction between an air
circulating fan and an HSBD fan is the presence of components that
enable an HSBD fan to be mounted from the ceiling. Therefore, DOE has
only considered the largest representative unit from the Air
Circulating Fans NODA for the HSBD analysis. Specifically, DOE selected
a 50-inch HSBD ceiling fan as a representative HSBD fan for its NOPR
analysis.
DOE requests comment and data on the distribution of HSBD blade
spans.
DOE requests comment and data regarding whether a 50-inch fan is
representative of an HSBD ceiling fan.
2. Efficiency Analysis
DOE typically uses one of two approaches to develop energy
efficiency levels for the engineering analysis: (1) relying on observed
efficiency levels in the market (i.e., the efficiency-level approach),
or (2) determining the incremental efficiency improvements associated
with incorporating specific design options to a baseline model (i.e.,
the design-option approach). Using the efficiency-level approach, the
efficiency levels established for the analysis are determined based on
the market distribution of existing products (in other words, based on
the range of efficiencies and efficiency level ``clusters'' that
already exist on the market). Using the design option approach, the
efficiency levels established for the analysis are determined through
detailed engineering calculations and/or computer simulations of the
efficiency improvements from implementing specific design options that
have been identified in the technology assessment. DOE may also rely on
a combination of these two approaches. For example, the efficiency-
level approach (based on actual products on the market) may be extended
using the design option approach to ``gap fill'' levels (to bridge
large gaps between other identified efficiency levels) and/or to
extrapolate to the max-tech level (particularly in cases where the max-
tech level exceeds the maximum efficiency level currently available on
the market).
In this analysis, DOE relied on a combination of these two
approaches to estimate the energy use and cost of meeting a given
efficiency level. As previously discussed, the efficiency of a ceiling
fan can be influenced by both the airflow and the power usage of the
models and the decision to attempt to meet amended standards via
increasing airflow versus decreasing power consumption will vary by
manufacturer and basic model.
a. Baseline Efficiency
For each product/equipment class, DOE generally selects a baseline
model as a reference point for each class, and measures changes
resulting from potential energy conservation standards against the
baseline. The baseline model in each product/equipment class represents
the characteristics of a product/equipment typical of that class (e.g.,
capacity, physical size). Generally, a baseline model is one that just
meets current energy conservation standards, or, if no standards are in
place, the baseline is typically the most common or least efficient
unit on the market.
Standard and Hugger Ceiling Fans
In the February 2022 Preliminary Analysis, DOE evaluated a baseline
unit as one that just meets the current energy conservation standards
for hugger and standard ceiling fans. DOE did not receive any comments
in opposition to this approach and therefore has followed the same
approach for assigning a baseline unit in this analysis.
DOE determined baseline energy consumption in the February 2022
Preliminary Analysis by dividing typical airflows for standard and
hugger ceiling fans by the baseline CFM/W. DOE evaluated higher
efficiency levels by assuming that manufacturers would maintain the
airflow of their products and meet efficiency standards by decreasing
power usage.
In response to the February 2022 Preliminary Analysis, ALA provided
data comparing ALA member EnergyGuide labels of baseline fans to
EnergyGuide labels of max-tech fans and stated that DOE is
overestimating the consumer savings between baseline and max-tech.
(ALA, No. 26 at p. 14).
In manufacturer interviews, manufacturers commented that to meet
higher efficiency levels for a given fan model without using a BLDC
motor, they would evaluate ways to both increase airflow and decrease
power consumption. Further, manufacturers pointed out that some of
their baseline fans are minimally efficient on account of having lower
airflow, not necessarily higher power consumption.
For this NOPR, DOE reevaluated its assumption that manufacturers
would maintain airflow when designing models with a higher CFM/W value
[[Page 40952]]
while still using AC motors. Specifically, DOE leveraged the California
Energy Commission Database (``CEC database''), which includes certified
CFM/W values, high-speed airflow, high-speed power measurements, low-
speed airflow, and low-speed power measurements, to identify change in
power consumption and change in airflow associated with higher
certified CFM/W values.
From the CEC Database, DOE observed that ceiling fans on the market
with higher CFM/W include a combination of higher airflow and lower
power consumption. In other words, baseline ceiling fans tend to have
relatively high power consumption and relatively low airflows, instead
of relatively high power consumptions and typical airflows.
For this NOPR analysis, DOE has maintained the baseline standard
and hugger ceiling fan as one that just meets current energy
conservation standards. However, DOE has modified the energy use
analysis to better align with market data which that suggests that
baseline market minimum ceiling fans have lower airflow in addition to
higher power consumption. This approach is described in greater detail
in Chapter 5 of the TSD.
DOE requests comment on the difference in airflow and power
consumption between fans at baseline efficiency and higher efficiency
levels while still using an AC motor.
Large-Diameter Ceiling Fans
In section 2.6.2.2 of the February 2022 Preliminary Analysis TSD,
DOE assigned a baseline efficiency for LDCFs as a fan that is minimally
compliant with current efficiency levels. DOE initially estimated a
baseline airflow for low- and high-airflow LDCFs. DOE then relied on
the minimally compliant CFEI100 and CFEI40 values to estimate the
baseline power consumption at maximum speed and 40-percent speed. DOE
used a cubic relationship to estimate the energy use at all other
operating speeds.
As noted in section IV.C.1 of this document, DOE is not evaluating
a separate high- and low-airflow LDCF in this NOPR. Therefore, DOE has
revised its baseline airflow to reflect a value representative of all
LDCFs, i.e. between the February 2022 Preliminary Analysis high- and
low-airflow models so that the LDCF baseline representative unit is
reflective of all LDCF fans.
For this NOPR analysis, DOE conducted additional manufacturer
interviews where it received additional data on LDCFs. As noted in
section IV.A.3.b of this document, manufacturers typically offer a
``family'' of LDCFs at multiple blade spans and do not optimize their
motor/transmission assembly across every blade span. Manufacturers
instead rely on using reasonably efficient motor/transmission designs
and airfoil designs to exceed energy conservation standards while
minimizing component inventory. As such, the least efficient products
on the market typically exceed the CFEI100 standard of 1.00 by a
considerable margin because manufacturers are not trying to just barely
meet energy conservation standards. Rather, they are trying to exceed
them by a sufficient amount so they can meet standards without having
to optimize every single model.
DOE observed a significant discrepancy in public CFEI40 values
depending on whether manufacturers marketed 40-percent speed power
consumption at high voltage (3-phase, 380-480 V) instead of lower
voltage (3-phase, 200-277 V). DOE notes that this discrepancy in power
consumption based on input voltage is much greater at low-speeds, while
measured power is nearly equal at 100-percent speed. See Chapter 5 of
the TSD for data demonstrating how test voltage impacts power
consumption.
Most LDCF basic models are rated to operate with both high and low
voltage. Operating voltage is not a consumer choice, because the
driving factor for operating voltage is whatever voltage a consumer has
at the fan's installation location. In the August 2022 TP Final Rule,
DOE clarified the test voltage required for certification after
receiving stakeholder feedback that the previous wording was unclear.
87 FR 50396, 50408. Further, technologies that improve high-speed
efficiency, such as airfoil design or better transmission efficiency
(i.e., permanent magnet direct-drive motors), are also likely to
improve the efficiency at CFEI40.
Since the least efficient fans on the market exceed the minimum
energy conservation standards, in this NOPR, DOE has revised its
baseline LDCF models to reflect the average CFEI100 and CFEI40 that
meet current standards but do not meet EL1 (i.e., the fans that would
have to be redesigned in the presence of an amended standard). DOE used
these average CFEI100 and CFEI40 values to calculate the baseline power
given the representative airflow. DOE used a cubic relationship to
estimate power consumption at all other operating speeds.
High-Speed Belt-Driven Ceiling Fans
In section 2.6.2.4 of the February 2022 Preliminary Analysis TSD,
DOE included preliminary market research on HSBD ceiling fans and noted
that it would evaluate whether energy conservations standards would be
technologically feasible and economically justified for these products.
DOE requested comment on the sales and distribution of efficiencies of
HSBDs currently on the market.
The CA IOUs recommended that DOE include HSBD ceiling fans in the
HSSD product class and large-diameter belt-driven ceiling fans in the
LDCF class, because belt-driven ceiling fans do not provide additional
utility in any consumer use case that would warrant a separate class.
(CA IOUs, No. 22 at p. 4) The Efficiency Advocates encouraged DOE to
evaluate potential standards for belt-driven ceiling fans. (Efficiency
Advocates, No. 25 at p. 3)
DOE did not receive any data regarding the current efficiency
distribution for HSBD ceiling fans. Given the overlap between large
air-circulating fan heads and HSBD ceiling fans, DOE relied on data for
large air-circulating fan heads to estimate the performance of HSBD
ceiling fans for its NOPR analysis. Specifically, DOE relied on
efficiency levels similar to those evaluated in the Air Circulating
Fans NODA (Docket No. EERE-2022-BT-STD-0002-0011).
DOE notes that, while the Air Circulating Fans NODA models multiple
air-circulating fans head diameters, HSBD ceiling fans need to have a
blade span/RPM ratio greater than 0.06 in order to meet the ceiling fan
definition. In general, smaller air circulating fans have relatively
high rpms and those rpms decrease as the blade span get larger.
Therefore, only the large air circulating fans with a blade span/RPM
ratio greater than 0.06, if sold in a ceiling mounted configuration,
would meet the definition of an HSBD ceiling fan. As such, DOE has
relied on only the 50-inch representative unit evaluated in the Air
Circulating Fans NODA for its analysis in this NOPR, since these fans
are most likely to ``circulate air''. DOE notes that the Air
Circulating Fans NODA presents efficiency in both CFM/W and fan energy
index (``FEI''). 87 FR 62038, 62043. To convert CFM/W and FEI to CFEI,
DOE relied on the Bioenvironmental and Structural System Laboratory
\23\ (``BESS Labs'')
[[Page 40953]]
database to identify the average airflow of a 50-inch fan. DOE
evaluated a baseline energy consumption for HSBD ceiling fans by
calculating high-speed power consumption from the CFM/W ratio at the
EL0 evaluated in the Air Circulating Fans NODA assuming average
airflow. From the airflow and power consumption, DOE calculated the
baseline CFEI value.
---------------------------------------------------------------------------
\23\ BESS Labs is a research, product-testing and educational
laboratory. BESS Labs provides engineering data to air in the
selection and design of agricultural buildings and assists equipment
manufactures in developing better products. Test reports for
circulating fans are publicly available at <a href="http://bess.illinois.edu/current.asp">bess.illinois.edu/current.asp</a>. (Last accessed November 22, 2022)
---------------------------------------------------------------------------
DOE requests data as to the average airflow of HSBD ceiling fans
and the range of airflows available.
b. Higher Efficiency Levels
As part of DOE's analysis, the maximum available efficiency level
is the highest efficiency unit currently available on the market. DOE
also defines a ``max-tech'' efficiency level to represent the maximum
possible efficiency for a given product.
Standard and Hugger Ceiling Fans
In section 2.6.2.1 of the February 2022 Preliminary Analysis, DOE
relied on market data to estimate typical airflows for ceiling fans at
both low and high speeds. DOE evaluated higher efficiency levels by
assuming that manufacturers would maintain the airflow of their
products and meet efficiency standards by decreasing power usage.
Specifically, DOE modeled two efficiency levels that assumed continued
use of AC motors, corresponding to a 10-percent and 20-percent
reduction in power consumption. DOE also evaluated two efficiency
levels that assumed a transition to BLDC motors, one that aligned with
ENERGY STAR levels and assumed a BLDC motor with inefficient fan blades
and a second efficiency level that corresponded to BLDC motors with
common blade materials.
DOE noted that one concern with assuming manufacturers would
maintain their airflow was that many manufacturers could increase fan
efficiency by moving hugger ceiling fans further from the ceiling,
results in increased airflow with no change in power consumption.
In response, ALA provided test data from eight ceiling fans
demonstrating that moving a ceiling fan from a very close mount, for
example 6 inches between the fan blades and the ceiling to 10 inches,
can double the CFM. (ALA, No. 26 at pp. 9-11)
For this NOPR analysis, DOE modified its energy use assumptions to
incorporate the fact that AC motor ceiling fans meet higher ELs by both
increasing airflow and decreasing power consumption. For standard
ceiling fans, DOE maintained the CFM/W levels of EL0, EL1, and EL2 from
the February 2022 Preliminary Analysis. However, instead of associating
an increase in efficiency with maintaining airflow and reducing power
consumption, DOE used a regression analysis to estimate the typical
airflow and typical power usage associated with a given CFM/W for AC
motor ceiling fans. Specifically, DOE modeled two different means of
achieving higher efficiency levels, one being via maintaining airflow
and reducing power consumption through more efficient motors and a
second approach via maintain power consumption and increasing airflow
through aerodynamic design and optimization. DOE then aggregated the
two approaches to align with the regression analysis. This analysis is
discussed in Chapter 5 of the TSD and better reflects the variety of
methods manufacturers can use to meet a given energy conservation
standard, including both decreasing power consumption and increasing
airflow.
For hugger ceiling fans, the ability to improve CFM/W without
necessarily decreasing power is more pronounced since manufacturers
have an additional option to move hugger ceiling fans further from the
ceiling. As ALA's test data demonstrate, each additional inch of
distance between a ceiling fan blades and the ceiling increases
airflow, until around 10 inches, where the airflow begins to level off.
To better reflect that a hugger ceiling fan is a similar product to a
standard ceiling fan, in this NOPR, DOE modified its EL1 and EL2 hugger
levels to better reflect the characteristics of a standard ceiling fan
moved closer to the ceiling. Specifically, DOE evaluated what the CFM/W
would be of an EL1 and EL2 standard ceiling fan if it (1) were moved
from 11 inches of space between the fan blades and the ceiling to 8
inches of space between the fan blades and the ceiling and (2) high-
speed airflow was reduced in accordance with the typical reduction in
airflow associated with moving a fan closer to the ceiling. DOE then
calculated the efficiency of that model to determine the EL1 and EL2
CFM/W for hugger ceiling fans.
To acknowledge that hugger ceiling fan and standard ceiling fan
models are not the same, DOE relied on CEC trendline data for hugger
ceiling fans to estimate the airflow and power consumption of typical
hugger ceiling fans on the market that meet a given efficiency level.
The full analysis demonstrating how the hugger ceiling fan efficiency
levels and energy consumption were calculated is discussed in Chapter 5
of the TSD.
DOE notes that, for both hugger ceiling fans and standard ceiling
fans, baseline ceiling fans in the February 2022 Preliminary Analysis
generally used more power than baseline fans in this NOPR analysis.
These revised values better reflect the multitude of choices
manufacturers have for meeting a higher efficiency level and are not
overly optimistic in assuming all CFM/W gains would be associated only
with decreasing energy consumption.
As noted in section 2.6.2.1 of the February 2022 Preliminary
Analysis TSD, DOE assumed two ELs associated with a transition to BLDC
motors. EL3 corresponded to the current ENERGY STAR levels and was
associated with BLDC motors with inefficient blades. EL4 corresponded
to BLDC motors with common blade materials. In the February 2022
preliminary analysis, the energy use at EL3 and EL4 was equivalent;
however, the inefficient blades were assumed to have less airflow,
resulting in a lower CFM/W.
While the February 2022 Preliminary Analysis generally assumed that
ENERGY STAR levels require BLDC motors, further investigation
demonstrated that many ceiling fans were capable of meeting ENERGY STAR
levels without transitioning to BLDC motors. Specifically, moving a
hugger ceiling fan further from the ceiling, while still being less
than 10 inches from the ceiling, could enable a manufacturer to meet
hugger ENERGY STAR levels without reducing power consumption.
To include an efficiency level associated with BLDC motors that is
unlikely to be met with certain AC fan models, DOE combined the two
BLDC efficiency levels from the February 2022 Preliminary Analysis into
one efficiency level in this NOPR analysis. The NOPR BLDC level is
higher than the ENERGY STAR level in the February 2022 Preliminary
Analysis, but lower than the max-tech level in the February 2022
Preliminary Analysis and is based on the minimum CFM/W values that
cannot be obtained with AC motors. Like the February 2022 Preliminary
Analysis, all blade designs and common blade materials currently on the
market for fans with BLDC motors will exceed the NOPR BLDC efficiency
level, many by a considerable margin. But the BLDC levels provide
sufficient flexibility for all blade designs and blade materials and
will permit hugger ceiling fans to have sufficient flexibility in terms
of distance between the fan blades and the ceiling.
In response to DOE's acknowledgment that many BLDC ceiling fans
will exceed the CFM/W of even the max-tech efficiency levels, the
Efficiency Advocates encouraged DOE to evaluate higher max-tech
efficiency levels,
[[Page 40954]]
consistent with the most efficient ceiling fans on the market.
(Efficiency Advocates, No. 25 at pp. 2-3) They stated that ceiling fans
currently available on the market more than double DOE's max-tech
efficiency level in the February 2022 Preliminary analysis, noting that
these models generally combine higher efficiency motors and more
aerodynamic blades. Id. Regarding the specific model the Efficiency
Advocates identified, DOE notes that linked manufacturer literature
cited by the Efficiency Advocates and the ENERGY STAR data cited by the
Efficiency Advocates report two different CFM/W values. Based on the
manufacturer literature for the basic model, the cited input power at
high-speed appears to actually be a weighted average value and not a
high-speed value.
DOE's review of the ceiling fan market indicates that for ceiling
fans using BLDC motors, the power usage is relatively constant, with
the key factor distinguishing between CFM/W being the amount of airflow
from a given fan at both low and high speed. In most settings, provided
the maximum airflow is sufficient to meet a consumer's needs, there is
not additional utility to providing more airflow beyond what a consumer
would want. Ceiling fan manufacturer balance fan aesthetics and airflow
in designing ceiling fans. DOE has not evaluated higher efficiency
levels with BLDC motors since those levels would limit minimum distance
that ceiling fan blades could be from the ceiling for hugger ceiling
fans (as described in section IV.A.3.a of this document), consumer
features (such as additional sensors, connectivity, or receivers) which
may decrease CFM/W by consuming additional power in standby mode (as
described in IV.B.1.a of this document), blade shape (which DOE has
screened out as a technology option due to the negative impacts on
consumer utility, as described in Chapter 4 of the TSD), and minimum
and maximum airflows (as described in Chapter 5 of the TSD). DOE has
provided examples of BLDC motor power usage and CFM/W ratings in
Chapter 5 of the TSD which demonstrate that BLDC power consumption is
approximately constant across all certified CFM/W values.
In addition to the technology-based efficiency levels described
previously, DOE observed that the BLDC technology option shows a
natural inclination for certain blade spans. Specifically, DOE observed
that for standard and hugger fans below 52'', fewer than 20 percent of
basic models included BLDC motors and an even smaller market share used
BLDC motors. However, for ceiling fans with blade spans greater than or
equal to 52'', there was a large increase in the share of basic models
using BLDC motors such at 60'', over 50 percent of basic models use
BLDC motors and at the largest blades spans, virtually all ceiling fans
use BLDC motors (See Chapter 5 of the NOPR TSD). This is because beyond
52'', manufacturers are typically designing and marketing products to
higher income consumers where the aesthetic appeals, smaller motor
sizes, and additional features associated with BLDC motors along with
the higher torque of BLDC motors creates a favorable market for BLDC
motors. As such, DOE has considered a step-function efficiency level
wherein ceiling fans that are less than or equal to 53'' in span use a
more efficient AC motor and ceiling fans that are greater than 53'' use
a BLDC motors.
Table IV.3--Standard and Hugger Ceiling Fan Efficiency Levels
------------------------------------------------------------------------
Efficiency level Description
------------------------------------------------------------------------
EL0....................................... Baseline.
EL1....................................... More Efficient AC Motor.
EL2....................................... More Efficient AC Motor.
EL3....................................... Market Based Step-Function.
<=53'' = More Efficient AC
Motors.
>53'' = BLDC Motors.
EL4....................................... BLDC Motor.
------------------------------------------------------------------------
Large-Diameter Ceiling Fans
As discussed previously, the CFEI metric takes into consideration
the performance of a given fan relative to the performance of a
reference fan. The reference fan assumes a certain airfoil,
transmission, motor, and controller efficiency. To meet a higher CFEI
value, some manufacturers may increase fan motor efficiency, while
others may increase their airfoil efficiency or transmission
efficiency. Further, these efficiencies are not necessarily independent
and can impact one another. For example, higher airfoil efficiency may
mean that a smaller motor can be used since more of the power input to
the fan blades is converted to airflow.
In the February 2022 Preliminary Analysis, DOE noted that it relied
on a combination of public data sources and aggregated confidential
data sources to evaluate the distribution of efficiencies available on
the market. DOE considered two efficiency levels in the February 2022
Preliminary Analysis: EL1, corresponding to a level that could still be
met with gear-driven IE3 motors, and EL2, corresponding to permanent
magnet direct-drive motors.
AMCA commented that ELs 1 and 2 in the February 2022 Preliminary
Analysis are too strict and that the results of a survey of its members
that manufacture LDCFs indicated that about 50 percent of LDCF products
would fail EL1 and 60 percent would fail EL2. They expressed concern
that implementing these ELs could damage the market. As a result, AMCA
requested that DOE reconsider its requirements for ELs 1 and 2. (AMCA,
No. 23 at p. 2) AMCA stated that, while EL1 in the February 2022
Preliminary Analysis was intended to represent a change from lower-
efficiency gearmotors to IE3 gearmotors, all AMCA members with gear-
driven ceiling fans already use IE3 motors. (AMCA, No. 23 at p. 2) In
relation to this, AMCA commented that the way the ELs were considered
in the February 2022 Preliminary Analysis TSD was erroneous. They
commented that the TSD wrongly assumed a CFEI100 value of 1.00 would be
met using an IE1 motor, but AMCA 208 specifies that a CFEI100 of 1.00
is based on an IE3 motor. AMCA's survey of its member companies and
their products indicated that no gear-driven HVLS ceiling fans use IE1
motors. AMCA stated that DOE's estimation that changing from an IE1
motor to an IE3 motor could reduce power consumption by 25 percent was
highly unlikely and not representative of the typical power savings
that could be achieved when switching from an IE1 motor to an IE3
motor. (AMCA, No. 23 at pp. 15-19) AMCA also commented that its survey
of its members that manufacture LDCFs indicated that 20 percent of
direct-drive LDCF models would fail EL1, even though EL1 is intended to
represent gear-driven fans with IE3 motors and EL2 is intended to
represent direct-drive fans. AMCA added that the apparent assumption in
the February 2022 Preliminary Analysis that switching from a gear-
driven to direct-driven setup improves efficiency is not always
correct. (AMCA, No. 23 at p. 2)
AMCA is correct that utilizing an IE1 motor as the assumed baseline
motor is a poor characterization of baseline LDCF efficiency. While it
is true that AMCA 208 assumes an IE3 motor in the reference fan and
that most manufacturers use an IE3 motor, the AMCA 208 calculations
also assume a perfectly-sized motor relative to the airfoil efficiency
and transmission efficiency of the reference fan. As noted in section
IV.C.2.a and demonstrated in data plots provided both in CA IOUs' (CA
IOU, No. 22 at p. 4) and AMCA's (AMCA, No. 9 at p. 16) public
[[Page 40955]]
comments, the least efficient LDCFs on the market tend to exceed the
energy conservation standards by a considerable margin. In this NOPR,
DOE has modified its baseline energy use analysis to reflect that with
an IE3 motor at baseline, manufacturers consistently exceed a CFEI100
of 1.00 and CFEI40 of 1.31.
DOE notes that manufacturer data show that EL1 represents an
efficiency level that is achievable with an IE3 motor. While AMCA's
comment states that 64.4 percent of gear-driven ceiling fans would fail
the February 2022 Preliminary Analysis EL1 level, that similarly means
35.6 percent of IE3 motors are capable of meeting EL1 levels.
Manufacturers did not identify unique characteristics about the gear-
driven ceiling fans that exceed EL1 levels from those that do not, and
AMCA comments suggest that both are using motors of similar
efficiencies.
As stated previously, many LDCFs are offered in a variety of blade
spans, often ranging from 8 feet to 24 feet, where the motor size used
for a given fan model is identical across several of the blade spans.
In interviews, manufacturers stated that LDCFs are typically not
optimized across every single blade span offered for sale to minimize
the number of parts. Rather, one motor and gearbox assembly will span
several blade spans. This ability to optimize ceiling fans for a given
blade span explains why some gear-driven ceiling fans can meet EL1
levels while others cannot. Since a third of gear-driven ceiling fans
in AMCA's database are capable of meeting EL1 levels, DOE has retained
its EL1 level in this NOPR but has recharacterized it as corresponding
to an IE3 motor with LDCF optimized for the given blade span. DOE has
modified its cost analysis to reflect that, while optimization of a fan
does not inherently have additional cost, there are production cost
impacts associated with having every blade span optimized, rather than
using the same motor-gearbox combination across a range of blade spans.
Regarding AMCA's comment that transitioning from a gear-driven fan
to a direct-drive fan does not inherently increase efficiency, this is
partially correct. While it is not impossible for a gear-driven ceiling
fan model to have a higher CFEI100 than a direct-drive fan, when all
other things are held equal, a direct-drive fan is not going to have
transmission losses. With no transmission losses, the highest CFEI
models on the market tend to be direct-drive models.
Like gear-driven ceiling fans, direct-drive ceiling fans have a
range of CFEI100 values depending on how well they are optimized for a
given application. AMCA commented that 54.1 percent of the direct-drive
fans in their database meet EL2 levels. Further, AMCA commented that
the average CFEI100 value for 20-foot and 24-foot ceiling fans is 1.44
and 1.41, respectively, both of which exceed EL2 levels. (AMCA, No. 23
at p. 5)
DOE notes that the percentage of models that would have to be
modified to meet a higher efficiency level is generally not indicative
of whether or not that efficiency level is economically justified.
Rather, economic justification is determined by analyzing the costs of
an amended standard relative to the cost savings of the more efficient
product. Further, the EL2 efficiency level is clearly technologically
feasible since 40 percent of models are already meeting DOE's max-tech
efficiency level.
Regarding the number of models that would have failed at the EL1
and EL2 levels evaluated in the February 2022 Preliminary Analysis, DOE
notes that stakeholders did not specify if the failure was on account
of not meeting CFEI100 values, not meeting CFEI40 values, or not
meeting some theoretical standby power limitation. As discussed
previously, DOE observed considerable difference in CFEI40 values
depending on the voltage manufacturers used to test their LDCFs. While
the test voltage has not changed, the August 2022 TP Final Rule
clarified the test voltage in response to stakeholder feedback that the
previous language was unclear. As such, some of the data stakeholders
are referencing as failing a given efficiency level may be based on
testing at the higher voltage configurations. Given that higher CFEI100
values tend to correlate with higher CFEI40 values, DOE only evaluated
higher CFEI100 efficiency levels and did not evaluate higher efficiency
standards at the CFEI40 value. DOE expects that the vast majority of
LDCFs exceed the current CFEI40 standards and those instances cited as
being close to the standard may have been tested at higher voltages.
This interpretation was supported by AMCA, who commented that the
average CFEI40 value for 20-foot and 24-foot fans was 2.19 and 2.31,
respectively, easily exceeding the current CFEI40 standards.
In DOE's energy use analysis for this NOPR, DOE relied on market
data to estimate the average CFEI40 values of fans at a given
efficiency level, rather than assuming LDCFs were minimally compliant
at the CFEI40 value.
AMCA commented that increasing the energy conservation standard
requirements for CFEI would have unintended and negative impacts on
both the ceiling fan industry and consumers. (AMCA, No. 23 at p. 1)
AMCA commented that a correction made to the input power calculation in
the AMCA 230-15 technical errata in 2021 would slightly increase the
calculated input power and therefore decrease the calculated CFEI. They
stated that, because this correction was made after the current energy
conservation standards were set, the current standard is more strict
than intended and that this should be considered when new energy
conservation standards are set. AMCA provided results from a study of
over 300 ceiling fan test reports showing that CFEI could decrease by
about 3 percent as a result of the correction. (AMCA, No. 23 at pp. 12-
13)
DOE notes that its test procedure includes the technical errata and
therefore manufacturers need to meet the current energy conservation
standards, namely, CFEI100 equal to 1.00 and CFEI40 equal to 1.31.
Given that some of the published data on which DOE's analysis is
derived may have been conducted in testing environments with differing
air densities, in this NOPR DOE has chosen to evaluate a more
conservative EL1 and EL2 by reducing the CFEI100 EL1 and EL2 levels by
0.03 relative to the February 2022 Preliminary Analysis values.
High-Speed Belt-Driven Ceiling Fans
As discussed previously, DOE relied on the October 2022 Fans and
Blowers NODA to evaluate efficiency levels for HSBD fans. Because the
CFEI metric is relative to a reference fan performance that accounts
for differences in airflow, DOE assumed the representative HSBD airflow
would remain constant at higher efficiency levels and calculated the
power consumption at each EL, maintaining the CFM/W values used in the
October 2022 Fans and Blowers NODA. DOE then calculated the CFEI value
based on the airflow and power consumption. See chapter 5 of the TSD
for additional details on this methodology.
c. Large-Diameter Ceiling Fan Standby Power
In the May 2021 RFI, DOE discussed that the CFEI metric does not
capture standby or off mode energy use and that DOE may need to develop
a separate standby mode metric for LDCFs. 86 FR 24538, 24544. In
section 2.6.2.3 of the February 2022 Preliminary Analysis TSD, DOE
noted that it had not identified a way to incorporate standby power
into the CFEI metric. Further,
[[Page 40956]]
DOE did not identify technology options that would reduce LDCF standby
power aside from removing energy saving controls and features. DOE did
not evaluate higher standby power efficiency levels in the February
2022 Preliminary Analysis because it had not identified technology
options for reducing standby power without impacting product utility
through removal of controller features.
In the February 2022 Preliminary Analysis, DOE used an average
standby power of 7 W, consistent with the January 2017 ECS Final Rule.
DOE stated that it was considering establishing a standby power limit
at 13 W, the maximum standby power observed in the market. DOE also
stated that it was considering a credit-based approach where fans that
are more efficient in active mode would be permitted to utilize more
standby power in standby operation.
In section 2.6.2.3 of the February 2022 Preliminary Analysis TSD,
DOE requested comment on technologies available to reduce standby power
without reducing consumer utility, the maximum standby power on the
market, potential future technologies that could increase standby
power, and any possible active mode-based credit for standby power
consumption.
Regarding specific technologies that increase or decrease standby
power, AMCA stated that the standby power consumed by a ceiling fan can
be affected by a wall controller powered from the variable frequency
drive (``VFD'') or separate wall plugin; a display used on the wall
controller; a display used on the VFD; cooling fans on the VFD;
communications devices; sensors; and an electronic filter. (AMCA, No.
23 at p. 5) AMCA added that increased drive efficiency paired with
larger heat sink to eliminate drive cooling fans, redesign/replacement
of the VFD to have cooling fans turn off under low loads, simplified
wall controllers with no display, elimination of communication devices,
and elimination of sensors could all reduce LDCF standby power. (AMCA,
No. 23 at p. 6) AMCA commented that sensors, wireless devices, network
communications, multi-fan/multiproduct controllers, grid-connected
demand-management controls, air disinfection, and lighting are
potential technologies that could be implemented into LDCFs in the
future which would further increase standby power. (AMCA, No. 23 at p.
8)
Regarding the current maximum standby power on the market, AMCA
provided data from their survey of member LDCF manufacturers showing
that the highest standby power consumption in its survey was 19 W for a
direct-drive fan and 12 W for a gear-driven fan. The average standby
power consumption was 9.8 W for a direct-drive fan and 6.8 W for a
gear-driven fan. (AMCA, No. 23 at p. 6) AMCA added that their analysis
of the LDCF models manufactured by member companies yielded an average
standby power of 8.8 W, rather than the 7 W that was previously
determined from a smaller dataset. Therefore, AMCA recommended that DOE
adjust the average standby power value to 8.8 W for LDCFs. (AMCA, No.
23 at p. 11) Additionally, AMCA stated that the results of the LDCF
model analysis indicated that standby power accounts for 1.1 percent to
2.5 percent of the total power consumed by LDCFs and commented that
enforcing strict standby power limits would place an unnecessary burden
on manufacturers. (AMCA, No. 23 at p. 11)
AMCA stated that about half the models currently on the market
would fail to meet a standard based only on an average standby power
limit. (AMCA, No. 23 at p. 7) For the 13 W standby power limit cited in
the February 2022 Preliminary Analysis, AMCA estimated that 18.1
percent of models would fail. (AMCA, No. 23 at p. 11) AMCA recommended
that DOE propose a less aggressive standby power requirement than what
was proposed in the February 2022 Preliminary Analysis, and revise its
analysis to produce new average and maximum standby power data
assumptions based on AMCA's LDCF manufacturer survey results.
AMCA supported DOE's suggestion for implementing a credit-based
system for regulating standby power, where LDCFs that achieve higher
active mode efficiencies are allowed more standby power. AMCA added
that this active-mode approach would allow manufacturers more
flexibility in LDCF design. (AMCA, No. 23 at p. 9) However, AMCA also
stated that the requirements proposed by DOE in the February 2022
Preliminary Analysis for this credit-based standby power approach were
too strict. AMCA supported this comment by providing data from their
survey of LDCF member companies that showed failure rates of 50.6
percent at EL1 and 60.5 percent at EL2, assuming a 7 W average was
used. Failure rates were 48 percent at EL1 and 59 percent at EL2 when a
standby power limit of 13 W was used. (AMCA, No. 23 at pp. 3, 9-10)
AMCA also recommended that DOE define the standby power allowance based
on the CFEI rating of a fan by starting at a standby power allowance of
15 W for a CFEI of 1.00 and increasing the standby power allowance by
1.0 W for every 0.02 increase in CFEI. (AMCA, No. 23 at pp. 10-11)
ALA commented that DOE should not set a separate standby power
standard for small-diameter fans. (ALA, No. 26 at p. 12)
42 U.S.C. 6295(gg)(2) requires DOE to incorporate standby power
into its existing test procedures, if technically feasible. Section 3.6
of appendix U specifies the current test procedure for measuring the
standby power consumption of LDCF. In the August 2022 TP Final Rule,
DOE clarified that testing shall be conducted with either the default
controller or, if multiple controllers are offered, the minimally
functional controller and that standby power consumption is not
required for the purpose of representations or certification until
compliance is required with an energy conservation standard. 87 FR
50396, 50408. To the extent voluntary representations are made in
writing or advertisements, appendix U is required, regardless of
whether compliance with an energy conservation standard is applied. See
42 U.S.C. 6293(c).
Section 42 U.S.C. 6295(gg)(3) requires DOE to incorporate standby
power into a single amended or new standard, if feasible. If not
feasible, DOE is required to prescribe a separate standard for standby
mode and off mode energy consumption, if justified under 42 U.S.C.
6295(o).
Regarding ALA's comment on standby power for small-diameter ceiling
fans, DOE notes that the existing CFM/W metric incorporates standby
power and therefore a separate evaluation of a standby power standard
for small-diameter ceiling fans is not needed.
One significant challenge in evaluating potential energy savings
associated with standby power for LDCF fans is that while appendix U
clarifies testing with the default controller or minimally functional
controller, there is no industry standardized default controller.
Depending on the intended application, a fan at default may include
other devices, such as a larger controller display or network
connectivity. Some of these sensors and devices may reduce energy
consumption overall. AMCA identified additional controller technologies
associated with connectivity with the greater grid and HVAC system that
would be appealing energy saving options in the future, but may not be
sold with the default controller today. Further, the only technologies
identified by AMCA for reducing standby power that do not explicitly
change consumer utility
[[Page 40957]]
include elimination or reduction of cooling fans in the VFD. While
these technologies could in theory be an option to reduce standby power
consumption, the easier path for manufacturers to meet a standby power
standard is by offering the product with fewer sensors and
communication devices. Therefore, imposing a standby standard could
increase overall energy consumption by causing manufacturers to forego
these devices with higher energy-saving capacity.
DOE notes that many of the drive specific technologies identified
by AMCA as potentially reducing standby power would also increase or
decrease controller losses in active mode. As noted, controller
efficiency is incorporated into the CFEI metric but assumed to be 100
percent for the reference fan. As manufacturers begin adding controller
losses, including drive cooling fans, the measured active mode
efficiency would decrease. Therefore, there is an existing incentive
for manufacturers to reduce drive losses, absent a separate standby
power standard.
Regarding AMCA's comment about a standby power efficiency standard
that credits active-mode performance being a possible logical approach,
DOE notes that standby power for LDCFs corresponds with the complexity
of the default controller and not with active mode performance. In
other words, increasing the CFEI of a given fan model would not be
correlated with higher standby power. As such, all the existing
concerns with reduced default controller features would apply with an
active mode, credit-based system.
DOE notes that the most cost-effective means for manufacturers to
reduce their standby power would be for manufacturers to remove
display, network connectivity, and sensors from their default
controller. Removing any or all these features would reduce standby
power consumption and lower controller costs. Therefore, there would be
no incremental costs associated with reducing standby power.
Simple controllers without displays, network connectivity, or
sensors exist today. Because there are additional manufacturing costs
associated with more advanced controllers, simple controllers are
typically the default controllers for fans targeting the lowest price
point. LDCFs targeting higher price points tend to offer controllers
with additional features to help justify their higher selling price.
LDCF manufacturers then offer several upgradable controllers with
increasing functionality, and consumers select the controller that has
their desired functionality.
As noted, Appendix U specifies testing standby power with the
default controller or minimally functional controller. Under a maximum
standby-power energy conservation standard, the most cost-effective way
for manufacturers to meet such standards would be to offer a new
minimally functional controller with fewer additional features. A
standby-power energy conservation standard would not impact the standby
power consumption of any of the upgradable controllers that consumers
are purchasing, only the minimally functional controller. Energy
savings for a standby power energy conservation standard would only be
achievable if consumers opted for a controller with less functionality.
As noted, consumers currently have the option to purchase fans with
controllers that offer less functionality, and typically at lower costs
than fans with more advanced controls. As far as DOE is aware,
information on consumer behavior regarding LDCF controllers is not
available, but DOE understands that consumers are already making the
decision to purchase LDCFs and controllers with additional
functionality, despite these products adding costs.
Therefore, DOE expects that any new standard for standby power for
LDCFs would result in manufacturers offering new minimally functional
controllers with reduced utility. These new controllers would likely
not result in energy savings, however, since consumers would continue
to select controllers with greater functionality when they purchase a
LDCF, as they do in the current market.
As such, in accordance with DOE's requirements at 42 U.S.C.
6295(gg)(3), DOE has tentatively determined not to analyze a separate
standard for standby mode and off mode energy consumption, since such a
standard would not lead to energy savings.
DOE requests comment and data regarding its tentative determination
that energy conservation standards for LDCF standby power would be met
by removing consumer features from the default controller, and that
this would likely not r
[…truncated; see source link]This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.